ML20153E821

Comment Supporting Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Agrees with Staff Assessment in Secy 98-061

ML20153E821
Person / Time
Site:	Calvert Cliffs
Issue date:	09/22/1998
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	Meyer D NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-63FR38865, RTR-NUREG-1633 63FR28865-00019, 63FR28865-19, SECY-98-061-C, SECY-98-61-C, NUDOCS 9809280263
Download: ML20153E821 (4)

Text

4 CHARLES II. CRUSE imore Gas and Electric Company

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Vice President ert Cliffs Nuclear Power Plant ie Nuclear Energy l$3 ${p g II (1650CalvenCliffs Qs3 Maryland 20657 Parkway Q)Cg j((d$

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/i September 22,1998 -

U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Mr. David L Meyer, Chief Rules Review and Directives Branch

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Request for Comments; Draft NUREG-1633, " Assessment of the Use of Potassium Iodide (KI) As a Protective Action During Severe Reactor Accidents" (63 FR 8865. July 20.1998)

We have reviewed draft NUREG-1633," Assessment of the Use of Potassium Iodide (KI) As a Protective Action During Severe Reactor Accidents," concerning the historical use, technical basis, and industry experiences with KI as a supplemental protective action for the general public.

We endorse the draft NUREG's conclusion that careful consideration should be given to whether the use of KI for the public during an emergency is advantageous. The draft NUREG accurately states that "considering" stockpiling or predistribution of KI as a protective action will not add any significant public health and safety benefit beyond the existing emergency planning practices at commercial nuclear power plants. g Baltimore Gas and Electric Company also agrees with the staff's assessment in SECY 98-061 " Staff Options for Resolving a Petition for Rulemaking Relating to Re-evaluation of the Policy Regarding the Use of Potassium Iodide (KI) by the General Public After a Severe Accident at a Nuclear Power Plant."

We endorse Option 2. This option recommends denying the petition and supports Federal Radiological Preparedness Coordinating Committee policy statement discussed in draft " Federal Register Notice on i Potassium Iodine Policy," COMSECY 97-028, which maintains that evacuation and sheltering are the I j primary protective actions. We strongly urge the NRC to reconsider its approval of the proposed l rulemaking petition.

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l l 9809280263 980922 PDa Nunse - l 1633 C PDR

. _ _ . . __ m _ ._ . __ __ - .- .._ . _ _ . . .

Mr. David L M;yer, Chi:f September 22,1998 Page 2 )

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I Should you have questions regarding this matter, we will be pleased to discuss them with you.

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Very truly yours, )

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/ ,rf f W/W CHC/JMO/ dim j

cc: Document Control Desk, NRC H. J. Miller, NRC i R. S. Fleishman, Esquire Resident Inspector,NRC J. E. Silberg, Esquire R. I. McLean, DNR

' S. S. Bajwa, NRC J. H. Walter, PSC A. W. Dromerick, NRC i

i

s

, .> c CHARLES H. CRUSE Baltimore Gas and Electric Company Vice President Calven Cliffs Nuclear Power Plant Nuclear Energy 1650 Calven Cliffs Parkway Lusby, Maryland 20657 410 495-4455 September 22,1998 l

U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Mr. David L Meyer, Chief -

Rules Review and Directives Branch

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Request for Comments; Draft NUREG-1633, " Assessment of the Use of Potassium Iodide (KI) As a Protective Action During Severe Reactor Accidents" (63 FR 8865. July 20.1998)

We have reviewed draft NUREG-1633," Assessment of the Use of Potassium Iodide SI) As a Protective Action During Severe Reactor Accidents," concerning the historical use, techniul basis, and industry experiences with KI as a supplemental protective action for the general public.

We endorse the draft NUREG's conclusion that careful consideration should be given to whether the use of KI for the public during an emergency is advantageous. The draft NUREG accurately states that "considering" stockpiling or predistribution of KI as a protective action will not add any significant public health and safety benefit beyond the existing emergency planning practices at commercial nuclear power plants.

Baltimore Gas and Electric Company also agrees with the staff's assessment in SECY 98-061 " Staff Options for Resolving a Petition for Rulemaking Relating to Re-evaluation of the Policy Regarding the Use of Potassium lodide (KI) by the General Public After a Severe Accident at a Nuclear Power Plant."

We endorse Option 2. This option recommends denying the petition and supports Federal Radiological Preparedness Coordinating Committee policy statement discussed in draft " Federal Register Notice on Potassium Icdine Policy," COMSECY 97-028, which maintains that evacuation and sheltering are the primary protective actions. We strongly urge the NRC to reconsider its approval of the proposed rulemaking petition.

l l

l

[, *

, . Mr. D;vid L Meyrr, Chirf September 22,1998 Page 2

- Should you have questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours, i

,a /

/ x#

CHC/JMO/ dim cc: Document Control Desk, NRC H. J. Miller, NRC i

R. S. Fleis%an, Equire Resident Inspector,NRC J. E. Silberg, Esquire R. I. McLean, DNR S. S. Bajwa, NRC J. H. Walter, PSC

• A. W. Dromerick, NRC 1