ML20137J114

Response to ASLB Questions Re Respiratory Protection. Statements Re Use of Handkerchiefs or Other Protective Masks Deleted from Emergency Info Brochures on Technical Grounds. Ld Butterfield Affidavit Encl.Related Correspondence

ML20137J114
Person / Time
Site:	Braidwood
Issue date:	01/21/1986
From:	Edgar G COMMONWEALTH EDISON CO., NEWMAN & HOLTZINGER
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20137J117	List: ML20137J114 ML20137J125
References
CON-#186-784 OL, NUDOCS 8601220254
Download: ML20137J114 (3)

Text

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I UNITED STATES OF AMERICA hyf,*gg NUCLEAR REGULATORY COMMISSION -O c "06 i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD utV2/

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In the Matter of  :

COMMONWEALTH EDISON COMPANY  : Docket Nos. 50-456 j

50-457 O (Braidwood Station, Units 1 and 2)  :

COMMONWEALTH EDISON'S RESPONSE TO TdB BOARD'S QUESTIONS REGARDING RESPIRATORY PROTECTION During the hearings on Contention 1(a) held in October 1985, it was noted that previous emergency information brochures prepared by Commonwealth Edison Company (" CECO") for certain of its other nuclear power plants had contained statements regarding the use of handkerchiefs or other protective masks as a means of respiratory protection in the event of an emer-gency. Because this statement was not included in the Braid-wood brochure, the Board requested CECO to provide the Board information ". . . explaining why this particular provision was deleted from the current brochure when it appeared in the Company's prior brochures." 1/

As explained in the accompanying affidavit of Lawrence D. Butterfield, Jr., the decision not to include the respira-tory protection statement in the Braidwood brochure was based 1/ Transcript of the emergency planning hearings held in this proceeding on October 29, 1985 at 562.

8601220254 860121 PDR ADOCK 05000456 G pop

• upon four factors. First, respiratory protection would be useful in only a relatively small number of accident scenarios involving offsite particulate releases. Second, the use of a hand-held protective mask would provide only limited and uncertain protection even where particulates are released.

Third, the use of protective masks could hinder or delay evacuation. And finally, such an instruction might create a false sense of security and could result in persons within the EPZ taking unnecessary risks or delaying evacuation.2/

Based on these factors, CECO believes that instructions on respiratory protection should not be given as a routine matter.

Rather if such instructions should become necessary and appropriate, they should be given specifically at the time of an emergency.3/

Recently, FEMA issued a Policy Statement on Respiratory Protection, concurred in by the NRC, in which FEMA found that instructions on respiratory protection are not required by NUREG-0654/ FEMA Rep. 1, Rev. 1, Section G.l.c. and that the absence of such language would not render a brochure inadequate. Although FEMA recommends that some instruction on respiratory protection be included in brochures, FEMA recognizes that such language might be inconsistent with the policy of local or state jurisdictions and might confuse 2/ See Affidavit of Lawrence D. Butterfield, Jr. at 1 6.

3/ Aff. at 1 7.

rather than inform the public. In this case, the State of Illinois believes that inclusion of respiratory protection instructions, as a routine procedure, would tend to cor#.se rather than inform the public and should not be included in the brochure. 4/

In summary, CECO submits that the respiratory protection statement was properly deleted from the brochure on reasonable technical grounds. In addition, the deletion was consistent with the policy of the State of Illinois and does not contra-vene the requirements of NUREG-0654/ FEMA, Rep. 1, Rev. 1, Section G.l.c.

Respectfully submitted, 3

Geor A . Edgar 7 Thomas A. Schmutz Newman & Holtzinger, P.C.

1615 L Street, N.W.

Suite 1000 Washington, D.C. 20036 (202) 955-6600 Attorneys for COMMONWEALTH EDISON COMPANY January 21, 1986 4/ Aff. at 11 9-10.