ML20058K773
| ML20058K773 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/26/1990 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20058K778 | List: |
| References | |
| CON-#390-10570 ALAB-924, LBP-90-12, OL, NUDOCS 9007110192 | |
| Download: ML20058K773 (13) | |
Text
.
OI "uY*'"
g g g p3*.fMne 26, 1990 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSIOq c,mu v before the
'H ATOMIC SAFETY AND LICENSING BOARD In the Matter of PUBLIC SERVICE COMPANY Docket Nos. 50-443-OL OF NEW HAMPSHIRE, 3.t 3.1 50-444-OL (Seabrook Station, Units 1 (Offsite Emergency and 2)
Planning Issues)
LICENSEES' MOTION FOR
SUMMARY
DISPOSITION WITH RESPECT TO THE HAL8 PATIENTS ISSUEH Pursuant to 10 C.F.R. 5 2.749, on the basis of the affidavits of Anthony M. Callendrello, Kevin J. Callahan, Dr. Donavon Albertson, and John Bonds, filed herewith, and for the reasons set forth below, the Licensees move that the Licensing Board summarily dispose of the so-called "ALS patients issue" and find that the time for preparing ALS patients for transport has been adequately considered as a part of the planning basis for the ETEs at Seabrook Station.
Reasons for Grantina the Motion In Public Service Company of New Hamoshire (Seabrook Station, Units 1 and 2), ALAB-924, 30 NRC 331 (1989), the Appeal Board questioned whether the time necessary to prepare advanced ALSMODIS.SB O
s
O life support (Als) patients for transportation had been adequately taken into account in the planning basis for evacuation time estimates (ETEs) contained in the New Hampshire Radiological Emergency Response Plan (NHRERP).
ALAB-924 at 351.
In Public Service comoany of New Hamoshire (Seabrook Station, Units 1 and 2), LBP-90-12, 31 NRC (May 3, 1990), this Licensing Board further addressed this matter and articulated the precise subissues to be resolved with respect to the matter 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 condition, gig., declaration of an alert, or at an order to evacuate, be medically appropriate?
(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 prepare ALS patients for evacuation produce ETEs that are too inaccurate to be useful in the selection of protective action options?
The affidavits filed herewith address each of these specific questions as well as the overall question as to whether the loading times have been adequately considered in the ETE planning basis for the NHRERP.
Beginning with the third of the specific questions listed above, the affidavits establish that an appropriate basis for analysis would assume that at the time of an emergency there would be present in the EPZ a total of 35 ALS patients (22 at
'LBP-90-12, slip op. at 23.
0 2
3 Exeter Hospital and 13 at Portsmouth Regional Hospital ), and this would occur during the day on week days.'
Turning next to the first specific question, that of preparation times, the affidavits reveal the following.
At Exeter Hospital the average preparation time for an ALS patient is 115 minutes, 70 minutes of which can be accomplished prior to ambulance arrival, leaving a final preparation and loading time of 45 minutes.'
In the case of Portsmouth Regional Hospital, the average preparation time for an ALS patient is 45 minutes, 10 i
l minutes of which can be accomplished prior to ambulance arrival, leaving a final preparation and loading time of 35 minutes.6 As to the second specific question, 1.a., the possible commencement of patient preparation at an earlier time, the affidavits reveal the following.
The Portsmouth Regional Hospital will use existing internal operational procedures and i
protocols to ensure 24-hour staffing for emergency conditions.7 Exeter Hospital commences calling in staff for an emergency at 2Callahan Affidavit 1 4.
3Albertson Affidgyli 1 4.
'This is so because elective surgery is generally not performed on weekends or off hours and therefore the maximum ALS patient count logically will occur on week days.
Callahan Affidavit 1 4; Albertson Affidavit 1 4.
Sca11ahan Affidavit 11 6-8.
'Albertson Affide.vit 11 6-8.
7Albertson Affidavit 1 14.
L o
seabrook at the Site Area Emergency classification.8 And the two hospital plans now provide for initiation of assembly of patients as medically appropriate upon receipt of the recommendation to evacuate which will maximize the number of patients available for evacuation upon arrival of the first ambulances.'
As to the fourth specific question, i.e., whether the inherent uncertainties as to ALS patient evacuation times at any given point in time make ETEs for such patients of no use in the planning process, the affidavits reveal that that is the case.
The emergency plans of both of the hospitals provida for the decision on ALS patient protective actions (s. g., evacuation) to be made by the medical staff on a case-by-case basis and without reference to the ETE for that individual, and this fact combined with the limited number of ALS patients make the ETE for these I. arsons an imprudent base from which to formulate protective action recommendations (PARS) for the individual ALS patient or the entire hospital."
Prescinding from the specific questions articulated by this I
Board in LBP-90-12, the affidavits also reveal the following:
First, even if one assumes that the ETEs for these individuals are significantly longer than the relevant ETEs for the general acallahan AffidavLt 1 11.
'E2nds Affidavit 1 5.
10Bonds Affidavit 1 7; Callendrello Affidavit 1 9.
" Bonds Affidavit 1 8; ggg ging Callendrello Affidavit 11 9, 27-28. l
s population, which they are not, this would not affect PAR formulation.
This is so because, if the condition of a patient prevents him or her from being loaded into an ambulance soon enough to join the evacuating stream of the general population, I
it will be because he or she cannot be moved from his or her bed i
soon enough to do so.
This means they wili bs sheltered in their rooms by default, in excellent shelter" which is the only j
1 alternative in any event and the alternative which would maximize
]
possible dose savings given the facts."
second, the affidavits make clear that the evacuation times for the ALS patients are essentially within the envelope of the shortest midweek daytime ETE for the general population of the ERPAs involved.
And in no case are they sufficiently long to affect PAR decision making.
Turning first to the Exeter Hospital:
It is located in ERPA F, the shortest midweek ETE for which is 4:40."
The last ambulance is estimated to arrive at its assigned special facility 2:13 after the order to evacuate."
It is also estimated that the last ambulance to evacuate an ALS l
patient will take 15 minutes to proceed (keeping in mind that l-this will be late in the evacuation) from the special facility to U
l Callendrello Affidavit 1 11.
"Id.
The Commonwealth has suggested that if that is the l
case there should be a plan to take people to the basement. Egg II. 28,428-29.
This ignores the fact that the reason that the l
patient cannot be evacuated is because he or she cannot or should l
not be moved from his or her room at all.
1 l
"Callendrello Affidavit 11 16-17.
"Callendrello Affidavit 11 18-20.
-S-l l
l l
the EPZ boundary.
This means that so long as all ALS patients at Exeter hospital can undergo final preparation and be loaded in 2:12 or less,'# the time to evacuate these patients will not exceed the ETE for the general population.'8 Exeter Hospital is capable of loading five ambulances simultaneously.
This means a total of ten patients at two per ambulance.i' This means a theoretical time of 2:15 to load all patients.21 This exceeds the 2:12 limit, but the three minutes will be easily erased because the loading of patients will begin before the last ambulance arrives at 2:13, and thus three full loading periods will not be necessary.22 As to the Portsmouth Regional Hospital:
It is located in ERPA G, the shortest midweek daytime ETE for which is 5:35.23 Patient preparation time before loading tote.ls two to three hours.'
Applying the times for last ambulance arrival and travel time as was done with the Exeter Hospital above, this YCallendrello Affidavit 1 21.
i
'I4:40 - 2:13 - 0:15 = 2:12; Callendrello Affidavit 1 21.
1s l
ga11endre11o Affidavit 1 22.
Callahan Affidavit 1 9.
l l
20Callahan affidavit 11 9-10.
21 l
22 + 10 = 2.2 loadings = 3 loading time periods x 45 minutes = 2:15.
gag Ca11endre11o Affidavit 1 23.
l 22Callendre11o Affidavit 1 23.
1 23Callendre11o Affidavit (( 16-17.
24Albertson Affidavit i 10. I i
means that so long as the ALS patients from the Portsmouth Regional Hospital can undergo final preparation and loading in 3:07 or less,25 the time to evacuate these patients will not exceed the ETE for the general population.I' Portsmouth Regional Hospital is capable of loading three ambulances simultaneously.27 This means a total of three patients at one per ambulance,28 for a calculated loading time of 2:55."
Given the parallel preparation and loading of ALS patients and the range of ALS patient preparation times for Portsmouth Regional Hospital (2:00 to 3:00), the range of times for patient preparation remaining to be performed after the arrival of the last ambulance is 0 to 47 minutes.30 Thus the range of times for loading the five required waves is 2:55 (assuming all preparation done before the last ambulance is assumed to arrive (2:13)) to 3:42 (assuming the preparation time was 3:00)."
This means that even assuming i
Portsmouth Regional Hospital did not start initial ALS patient preparation until the actual order to evacuate, and assuming they did not perform any loading prior to the time the last ambulance l
255:35 - 2:13 - 0:15 = 3:07; Callendrello Affidavit 1 21.
I 2'Callendrello Affidavit 1 22.
27Albertson Affidavit 11 9,
11.
l
\\
2sAlbertson Affidavit 11 9, 13.
"13 + 3 = 4.33 loadings = 5 loading periods x 35 minutes =
175 minutes or 2:55.
Sag Callendrello Affidavit 1 24.
3*Callendrello Affidavit 1 24.
MCa11endrello Affidavit 1 24. !
1 i
arrives at the facility, and assuming that the maximum 3:00 time was needed for patient preparation time, the final patient preparation and loading time would exceed the midweek daytime ETE for the ERPA by 35 minutes.32 Even assuming, in theory, that such a disparity were to occur, the 35 minute period is not enough to affect any choice of PAR.33 In addition, it should be realized that the above-described calculations are conservative in nature."
Thus, it is clear that the ETE for ALS patients will be essentially within the envelope of the ETE of general populations and need not be separately considered for planning purposes.
Respectfully submitted,
..Jd' ': /
omas C. DigdEn, Jr.
George H. Lewald Kathryn A. Selleck Jeffrey P. Trout Ropes & Gray One International Place Boston, MA 02110-2624 (617) 951-7000 Counsel for Applicants 32Callendre11o Affidavit 1 24.
33]DC. 26,933-34; Callendrello Affidavit 5 6.
MCa11endre11o Affidavit 1 26..
i r
1 L
STATEKENT OF MATERIAL FACTS AS TO WHICE No MATERIAL Is5UE REKAIMS TO BE HEARD i
1.
A prudent planning basis for the ALS patient census at the time of an emergency would be a total of 35 ALS patients in the entire EPZ (22 at Exeter Hospital and 13 at Portsmouth Regional Hospital).
2.
This number of 35 would occur during the day on week days.
3.
At Exeter Hospital the hverage preparation time for an i
ALS patient is 115 minutes, 70 minutes of which can be accomplished prior to ambulance arrival, leaving a final preparation and loading time of 45 minutes.
4.
In the case of Portsmouth Regional Hospital, the average preparation time for an Als patient is 45 minutes, 10 minutes of which can be accomplished prior to ambulance arrival, leaving a final preparation and loading time of 35 minutes, t
5.
In accordance vith its emergency management plan, Portsmouth Regional Hospital will use internal operational procedures and protocols to ensure 24-hour staffing for emergency conditions.
6.
Exeter Hospital commences calling in staff for an emergency at Seabrook at the Site Area Emergency Classification.
7.
The hospital emergency plans for both Exeter and Portsmouth Regional Hospitals provide for initiation of assembly of patients, as medically appropriate, upon receipt of the recommendation to evacuate which will maximize the number of
I i
patients available for evacuation upon arrival of the first ambulances.
8.
The emergency plans of both of the hospitals provide for the decision on ALS patients protective actions (g.g.,
evacuation) to be made by the medical staff on a case-by-case basis and without reference to the ETE fo-that individual.
9.
In the event an ALS patient is not evacuated or is delayed in evacuation, the only other proteclive action for such a patient is sheltering.
j 10.
Exeter Hospital is located in ERPA F, the shortest midweek daytime ETE for which is 4:40.
11.
Exeter P.ospital is capable of loading five ambulances simultaneously.
Patients will be loaded two per ambulance.
12.
The Portsmouth Regional Hospital is located in ERPA G, the shortest midweek daytime ETE for which is 5:35, 13.
Portsmouth Regional Hospital is capable of loading three ambulances simultaneously.
Patients will be loaded one per ambulance.
14.
The last ambulance is estimated in the ETE Study to arrive at its assigned special facility 2:13 after the order to I
evacuate.
l 15.
Towards the end of the evacuation time frame, the last ambulance to evacuate a'.t ALS patient will take 15 minutes or less to proceed from the special facility to the EPZ boundary.
16.
The loading of patients will begin before the last ambulance arrives at Exeter Hospital. - _-
i MlilD ushkC 90 AN 27 P314 CERTIFICATE OF SERVICE Licenseesherein,herebycertifythatonJune26,TS[9'Oone of the attorneyk h(E I,
Thomas G. Dignan, Jr.,
R,Lomade service of the within document by depositing copies thereof with Federal Express, prepaid, for delivery to (or, where indicated, by depositing in the United States mail, first class postage paid, addressed to):
Administrative Judge Ivan W. Smith Adjudicatory File Chairman, Atamic Safety and Atomic Safety and Licensing Licensing Board Board Panel Docket (2 copies)
U.S.
Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, ND 20814 Administrative Judge Richard F.
Cole Robert R.
Pierce, Esquire Atomic Safety and Licensing Board Atomic Safety and Licensing
=
U.S.
Nuclear Regulatory Commission Board East West Towers Building U.S.
Nuclear Rog"latory 4350 East West Highway Commission Bethesda, MD 20814 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Administrative Judge Kenneth A.
Mitzi A.
Young, Esquire McCollom Edwin J.
Reis, Esquire 1107 West Knapp Street Office of the General Counsel Stillwater, OK 74075 U.S.
Nuclear Regulatory Commission One White Flint North, 15th Fl.
31555 Rockville Pike Rocksille, MD 20852 George Dana Bisbee, Esquire Diane Curran, Esquire Associate Attorney General Andrea C.
Ferster, Esquire Office of the Attorney General Harmon, Curran & Tousley 25 Capitol Street Suite 430 Concord, NH 03301-6397 2001 S Street, N.W.
Washington, DC 20009
- Atomic Safety and Licensing Robert A.
Backus, Esquire Appeal Panel 116 Lowell Street U.S.
Nuclear Regulatory P.
O.
Box 516 Commission Manchester, NH 03105 Mail Stop EWW-529 Washington, DC 20555
5 l'
Philip Ahrens, Esquire Suzanne P. Egan, City Solicitor Assistant Attorney General Lagoulis, Hill-Whilton &
Department of the Attorney Rotondi General 79 State Street Augusta, ME 04333 Newburyport, MA 01950 Paul McEachern, Esquire John Traficonte, Esquire Shaines & McEachern Assistant Attorney General 25 Maplewood Avenue Department.of the Attorney P.O.
Box 360 General Portsmouth, NH 03801 One Ashburton Place, 19th Fl.
Boston, MA 02108
- Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Hill-Whilton &
Washington, DC 20510 Rotondi (Attn:
Tom Burack) 79 State Street Newburyport, MA 01950
- Senator Gordon J. Humphrey Barbara J.
Saint Andre, Esquire One Eagle Square, Suite 507 Kopelman and Paige, P.C.-
Concord, NH 03301 101 Arch Street (Attn:
Herb Boynton)
Boston, MA 02110 H. Joseph Flynn, Esquire Judith H.'Mizier, Esquire Office of General Counsel 79 State Street, 2nd Floor Federal Emergency Management Newburyport, MA 01950 Agency 500 C Street, S.W.
Washington, DC 20472 Gary W.
Holmes, Esquire Ashod N. Amirian, Esquire Holmes & Ells 145 South Main Street 47 Winnacunnet Road P.O.
Box 38 Hampton, NH 03842 Bradford, MA 01835 Mr. Richard R.
Donovan Mr. Jack Dolan Federal Emergency Management Federal Emergency Management Agency Agency - Region I Federal Regional Center J.W. McCormack Post Office &
130 228th Street, S.W.
Courthouse Building, Room 442 Bothell, Washington 98021-9796 Boston, MA 02109 i
4 I
\\
=c,
,Il
' George Iverson,- Director N.H. Office of Emergency Management 4
7c
- State House office Park South 107 Pleasant Street Concord, NH 03301 Wf ThomaTs GT Dig lFrsfG Jr.
(*= Ordinary U.S. First Class Mail) 3-
...... _. _ _