ML20211Q713
| ML20211Q713 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 09/09/1999 |
| From: | Abbott R NIAGARA MOHAWK POWER CORP. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-64FR31737, RULE-PR-50 64FR31737-00031, NUDOCS 9909150130 | |
| Download: ML20211Q713 (1) | |
Text
m 3I Niagara @ Mohawk',j I
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Richard B. Abbott Phone: 315 349.IN Vice President 99 SEP 13 P 3 :M 8'5 3*"4" i
NuclearEngineering September 9,1999
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Secretary of the Commission I
U.S. Nuclear Regulatory Commission DOCKET NUMBER as ston,x 20m PROPOSED RULE b 50 NMDb Attention:
Rulemakmgs and Adjudications Staff
Subject:
Proposed Rule: Consideration of Potassium Iodide in Emergency Plans (64/113 Federal Register, P.31737, June 14,1999) Reauest for Comments Gentlemen:
Niagara Mohawk Power Corporation (Niagara Mohawk) submits the following comments on the proposed rulemaking to amend the emergency planning standard in 10 CFR 50.47 (b)(10)
(64/113 Federal Register, P.31737, June 14,1999). The proposed rulemaking is in response to a petition that emergency planning protective actions include explicit consideration by the state of the prophylactic use of potassium iodide (KI) by the general public.
Niagara Mohawk, as the licensee for Nine Mile Point Units 1 and 2, strongly urges the NRC to reconsider its decision to grant the petition. The discussion published with the proposed rule does not present any new evidence that stockpiling or predistribution of KI as a protective action will add a significant public health and safety benefit. An adequate level of protection is already provided by existing emergency planning i
procedures at and around commercial nuclear power plants. Adequate guidance is available to states and local governments that feel it is appropriate to make KI available to the general public.
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The petitioner has not proved the claimed increase in benefits of using K1 as a thyroid blocking agent in a radiological emergency, on the basis of current scientific data. U.S. programs are built on the sound premise that evacuation is generally feasible and is more effective at dose reduction than use of KI because evacuation reduces the dose to all organs, not just the thyroid.
Niagara Mohawk believes that the cost of purchasing KI and developing plans and procedures to meet any new requirements promulgated by the proposed rule should not be the resp 9nsibility of the nuclear industry.
Niagara Mohawk agrees that state and local authorities should make the appropriate determmation and be financially and administratively responsible regarding stockpiling and distribution of KI, as is the current practice.
Niagara Mohawk supports the Nucl:ar Energy Institute (NEI) position urging the NRC to deny the petition. We appreciate the opportunity to comment on the proposed rulemaking.
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Very truly yours, db cY 3
9909150130 990909 PDR PR Richard B. Abbott 50 64FR31737 PDR Vice President Nuclear Engineering
$/O Nine Mde Point Nuclear Station P0. Box 63. Lycoming, New York 13093-0063
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