NUREG-1633, Responds to NRC Request for Public Comments on Draft NUREG-1633 by Forwarding Addl Comments That Have Been Received to Date.Requests That Attached Ltrs Be Placed in PDR & Confirmation of Completion of Request

Responds to NRC Request for Public Comments on Draft NUREG-1633 by Forwarding Addl Comments That Have Been Received to Date.Requests That Attached Ltrs Be Placed in PDR & Confirmation of Completion of Request

ML20154Q105
Person / Time
Issue date:	10/20/1998
From:	Mohseni A NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD)
To:	Mcknight J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20154Q110	List: ML20154Q133 ML20154Q140 ML20154Q154 ML20154Q164 NUREG-1633, Responds to NRC Request for Public Comments on Draft NUREG-1633 by Forwarding Addl Comments That Have Been Received to Date.Requests That Attached Ltrs Be Placed in PDR & Confirmation of Completion of Request
References
RTR-NUREG-1633 NUDOCS 9810230139
Download: ML20154Q105 (6)

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UNITED STATES'

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,7 j NUCLEAR REGULATORY COMMISSION g-WASHINGTON, D.C. 2006Hmot

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October 20, 1998 A

MEMORANDUM TO:

James C. McKnight.

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Records Management Branch

' information Management Division, OClO

'Aby S. Mohseni -h kbA FROM:

Incident Response Division, AEOD

SUBJECT:

DOCUMENTS FOR PDR

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in response to NRC's request for public comments on its draft NUREG-1633, the following additional comments have been received to date. Please place the attached letters in the PDR, where they.can be accessed by allinterested parties. Some of these comments may c already be in the PDR.' Please confirm the completion of this request.

i Attachments:

1.

McKenna 9/27/98 l

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PSE&G 9/15/98

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Southern Company 9/15/98 4.

Puskin and Nelson, EPA 5.

N. Fine 10/6/98 6.

Nebraska,10/7/98 7.

' Entergy 9/16/98 8.

Eric Golden, CHP,9/28/98 l

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- County of Pickens 9/22/98

5 10.

HPS President 10/9/98 11.

Universitat Wurzburg 10/9/98 y

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EPA center for Risk 10/1/98 y

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Mc Kenna's comments on Draft NUREG-1633 September 27,1998

1. Page iii, Para. 4. Add. Protective actions for the public beyond 3 miles would be determined based on dose projection and field monitoring data. (Ref NUREG-0654, supp. 3, page. 3).

Thus, the decision to expand protective action beyond 3 miles most likely will occur after the start of a release.

2. Page iv, Para 2. Add after the first sentence: These dose estimates are for the centerline of the plume and assume a constant wind direction. The average off-site dose resulting from these scenarios would be much lower especially if the wind direction varies as would be expected.

3. Page iv, Para 3 last two sentences revise to read something to the effect: For the two most serious accident scenarios persons at the centerline of the plume could receive doses resulting in early deaths out to about 5 miles and doses sufficient to result in other early health effects vomiting or hypothyroidism beyond 10 miles. Reductions in a thyroid dose would not reduce the risk of early deaths or other non-thyroid heath effects. The only effective protective action for reducing the risk of early deaths is prompt evacuation of the area out to 5 miles. However, reduction in a thyroid dose w! thin 10 miles could substantially reduce the number of early heath effects involving the thyroid. Thyroid blocsing reduces the distance to which the center line dose j

2 exceed the threshold for deterministic thyroid effects (5 X 10 rem) to less than 10 miles in one case. In both cases the number of persons with doses above the threshold for deterministic thyroid effects will be reduced significantly by thyroid blocking. Reduction in a dose to thyroids within 10 miles would also reduce an individual's risk of thyroid cancer. However, to affect a substantial reduction in number of excess thyroid cancers would require reduction in thyroid doses to people well beyond 10 miles may need to discuss collective dose >>.

4. Page iv, Para 4 last sentence: Revise to something to the effect: For the third accident scenario the whole body doses at the centerline of the plume can result in early, but not fatal, heath effects, within one or two miles and thyroid dose sufficient to result in early health effects beyond 10 miles. Reduction in thyroid doses could substantially reduce the number of early health effects involving the thyroid. It could also reduce the individual's risk of cancer within 10 miles especially among children. However, as discussed above, in order to reduce substantially the number of excess thyroid cancers will require reduction in thyroid doses well beyond 10 miles. Only prompt evacuation will be effective in reducing the risk of the more serious non-thyroid cancers such as leukemia.

5. Page iv, Last para, last sentence, revise to read something to the effect: The ideal time to recommend Kl for the public close to the plant is before a release. This is best assured by recommending Kl upon detection of actual or projected core damage. However, this could result in the public taking KI without a release warranting such action. Notwithstanding, accidents of this severity should be very rare and are expected at most only once or twice during the next 50 years. In addition, if Kl was recommended upon confirmation of a release the risk of unwarranted administration would be greatly reduced. This latter approach may be appropriate i

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for the areas beyond 3 miles and is consistent with the approach for this area where additional protective actions are taken based on environmental monitoring results.

6. Page v, Para 2 last sentence, revise something to the effect: Consequently, because the l

potentials exist for early deaths close to the plant any time core damage occurs, prompt evacuation of the area within 2-3 miles is used to protect the public. The public beyond 3 miles is instructed to go inside and listen for further instructions in order to be prepared to act promptly.

Further protective actions for the public beyond 3 miles would be determined based on dose projections and field monitoring data. (Ref NUREG-0654, supp 3, page. 3) Thus the decision to expand protective action beyond 3 miles most likely will occur after a release. Thus, the people beyond 3 miles most likely will be exposed to the plurr.e in the event of a large release.

7. Page v, Para 3 add the following points under "Chernobyl Experience" It is generally accepted among the international scientific community that the excess thyroid cancers in Belarus, Ukraine and Russia are the result of the intake of radioiodine.

It is generally accepted among the international scientific community that KI is safe when given to the appropriate cohort, in the appropriate dose and with the appropriate instructions.

8. Page v, Para 5, and page vi Para 2. True Ki is not a substitution for evacuation when attempting to substantially reduce the risk of early deaths. However, there ate situations where KI could be beneficial. Accidents are possible where thyroid EPA PAGs are exceeded in an area 2-5 times larger than the area where the evacuation PAG is exceeded (See NUREG-0396 fig l-16). Also, discuss the short comings of evacuation such as: slowest of options, not always possible, not appropriate for all situations (Evac PAG not exceeded but Kl PAG is exceeded).

l There are accidents where the release will be too fast to allow an evacuation of the areas near the plant to be completed in time to avoid the plume (see NUREG-1150, page 11-2). In addition, evacuation beyond 3 miles will most likely start after the release is detected and therefore this area cannot be evacuated before the arrival of the plume. KI could be very beneficial for this area. Revise to discuss the benefits and challenges 'or the use of Kl for the reasonable range of accident scenarios and areas. See the table below for suggestions.

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Benefits and Challenges of Kl for a Severe Reactor Accident Area Ki beneficial for:

Challenges Comment Miles 0-2/3 Reducing the number of deterministic Provision to give Kl Protective action thyroid effects for:

so it will not delay recommended based

- Release before evacuation is evacuation.

on plant conditions - a completed primary goal is to take

- Special populations action before a

- Entrapment - bad weather release to reduce risk

- During evacuation if over taken by of early deaths plume Reducing individual risk of thyroid cancer but no sigriificant reduction in total number of excess thyroid cancer 2/3-10 Reducing the number of deterministic Provision to promptly Protective actions thyroid effects for:

detect environmental recommended after a

- During decisions making process levels warranting release based on (before evacuation is recommended) taking KI and to environmental data.

- Entrapment - bad weather administer Kl without

- During evacuation delaying evacuations.

Reducing individual risk of thyroid cancer but no significant reduction in total excess thyroid cancers for:

- Those listed above and lesser releases not warranting evacuation

> 10 Reducing in the in total excess thyroid Timely distribution to Protective actions cancers for large release resulting in high large population recommended after a thyroid doses over a large area (out to release based on 20-50 miles) environmental ( ' 3.

- Timely evacuation would be impossible EPA PAG for KI i,iay or impractical.

be exceeded over a

- Reception centers in the event of a large very large and release complex area.

- Special populations

9. Page vi. Para 3. Revise to indicate that the size and availability of the national stockpiles are uncertain. << l do not think that there are more than a few thousand doses >>

10. n ge vii, Para 3, Change ". Buglova M.D." to "..Buglova M.D. Ph.D."

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11. Page 2 Para 6 (last), Sentence 3 and 4, are incorrect. It is true that the risk of early deaths is virtually "0" for late containment failures (see NUREG-1150, Fig 13.6). However, core melt accidents with a late containment failure or leakage can result in ver/ high thyroid doses and dose exceed the EPA PAG for evacuation. I ran a late containment failure on RASCAL (1-131 release fraction of 1.2 e-2, which is consistent with NUREG-1150 late failure cases, e.g., fig 5.7 p.5-14) and got the following:

1 mile 10 miles TEDE 160 rem 16 rem Thyroid 3000 rem 300 rem Ciearly late containment failures can result in hiegh thyroid doses and whole body doses warranting protective actions (evacuation and thyioid blocking). Revise sentence 3 and 4 to read something to the effect: A core melt with early containment failure is required for early deaths offsite. However, cores melt with late failuri or leakage can result in doses warranting evacuations and thyroid doses resulting in determilistic thyroid effects. Thus, to be considered severe in the present context, an accident must involve core damage. Without core damage there is not needed for any protective action including evacuation or administration of Kl.

13. (No comment)

14. Page 4, Para 5, Add that deterministic health effects are possible at thyroid doses above 500 rad (5 Gy - IAEA SS-109). Revise the last sentence to read something to the effect:

Deterministic health effects require relatively large doses and the first objective of emergency planning is to take actions to prevent or avoid these effects (EPA 400-R-92-001,lAEA-BSS, ICRP-60). The second objective d emergency planning is to reasonably reduce the risk of stochastic health effects. That is tr.u protective action should do more good than harm.

15. Page 5, Para 1, last sentence. Revise to read something to the effect: It is during the plume phase that large doses to the whole body and thyroid can occur. For most accidents, the largest doses are projectad to occur in the plume EPZ (10 mile radius) but high thyroid doses, sufficient to result in detemanistic health effects or that exceeds the EPA PAGs, may occur well beyond 10 miles. Add a new paragraph to te effect: EPA is responsible for developing the protective action guides (PAGs) for the non-ingestion pathways (EPA 400-R-92-001). The EPA PAGs indicate evacuation if 1-5 rem is projected to the whob body and administration of stable iodine if 25 rem is projected to the thyroid from radio-iodine.

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16. Page 5, Para 6, This paragraph is not very clear or helpful. I think that something similar to that in NUREG-0396, Appendix l-Section E (Fig 1-11,1-13) would be more useful.

17. Page 5, Para 7, This paragraph is not clear. It is possible to have offsite releases where the thyroid deterministic threshold (500 rad) is exceeded and the whole body deterministic l

threshold (50 rem) is not. This is demonstrated by Table 5 of the document. Therefore, the adverse heath effects of the thyroid doses may not be much less than those of the whole body doses.

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18. Page 6 Para 5, IAEA (BSS and SS-109) indicates that the threshold for deterministic thyroid effects is 5 Gy (not 1000 rad). Also revise to indicate that it is possible to have offsite releases resulting in doses exceeding the thyroid deterministic threshold (500 rad) and yet the whole 1

body deterministic threshold (50 rem) is not exceeded as shown in Table 5. It is also possible to have a release resulting in doses exceeding the EPA PAG for Kl administration and yet the whole body dose is less than the EPA PAG for evacuation.

19. Pago 8, Para 1, Delete last sentence, stable iodine will block all isotopes of radio-iodine equally well.

20. Page 8, Para 2, Add: Since Chernobyl, Belarus studies could not find a correlation between lodine deficiency in the diet and incidents of excess thyroid cancers (Dr Buglova's talk at EPA Conference).

21. Page 10, Para 3, Revise to clarify, as discussed earlier that there is a range of deterministic health effects including some affecting the thyroid. So clearly thyroid blocking could prevent some (thyroid) deterministic health effects.

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22. Page 11, para 2, revise to remove the questions concerning the Polish experience. Their results have received extensive international peer review and are internationally accepted (IAEA, WHO, US-NIH, numerous governments.. ). In addition, clarify that except for two cases the side effects from the administration of stable iodine in Poland were " mild and transient" l

(Potassium lodine Prophylaxis in Case of Nuclear Accident: Polish Experience, Dr J. Nauman, EPA International Radiological Post-Emergency Response issues Conference, Meeting Proceedings, Sept 9-11,1998) such as skin rashes, headaches, vomiting (ref 23). Also make it clear that based on the Polish experience that Poland, Belarus, WHO et al found Kl to be safe j

for use by the general public.

23. Page 12/13, IV Emergency Preparedness, Add a discussion of te EPA PAGs and guidance for evacuation, shelter and administration of stable iodine. Also, address comment 8.

24. Page 16, add comment 20.

25. Page 18, last para. Revise as indicted in comment 22.

26. Page 25, Table 4. The elevation for RUSR-1 and 4 cases are most likely "O m" and not "1010 m" (1010 m gives a 0 rem thyroid dose within 10 miles). Are you sure the release time for the cases are correct?

27. Page 27/28 revise to be consistent with other comments on pages iii, iv, v and vi.

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28. Page 30, remove reference 19 (personnel communications with Dr Bloglova) and replace l

with the appropriated reference provided by her).

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Nuclear Business Unit SEP151998 -

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LR-N980448 Mr. David L. Meyer Chief, Rules Review and Directives Branch, U.S. Nuclear Regulatory Commission Office of Administration Washington, DC 20555 COMMENTS ON NRC DRAFT NUREG 1633 SALEM AND HOPE CREEK GENERATING STATIONS DOCKET NOS. 50-272,50-311 AND 50-354

Dear Mr. Meyer:

Public Service Electric & Gas Company (PSE&G) submits the following in response to the notice requesting comments on the draft of NUREG-1633 " Assessment of the Use of Potassium lodide (KI) As a Protective Action During Severe Reactor Accidents" The draft NUREG provides a technical assessment on the potential impact of the release of radiciodines during a severe reactor accident and the effect of the use of K1 to reduce the offects of the radiciodines on the impacted population. As an assessment, we believe the NUREG should provide a balanced oiscussion on the benefits and risks of the use of Kl.

We recommend reversing the sequence of the first two bullets in the "KI Benefits and Challenges" section to put more emphasis on evacuation as the most appropriate and effective protective action. The existing emergency plans at commercial nuclear power plants and the impacted states provide adequate prctection for the public by implementing timely evacuation of the public and querantine of contaminated food and drink.

The NUREG should provide additional discussion on toe significant experience in the l

United States of successfully implementing public evacuations, as is regularly demonstrated in the response to the threat of hurricanes. Most of the examples cited in the draft NUREG are related to KI distribution in Europe where international boundaries can impact the implementation of protective actions requiring planned evacuation of members of the public. The United States does not have these boundary limitations.

Themrmurh s ff$ ?.2?C 2ll hj]9 i

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SEP151998 l

Document Control Desk 2

LR-N980448 The benefits of the uae of Kl are discussed in the draft NUREG without a balanced discussion of the riske of the use of Kl. Kl has been shown to be effective in reducing thyroid dose when taken just pnor to uptake of radiciodines. This protectiva action is appropriate for emergency workers entering areas of potential or actual airborne radiciodine contamination. Procedures issued by the states contain strict controls for l

issuing Kl to emergency workers. These same controls would not be practicat if Klis predistributed for public use. State plans require precautionary evacuation of schools at a Site Area Emergency. This precludes the need for issuing Kl for children. Many states also prohibit issuing any medication to school children without parental permission. While these issues are presented in the draft NUREG, the negatives of predistribution of Kl are not described as clearly as the potential benefita of use of Kl.

J Stockpiling and predistribution of Kl would more likely lead to use when it is not needed or delays in implementation of other plar.ned protective actions. As stated in the draft NUREG, Kl is medically inadvisable for various groups of people. For there reasons the use of Ki for public consumption can increase risks more than the potential benefits gained. PSE&G mcommends the NRC reconsider the proposed rulernaking petition for stockpiling and use of KI for the general publ:c.

J In SECY-98-061, the NRC staff addressed their support of evacuation and sheltering as the primary protective actions. The discussion contained w' thin SECY-98-061 should r

be included in the draft NUREG.

If you have any questions or require additionat information, please contact Ms. Donna Miller at (609) 339-1757.

Sincecaly, Dd4 D. R. Powell DirecCor -

Licensing / Regulation and Fuels I

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c ' l \\h Mr. H. J. Milfe'r, Adm,nistrator - Region 1 1~

U. S. Nuclear Regulatory Commission L)'i 475 Allendale Road King of Prussia, PA ~19406 y

Mr. P.' Milano, Licensing Prcject Manager - Salem n

U. S. Nuclear Regulatory Commission One White Flint North

. Mail Stop 14E21

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,a Ji Mr. R. Ennis, Licensing Project Manager - Hope Creek i,

L 'J.- S. Nuclear Regulatory Commission J0ne White Flint North x

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11555 Rockville Pike R ockville, MD 20852

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Mr S. Morris.

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-L US NRC Senior Resident inspector - Salem Mr. S. Pindale (X24)

USIORC Senior Resident inspector - Hope Creek

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Mr. K Tosch, Manager IV, 1

- Dureau of Nuclear Engineering

'PO Bpx 415 Trenten, NJ 08625 4

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DVH BC Sr. Vice President - Nuclear Operations (X04)

Sr. Vice President - Nuclear Engineering

-(N19)

General Manager - Salem Operations (SOS)

General Manager - Hope Creek Operations (H07)

Director - QA/NT/EP (X01)

Program Manager - NRB (N38)

Manager - Financial Control & Co-Owners Affairs (N18)

Onsite Safety Review Engineer - Salem (S12)

Onsite Safety Review Engineer - Hope Creek (H11)

Salem Licensing Manager (N21)

Hope Creek Licensing Manager (N21)

Je# Keenan, Esq.

(X09)

Records Management (N21)

Microfilm Copy File l

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a J. Bernie Beasley, Jr., P.E.

Southern Nuclear 6

Vice President Operating Company. Inc.

h gg7 Vogtle Project 40 invemess Center Parkway

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'(y 9 PO Box 1295 Birmingham, Alabama 35201 S((t"#/

Tel 205 992 7110 "j

h (l6 Fax 205 992 0403 SOUTHERN COMPANY September 15, 1998 Energy to Serve nur bid "

Docket Nos.

50-348 50-321 50-424 HL-5682 50-364 50-366 50-425 L.CV-1250 Mr. David L. Meyer, Chief Rules Review and Directives Branch Mail Stop T-6 D69 OfTice of Administration United States Nuclear Regulatory Commission Washington, D. C. 20555-0001 Comments on Draft Nureg-1633, " Assessment of the Use of Potassium Iodide (KI) As a Protective Action During Severe Reactor Accidents,"

(63 Fed Ren 38865. July 20.1998)

Dear Sir:

Southem Nuclear Operating Company (Southem Nuclear) has reviewed NRC's Draft Nureg-1633, notice of which was published in the Federal Register on July 20,1998. The Draft Nureg provides a s>uopsis of the historical use, the technical basis and industry experiences with KI as a supplemental protective action for the general public living in the area around a commercial nuclear power plant. In accordance with the request for comments, Soutlwrn Nuclear endorses comments submitted by the Nuclear Energy Institute (NEI) which accurately convey Southem Nuclear's position on the referenced NRC Draft Nureg-1633.

Southem Nuclear would like to emphasize that though KI stockpile and distribution are common practice in the European countries, consequences of the Chernobyl experience should not provide adequate grounds for changing the current U. S. policy. The Federal Radiological Preparedness Coordinating Committee (FRPCC) policy statement discussed in COMSECY 97-028, asseits that evacuation, and under certain conditions shelter, constitute the primary protective actions for public protection. At the emergency classifications where protective actions are performed, Ki would not add any significant level of safety and could actually hinder and complicate the emergency response effort.

Should you ha've any questions, please advise.

Respectfully su mitted, A~

J.

amie B asley, Jr.

JBB, Jr/NMM 4%OQYOlW 0

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l ADy Mohseni-KI COiTnT.66th Page 1 l From:

JEROME PUSKIN <PUSKIN.JEROME@EPAMAILEPA. GOV >

To:-

GATED.nrcamtp("LYMAN.RITCHEY@EPAMAIL. EPA. GOV")

Date:

Mon, Oct 5,1998 1:42 PM

Subject:

KI Comments

Ritchey, l

l' l understand that you are collating comments on NRC's KI report.

Attached are comments from Neal Nelson & myself.

Thanks, i

Jerry CC:

GATED.nrcamtp("N ELSON.N EAL@EPAMAIL. EPA. GOV")

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