ML18106A873
| ML18106A873 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 09/15/1998 |
| From: | Dawn Powell Public Service Enterprise Group |
| To: | Meyer D NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-63FR38865, RTR-NUREG-1633 63FR38865-00006, 63FR38865-6, LR-N980448, NUDOCS 9809220298 | |
| Download: ML18106A873 (3) | |
Text
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,//ff Pub,lc Servi~ Eleo;trti;; and Oas Company P.O. Box :.136 Haneacks Rtir!gP., New Jersey OS038-0236 Nucfear B1.1sine;a Unit I
I Mr: David L. Meyer Chjef, Rules Review and Directives Branch, U.S. Nuclear Regulato,.Y Commission Office of Administration Washington, DC 20555 SEPt 5 1999*
LR-N980448 COMMENTS ON NRC DRAFT NUREG-1633 SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50*272, 50*31-1 AND 50*364 D~ar Mr. Meyer:
Public Service*Electric & Gas Company (PSE&G) submits the following in response to the notice requesting comments on the draft of NUREG-1633 "Assessment of the Use of Potassium Iodide (Kl) As a Protective Action Curing Severe Reactor Accidents".
The draft NU REG provides a technical assessment on the potential impact of the release of radioiodines during a severe reactor accident and the effect of the use of Kl to reduce the effects of the radioiodines on the impacted population. Ae an assessment. we be!iave the NUREG should provide a balanced discussion on the benefits and risks of the use of Kl.
We recommend reversing the sequence of the first two bullets in the °KI Benefits and Challenges" section to put more emphasis on evacuation as the most appropriate and effective protective action. The existing emergency plans at commercial nuclear power plants and the impacted states provide adequate protection for tne publlc by implementing timely evacuation of the public and quarantine of contaminated food and drink.
The NUREG should provide additional discussion on the significant experience in the United States of successfully Implementing pubfic evacuations, as is regularly demonatrated in ths response to the threat of hurricanes. Most of the examples cited in the draft NUREG are related to Kl distribution in Europe where international boundaries can impact the implementation*of protective actions requiring planned evacuation of members of the public. The United States does not have these boundary limitations.
The pawc-r is m }OUr h.mds.
9809220298 980915 PDR NUREG 1633 C PDR O:>*ttOO :u:v Gf!J'
FRf;M PSE&G RESTART ENGINEERING e Document Control Desk I.'
LR-:N980448 2
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Th~ benefits of the use of Kl are discussed in the draft NUREG without a balanced
~iseussion of the risks of the use of Kl. Kl has been shewn to be effective in reducing
/ttiyfoid dose when taken just prior to uptake of radioiodines. This protective action is appropriate for emergency workers entering areas of potential or actual airborne rad~olodlne contamination. Procedures issued.by the states contain strict controls for issuing Kl to emergency workers. These same controls would not be practical if Kl is pre!distrfbuted for publie use. State plans req*uire precautionary evacuation of schools at a Site Area Emergency. ThiS predudes the need for issuing Kl for children. Many states also prohibit issuing any medication to school children without parental pennission. While these issues are presented in the draft NU REG, the negatives of precfistribution of Kl are net described as clearly as the potential benefits of use of Kl.
Stockpiling and pradistribution of Kl would more likely lead to use when it is not needed
- or delays ip impl~ntation of other planned protective actions. As stated in the draft NU REG, Kl is medically inadVisable fer various groups of people. For these reasons the use of Kl for public consumption can increase risks more than the potential benefits gained. PSE&G recommends the NRC reconsider the proposed rulemaking petition for stockpiling and use of Kl for the general public.
In SECY~98-061, the NRC staff addressed their suppcrt of evacuation and sheltering as the primary protedive actions. The discussion contained within SECY-98-061 should be included in the draft NUREG.
lf"you have any questions or require additional informationj please contact Ms. Donna Miller at (609) 339-1757.
Sincerely, JJ,£.~
D.R. Powell Olrectcr-Ucensing/Regulation and Fuels
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Document Control Desk LR-N9B0149 3
C Mr. H. J_ Miller, Administr.-itor - Region I
- u. S. Nuclear Regulatory Commission
.475 Allendale Road King of Prussia1 PA 19406 Mr. P. Milano, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Fllnt North Mail Stop 14E21 11555 Rockville Pike Rockville, MD 20852 Mr.. R. Ennis, Licensing Project Manager
- Hope Creek U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 14E21 11555 Rockville Pike Roekville, MD 20852 Mr. S. Morris (X24)
USNRC Senior Resident Inspector - Salem Mr. s. Pindale (X24)
USNRC Senior Resident Inspector - Hope Creek Mr. K Tosch, Manager IV, Bureau tJf Nuclear Engineering PO Bax41&
Trenton, NJ. 08625