ML20236T137

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Responds to Wolf 871027 Request for Status Rept on Medical Svcs Issues Re Plant.Fema 871006 & 1119 Ltrs to NRC Re Review of Offsite Medical Svcs for Plant Encl.Fema Preparing Amended Guidance on Point Due to Confusion
ML20236T137
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 11/23/1987
From: Vogler B
NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To: Hand C, Johnson E, Wolfe S
Atomic Safety and Licensing Board Panel
References
CON-#487-4914 OL, NUDOCS 8712010039
Download: ML20236T137 (10)
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Eu Sheldon J. Wolfe, Chairman Dr. Cadet H. Hand, Jr. Administrative Judge Administrative Judge Atomic Safety and Licensing Board c/o Bodega Marine Laboratory U.S. Nuclear Regulatory Commission University of California J Washington, D.C. 20555 P. O. Box 247 Bodega Bay, California 94923 Mrs. Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory P. O. Box X, Building 3500 Oak Ridge, Tennessee 37830 in the Matter of SOUTHERN CALIFORNIA EDISON COMPANY, ET AL., (San Onofre Nuclear Generating Station, Units 2 and 3) Docket Nos. 50-361 OL s 50-362 OL

Dear Administrative Judges:

This letter is in response to the letter from Judge Wolfe, dated October 27, 1987, requesting a status report on the medical services issues (10 C.F.R. 6 50.47(b)(12) that are pending in the captioned matter, in a Memorandum addressed to Frank J. Congel, Director, Division of Radia-tion Protection and Emergency Preparedness, Office of Nuclear Reactor Regu-lation, NRC, the Federal Emergency Management Agency (FEMA) on October 6,1987, furnished the NRC staff with a copy of its " Interim Findings And Determination Relating To The Status Of Medical Services At The San Onofre Nuclear Generating Station." On pages 2-3 thereof, FEMA, in Section L.3, notes that the list of hospitals statewide known to have a capabi!Ity for treating contaminated injured individuals is only partially adequate because it does not contain information to indicate ambulatory /non-ambulatory capacities for providing medical support for contaminated injured members of the general public. FEMA notes that the State of California is upgrading its list of hos-pitals and concludes on page 5 of its " Interim Findings" that there is reason-able assurance that the plans for medical services for members of the general public who may be contaminated / injured as a result of a radiological emergen-cy at San Onofre are adequate and can be implemented. The Staff, after further consultations with FEMA, forwarded the FEMA " inter-im Findings" along with its analysis in a Memorandum, dated November 19, 1987, from Mr. Congel to William J. Olmstead, Assistant General Counsel for 8712010039 871123 {DR ADOCK 05000361 1 PDR h90

l Hearings, . Office of the General Counsel. In the Staff memorandum,  : Mr. Congel points out that the reason the San Onofre hospital lists do not  ! Indicate ambulatory /non-ambulatory capacities is because of confusion over terminology and' that this confusion is not restricted to San Onofre. . Mr. Congel points out that FEMA is preparing amended guidance on this point ' because of the confusion that has developed. Mr. Congel ccncludes that the FEMA finding is positive and that the - Staff finds that there is reasonable assurance that adequate and protective measures can and will be taken in the event of a radiological emergency at San Onofre. Copies of. the FEMA Memoranda, " Interim Findings" and the Staff Memorandum ., are transmitted herewith for the information of the Board and parties to this i proceeding. 

                                                                                               . Sincerely, f    YW' N       .

B njamin H. Vog!r Senior Supervisory Triali- ttorney

Enclosure:

As stated cc: Service List 1 ii

[ llV November 19, 1987 . l l -i J Docket Nos.:- 50-361/362 L. 

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i MEMORANDUM TO: William J. Olmstead Assistant General Counsel for Hearings - Office of the General Counsel .! Frank J. Congel, Director d FROM: 1 Divist'on of Radiation Protection -{ and: Emergency Preparedness l Office of Nuclear. Reactor Regulation ]

SUBJECT:

FEMA REVIEW 0F 0FFSITE MEDICAL SERVICES FOR SAN ONOFRE 1 

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This memorandum forwards. a FEMA finding that the emergency plans of the State of California and the concerned local jurisdictions satisfy the requirements j of FEMA Guidance Memorandum MS-1, Medical Services, for San Onofre with the exception of one item. The exception involves the annotation of hospital lists to indicate ambulatory /non-ambulatory capacities. It is our understanding from discussions with FEMA that the hospital lists do not indicate ambulatory /non- ) ambulatory capacities because of confusion over the terminology. FEMA has advised that the San Onofre plan is not the only plan that reflects J confusion over the terminology regarding hospital capacities. FEMA is pre-paring amended guidance for GM-MS-1 on this point because of the confusion that has developed. The . term " Interim Findings" refers to the - status of FEMA's overall 44 CFR 350 review for the San Onofre offsite plans ) Nevertheless, the- FEMA finding is positive. Therefore, regarding offsite medical services at San Onofre, the Staff finds that there is reasonable (,ssurance .that adequate protective measures can and will be taken in the event 4 of a radiological emergency. t priginai signed by Franx1. consei  ! l Frank J. Congel, Director ) Division of Radiation Protection l' and Emergency Preparedness Office of Nuclear Reactor Regulation a i q 

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Federal Emergency Management Agency Washington, D.C. 20472 OCT - 61987 MEMORANDUM FOR: Frank J. Congel Director Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation U. S. Nu lear Regulat ry Commission FROM: R N K 

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Assistant Associate Director Office of Natural and Technological 4 Hazards Programs

SUBJECT:

Review of Offsite Medical Services Capabilities of State and Local Governments Site-Specific to the San Onofre Nuclear Generating Station This is in response to your memorandum of September 2,1987, requesting - further documentation on the Federal Emergency Management Agency's (FEMA) l review of the offsite medical services capabilities at the San Onofre ) Nuclear Generating Station. As requested, we have supplemented our conclusion with a specific evaluation of the material submitted by the State of California and the Southern California Edison Company against each of the review and acceptance criteria outlined in Guidance Memorandum MS-1. Details are contained in the attached interim finding prepared by FEMA Region IX. Based on the FEMA review, it has been determined that the offsite medical services capabilities of the State of California and the local jurisdictions satisfy the requirements of Guidance Memorandum MS-1, Medical Services, with the exception of one item. The exception involves the annotation of hospital lists to indicate ambulatory /non-ambulatory capabilities. , If you have any questions or need additional information, please contact me at 646-2871.

Attachment:

As stated ) i 1 l i 

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t Federal Emergency Management Agency i k Region IX Building 105 8 Presidio of San Francisco, California 94129 SEP 2 l 1987 l l MEMORANDUM FOR: ASSOCIATE DIRECTOR STATE AND LOCAL PROGRAMS AND SUPPORT FROM: e 1

SUBJECT:

Medical Services Interim Finding San Onofre Nuclear Generating Station The attached interim finding is provided in response to the telephone request from your staff. We understand that the information previously provided by memorandum dated July 18, 1987 and transmitted to the NRC by memorandum dated August 20, 1987, was not sufficient to meet the NRC requirements in view of the 

                          -GUARD suit against the San Onof re Nuclear Generating Station. We believe the attached formal interim finding will accommodate the NRC request.

If there are further questions or a need for clarification of any portion of the information provided, contact Susan Elkins at FTS 469-7186. Attachment l

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Ihf xIM FINDINGS AND DETERMINATIONS RELATING TO THE STATUS OF MEDICAL SERVICES AT THE SAN ONOFRE NUCLEAR GENERATING STATION I. INTRODUCTION This interim finding serves to update the FEMA Region IX medical services evaluation provided by memorandum dated April 18, 1985. Its purpose is to relate actions taken by Southern California Edison Company and the state and local offsite jurisdictions since that time and respond to the NRC letter of request for a j finding on the adequacy of medical services arrangements dated February 5,1987. II. BASIS FOR EVALUATION The basis for evaluating the adequacy of medical services at the San Onofre Nuclear Generating Station consists of observed events, personal contacts, plan review, and products received from the utility and offsite jurisdictions to ensure compliance with Guidance Memorandum (GM) MS-1, Medical Services. III. STATUS OF ACTIVITIES Medical services activities have been observed and evaluated. The following report on the status of medical services at the San i Onofre Nuclear Generating Station is keyed to Guidance Memorandum (GM) MS-1, Medical Services and numbered accordingly: A. Assignment of Responsibility (Organization Control) The local offsite jurisdictions and the utility: Orange County, San Diego County, City of San Clemente, City of San Juan Capistrano, California Department of Parks and Recreation, Camp Pendleton Marine Corps Base, and the Southern California Edison Company, entered into an Interjurisdictional Agreement during 1982 and formed an Interjurisdictional Planning Committee by that agreement to establish coordinated procedures for emergency response plans. To date there are22suchprocedugesthathavebeendeveloped.

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  • Interjurisdictional I'

A.3. Evaluation Criterion. Procedure #18 (Medical /Public Health . sets. forth information-relative to primary and support facilities, and procedures for handling responsibilities contaminated / injured persons in the event of a radiological emergency at the San Onofre Nuclear Generating Station. Interjurisdictional Procedure #12 (Decontamination) contains a list of hospitals (in the case of Orange County there are approximately 21) that can handle decontamination procedures. The Southern California Edison Company has updated agreements with hospitals, doctors, and ambulance companies to assure that the providers have adequate technical information and treatment capabilities for handling " contaminated injured" individuals (see Brief filed on behalf of Southern California Edison Company by Orrick, Herrington & Sutcliffe before the U.S. Nuclear Regulatory Commission on June 29,1987). Planning provisions for medical services have been found to be adequate by the Regional Assistance Committee (RIX RAC). L. Medical and Public Health Support L.1. Evaluation Criterion. Each of the local.offsite 

                    'j jurisdiction plans identifies a primary and backup hospital for the evaluation and emergency treatment of
                     " contamination injured" members of the general public.

The agreements are' initiated and executed by the utility and the hospital and referenced in local offsite plans. Each of the offsite jurisdiction plans identifies primary / support hospitals adequately. L.3 Evaluation Criterion. The State of California Department of Health Services Annex to the Office of Emergency Services California Nuclear Power Plant Emergency Response Plan contains a list of hospitals statewide known to have a capability for treating 

                       " contaminated injured" individuals. The State is in the process of updating that list. However, the list does    not     contain       information                           to                 indicate ambulatory /non-ambulatory      capacities                          for              providing medical support for " contaminated injured" members of the general     public and        any special radiological capabilities.

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y . : ,h ' . . .. y7; This element is only partially adequate. L.4 Evaluation Criterion. As mentioned in Item A.3-above, the utility has updated agreements. to ensure - ambulance companies will provide- transport of 

                                                                        " contaminated injured" individuals.

l Transportation provisions for medical services is found by the RIX RAC to be adequate. O. Radiological Emergency Response Training 0.4. 'During. the period 1981-85, the utility provided L annual training for those' who may be called on to 

                                                                       - assist in an emergency for medical support. Since.
                                                                       '1985, the training has been' provided on a biannual basis for                     both hospital staff and transportation
                                                                       - providers.                       The utility uses FEMA publication SM 80/1984, Hospital Emergency - Department Management of Radiation Accidents.                                          The utility has .also taken Ladvantage of'the FEMA teleconference system directed at this subject area, providing'the connection and airing of the            teleconference for various medical services agencies in the area.

This criterion is more than adequately- met at this site . N. ' Exercises and Drills 

                                                                       .N.2.           In conjunction with Ites 0. above, the utility conducts drills and exercises biannually for both hospital staff and transportation providers (during 1981-85 this was done on an annual basis) on a rotational basis.

A medical services drill was conducted on June 10, 1987 by the utility. The drill was evaluated onsite by the Nuclear Regulatory' Commission, Region V. The offsite . portion of the drill was observed and evaluated by FEMA Region IX REP program staff and two representatives (Dr. James A. Roseboro and Robert Nicol) from the Food , and Drug Administration. In addition, drill 

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instructors from the utility and Health Physicists from ' the Counties of Orange and San Diego (James Hartrandt, Orange, and Frank O. Bold, San Diego) observed and evaluated the entire drill. 1 _m- .__m. - . ~_-m-m.--_.-- -- .__m.__.._ m.--_._ - m .m__ _ _ _ _ . , _ _ _ _ . __ _m_____ _ ____

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i l l The drill simulated an accident at the San Onofre l Nuclear Generating Station in which a Radwaste Handler j was struck by a 55-gallon spent resin drum that had j 

                 .      been punctured by a fork lift, injuring him and, at the                           j same time causing him to become contaminated with                                )

relatively high activity spent resins from the drum. l After receiving the proper health physics and medical l care onsite, the contaminated / injured worker is I transported to the San Clemente General Hospital by the City of San Clemente Paramedic ambulance for l decontamination and further medical attention. Upon arrival at the hospital, the patient was received by , the hospital emergency room personnel and treated in a j specially prepared room dedicated for contaminated ) injuries. All steps and measures taken to deal with a  ! radioactively contaminated injury were evaluated. i i The San Clemente General Hospital Plan for the Decontamination and Treatment of the Radioactively Contaminated Patient was reviewed prior to the drill evaluation. Attachment H of that plan is attached to indicate the scope of available medical services support. The NRC Region V Inspection report of this activity is a matter of record and dated June 24, 1987. Immediately following the drill, a critique was held at the hospital and another at the San Onofre Nuclear Generating Station Emergency Operations Facility. The minor nature of the FEMA. findings were provided to the utility. No formal report was issued. The FEMA i findings were related to security of the area and items effected by exercise simulation. The overall finding ) for performance by ambulance and medical staffs was exemplary.  ; More than adequate drills and exercises of medical services activities are conducted at this site. IV APPLICATION OF CRITERIA l The criteria for review and approval of medical services plans and preparedness measures, as cited in Guidance 3 Memorandum MS-1, Medical Services, were addressed in the review of plans, procedures, agreements, drill evaluation and other related preparedness measures. I 1 i 

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V INTERIM EVALUATION A. The actions voluntarily taken by the state-and-local offsite jurisdictions and tp:: utility in addressing ' medical services requirements for contaminated / injured individuals and their 

                                        - accomplishments have been excellent and exceed the established requirements.

B. There is reasonable assurance that the plans for-medical services for members of the general public who may be contaminated / injured as a. result of.a radiological' emergency at the San Onofre Nuclear Generating Station .are adequate and can be 

                                         ' implemented as demonstrated in the exercise.

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