ML20137S575

Response Supporting Applicant Proposal to Use Montgomery Hosp as Backup Facility to Treat Contaminated Injured Onsite Personnel.W/Certificate of Svc

ML20137S575
Person / Time
Site:	Limerick
Issue date:	12/02/1985
From:	Ferkin Z PENNSYLVANIA, COMMONWEALTH OF
To:	Atomic Safety and Licensing Board Panel
References
CON-#485-390 ALAB-819, OL, NUDOCS 8512060264
Download: ML20137S575 (5)

Text

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.M 0]?E!rn UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISShi DEC -5 g0 35 Crm. .

ICc ! c'7 BeforeTheAtomicSafetyAndLicensinj,V.-a,BdardI In the Matter of )

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Philadelphia Electric Company )

Docket Nos. 50-352 (Limerick Generating Station, Units 1 and 2)

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) 50-353 h COMMONWEALTH OF PENNSYLVANIA'S COMMENTS ON LICENSEE'S PROPOSAL TO USE MONTGOMERY HOSPITAL AS A BACKUP FACILITY TO TREAT CONTAIMINATED INJURED ONSITE PERSONNEL In ALAB-819, the Atomic Safety and Licensing Appeal Board (Appeal Board) remanded for further disposition the matter of a backup horpital to receive contaminated and injured onsite personnel. In accordance with the remand, the Licensing Board iscued an Order, dated October 28, 1985, which directed Philadelphia Electric Company (PECo) to submit its proposal for resolution of the remanded issue within 20 days.

The Board provided other interested parties, including the Commonwealth of Pennsylvania, an opportunity to comment on PECo's proposal.

PECo submitted its proposal for resolution of the remanded issue on November 18, 1985. The Commonwealth has reviewed the proposal and provides the following comments.

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PECo has chosen Montgomery Hospital, located in Norristown, Pennsylvania, as a backup facility for treatment of onsite contamined injured personnel. PECo encloses a letter dated November 14, 1985 from the President, Montgomery Hospital to the Medical Director, PECo which states in pertinent part that 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." The letter states further that Montgomery Hospital 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." The letter indicates that PECo has agreed to provide Montgomery Hospital with personnel training, equipment and supplies, procedures for handling treatment and decontamination of an. injured or ill patient from Limerick, and other services related to the care of contaminated injured individuals.

The Commonwealth notes that Montgomery Hospital lies outside the plume exposure pathway emergency planning zone for the Limerick Station but closer to the Limerick Station than the Hospital of the University of Pennsylvania. See Comm. Ex. E-9; Licensee's Proposal (Map Attachment and Chart). The capabilities 2

of Montgomery Hospital have also been reviewed by PECo's consultant, Dr. Roger E. Linnemann, who concluded that the hospital is adequately prepared to handle contaminated and injured patients. Licensee Proposal at 5; Affidavit of Roger E.

Linnemann, M.D. (April 4, 1985).

The Commonwealth is of the view that the materials submitted by PECo are responsive to the Board's Order of October 28, 1985 and that Montgomery Hospital is an appropriate facility for treatment of contaminated injured onsite personnel.

Respectfully submitted,

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Zori G. Ferkin Counsel for Commonwealth of Pennsylvania Dated: December 2, 1985 3 l i

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...ITED STATES OF AMERICA

' NUCLEAR REGULATORY COMMISSION CERTIFICATE OF SERVICE In the Matter of )

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PHILADELPHIA ELECTRIC COMPANY ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

I hereby certify that I have this 2nd day of December, 1985 served copies of " Commonwealth of Pennsylvania's Comments on Licensee's Proposal to Use Montgomery Hospital as a Backup Facility To Treat Contaiminated Injured Onsite Personnel" the above-captioned matter upon the following by deposit in the United States mail, postage paid:

Helen F. Hoyt Benjamin H. Vogler, Esq.

Administrative Judge Counsel for NRC Staff Atomic Safety and Licensing Office of the Executive Board Legal Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Richard F. Cole Robert L. Anthony Administrative Judge Friends of the Earth of the Atomic Safety and Licensing Delaware Valley Board P.O. Box 186 U.S. Nuclear Regulatory Commission 103 Vernon Lane Washington, D.C. 20555 Moylan, PA. 19065 Dr. Jerry Harbour Joseph H. White, III Administrative Judge 234 Edgemont Avenue Atomic Safety and Licensing Ardmore, PA. 19003 Board U.S. Nuclear Regulatory Commission Charles W. Elliott, Esq.

Washington, D.C. 20555 Brose and Postwistilo 325 N. 10th Street Atomic Safety and Licensing Easton, PA. 18042 Appeal Panel U.S. Nuclear Regulatory Commission Thomas Gerusky, Director Washington, D.C. 20555 Bureau of Radiation Protection Department of Environmental Troy B.-Conner, Esq. Resources Conner'and Wetterhahn, P.C. 5th Floor, Fulton Bank Building 1747 Pennsylvania Avenue, N.W. Third and Locust Streets Washington, D.C. 20006 Harrisburg, PA. 17120 1

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' Ann Hodgdon, Esq.

Counsel for NRC Staff Office of the Executive Frank Romano Legal Director 61 Forest Avenue U. S. Nuclear Regulatory Ambler, PA 19002 Commission Washington, DC 20555 Docketing and Service Section Phyllis Zitzer Office of the Secretary Limerick Ecology Action U.S. Nuclear Regulatory Commission P.O. Box 761 Washington, D.C. 20555 Pottstown, PA. 19464 Atomic Safety and Licensing Steven P. Hershey, Esq.

Board Panel Community Legal Services, Inc.

U.S. Nuclear Regulatory Commission Law Center ' Jest Washington, D.C. 20555 5219 Chestnut Street Philadelphia, PA. 19139 Timothy R.S. Campbell Director Kathryn S. Lewis, Esq.

Department of Emergency Services City of Philadelphia 14 East Biddle Street - Municipal Services Building West Chester, Pennsylvania 19380 15th and JFK Boulevard Philadelphia, PA. 19107 Philadelphia Electric Company .

ATTN: Edward G. Bauer, Jr. Director, Pennsylvania Emergency Vice President & General Counsel Management Agency 2301 Market Street B-151 Transportation and Safety Philadelphia, Pennsylvania 19101 Building Harrisburg, PA. 17120 Angus Love, Esq.

101 East Main Street Spence W. Perry, Esq.

Norristown, Pennsylvania 19404 Associate General Counsel Federal Emergency Management Agency David Wersan,.Esq. 500-C. Street, S.W., Room 840 Assistant. Consumer Advocate Washington, D.C. 20472 Office of Consumer Advocate 1425' Strawberry Square Jay Gutierrez, Esq.

Harrisburg, Pennsylvania 17120 U.S. Nuclear Regulatory Commission Region I Christine N. Kohl 631 Park Avenue Atomic Safety and Licensing King of Prussia, PA. 19406

-Appeal Board U.S. NRC Reginald L. Gotchy Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board Gary J. Edles U.S. NRC Atomic Safety and Licensing Washington, D.C. 20555 LAppeal Board Washington, D.C. 20555 f/ Zori G. Fer Chief Counsel Governor's Energy Council 2