ML20071H625

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Affidavit of Kv Miller Re Reed Contention 6 on Protective Actions Against Radioiodines.State of Mo Will Not Administer Potassium Iodine to General Public in Event of Accident,But Drug Will Be Available to State Emergency Workers
ML20071H625
Person / Time
Site: Callaway Ameren icon.png
Issue date: 05/11/1983
From: Keith Miller
MISSOURI, STATE OF, UNION ELECTRIC CO.
To:
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ML20071H409 List: ... further results
References
ISSUANCES-OL, NUDOCS 8305250424
Download: ML20071H625 (7)
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7 z BEFORE THE ATOMIC SAFETY AND LICENSI BOARD X 'JP_L/

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j UNION ELECTRIC COMPANY ) Docket No. STN 50-483 OL

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(Callaway Plant, Unit 1) )

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q AFFIDAVIT OF'KENNETH V. MILLER ON REED CONTENTION 6 (PROTECTIVE ACTIONS AGAINST RADIOIODINES)

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State of Missouri )

s KENNETH V. MILLER, being duly sworn, deposes and says as follows: -

' 1. I am the Administratior of the Missouri Bureau of

' Radiological Health, which is part of the Division of Health w

y within the Missouri Department of Social Services. My business r

address-is P..O. Box 570, Jefferson City, Missouri 65102.

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In the-event of an accident at the Callaway Plant, it would be the r

responsibility'of the Bureau of Radiological Health to direct operations specifically related to nuclear radiation affecting-y.

T~ the. environment:outside the.Callaway Plant exclusion area.

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4 This responsibility includes nuclear radiation monitoring, determining the need for implementing protective actions, advising oth'er agencies regarding actions that should be aken, determining individual exposure levels, and determining the need for decontamination. One of the policy questions which the State of Missouri has had to resolve in connection with the occurrence of an-accident at the Callaway Plant, and which falls within the area of expertise of the Bureau of Radiological Health, is the extent to which potassium iodide or "KI" will be distributed to Missouri residents in the event of an accident at the Callaway Plant.

2. This statement describes Missouri's policy on the distribution of KI. I make this affidavit in response to Reed Contentions 6 (Protective Actions Against Radioiodines). I have personal knowledge of the matters stated herein and believe them to be'true and correct. -A summary of my profes-sional qualifications and experience is attached hereto as Exhibit "A".
3. The State of Missouri has decided not to administer KI to the general public in the event of an accident.at the Callaway. Plant. However, the state will make KI available to specified' personnel, including emergency workers,. considered to be at greater risk. This policy is based on available federal guidance and our understanding of the advantages and disadvan-

.tages~of KI distribution.

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4. The purpose of administering KI would be for use as a thyroid-blocking agent in a radiological emergency. When an individual takes KI, radioiodine which might be released from the power plant and inhaled or ingested by the individual is prevented from accumulating in the thyroid.
5. A number of federal agencies, including the Food and Drug Administration ("FDA"), the Federal Emergency Management Agency (" FEMA"), the' Nuclear Regulatory Commission ("NRC") and the Environm. ental Protection Agency (" EPA") have an interest in the question whether, in the event of an accident at a nuclear power plant, KI should be administered to the general public or to specific members of the public located within the plant's

" ten mile plume er.posure pathway emergency planning zone

("EPZ").

S. In June, 1982, FDA announced in the Federal Register the availability of its final recommendations concerning the administration of KI to the public in a radiation emergency.

FDA concludes in its final KI recommendations that the risks from the-short-term use of relatively low doses of KI for thyroid blocking in a radiation emergency are outweighed by the risks of radiciodine-induced thyroid nodules or cancer at a projected dose to the thyroid gland of 25 rem. H)A recommends that KI in doses of 130 milligrams ("mg") per day for adults and children above 1 year of age and 65 mg per day for children  !

l below 1 year of age be considered for thyroid blocking in radiation emergencies for those persons who are likely to

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=1 receive a projected radiation dose of 25 rem or greater to the e thryoid gland from radioiodines released into the environment.

See 47 Fed. Reg. 28158 (June 29, 1982).

7. FEMA has endorsed FDA's guidance on the administration of KI. See December 1, 1982 FEMA Interim Policy Guidance on Potassium Iodide.
8. Both the FEMA and NRC staffs have recommended that nuclear power plant licensees as well as state and local governments provide radioprotective drugs for thyroid protec-tion in the event of a nuclear power plant accident for (i) emergency workers and other individuals remaining or arriving onsite during the emergency; (ii) emergency workers within the plume exposure EPZ; and (iii) institutionalized persons within the plume exposure EPZ whose immediate evacuation may be infeasible or very difficult. See Testimony of Brian K.

Grimes, Director, Division of Emergency Preparedness, U.S.

Nuclear Regulatory Commission, Before the Subcommittee on Oversight and Investigations, Committee on Interior and Insular Affairs, United States House of Representatives, dated March 5, 1982.

9. To date, neither the NRC nor FEMA has recommended the administration of KI to the general public located within the 10 mile plume exposure pathway EPZ.
10. EPA is primarily responsible for the establishment of Protective Action Guides ("PAGs") for radiological emergency respcnse planning, in coordination with appropriate federal m

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< agencies.. EPA.also prepares guidance for state and local l-h governments'on. implementing PAGs, including recommendations on protective actions which can be taken to mitigate the potential

radiation dose to the. population. In its Manual-for Protective etion Guides and Protective Actions for Nuclear Incidents, EPA-520/1-75-001, Sept., 1975 (Revised June 1980),-at pages 1.41-1.42, EPA recommends the use of KI as a prophylaxis for emergency workers located in areas posuibly involving radicio-dine contamination, in accordance with state health laws and under the direction of state medical officials. With respect to the efficacy of administering KI to the general population, EPA notes .that this option is still under consideration by
government agencies but should not be construed to be the policy of EPA at this time.
11. Consistent with available federal guidance, the Missouri Division of Health will make KI available to state emergency workers and will store KI for distribution to the 1 State Mental Hospital in Fulton, Missouri in the event that institution elects to use it. KI will also be distributed to the. county courts, or emergency units designated by the courts,.

in those areas which might fall within the plume exposure pathway EPZ. In the event of an emergency the Division of Health will. provide current.information~regarding projected exposures and will offer guidance on the use of KI. Decisions

'on whether to administer KI to local emergency workers or to staff and patients at'the State Hospital will'be made by local'

.J authorities and hospital officials, respectively. They will also be responsible for administering the drug if the decision is made to use it. KI will not be distributed to the general public.

H _ d V. 99t3A-Kenneth V. Miller Subscribej and sworn to before me this \\ D day of May, 1983.

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Notary Publi (

My Commission expires % a cc.w. 2.k,\9 D .

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s EXHIBIT A PROFESSIONAL -QUALIFICATIONS STATEMENT FOR KENNETH V. MILLER .

Education: B.S. Degree in Physics from Western Illinois' University One academic year of graduate study in radiological health, University of Michigan

- Experience: Twenty-two years with Missouri's radiological health program.

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