LIC-99-0082, Comment Opposing Proposed Rule 10CFR50 Re Rev to NRC Emergency Preparedness Regulations on Use of Potassium Iodide in Emergency Plans

Comment Opposing Proposed Rule 10CFR50 Re Rev to NRC Emergency Preparedness Regulations on Use of Potassium Iodide in Emergency Plans

ML20216F594
Person / Time
Site:	Fort Calhoun
Issue date:	09/10/1999
From:	Gambhir S OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-64FR31737, RULE-PR-50 64FR31737-00058, LIC-99-0082, NUDOCS 9909220121
Download: ML20216F594 (2)

Text

i

• 58

.. ~

e DOCKET NUMBER DOCFE i E PROPOSED RULE N 60 N'

• " ~ "**

wsous a sueetuns (WRSt737) \

On4 MW 682W V) SEP 20 KC :25 i September 10,1999 C-l LIC-99-0082 d AD. ,

Secretary of the Commission j Attention: Rulemaking and Adjudications Staff i U. S. Nuclear Regulatory Commission )

Washington, D.C. 20555-0001

References:

1. Docket No. 50-285

2. Federal Register Volume 64 dated June 17,1999 (64 FR 317Pi

Subject:

Comments on Proposed Revision to NRC Emergency Preparedness )

Regulations on Use of Potassium lodide in Emergency Plans

)

{

In Reference 2, the NRC proposes to amend its emergency planning regulations governing domestic licensing ofproduction and utilization facilities. The current regulations would be amended to require that " consideration" be given to including potassium iodide (KI), as a protective measure for the general public that would supplement sheltering and evacuation.

The Omaha Public Power District (OPPD) does not support the proposed revision. It is OPPD's position that the proposed rule will not provide a substantial increase in the protection of the public health and safety. OPPD believes that the proposed rule requiring the states to give

" consideration" to the use of KI is inappropriate. The proposed rule fails to provide clear and concise guidance on the administration of K1 to the general public and puts the burden of assessment on the states, which have fewer technical resources and expertise than the NRC, EPA, and FDA.

The proposed rule does not define " consideration," which is likely to result in various interpretations. One state might interpret " consideration" to mean that Emergency Management and Radiation Protection staff should meet and document their decision. Another state might interpret " consideration" to involve a formal notice and comment process with public hearings.

The wording of the proposed rule leaves the meaning of" consideration" to be decided by the courts, post-incident, and does not constitute effective guidance.

In addition, OPPD does not support the stockpiling of K1 for distribution to the general public in the event of a nuclear power plant accident for the following reasons:

9909220121 990910 PDR PR 50 64FR31737 PDR 4171 Employment uth Equal opputunity

e

,; U. S. Nuclear Regulatory Commission

= LIC-99-0082 Page 2

. Evacuation of potentially affected areas within the 10-mile Emergency Planning Zone is the preferred protective action to protect the health and safety of the general public. Distribution of KI to the general public could inhibit orderly evacuation and divert limited local resources during the early stages of an incident.

The distribution of KI to the general public could impart a false sense of security regarding the prevention of severe health effects resulting from radiation exposure. KI is not effective unless administered prior to or shortly following inhalation or ingestion of radiciodines.

Also, KI does not limit dose due to whole body exposure from other radioisotopes potentially present in a radiological release from a nuclear power plant incident.

. KI is contraindicated for some groups of people.

. Emergency plans will not be able to address legal liabilities associated with the drug's administration. State and local governments will be unable to control dosage or provide medical supervision for the administration to schoolchildren. ,

e International experience with the drug is not necessarily useful in assessing the l appropriateness of the protective measure in the United States because of the differences m I reactor designs and emergency preparedness capabilities.

e l

The cost associated with stockpiling KI for the general public out-weigh the benefits. '

The NRC, in conjunction with the Environmental Protection Agency (EPA) and the Food and j Drug Administration (FDA) has the responsibility to develop and promulgate guidance to state and local governments on the appropriateness of various protective measures. These federal agencies have developed clear and concise guidance for when evacuation, sheltering, and j ingestion protective actions are warranted. States maintain the authority to adopt stricter guidelines than those of the federal govemment.

Please contact me if you have any questions.

Sincerely, i l

kh S. K.' Gambhir 1

Division Manager Nuclear Operations Attachment SKG/mle c: E. W. Merschoff, NRC Regional Administrator, Region IV L. R. Whadon, NRC Project Manager W. C. Walker, NRC Senior Resident Inspector Document Control Desk Winston & Strawn L