ML20100E843

Comment Opposing Petition for Rulemaking PRM-50-63 Re Amending Emergency Planning Std

ML20100E843
Person / Time
Site:	Calvert Cliffs
Issue date:	02/09/1996
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-60FR58256, RULE-PRM-50-63 60FR58256-00044, 60FR58256-44, NUDOCS 9602150242
Download: ML20100E843 (3)

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CH ARLES II. CHUse 00CKUED naitimore Gas and Electric Company t! W Calvert Cliffs Nuclear Power Plant Vice President 1650 Calvert Clius Parkw ay Nuclear Energy Lusby. Maryland 20657 4 0 493-4455

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February 9,1996 DOCKETtJugggg RUl.2 5%SQ Secretary E U.S. Nuclear Regulatory Commission Washington, D.C. 20555-000l ATTENTION: Docketing and Services Branch

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Petition for Rulemaking Filed by Mr. Peter G. Crane (60 FR 58256 -

November 27.1995) Request for Comments Baltimore Gas and Electric Company submits the following comments on the subject petition. We have reviewed the proposed petition to amend the emergency planning standard in 10 Code of Federal Regulations 50.47, (60 FR 58256 - November 27,1995), " Peter G. Crane, Receipt of Petition for Rulemaking." The proposed petition recommends that the planning standard for protective actions for the general public include the prophylactic use of potassium iodide (KI).

Baltimore Gas av Electric Company urges the Nuclear Regulatory Commission (NRC) to deny the petition. We believe that stockpiling or predistribution of KI will not add any significant public health and safety benefit to the level of protection currently provided by existing emergency plans at and around commercial nuclear power plants. The current Federal Policy on Distribution of Potassium Iodide for Use as Thyroidal Blocking Agent provides sufficient guidance to state and local governments for determining appropriate actions to protect the general public.

The Nuclear Energy Institute (previously the Nuclear t.L :.agement and Resource Council) provided a white paper to the Commissioners on December 7,1993, statmg why the industry had concluded that " stockpiling or predistribution of potassium iodide (for the general public) will not add any significant public health and safc*v benefit to the adequate level of protection currently provided by existing emergency preparedness at and around commercial nuclear power plants." The paper discussed the lessons learned from events and studies that occurred since the original 1985 federal policy. The events and studies include the Chernobyl accident and the NRC analysis report, advances in source term knowledge, continuing experience with a state K1 distribution program, and the 1993 NRC report on KI. The white paper addresses the petitioner's concerns and urges the NRC to retain its current policy.

9602150242 960209 PL PRM S0-63 PDR 3b0

O Docketing and Services Branch l February 9,1996 l 1

Page 2 1 The white paper also quoted Environmental Protection Agency's 1992 Protective Action Guides. The Guides state in part that although the use of K1 has been identified m an effective protective action, evacuation arJ s heltering are preferred alternatives for most situations. Evacuation and sheltering provide protection for the whole body and avoid risk of misapplication of KI. The Guides make a strong case for l maintaining the current policy, and associated regulation regarding Kl. l Additional reviews that support denying the proposed petition include the May 6, 1994, NRC Commissioners vote to retain the current KI policy, and the Federal Radiological Preparedness and Coordinating Committee (FRPCC) Subcommittee on Potassium Iodide Report and Recommendations.

Baltimore Gas and Electric Company agrees with NRC Commissioner de Planque's comments on SECY 93-318 and SECY-94-87. Commissioner de Planques su" ports the May 6,1994, vote to retain the current KI policy. The Commission vote effectively endorses the current policy, is consistent with the expressed industry opinion and supports the case to deny the petition. l l

In 1991, the FRPCC established an Ad Hoc Subcommittee on Potassium lodide to reexamine the 1985 l policy and to consider the federal governnwt , urchasing and stockpiling KI for use by the public. The l I

subcommittee conferred with the Conferese of Radiation Control Program Directors, evaluated state polices on KI, current needs, invited and solicited input from states concerning use and distribution of K1 to the public, evaluated foreign experiences, and the updated NRC study on the cost-effectiveness of stockpiling KI for the public. The FRPCC subcommittee submitted its recommendations to the Chairman of the FRPCC on September 15, 1994. In the body of the report the subcommittee notes that, "In conducting its reviews of the post-1985 data, the Subcommittee on K1 uncovered no new infonnation that changes the bases for the 1985 recommendations concerning public use of KI." As part of the Subcommittee's review, Federal Emergency Management Agency conducted a survey of states that would be affected by a change in the current KI policy. The survey revealed that 33 of the 43 responding states were opposed to the creation of a K1 stockpile program. The report notes, "The problems involved in distributing KI to the general public and the states' use of evacuation as the primary protective r.ction were the major factors that these states cited in not supporting such a Federal initiative."

The subcommittee report concludes with the following recommendations: the FRPCC policy on KI (Federal Register Vol. 50, No.142 - Wednesday, July 24,1985) should not be changed, and the federal government should not stockpile KI for use by the public. This report was forwarded to Mr. Dennis H. Kwiatkowski, Chairman of the FRPCC on September 15,1994.

In summary, it does not appear that making K1 available to the general public will add any significant public health and safety benefit to the level of protection currently provided 1.; existing emergency preparedness at and around commercial nuclear power plants. The low probability of an event occurring that would release radionuclides combined with the difficulties of effectively distributing KI make it unlikely that the public will ever benefit from a change in the current policy.

The events that have occurred and studies initiated since the 1985 federal policy make a strong case for maintaining the current KI policy. Guidance already exists for state and local governments that wish to make KI available to the general population if they feel it is appropriate. Given the safety record of the U.S. commercial nuclear power program and demonstrated strength of its emergency preparedness programs, Baltimore Gas and Electric Company strongly urges the NRC to deny the proposed petition.

Docketing and Services Branch February 9,1996 Page 3 .

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l We appreciate the opportunity to comment on the Petition for Rulemaking filed by Mr. Peter G. Crane. If j you would like to discuss our comments further, please do not hesitate to contact us. l l

Very truly yours,

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CliC/DJM/bjd j t f l

ec: Document Control Desk, NRC D. A. Brune, Esquire

.I E. Silberg, Esquire L. B. Marsh, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC Resident Inspector, NRC R. I. McLean, DNR J. H. Walter, PSC l

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