ML20199E087
| ML20199E087 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 01/17/1998 |
| From: | James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-62FR66038, RULE-PRM-50-63A 62FR66038-00051, 62FR66038-51, NUDOCS 9802020091 | |
| Download: ML20199E087 (2) | |
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James M. Levine TEL (602)393-5300 Mail Station 7602 Palo verde Nuclear SenKr Vice I 'esident FAX (602)393-6077 P.O. Box 52034 Gener=W Ots'Jc..
Nuclear Phoenix, AZ B5072-2034 102-04062 -JMUGAM January 17,1998 Secretary U. S. Nuclear Regulatory Commission a
ATTN: Rulemaking and Adjudications Staff hmq Washington, DC 20555-0001 DOCKET NUMBER ch PETITION RULE PRM 60-GSA E g
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Dear Sirs:
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Subject:
Palo Verde Nuclear Generating Station (PVNGS) 4E f@
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Units 1,2, and 3 h
M Docket Nos. SYN 50 528/529/530 N5 U
Response to Request for Comment on Potassium lodidelKf)*
RJiemaking Petition Filed by Mr. Peter G. Crane In the December 17, 1997 Federal Register (62FR66038), the 19RC requested public l
comment on an amended petition for rulemaking filed by Mr. Peter G. Crane. The amended petition for rulemaking requests that the NRC amend their emergency planning regubtions to req Jire consideration of the prophylactic use of potassium iodide (KI) for the general public in developing a range of emergency planning protective actions.
Palo Verde has reviewed the petition for rulemaking in conjunction with Arizona State and local government response agen,y decision-makers (Arizona Division of Emergency Management). Based on this review, Palo Verde supports the position of Arizona State and local government that additional rulemaking regarding the distribution of KI to the general public is neither necessary nor : sable, and strongly urges that this petition be denied.
Emergency preparedness for Palo Verde is built on the premise of evacuation. Given the low population in the 10-mile Emergency Planning Zone (EPZ) and the relative ease of evacuation, it is felt that evacuation provides the most timely and comprehensive protection for the general public.
If, for some reason, state and local govemment determine that it is appropriate to distribute Kl to the general public, guidance is already available to achieve this end. Additional regulatory requirements are not needed and would not likely contribute to the overall effectiveness of the emergency preparedness program. State and local government response agencies also expressed concerns with
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__ ATTN: Rulem king cnd Adjudications St:ff Ros,nonse to Request for Comment on Potassium lodide (KI) Rulemaking Filed by Mr.
a, Peter G. Crane Page 2
_ regard to-additional costs for KI purchase, inventory, verification, plan and procedure changes, and training. - In addition, they were concemed about creating new areas for evaluation-exposure during drills and exercises, and about whether or not medical i
evidence as to the benefits of Ki-(based on when and how distributed) supports a requirement that is this prescriptive, in summary,- Palo Verde urges the NRC to deny the proposed amended petition and to-retain the current policy as providing adequate protection of the public health and safety.
Sincerely,9 '
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JM1) GAM /rlh cc:
E. W. Merschoff J. W. Clifford J. M. Moorman K. E. Perkins
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