ML20055G639
| ML20055G639 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/16/1990 |
| From: | Bachmann R NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20055G640 | List: |
| References | |
| CON-#390-10632 ALAB-924, LBP-90-12, LBP-90-20, OL, NUDOCS 9007240015 | |
| Download: ML20055G639 (4) | |
Text
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h3L JUL ! 6189)
DOCKETED l
UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION
)
RErgRE THE ATOMIC SAFETY AND LICENS b N A O.
prncE CT StCREWY 00CM litt 3. ' i iWIT
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3:e In the Matter of
)
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Docket Nos. 50-443 OL PUBLIC SERVICE COMPANY OF
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50-444 OL NEW HAMPSHIRE, 31 A1
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Off-site Emergency Planning
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(Seabrook Station,
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Units 1 and 2)
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1 NRC STAFF ANSWER IN SUPPORT OF LICENSEES' MOTION FOR
SUMMARY
DISPOSITION OF ALS ETE ISSUE Pursuant to 10 C.F.R. $ 2.749(a), the NRC Staff herewith files its answer in support of "Licenseos' Motion for Summary Disposition with Respect to the 'ALS Patients Issue'", dated June 26, 1990
(" Motion").
BACKGROUND In ALAB-924, 30 NRC 331 (1989), the Appeal Board found that it was " unable to conclude that the issue of preparaticn time has received appropriate consideration as a factor in deriving accurate ETEs for (advanced life support (ALS) patients) of the special facility population." Isl. at 351-52.
The matter was remanded to the Licensing Board "to resolve this deficiency." Isl.
In LBP 12, 31 NRC _ (May 3, 1990), and again in LBP-90-20, 31 NRC _
(June 27, 1990), the Licensing Board set forth the subissues underlying the Appeal Board's remand as follows:
(1)
How long does it take to efficiently prepare an ALS patient for transportation?
(2)
Would preparation of patients at an early initiating 9007240015 900716
)A S PDR ADOCK 05000443 G
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~2-condition, hg., declaration of an alert, or at an order to evacuate, be medically appropriate?
f (3)' How many ALS patients are there in the EPZ?
Where are the ALS patients?
only at Exeter and Portsmouth Hospitals?
(4)
Would uncertainties in the times available to prepara ALS patients for evacuation produce ETEs that are too inaccurate to be useful in the selection of protective l
action options?
LBP-90-12, slip op. at 23; LBP-90-20, slip op, at 3.
1 On June 26, 1990, pursuant to the schedule agreed upon at the prehearing conference held on June 5, 1990 (Tr. 28442-444), the Licensees filed their Motion for summary disposition of the f
remanded issue.
I pJSCUSSIO!(
l
{
i The Licensees have established, through their supporting J
\\
affidavits,I that it would take from 45 minutes to 115 minutes to l
prepare an average ALS patient for evacuation; and that. medically appropriate preparation prior to ambulance arrival would reduce the times _ to 35 minutes to 45 minutes.
Albertson Aff. at 11 6-8; l-l Callahan Aff. at il 6-8.
The Licensees further established through l
t affidavits that the maximum estimated number of ALS patients in the IAffidavit of Dr.
Donavon Albertson
("Albertson Aff.");
l-Affidavit of Kevin J. Callahan ("callahan Aff."); Affidavit of John Bonds
("Bondo Aff.");
Affidavit of Anthony M.
Callendrello
("Callendrello Aff.").
f.
EPZ is 35, 22 at Exeter Hospital and 13 at Portsmouth Regional e
Hospital.
Albertson Aff. at 1 4; Callahan Aff. at 1 4.
With t
V regard to the last subissue propounded by the Board - the choice of evacuation or sheltering of ALS patients will be made by the hospital medical staff on a case-by-case basis.
Bonds Af f, at 1 7.
The decision is made by weighing the medical risk of evacuation against the radiological risk of sheltering.
Id.
at 1 8.
Therefore, it does not depend on the accuracy of ETEs for ALS patients as a class.
The Licensees have also computed ETEs for ALS patients based on preparation times estimated by hospital officials, ambulance loading capabilities, and ambulance mobilization and travel times.
Motion at 5-8; Callendrello Aff, at 11 10-25.
The Staff reviewed the Licensees' computations and made findings as set forth in the i
attached affidavit of Thomas Urbanik II.2 The Licensees' ETE I
calculations utilized an appropriate methodology and reasonable assumptions.
Urbanik Aff, at 1 3.
Assuming that the patient preparation times provided by the two hospitals are accurate, the resulting ETEs prepared by the Licensees are reasonable.
Urbanik t
l Aff. at 1 4.
i l
p The Licensees have thus fulfilled the mandate of the Appeal Board in ALAB-924 to give the preparation time of ALS patients
" appropriate consideration" in deriving ETEs.
In addition, the 2Affidavit of Thomas Urbanik II concerning Licensees' Motion for Summary Disposition of the "ALS Patients Issue"
("Urbanik Aff.").
E J
\\ Licensees have compared the ALS ETEs to the shortest midweek 4
daytime ETE for the general population of the ERPAs involved.
Motion at 5.
Since the ETEs for ALS patients are essentially the same as those for the general po,,ulation, separate ETEs for ALS patients need not be used for planning purposes.
Motion at 8.
The Staff submits that whether this Board accepts the Licensees' assertion that the ALS ETEs may be disregarded, it is 7
clear the preparation times for ALS patients have been considered pursuant to ALAB-924.3 Accordingly, the Licensees' Motion should be granted.
Respectfully submitted, Richard G.
Bachmann Counsel for NRC Staff
)
Dated at Rockville, Maryland this 16th day of July, 1990 l
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3 If the 1.icensing Board deems ic necessary, it wr>uld be a simple matter for the Licensees tea include the ALS ETEs in t: heir ETE Study and to provide them to the two hospitals.
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