KI -- EPA Recommendations

[Jim Hardeman <Jim_Hardeman@mail.dnr.state.ga.us>]

I apologize in advance if this winds up being a duplicate
message, but I received a "nastygram" that indicated that it
didn't go through.

=======================

Just so everybody is up to speed on what is happening with
KI at the federal level. Last year, NRC received a petition for
rulemaking from Peter Crane (an NRC staff attorney acting as
an individual) requesting that the NRC amend its regulations
concerning emergency planning for commercial nuclear power
facilities to include a requirement that emergency planning
protective actions include sheltering, evacuation, and the
prophylactic use of potassium iodide, which prevents thyroid
cancer after nuclear accidents. The petitioner#s request would
amend one of the 16 planning standards in 10 CFR 50.47 by
which licensee emergency plans are evaluated in order to
assure that the option of using potassium iodide is included
in emergency planning. This petition was noticed in the
Federal Register on (60 FR 58256) as #Peter G. Crane,
Receipt of Petition#.

The Georgia Environmental Protection Division (EPD),
representing both itself and the Georgia Emergency
Management Agency (GEMA), submitted comments to NRC
on this FR notice, as did many other states. The gist of our
comments is as follows:

"The Georgia Environmental Protection Division (EPD)
recognizes the value of the prophylactic use of KI for thyroid
blocking, and the Georgia Radiological Emergency Plan
(REP) includes provisions for distribution of KI to emergency
workers. For protection of the general public, however, we
agree with NRC that in almost all circumstances, evacuation
is the most effective protective measure, especially when the
decision to evacuate is based on plant status and placed into
effect prior to any release of radioactive material. As a general
rule, we do not consider in-place sheltering to be an effective
protective measure, except in extremely severe weather
conditions which would make vehicular travel, even over short
distances, a deadly proposition. It is under these
circumstances that the petitioner sees the distribution of KI to
be of some benefit. We contend, however, that the same
extremely severe weather conditions which would preclude
evacuation would also preclude distribution of KI in a timely
manner (i.e within several hours after exposure).

"The petitioner does not discuss the logistics of the
establishment and maintenance of state and/or federal KI
stockpiles, nor does he discuss the logistics of distribution of
KI in the event of a #major accident#. We contend that the
resource requirements for maintenance of state and/or federal
KI stockpiles,  the logistical problems attendant to
distribution of KI during an accident at a commercial nuclear
power facility and the potential for over-reliance on the
effectiveness of KI would detract from the overall effectiveness
of emergency preparedness and response efforts."

On June 27 of this year, the Federal Radiological Protection
Coordinating Committee (FRPCC) Ad Hoc Committee on
Potassium Iodide held a public hearing on this subject at
FEMA headquarters in Washington, DC. The Conference of
Radiation Control Program Directors (CRCPD) presented
comments at this hearing, and those comments closely
mirrored those above. 

Several states and utilities also presented comments at this
hearing, and without exception the positions taken were very
closely aligned with the one outlined above. One commenter
from TVA noted that the experience with pre-distribution of KI
within even 2 miles of nuclear power plants had been dismal. 

The NRC will be making a decision on whether to grant, deny,
or grant in part and deny in part the KI petition probably
before the end of this year. The FRPCC Ad Hoc Committee
on Potassium Iodide will be making its recommendations to
the full FRPCC either late this year or early in 1997.

I'll be happy to try to answer any more questions on this
subject if I can.

Jim Hardeman, Manager
Environmental Radiation Program
Environmental Protection Division
Georgia Department of Natural Resources
4244 International Parkway, Suite 114
Atlanta, GA 30354
(404) 362-2675  fax: (404) 362-2653
Jim_Hardeman@mail.dnr.state.ga.us
hardeman@mindspring.com