ML20005C142
| ML20005C142 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/16/1981 |
| From: | Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Chandler L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20005C141 | List: |
| References | |
| NUDOCS 8111180447 | |
| Download: ML20005C142 (1) | |
Text
F p*#fGuq UNt1ED STATES o,
NUCLcAR flEGULATORY COMMISSION
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,5 November 16, 1981 Note to: Lawrence J. Chandler Deputy Assistant Chief Hearing Counsel Office of the Executive Legal Director Frcm:
Brian K. Grimes, Director Division of Emergency Preparedness Office of Inspection and Enforcement Subj:
FEMA i.etter of October 15, 1981 At your request, I have reviewed the FEMA letter of October 15, 1981 dealing with the subject of medical services for the general public. My comments are attached.
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Brian K. Grimes Division of Emergency Preparedness Office of Inspection and Enforcement I
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flRC STAFF C0!!!!EfiTS Ofl FEf1A LETTER OF OCTOBER 15, 1981 REGARDIflG 0FFSITE 11EDICAL FACILITIES A review of the letter, dated October 15, 1981, sent by FE!!A to Judge James L. Kelley regarding FEi1A's position on the need for offsite medical facilities was performed.
We agree with the FEf1A "botton line" that no specific considerations of medical facilities for the general public are required for very large accidents and that State and local governments in such a situation would need to rely on facilities in other States, which are not explicitly provided for in the response plans, as well as those facilities which have been specifically identified for support and from which suppc,rt agreements have been obtained.
Our understanding of the FEf1A statenent regarding the need for special medical services is that it refers to the general integrated medical services system of footnote 1 to Planning Standard L of flVREG-0654/FEt1A REP-1.
To provide perspective on the FEt1A statenent in this context requires an understanding of the nature of the hazard under consideration. The nature of the hazard bearing on the need for medical facilities, in summary, can be thought of 16 several parts:
(1) non-radiation injuries to onsite workers or offsite emergency workers whose treatnent is complicated by contamination by radioactive materials.
(The criteria for preplanned nedical facilities are entirely centered around this aspect of the hazard in the flRC Staff's view.)
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2-(2) contamination by radioactive materials of emergency verkers and, in very severe accidents, menbers of the general public.
(The criteria for monitoring capabilities are centered around this aspect of the hazard while, in the NRC Staff's view, no medical facilities would be required for radiation exposures resulting fran personal contanination of, for example, clothing. Twelve hours are therefore allowed by the NUREG-0654/ FEMA-REP-1 criteria to perform monitoring of contaninated individuals at relocation centers.)
(3) life threatening exposures to a few onsite personnel or offsite emergency workers and, in very severe accidents, to menbers of the general public.
(The criteria require local nedical knowledge of radiation effects to be able to evaluate radiation exposure effects and uptakes principally for the purpose of providing support in case of onsite radiation worker accidents.
No special neasures are specified for the general public, in the NRC Staff's view, because several days would be available to arrange for medical assistance to any individuals identified on the basis of nausea synptons during the first few hours as likely to need such assistance.
No special preplanning would be needed in such a case because transportation to any facility in the U.S. could be accomplished using the resources of the Federal Government which could be nade available in the l-l unlikely event of any such catastrophe.)
Specific NRC Staff conments on the scope and applicability of each of the NUREG-0654/ FEMA-REP-1 criteria referenced in the FEf1A letter are given bel ow.
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1.
Criterion L-1 This criterion, relating to the ability to evaluate radiation exposure and uptake and handle contaminated individuals, relates only to a local and a backup hospital and, because of this limitation, was clearly not intended to apply to large numbers of individuals. The intent of the criterion was principally to assure capability to handle cases arising from radiation worker accidents.
In the NRC Staff's view, a capability to handle four to six contaninated individuals at each such hospital would be adequate.
These capabilities would be a part of the integrated energency nedical services described in footnote 1 to Planning Standard L.
2.
Criterion L-3 This criterion clearly applies to a contaminated individual who has also sustained an injury and does not apply to treating symptoms of high radiation exposures. - In the NRC Staff's view the criterion was formulated to assure that State officials had knowledge of surrounding capabilities for such treatment in case local facilities could not be used or additional facilities were required for onsite or offsite energency workers who had sustained injuries and were contaminated (e.g., a traffic accident). Such facilities, of course, would not be closed to the general public.
3.
Criterion L-4 The provision requiring capability to transport accident victims is directly related, in the NRC Staff's view, to the medical facility requirements discussed above and therefore, as a planning basis, relates only to onsite and offsite emergency workers.
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Criterion A-3 This criterion calls for written agreements for those measures required by other criteria, including the medical support organizations called for in Planning Standard L, to the extent documentation of such agreenents is called for.
5.
Criterion J-12 This criterion refers to nonitoring capabilities rather than medical services. The criterion applies to State and local organizations and states:
Each organization shall describe the means for
. registering and nonitoring of evh;uees at relocation centers in host areas. The personnel and equipment available should be capable of nonitoring within about a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period all residents and transients in the plume exposure EPZ arriving at relocation centers.
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Criterion J-10.d.
In the NRC Staff's view, this criterion does not relate to medical services directly but rather to provisions for identifying and providing special notification or other assistance to handicapped persons or making special provisions for sheltering, thyroid blocking or evacuation of institutions such as prisons. Of course, if a hospital evacuation were involved the plans would include assuring the medical well-being of the patients during transport.
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Criteria J-10.e.,f.
These criteria relating to the use of radioprotective drugs relate to the general public only insofar as a clear line of authority to decide such matters in the State is required.
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the Federal Government has been nade to stockpile or distribute such drugs to the general public.
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Criteria N.2; 0-1, 2, 3, 4, 5 Criterion N-2 involves a medical drill for only an onsite contaninated individual and only applies to the licensee and local organizations. The only specific criteria in Section 0. relating to training of nedical support personnel are item 0-4.h. and a footnote to iten 0-1.a. which do not expand the scope of support called for in the criteria discussed above.
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