ML20215E068

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Applicant Motion for Summary Disposition of Seacoast Anti- Pollution League Contention 25.*
ML20215E068
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 06/11/1987
From: Dignan T
PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20215D921 List:
References
OL, NUDOCS 8706190242
Download: ML20215E068 (9)
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Dated: June 11, 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD I

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In the Matter of )

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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL

) Off-site Emergency (Seabrook Station, Units 1 and 2) ) Planning Issues

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APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION OF SEACOST ANTI-POLLUTION LEAGUE CONTENTION NO. 25 Now come the Applicants pursuant to 10 CFR 2.749 and on the basis of the facts set forth in the " Affidavit of Richard H. Strome (SAPL-25)" and for the reasons set forth below, move the Board to issue an order granting summary disposition in favor of the Applicants with respect to Seacoast Anti-Pollution League (SAPL) Contention No. 25.

REASONS FOR GRANTING THE MOTION SAPL Contention No. 25 reads as follows: j i

"The New Hampshire State and Local Rules j and Emergency Response Plans do not j reasonably assure that the public health i and safety will adequately be protected j l

1 8706190242 870611 I PDR ADOCK 05000443 I G PDR J

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I because the provisions for protecting j those persons whose mobility may be j impaired due to such factors.as i institutional or other confinement are patently lacking, therefore the plans do  ;

not meet the requirements of 10 CFR '

6 10.47(a)(1), S 50.47(b)(8) and NUREG j II-J.10.d." l This contention also raises the issue of "special needs" i i

persons. The Strome Affidvit makes clear that adequate i

provisions have been made for reception of the mobility impaired in Exeter Hospital, Strome Aff. 2-6;. Seacoast i

Health Center, id. 7; Eventide Home and Goodwin's of l Exeter, Ijd. 8. Letters of Agreement (LOA's) are in place  ;

1 with ambulance companies as well as with the Red Cross. Id. ]

11 9-10. Manpower and transportation requests have been  !

met. Id. 11-14. No basis exists for saying that NHRERP Rev. 2 does not adequately plan for the mobility impaired.

i By their attorneys, j 7

. c ptl(N .cl Thomas G. Dignan, Jr.

George H. Lewald Kathryn A. Selleck Deborah S. Steenland Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 f

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STATEMENT OF MATERIAL' FACTS NOT-IN DISPUTE j i

1. Revision 2 of the'New. Hampshire Radiological

, i Emergency Response Plan.(NHRERP), Volume 26A (Exeter Special  ;

.f Facilities. Plans) contains in Attachment A to the Exeter i Hospital RERP, letters of agreement with all three of its i

designated host: facilities; i.e., Concord Hospital,-Catholic ( l Medical Center and.Hampstead Hospital. Each' host-facility

-1 indicates that it would provide. temporary shelter.as a receiving site for Exeter Hospital in-the event evacuation j is required.

2. The categories of patients cited in SAPL Contention No. 25 are " transportation" grouping categories only. The

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level of care categories contained in all letters of i i

agreement are " medical care" grouping categories which are.

1 standard in the medical industry. Hampstead Hospital is not- l an acute care hospital; so by definition, it can only' accept Class I patients. This is well understood by healthcare administrators and does not have to be restated in the l letter of agreement. Hampstead Hospital can accept 25 Class I patients. Exeter Hospital has a capacity of only 10 Class III patients. The following summarizes-the commitment ,.

for providing temporary shelter for the three classes of  ;

Exeter Hospital patients, and constitutes an excess capacity for evacuation. Exeter Hospital has a maximum of 80 patients; compared to 85 shelter slots available.

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. - 1 Intermediate Advanced l Ambulatory Care' Life Support. j (Class I) (Class'II) '(Class III) J 20 10

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Catholic Medical Center --- 1 Concord Hospital --- 20 10 Hampstead Hospital 25 --- ---

Totals- 25 40 20-.

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3. The Exeter Hospital RERP (Section.II; Ail)Cassigns-the responsibility for' overseeing'the: preparation.of patient

. census reports, the classification of patients for  ;

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transport, and the coordination of the patient care,

,i clinical care and support departments to the Direc, tor'of. -!

Nursing.. The EMS Coordinator is.responsibleLfor verifying 4

that patient transportation need assessments are: appropriate l

for.the category of patient,; identifying special' 1 l

transportation needs, and' contacting designated host j i

i facilities to determine their capabilities, j i

4. The Exeter Hospital RERP.(Section III.D.5.f) 1 I

designates prioritization, by " transportation" group ) '

J categories, the staffing levels required for each category.-  !

The following is a comparison between " medical care" class,. l q

" transportation" categories and Exeter Hospital patient j capacity. )

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Evacuation Approximate f Medical Level. Transportation. Patient 1

~ of Care Categories Capacity Class I (Ambulatory) ..

IV- 40-50

  • Class II (Intermediate' Care) II and.III 12-20"*- J Class III (Advanced Life Support) I~ 5-10
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  • Maximum patient'capacityz(total of 80) ]

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5.Section III.C,7 to-the Exeter Hospital RERP provides for the prioritization of patients for evacuation. This  !

-t includes allowing for consideration (by medical personnel)  !

of current medical status, as'it applies to patients falling .

I into the categories of (1) Medical / Surgical, (2) Recovery-  !

Room, and (3) Intensive / Cardiac Care (ICU/CCU) only. The.  !

I next revision of the NHRERP will include-a revision that, at'

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the Site Area Emergency classification, authorities should 1 determine which patients who, by virtue of age or' medical- y 1

condition, will require extraordinary assistance in- d l

evacuation.

6. Volume 18A'(Hampton Special Facilities Plans) of the NHRERP contains the Seacoast Health Center RERP.

I Attachment A,Section II, lists the Maple Leaf Health Care j i

host facilities on Pearl Street, Maple Street, an'd the Villa ,

Crest Units; all of which are located in Manchester, NH.

All three host facilities have the same owner who has submitted a letter of agreement indicating the willingness of these three facilities to serve as host facilities for the Seacoast Health Center. Attachment "A" to Strome Aff.

7. Volume 26A (Exeter Special Facilities Plans) of.the RERP contains both the Eventide Home RERP, and the'Goodwin's

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e of Exeter RERP. The Eventide Home host facility is McKerley

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Health Care Center in Derry, NH. Goodwin's three' host '

facilities, which are all owned'by the " Clipper Home Affiliates," are the Clipper Homes of Wolfboro, Rochester- )

s and North Conway. These facilities have verbally agreed to j q

serve as host facilities and a. letter of agreement covering - j

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all of the above host facilities will be appen'ed.to their respective RERP. In the case of Goodwin's:of Exeter,11t'is also owned by Clipper Home . Affiliates; :therefore, a letter-of agreement is not required. However, one will be- i provided.

8. Letters of agreement with Reception Centers are not required, as these are public buildings. Volume 5 of the .

NHRERP contains a letter of agreement with the American National Red Cross. Letters of agreement are not required-

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between the State and potential mass care facilities, as the Red Cross handles this role. The Regional Assistance Committee (RAC) stated ~in their August,=1986 reply to NHRERP's Revision 2 that this arra'ngement was adequate (A),

and replied on page 10 of 134 with the following.

A.3(2) - The Red Cross Letter of Agreement demonstrates an ability to 1 open and staff planned mass care '

facilities. The Red' Cross letter of agreement states that "the American Red Cross will conduct' shelter and feeding operations in' centers and facilities designated in advance by' the New Hampshire Disaster Planning Office, under arrangements worked out among the Disaster Planning

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3. l L b; Office, the American Red Cross and

. officials or owners of the.

buildings."

9. Volume 5 of the.NHRERP-contains-a letter of agreement with the'O'Brien' Ambulance Company'of Beverly, MA,.

in which they specificallyLstate that they will. provide emergency transportation' services for an' accident at.the' Seabrook Nuclear Power Station. All letters of-agreement include.a commitment to~ provide the required number of-ambulance. company personnel (EMTs). Even if O'Brien were.

unable to provide assistance at the time of.an emergency for i whatever reason, sufficient reserves of ambulances and EMTs are available under agreement to meet anticipated requirements.

10. Volumes 16 through-32 of the NHRERP comprise;all of-the 17 New Hampshire Town RERPs. In Section IV of each plan, an attachment to the Transportation Coord$nator's (or equivalent town title) provides the individual town transportation requirements. Included-in each. list is a category entitled "Special Needs" which lists thoseL requirements based on the Special Needs Survey conducted by .  ;

the State of New Hampshire (NHCDA).

11. Revision 2 of the NHRERP, Volume 2 (Appendices),

l contains in Appendix I (pg. I-3), a summary of j transportation resource requirements for_all 17 New i Hampshire towns and any special facilities or institutions.

The number of vans required is specified. This table and-7-

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b, allJ17 local town-RERP transportation requirementsilistings, will all be updated to reflect current information.

12. It.is unclear from the contention whatLthe basis; which asserts lack of manpower refers.to - lack of manpower for' identifying persons with special needs cnr lack'of'

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manpower.for assisting mobility. impaired persons in an evacuation. For the former, manp'ower at the state or loca11 level'is not an issue; ide:ntification . of these people isj done by means of a mailed survey conducted by'NHCDA.. For the latter, the plans make provisions for emergency medical support personnel to provide this assistance. .Approximately 200 such individuals have been identified within the EPZ-communities through the Bureau of Emergency Medical Services- .

of the New Hampshire Division of Public Health Services. In addition, NHCDA has written agreements'with ambulance services beyond the EPZ communities which indicate that.

approximately 130 emergency medical personnel are available to accompany ambulances and to provide assistance for' mobility impaired persons. As an added resource, the N.H.  !

National Guard can make available approximately 75 medically qualified personnel. The NHCDA Special Needs Survey was utilized during development of the NHRERP, Revision 2 to assess the need for assistance. The survey revealed 44 persons outside of institutions who are bed-ridden and may require assistance. Special facility plans.for hospitals '

and nursing homes provide for staffing forL this purpose.

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, 13. Ambulance: drivers are trained in advance in the-methods in whichtthey will be assigned. pickup of homeboun'd or institutionalized evacuees. This:would also inclu'de other drivers evacuating this group. Directions with which ambulance drivers can reach effected homes and institutions are provided:to them upon dispatch from the. Local Transportation Staging Area, as. described in Appendix!F to j the Rockingham County Sheriff's Department procedure in 1

Volume 4B (State Agency Procedures for'Seabrook Station)'of' the NHRERP. They will receive a map to an institution and written directions to individual homes (if required). .

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