ML20024F212
| ML20024F212 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/24/1983 |
| From: | Rohrer D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20024F213 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8309090065 | |
| Download: ML20024F212 (7) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of UNION ELECTRIC COMPANY Docket Nos. STN 50-483 OL (Callaway Plant, Unit 1)
NRC STAFF TESTIMONY OF DAVID M. R0HRER REGARDING EMERGENCY PLANNING (CONTENTIONS 6 and 16)
Q.1.
Please state your name and occupation.
A.1.
My name is David M. Rohrer.
I am employed by the U. S. Nuclear Regulatory Commission as an Emergency Preparedness Specialist in the Emergency Preparedness Branch, Division of Emergency Preparedness and Engineering Response, Office of Inspection and Jnforcement.
Q.2.
Please describe the nature of the responsibilities you have had with respect to nuclear power plant emergency preparedness.
A.2.
Since May 1980, I have had responsibility for the review and evaluation of radiological emergency response plans submitted by nuclear power plant license applicants and licensees to assure that the proposed plans meet the regulatory requirements and guidance o' the Commission.
I also function as a Team Leader and Team Member an Emergency Preparedness Implementation Appraisal Teams engaged in the onsite inspections of the implementation phase of licensee's emer-gency preparedness programs.
I observe nuclear power plant emergency 8309090065 830824 PDR ADOCK 05000483 PDR pSol
- drills and exercises, including those involving State and local response agencies and participate in inter-agency critiques of emergency planning.
Q.3.
Have you prepared a statement of professional qualifications?
A.3.
Yes. A copy is attached to this testimony.
l Q.4.
What is the purpose of this testimony?
A.4.
The purpose of this testimony is to respond to those portions of Contentions 6 and 16 dealing with the flRC staff position regarding the distribution of potassium iodide (KI) for use by the general public as a prophylactic drug for thyroidal blocking.
Q.5.
What is the position of the NRC with regard to the distribution of potassium iodide (KI) to members of the general public living within 4
ten miles of a nuclear facility?
A.S.
To date the NRC has found no compelling reason to recommend the distribution of KI to the general public located within the 10 mile plumeex-posureEmergencyPlanningZone(EPZ). The basis for this position is the following:
- 1) Staff studies conducted by both the FDA and NRC indicate that the fatal carcinogenic risk is greater from the whole body dose than from the thyroid dose using the airborne plume from various accidents in WASH-1400, " Reactor Safety Study". These studies are based on the analysis presented in NUREG/CR-1433, "Examina-tionoftheUseofPotassiumIodide(KI)asanEmergency
Protection Measure for Nuclear Reactor Accidents," October 1980 and indicated that for a ratio of 20 to 1 thyroid to whole body dose, the resulting risk of cancer death is three times greater for the whole body dose. This difference in risk is a result of the low percentage of deaths for thyroid cancer as compared to a higher percentage of deaths for many other types of cancer.
This makes the value of administering KI to the general public questionable as other protective measures (e.g., evacuation or shelter) would be instituted based on the more critical effects, which would also reduce the thyroid dose.
In addition, the analysis in NUREG/CR-1433 indicates that while the absolute cost of stockpiling KI is not high, the national distribution of KI for thyroid blocking of the general public would be ques-tionable from a cost / benefit standpoint even assuming adminstra-tion would be 100% effective.
- 2) KI administration may give the general public a false belief that they are protected from the total radiation effects of an airborne release when only their thyroid is protected and the critical dose may be from external radiation or from inhalation of particulate matter rather than from uptake of inhaled radioiodine.
- 3) The NRC staff is continuing its studies on the abundance and the chemical and physical forms that radiciodine might take in a release resulting from various nuclear power plant accident scenarios. As discussed in NUREG-0772, " Technical Bases for Estimating Fission Product Behavior During LWR Accidents", the
4_
most probable form for the radiciodine release during a light water reactor accident may be cesium iodide, a non-volatile particulate; however, a variety of chemical forms are possible.
Thus, the radioiodine available for release in the more con-servative accident scenarios may be significantly less than now projected.
For the more probable accident scenarios the reduction in the radioiodine availability could be even larger.
- 4) The NRC staff is continuing studies on the use of other expedient measures (e.g., use of a dust respirator) rather than thyroid blocking to protect the general public. A report prepared by the Harvard School of Public Health, NUREG/CR-2272, " Expedient Methods of Respiratory Protection," describing this work was published in November 1981. The work shows some promise for such alternative means of reducing the inhalation dose from an airborne release for all particulates and would be equally effective as KI against radiciodines in a particulate form.
- 5) The problems of finding an effective means of distributing KI so that it is available to the general public in a timely fashion continues to be a problem.
If the material is stock-1 piled at the regional, State or even at the local level, the ability to distribute and administer the KI to the public before the arrival of the plume appears to be more difficult, and may require more time than to evacuate them from its path.
Adminstration of KI more than four hours after the exposure to radiciodine will result in reducing its effectiveness from 95%,
just prior to exposure to the plume, to less than 50% effective
. in preventirig thyroid uptake.
If, on the other hand, the XI is predistributed to each household, control of when and how it is used is not assured. The NRC has requested FEMA to study the logistical problems of distribution of both KI and of simple respiratory protection devices.
Q.6.
Is this position consistent with that of other Federal agencies?
A.6.
Yes.
Q.7.
Does NRC require that special compensatory measures be taken if KI is not distr,ibuted to members of the general public?
A.7.
No.
Q.8.
Are you aware of the postion of the State of Missouri with regard to the distribution of KI acceptable to the NRC?
A.8.
Yes.
s Q.9.
What is that position?
A.9.
The position of the State of Missouri is that it will not administer KI to the general public.
Q.10. Is that position acceptable to the NRC?
A.10. Yes. See comments in response to Q.5., above.
t i
DAVID M. R0HRER OFFICE OF INSPECTION AND ENFORCEMENT STATEt1ENT OF PROFESSIONAL QUALIFICATIONS From May 1980 to the present, I have been employed as an Emergency Preparedness Analyst in the Emergency Preparedness Branch (EPB), Division of Emergency Pre-paredness and Engineering Response, Office of Inspection and Enforcement, U.S.
Nuclear Regulatory Commission.
I have the responsibility for the review and evaluation of radiological emergency plans submitted by nuclear power plant license applicants and licensees to assure that proposed plans meet the regu-latory requirements and guidance of the Commission.
I also function as a Team Leader and Team Member on Emergency Preparedness Implementation Appraisal Teams engaged in the onsite inspection of the implementation phase of licensee emer-gency programs.
I observe nuclear power plant emergency drills and exercises involving State and local government response agencies and participate in interagency critiques. As a senior member of the EPB Staff, I routinely act as the NRC representative at numerous meetings with licensees and applicants; State and local emergency planning groups; and public meetings with other Federal and bdustry groups.
From September 1977 to May 1980, I was employed as a Health Physicist and Senior Project flanager with the High-level and Transuranic Waste Branch (HLTWB) of the Division of Waste Management, Office of Nuclear Material Safety and Safeguards, USNRC.
In that capacity, I served as the lead staff technical expert for the development of the technical requirements for the performance of waste forms and packaging for the disposal of high-level wastes in deep geologic repositories (NRC proposed regulation 10 CFR Part 60).
From July 1973 to September 1977, I was employed as a Staff 11 ember in the Special Studies Section of the Radioactive Waste llanagement Group at the Los Alamos Scientific Laboratory (LASL). LASL is operated by the University of C6lifornia for the U.S. Departnent of Energy. While at LASL I was assigned to a number of Health Physics related programs dealing with advanced treatment and disposal technologies for radioactive wastes, especially those contaminated with transuranic radionuclides.
I also served as a technical expert and con-tributing author to both: 1) the flRC S-3 Task Force on the Environmental Impacts of the Fuel Reprocessing and Radioactive Waste Management Positions of the Nuclear Fuel Cycle (NUREG-0116 and 0216); and 2) the DOE Generic Environ-mental Impact Statement Task Force for the flanagement of Commercial Radioactive Wastes (DOE /E15-0046, 00E/ET-0028 and 0029).
From November 1972 to fiay 1973, I was employed as an Environmental Control Analyst with the Newport News Shipbuilding and Dry Dock Company before accepting my position at LASL.
I received a Bachelor of Science degree in Physics in 1971 and a 11 asters of Science degree in Environmental Engineering in 1972 from the Florida Institute of Technology (FIT). Subsequent to my graduation, I was a member of the Adjunct Facility at FIT, teaching a masters level course in Health Physics before accepting a position with !!cwport flews Shipbuilding and Dry Dock Company.
2-I am a full meraber of the Health Physics Society (both National and Local Chapters), the American Association for the Advancement of Science, and have been a member of the Materials Research Society and the American Ceramic Society (Nuclear Division).
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