ML20106A080

Affidavit of Re Linnemann,Supporting Applicant Motion for Summary Disposition on Contention P.Procedures Adequate to Handle Medical Consequences of Accident at Plant.Certificate of Svc Encl

ML20106A080
Person / Time
Site:	Perry
Issue date:	02/05/1985
From:	Linnemann R CLEVELAND ELECTRIC ILLUMINATING CO., PENNSYLVANIA, UNIV. OF, PHILADELPHIA, PA, RADIATION MANAGEMENT CORP. (RMC)
To:
Shared Package
ML20106A063	List: ML20106A062 ML20106A071 ML20106A080
References
OL, NUDOCS 8502110034
Download: ML20106A080 (14)

Text

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l, February 5, 1985 C XnETED u N?C  :

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSI8p FEB -8 A!1 :01 BEFORE THE ATOMIC SAFETY AND LICENSINGrBOARD-

'In-the Matter of )

)

THE CLEVELAND ELECTRIC ) Docket Nos. 50-440

. ILLUMINATING COMPANY ) 50-441

)

(Perry Nuclear Power Plant, )

Units l and 2). )

s AFFIDAVIT OF ROGER E. LINNEMANN ON CONTENTION P County of Philadelphia )

) ss Commonwealth of Pennsylvania )

Roger E. Linnemann, being duly sworn,~ deposes and says:

l'. I am Vice Chairman and Chief Medical Officer,

-Radiation Management Corporation.("RMC"), University City Science. Center, Philadelphia, Pennsylvania. I am also-Clinical-

. Associate Professor of Radiology, University of Pennsylvania c School.of-Medicine and Visiting Associate Professor of Clinical' x

Radiology, Northwestern University Medical School. I am licensed:to practice medicine and surgery in Pennsylvania, Illinois and Minnesota-and;am certified by the American Board

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, offRadiology and the American Board of Nuclear Medicine. I have represented the. Commonwealth.of Pennsylvania in the 3 .: ..a '

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e i Medical Liaison Officer's Network, a national organization of physicians establidhed by the U.S. Environmental Protection Agency and the Department of Defense to consult on radiation problems associated with federal installations. As Chief Medical Officer of RMC, I am responsible for the training which RMC has provided to hospitals in the area surrounding the Perry Nuclear Power Plant. I am also familiar with the capability of hospitals to treat injured individuals who are contaminated with radioactive materials, as well as individuals suffering from radiation exposure. A current statement of my professional qualifications is attached hereto. I have personal knowledge of the matters stated herein and believe them to be true and correct. I make this affidavit in support of Applicants Motion for Summary Disposition of Contention P.

2. Radiation injuries result from either exposure-to radiation or contamination by radioactive materials. In the case of radiation exposure, the patient suffers' injury from the energy deposited in the cells during the period of radiation, but the patient is not radioactive and presents no hazard to response personnel. Contamination results from loose radioactive. particles adhering to the body. An exposure hazard remains until these particles are removed. Radioactive contamination-is easy to detect and decontamination is easily accomplished by removing contaminated clothes and bathing the affected area.

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3. Should a patient be exposed and injured, no special emergency facilities are needed. The patient can be handled as any other injured patient. If the patient is contaminated, procedures are implemented to reduce exposure and control the spread of any contamination. However, these procedures are not unique to radiation injury cases; similar steps are taken for chemical contamination or septic cases.

, 4. The characteristics of radiation injury make it one of the easiest medical emergencies to handle. Radiation injuries are seldom if ever immediately life-threatening. The

, consequences unfold over a period of time with predictable sequence. Therefore, treatment of any life-threatening traumatic injury or serious illness always takes precedence over treatment of the radiation injury. Once the patient is resuscitated and stabilized, he can be decontaminated and placed in a regular hospital bed. There is then time for assessment and treatment of the radiation injury. No special equipment is needed (such as lead-lined operating rooms, radiation resistant equipment, etc.) because of the nature of the radiation exposure and the conditions of treatment. Any contaminated materials would be disposed of following the same procedures used for nuclear medicine departments; no special equipment would be needed to handle this disposal.

5. Even in the extremely unlikely event of an accident at a nuclear plant with substantial off-site release of

. radiation, there would not be the need for any large number of

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.o hospital beds for an injured population. Such an accident would not involve the generation of large numbers of traumatic casualties. The only way in which an off-site population can ,

be affected is through overexposure to radiation.

6.. The characteristics of a radiation release mitigate against the possibility that an individual would receive the s'

level of exposure (about 150,000 millirem over a period of a i few hours) which would require hospitalization. Distance, dispersion and absorption of radiation by other materials (by

, shelter, for example) make it unlikely that anyone off-site ,

would receive a large enough exposure to initiate the first 1 symptoms of< radiation sickness (about 75,000 millirem), let alone hospitalization. Given the relative ease of decontamination (changing clothes and bathing), overexposure from contamination is also unlikely. To cause a redness to the skin from' fission product radiation would require a total dose ,

of about' 800,000 millirem; one would literally have to leave caked radioactive dirt on the skin for hours to. deliver:these kinds of doses.

,. 7. Based on these considerations, one could reasonably.

expect that'the medical' responsibilities of a major nuclear power plant accident would be the treatment of a few injured plant workers who:were also contaminated or exposed, and a larger. number of.the public who might be slightly contaminated.

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These cases could readily be handled by present medical

r'esources.

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8. The emergency plans relating to the Perry Nuclear ,

Power Plant identify Lake County Memorial Hospital East, Lake )

County Memorial-Hospital West, Geauga Community Hospital and Ashtabula County Medical Center as the local hospitals

. designated to handle members of the general public who may have radiation uptake or exposure. Lake County Plan, S L-03;

.Ashtabula County Plan, S L.3; Geauga County Plan, S L-2. The Perry Emergency Plan (S 5.3.3.2) designates Lake County

-Memorial Hospital East as the hospital to receive highly-contaminated-injured persons from on-site for initial treatment and decontamination. (If Lake County Memorial Hospital East were being evacuated due to an accident at Perry

-- it is within the 10 mile EPZ -- these persons would be taken directly to Lake County Memorial Hospital West.) Definitive, long-term care for contaminated injuries and significant

-radiation overexposure is available through RMC's arrangements with Northwestern Memorial Hospital _in Chicago, and.the

' Hospital of the University of Pennsylvania, Philadelphia.

9. RMC has provided extensive training to personnel'of both Lake County Memorial Hospitals (East and West), Ashtabula County Medical Center and Geauga Community Hospital. The trainino program has as its objectives to first insure that immediate emergency medical care is provided to an injured individual.and, secondly, to perform appropriate decontamination.and contamination control techniques. The topics of the training include the biological effects of

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-ionizing radiation, personnel protective actions, use of  ;

emergency room equipment and supplies for the contaminated -

t patient, contamination control techniques, and decontamination i

and bioassay procedures. Eighty-five hospital personnel have been trained, including fifteen physicians, fifty-three nurses, eleven nuclear medicine and radiology personnel, and 6 emergency medical technicians.

10. In the event of multiple contaminated and injured personnel, the support hospitals would be able to handle the increased numbers. Since hospitals already have procedures to handle mass casualty situations (for example, a bus accident),

these can easily be applied to handle multiple injured contaminated patients. Incoming patients would be triaged on the basis of their injuries, since traumatic injury always takes precedence over contamination. If additional treatment rooms are necessary, the designated Radiation Emergency Area can readily be expanded. However, multiple injuries would be very rare. In my fifteen years experience at twenty-five

-nuclear power plant sites, only two cases involved multiple injuries -- in.each case involving two employees each.

L' 11. In addition to these four hospitals, there are some I

fifty hospitals in the counties around the 10 mile EPZ which can receive and care for most radiological accident cases.

These:are listed in the State Plan, Fig. II-L-2. They should be capable of dealing with contaminated and exposed

-individuals, including those who have been otherwise injured.

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Thirty-seven of these hospitals have diagnostic and/or therapeutic radioisotope facilities. This requires that they are able to handle contaminated and injured patients which could result from injuries within their own facilities.

12. The State has indicated that all of the hospitals listed in the State Plan are accredited by the Joint Commission on Accreditation of Hospitals. Standard V of the Commission's Accreditation Manual for Hospitals (1984) requires each hospital to have procedures for:

The emergency management of individuals who have actual or suspected exposure to radiation or who are radioactively contaminated. Such action may include radioactivity monitoring and measurement; designation and any required preparation of space for evaluation of the patient, including, as required, discontinuation of the air circulation system to prevent the spread of contamination; decontamination of the patient through an appropriate cleansing mechanism; and containment, labeling, and disposition of contaminated materials. The individual responsible for radiation safety should be notified.

Given the existing emergency room facilities of all the hospitals identified in-the State plan and the radioisotope facilities in 37 of them, these facilities would be able to handle any conceivable patient loa'd arising'from an accident at the Perry facility. Because there are many hospitals available, and because the radiation health effects which might be observed are seldom if ever life threatening, the present plans and procedures are more.than adequate to handle the medical consequences of an accident at the Perry plant.

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13. In suunary, the Applicant, the State and Cbtaity plans havo

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adequately addzwaasd the hospital designations and the medical services to be pewidad by hospitals, including assistance to contaninated individuals, in the event of an accident at the Perry Nuclear Power py g ,

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, Linnemann, M.D.

Siew ribed and sworn before i rue this i d th day of February,1985.

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N consdssion Expires: Notary rubite.msa Itdse Co.

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ROGER E. LINNEMANN, M.D.

EDUCATION University of Minnesota, Minneapolis, MN; B.A. (Cum Laude) 1952 University of Minnesota, Minneapolis, MN; B.S., M.D. 1956 Walter. Reed Army. Hospital, Washington, D.C.; Internship 1956-57 Walter Reed Army: Hospital, Washington, D.C.; Residency 1962-65

= Certified by American Board of Radiology 1964 Certified by.American Board of Nuclear Medicine 1972 Licensed.to practice medicine in (1) Commonwealth of Pennsylvania,

(2)-Illinois; and-(3) Minnesota Sandia Base, New Mexico; Nuclear Weapons Orientation Course 1961 Walter Reed Army Institute of Research, Washington, D.C.; Medical Si Aspects of Nuclear Warfare 1962 PROFESSIONAL EXPERIENCE 1981 present Vice Chairman and Chief Medical Officer, Radiation Management Corporation 1969-1981 President / Chief Executive Officer, Radiation Management Corporation fl974 present Clinical Associate Professor of Radiology, University of Pennsylvania School of: Medicine

. .1977-present Visiting Associate Professor, Clinical Radiology, Northwestern University Medical School

.1969-1974 Assistant Professor, Clinical-Radiology, University'of M Pennsylvania: School'of Medicine 1.1968-1969 Nuclear Medical Consultant,; Philadelphia Electric Company January-' . Assistant Professor, Radiology, University of-Minnesota l August 1968 Schooliof Medicine (investigated.use of isotopes in kidney _

function evaluation)'

'1957-1968 . Employed by United States Army:.

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1965-1968- Commanding Officer, Nuclear Medicine Research Detachment, Europe; Radiological Health Consultant, US Army-Europe.

(responsible for plans, procedures and training of military hospitals and personnel in the evaluation, evacution and treatment of radiation casualties. In January 1966 sent to Palomaris, Spain for evaluation of medical and environmental aspects of the mid-air collision involving nuclearfweapons)

-1961-1962 Research Associate, Department of Radiobiology, Walter Reed Army Institute of Research, Washington, D.C.

(investigated use of anti-radiation drugs in treatment of cancer) 1957-1961. General Medical Officer, Europe PROFESSIONAL APPOINTMENTS 1982 present American Medical Association Counsel on Scientific Affairs Subcommittee on the Management of Radiation Accident Victims 1979' present Health Physics Society Standards Committee l1978-present'

. General Dynamics _ Electric Boat Division Radiological Health Consultant 1973 present. - University of Pennsylvania Radiation Safety Committee

, ~1970-present -The American Nuclear Society Subcommi.ttee for Writing Emergency Procedures Standards 19691&-1975- - Atomic: Energy Commission ad hoc Committee on Medical

- Aspects.of Radiation Accidents 1966 present American College of Radiology:

1969 present Commission on Radiologic Units, Standards of Protection.

1969-present Committee on Radiation Exposure of Women 1969 present Committee on Radiological Aspects of Disaster Planning 1967-1978 International: Affairs Committee 1965-1968' U.S. Delegate to NATO Radiation Protection Committee and Medical-Aspects of_ Nuclear Warfare. Committee

[197'l;present- .- Department'of Defense and Environmental Protection' Agency Medical Liaison Officer's Network (MLON)-State of-W Pennsylvania-Representative I-

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i PROFESSIONAL MEMBERSHIPS American College of Radiology ,

American Public Health Association 3 American Medical Association

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Society of Nuclear. Medicine L Philadelphia Roentgen Ray Society Pennsylvania Medical Society College of. Physicians of. Philadelphia H Radiological Society of North America, Inc.

American Institute of Physicists /American

. Association of Physicists in Medicine lAmerican Ccllege of Nuclear Physicians l-AWARDS AND HONORS 1978. ' Association of Medicine & Security, Madrid, Spain

- (Honorary Member) 1968 University of Minnesota Radiological Research Scholar

. (National Research Council) 1968' United-States Army Legion of Merit I

' PUBLICATIONS

, 'Linnemann, Rog/r E. "The Acute Radiation Syndrome'and its Impact on the Chain of Evacuation" . - Medical Bulletin, U.S. Army Europe:22, No. 12 ,

December 1965?

FLinnemann, Roger E.<and Robert T. Wangemann. " Medical Support of Nuclear

,w Wanpons Accidents". Medical Bulletin, U.S. Army Europe (November 1967)

(Linnemann,' Roger:E.' and O. Messerschmidt. "Erholungsvorgaenge bei Grosstieren nach;Ganzkoorperbestrahlung", :dem 6, Jahrbuch von der v reinigung Duetscher Strahlenschutzaerzte (1968).

"Linnemann,. Roger'E. " Command Radiation-Guidance" Military Medicine: 33, s ipp. 771-716-(September:1968)

L ELoken,.Merle'K.,:Linnemann,JRoger-E. and. George S. Kush. " Evaluation of '

Rcnal-Function.Using a: Scintillation Camera and Computer" Radiology:93,

- Ns.D1, pp.-85-94.(July 1969)

LLinnemann,-RogerLE., Loken, Merle K.Jand: Colin Markland. " Computerized '

' l Cozpartmental~ Renograms tct Study -Kidney ' Function" Journal of Urology:103,

pp.1533-537

(May'1970)

Linnemann, Roger E. and J.W. Thiessen. " Regional \pproach to the Management-AoffRadiation. Accidents" Journal of the American Ptblic Health Association:61-

. Nob 6, pp. 1229-1235:(June 1971) k

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't Linnemann, Roger E. and Robert H. Holmes. " Nuclear Accidents and Their Management" Emergency Medical Care, pp. 281-292, Spitzer, Stanley and Wilbur W. Oaks (eds.) New York: Brune and Stratton, Inc. (1971)

Linnemann,_ Roger E. " Medical Aspects of Power Generation" Impulse Massachusetts: Electrical Council of New England (June 1975)

Linnemann, Roger E. " Bugs in the Nuclear Fuel Cycle" Spectrum, p. 59, Gadi Kaplan:(ed.) Piscataway,_NJ: The Institute of Electrical and Electronic Engineers, Inc. (September 1975)

Linnemann, Roger E. and. Fred A. Mettler, Jr. " Emergency Medical Assistance Programs for Nuclear Power Reactors" International Atomic Energy Agency Symposium on the Handling of Radiation Accidents, IAEA-SM-215/22, Vienna Austria '1977)

Linnemann, Roger E. "Why ALARA?" Transactions of 1979 American Nuclear Society Conference, Atlanta, GA (June 3-7, 1979), Vol. 32, TANS AO 32 1 83;

-ISSN 0003-018x (1979).

Linnemann,-Roger E., Hackbarth, C.J. and Ray Crandall. "The Contaminated and Injured Patient" Proceedings of Twenty-Fourth Annual Meeting of the Health Physics Society, July 9-13, 1979 (Philadelphia, PA)

Linnemann, Roger E. ",The Three Mile Island Incident in 1979: The Utility Resposne" The Medical Basis'for Radiation Accident Preparedness, K.F. Hubne and_S.A. Fry (eds), Elsvier/ North-Holland, pp. 501-509-(1980)

Linnemann, Roger E. " Initial Management of Radiation-Injuries" Journal of Radiation Protection,-5, No. 1, pp. 11-25 (December 1980)

Linnemann, Roger E. " Facilities for Handling.the Contaminated Patient" Radiation Accident Preparedness: Medical and Managerial Aspects, Science-Thru-Media Company: New York (1980)

Linnemann,. Roger E., Eugene Saenger, Gould A. Andrews and Niel Wald.

"A Systems Approach to the Initial Management of Radiation Injuries"

' Systems' Approach to Emergency Medical Care, Appleton-Century-Crofts:

New York (1980) i Linnemann, Roger E., Stephen M. Kim and Frazier L. Bronson. "Three Mile

-Island

Medical and Public Health Aspects of a Radiation-Accident" Journal of Radiation Protection,-6, No. 1, pp. 45-54 (October 1981) l Y

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f e' g~ i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARDgr f vennC a

In the Matter of ) ES FtB -8 A11 :02

)

THE CLEVELAND ELECTRIC ) Docket-Nos.:50-440 ILLUMINATING COMPANY ) 00 KEin3 r509441

) SRANCH (Perry Nuclear Power Plant, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Motion For

--Summary Disposition of Contention P," " Applicants' Statement of Material Facts As'To Which There Is No Genuine Issue To Be Heard on' Contention P," and." Affidavit of Roger E. Linnemann on Contention'P" were served this 5th day of February, 1985, by deposit in the U.S. mail, first class,. postage prepaid, upon the parties listed on the attached Service List, except for those parties identified by asterisk who were served by hand delivery.

f ) i N. $ < / ,

Jay- S lberg

. Dated:' February'5, 1985-L_

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-t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

~ THE' CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL. ) 50-441

)

(Perry Nuclear Power Plant, )

Units 1 and'2) )

SERVICE LIST-JamesJP. Gleason, Chairman Atomic Safety and Licensing 513 Gilmoure Drive Appeal Board Panel Silver Spring, Maryland 20901 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Jerry R. Kline Docketing and Service Section Atomic Safety and Licensing Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr.-Glenn O. Bright + Colleen P. Woodhead, Esquire Atomic Safety and Licensing Board Office of the Executive Legal U.S.-Nuclear Regulatory Commission Director Washington, D.C.- 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Alan S. Rosenthal, Chairman Atomic Safety and Licensing hrTerry Lodge, Esquire

-Appeal Board Suite 105

.U.S. Nuclear Regulatory Commission 618 N. Michigan Street Washington, D.C. 20555 Toledo, Ohio 43624 Dr. W. Reed Johnson Donald T. Ezzone, Esquire Atomic Safety and Licensing Assistant Prosecuting Attorney Appeal Board .

Lake County Administration

.U.S. Nuclear Regulatory Commission Center Washington, D.C. 20555 105 Center Street Painesville, Ohio 44077 Gary J. Edles, Esquire AtomicfSafety and Licensing Atomic Safety and-Licensing

~ Appeal Board Board Panel U.S.oNuclear Regulatory Commission U.S. Nuclear Regulatory Commission 1 Washington, D.C. 20555 Washington, D.C. 20555

' John G. Cardinal, Esquire. 46 Ms. Sue Hiatt Prosecuting Attorney '8275 Munson Avenue Ashtabula County Courthouse Mentor, Ohio 44060 Jefferson,. Ohio -44047 w.

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