ML20136E140

Proposal for Resolution of Remanded Issue from Second Partial Initial Decision ALAB-819 Re Medical Arrangements for Contaminated/Injured Onsite Personnel.One Oversize Map & Certificates of Svc Encl

ML20136E140
Person / Time
Site:	Limerick
Issue date:	11/18/1985
From:	Conner T, Corner T CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
References
CON-#485-231 ALAB-819, OL, NUDOCS 8511210430
Download: ML20136E140 (15)

Text

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pg 6-UNITED STATES OF AMERICA '85 NOV 20 A10:35

. NUCLEAR REGULATORY COMMISSION

(.FFICE OF SEh W Before the Atomic Safety and LicensinWB6kedg O '.

In the Matter of )

)

Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 C[_,

(Limerick Generating Station, )

Units 1 and 2) )

LICENSEE'S PROPOSAL'FOR RESOLUTION OF REMANDED ISSUE REGARDING LICENSEE'S MEDICAL ARRANGEMENTS FOR CONTAMINATED INJURED ONSITE PERSONNEL Preliminary Statement In ALAB-819, the Atomic Safety and Licensing ' Appeal .

Board (" Appeal Board") affirmed the Second Partial Initial Decision issued by the presiding Atomic Safety and Licensing Board (" Licensing Board" or " Board") in all respects except ane. The single matter remanded for further disposition is the addition of a second backup hospital to receive any of the Licensee's onsite personnel who might be both contaminated and injured as a result of an accident at the Limerick Generating Station (" Limerick") .O In accordance with the romand instructions of ALAB-819, the Licensing Board iesued an Order, dated October 28, 1985, 1/ See Philadelphia Electric Company (Limerick Generating

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IIation, Units 1 and 2), ALAB-819, 22 NRC (October 22, 1985) (slip op. at 39-50, 100-01), rev'a in part, LBP-84-31, 20 NRC 446 (1984).

est12tos esiste POR A K O$000352 9 PDR NE

which directed Licensee to submit its proposal for resolu-tion of the remanded issue 20 days from service of the order.M The Board further directed Licensee to submit a map geographically plotting the location of the 19 hospitals (in addition to the Pottstown Memorial Medical Center) listed in the Limerick offsite emergency plans, with clearly discernible distances from Limerick noted. Finally, the Board directed that the status of accreditation by the Joint Committee on Hospital Accreditation ("JCHA") for each hospital be clearly identified.

I. Licensee's Response to the Licensing Board's Request for Information.

i As directed, Licensee has prepared a chart depicting each of the 20 hospitals (including Pottstown Memorial Medical Center) listed in the offsite emergency plans for Limerick as capable of treating contaminated injured indi-viduals. The attached chart lists each of the 20 hospitals, the county in which it is located, its distance from Limerick, and JCHA accreditation status. Also attached is a map of the Limerick area, including the area beyond the

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2/ Limerick, supra, " Order" (October 28, 1985). The Board afforded t ie NRC Staff, the Commonwealth of Pennsylvania and Limerick Ecology Action (" LEA") an 6 opportunity to comment on the Licensee's proposal. The Board also urged interested parties "to submit any  ;

other material information which in their opinion will satisfy the Commission requirements under Section IV.E.

of Appendix E to 10 CFR Part 50 for a back-up facility

for treatment of contamined injured individuals." I_d, d.

l at 2.

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approximately 10-mile plume' exposure emergency planning zone

.("EPZ"), which depicts the location of each hospital in relation to'the Limerick plant.

II. Licensee's Proposal for Resolution

' of the Remanded Issue.

In compliance with ALAB-819 and the Licensing Board's Order, Licensee has' pursued available options with regard to a second backup hospital to receive onsite personnel who I 1

might be contaminated and injured in the event of an acci-  !

dent at Limerick.1 As a result of its review of area hospitals, Licensee'datermined that the Montgomery Hospital 1

in Norristown is a suitable choice because it meets the Appeal Board's stated objective of designating a hospital outside the EPZ hut closer to Limerick than the Hospital of the University of Pennsylvania (" HUP"). Accordingly, PECO has entered an agreement with Montgomery Hospital to serve as a second backup. A copy of the agreement is attached.

Inasmuch as the Appeal Board expressly declared in ALAB-819 that "[wle do not impose any particular requirements on PECo's arrangements for adequate backup medical services for persons who are contaminated and t

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3/ It is noted that Licensee has asked the Commission to review this particular disposition in ALAB-819, given

. the situation at other nuclear power plants throughout the United States, many of which rely upon a backup hospital located ' more than 100 miles away from the facility. See Licensee's Petition for Review of ALAB-819 (November 5, 1985) .

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s injured onsite,"M ' Licensee sees no issue to be litigated in further-hearings. ,

The capability of Montgomery Hospital to handle contam-ina'ted injured patients has already been established.on the v record by competent medical testimony. Specifically, =the capability to provide medical treatment for contaminated injured inmates at the State Correctional Institution at Graterford was raised by the inmates as an issue in t' hat .'

phase of the proceeding that led to the issuance of the Fourth Partial Initial Decision. To resolve the inmatesI 5

concern,_/ Licensee provided the Board and parties with the

, ' affidavit of Roger E. Linnemann, M.D., who had testified as Licensee's expert witness on the subject of medical ,

arrangements for the treatment of contaminated injured [ r i

onsite personnel in an earlier phase of the proceeding (ff.

.? of Tr. 9772, 9791 ej seg. ) . ,

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4/ Id. at 49 n.7. The Appeal Board further stated that

. 'Tw]e simply expect PECo to explore the entire range of ,,f reasonable options addressed to the concerns raised by '.-

LEA's contention" and that "the facility selected should lie beyond the area subject to potential evacuation, but should' otherwise be as close as possible to Limerick " M.

5_/ At a prehearing conference on March 22, 1985, the inmates' counsel stated that this particular concern would be satisfied by an affidavit from Dr. Roger E.

Linnemann as to the capability of the hospital which routinely provides treatment to Graterford prisoners to handle contamined injured individuals (Tr. 20720).

Dr. Linnemann visited Montgomery Hospital on April 1,

.i 1985 "to evaluate the hospital's plans and preparations for handling radiation exposure cases as well as radioactively contaminated and injured patients."bI As stated in his

( .g affidavit provided to the Board and parties, Dr. Linnemann

'Kt'.,

r*" , met with responsible hospital staff and provided a detailed

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evaluation of the hospital's ability to treat contaminated

' injured individuals. . Dr. Linnemann concluded that, in his professional opinion, Montgomery Hospital "has adequate facilities, plans, procedures and trained staff to handle contaminated and injured patients as well as those external-ly exposed to radiation."1/

Given the professional qualifications of Dr. Linnemann, the thoroughness of his evaluation, and the conclusiveness of his medical opinion, Licensee believes that there is no

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further issue to be litigated.8_/ Accordingly, after the a

review and commen period provided by the Board in its Order of October 28, 1985, Licensee believes that the Board should e

issue a supplemental PID with the requisite findings or take

, other appropriate action.

,/ 6/ Affidavit of Roger E. Linnemann, M.D. 11 (April 4, y,- 1985).

7/ Id. at 14.

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8/ Licensee's agreement with Pottstown Memorial Medical Center is already in the record (PECO Exh. 43) and was

, found acceptable by all parties, including the NRC (Footnote Continued) f

,, o i w 1, , .- .. ._ .- - - - _ _ _ -

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l Conclusion For the reasons discussed above, Licensee has satisfied i

the requirements for obtaining a second backup hospital for the treatment of any contaminated injured onsite personnel in the event of an emergency at Limerick and has therefore complied with the requirements on remand from ALAB-819.

Following a comment period for the parties, the Board should issue a supplemental PID with requisite findings as to the second backup hospital or take other appropriate action.

' Respectfully submitted, CONNER & WETTERHAHN, P.C.

Troy . Conner, Jr.

Robert M. Rader Nils N. Nichols Counsel for the Licensee November 18, 1985 1

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(Footnote' Continued)

Staff. The Appeal Board also accepted the agreement.

See Limerick, supra, ALAB-819, 22 NRC (October 22, 1985) (slip op. at 40-41).

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03LKETEC U5tWC UNITED STATES OF AMERICA '85 NOV 20 N0:35

. NUCLEAR REGULATORY COMMISSION OFFICE OF SECRL'A.-

DOCKETt LPW ;

In the Matter of )

)

Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Proposal for Resolution of Remanded Issue Regarding Licensee's Medical Arrangements for Contaminated Injured Onsite Personnel," dated November 18, 1985 in the captioned matter have.been served upon the following by deposit in the United States mail this 18th day of November, 1985:

• Helen F. Hoyt, Esq. Atomic Safety and Licensing Chairperson Appeal Panel Atomic Safety and U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Docketing and Service Section

• Dr.. Richard F. Cole U.S. Nuclear Regulatory Atomic Safety and Commission Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory i

. Commission Ann P. Hodgdon, Esq.  !

Washington, D.C.- 20555 Counsel for-NRC Staff Office of the Executive

• Dr. Jerry Harbour Legal Director Atomic Safety and U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555

• Hand Delivery

1 2-s Atomic Safety and Licensing Angus Love, Esq.

Board Panel 107 East Main Street U.S. Nuclear Regulatory Norristown, PA 19401 '

Commission-Washington, D.C.~ 20555 Robert J. Sugarman, Esq.

Sugarman, Denworth &

Philadelphia Electric Company Hellegers ATTN: Edward G. Bauer, Jr. 16th Floor, Center Plaza Vice President & 101 North Broad Street General Counsel Philadelphia, PA 19107 2301 Market Street Philadelphia, PA 19101 John L. Patten, Director Pennsylvania Emergency Mr. Frank R. Romano. Management Agency 61 Forest Avenue Room B-151

! Ambler, Pennsylvania 19002 Transportation and Safety Building Mr. Robert L. Anthony Harrisburg, PA 17120 Friends of the Earth in the Delaware Valley Kathryn S. Lewis, Esq.

106 Vernon Lane, Box 186 City of Philadelphia Moylan, PA 19065 Municipal Services Bldg.

l 15th and JFK Blvd.

Charles W. Elliott, Esq. Philadelphia, PA 19107 325 N. 10th Street Easton, PA 18064 Spence W. Perry, Esq.

Michael B. Hirsch, Esq.

! Miss Phyllis Zitzer Associate General Counsel Limerick Ecology Action Federal Emergency P.O. Box 761 Management Agency 762 Queen Street 500 C Street, S.W. -

Pottstown, PA 19464 Room 840 Washington, DC 20472 Zori G. Ferkin, Esq.

Assistant Counsel Thomas Gerusky, Director

. Commonwealth of Pennsylvania Bureau of Radiation Governor's Energy Council Protection 1625 N. Front Street Department of Environmental Harrisburg, PA 17102 Resources 5th Floor Jay M. Gutierrez, Esq. Fulton Bank Bldg.

U.S. Nuclear Regulatory Third and Locust Streets Commission Harrisburg, PA 17120 631 Park Avenue King of Prussia, PA 19406 1

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James Wiggins Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 47 Sanatoga, PA 19'464 Timothy R.S. Campbell, Esq.

Director Department of Emergency Services 14 East Biddle Street West Chester, PA 19380 Mr. Ralph Hippert Pennsylvania Emergency Management Agency B151 - Transportation and Safety Building Ilarrisburg, PA 17120 Theodore G. Otto, Esq.

Department of Corrections Office of Chief Counsel P.O. Box 598 Lisburn Road Camp Hill, PA 17011 4 .

' Rcbert M. Rader

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DMKEiEP UStiRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '85 NOV 20 A10:35 0FFin CF SECktiAr In the Matter of ) 00CKETING 4 SLRV:G BRANCH

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Philadelphia Electric Company ) Docket Nos._50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

AMENDED CERTIFICATE OF SERVICE I hereby certify that copies of "Lic ansee's Proposal for Resolution of Remanded Issue Regarding Licensee's Medical Arrangements for Contaminated Injured Onsite Personnel," dated November 18, 1985 in the captioned matter have been served upon the following by deposit in the United States mail this 18th day of November, 1985:

• Helen F. Hoyt, Esq. Atomic Safety and Licensing Chairperson Appeal Panel Atomic Safety and U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Docketing and Service Section

• Dr. Richard F. Cole U.S. Nuclear Regulatory Atomic Safety and Commission Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission

• Ann P. Hodgdon, Esq.

Washington, D.C. 20555 Counsel for NRC Staff Office of the Executive

• Dr. Jerry Harbour Legal Director Atomic Safety and U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555

• Hand Delivery

0 Atomic Safety and Licensing Angus Love, Esq.

Board Panel 107 East Main Street U.S. Nuclear Regulatory Norristown, PA 19401 Commission Washington, D.C. 20555 Robert J. Sugarman, Esq.

Sugarman, Denworth &

Philadelphia Electric Company Hellegers ATTN: Edward G. Bauer, Jr. 16th Floor, Center Plaza Vice President & 101 North Broad Street General Counsel Philadelphia, PA 19107 2301 Market Street-Philadelphia, PA 19101 John L. Patten, Director Pennsylvania Emergency Mr. Frank R. Romano Management Agency 61' Forest Avenue Room B-151 Ambler, Pennsylvania 19002 Transportation and Safety Building Mr. Robert L. Anthony Harrisburg, PA 17120 Friends of the Earth in the Delaware Valley Kathryn S. Lewis,.Esq.

106 Vernon Lane, Box'186 City of Philadelphia Moflan, PA 19065 Municipal Services Bldg.

15th and JFK Blvd.

• • Charles W. Elliott, Esq. Philadelphia, PA 19107 325 N. 10th Street Easton, PA 18064 Spence W. Perry, Esq.

Michael B. Hirsch, Esq.

• • Miss Phyllis Zitzer Associate General Counsel Limerick Ecology Action. Federal Emergency P.O. Box 761 Management Agency 762 Queen Street' 500 C Street, S.W.

Pottstown, PA 19464 Room 840 Washington, DC 20472

• • Zori G. Ferkin, Esq.

. Assistant Counsel Thomas Gerusky, Director Commonwealth of Pennsylvania- Bureau of Radiation Governor's Energy Council Protection 1625 N. Front Street Department of Environmental Harrisburg, PA 17102 Resources 5th Floor Jay M. Gutierrez, Esq. Fulton Bank Bldg.

U.S._ Nuclear Regulatory Third and Locust Streets Commission Harrisburg, PA 17120 631 Park Avenue King of Prussia, PA 19406

• • Federal Express

a 4 James Wiggins Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 47 Sanatoga, PA 19464 Timothy R.S. Campbell, Esq.

Director Department of Emergency Services 14 East Biddle Street West Chester, PA 19380 Mr. Ralph Hippert Pennsylvania Emergency Management Agency B151 - Transportation and Safety Building Harrisburg, PA 17120 Theodore G. Otto, Esq.

Department of Corrections Office of Chief Counsel P.O. Box 598 Lisburn Road Camp Hill,-PA 17011 4 8 ~h L Robert M. Rader

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l November 15, 1985 Dr. William F. Hushion Medical Director l Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101

Dear Dr. Bushion:

i This letter confirms the verbal understanding reached between Montgomery Hospital and Philadelphia Electric Company '

(PECO).

Montgomery Hospital agrees to respond to PECO requests to provide hospital treatment for victims of radiological accidents, including contaminated individuals from the Limerick Generating Station. Montgomery Hospital also agrees to maintain its capacity to respond to these incidents, making appropriate personnel available for training and participation in emergency medical drills, and to fulfill its responsibilities delineated in .

its protocol for handling radiation accidents.

It is the understanding of Montgomery Hospital that PECO agrees to the following:

1. To provide for the training and retraining of Montgomery Hospital personnel in the medical l response to radiological accidents. .

2. To provide special equipment and supplies necessary for Montgomery Hospital to maintain its capacity to

, respond to radiological accidents.

3. To provide procedures for the handling, treatment and decontamination of an injured or ill patient from the Limerick Generating Station.

4. To perform a semi-annual inventory of equipment and facilities. -

5. To provide for the removal from Montgomery Hospital  ;

of all contaminated waste resulting from radiological accidents involving PECO personnel or facilities. -

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N:v bar 15,1985 Paga Twa

6. To provide monitoring for radioactive contamination, and decontamination required as a result of incidents involving individuals from Limerick Generating Station, and to repair or replace equipment and facilities which in PEco judgment are not decontaminable to Nuclear Regulatory Commission standards for unrestricted use, or are damaged by PECO decontamination offorts.

7. To provide a PECO-qualified Radiation Protection Technician at the hospital, for each incident, in .

the ambulance or at least upon arrival of the ambulance at Montgomery Hospital.

8. To provide or arrange for ambulance service. <

9. To retain a medical consultant to include consultation and laboratory se'rvices on a 24-hour standby basis (including dispatch of consultant to Montgomery Hospital if medically required), and '

through said consultant to provide access to a definitive care center.

i Ap6sde

~ _ #l/Y "Date I fent go ery Hospital cor Roberta Kankus (PECO) , .

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LIMERICK GENERATING STATION HOSPITALS LISTED 'IN RISK COUNTY' PLANS Map Distance JCHA Numbe[ Hospital County from_ LGS (l) Accredited-1 Community General Hospital Berks County 19.0 Yes 2 Reading Hospital and Medical Center Berks County. 20.0 Yes 3 Saint Joseph's Hospital Berks County 18.5 Yes 4 Brandywine Hospital Chester County 21.5 Yes 5 Chester County Hospital Chester County 17.5 Yes 6 Paoli Memorial Hospital Chester County 13.5 Yes 7 Phoenixville Hospital Chester County 8.5 Yes 8 Southern Chester County Medical Center Cnester County 31.5 Yes 9 Abington Memorial Hospital Pontgomery County 25.0 Yes ,

10 bryn Mawr Hospital S'untgomery County 20.0 Yes 11 Chestnut Hill Hospital Philadelphia County 22.5 Yes 12 Grand View Hospital Bucks County 15.0 Yes 13 Holy Redeemer Hospital "ontgomery County 27.5 Yes 14 Lankenau Hospital Montgomery County 23.5 Yes 15 Montgomery Hospital Montgomery County 14.5 Yes 16 Nortn Penn Hospital Montgomery County 17.0 Yes 17 Rolling Hill Hospital '-1u n tg ome r y County 27.5 Yes lo Sacred Heart Hospital "ontgomery County 15.5 Yes 19 SurburDan General Hospital Pontcomery County 15.0 (2) 20 Pottstown Memorial Medical Center Montgomery County 1.5 Yes NOTES:

(1) Distances are derived from the original 35 inch by 45 inch Alfred B. Patton, Inc. map.

The distances on the reproduced versions are not to scale.

(2) Accreoited oy the American Osteopathic Hosnital Association. ,

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• APERTURE CARO /HARD COPY AVAILABLE FROM RECORD SEfMCES BRANCH,TIDC FTS 492=S989 .

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