ML19351F903
| ML19351F903 | |
| Person / Time | |
|---|---|
| Site: | Brunswick, Robinson  |
| Issue date: | 02/17/1981 |
| From: | Eva Hickey Battelle Memorial Institute, PACIFIC NORTHWEST NATION |
| To: | Kevern T Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0654 NUDOCS 8102200458 | |
| Download: ML19351F903 (18) | |
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D OBattelle Pacific Northwest Laboratories P.O. Box 999 Richland, Waihington U.S.A. 99352 Telephone (509)
Telex 15-2874 February 17, 1981 Mr. Tom Kevern, Team Leader Emergency Preparedness Task Force Nuclear Regulatory Commission Washington, DC 20555 Cear Tom, Enclosed are PNL's partial reviews of the H. B. Robinson and Brunswick Emergency Plans. As you requested, Sections D, F, I, J, X and L of NUREG-0654, Rev. I were evaluated for each plant.
I will continue my review of the emergency plans and will have completed evaluations ready in early March.
If I may be of further assistance, please do not hesitate to call.
Sincerely, Eva Eckert Hickey, Research Scientist Health Physics Technology Section EEH/tp Attachment cc:
A. E. Desrosiers, project leader F. G. Pagano, NRC Y%
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Brunswick PLANNING STANDARD D A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.
SYNOPSIS:
The Brunswick emergency plan has adopted a standard emergency classifiction and action level scheme as expressed in Appendix 1 of NUREG-0654, however, the plah lacks a number of the example initiating conditions for the four emergency classifications. The emergency plan does not address the parameter values and equipment status for each emergency class.
EVALUATION:
The licensee's plan partially satisfies the intent of Planning Standarc D.
ANALYSES OF CRITERIA 1.
Criterion 1, page 42 of NUREG-0654, is partially satisfied.
The plan provides the criteria for establishing the level of the emergency conditions; however, the plan does not specify the parameter values and equipment status.
2.
Criterion 2, page 42 of NUREG-0654 is partially satisfied.
The plan lacks some of the example initiating conditions discussed in Appendix 1.
The initiating conditions not present in the Brunswick plan are discussed below.
In addition, the emergency plan does not specifically state that all postulated accidents in the FSAR for Brunswick have been addressed in the EAL's.
UNUSUAL EVENT The following initiating conditions were not fully addressed:
1)
Emergency Core Cooling System (ECCS) initiated and discharge to vessel.
2)
Fuel damage indication.
Examples:
- a. High offgas at BWR air ejector monitor (greater than 500,000 uCi/sec; corresponding to 16 isotopes decayed to 30 minutes; or an increase of
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100,000 uCi/sec within a 30 minute time period).
- 3) Exceeding either primary / secondary leak rate technical specification or primary system leak rate technical specification.
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3 Brunswick PLANNING STANDARD D (CONTINUED)
- 4) Loss of offsite power ur loss of onsite AC power capability.
5)
Security threat or attempted entry or attempted sabotage.
- 6) Natural phenomenon being experienced or projected beyond unusual levels; 50 year flood or low water, tsunami, hurricane surge, seiche.
- 7) Other hazards being experienced or projected:
train derailment onsite or turbine rotating component causing rapid plant shutdown.
- 3) Other plant conditions exist that warrant increased awareness on the part of a plant operating staff or State and/or local offsite authorities or require plant shutdown under technical specification requirements or involve other than normal controlled shutdown (e.g., cooldown rate exceeding technical specification limits, pipe cracking found during operation).
9)
Transportation of contaminated injured individual from site to offsite hospital.
ALERT The following initiating condf tions were not fully addressed:
1)
Severe loss of fuel cladding - a. High off gas at BWR air ejector monitor (greater than 5 ci/sec; corresponding to 16 isotopes decayed 30 minutes)
- 2) Rapid grors failure of one steam generator tube with loss of offsite power.
- 3) Primary coolant leak rate grater than 50 gpm.
- 4) Coolant pump seizure leading to fuel failure.
- 5) Complete loss of any function needed for plant cold shutdown.
- 6) Radiological effluents greater than 10 times technical specification instantaneous limits (an instantaneous rate which, if continued over 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, would result in about 1 mr at the site boundary under average meteorological conditions).
No te:
The Brunswick EAL used 1000 times technical specification instantaneous limits instead of 10 times the limits.
- 7) Severe natural phenomena being experienced or projected - Flood, icw water, tsunami, hurricane surge, seiche near design level.
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Srunswick PLANNING STANDARD D (CONTINUED)
- 8) Other plant conditions exist that warrant precautionary activation of Technical support center and placing near-site emergency operations facility and other key emergency personnel on standby.
SITE AREA OMERGENCY The following initiating conditions were not fully addressed.
- 1) Known loss of coolant accident greater than makeup pump capacity.
- 2) Degraded core with possible loss of coolable geometry (indicators should include instrumentation to detect inadequate core cooling, coolant activity and/or containment radioactivity levels.
3)
Transient requiring operation of shutdown systems with failure to scram (continued power generation but no core damage immediately evident).
4) a.
Effluent monitors detect levels corresoonding to greater than 50 mr/hr for 1/2 hour or greater than 500 mr/hr W.B. for two minutes (or five times these l'evels to the thyroid) at the site boundary j[oj; adverse meteorology.
b.
These dose rates are projected based on other plant parameters (e.g.,
radiation level in containment with leak rate appropriate for existing containment pressure) or are measured in the environs.
c.
EPA Protective Action Guidelines are projected to be exceeded outside the site boundary.
- 5) Other hazards being experienced or projected with plant not in cold shutdown:
a.
Aircraft crash affecting vital structures by impact or fire.
b.
Severe damage to safe shutdown equipment from missiles or explosion.
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c.
Entry of uncontrolled flammable gases into vital areas. Entry of uncontrolled toxic gases into vital areas where lack of access to the area constitutes a safety problem.
- 6) Other plant conditions exist that warrant activation of emergency centers and monitoring teams or a precautionary notification to the public near the site.
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Brunswick PLANNING STANDARD D (CONTINUED)
_ GENERAL EMERGENCY The following initiating conditions were not fully addressed:
1) a.
Effluent monitors detect levels corresponding to 1 rem /hr W.B. or 5 rem /hr thyroid at the site boundary under actual meteorological condi tions The Brunswick initiating condition does not state actual meteorological conditions.
- 2) Loss of physical control of the facility Mote: Consider 2 mile precautionary evacuation 3)
Other plan conditions exist, from whatever source, that make release of large amounts of radioactivity in a short time period possible, e.g., any core melt situation.
No tes:
a.
For core melt sequences where significant releases from contain-ment are not yet taking place and large amounts of fission products are not yet in the containment atmosphere, consider 2 mile precautionary evacuation. Consider 5 mile downwind evacuation (45' to 90' sector) if large amounts of fission products (greater than gap activity) are 19 the containment atmosphere. Recommend sheltering in other parts of the plume exposure Emergency Planning Zone under this circumstance.
For core melt sequences where significant releases from l
containment are not yet taking place and containment failure leading to a direct atmospheric release is likely in the sequence but not imminent and large amounts of fission products in addition to noble gases are in the containment atmosphere, consider precautionary evacuation to 5 miles and 10 mile downwind evacuation (45' to 90 sector).
l c.
For core melt sequences where large amounts of fission products other than noble gases are in the containment atmosphere and containment failure is judged imminent, recommend shelter for those areas where evacuation cannot be completed before transport of activity to that location.
3.
Criteria 3 and 4 are not applicable to the licensee.
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Brunswick DLANNING STANDARD F Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public.
SYNOPSIS: The licensee's plan provides for 24-hour per day notification to alert and activate onsite and offsite emergency response organizations, including State / local and Federal government organizations. Provisions for communications between the Brunswick plant and State and local emergency operations centers as well as the radiological monitoring teams are available.
EVALUATICN:
The plan almost satisfies the intent of Planning Standard F.
ANALYSES OF CRITERIA 1.
Criteria la.,
b.,
c.,
and e., page 47 of NUREG-0654 are completely satisfied. Crf teria Id. and f. are not satisfied since Brunswick has no near site Energency Operations Facility and, therefore, there is no communications to the EOF.
PLANNING STANDARD I Adequate methods, systems and equipment for assessing and monitoring actual or potential offsite consequences of a radiological energency condition are in use.
SYNOPSIS:
The licensee's emergency plan discusses onsite capability to make radiological assessments such as post-accident sampling capability, radiation and effluent monitors as well as in-plant iodine instrumentation.
The Brunswick plan adequately discusses the methods for assessing the actual or potential consequences of a radiological emergency.
EVALUATION:
The emergency plan partially satisfies the intent of Planning Standard I.
ANALYSES OF CRITERIA 1.
Criterion 1, page 56 of NUREG-0654 is only partially met.
The Brunswick Energency plan gives some effluent parameter values that would be characteristic of off-normal conditions, however, each example initiating conditien does not have an instrument parameter to indicate an abnormal condi tion.
2.
Criterion 2, page 56 of NUREG-0654, is satisfied, however, the licensee should commit to a date that the radiation containment monitor would be operational.
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Brunswick PLANNING STANDARD I (CONTINUED) 3.
Criteria 3, 4, 6 and 7 are fully met.
4.
Criterion 5 is partially satisfied.
The licensee has the capability to acquire meteorological data and make assessments with the data.
Sufficient back up meteorological data is also available. The data, however, is not stated as being accessible to the TSC and the offsite NRC center. Also, since Brunswick has no EOF, the data is not available to that facility.
The meteorological data is not sent to the State for independent analysis.
5.
Criterion 8, page 58 of NUREG-0654 is mostly satisfied.
The estimated deployment times of the field monitoring teams are not discussed.
6.
Criterion 9, page 58 of NUREG-0654, is partially satisfied.
The radiciodine detection capacity needs only to be as low as 10-7 uCi/cc.
There is no discussion of interference from noble gas or background radiation while measuring radioiodne concentrations.
7.
The emergency plan does not directly address relating various measured parameters to dose rates for key isotopes and gross radioactivity measurements as required by Criterton 10, page 58 of NUREG-0654, 8.
Criterion 11 is not applicable to the licensee.
PLANNING STANDARD J A range of protectivr actions have been developed for the plume exposure pathway EPZ for emergency workers and the public. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.
SYNOPSIS: The licensee has provided adequate monitoring and decontamination of people evacuated from the site. Provisions have been made to account for all individuals onsite when an emergency occurs. Sufficient supplies such as respiratory protection, protective clothing and radioprotective drugs are available for persons remaining onsite.
The licensee has provided the means for notification of the transient and resident population -located within the plume exposure pathway. The plan provides representative protective actions at various dose levels for offsite populations.
EVALUATION:
The licensees emergency plan partially satisfies the intent of Planning Standard J.
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Brunswick PLANNING STANDARD J (CONTINUED)
ANALYSES OF CRITERIA 1
Criterion 1, page 59 of NUREG-0654 is not satisfied.
The plan implies that all personnel will be advised when an emergency condition is in effect, however, the actual means to notify and time needed to alert the employees is not specifically stated. The same is true for visitors and persons in the public access areas.
The plan needs to make definitive statements as to the means and time necessary to warn individual onsite.
Contractor and construction personnel must also be addressed in the plan.
2.
Criterion 2, page 59 of NUREG-0654 is not addressed.
Evacuation routes and transportation for onsite personnel are not included in the emergency plan.
3.
Criteria 3 and 6 are adequat91y addressed.
4.
Criterion 4, page 60 of NUREG-0654 is partially satisfied.
The licensee has not provided for evacuation of non-essential personnel during a Site or General Emergency condition.
5.
Criterion 5, page 60 of NUREG-0654 is partially satisfiec.
The plan addresses personnel accountability, but does not commit to accounting for missing individuals,within 30 minutes of the start of an emergency.
6.
Criterion 7, page 60 of NUREG-0654 is not satisfied.
The Brunswick emergency plan does not specifically state that the licensee will recommend protective actions to State and local authorities.
7.
The licensee's plan does not contain time estimates for evacuation within the plume exporure EPI as is required by Criterion 8, page 61 of NUREG-0654 8.
Criteria 9,10d-1,11 and 12 are not applicable to the licensee.
9.
Criteria 10b and c are fully satisfied. Criterion 10a, page 61 of NUREG-0654 is not addressed. Maps showing evacuation routes, areas, shelters and radiological monitoring points are not in the energency plan.
Criterion 10 m, page 64 of NUREG-0654 is not fully satisfied. Protection from local homes and other shelters as not discussed nor is direct and indirect inhalation exposure.
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Brunswick PLANNING STANDARD X Means for controlling radiological exposures, in an emergency, are established for emergency workers.
The means for centrolling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.
SYNOPSIS: The licensee has provided an adequate radiation protection program to be implemented in an emergency situation.
The plant is capable of making dose determinations and keeps dose records. Contamination control is addressed in the plan as is decontamination of personnel and equipment.
EVALUATION:
The plan partially satisfies the intent of Planning Standard K.
ANALYSES CF CRITERIA 1.
Criterion 1 parts a and b are satisfied.
Sections ic, d, e, f, and g, page 66 of NUREG-0654 are not addressed. These include Protection Action Guides not given for performing assessment actions; providing first aid; performing personnel decontaminatics: providing ambulance service; and providing medical treatment services.
2.
Criterion 2 is completei/ s Msfied.
3.
Criterion 3b is satisfied. Criterion 3a, page 67 of NUREG-0654, lacks sp9cific reference to 24-hour per day capability of dose determination.
4.
Criterion 4 is not applicable to the licensee.
5.
Criterion 5, page 67 of NUREG-0554 is only rartisily satisfied, Criterion 5a requires specified action levels for decontamination, however, the plan does not provide these action levels.
6.
Criterion 6 parts a and b are fully satisfied. Part 6c, page 67 of NUREG-0654, is not addressed.
The Brunswick plan provides no criteria for returing areas to normal use.
7.
Criterlan 7, page 65 of NUREG-0654, is mostly satisfied.
The plan lacks specific reference to radioiodine contamination of the skin.
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Brunswick PLANNING STANDARD L Arrangements are made for medical services for contaminated injured individuals.
SYNOPSIS:
The licensee has made arrangements with Dosher Memorial Hospital for medical services which have the capability to treat contaminated and non contaminated injured personnel.
The back up treatment facility is the North Carolina Memorial Hospital in Chapel Hill, N.C.
Three physicians are also available to give Brunswick assistance in an emergency situation. Anbulance Service is to be supplied by the Southport Volunteer Rescue Squad. Agreements from the hospitals, physicians and Rescue Squad are in the Energency plan.
The licensee has previoed for onsite first and treatment.
EVALUATION:
The Brunswick plan fully satisfies the intent of Planning Standard L.
ANALYSES OF CRITERIA l.
Criteria 1, 2, and 4 are fully met.
2.
Criterion 3 is not applicable to the licensee.
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H. B. Robinson PLANNING STANDARD D A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on informction provided by facility licensees for determinations of minimum initial off:ite response measures.
SYNOPSIS:
The licensee has established an emergency classification scheme similar to that found in Appendix 1 of NUREG-0654 Most of the example initiating conditions in Appendix 1 are represented in the H. B. Robinson Emergency Plan.
The instrument parameters which indicate the class of emergency occurring are not present in the plan.
EVALUATION:
The licensee's emergency plan partially satisfies the intent of Planning Standard D.
ANALYSES OF CRITERIA
- 1) Criterion 1, Page 42 of NUREG-0654 is partially satisfied.
The parameter values and equipment status for each emergency class are not in the emergency plan.
- 2) Criterion 2, Page 42 of NUREG-0654 is partially met.
There is no statement that all postulated accidents in the FSAR are included in the initiating conditions in the emergency plan.
The example initiating conditions found in Appendix 1 of NUREG-0654 which are missing in the H.
B. Robinson EAL's are listed below.
Unusual Event The following initiating conditions were not fully addressed:
- 1) Failed fuel monitor (PWR) indicates increase greater than 0.1% equivalent fuel failures within 30 minutes.
2)
Natural phencmenon being experienced or projected beyond usual levels.
a.
50 year floor or low water, tsunami, hurricane surge, seiche
- 3) Other hazards being experienced or projected:
a.
Train derailment on-site.
b.
Turbine rotating component failure causing rapid plant shutdown.
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H. B. Robinson PLANNING STANDARD D (CONTINUED) 4)
Other plant conditions exist that warrant increased awareness on the part of a plant operating staff or State and/or local offsite authorities or require plant shutdown under technical specification requirements or involve other than normal controlled shutdown (e.g., cooldown rate exceeding technical specification limits, pipe cracking found during operation).
5)
Transportation of contaminated injured individual from site to offsite hospital.
- 6) Rapid depressurization of PWR secondary side.
Alert The following initiating conditions were not fully addressed:
1)
Initiating condition 6 in the plan reads, " Primary coolant leak -rate greater than capacity of a single charging pump...." According to Appendix 1, it is necessary to relate this to a leak rate greater than 50 gpm.
- 2) Coolant pump seizure leading to fuel failure.
- 3) Complete loss of any function needed for plant cold shutdown.
4)
Initiating condition 15 of the Robinson plan states that radiological effluents greater than 1,000 times technical specification instantaneous limits indicate an alert condition, however, the requirement is 10 times technical specification instantaneous limits.
5)
Severe natural phenomena being experienced or projected:
l a.
Flood, low water, tsunami, hurricane surge, seiche near design level s l
- 6) Other plant conditions exist that warrant precautionary activation of l
technical support center and placing near-site Energency Operations Facility and other key energency personnel on standby.
Site Emergency l
The following initiating conditions were not fully addressed:
- 1) Degraded core with possible loss of coolable geometry (indicators should include instrumentation to detect inadequate core cooling, coolant activity and/or containment radioactivity levels).
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H. 3. Robinson PLANNING STANDARD D (CONTINUED)
- 2) Complete loss of any function needed for plant hot shutdown.
3)
Transient requiring operation of shutdown systems with failure to scram (continued power generation but no core damage immediately evident).
4) a.
Effluent monitors detect levels corresponding to greater than 50 mr/hr for 1/2 hour or greater than 500 mr/hr W.B. for two minutes (or five times these levels to the thyroid) at the site boundary for adverse meteorology.
b.
These dose rates are projected based on other plant parameters (e.g.,
radiation level in containment with leak rate appropriate for existing containment pressure) or are measured in the environs, c.
EPA Protective ktion Guidelines are projected to be exceeded outside the site boundary.
5)
Imminent loss of physical control of the plant.
6)
Other hazards being experienced or projected with plant not in cold shutdown:
a.
Entry of uncontrolled toxic gases into vital areas where lack of access to the area constitutes a safety problem.
- 7) Other plant conditions exist that warrant activation of emergency centers and monitoring teams or precautionary notification to the public near the si te.
General Emergency The following initiating conditions were not fully addressed:
1)
Effluent monitors detect levels corresponding to I rem /hr W.B. or 5 rem /hr thyroid at the site boundary under actual meteorological conditions.
The Brunswick initiating condition does not state actual meteorological
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condi tions.
1
- 2) Loss of physical control of the facility.
Note: Consider 2-mile precautionary evacuation.
1 1
Other plant conditions exist, from whatever source, that make release of large amounts of radioactivity in a short time period pssible. e.g., any core melt situation.
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H. B. Robinson PLANNING STANDARD D (CONTINUED)
Notes:
a.
For core melt sequences where significant releases from containment are not yet taking place and large amounts of fission products are not yet in the containment atmosphere, consider 2-mile precautionary evacuation. Consider 5-mile downwind evacuation (45* to 90 sector) if large amounts of fission products (greater than gap activity) are in the containment atmosphere. Recommend sheltering in other parts of the plume exposure Emergency Planning Zone under this circumstance.
b.
For core mJlt sequences where significant releases from containment are not yet taking place and containment failure leading to a direct atmospheric release is likely in the sequence but not imminent and large amounts of fission products in addition to noble gases are in the containment atnosphere, consider precautionary evacuation to 5 miles and 10-mile downwind evacuation (45 to 90 sector).
c.
For core melt sequences where large amounts of fission products other than noble gases are in the containment atmosphere and containment failure is judged imminent, recommend shelter for those areas where evacuation cannot be completed before transport of activity to that location.
d.
As release information becomes available, adjust these actions in acccrdance with dose projections, time available to evacuate and estimated evacuation times given current conditions.
3.
Criterion 3 and 4 are not applicable to the licensee.
PLANNING STANDARD F Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public.
SYNOPSIS: The licensee's plan provides for 24-hour per day notification to alert and activate onsite and offsite emergency response organizations including State / local and Federal government organizations. Provisions for communications between the H. B. Robinson plant and State and local emergency operations centers as well as the radiological monitoring teams are available.
EVALUATION:
The plan almost satisfies the intent of Planning Standard F.
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r H. B. Robinson PLANNING STANDARD F (CONTINUED)
ANALYSES OF CRITERIA 1.
Criteria la, b, c. and e, Page 47 of NUREG-0654 are completely satisfied. Criteria ld and f are not satisfied since H. B. Robinson has no nearsite Emergency Operations Facility, therefore, there is no i
communications to the EOF.
PLANNING STANDARD I Adequate methods, systems and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.
SYNOPSIS: The licensee's emergency plan discusses onsite capability to make radiological assessmer ts such-as post-accident sampling capability, radiation and effluent monitors as well as in-plant iodine instrumentation.
The H. B.
Robinson plan adequately discusses the methods for assessing the actual or potential consequences of a radiological emergency.
EVALUATION:
The emergency plan partially satisfies the intent of Planning Standard I.
AilALYSES OF CRITERIA 1.
Criterion 1, Page 56 of NUREG-0654 is only partially met.
H. B. Robinsen Emergency plan gives some effluent parameter values that would be characteristic of off-normal conditions, however, each example initiating condition does not have an instrument parameter to indicate an abnormal condition.
I 2.
Criterion 2, Page 56 of NUREG-0654, is satisfied, however, the licensee i
should commit to a date that the radiation containment monitor would be operational.
3.
Criteria 3, 4, 6 and 7 are satisfied.
l 4.
Criterion 5, Page 57 of NUREG-0654, is partially satisfied.
The licensee has the capability to acquire meteorological data and make assessments with the data. Sufficient back up meteorological data is also available. The data, however, is not stated as being accessible to the TSC and the offsite NRC center. Also, since H. B. Robinson has no E0F, l
the data is not available to that facility. The meteorological data is not sent (nor offered) to the State for independent analysis.
5.
Criterion 8, Page 58 of NUREG-0654, is almost satisfied. The estimated deployment times of the field monitoring teams are not discussed.
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H. B. Robinson PLANNING STANDARD I (CONTINUED) 6.
Criterion 9, Page 58 of NUREG-0654, is partially satisfigd.
The radiciodine detection capacity needs to be as low as 10-' uCi According to the H. B. Robinson is capable of detecting 5x10 fcc.
uCi/cc.
There is no discussion of interference from noble gas or background radiation while measuring radioiodine concentrations.
7.
The emergency plan does not directly address relating various measured parameters to dose rates for key isotopes and gross radioactivity measurements as required by Criterion 10, Page 58 of NUREG-0654, 8.
Criterion 11 is not applicable to the licensee.
PLANNING STANDARD J A range of protective actions has been developed for the plume exposure pathway EPZ for emergency workers and the public. Guidelines for-the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been develcped.
SYNOPSIS: The licensee has established an adequate means of radiological monitoring and decontamination of people being evacuated from the site.
Individuals remaining onsite will be provided with respiratory protection and protective clothing as needed. Radioprotective drugs will be administered when recommended by expert medical opinion. The plan has maps showing population distribution around the nuclear facility.
In addition, the plan provides representative protective actions at various dose levels for the off-site population.
EVALUATION 1 The Robinson plan partially satisfies the intent of Planning Standard J.
ANALYSES OF CRITERIA 1.
Criterion 1, Page 59 of NUREG-0654, is partially satisfied.
The plan does not specifically state the means of notification.
It is apparent that there is a system of notification and that people onsite will know where to assemble, but the means and time required to accomplish this are not addressed in tha plan. Also, part ic, contractor and construction personnel, needs to be specifically addressed.
2.
Criterion 2, Page 59 of NUREG-0654 is not addressed.
Evacuation routes and transportation for onsite personnel must be included in the emergency plan.
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H. B. Robinson PLANNING STANDARD J (CONTINUED) 3.
Criteria 3 and 6 are adequately addressed.
4.
Criterion 4, Page 60 of NUREG-0654 is partially satisfied.
The licensee has not provided for evacuation of non-e;sential personnel during a Site or General Emergency condition.
5.
Criterion 5, Page 60 of NUREG-0654 is partially satisfied.
The plan addresses personnel accountability, but does not commit to accounting for missing individuals within 30 minutes of the start of an emergency.
6.
Criterion 7, Page 60 of NUREG-0654, is not satisfied.
The H. B. Robinson emergency plan does not specifically state that the licensee will recommend protective actions to State and local authorities.
7.
The licensee's plan does not contain time estimates for evacuation within the plume exposure EPZ as is required by criterion 8, Page 61 of NUREG-0654.
8.
Criteria 9,10d-1,11 and 12 are not applicable to the licensee.
9.
Parts b and c of criterion 10 are fully satisfied.
Part a, Page 61 of NUREG-0654 is not addressed. Maps showing evacuation routes, areas, shelters and radiological monitoring points are not in the emergency pl an.
Section M of criterion 10, Page 64 of NUREG-0654, is not fully satisfied. Radiological protection afforded from homes and other shelters is not discussed nor is direct and indirect inhalation exposure.
PLANNING STANDARD K Means for controlling radiological exposures, in an emergency, are established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Energency Worker and Lifesaving Activity Protective Action Guides.
SYNOPSIS:
The licensee has established exposure guidelines for lifesaving actions and repair and assessment actions. The exposures in excess of 3 rem must be authorized by the Plant General Manager or Environmental and Radiation Control Supervisor or the Site Emergency Coordinator. The plan discusses personnel radiation protection such as issuing dosimetry, keeping dose records and providing necessary decontamination.
EVALUATION:
The plan partially satisfies the intent of Planning Standard K.
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H. B. Robinson PLANNING STANDARD K (CONTINUED)
ANALYSES OF CRITERIA 1.
Criterion 1, Page 66 of NUREG-0654, is partially satisfied. Sections d, e, f, and g of criterion 1 are not addressed.
The exposure guidelines for providing first aid, perfonning personnel decontamination, providing ambulance service and providing medical treatment services are not discussed in the emergency plan.
2.
Criterion 2 is completely satisfied.
3.
Criterion 3, Page 67 of NUREG-0654, is mostly satisfied.
The plan lacks specific reference to 24-hour capability of dose determination.
Criterion 3b is fully satisfied.
4.
Criterion 4 is not applicable to the licensee.
5.
Criterion Sa, Page 67 of NUREG-0654, is not addressed.
The emergency plan does not specify action levels for determining the need for decontamination. Criterion 5b is fully satisfied.
6.
Criterion 6, Page 67 of NUREG-0654, is mostly satisfied.
The plan makes no reference for returning contaminated areas to normal use as is required in part c of criterion 6.
7.
Criterion 7, Page 68 of NUREG-0654, is mostly satisfied.
The plan lacks specific reference to radiciodine contamination of the skin.
PLANNING STANDARD L Arrangements are made for medical services for contaminated injured individuals.
SYNCPSIS: Local medical assistance will be supplied by the Byerly Hospital which is capable of treating contaminated and noncontaminated injured persons. The North Carolina Memorial Hospital in Chapel Hill, NC has agreed to serve as a backup facility in the event that Byerly is full or uninhabitable. The Lake Robinson and Hartsville Rescue Squads have agreed to provide rescue service to the H. B. Robinson plant when needed.
The licensee has provided adequate onsite first aid.
EVALUATION:
The plan fully satisfies the intent of Planning Standard L.
ANALYSES OF CRITERIA 1.
Criteria 1, 2 and 4 are fully satisfied.
2.
Criterion 3 is not applicable to the licensee.
L
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