ML18046A353

Discusses Inconsistency Between NRC & FEMA Positions Re Submittal of State & Local Emergency Response Plans.Code Should Be Revised to Require Submittal of Plans by FEMA or State or Allow Licensee Specified Response Time

ML18046A353
Person / Time
Site:	Palisades, Big Rock Point  File:Consumers Energy icon.png
Issue date:	01/23/1981
From:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Crutchfield D Office of Nuclear Reactor Regulation
References
NUDOCS 8102020206
Download: ML18046A353 (2)

Text

General Offices: 212 West Michigan Avenue, Jackson, Michigan 49201 * (517) 788-0650 January 23, 1981 Director, Nuclear Reactor Regulation Att Mr Dennis M Crutchfield, Chief Operating Reactors Branch No 5 US i-Tuclear Regulatory Commission Washington, DC 20555 DOCKET 50-155 & 50-255 -

LICENSE DPR-6 & DPR BIG ROCK POINT & PALISADES PLANTS-EMERGENCY PLANNING ftliD PREPA...!\EDNESS NRC letter dated November 13, 1980 informed Consumers Power Company that final regulation for emergency planning became effective November 3, 1980 in the form of a revised 10 CFR 50 Appendix E and a new 10 CFR 50.47. These regulations and 10 CFR 50.54(s)(l) require that the Licensee of an operating nuclear power plant submit a site specific radiological emergency response plan including the associated State and local emergency response plans by January 2, 1981.

Consumers Power submitted new site specific radiological emergency response plans for the Big Rock Point and Palisades Plants on December 19, 1980 and January 2, 1981, respectively. However, these submittals did not include the State a...~d local emergency response plans because of Consumers Power's inability to obtain approved plans. Consumers Power was instructed by both the Federal Emergency Management Administration (FEMA - Region V) and the State of .Michigan not to submit "draft" State or local plans. This instruction appears to be made to eliminate the submittal to the NRC of draft plans (currently being re-vised as a result of observations made by FEMA during the Palisades Pla...~t emer-gency exercise on December 9, 1980) which are not finalized or implemented. It is our understanding from Ffilif..A that until they (FEMA) approve the State plan and notif"J the NRC of such approval, submittal of a draft State plan is unneces-sary.

This apparent inconsistency between the NRC and FEMA positions has been dis-cussed with the NRC staff by Consumers Power. In reviewing applicable regula-tions such as 10 CFR 50, NUREG-0654/FEMA.-REP-l Rev 1 and the President's State-ment of December 7, 1979, it becomes clear that FEMA has been charged with the responsibility of revi~wing and approving State and local e~ergency plans.

Therefore, it is suggested that the appropriate sections of 10 CFR 50 be revised to require submittal of State and. local emergency plans by FEMA or the State; .A.. 'fS" or allow the Licensee to submit the plans within a specified time from the f10 receipt of approved plans. ~

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January 23, 1981 Big Rock Point Plant Mr Dennis M Crutchfield 2 The current situation leaves Consumers Power incapable of meeting the 10 CFR 50.54(s)(l) requirement with respect to schedule for submittal of State and local emergency plans because FEMA and the State of Michigan have not approved them. However, Consumers Power will submit the appropriate State and local emergency plans upon our receipt of approved copies.

In the interim between now and final approval (estimated by FEMA to be March 1981) of the State and local plans, FEMA - Region V (Mr D Bement - phone number 616-968-8142 ext 6021) has informed Consumers Power that they would accept NRC participation in their review.

David P Hoffman Nuclear Licensing Administrator CC Director, Region III, USNRC NRC Resident Inspector - Big Rock Point

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