ML18046B150
| ML18046B150 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/04/1981 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18046B149 | List: |
| References | |
| GL-81-27, NUDOCS 8112210430 | |
| Download: ML18046B150 (4) | |
Text
General Offices:
1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-1636 November 4, 1981 Director, Nuclear Reactor Regulation Att Mr Dennis M Crutchfield, Chief Operating Reactors Branch No 5 US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES - PRIVACY AND PROPRIETARY MATERIAL IN EMERGENCY PLANS David P Hoffman Nuclear Lice11si11g Administr.itur Consumers Power Company has again reviewed NRC Generic Letter No 81*27, Privacy and Proprietary Material in Emergency Plans, dated July 9, 1981 and our-Palisades Plant Site Emergency Plan and Palisades Plant Emergency Implementing Procedures. *our conclusion remains the* same -- the
- Emergency Implementing Procedures should be withheld from public disclosure in accord-ance with 10CFR2.790(d)(f).
In response to NRC letter dated October 2, 1981 (J M Felton to D P Hoffman) the following information is provided to support our position (Mr R J Lavins agreed by phone on October 30, 1981, to a one week extension for our response.)
Several years ago Consumers Power made a concerted effort-to separate nuclear power plant emergency plans into two documents.
One document, the Site Emergency Plan (Plan), was made part of the plant FSAR and thereby became a public document.
The Plan provides an overall concept for coping with emer-gencies; identifies advance planning essential for response to emergencies; and, presents information identifying the coordination between Consumers Power Company and various State and Local agencies in response to an emergency.
The Plan (plus publicly distributed emergency preparedness brochures) is intended to provide the necessary information for assisting the public in the event. of a nuclear power plant incident.
The other document, the Emergency Implementing Procedures (Procedures), was developed to assist,Consumers Power employees in responding to a nuclear power plant incident.
The Procedures are considered internal plant documents containing a level of detail necessary to help employees in executing their specific responsibilities.
Since the
'ii. CO~
Procedures are already covered in a general manner within the Plan, it is unnecessary to *make them public.
Additionally, the Procedures do contain
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information which could be used by a disgruntled citizen, prankster or J /
oc1181-0002a142 8112210430 811211 PDR ADOCK 05000255
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Mr Dennis M Crutchfield, Chief
' Palisades Plant November 4, 1981 potential saboteur for reducing the effectiveness of our emergency response activities and physical protection of our plant.
The attached Affidavit contains additional details as to the basis for excluding the Implementing Procedures from public disclosure.
David P Hoffman Nuclear Licensing Administrator CC Director, Region III, USNRC NRC Resident Inspector-Palisades Plant Director, Division of Rules and Records, Office of Administration, J M Felton ocll81-0002a142 2
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CONSUMERS POWER COMPANY AFFIDAVIT STATE OF MICHIGAN )
)
SS.
COUNTY OF JACKSON )
I, Frederick W Buckman, being duly sworn, hereby say and depose that:
- 1.
I am Executive Director, Nuclear Activities Department, for Consumers Power Company, and as such I am authorized to execute this Affidavit.
- 2.
I am familiar with Consumers Power Company's detailed Document Control System and procedures which govern the protection and control of information.
- 3.
I.am familiar with the Palisades Plant Emergency Implementing Procedures referred to as the "Document".
Information contained in the "Document"is controlled in accordance with procedures established by Consumers Power Company for*the coqtrol and protection of information.
- 4.
Pursuant to the provisions of Paragraphs (b) and (d) of Section 2.790 of Title 10 Code of Federal Regulations, the following is furnished for consideration by the Commission in determining whether the "Document" should be withheld from public disclosure:
A. *The ;'Document" is Owned and has been held in confidence by
.Consumers Power Company.
B.
The "Document" is of the type customarily held in confidence by Consumers Power Company in accordance with established procedures for safeguarding information.
The basis that the "Document" is held in confidence is 'that the "Document" contains:
- 1. names and telephone numbers of both employees and State/local officials who respond to emergencies;
- 2. floor plans of various plant areas including the control room, security central alarm station, cable penetration room, battery room and laboratory facilities;
- 3.
communication system and equipment details, including locations*;
- 4. methods of ingress and egress from the power plant protected area, and;
- 5. location of emergency response equipment both on-site and off-site.
C.
The "Document" is being transmitted to the Commission in confidence and, under the provisions of 10CFR2.790 is to be received in confidence by the Commission.
oc1181-0002a142
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D.
To the best of my knowledge and belief the "Document" is not available in public sources.
2 E.
Public disclosure of the "Document" could cause a reduction in the effectiveness of Consumers Power Company to respond to a nuclear incident and therefore potentially lead to a more serious event.
THAT the statements made hereinabove are, to the best of my knowledge, information and belief, truthful and complete.
CONSUMERS POWER COMPANY Buckman, Executive Director Nuclear Activities Department SUBSCRIBED AND SWORN TO before me this 4th day of November, 1981 *
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Helen I Dempski,NOtaPUblic Jackson County, Michigan My Commission expires December 14, 1983.
oc1181-0002a142
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