ML20210U453

Comment Opposing Proposed Rule 10CFR50 Re Consideration of Potassium Iodide (Ki) in Emergency Plans.Urges NRC to Retain Current Policy for Ki Usage

ML20210U453
Person / Time
Site:	Columbia
Issue date:	08/12/1999
From:	Coleman D WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-64FR31737, RULE-PR-50 64FR31737-00013, NUDOCS 9908200113
Download: ML20210U453 (2)

Text

'

13 ENERGY NORTH WEST DOCMCTED PO. Box 968 m Richland, Washington 99352-0968 DE ~ ~~

August 12,1999 70CKET NUVBER wE8NM GO2-99-154 T'f0 POSED HULE NE 50 (VjFR3I737) Cij dl.

ADJt Docket No. 50-397 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 ATTENTION: Rulemakings and Adjudications Staff l

SUBJECT:

PROPOSED RULE: CONSIDERATION OF POTASSIUM IODIDE IN-

{

EMERGENCY PLANS (64 Fed. Reg. 31737-JUNE 17,1999) l RESPONSE TO REQUEST FOR COMMENTS Energy Northwest submits these comments in response to the Proposed Rule: Consideration of Potassium Iodide in Emergency Plans (64 Fed. Reg. 31737-June 17,1999). We have reviewed the proposed rulemaking to amend the emergency planning standard in 10CFR50.47 (64 Fed. l Reg. 31737-June 17,1999). The proposed petition recommends that the planning standard for protectivc actions require explicit consideration of the prophylactic use of potassium iodide (KI) for the general public.

We strongly urge the NRC to deny the petition and to retain the current policy for K1 usage.

U.S. programs are built on the premise that evacuation is generally feasible and is more effective at dose reduction because it reduces dose to all organs, not just the thyroid. Energy Northwest and the majority of commercial nuclear power plants have adopted the protective actions described in the NRC Response Technical Manual (NUREG/BR-0150) to evacuate the general population in the event of severe core damage. The Response Technical Manual also goes on to recommend the stockpiling or distribution of KI during emergencies for emergency workers and institutionalized persons but does not recommend requiring predistribution or stockpiling for the general public.

Energy Northwest strongly believes that the current policy on distribution of potassium iodide for use as a thyroid blocking agent is sound and will provide adequate protection of public health.

'y The safety record of the U.S. commercial nuclear power program and demonstrated strength of its current emergency preparedness programs supports the continuation of current practices for the distribution ofKI.

9908200113 990812 PDR PR 50 64FR31737 PDR

!, U.S. Nuclear Regulatory Commission Page 2 PROPOSED RULE: CONSIDERATION OF POTASSIUM IODIDE IN EMERGENCY PLANS (64 FED. REG. 31737-JUNE 17,1999)

RESPONSE TO REQUEST FOR COMMENTS In addition, the proposed rule fails to provide any new evidence that stockpiling or predistribution of potassium iodide as a protective action will add significant public health and safety benefit to the adequate level of protection currently provided by existing emergency planning at and around commercial nuclear power plants. Furthermore, guidance is already available for state and local governments that 'wish to make KI available to the general public if they feel it is appropriate.

Energy Northwest agrees with the stipulation in the proposed rule that the state and local authorities should make the determination regarding stockpiling and distribution of KI. The cost of purchasing and development of plans and procedures should not be the burden of the nuclear industry.

We appreciate the opportunity to comment on the proposed rulemaking. If you would like to discuss our comments further, please do not hesitate to contact Tim Messersmith at (509) 377-8568.

Res)ectfull

. . W D.W. Coleman (Mail Drop PE20)

Manager, Regulatory Affairs DWC:rej