ML20097D732

Comment Opposing Petition for Rulemaking PRM-50-63 Re CPSES Request for Amend to Its Regulations Dealing W/Emergency Planning to Include Requirement That Emergency Planning Protective Actions for General Public Include Listed Info

ML20097D732
Person / Time
Site:	Comanche Peak
Issue date:	02/09/1996
From:	John Marshall TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Hoyle J NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-60FR58256, RULE-PRM-50-63 60FR58256-00035, 60FR58256-35, NUDOCS 9602130153
Download: ML20097D732 (2)

Text

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00CKEIE0 l F- Log # TXX 96047

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, File # 10185 96 FEB 12 90 m 7UELECTRIC 'Ey'"'

February 9,19gg ; '

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C. Lance Terry Group Mce Presodent Mr. John C. Hoyle '

DOCKETNuggg Secretary U. S. Nuclear Regulatory Commission pg W ONflutg Washington, DC 20555 UOFQ 3

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50 445 AND 50 446 h 1 COMMENTS ON PETITION FOR RULEMAKING FILED BY  !

PETER G. CRANE l REF: 60 FR 58256 November 27, 1995  !

Dear Mr. Hoyle:

TU Electric recommends that the NRC deny the petition filed by Mr. Peter G. Crane that requests the NRC amend its regulations concerning emergency planning to include a requirement that emegency planning protective actions for the general public include sheltering, evacuation and the prophylactic use of potassium iodide (KI). TU Electric also endorses the detailed comments being provided by the Nuclear Energy Institute (NEI) on the subject Federal Register Notice.

The current federal policy, formulated by the Federal Radiological Preparedness Coordinating Committee (15 federal agencies) in 1985 regarding stockpiling and distributing KI during emergencies for emergency workers and institutional persons, but not the public, should remain in effect.

TU Electric's recommendation to deny Mr. Crane's petition is not based on concern for KI's initial and periodic replacement costs. Potassium iodine is relatively inexpensive at approximately a dollar per a bottle of fourteen 130 mg tablets. Our recommendation to deny Mr. Crane's recommendation to make potassium iodide available to the public is based primarily on our belief that the most effective protective measure for the public would be their evacuation. On the basis of EPA 400, " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents",

evacuation should take place when the projected dose (whole body and organ or TEDE and CEDE) would exceed one (1) rem. The same document recommends ingestion of stable iodine only if the projected dose (CEDE) would exceed 25 rem and would require the approval of the state medical official.

9602130153 960209 PDR PRM 50-63 PDR Energy Plaza 1601 Bryan Street Da!!as, Texas 75201 341I go

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TXX-96047 Page 2 of 2 TV Electric recommends that the NRC consider the following:

o Mr. Crane's advocacy of potassium iodide predistribution is likely to be perceived by the public as a sure fire and all purpose means for self protection for all physical and chemical forms of radionuclides. The public may believe that the first choice for '

self protection for any projected radionuclide exposure is drugging themselves with potassium iodide: if so, then they have been given a false sense of security.

o To be an effective thyroid blocking agent, KI (non radioactive iodide tablet) should be taken prior to inhaling radioactive iodine.

It is unlikely, regardless of the extent of predistributed KI within the plume exposure pathway, that quantifying the need for and getting KI into the hands of individuals will occur in time to be effective.

The present regulations and the current federal guidance adequately address the concern for_ protection of the public.

Sincerely, C. L. Terry By:.

U. S. Marshall Generic Licensing Manager CLW/vid c - John F. Schmitt, NEI