ML20023D113

Position Re Commission 830405 Memorandum & Order CLI-83-10 on Offsite Medical Svcs.Util Provided Necessary Level of Medical Svcs for General Public.Declaration of Svc Encl

ML20023D113
Person / Time
Site:	San Onofre
Issue date:	05/16/1983
From:	Pigott D SOUTHERN CALIFORNIA EDISON CO.
To:
References
CLI-83-10, ISSUANCES-OL, NUDOCS 8305190252
Download: ML20023D113 (9)

Text

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d) N UNITED STATES OF AMER V CJ NUCLEAR REGULATORY COM ((

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ION 2 BEFORE THE ATOMIC SAFETY AND LTCENSING8 BOARD 7'

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A *N NI5s h v!k k In the Matter of ) NQ j_

SOUTHERN CALIFORNIA EDISON ) DOCKET NOS. 50-361 OL COMPANY, _e t _al . ) 50-362 OL (San Onofre Nuclear Generating )

Station, Units 2 and 3) )

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APPLICANTS'-POSITION RE COMMISSION'S MEMORANDUM AND ORDER CLI-83-10 ON OFFSITE MEDICAL SERVICES DAVID R. PIGOTT EDWARD B. ROGIN SAMUEL D. CASEY JOHN A. MENDEZ Of ORRICK, HERRINGTON & SUTCLIFFE A Professional Corporatio'n 600 Montgomery Street San Francisco, California 94111 Telephone: (415) 392-1122 CHARLES R. KOCHER JAMES A.-BEOLETTO SOUTHERN CALIFORNIA EDISON COMPANY P.O. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Telephone: (213) 572-1212 Attorneys for Applicants, Southern California Edison Company, San Diego Gas & Electric Company, City of Anaheim, California and 8305190252 830516 City of Riverside, California PDR ADOCK 05000361 G PDR Dated: May 16, 1983.

UNITED STATES OF ?.MERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

SOUTHERN CALIFORNIA BDISON ) DOCKET NOS. 50-361 OL COMPANY, _e t _al . ) 50-362 OL

)

(San Onofre Nuclear Generating )

Station, Units 2 and 3) )

)

APPLICANTS' POSITION RE COMMISSION'S MEMORANDUM AND ORDER CLI-83-10 ON OFFSITE MEDICAL SERVICES I

STATEMENT OF THE CASE By Initial Decision dated May 14, 1982 (LBP-82-39, 15 NRC 116 3) , the Atomic Safety and Licensing Board ("ALSB")

determined that with respect to arrangements for medical services, Applicants had not met their burden of proving that adequate medical services had been arranged as required by 10 CFR S 50.47 (b) (12) . The ASLB retained jurisdiction over the issue and allowed Applicants a six-month period of time l

within which remedial action was to be taken and reviewed by l <~

l the ASLB.

l In ALAB-680, the Atomic Safety and Licensing Appeal l

Board ("ASLAB") denied Intervenors' motion for a stay of the Initial Decision and indicated that it had serious reservations concerning the accuracy of the ASLB's inter-l j pretation of 10 CFR S 50.47 (b) (12) .

l t _-

On September ?4,1982, the Nuclear: Regulatory Commission directed certification of two issues concerning the scope of offsite medical services to be provided the general public pursuant to 10 CFR S 50.47 (b) (12) . The Commission, in response to a separate question certified to it by the ASLB, suspended all further proceedings on the medical-services issue pending its determination of the previously certified issues. (Memorandum and Order, CL 82-35.)

On April 5, 1983, by Memorandum and Order ~CLI-83-10, The Commission ruled on the certified questions concerning offsite medical services.

Pursuant to procedures agreed upon in a telephone conference of April 11, 1983, Applicants hereby submit their position with respect to satisfaction of 10 CFR S 50.47 (b)-(12) as interpreted by the Commission.

II PURSUANT TO 10 CFR S 50.47 (b) (12)

LOCAL AND REGIONAL MEDICAL FACILITIES HAVE BEEN IDENTIFIED IN THE OFFSITE EMERGENCY PLANS

, _ _ The' Commission's Memorandum and Order CLI-83-10 discusses medical services arrangements required for various

_ levels of contamination and radiation exposure. With respect to members of the general public who may suffer both a traumatic injury and contamination, it is contemplated that the medical arrangements provided for onsite and emergency workers would be available to such individuals and would be sufficient.

2

.With. respect to individuals who become injured and are also contaminated, the arrangements

'that are currently required for onsite person-nel and emergency workers provide mergency 1 capabilities which should be adequate for treatment of members of the general public.

1Therefore, no-additional medical facilities or capabilities are required.for the general public. However, facilities with which prior arrangements are made and those local or regional facilities _which have the capability 4

to treat contaminated injured individuals should be identified. (CLI-83-10, p. 2.)

This ASLB has previously determined that medical

. services for onsite and emergency workers are in place and

? adequate._ (15 NRC 1183, 1244-1245.) Pursuant to CLI-83-10, the offsite agencies have been informed which hospitals can provide medical' services to persons traumatically injured and contaminated as_the result of an emergency at San Onofre. Those hospitals will-be further identified in future. revisions of the offsite emergency plans. (cf. Letters of May 13, 1983 from F. K.

Massey of SCE-to_Carole Hopwood at Orange County; Marion Wright of San-Diego County; Ron Coleman of the City of San Clemente; and Cynthia Ferguson of San Juan Capistrano. Copies of said letters are submitted herewith as Attachments to " Applicants' Motion to Augment Record. "

With respect to members of the general public who may have experienced severe exposure and are in need of medical assistance as a result of that exposure, the Commission has recognized the medical fact that such individuals will not

-need emergency medical care. The necessary treatment can be arranged on an ad hoc basis. (CLI-83-10, pp. 11-12.) The Commission has determined that the general public will receive 3

adequate medical attention on an ad hoc basis, assuming that offsite emergency plans have identified the local medical facilities where diagnosis and treatment can be obtained and if emergency planning officials also are aware of regional facilities that can be used in the event of an emergency.

The Commission correctly concludes that " Diagnosis and treatment could take place at most existing medical facilities." (CLI-83-10, p. 12.) Applicants have surveyed the status of medical facilities in the area of San Onofre and have determined that many hospitals in the area have nuclear medicine departments accredited by the " Joint Commission on Accreditation for Hospitals." As a part of having such an accredited nuclear medicine department, it is necessary for each such hospital to have the capability to treat persons accidentally exposed cn: contaminated by radiation. Emergency departments of hospitals having nuclear medicine departments must be capable of handling raiological emergencies. Emergency department services muct relate to:

The emergency management of individuals who have actual or suspected exposure to radiation or who are radioactively contaminated. Such action may include radioactivity monitoring and measurement; designation and any required preparation of space for evaluation of the patient, including, as required, discontinuation of the air circulation system to prevent the spread of contamination; decontamination of the patient through an appropriate cleansing mechanism; and containment, labeling and dis-position of contaminated materials. (Accreditation Manual for Hospitals 1982, Joint Commission on Accreditation for Hospitals, pp. 29-30.)

2 .

Radiation decontamination facilities shall be provided whenever radioactive isotopes are used. (Ibid. p. 45) 4

• O Contemporaneous with the filing of this document, Applicants are also submitting " Applicants' Motion to Augment Record." Attached to that motion are updated portions of the Orange County _(Applicants' Exhibit No. 53) and San Diego County (, Applicants' Exhibit No. 54) emergency plans which indicate the medical facilities available to each County.

Both plans have been revised since the time of hearing. Each of the listed hospitals has an accredited nuclear medicine department pursuant to the Joint Commission on Accreditation of-Hospitals. It is Applicants' understanding that the two Counties have arrangements with the hospitals that their services will be available in the event of a nuclear emergency.

In addition to the hospitals listed in the emergency plans, Applicants have identified hospitals north of San Onofre that have accredited nuclear medicine departments and thus should be identified for purposes of implementing ad hoc

. arrangements in the event of a nuclear emergency. The appro-priate Orange County official has been advised of such facilities. (Letter of May 13, 1983 from F. K. Massey of SCE to Carole Hopwood, Manager, Emergency Management Division, General Service Agency, County of Orange, attached to Applicants' Motion to Augment Record.)

III APPLICANTS HAVE MET THE REQUIREMENTS OF 10 CFR S 50.47 (b) (12)

As described in the foregoing discussion and verified in documents attached to Applicants' Motion to Augment Record, 5

Applicants have provided the necessary level of medical services for the general public:

(1) Medical services are available to care for injured and contaminated individuals.

(2) _The offsite emergency plans for San Diego and Orange County describe the medical facilities available to provide diagnosis and treatment of radiation exposure in the event of a nuclear emergency. ,

(3) The County of Orange has been advised of additional regional facilities that could be available in the event of a nuclear emergency.

IV CONCLUSION It is submitted that Applicants have provided the requisite level of offsite medical services required by 10 CFR S 50.47 (b) (12) .

Dated: May 16, 1983. Respectfully submitted, DAVID R. PIGOTT EDWARD B. ROGIN SAMUEL-B. CASEY JOHN A. MENDEZ Of ORRICK, HERRINGTON & SUTCLIFFE A Professional Corporation CHARLES R. KOCHER JAMES A. BEOLETTO SOUTHERN CALIFORNIA EDISON COMPANY By David R. Pigott Counsel for Applicants 6

• 4 DECLARATION OF SERVICE BY MAIL I am over the age of eighteen years and not a party 1

to the above-entitled cause. My business address is 600 Montgomery Street, 12th Floor, San Francisco, California 94111 I served the foregoing APPLICANTS' POSITION RE COMMISSION'S MEMORANDUM AND ORDER CLI-83-10 ON OFFSITE MEDICAL SERVICES, APPLICANTS' MOTION TO AUGMENT RECORD and APPLICANTS' PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW, dated May 16, 1983, by depositing a true copy thereof enclosed in the United States mail or by Express Mail service, at San Francisco, California, on May 16, 1983, enclosed in a sealed envelope with postage thereon fully prepaid, addressed as follows:

Stephen F. Eilperin, Esq. *Dr. Cadet H. Hand, Jr.

Chairman, Atomic Safety and c/o James L. Kelley, Chairman Licensing Appeal Board Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Board U.S. Nuclear Regulatory Dr. Reginald L. Gotchy Commission Atomic Safety and Licensing Washingtonn, D.C. 20555 Appeal Board U.S. Nuclear Regulatory Commission *Mrs. Elizabeth B. Johnson Washington, D.C. 20555 c/o James L. Kelley, Chairman Administrative Judge

. Dr. W. Reed Johnson Atomic Safety and Licensing Atomic Safety and Licensing Board Appeal Board- U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555

• James L. Kelley, Chairman Robert Dietch, Vice President Administrative Judge Southern California Edison Co.

Atomic Safety and Licensing Board 2244 Walnut Grove Avenue U.S. Nuclear Regulatory Commission Rosemead, CA 91770 Washington, D.C. 20555

• Charles R. Kocher, Esq.

• Lawrence J. Chandler, Esq. James A. Beoletto, Esq.

Donald F. Hassell, Esq. Southern California Edison Co.

Nuclear Regulatory Commission 2244 Walnut Grove Avenue Office of the Executive Legal Rosemead, CA 91770 Director Washington, D.C. 20555

• DESIGNATES MAILING BY EXPRESS SERVICE

- , ~ - - . . , - - , - ~ , , , - - . . , , - , , , , , , - -- .~.

Mrs. Lyn Harris Hicks Mr. Lloyd von Haden GUARD 2089 Foothill Drive 3908 Calle Ariana Vista, CA 92083 San Clemente, CA 92801 James F. Davis Richard J. Wharton, Esq. State Geologist University of San Diego Division of Mines and Geology School of Law 1416 Ninth Street, Room 1341 Alcala Park Sacramento, CA 95814 San Diego, CA 92110 Phyllis M. Gallagher, Esq.

Janice E. Kerr, Esq. 1695 W. Crescent Avenue J. Calvin Simpson, Esq. Suite 222 Lawrence Q. Garcia, Esq. Anaheim, CA 92801 California Public Utilities Commission Atomic Safety and Licensing 5066 State Building Appeal Board San Francisco, CA 94102 U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Charles E. McClung, Jr., Esq.

24012 Calle de la Plata Atomic Safety and Licensing Board Suite 330 U.S. Nuclear Regulatory Commission Laguna Hills, CA 92653 Washington, D.C. 20555 Alan R. Watts, Esq. Samuel J. Chilk Rourke & Woodruff Secretary of the Commission California First Bank Building U.S. Nuclear Regulatory Commission 10555 North Main Street. Washington, D.C. 20555 Santa Ana, CA 92701 James C. Holcombe

• Louis Bernath San Diego Gas & Electric Co.

101' Ash Street San Diego, CA 92101 Executed on May 16, 1983, in the City and County of San Francisco, State of California.

I declare under penalty of perjury that the foregoing is true and correct.

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