ML20027C509
| ML20027C509 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/14/1982 |
| From: | Chandler L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | NRC COMMISSION (OCM) |
| References | |
| ISSUANCES-OL, NUDOCS 8210180095 | |
| Download: ML20027C509 (24) | |
Text
.!
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION BEFORE THE COMISSION In the Matter of
)
SOUTHERN CALIFORNIA EDIS0N COMPANY, Docket Nos. 50-361 OL ET AL.
50-362 OL (San Onofre Nuclear Generating
)
j Station, Units 2 and 3)
)
NRC STAFF'S BRIEF REGARDING MEDICAL SERVICES ISSUES CERTIFIED BY COMISSION ORDER i
l Lawrence J. Chandler Deputy Assistant Chief Hearing Counsel l
l Dated: October 14, 1982 DESIGNATED ORIGINAL O
Certified By
~b567 8210180095 821014 PDR ADOCK 05000361 G
PDR L
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of SOUTHERN CALIFORNIA EDIS0N COMPANY, Docket Nos. 50-361 OL ET AL.
50-362 OL (San Onofre Nuclear Generating
)
Station, Units 2and3)
)
NRC STAFF'S BRIEF REGARDING MEDICAL SERVICES ISSUES CERTIFIED BY COMMISSION ORDER Lawrence J. Chandler Deputy Assistant Chief Hearing Counsel Dated: October 14, 1982 f
1
(
i o
y-
,.-e,.
TABLE OF CONTENTS fage_
TABLE OF AUTHORITIES....................................
11
~
I.
INTR 000CTION............................................
1 II.
BACKGR0VND..............................................
2 III. DISCUSSION..............................................
5 A.
FIRST CERTIFIED QUESTION...........................
5 1.
Case 1aw......................................
5 2.
Commission regulations........................
7 3.
Guidance documents............................
8 4.
Conclusion....................................
11 B.
SECOND CERTIFIED QUESTI0N..........................
11 IV.
CONCLUSION..............................................
17 l
i l
9
- ii -
TABLE OF AUTHORITIES Page Commission Decisions
~
Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit No.1),
LBP-81-59,14NRC1211(1981)..........................
5, 6 Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2),
LBP-82-70, NRC
,(August 31,1982)..............
6 Pennsylvania Power and Light Company and Allegheny Electric Cooperative, Inc.,
(Susquehanna Steam Electric Station, Units 1 and 2), LBP-82-30, 15 NRC 771 (1982)...........
6 South Carolina Electric and Gas Company (Virgil C. Summer Nuclear Station, Jnit 1),
LBP-82-57, NRC
,(August 4,1982)...............
6 Southern California Edison Company, et al.
(San Onofre Nuclear Generating Station, Units 2 and 3), ALAB-680, NRC (July 16, 1982)........................................
3, 5, 12 Southern California Edison Company, et al.
(San Onofre Nuclear Generating Station, Units 2 and 3, LBP-82-39, 15 NRC 1163 (1982)...........
3, 4, 6, 12 Southern California Edison Company, et al.
(San Onofre Nuclear Generating Station, Units 2 and 3, LBP-82-3, 15 NRC 61 (1982)..............
4 Regulations 10 C.F.R. 6 50.47(b)(12)...............................
passim 10 C. F. R. Pa rt 50, Appendix E..........................
7, 8 10 C.F.R. 5 2.764(f)...................................
4
- iii -
Page Federal Register 45 Fed. Reg. 55402.....................................
7, 8 44 Fed. Reg. 75167.....................................
8 44 Fed. Reg. 61123.....................................
7 38 Fed. Reg. 1272................!*....................
7
~
35 Fed. Reg. 19568.....................................
7 Miscellaneous Documents NUREG-0654.............................................
9, 10, 14, 16 NUREG-0472.............................................
9 NUREG-0396.............................................
8, 9 NUREG-75/111...........................................
9 REGULATORY GUIDE 1.101.................................
9 f
4 e
G
10/14/82 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of SOUTHERN CALIFORNIA EDIS0N COMPANY,)
)
50-362 OL (San Onofre Nuclear Generating Station, Units 2 and 3)
)
NRC STAFF'S BRIEF REGARDING MEDICAL SERVICES ISSUES CERTIFIED BY COMMISSION ORDER I.
INTRODUCTION By Order dated September 24, 1982, CLI-82-27, the Commission directed the Atomic Safety and Licensing Appeal Board to certify to the Commission two issues regarding the scope of the requirements of 10 C.F.R. 6 50.47(b)(12) calling for arrangements for medical services for contaminated injured individuals. Specifically, the issues on which certification was directed are:
(1) Does the phrase " contaminated injured individuals" as used i
in 10 CFR 50.47(b)(12) require applicants for nuclear power plants j
to provide arrangements for medical services only for members of the j
public who have suffered traumatic injury and are also contaminated with radiation?
i l
l (2)
If the anwer to Question 1 is no, to what extent does 10 l
CFR. 6 50.47(b)(12) require advance, specific arrangements and I
commitments for medical services for the general public as opposed to the general knowledge that facilities and resources exist and could be used on an acl hoc basis?
The Commission invited interested parties to submit briefs on the i
foregoing issues within twenty days of the date of its Order.
n
, II. BACKGROUND By stipulation among tbc parties to this operating license proceeding, a contention was admitted as follows:
Contention 2:
Whether there is reasonable assurance that the emergency response planning and capability of implementation for S0flGS 2 and 3, affecting the offsite transient and permanent population will comply with 10 C.F.R. 6 50.47(a)(1) and (b) or (c)(1) as regards:
D.
The arrangements for medical services for contaminated and injured individuals, 10 C.F.R. 9 50.47(b)(12).
During the course of the hearing, argument was had on the admission of testimony being offered by Intervenors' witness, Dr. Lyons, raising the question of the scope of the above contention and the referenced regulation in terms of requiring arrangements for medical services for members of the general public (Tr. 9634-9665). The Atomic Safety and Licensing Board then determined that it would receive testimony on the need for such arrangements, ruling that the provisions of 10 C.F.R.
l 6 50.47(b)(12) were to be extended to the general public (Tr. 9666-9670).
In addition, the Licensing Board, on the record, inquired of FEMA whether in its view, specific arrangements need to be made for medical services for people within the 10-mile plune exposura pathway EPZ who may i
be contaminated, suffering from radiation or both.
By letter from 1
Marshall E. Sanders, Acting Chief, Technological Hazards Division, Office l
of Natural and T1.chnological Hazards, FEMA, to Licensing Board Chairman Kelley, dated October 15, 1981, FEMA expressed its view generally supporting the proposition that arrangements for medical services are required.
. The rationale for the Licensing Board's on-the-record ruling was later articulated in its Initial Decision of May 14,1982(LBP-82-39,15NRC 1163, 1186-1200, 1245-1247 (1982).
In that Decision, the Licensing Board concluded, inter alia, that 10 C.F.R. 6 50.47(b)(12) " requires applicants
~
and offsite jurisdications to develop and stand ready to implement arrangements for medical services for members of the offsite public who may be injured in a serious accident."
(Id. at 1199). No appeal from thisdeterminationwastakenbyanyparty.3/
The Atomic Safety and Licensing Appeal Board, in its Decision denying Intervenors' application for a stay of the Licensing Board's
, Initial Decision, expressed " serious doubts that the Board's reading [of 10 C.F.R. 9 50.47(b)(12)] is accurate."
(ALAB-680, NRC
, slip op.
at 15-21, July 16,1982). The Appeal Board also opined that the pertinent regulation makes a real and deliberate distinction between
" contaminated injured" individuals and " members of the general public who may have suffered radiation exposure in a nuclear accident" (Id. at 16),
and suggests that the former, narrower reading is that which is contem-plated by the regulation rather than the latter, broader reading given by the Licensing Board.
l 1
--1/
Intervenors' appeal from the Initial Decision as it relates to Contention 2.D. is limited to the Licensing Board's condition, allowing a period of six months after commencement of full power operation in which such arrangements must be made and found acceptable. The Licensing Board retained jurisdiction of the issue of the adequacy of the arrangements made.
(
1
. Subsequent to the Appeal Board's decision,2/ the Licensing Board, in accordance with its Initial Decision and pursuant to the jurisdic-tion it expressly retained over the medical services issue, solicited responses from the parties on specific questions regarding the need for
~
and scope of any further hearing on this matter. Memorandum and Order (Concerning Whether Further Proceedings on the Adequacy of Offsite Planning for Medical Services Should Be Conducted), August 6,1982.
Responses were filed by all parties on September 3,1982.3_/
Against this background, the NRC Staff responds to the questions which the Comission directed be certified to it.
-2/
On July 16, 1982, the Comission issued an Order, pursuant to 10 C.F.R. 9 2.764(f), declining to stay the effectivenss of the Licensing Board's Partial Initial Decision, LBP-82-3,15 NRC 61 (1982), or Initial Decision, supra, thus paving the way for issuance of an operating license authorizing full power operation for San Onofre Nuclear Generating Station, Unit 2.
By Amendment No. 7 to Operating License No. NPF-10, issued on September 7, 1982, full power operation was authorized.
In its "immediate effectiveness" Order, the Comission specifically provided that it would conduct a i
subsequent review, pursuant to 10 C.F.R. 6 2.764(f), of the l
Licensing Board's future decision on the is' sue of medical services over which the Licensing Board had retained jurisdiction.
-3/
By Memorandum and Order (Setting Medical Arrangements Question for Hearing), dated October 1,1982, the Atomic Safety and Licensing Board directed that a hearing will be held to consider the adequacy of arrangements made for medical services for the general public, in l
accordance with its Initial Decision of May 14, 1982, LBP-82-39. By Memorandum and Order (Certifying a Question to the Commission),
dated October 5,1982, the Licensing Board sought direction from the Comission as to whether, in view of the Comission's Order directing certification, supra, it wished the Licensing Board to go fomard with its hearing.
I l
l
. III. DISCUSSION A.
The first certified question is:
(1) Does the phrase " contaminated injured individuals" as used in 10 C.F.R. 50.47(b)(12) require applicants for nuclear power plants to provide arrangements for medical services only for members of the public who have suffered traumatic injury and are also
~
contaminated with radiation?
As discussed below, it is the Staff's position that the phrase
" contaminated injured individuals" as used 10 C.F.R. 6 50.47(b)(12) requires that applicants demonstrate that suitable arrangements have been made for medical services for onsite and other emergency workers who are traumati-cally injured and are also contaminated with radiation; such injuries may
[includesevereradiationexposures. This regulation does not require applicants to make arrangements for medical services for the general public. While this requirement initially provides for a relatively small number of individuals, it provides an adequate emergency planning base from which broader arrangements can, if necessary, be made on an act hoc basis as discussed below in response to the seco.id certified question.
1.
Case law A review of Commission case law provides little help in under-standing the scope of 10 C.F.R. 6 50.47(b)(12). This regulation has re-ceived no explicit consideration by the Commission in the context of any licensing proceeding, nor has the Appeal Board spoken on the matter except in regard to this proceeding, in ALAB-680.
It has been addressed, however, in several recent Licensing Board decisions in addition to San Onofre.
The Licensing Board in San Onofre correctly observed that the decision in Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1), LBP-81-59, 14 NRC 1211 (1981), appears to assume 4
. that arrangements are required for members of the general public.
(San Onofre,15NRCat1195-1196) That decision does not attempt, however, to analyze the requirements of 10 C.F.R. 6 50.47(b)(12) in terms of specifically defining either the population to be provided for or the
~
scope of arrangements to be provided.
It does discuss the adequacy of general arrangements for radiation treatment for the public.
(See,TMI-1, 14NRCat1656-1663).
The TMI-1 decision is the only decision of which we are aware which implies that treatment of severe radiation exposure of members of the general public is contemplated by 10 C.F.R. 6 50.47(b)(12), as the
, Licensing Board determined in San Onofre.4/
~
-4/
The Licensing Board decisions in Pacific Gas and Electric Company (DiabloCanyonNuclearPowerPlant, Units 1and2),LBP-82-70, NRC -
, August 31, 1982, slip op. at 60-61, 178-183, South Carolina"liTectric and Gas Company (Virgil C. Summer Nuclear Station, Unit 1),LBP-82-57, NRC
, August 4, 1982, slip op. at 14-16, and Pennsylvania Power and Light Company and Allegheny Electric Cooperative. Inc. (Susquehanna Steam Electric Station, Units 1 and 2), LBP-82-30, 15 NRC 771, 801-802 (1982), also touch on the question of arrangements for medical services. Again, however, none of the decisions addresses the scope of 10 C.F.R. 6 50.47(b)(12).
t f
Rather, each appears to evaluate the adequacy of arrangements for I
decontaminating members of the public, not for the treatment of severely exposed members of the general public as determined necessary in the San Onofre decision, supra. It is, however, worth noting in this regard, that the state of preparedness in the jurisdictions of concern in connection with San Onofre seems to be comparable.
(See, e.g., Orange County Plan, A 53, IV. A.2.(2), (3) at IV-2-IV-3; IV. A.5.b.(5)pplicants Exhibit No.
at IV-8; and, V.C.3.e. and f. at V-38-V-41; San Diego County Plari, Applicants Exhibit No. 54, V.F. at V-6; XI.C. at XI-2; XIV.B at XIV-1 (see also XIV-3); and Appendix, Department of Health Services at XIV-4-XIV-6; and, State of California Plan, Intervenors Exhibit No. 23, V.F. at 49-51.
l
. f 2.
Commission regulations The' Commission's emergency planning regulations prior to promulgation of upgraded emergency planning regulations in 1980, 45 Fed.
Reg. 55402, were embodied in Appendix E to 10 C.F.R. Part 50. As rele-
~
vant to the certified questions, the requirement was there imposed on applicants to make provisions for:
VI.
F.
Emergency first aid and personnel decontamination facilities, including:
1.
Equipment at the site for personnel monitoring; 2.
Facilities and supplies at the site for decontamination of personnel; 3.
Facilities and medical supplies at the site for appropriate emergency first aid treatment; 4.
Arrangements for the services of a physician and other medical personnel qualified to handle radiation emergencies; and 5.
Arrangements for transportation of injured or contaminated individuals to treatment facilities outside the site boundary; G.
Arrangements for treatment of individuals at treatment facilities outside the site boundary.
(35 Fed. Reg. 19568, as amended at 38 Fed. Reg. 1272; emphasis added).
Two things are obvious in the above-quoted provisions:
first, that the thrust of the regulation is directed at onsite requirements and planning, I
and, second, that the language in F.5 therein, subsequently replaced by amended Appendix E, IV.E.6, was written disjunctively, that is, arrangements were then required for transportation of " injured or contaminated" individuals to treatment facilities offsite; the word I
e
_8_
"or", in the present regulations is absent without explanation.5/
The Statements of Considerations accompanying both the proposed rule and the promulgation of the upgraded emergency planning regulations, 45 Fed. Reg. 55402, are otherwise silent as to specific Coninission consideration of the medical services requirement.
3.
Guidance documents Consistent with the Staff's position is NUREG-0396, Planning i
Basis For The Development of State and Local Government Radiological Emergency Response Plans In Support of Light Water Nuclear Power Plants, December 1978, which was endorsed by the Commission in October 1979 (44 Fed. Reg. 61123).
In particular, NUREG-0396 describes the concept of Emergency Planning Zones (EPZs) and the planning basis for them.
4 Relevant to the certified questions:
The Task Force does not recommend that massive emergency preparedness programs be established around all nuclear power stations. The following examples are given to further clarify the Task Force guidance on EPZs:
No special local decontamination provisions for the general public (e.g., blankets, changes of clothing, food, special showers) 1 No stockpiles of anti-contamination equipment for the general public No construction of specially equipped fallout shelters No special radiological medical provisions for the general public i
No new construction of special public facilities for emergency use I
No special stockpiles of emergency animal feed No special decontamination equipment for property and equipment
-5/
Curiously, "or" does appear in the initially proposed upgraded rule, in Appendix E.IV.E.6 (44 Fed. Reg. 75167). One could read the omission of "or" to signify that the planning required is for l
individuals who are contaminated as well as injured and that it is not required for individuals who are only physically injured.
,_..,-m.-
___,,_m.-
r -,, _.,
1
' No participation by the general public in test exercises of emergeacy plans.
Some capabilities in these areas, of course, already exist under the general emergency plans of Federal and State agencies.
(NUREG-0396 at14-15).
The continuing applicability of NUREG-0396 is evidenced in the upgraded Appendix E (footnote 2).
NUREG-0654, the current principal guidance for the upgraded rules, expressly supersedes NUREG-75/111 and Regulatory Guide 1.101 (NUREG-0654, Rev. 1 at 5).6/ Those documents, being of pre-TMI-2 accident vintage, have clearly been overtaken by events, the Commission placing new and greater emphasis on emergency preparedness in the post-TMI-2 era, parti-cularly in regard to requirements for offsite planning.
Although a review of NUREG-0654 is not wholly satisfying, direction can be found. The requirements of 10 C.F.R. 9 50.47(b)(12) are addressed by the criteria of Planning Standard L in NUREG-0654 (at 69). A perspec-tive on these criteria is given by section H of the Introduction of NUREG-0654 which makes clear that, althougi) a licensee has the primary responsibility for onsite emergency preparednass, "it is a necessary part of the facility eme'gency planning to make advar.ce arrangements with State and local organizations for special emergency assistance such as
-6/
See also, NUREG-0472/ FEMA-REP 4, Joint Review of Coments, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, April 1981, at I-2.
This document, which presents comments on NUREG-0654 (January 1980) and the joint responses of the NRC and FEMA, resulting in the issuance of NUREG-0654, Rev.1 (November 1980),
l does not shed any light on the certified issues. All references herein to NUREG-0654 are to NUREG-0654/ FEMA-REP-1, Rev. 1 (November 1980), Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. Revision 2 to Regulatory Guide 1.101 (October 1981) now references NUREG-0654.
9
. ambulance, medical, hospital, fire and police services."
(NUREG-0654 at25). This then suggests that the " State" and " Local" planning
" requirements" imposed by Planning Standard L are intended to be supportive of the licensee's onsite planning and are not intended to
~
expand such requirements to the general public offsite.
Additional support is found from a reading, irl pari materia, of Planning Standard K and L.
Planning Standard K, specifically in paragraphs 5 and 7, requires the establishment of means for radiological decontamination of emergency personnel as well as the provision of the capability for decontaminating relocated onsite personnel.
Properly
, read, Planning Standard L carries forward on these requirements for onsite personnel and emergency workers by providing for other types of medical services for these individuals who are also injured; it is directed at assuring that necessary medical service facilities are capable of handling injured personnel who are also contaminated, recog-nizing that additional knowledge is required and precautions must be taken in treating them - e.g. in the handling and disposal of contami-nated clothing and medical equipment and personal protection for the individuals providing the medical services. To this purpose one may look to the more general medical services developed under public health plans (See, footnote 1 to Planning Standard L).
Further support for the Staff's position is found in NUREG-0654, Planning Standard N. Exercises and Drills. As relevant to the Commission's inquiries, 1 2.c provides:
. c.
Medical Emergency Drills A medical emergency drill involving a simulated contaminated individual which contains provisions for p(articipation by the local support services agencies i.e., ambulance and offsite medical treatment facility) shall be conducted annually. The offsite portions of the medical drill may be performed as part of the required annual exercise.
No provision is made which bears on medical services for the general public; this provision, in the Staff's view, is directed solely to the transportation and treatment of an onsite or emergency worker at offsite facilities (See also, footnote 1 to Planning Standard 0.
Radiological Emergency Response Training). Since the purposes of exercises and drills are to evaluate major portions of emergency response capabilities and develop and maintain skills (Planning Standard N), the omission of any provision suggesting the need for such activities as they relate to the general public is significant.
4.
Conclusion In conclusion,10 C.F.R. Q 50.47(b)(12) does not require arrangements for medical services for the general public.
B.
The second certified question reads:
(2) If the answer to Question 1 is no, to what extent does l
10 C.F.R. 6 50.47(b)(12) require advance, specific arrangements and commitments for medical services for the general public as opposed to the general knowledge that facilities and resources exist and couldbeusedonanajihocbasis?
In light of the Staff's response to the first certified question, it is the Staff's position that, as a consequence of the requirements that are imposed by the Commission's regulations, an adequate emergency planning base exists to enable arrangements for medical services for the general public to be made on an aji hoc basis.
The arrangements required for onsite and emergency workers discussed above could be called upon to directly provide for the needs of limited
=--T+
~ " -
12 -
numbers of the general public who may need medical services. More significantly, however, the arrangements made in tenns of hospital and transportation facilities, the services of physicians, and training allow for an orderly expansion to acconinodate the larger needs of the general public. A review of the emergency plan for Orange County (Applicants Exhibit No. 53) is illustrative. This plan, in both its text and figures, identifies and locates available hospital resources (at V-30),
transportation (at V-12-V-15) and training (at V-44-V-47).
It further identifies persons (by title and function) who have the responsibility for coordinating such resources on a local, state and federal level.
(See, generally,Section IV).
Most significant to the rationale of ad hoc planning for medical services for the general public is the fact that ininediacy of action is not a factor in connection with either decontamination or treatment of severe radiation exposure. As the Licensing Board found, severe radiation exposure follows a reasonably predictable course evolving over a week or more (Initial Decision 114-5, 15 NRC at 1245; also, ALAB-680, slip op. at 16 (n.1),17-18), allowing for the identification of exposed I
persons, the initiation of a medical history, and the arrangement of appropriate, adequate care. Such care need not be provided locally but, rather, because of the time available, could be arranged anywhere in the country.
(See, Initial Decision, 19, 15 NRC at 1246).
d hoc planning thus can better provide for specific needs as they are identifed without an unreasonable commitment of resources - in terms of expensive, dedicated facilities and personnel - prior to ascertaining the nature and magnitude of the need.
.y m
. Further support for the Staff's position, we believe, may be found in FEMA's October 15, 1981 letter, previously referred to. The Licensing Board had posed a second question to FEMA regarding what consideration is given very low probability high-consequence accidents, commonly referred to as Class 9 accidents, in the context of whether arrangements for medical services for the public are required. FEMA, in its October 15th response stated (at 3-4):
Class 9 accidents are commonly understood to indicate nuclear power plant accidents involving a core melt down. As indicated earlier, the planning and preparedness guidance provided in NUREG-0654 for the provision of medical services to contaminated (injured) persons applies to all four classes of emergency action levels as described in Appendix 1.
The fourth class level, " General Emergency," involves the actual or imminent substantial core degradation or melting with the potential for loss of containment."
(Page 1-3)
In response to your specific question, general guidance is provided for the provision of medical services for " General Emergencies." No specific considerations, however, are provided for a class 9 accident.
If such an accident occurred and if the accident resulted in a large number of persons being contaminated by excessive levels of radia-tion, State and local governments would have to rely upon identiffed medical support organizations in an area beyond the EPZs for the plant where the accident occurred and even other States with facilities that have the required capabilities and resources.
Such support is already anticipated in the guidance provided in NUREG-0654/ FEMA-REP-1. State and local governments are expected to document such support by providing written agreements in their emergency response plans. Also, all medical organizations which are party to such agreements would assure that their emergency perscnnel were trained to cope with such a scenario. Participation in annual exercises and periodic drills would constitute a significant part of a training program.
Although not h from doubt, the Staff understands the foregoing to mean that whil pecific arrangements are required for a low probability, equence event, which is within the class of events L
triggering a " General Emergency" (see NUREG-0654, Appendix 1 at 1-16 to 1-19), State an>., local jurisdictions may rely, on an ad hoc basis, on the planning in place for lower class events as a base from which arrange-ments made can be expanded.
If one then looks to the next lower class,
~~
" Site Area Emergency," it is clear that no arrangements for medical services for the general public are called for since that level of emergency does not involve releases exceeding EPA Protective Action Guideline exposure levels except near the site boundary (NUREG-0654 at 1-12), hence, offsite individuals would not be expected to be contaminated or severely exposed.
The Staff has provided its views on the FEMA letter to the
,J Licensing Board:
To provide perspective on the FEMA statement 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 in several parts:
(1) non-radiation injuries to onsite workers or offsite emergency.
workers whose treatment is complicated by contamination by radioactive materials.
(The criteria for preplanned medical facilities are entirely centered around this aspect of the hazard in the NRC Staff's view.)
i (2) contamination by radioactive materials of emergency workers and, in very severe accidents, members 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 from personal contamination of, for example, clothing. Twelve hours are therefore allowed by the NUREG-0654/ FEMA-REP-1 criteria to perform monitoring of contaminated individuals at relocation centers.)
(3) life threatening exposures to a few onsite personnel or offsite emregency workers and, in very severe accidents, to members of the general public.
(The criteria require local medical 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, l
l
.-m...
. No special measures 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 symptoms 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 made available in the
~
unlikely event of an,v such catastrophe.)
(NRCStaffComments on FEMA Letter of October 15, 1981 Regarding Offsite Medical Facilities, attached to letter from Lawrence J. Chandler, Aeputy Assistant Chief Hearing Counsel, to Licensing Board, ated November 16,1981.)
FEM,,'s position on this issue was recently confirmed in a memorandum from Richard W. Krimm, Assistant Associate Director, Office of Natural and Technological Hazards, FEMA, to Brian Grimes, Director, Division of Emergency Preparedness, NRC, dated September 3,1982 (attached to NRC Staff's Response to Licensing Board's Memorandum and Order (Concerning Whether Further Proceedings On The Adequacy Of Offsite Planning For Medical Services Should Be Conducted), September 3,1982). As pointed out therein, "The medical services being called for here are those predominantly of medical staff knowledge and capability to handle the additional factor of radiological contamination or exposure."
(FEMA response to Question 2 at 2.) Further, with respect to what arrangements it believes to be necessary, FEMA states that " Decontamination facilities and monitoring equipment would be necessary along with trained and knowledgeable staff.
Planning, training and pre-established procedures are clearly a need. The arrangements for beds, special medicines, if any, and perhaps the need for isolation could be handled on an ad ho basis."
(FEMA response to Question 3 at 2.)
f Viewed in the context of the foregoing, the Staff's position 1: not inconsistent.
" Medical staff knowledge and capability to hanale tFe C
. additional factor of radiological contamination" as well as " Monitoring equipment" are already accounted for in NUREG-0654, Planning Standard J.12, which requires, with respect to the State and local jurisdictions, that:
- 12. Each organization sFall describe the means for registering and monitoring of evacuees at relocation centers in host areas. The personnel and equipment available should be capable of monitoring 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.
Offsite " decontamination facilities" are required by Planning Standard K.7 which requires that:
7.
Each licensee shall provide the capability for decontaminating relocated onsite personnel, including provisions for extra clothing and decontaminants suit-able for the type of contamination expected, with particular a oftheskin.gentiongiventoradioiodinecontamination Additionally, Planning Standard L.3 requires the development of a list of medical facilities capable of providing for any contaminated injured individual.
Thus, those matters for which FEMA believes arrangements should be made are in fact made, albeit in a different context, and can be expanded on an a_d hoc basis, to accommodate the general public. As to additional l
measures - e.g., beds, special medicines, isolation - FEMA, too, recog-nizes that such arrangements can be made on an g hoc basis.
(FEMA response to Question 3).
Accordingly, to the extent that arrangements for medical services for the general public are not provided for, they can be made on an a_d_
i l
hoc basis.
7/
Relocation centers often designated are schools which may have shower facilities which under proper guidance, could be used for decontamination of the evacuated members of the general public.
O f
. IV. CONCLUSION For the foregoing reasons, the Stef f believts that (1) no advance planning is required by 10 C.F.R. 9 50.47(b)(12) for medical services for members of the general public and (2) that Juch arrangments which may be
~
necessary are most effectively made on an g hoc basis.
Respectfully submitted, 21 W$
Lawrence J. Chandler Deputy Assistant Chief Hearing Counsel Dated in Bethesda, Maryland this 14th day of October 1982 O
- -, - - ~, - - - - - - - -
D
~
UNITED STATES OF AMERICA NUCLEAR REGULATORY COP #11SSION BEFORE THE COMMISSION In the Matter of
)
SOUTHERN CALIFORNIA EDIS0N COMPANY, Docket Nos. 50-361 OL
_ET _AL.
)
50-362 OL
)
(San Onofre Nuclear Generating
)
Station, Units 2 and 3)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S BRIEF REGARDING MEDICAL SERVICES IS CERTIFIED BY COMMISSION ORDER"_.in the above-captioned proceeding have been serve on the 'following by deposit in the United States mail, first class, as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, or as indicated by double asterisk by hand-delivery, this 14th day'of October 1982:
Stephen F. Eilperin, Esq., Chairman Atomic Safety and Licensing Appeal Dr. Cadet H. Hand, Jr.,
Board Administrative Judge U.S. Nuclear Regulatory Commission c/o Bodega Marine Laboratory University of California Washington, D.C.
20555*
P. O. Box 247 Dr. Reginald L. Gotchy Bodega Bay, California 94923 Atomic Safety and Licensing Appeal Mrs. Elizabeth B. Johnson, Board U.S. Nuclear Regulatory Commission Administrative Judge
.Weshington, D.C.
20555*
Oak Ridge National Laboratory P. O. Box X, Building 3500 Dr. W. Reed Johnson Oak Ridge, Tennessee 37830 Atomic Safety and Licensing Appeal Janice E. Kerr, Es Board J. Calvi'n Simpson,q.Esq.
i U.S. Nuclear Regulatory Commission Washington, D.C.
20555*
Lawrence Q. Garcia, Esq.
CA. Public Utilities Commission 2;,nes L. Kelley, Esq., Chairman 5066 State Building Administrative Judge San Francisco, CA 94102 Atomic Safety and Licensing Board
- Samuel J. Chilk U.S. Nuclear Regulatory Commission Secretary to the Commission Washington, D.C.
20555*
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 1i:
-.___._.,,,_-e____
.r_,_,.__,_
Alan R. Watts, Esq.
David R. Pigott, Esq.
Daniel K. Spradlin Samuel B. Casey, Esq.
Rourke & Woodruff John A. Mendez, Esq.
10555 North Main Street Edward B. Rogin, Esq.
Suite 1020 Of Orrick, Herrington & Sutcliffe Santa Ana, California 92701 A Professional Corporation 600 Montgomery St.
Gary D. Cotton San Francisco, California 94111 Louis Bernath San Diego Gas & Electric Company Richard J. Wharton, Esq.
101 Ash St., P. D. Box 1831 University of San Diego School San Diego, California 92112 of Law, Alcala Park San Diego, California 92110 A. S. Carstens 2071 Caminito Circulo Norte Charles R. Kocher, Esq.
Mt. La Jolla, California 92037 James A. Beoletto, Esq.
Southern California Edison Company Atomic Safety and Licensing Board 2244 Walnut Grove Avenue U.S. Nuclear Regulatory Commission Rosemead, California 91770 Washington, D.C.
20555*
Phyllis M. Gallagher, Esq.
Atomic Safety and Licensing Appeal 1695 West Crescent Avenue Panel Suite 222 U.S. Nuclear Regulatory Commission Anaheim, California 92701 Washington, D.C.
20555*
Charles E. McClung, Jr., Esq.
Secretary Fleming, Anderson, McClung & Finch U.S. Nuclear Regulatory Commission 24012 Calle de la Plata ATTN:
Chief, Docketing & Service Suite 330 Branch Laguna Hills, California 92653 Washingtcn, D.C.
2055E*
Mrs. Lyn Harris Hicks GUARD 3908 Calle Ariana San Clemente, California 92672
' Lawrence J. Chandler Deputy Assistant Chief Hearing Counsel 9
. __