ML20086T751

Supplemental Response to Atty General Belloti Interrogatories Re Number of Persons for Which State of Nh Must Assure Medical Svcs,Per 10CFR50.47.W/Certificate of Svc.Related Correspondence

ML20086T751
Person / Time
Site:	Seabrook
Issue date:	02/29/1984
From:	Swiren B Federal Emergency Management Agency
To:
Shared Package
ML20086T748	List: ML20086T745 ML20086T751
References
OL, NUDOCS 8403070022
Download: ML20086T751 (9)

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RELATED CORRI5FONDENCE DOCKETED USNRC Util'IED STATES OF NERICA NUCLEAR REGUIATORY COtNISSION

,84 MR -2 A10 :28 BEFORE 'ITE A'IUiIC SAFETY AND LICD2SItG BOARD 77 7 : ,. w. . .,

CC';.iSIUML-E.U 1:CH In the Matter of )

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PUBLIC SERVICE COtPA:1Y OF ) Docket Nos. 50-443 OL NB1 HA?EdHIRE, et al. ) 50-444 OL

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(Seabrook Station, Units 1 and 2) )

FEDERAL DEGENCY MANAGDOR AGENCY'S SUPPLDD7fAL RESPCNSES

'IO ATIORNEY GENERAL BELIDTI'S IITIERROGA'IORIES __

I?7IERROGA'IORY 5 AS NiDED In the opinion of FEMA, what is the ntrl)er of persons for which the State of New Hampshire must assure medical services persuant to 10 C.F.R. S 50.47 (b)

(12)? State the basis for your answer in detail, describing the types of in-juries and sources or levels of contamination for which your estimate accounts.

Identify and produce all documents upon which you rely for any portion of your answer.

FEttA'S RESPONSE 'IO ItTIERROGA'IORY 5 In the Matter of Southern California Edison Canpany, et al, ' San Onofre Generating Station, Units 2 and 3),17 N.R.C. 528 (1983), the 0:runission in-terpreted the requirement for arranging for off-site medical services. We Ccmmission held 10 C.F.R. S 50.47 (b)(12) required "that emergency response efforts should include consideration of: (1) those who become injured and also contaminated, and (2) those who may be exposed to dangerous levels of radiation." Matter of Southern California Edison Cmpany,17 N.R.C. at 530.

'Ihe Cmmission construed the NRC regulation to require "immediate or near term care. Advance planning would be most useful for immediate or near term care while long Mm care can be handled on an g hoc basis and

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should not require advance planning." Matter of Southern California Edison Cmoany,17 N.R.C. at 535.

%e Cmmission went on to hold that:

with respect to individuals who become injured and are also contamin-ated, the arrangements that are currently required for on-site person-nel and emergency workers provide emergency capablities which should be adequate for treatment of members of the general public. %erefore, no additional medical facilities or capabilities are required for the general public.

. Matter of Southern California Fdison Cmpany,17 N.R.C. at 536.

On the basis of this ruling, in order to meet the requirements of 10 C.F.R. S 50.47 (b)(12), the State of New Hampshire should provide medical services for the same n mb2r of contaminated individuals as provided for by the on-site plan. Additional arrangements are not required by this regulation.

We Federal Emergency Management Agency will consult with the Nuclear Regulatory Commission (NRC) Staff to determine if such adequate arrangements have been made in the on-site plan.

As to individuals who are exposed to radiation and who need medical treatmcnt for that reason, the Cm mission has determined:

Here the special hazard is posed by the radiation exposure to the patient. %e nature of the radiation injury is that, while medical treatment may be eventual 3y required in cases of extreme exposure, l the patients are unlikely to need emergency medical care. We non--

i imediacy of the treatment required for radiation-exposed individuals provides onsite and offsite authorities with an additioral period of time to arrange for the required medical service. Rus, any treatment required could be arranged for on an ad hoc basis.

Matter of Southern California Edison Cm pany, 17 N.R.C. at 535-36.

On the basis of the Cmmissions interpretation of 10 C.F.R. S 50.47 (b)(12) the State of New Hampshire need only " identify those local or regional medical f facilities which have the capablities to provide appropriate medical treatment for l radiation exposure. " Matter of Southern California D31 son Cmpany,17 N.R.C. at l 537. .

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4 As to that aspect of the interrogatory that asks for this Aaency to describe the types of injuries and levels of contamination taken into account, under the comission ruling in the Matter of Southern California Edison Company the re-quirement is that the individual suffer a traumatic injury and be contaminated.

No specific level of radiation exposure or contamination is considered.

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IlnuoO3A'IORY 6 In the opinion of FD%, can the health care facilities identified in the RERP provide to the ntuber of contaminated injured individuals specified in your answer to interrogatory 5 all medical treatment which could be of help to them? If not, can such treatment be provided by other health care facili-ties in New Hampshire and/or 11assachusetts? State the basis for your answers in detail and identify and produce any documents upon which you rely. List all medical facilities other than those identified in the RERP which might be required to provide care to assure that the full number of persons specified in your answer to interrogatory 5 receive all treatment which could be of help to them.

FEMA RESPONSE 'IO INIERROGA'IORY 6 See response to Interrogatory S.

INI'ERROGA'IORY 9 In the opinion of FDW, has the State established an emergency action level scheme consistent with that established by the Applicants? State the basis for your response in detail and identify and produce documents upon which you rely in support of your answer.

FDM RESPONSE 'IO ItEAM'IORY 9 The State of New Hanpshire has adopted the standard emergency classi-fications, which are identical with those utilized by the utility in the on-site plan. 'Ibe utility still needs to identify the design based plant operating parameters and initiating conditions, which together with the emergency classi-fications constitute the Emergency Action Level scheme. We anticipate that the State of New Hanpshire adopt this same Emergency Action Invel scheme.

i 4 IturmOGNIORY 17 AS AMDIDED In the opinion of FD%, can the transient beach populations in the New

, llampshire coastal ocmrunities within ten miles of the Seabrook site be protected frcn all adverse health effects potentially associated with radiation exposure by means of evacuation in the event of a radiological emergency at Seabrook Station? If your answer is in the negative, indicate what adverse health effects could be experienced by the beach population and the numbers of such persons who may potentially experience each such effect. hhether your answer in in the affirmative or negative, state the basis for it in detail and identify and produce all doctnents upon which you rely.

IT1% RESPONSE 'IO IITTERROGNIORY 17 The planning basis of IUREG-0654/ FDR REP 1, Revision 1 (1980), clearly states that "'Ihe overall objective of emergency response plans is to provide dose savings (and in some cases immediate life saving) for a spectrum of acci-Ments that could produce doses in excess of Protective Action Guides (P1G's)."

There is an implicit recognition of the fact that in some lw prcbability accidents members of the public will be exposed to some level of radiation.

FDR has not undertaken an independent analysis of the issue raised by this contention. 'Ihe NRC has addressed the probability of accident risk and health impacts in section 5.9.5.0, p.5-45 et seg. , of the Final Environmental Statement (CES),IUREG-0895. As stated in the FES the " consequence model also contains provisions for incorporating the consequence-reduction benefits of evacuation, relocation, and other protective actions." p 5-50. Based upon this analysis, under certain scenarios considered by the NRC the transient beach may be exposed to radiation released during an accident at Seabrook.

The basis for FD%'s statement is the FES, IUREG-0895.

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i INTERPOGATORY 18 AS AMD3DED In the opinion of FD%, can the seasonal residents in the beach areas within ten miles of the Seabrook site be protected from all adverse health effects potentially associated with radiation exposure by means of in-place sheltering? If your answer is in the negative, indicate what adverse health effects could be experienced by the seasonal population and the ntsnbers of such persons who may potentially experience each such effect. Whether your answer is in the affirmative or negative, state the basis for it in detail and identify and produce all documents upon which you rely.

FD% RESPONSE TO INTERROGATORY 18 See answer to intentgatory 17.

INTERROGATORY 19 In the opinion of FD%, what is the most efficient evacuation routing scheme for the seasonal and transient beach populations in the coastal New Hampshire comunites within ten miles of the Seabrook site? State the basis for your answer in detail and identify and produce all documents upon which you rely.

Do the routes which you have specified conform in all respects to those assumed by the Applicants in their evacuation time estimates as set forth in Appendix C to the FSAR? To those assumed by Costello, Lomasney & deNapoli/C.E.

Maguire in their " Final Draft of Appendix E Emergency Planning Lone Evacuation Time Study"? If the answer in both cases is no, will FD% require revised evacuation time estimates based on the most efficient routing scheme? Uhen will such estimates be required to be corpleted?

FD% RESPCNSE TO Ilm.xHQMORY 19 FDR has not formed a conclusive opinion on this matter at this time.

FE2% is working with both plume EP2 states with regard to evacuation routing and traffic control planning and coordination.

FD% is also independently doing a detailed conparison of the two studies referenced above in ths Interrogatory.

6 IITTERROGMORY 20 In the opinion of FDR, what traffic management plans or traffic controls will lead to the most efficient evacuation of the seasonal and transient beach populations in the coastal New Harpshire cormunites within 10 miles of the site? State the basis for your answer in detail and identify and produce any documents which you rely. Have these traffic controls and management plans been reflected in the evacuation time estimates prepared by the Applicants?

2ose prepamd by C. E. Maguire? If the answer in both cases is no, will FDR require evacuation time estimates based on such plans and controls? W en will such estimates be required to be completed?

FD% Response see response to interrogatory 19.

Signed this 13 day of February,1984.

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BRUCE J. SWIRHi Drergency Management Specialist Federal Emergency Management Agency Region I 2 en appeared before me Bruce J. Swiren and after having been duly sworn stated that the aforegoing statements were true and accurate to the best of his information and belief.

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,A TJTARY PUBLIC Date: ,2 e) f- d'Y l My cormission expires:

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WJED CORRESPONDENCE UNITED STATES OF AMERICA 000'E~EE NUCLEAR RH3UIA'IORY COMMISSION N BEFORE 'IEE A'IO4IC SAFETY AND LICENSING N '84 KAR -2 A10 :28 LFF;2 ?: SE, -t ;

OCChElih0 ?. SEin .

In the Matter of ) BRANCH

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PUBLIC SERVICE COMPANY OF ) Dacket Nen. 50-443 OL N W HAMPSHIRE, et _al.

_ ) 50-444 OL (Seabrook Station, Units 1 and 2) )

CERTIFICATE OF SERVICE i

I, Brian P. Cassidy, state that I served a copy of FEMA's Supplemental Response to the Massaschusetts Attorney General's Interrogatories, by mailing in a franked envelope upon the parties identified in the attached service list on this 29th day of February 4. -

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m Regional Counsel Fed ral Emergency Managen Agency SERVICE LIST Helen Hoyt, Esq. , Chairman Dr. Jerry Harbour Administrative Judge Administrative Judge Atomic Safety and Licensing Atoric Safety and Licensing Board Board Panel Panel U.S. Nuclear Regulatory Ccxnmission U.S. Nulcear Pegulatory Ccrnmission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Dumeth A. Luebke Robert Perles, Esquire Administrative Judge Office of the Executive Legal Director Atomic Safety and Licensing Board U.S. Nuclear Regulatory Agency  ;

Panc1 Washington, D.C. 20555 U.S. Nuclear Regulatory Cmmissicn Washington, D.C. 20555 Edward L. Cross, Jr., Esq. Jo Ann Shotwell, Asst. Attorney General George Dana Bisbee, Esq. Dept. of the Attorney General Environmental Protection Division One Ashburton Place,19th Floor State House Annex Boston, MA 02108 Concord, NH 03301

Nicholas J. Costello Charles Cross, Esq.

1st Essex District Shaines, Madrigan, & McEacher Whitehall Road 25 Maplewood Avenue Ame'sbury, MA 01913 P.O. Box 366 Ibrtsmouth, NH 03801 Sandra Gavutis Senator Gordal J. Humphrey Town of Kensington, New Hampshire 1 Pillsbury Street RFD I Concord,t&I 03301 East Kingston, NH 03827 (Attn: Herb Boynton)

Edward J. Meany Mr. Maynard B. Pearson Town of Rye, New Hampshire Town of Amesbury, Mass.

155 Washington Road 40 Monroe Street Rye, NH 03870 Amesbury, MA 01913 Anne Verge, Gairman Patrick J. McKeon Board of Selectmen Gairman of SelectInen, Rye Town Hall New Hampshire South Hanpton, NH 03842 10 Central Road Rye,t&I 03870 R.K. Gad III, Esq. Town of North Hanpton Ropes and Gray North Hampton, NH 03862 255 Franklin Street i

Doston, MA 02110 l

Deverly Hollingworth Carole F. Kagan, Esq. l 7 A Street Law Clerk to the Board l Hampton Beach, NH 03842 Atomic Safety and Licensing Board l U.S. Nuclear and Regulatory Commission Mr. Robert J. Harrison Washington, D.C. 2055S' President and Chief Executive Officer Public Service Co. of New Hampshire P.O. Box 330 Docketing and Services Section Manchester, tal 03105 Office of the Secretary U.S. Nuclear Regulatory Comnission Robert A. Backus, Esq. Washington, D.C. 20555 116 Imell Street P.O. Box 516 Manchester, NH 03105 Ietty Hett Senator Gordon J. Humpnrey Town of Brentwood U.S. Sentate RFD Dalton Road Washington, D.C. 20510 Brentwood, tal 03833 (Attn: 'itzn Burack)

Thanas G. Dignan, Jr. , Esq. John B. Tanzer Popes & Gray Town of Hanpton, IMw Hanpshire 255 Franklin Street 5 Morningside Drive Doston, MA 02110 Hampton, NH 03842

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l Atomic Safety and Licensing Atmic Safety and Licensing 2

Appeal Panel Board Panel U.S. Nuclear Regulatory Comnission U.S. Nuclear Regulatory Comnission Washington, D.C. -20S55 Washington, D.C. 20555 Jane Doughty Phillip Ahreans, Esq.

Field Director Assistant Attorney General Seacoast Anti-Pollution Imague State House Station #6

-.l- 5 Market Street Augusta, ME 04333 Portsmouth, NH 03801 Calvin A. Canney U1111am S. Jordan, III, Esq.

City Hall Ellyn R. Weiss, esq.

4 126 Daniel Street Harmon & thiss Portsmouth, NH 03801 1725 I Street, N.W.

Suite 506

. Roberta C. Pevear Washington, D.C. 20006

] 7twn of Haupton Falls, New Hanpshire Drinkwater Road

Hanpton Falls, NH 03844 4

Dr. Murray J. Tye Tufts University School of Medicine 4

Department Of Dermatology

, 209 Sumer Street Haverhill, MA 01830 l

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