ML20080C714
| ML20080C714 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/24/1983 |
| From: | Keith Miller MISSOURI, STATE OF |
| To: | |
| Shared Package | |
| ML20080C696 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8308290187 | |
| Download: ML20080C714 (11) | |
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EAACM UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
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UNION ELECTRIC COMPANY ) Docket No. STN 50-483 OL
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(Callaway Plant, Unit 1) )
TESTIMONY OF MISSOURI BUREAU OF RADIOLOGICAL HEALTH BY KENNETH V. MILLER IN RESPONSE TO REED CONTENTION 6 (PROTECTIVE ACTIONS AGAINST RADIOIODINES) l 8308290187 830824
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1 Q.1 Please state your name.
2 A.1 Kenneth V. Miller.
3 Q.2 Mr. Miller, by whom are you employed?
4 A.2 I am the Administrator of the Missouri Bureau of 5 Radiological Health, which is part of the Division of Health 6 within the Missouri Department of Social Services. My business 7 address is P.O. Box 570, Jefferson City, Missouri 65102.
8 Q.3 In the event of an accident at the Callaway Plant, 9 what would be the role of the Bureau of Radiological Health?
10 A.3 It would be the responsibility of the Bureau of 11 Radiological Health to direct operations specifically related 12 to nuclear radiation affecting the environment outside the 13 Callaway Plant exclusion area. This responsibility includes 14 nuclear radiation monitoring, determining the need for imple-15 menting protective actions, advising other agencies regarding 16 actions that should be taken, determining individual exposure 17 levels, and determining the need for decontamination.
18 Q.4 Mr. Miller, please summarize your professional quali-19 fications.
20 A.4 I have a Bachelor of Science degree in Physics from 21 Western Illinois University, and completed one academic year of 22 graduate study in radiological health at the University of 23 Michigan. My experience includes twenty-three years with the 24 State of Missouri's radiological health program.
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1 Q.5 What is the purpose of your testimony?
2 A.5 The purpose of my testimony is to respond to Mr.
3 Reed's challenge, in Contention 6, to the State's policy on the 4 distribution of potassium iodide or "KI" to the population 5 within the plume exposure pathway emergency planning zone 6 ("EPZ") for the Callaway Plant. That policy question falls 7 within the area of expertise of the Bureau of Radiological 8 Health.
9 Q.6 What decision has the State of Missouri reached with 10 respect to potassium iodide distribution?
11 A.6 The State of Missouri has decided not to administer 12 KI to the general public in the event of an accident at the 13 Callaway Plant. However, the State will make KI available to 14 specified personnel, including emergency workers, considered to 15 be at greater risk. This policy is based on available federal 16 guidance and our understanding of the advantages and 17 disadvantages of KI distribution.
18 Q.7 What would be the purpose of administering KI?
19 A.7 The purpose of administering KI would be for use as a 20 thyroid-blocking agent in a radiological emergency. When an 21 individual takes KI, radioiodine which might be released from 22 the power plant and inhaled or ingested by the individual is 23 prevented from accumulating in the thyroid.
24 Q.8 Please describe the federal guidance used in 25 formulating the State of Missouri's health policy decisions 26 with respect to the administration of KI.
1 A.8 A number of federal agencies, including the Food and 2 Drug Administration ("FDA"), the Federal Emergency Management 3 Agency (" FEMA"), the Nuclear Regulatory Commission ("NRC") and 4 the Environmental Protection Agency (" EPA") have an interest in 5 the question whether, in the event of an accident at a nuclear 6 power plant, KI should be administered to the general public or 7 to specific members of the public located within the plant's 8 ten-mile plume exposure pathway EPZ.
9 In June, 1982, FDA announced in the Federal Register the 10 availability of its final recommendations concerning the admin-11 istration of KI to the public in a radiation emergency. FDA 12 concludes in its final KI recommendations that the risks from 13 the short-term use of relatively low doses of KI for thyroid 14 blocking in a radiation emergency are outweighed by the risks 15 of radioiodine-induced thyroid nodules or cancer at a projected 16 dose to the thyroid gland of 25 rem. FDA recommends that KI in 17 doses of 130 milligrams ("mg") per day for adults and children 18 above 1 year of age and 65 mg per day for children below 1 year 19 of age be considered for thyroid blocking in radiation 20 emergencies for those persons who are likely to receive a 21 projected radiation dose of 25 rem or greater to the thyroid 22 gland from radiciodines released into the environment. See 23 Fed. Reg. 28158 (June 29, 1982).
24 FEMA has endorsed FDA's guidance on the administration of 25 KI. See December 1, 1982 FEMA Interim Policy Guidance on 26 Potassium Iodide.
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1 Both the FEMA and NRC staffs have recommended that nuclear 2 power plant licensees as well as State and local governments 3 provide radioprotective drugs for thyroid protection in the 4 event of a nuclear power plant accident for (i) emergency 5 workers and other individuals remaining or arriving onsite dur-6 ing the emergency; (ii) emergency workers within the plume ex-7 posure EPZ; and (iii) institutionalized persons within the 8 plume exposure EPZ whose immediate evacuation may be infeasible 9 or very difficult. See Testimony of Brian K. Grimes, Director, 10 Division of Emergency Preparedness, U.S. Nuclear Regulatory 11 Commission, Before the Subcommittee on Oversight and Investiga-12 tions, Committee on Interior and Insular Affairs, United States 13 House of Representatives, dated March 5, 1982.
14 To date, neither the NRC nor FEMA has recommended the ad-15 ministration of KI to the general public located within the 16 10-mile plume exposure pathway EPZ.
17 EPA is primarily responsible for the establishment of Pro-18 tective Action Guides ("PAGs") for radiological emergency re-19 sponse planning, in coordination with appropriate federal 20 agencies. EPA also prepared guidance for state and local 21 governments on implementing PAGs, including recommendations on 22 protective actions which can be taken to mitigate the potential 23 radiation dose to the population. In its Manual for Protective 24 Action Guides and Protective Actions for Nuclear Incidents, 25 EPA-520/1-75-001, Sept., 1975 (Revised June 1980), at pages l
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1 1.41-1.42, EPA recommends the use of KI as a prophylaxis for 2 emergency workers located in areas possibly involving 3 radiciodine contamination, in accordance with state health laws 4 and under the direction of state medical officials. With 5 respect to the efficacy of administering KI to the general pop-6 ulation, EPA notes that this option is still under considera-7 tion by government agencies but should not be construed to be 8 the policy of EPA at this time.
9 Q.9 Based on this federal guidance, what policies of KI 10 administration have the State of Missouri adopted?
11 A.9 Consistent with available federal guidance, the 12 Missouri Division of Health will make KI available to state 13 emergency workers and will store KI for distribution to the 14 State Mental Hospital in Fulton, Missouri in the event that 15 institution elects to use it. KI will also be distributed to 16 the county courts, or emergency units designated by the courts, 17 in those areas which might fall within the plume exposure path-18 way EPZ. In the event of an emergency the Bureau of 19 Radiological Health will provide current information regarding 20 projected exposures and will offer guidance on the use of KI.
21 Decisions on whether to administer KI to local emergency 22 workers or to staff and patients at the State Hospital will be 23 made by local authorities and hospital officials, respectively.
24 They will also be responsible for administering the drug if the 25 decision is made to use it. KI will not be distributed to the 26 general public.
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1 This policy of the State of Missouri on the administration 2 of KI is contained in Annex B of the Missouri Nuclear Accident 3 Plan - Callaway, which sets forth the State PAGs. That portion 4 of Annex B concerning radioprotective drugs is appended to this 5 testimony as Attachment 1.
Attachment 1 ANNEX B NUCLEAR ACCIDENT PLAN STATE PROTECTIVE ACTION GUIDES (PAG' s)
A. INTRODUCTION In the event of a nuclear incident, a contaminating event could result which may have public health implica-tions over a large area with diverse population densities. A contaminating event includes, but is not limited to accidents at nuclear facilities, transporta-tion accidents, and f allout from nuclear devices under peacetime conditions. If such an incident occurs, an estimate will be made of the radiation dose which af-fected population groups could receive. This dose esti-mation is called the proj ected dose. A protective ac-tion is an action taken to avoid or reduce this projected doze when the benefits derived from suc'h ac-tions are sufficient to off set any undesirable eff ects of the protective action. The State Protective Action Guide (PAG) is the projected dose to individuals in the population which warrants taking protective actions.
The decision to initiate a protective action may be a complex process with the benefits of taking such action being weighed against the risks and most likely be made under difficult emergency conditions with little time available in which to act. PAG's have therefore been developed to reduce to manageable levels the decisions that must be made to protect the public in the event of a nuclear incident. The response for a given situation will be based on the State Protective Action Guides and the spectrum of possible protective action options available at that time.
I CALLAWAY B1 MAY 1983
s Protective actionc will by bescd upon scacurcm:nts provided by trained field monitors using portable GMabove survey meters with readings taken approximately 3' the ground surface. Beta vs. Gamma exposure rates will be determined by using GM portable survey meters with readings taken with the probe shield open and closed.
Exposure rates may be converted to projected doses using graphs contained in Annex B. Correction f actorsTocon-tained in Annex B will be used as appropriate. use the graphs, take the gamma exposure rate (MR/hr.),
proceed along that line to the projected exposure dura-tion (hrs.). This point is the projected dose (Rem).
The projected exposure time will be based upon the esti-mated duration of release provided by the facility.
For the purposes of the PAG, the residential dwellings locatted within 5 miles of any fixed nucletar f acility are assumed to be wood frame houses with no basements. Us-ing such an assumption will result in the most conserva-tive protection factor (PF) of about 3. This PF will be used to determine (1) whether to recommend sheltering VS. evacuation, (2) whether to continue sheltering, or (3) whether to evacuate. The time it takes to transport Transportation is a factor in determining evacuation.
times can be found in each appropriate County evacuation plan.
Application of the Protection Factor to projected dose, as determined by accident assessment personnel utilizing Projected Dose charts in the Annex, shall be the bases for recommended protection actions.
A protective action guide under no circumstances implies acceptable dose. Since PAG's are based on projected dose, they are used only in an af ter the f act eff ect to minimize the risk from an event that is occurring or has already occurred. In scue situations, protective ac-tions may be indicated at levels lower than the PAG's.
Total Population Exposure Estimation of total population expossre (in Man-REMS) is clearly a functional responsibility of the Federal Gov-ernment together with the utility operator. All radi-ological monitoring data collected by State monitoring teams shall be accumulated at the Forward Command Post, forwarded to the State EOC, and utility EOF, and will be available to government and utility officials.
CALLAWAY B2 MAY 1983
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- 1. Lifting of Protecticn Ccntrols l
l The lifting of controls for protective actions may be justified on the basis of cost savings when the corresponding health risks have been adequately reduced. For example, the costs incurred by the pu-blic, state, and local governments in maintaining access control, pasture control, milk control, or food and water control will exceed the risk reduc-tion value of these controls after a certain period of time. At this point, the controls should remain
' relatively constant with respect to time, while their significance in reducing risk will decrease as the released nuclides are ((econtaminated} dispersef or decay away.
- 2. Re-entry After an evacuation, persons will be allowed to re-enter the area when the risk has been averted or reduced to levels acceptable for members of the gen-eral population. However, it may be necessary for certain essential personnel to return before the
> projected dose is reduced to acceptable guide levels. Recommendations relative to re-entry will
- be determined on a case-by-case basis and will be I based on consideration of the remaining radiation risk and the undesirable eff ects of continuing protective actions. Re-entry and recovery proce-dures are established in Attachment 1 to Annex B. j H. RADICPROTECTIVE DRUGS
- 1. The Division of Health, Bureau of Radiological Health, will provide Potassium Iodide (KI) for use*
by state and local emergency workers who may be required to enter the plume exposure pathway EPZ where the projected dose to the thyroid is 25 rem or greater. The Division of Health has decided that evacuation is a more feasible logistical response for protection of the general public against radioi-odine than is issuance of KI to a large population of people.
CALLAWAY B15 MAY 1983
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- 2. As conditions warrant, the Administrator of tho Bureau of Radiological Health will advise state emergency personnel working in an affected area that KI will be made available. BRE will advise local emergency organizations when conditions have reached a level where available federal guidance suggests the use of KI. Local emergency organizations will make the decision about whether to make KI available to their emergency workers. The decision to make KI l available will be based l%ccident assessment informa-tion such as the expected duration and type of release, areas affected, reaction time available and support logistics will be considered along with -
projected thyroid dose rates.
- 3. The Bureau of Radiological Health will acquire suf-ficient quantities of potassium iodide to support i state and local emergency organizations. The quan- i tities to be purchased will be based on the number of emergency workers anticipated to be operating in the risk area in the event of an accident. Quanti-ties purchased will also take into account the ad-ministration of one daily dose of 130 mg of KI for a maximum of 10 days per emergency worker.
} 4. Potassium iodide for state field monitoring person-nel will be stored in the Office of the Bureau of Radiological Health under the supervision of the Ad-ministrator and will be inventoried annually. It l will be distributed from the Forward Command Post
'l under the direction of the Administrator or his representative. Doses will be recorded on the at-tached Dosage Record Form.
- 5. Potassium iodide for local emergency workers and for state emergency personnel other than field monitor-ing teams will be distributed to local government i agencies in the areas that might be within the plume :
exposure pathway EPZ. The local government agencies will be responsible for storing and inventorying an-nually the K! and for dispensing the KI to emergency workers if the decision is made to use it. Doses will be recorded on the attached form.
- 6. Potassium lodide will be provided for persons for whom evacuation would not be feasible by state and local emergency personnel under BRE direction as :
conditions warrant, based on the criteria specified l l above. Advice regarding the use of KI will be l provided to any person who elects to use it, and a l dosage record will be maintained.
CALLAWAY B16 MAY 1983
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