ML20063M597

Responds to 820811 Request for Info,Answering ASLB Questions in 820806 Memorandum & Order Re Possible Further Proceedings on Adequacy of Offsite Planning for Medical Svcs

ML20063M597
Person / Time
Site:	San Onofre
Issue date:	09/03/1982
From:	Krimm R Federal Emergency Management Agency
To:	Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
NUDOCS 8209150264
Download: ML20063M597 (3)

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a ,D i Federal Emergency Management Agency $>- 3 01 m' s J Washington, D.C. 20472 SEP 3 19ff i

(EMORANDUM FOR: Brian Grimes, Director Division of Emergency Preparedness

) U.S.tjuclea(Re latory Commission FROM: R1 MYr in' R-AssistantAssociakeDirector Office of Natural and Technological Hazards i

SUBJECT:

ASLB Memorandum and Order (8/6/82) San Orofre Nuclear Generating Station, Of fsite Planning Medical Services I am responding to the letter to Spence W. Perry, Esquire, the Federal Emergency Management Agency Associate General Counsel (8/11/82), from Mr. Joselp Scinto, Deputy Director, Hearing Division, Nuclear Requatory Commission (NRC), which requested information concerning whether further proceedings on the adequacy of of fsite planning for medical services should be conducted. This subject appears in a Memorandum and Order issued by the NRC/ASLB dated August 6, 1982, for the San Onofre Generating Station, Units 2 and 3 (Docket N s. 50-361-OL and 50-362-OL). The ASLB is proposing to consider in the light of further submissions whether further proceedings may produce a better evidentiary record on the need, if any, for medical services ar rangements for the of fsite public.

Following are questions the Board asked FEMA as well as our responses (it should i be noted that both the questions and the answers address the radiological conditions of contamination or exposure and not a concurrent condition such as broken bones, bleeding or unconsciousness. While I am aware of a variation in viewpoint on the breadth of the discussion, this does not constitute an inconsistency.):

1. If further proceedings were directed, what additional evidence, if any, would

you produce on the need for medical services arrangements offsite, beyond that recognized by the Appeal Board in ALAB-680? Describe briefly the thrust of that evidence and the qualifications of proposed expert witnesses.

There is no additional evidence that FEMA would produce on the need for medical services arrangements offsite, but we will restate our position that appeared on page 36 of the initial decision dated May 14, 1982, which is as follows:

" FEMA believes that special arrangements for medical services need Io be made for persons within the 10-mile EPZ who may suffer from radiation exposure, .

I radiological contamination, or both. Moreover, this position is supported by specific planning standards and criteria in NUREG-0654/ FEMA-REP-1, Rev. I for use by State and local gosernments in assuring that adequate arrangements are i

made for the provision of medical sersices for accidents encompassing the full range of the four classes of emergency action levels as delineated in Appendix 1."

8209150264 820903 PDR ADOCK 05000361 F PDR

The planning and preparedness guidance provided in NUREG-0654/ FEMA-REP-1 for medical services is based, in part, on the possibility that despite the application of protective response measures, persons within the 10-mile EPZ may be exposed to dangerous levels of radiation. Those persons so exposed would, therefore, require appropriate medical services. (Letter to the Board Chairman from Marshall Sanders, Acting Chief, Technological Hazards Division, dated October 15, 1981.)"

The use of expert witnesses for the presentation of new evidence is not expected.

Expert witnesses for clarification or reaffirmation may be used by FEMA if needed.

2. Two witnesses, Drs. Linnemann and Ehling, testified that hospitalization was indicated for a person who has received a 150 to 200 rem whole body radiation dose, Tr. 7728, 9992. If that is so, and if it is prudent to assume that perhaps several hundred people offsite could receive such doses in a serious accident, then is it necessary, or at least prudent, to make advance arrangements for medical services for such people? _

Yes, it is prudent to make advance arrangements for medical services for offsite persons who might be classified as contaminated or radiologically exposed (150 to 200 rem whole body radiation dose).

The justification for this answer is, in part, the difficulty of predicting additional and concurrent medical needs. Advanced arrangements are justified because of the need to initiate a medical history for those exposed individuals whose future health could be af fected and to reduce organizational demands on hospital emergency staf f.

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.

3. If such arrangements were to be made, what would they consist of--beds,.decontam-ination and testing facilities, specially trained personnel, special medicines, what else? Would it be possible to make the necessary arrangements on an ad_ hoc basis?

If so, how long would that take?

Decontamination facilities and monitoring equipment would be necessary along with trained and knowledgable 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 hoc basis. The time involved is indeterminate because of the variation in facilities, variation in the magnitude of tha demand, and the location of the medical supply source with respect to the hospital (s).

4. In assessing the need for medical services, should one assume that the emergency plans for evacuation and sheltering will be effective (as suggested at p. 20 of ALAB-680) or ineffective (as suggested in the FEMA letter quoted at p. 36 of the initial decision)? .

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No assumption should be made about the effectiveness of evacuation and sheltering. ,

These are protective. actions available for use just as medical services are to be j available when needed. To protect the health of the public, one or all may be required and the decisionmakers need the availability of all three. NUREG-4 0654/ FEMA REP 1, Rev 1, planning standards D, J, and L call for these protective actions to assure that State and local officials will be aware of these alternatives i for protecting the public health. {

i 5. Did the Board.in its Initial Decision (at 35-37) correctly state the FEMA position?

Yes, the position is correctly stated. Arrangements for medical services should be made for the general public in the 10-mile emergency planning zone.

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