ML20106A071
| ML20106A071 | |
| Person / Time | |
|---|---|
| Site: | Perry, Harris  |
| Issue date: | 02/05/1985 |
| From: | Silberg J CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20106A063 | List: |
| References | |
| OL, NUDOCS 8502110030 | |
| Download: ML20106A071 (4) | |
Text
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February 5f.
85 UNITED STATES OF AMERICA
.gg ff8 -8 g,
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD-l
, [m. f.
In the Matter of
)
)
- THE CLEVELAND ELECTRIC
)
Docket Nos. 50-440 ILLUMINATING COMPANY
)
50-441
)
(Perry Nuclear. Power Plant,
)
Units 1 and 2)
)
APPLICANTS' STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD ON CONTENTION P Pursuant to 10 C.F.R. S 2.749(a), Applicants state, in support'of their Motion for Summary Disposition of Contetion P in this proceeding, that'there is no genuine issue to be heard with respect to the following material facts:
1.
A patient suffering from radiation exposure is not radioactive and poses no hazard to response pernonnel.
Affida-vit of Roger E. Linnemann on Contention-P ("Linnemann Aff."),
1 2.
2.
Radioactive contamination results from' loose radioac-tive particles ddhoring to the body.
Contamination is easy to
~
detect and is easily removed by changing clothes and bathing the effected-area.
Linnemann Aff., 11 2, 6.
3.
No special emergency facilities are required for a patient who_is exposed and injured.
Linnemann Aff., 1 3.
Fobk 0
p b.
4 14.
For a contaminated patient, procedures are imple-mented to reduce exposure and control contamination.
These procedures are'not unique to radiation injury cases.
Linnemann
-Aff., 1.3.
,5.
' Radiation injuries are among the easiest medical emergendies to handle.
Such injuries are seldom.if ever life-threatening and unfold in a predictable sequence over a
. period of-time.
Linnemann Aff., 1 4.
6.-
Even an extremely unlikely nuclear plant accident
.with substantial off-site radiation releases would not generate-large numbers"of traumatic injuries _or the need for a large number of hospital beds.
Linnemann Aff., 1 5.
~
7.
The characteristics of a radiation release mitigate against.the possibility that an individual would receive enough exposure or contamination to require hospitalization.
.Linnemann'Aff., 1 6.
8.
Emergency plans for the.three plume exposure pathway
-EPZ counties identify four hospitalsfto handle members of the public who may have had radiation ~ uptake or exposure.
The Perry emergency plan' designates one of these-hospitals to re-ceive radiation injuries from the plant-(one of the other hos-
'pitalsLwould be l'ts backup).
Linnemann Aff., 1 8..
9..
Extensive training in handling radiation. injuries has been provided to all four of the designated hospitals.
Eighty-five. hospital personnel have been trained.
Linnemann Aff., 1 9.,
Z. _ _
1.,
7 10.
Multiple injuries from nuclear power plants are rare.
-Linnemann'Aff., 1 10..
- 11. ' Support hospitals would be able to handle multiple contaminated and injured personnel, using their existing mass casualty procedures.
Designated Radiation Emergency Areas
.could be readily expanded.
Linnemann Aff., 1 10.
12.
The State Plan identifies some 50 hospitals in the counties around the plume-EPZ, which should be capable of han-dling contaminated and exposed individuals, including those who are injured.
Linnemann Aff., 1 11.
13.
Thirty-seven of the hospitals on the State list have diagnostic and/or therapeutic radioisotope facilities, which 4
requires that they be able to handle contaminated and injured patients.
Linnemann Aff., 1 11.
14.
Accredited hospitals must have procedures for the r
emergency management of individuals who have actual or sus-pected exposure to radiation or who are radioactively contami--
nated.
All the hospitals listed on the State Plan are indi-cated to fue accredited.
Linnemann Aff., 1 12.
E6. -
i
,L' 15.
The many available hospitals, with their existing emergency.-rooms and radioisotope facilities, would be able to handle any conceivable patient load arising from an accident at Perry. - Linnemann Aff., 1 12.
Respectfully submitted, i
A
/
J B.
pilberg PTTTMAN, POTTS & T OWBRIDGE M Street, N.W.
ington, D.C. 20036 (202) 822-1000 Counsel for Applicants
' Dated:
February 5, 1985
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