ML20198Q485
| ML20198Q485 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/16/1998 |
| From: | Terry C, Walker R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-62FR66038, RULE-PRM-50-63A 62FR66038-00030, 62FR66038-30, NUDOCS 9801230052 | |
| Download: ML20198Q485 (2) | |
Text
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Log # TXX 98011
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DOCKET NUMBER PETm0N RULE PRM 604J A d
hre IM F# "03 8) y U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Docketing and Services Branch
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50 445 AND 50 446 COMMENTS ON AMENDED PETITION FOR RULEMAKING FILED BY PETER G. CRANE REF:
62 FR 66038 December 17, 1997
Dear Mr. Hoyle:
TU Electric recommendt. that the NRC deny the amended petition filed by Mr.
Peter G. Crane that requests the NRC amend its regulations concerning emergency planning to require consideration of sheltering, evacuation, and the prophylactic use of potassium iodide (KI) for the general public in developing a range of emergency planning protective actions.
TU Electric also endorses the detailed comments being provided by the Nuclear Energy Institute (NEI) on the subject Federal Register Notice.
With respect to consideration of the use of KI, the current federal policy, formulated by the Federal Radiological Preparedness Coordinating Committee (15 federal agencies) in 1985 regarding stockpiling and distributing KI during emergencies for emergency workers and institutional persons, but not the public, should remain in effect. U.S. programs for emergency preparedness at nuclear power plants are based on evacuation of the general public as the preferred protective action. Evacuation is generally feasible and is more effective at dose reduction because it reduces dose to all organs, not just the thyroid as with the use of KI.
TU Electric's recommendation to deny Mr. Crane's petition is not based on concern for KI's initial and periodic replacement costs.
Potassium iodine is relatively inexpensive at approximately a dollar per a bottle of fourteen 130 mg tablets. Our recommendation to deny Mr. Crane's recommendation to make potassium iodide available to tne public is based priearily on our belief that the most effective protective measure for the public would be their evacuation. On the basis of EPA 400, "Hanual of Protective Action Guides and Protective Actions for Nuclear Incidents",
i evacuation should take place when the projected dose (whole body and orga..
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i TXX 98011 Page 2 of 2 or TEDE and CEDE) would exceed one (1) res. The same document recommends ingestion of stable iodine only if the projected dose (CEDE) would exceed 25 res and would require the approval of the state medical official.
The State of Texas currently does not recommend the use of KI by members of the general public, and Texas neither supplies nor will administer KI to members of the peneral public.
Instead, the Texas Department of Health recommends that pertons in areas affected by an accidental release of radioactive materiale follow the advice of local officials and evacuate or seek shelter when instructed to do so.
TU Electric recommends that the NRC consider the following:
o Mr. Crane's advocicy of the consideration of potassium iodide predistribution is likely to be perceived by the public as an all-purpose means for self protection for all physical and chemical forms of radionuclides.
The public may believe that the first choice for-self protection for any projected radionuclide exposure is taking potassium iodide, which may lead to a false sense of security.
o-To be an effective thyroid blocking agent, KI (non radioactive iodide tablet) should be taken arior to inhaling radioactive iodine.
It is unlikely, regardless of tie extent of predistributed KI within the plume exposure pathway, that determining the need for and distributing KI to the individuals will occur in time to be effective.
The present regulations and the current federal and state guidance adequately address the concern and considerations for protection of the public.
Sincerely,
$* k C. L. Terry By:
M RogeVD. Walker Regulatory Affairs Manager CLW/c1w c
Mr. Alan Nelson. NEI