ML18106A881

Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide as Protective Action During Severe Reactor Accidents. Believes That Discussion Contained in SECY-98-061 Should Be Included in Draft NUREG

ML18106A881
Person / Time
Site:	Salem, Hope Creek
Issue date:	09/15/1998
From:	Dawn Powell Public Service Enterprise Group
To:	Meyer D NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-63FR38865, RTR-NUREG-1633 63FR38865-00011, 63FR38865-11, LR-N980448, SECY-98-061-C, SECY-98-61-C, NUDOCS 9809280211
Download: ML18106A881 (4)

Text

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197 !3 SEP 2 I FM I: lf 7 '\.J 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 Iodide (Kl) As a Protective Action During Severe Reactor Accidents".

I The draft NU REG provides a technical assessment on the potential impact of the release of radioiodines during a severe reactor accident and the effect of the use of Kl to reduce the effects of the radioiodines on the impacted population. As an assessment, we believe the NU REG should provide a balanced discussion on the \I ci benefits and risks of the use of Kl. u We recommend reversing the sequence of the first two bullets in the "Kl Benefits and Challenges" section to put more emphasis on evacuation as the most appropriate and effective protective action. The existing emergency pla"ns at commercial nuclear power plants and the impacted states provide adequate protection for the public by implementing timely evacuation of the public and quarantine of contaminated food and drink.

The NUREG should provide additional discussion on the significant experience in the 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 Kl 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.

-- -- - 9ao9280211 -9ao91s

~2~3 ~UREG PDR The power is in your hands.

95-2168 REV. 6/94

SEP 15 J998 Document Control Desk 2 LR-N980448 The benefits of the use of Kl are discussed in the draft NU REG without a balanced discussion of the risks of the use of Kl. Kl has been shown to be effective in reducing thyroid dose when taken just prior to uptake of radioiodines. This protective action is appropriate for emergency workers entering areas of potential or actual airborne radioiodine contamination. Procedures issued by the states contain strict controls for issuing Kl to emergency workers. These same controls would not be practical if Kl is 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 benefits of use of Kl.

Stockpiling and predistribution of Kl would more likely lead to use when it is not needed or delays in implementation of other planned protective actions. As stated in the draft NU REG, Kl is medically inadvisable for various groups of people. For these reasons the use of Kl for public consumption can increase risks more than the potential benefits gained. PSE&G recommends the NRG reconsider the proposed rulemaking petition for stockpiling and use of Kl for the general public.

In SECY-98-061, the NRC staff addressed their support of evacuation and sheltering as the primary protective actions. The discussion contained within SECY-98-061 should be included in the draft NUREG.

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

Sincerely, D.R. Powell Director -

Licensing/Regulation and Fuels

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• SEP 15 1998 Document Control Desk 3 LR-N980149 C Mr. H. J. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. P. Milano, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 14E21 11555 Rockville Pike Rockville, MD 20852 Mr. R. Ennis, Licensing Project Manager - Hope Creek U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 14E21 11555 Rockville Pike Rockville, MD 20852 Mr. S. Morris (X24)

USN RC Senior Resident Inspector - Salem Mr. S. Pindale (X24)

USNRC Senior Resident Inspector - Hope Creek Mr. K. Tosch, Manager IV, Bureau of Nuclear Engineering PO Box415 Trenton, NJ 08625

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• SEP 15 1998 Document Control Desk 4 LR-N98448 DVH BC Sr. Vice President - Nuclear Operations (X04)

Sr. Vice President - Nuclear Engineering (N19)

General Manager - Salem Operations (SOS)

General Manager - Hope Creek Operations (HO?)

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)

Jeff Keenan, Esq. (X09)

Records Management (N21)

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