ML20198Q848

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Comment Opposing PRM 50-63A by Pg Crane Amending Petition for Rulemaking Re Use of Potassium Iode
ML20198Q848
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 01/15/1998
From: Medling E
SOUTHERN CALIFORNIA EDISON CO.
To:
NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-62FR66038, RULE-PRM-50-63A 62FR66038-00037, 62FR66038-37, NUDOCS 9801230154
Download: ML20198Q848 (2)


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USNRC u mms m.mmey, J-January 15, 1998 OFFK1 _. h y. gg RULL M i.. si Secretary, U.S. Nuclear Regulatory Commission ADJUDCtX "ai:F Attn: Rulemaking and Adjudications Staff Washington, D. C. 20555-001 DOCKET NUMBER

Subject:

Southern relifornia Edison (SCE)

PETm0N RULE PRM 50434 Comments on Amended Petition for Rulemaking (H F/2 M03F)

Filed by Mr. Peter G. Crane (62 Federal Register 66038 - December 17,1997)

Gentlemen:

The subject Federal Register notice requested comments on an amended petition for rulemaking regarding the planning standard for the NRC's emergency planning regulations.

The amended petition, if adopted by rulemaking, would require states to document why they choose not to distribute potassium iodide (KI) to the public.

SCE has reviewed the amended petition and discussed this matter with the State of California Office of Emergency Services and Department of Health Services.

This letter provides our comments on the amended petition.

We believe the rulemaking reauested in the amended petition would add no benefit to existing emergency plans or an increase in the public health and safety. However, it does add the burden of additional documentation associated with reconsidering existina plans which have provided reasonable assurance for the protection of public health and safety for many years and are considered to be based on the best technical information.

In addition, we believe that stockpiling or predistribution of potassium iodide (KI) as a protective action would not add any significant public health and safety benefit to the current level of protection provided by existing emergency plans for California's commercial nuclear power plants.

Our emerger,cy plans focus on evacuation as the key protective action to prevent exposure since it protects against exposure to all radionuclides, not just iodino.

In addition, the potential for misadministration of K1 is present when predistributed to the general public, and incidents of misadministration l

have been informally reported at industry meetings by states which f

predistribute KI to the public.

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r Secretary. I U. S. Nuclear Regulatory Commission The Federal policy, published in 1985, does not recomend requiring that K1 be stockpiled or predistributed to the general public.

This position is based on the best technical information which indicates that prompt evacuation and in-place sheltering are the preferred protective actions for the general public.

In 1997, the NRC revised its position to fund the purchase of K1 for states at their request.

In this revision, the NRC did not revise or invalidate the technical basis of the existing position.

The basis for the revision was the recognition that since the state and local governments bear ultimate responsibility for protection of their citizens, NRC would allow the decision for local stockpiling and use to be made at the local level.

The State of California Emergency Plans also includes a policy on potassium iodide. This policy does not recommend predistribution of K1 to the general public.

The amended petition doer not provide any new information or justification for the additional burden of requiring states to reconsider their emergency plans.

Given the demonstrated strength of current emergency preparedness programs, we urge the NRC to retain the current policy and request that the NRC deny the amended petition.

Should you have any questions, please contact me at 714-368-7492.

Since ely, lk' l1

'ha cc:

E. W. Merschoff, Regional Administrator, NRC Region IV X. E. Perkins, Jr., Director, Walnut Creek Field Office, NRC Region IV M. K. Webb, NRC Project Manager. San Onofre Unit 1 M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3 Louis Carson, Regional Projact Inspector, San Onofre Unit 1 J. A. Sloan, NRC Senior Resident inspector, San Onofre Units 2 & 3 S. S. Bajwa, Section Chief, Decommissioning Section l

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