ML19318B383

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Forwards Evaluation of SEP Topics II-1.A Re Exclusion Area Authority & control,II-1B Re Population Distribution & II-1.C Re Potential Hazards.Evaluation Will Be Basic Input Into Integrated Safety Assessment Unless Mods Required
ML19318B383
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 06/06/1980
From: Crutchfield D
Office of Nuclear Reactor Regulation
To: Hoffman D
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
TASK-02-01.A, TASK-02-01.B, TASK-02-01.C, TASK-RR NUDOCS 8006260029
Download: ML19318B383 (20)


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  • **euq#g UNITED STATES NUCLEAR P.EGULATORY COMMISSION a

wAsMNGTON, D. C. 20555 jr 3kncf4,/

June 6, 1980 Docket No. 50-155 1

Mr. David P. Hoffman Nuclear Licensing Administrator Consumers Power Cogany 212 West Michigan Avenue Jackson, Michigan 49201

Dear Mr. Hoffman:

RE:

SEP TOPICS II-1. A, II-1.B. and II-1.C (Big Rock Point)

Enclosed is a copy of our evaluation of Systematic Evaluation Program Topics II-1.A-Exclusion Area Authority and Control, II-1.B-Population 1

your facility, as described in Docket No. 50-155 with the criteria Distribution and Il-1.C-Potential Hazards.

These assessments cog are currently used by the regulatory staff for licensing new facilities.

Please inform us if your as-built facility differs from the licensing basis assumed in our assessments.

We have discussed these assessments with your staff and believe the facts concerning your plant are correct.

Therefore, our review of these topics is coglete and these evaluations will be a bas':

acut to the integrated safety assessment for your facility unless you f.3

'fy changes needed to reflect the as-built conditions at your faciH;y. These topic assess-ments may be revised in the future if your facility design is changed or if NRC criteria relating to tnese topics is modified before the integrated assessment is completed.

Sincerely, Dennis M. Crutchfield, C f

Operating Reactors Branch #5 Division of !.icensing

Enclosure:

Cogleted SEP Topics II-1.A.

II-1.B.'and II-1.C cc w/ enclosure:

See next page 80062600 M f

Mr. Davi'd P. Hoffman June 6, 1980 cc w/ enclosure:

- Mr. Paul A. Perry, Secretary U. S.~ Environmental Protection Consumers Power Comarty Agency 212 West Michigan Avenue Federal Activities Branch Jackson, Michigan 49201 Region V Office ATTN:

EIS COORDINATOR Judd L. Bacon. Esquire 230 South Dearborn Street Consumers Power Cogany Chicago, Illinois 60604 212 West Michigan Avenue Jackson, Michigan 49201 Herbert Grossman, Esq., Chairman Atomic Safety and Licensing Board Joseph Gallo, Esquire U. S, Nuclear Regulatory Ccanission Isham, Lincoln & Beale Washington, D. C.

20555 1120 Connecticut Avenue Room 325 Dr. Oscar H. Paris Washington, D. C.

20036 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Peter W. Steketee, Esquire Washington, D. C.

20555 505 Peoples Building Grand Rapids, Michigan 49503 Mr. Frederick J. Shon Atomic. Safety and Licensing Board Sheldon, Harmon and Weiss U. S. Nuclear Regulatory Comission 1725 I Street, N. W.

Washington, D. C.

20555 Suite 506 Washington, D. C.

20006 Big Rock Point Nuclear Power Plant ATTN:

Mr. C. J. Hartman Mr. John O'Neill, II Plant Superintendent Route 2, Box 44 Charlevoix, Michigan 49720 Maple City, Michigan 49664 Christa-Maria Charlevoix Public Library Route 2, Box 108C 107 Clinton Street Charlevoix, Michigan 49720 Charlevoix, Michigan William J. Scanlon, Esquire Chairman 2034 Pauline Boulevard County Board of Supervisors Ann Arbor, Michigan 48103 Charlevoix County l

Charlevoix, Michigen 49720 l

Off.ica of the Governar (2)

Room 1 - Capitol Building l

Lansing, Michigan 48913 Director, Technical Assessment L

Division Office of Radiation Programs L

. (AW-459)

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U. S. Environmental Protection Agency.

Costal-Mall #2 Arlington, Virginia 20460.

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BIG ROCK POINT Topic II-1.A - Exclusion Area Authority and Control f

1 The safety objective of this topic is to assure that appropriate exclusion area authority and control are maintained by the licensee as required by 10 CFR Part 100. The review has been conducted in accordance with the guidance given in SRP 2.1.2.

The capability of the plant to meet the dose criteria of 10 CFR Part 100 at the exclusior area boundary will be evaluated in the design basis event phase of the SEP review.

The Big Rock Point nuclear power plant is located on the shore of Lake Michigan in Charlevoix County. in the northern part of Michigan's lower peninsula. The plant site is approximately three miles northeast of the city of Charlevoix and eleven miles west of the city of Petoskey, Michigan. The site exclusion area is defined by the site property limits and thus the exclusion area boundary lines are identical to the plant property lines. A map of the exclusion area, which was obtained from the Big Rock Point Fint.1 Hazards Sumary Report,U) is shown in Figure 1 of this report.

The nearest boundary of the exclusion area on the landward side of the plant is 2,680 feet.

The. licensee has stated that all'of th'e _approximately.600 acres of property within the exclusion area boundaries including the mineral rights is owned by the licensee.

Parts of the exclusion area are traversed by U.S. Route 31 and the Chesapeake and Ohio Railroad, as shown in Figure 1. Arrangements have been made.to control traffic on. Route 31 in the event of a plant emergency, as documented in the Site Emergency Plan.(2)

Similar arrangements, however, have ~ not been made regarding the railroad line.

This is a l

-4 2-departure from the requirement in 10 CFR Part 100 that appropriate and effective arrangements be made to control traffic under emergency conditions on transportation routes through an exclusion area. We do not consider this a significant deviation from current criteria in that the railroad line crosses just a remote corner of the exclusion area and carries a low volume of traffic (two to three trains per week).

In addition, the licensee has verbally stated that arrangements to control traffic on the railroad will be included in the new site emergency plan which is currently being developed.

The licensee, under Michigan law, owns to the water's edge and has the

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right to control access from the landward side to the lakeshore frontage within the exclusion area.

The exclusion area is not defined over the waters of Lake Michigan adjacent to the site. The staff in other cases involving shore front sites has interpreted the definition of an exclusion area in 10 CFR Part 100 as applying to the entire area surrounding a reactor including the overwater portion.

In these cases, applicalts have been required to make appropriate arrangements to control water traffic within the exclusion area in case of an emergency. While the Big Rock Point licensee has not specifically defined an exclusion area over the water, arrangements have been made with the U.S. Coast Guard,(3) as documented in the Site Emergency Plan, for the control of water traffic offshore of the plant in h.

the event of an emergency.

We find that the arrangements made by the licensee with 1

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the U.S. Coast Guard meet the intent of the criteria in Part 100 and, i

therefore, the lack of a defined exclusion area over the water does not constitute a significant safety issue Ter the SEP review.

It may be necessary for the licensee to define an exclusion area offshore at some future date in order to evaluate the atmospheric dispersion characteristics of the site in accordance with new atmospheric dispersion models which take into account wind direction and variation in exclusion area boundary distances.

This issue will be evaluated under SEP Topic II-2.C.

We conclude that the Big Rock Point licensee has the proper authority, with one exception, to determine all activities within the exclusion area, as required by 10 CFR Part 100. The exception concerns the lack of an arrange-ment to control traffic on the Chesapeake and Ohio Railroad line which traverses a part of the exclusion area. This is a departure from current criteria but we do not consider it a significant safety issue in view of the location of the railroad line in relation to the plant, the low volume of traffic on the line, and the stated intention of the licensee to include such i

an arrangement in the new site emergency plan. This completes the evaluation of this SEP topic.

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References 1.

Final Hazards Summary Report for Big Rock Point Plant, Consumers Power

~ Company, Occket No. 50-155, November 1961.

2.

Site Emergency Plan, Big Rock Point Plant, Consumers Power Company, Occket No. 50-155, Re-issued April 1, 1978.

3.

Appendix B Site Emergency Plan, Big Rock Point Plant, Agreement letter with U. S. Coast Guard, September 4, 1975.

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BIG ROCK P0!NT Topic II-1.B Population Distribution Thesafetyobjectiheofthistopicsistoassurethatthelowpopulation zone and population center distance sper.ified for the plant site are compatible with the current population distribution and are in conformance with the definitions and distance criteria of 10 CFR Part 100. The review was conductedinaccordancewiththeguidancegiheninSRP2.1.3. The capability of th e plant to meet the dose criteria of 10 CFR Part 100 at the outer boundary ofthelowpopulati,onzonewillbeehaluatedinthedesignbasisehentphase oftheSEPrehiew. The adequacy of emergancy preparedness planning for the area surrounding the plant including the low population zone will be assessed bytheCommissioninaseparaterehieweffort.

The region surrounding the Big Rock Point plant is generally of low population density and rural to suburban in character. The total population within 30 miles, based on 1970 Census data, was only 46,016. Howeher,theregionhasshownasignifi-cant increase in population between 1970 and 1979. The counties of Charlevoix, Emmet, and Antrim, which cover the majority of the area within 30 miles of the plant, experienced an overall increase of 31". in their resident population between 1970 and 19790) The majority of this population increase is attributed to in-migration primarily from other regions of Michigan.

Seasonal population is an important factor in the area surrounding the plant as this part of Michigan attracts a large number of visitors year round with the peak occurring in the summer season. The seasonal population (i.e., seasonal residents, overnight tourists, and daily visitors) in the three-county area is estimated to increase the population by 75". during the height o." the season (.I) By applying these growth factors to the 1970 Census population we estimate that the 1979 population within 30 miles of the plant was about 60,280 with an additional

'45,210 seasonal cesidents and visitors. This results in a cummulative popula-tion density at ~30 miles of 37 persons per square mile based on the conservative assumption that the seasonal' population is at its peak level _ the entire year.

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. I The licensee has recently completed a survey of the population within a four mile radius of the plant (2) The population was estimated by determining the number of residences within the four mile radius and multiplying each residence by an occupancy factor of 2.9 residents per house, a factor which was derived by the licensee from a study of the population within the licensee's service area. The licensee's population data indicate that as of June 1979, approximately 174 persons resided within two miles, 948 within three miles, and 2,894 within four miles of the plant. These i

population estimates have some conservatism in them in that seasoncl houses were included in the count of residential structures. The licensee also identified 300 industrial workers within the four mile radius.

The nearest city to the plant site is Charlevoix City whose boundary is about 3.5 miles southwest of the site. Charlevoix City had a 1970 Census population of 3,519 and an estimated 1979 population of 4,188(.I) The population is estimated to increase by roughly 60% in the summer tourist season based on the assumption that the seasonal increase in Charlevoix City is the same as that for Charlevoix County as a whole. The resident population of Charlevoix City is projected to reach a level of 6,965 by the year 2000(.3)

The low population zone specified for the Big Rock Point site is the area l

within a 2.5 mile radius of the olant(.4) We have examined the population distri-bution in the vicinity of the plant, in particular the population of Charlevoix City, to determine if a population center as defined in 10 CFR Part 100, i.e.,

a densely populated center containing more than about 25,000 residents, exists near the site. We find' based on an examination of present and projected population data and on observations made during a visit to the site in July

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-. 1979, that neither Charlevoix nor any other city within 30 miles of the plant is now, or is likely to become in the foreseeable future, a population center as defined in 10 CFR Part 100.

We conclude that the low population zone and population center distances specified for the Big Rock Point site remain valid and the site is in conformance with the distance requirements of 10 CFR Part 100 in that the population center dittance is more than one and one-third times the distance from the reactor to the outer boundary of the low population zone.

This completes the evaluation of this SEP topic.

Since the plant site conforms to current licensing criteria, no additional SEP review is required.

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s References-1.

" Population Characteristics of Northwest Michigan", developed by Nancy C.. Hayward, Director, Data - Research Center, Inc., Traverse City, Michigan, June 1979.

2.

" Big Rock Point Residential Survey - 1978 (Draft)," letter to F..Kantor, NRC, from W. J. Beckius, Consumers Power Company, October 11, 1979.

3.

" Working Paper. #9, Population Projections, and Working Paper #9A, Transient Population Projects," developed by Northwest Michigan Regional Planning and Development Commission, Traverse City, Michigan, May 1977.

' 4 Site Emergency Plan, Big Rock Point Plant, Consumers Power Company, October 1973.

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BIG ROCK POINT-Topic II-l.C - Potential Hazards Due to Nearby Industrial, Transportation, and Military Facilities The safety objective of this topic is to assure that the nuclear plant is adequately protected and can be operated with an acceptable degree of safety with regard to potential accidents which may occur as the result of activities at nearby industrial, transportation, and military facilities. The review was conducted in accordance with the guidance of SRP's 2.2.1, 2.2.2 and 2.2.3.

Industrial activity in the vicinity of the-Big Rock Point plant consists primarily of small manufacturing companies. There are also some cement plants and quarries in the area. The closest industrial facility is a manufacturing plant located about one _ mile east where 105 employees are engaged in producing custom molded plastic fixtures. An inventory of approximately 100,000 pounds I

-of thermoplastic materials is stored at the facility.O These materials are not an explosive hazard but could produce toxic combustion products if a fire should occur. The severity of this event with regard to safe operation of the nuclear plant, in particular, the habitability of the control room, would depend on many factors including source parameters, wind speed and direction, cloud plume rise, and protective actions taken by plant operators. Al though the probability of an offsite fire adversely affecting plant opera-tion is low, we believe that the possible occurrence of this event should be one of the factors considered in the overall evaluation of the adequacy of the control room habitability systems. This matter will be discussed further in SEP Topic VI-8, Control - Room Habitability.

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. An industrial park is located about 2.5 miles southwest of the plant.

Several

' light manufacturing companies employing a total of about 200 persons are l

2-located in. the park. No hazardous materials in quantities large enough to affect.the safe operation of the nuclear plant are known to be processed, ll stored, or' transported at the industrial park. An oil company storage terminal is located on US Route 31 near the industrial park. The maximum storage capacity at the terminal is approximately 46,000 gallons of fuel oil and 40,000 gallons of gasoline (.2) No propane is stored at the facility. The separation distance between the fuel storage terminal and the nuclear plant

-(over two miles) is considered adequate to preclude accidents at the terminal

.affecting the safe operation of the nuclear plant. A local planning official i

has stated that no additional industrial developments are proposed or planned for the area in the vicinity of the plant (3)

The nearest highway to the plant is US Route 31 which is located ?,760 feet southeast at its closest point of approach.

Shipments of explosives used in local quarry operations travel on Route 31 past the plant. The guidance of Regulatory Guide'l.91, Revision 1, was utilized to evaluate the consequences

~ f a postulated explosive accident on the highway.

Regulatory Guide 1.91, Rev.1, o

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has been specifically identified by the NRC's Regulatory Requirements Review Committee as one of.the items to be considered for backfit on operating reactors. We fine that the separation distance between the highway and the plant exceeds the minimum distance criteria given in-the regulatory guide for truck-size shipments of explosive materials and, therefore, there is reasonable assurance that an explosive accident on the highway will not affect the safe operation of the plant.*

.t We have also evaluated the potential consequences of highway accidents involving j! -

l toxic chemicals. - A conservative analysis indicates that certain toxic chemicals

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-which form a ~ gas cloud when released (e.g., chlorine, ammonia) could reach the

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power plant safety-related structures, systems, and :omponents could withstand

.a-peak positive incident overpressure of 1 psi. The apability of the Big Rock-Point Plant' to ' withstand a l-psi overpressure will be evaluated in SEP Topic III-2.

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plant in concentrations high enough to be of concern depending on such factors as' spill size and atmospheric dispersion conditions. A;cident data compiled by the Michigan Department of Highways indicate that the expected frequency ofanaccidentinholhinghazardouschemicalsontheapproximatelyten-milestretch of~USRoute31pasttheplantisabout1.3Xlb-3 peryear[(4) The percent of tankertruckaccidentswhichinholheasignificantlossofmaterialisabout 2%.(5) The percent of time on an annual basis that the wind blows from the ten-mile stretch of Route 31 toward the plant is about 51%. Thus,weconserhatihely estimate tha'. ine potential annual exposure rate to the plant due to toxic chemical accident on Route 31 is about 16-5 per year.

TheprobabilityoftoxicchemicalexposurenotedaboYeishigherthanthe acceptance probability le6el used in current licensing criteria (see SRP 2.2.3).

Howeher,thecalculatedfrequencyoftoxicchemicalaccidentsonRoute31past

- the plant is based on the assumption that the toxic chemical traffic on Route 31 is'similar to that on other highways in Michigan. Our review of the industrial acti6ity in the region surrounding the plant indi, cates a lack of industrial or chemical complexes which would generate toxic chemical traffic. Therefore, it is our judgement that the threat to the safe operation of the plant posed by highway accidents inYolhing toxic chemicals is sufficiently remote so that suchaccidentsneednotbeconsideredasadesignbasisehent.

If future traffic information shows an increase in toxic chemical shipments on Route 31,

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itwillbenecessaryforthestaffandthelicenseetorehiewthesituationto determineifadditionalprotectiYemeasuresfortheplantarerequired.

(See

-SEP Topic VI-8, Control Room Habitability, for further-discussion).

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. A Chesapeake & Ohio Railroad branch line runs approximately 5,600 feet south of the plant at its closest point.

Information obtained from the railroad company indicates that three freight trains per week providing only local service use the line(6)The railroad company identifies propane as the only hazardous material shipped on the line. We have evaluated the consequences of a postulated explosion on the railroad in accordance with the guidance in Regulatory Guide 1.91, Revision 1.

We find that the separation distance between the railroad line and the plant exceeds the minimum distance criteria given in the regulatory guide for railroad shipments of explosive materials and, therefore, is acceptable.

The nearest pipeline to the plant is a 6-inch diameter natural gas line which is located about 1.5 miles south {7) At this distance, pipeline accidents will not affect the safe operation of the plant, based on evaluations of pipeline accidents done in previous licensing reviews. There are no gas or oil production fields, undergrouna storage facilities, or refineries in the vicinity of the plant.

There are no large commercial harbors near the plant but some commercial shipping does take place at Charlevoix Harbor which is approximately 4 miles southwest of the plant. While the great majority of the cargo consists of non-hazardous commodities such as coal and limestone, some gasoline and fuel oil is shipped from the harbor by barge $8)All of the gasoline and fuel oil is loaded into barges from trucks for shipment to Beaver Island which is some 25 miles northwest of Charlevoix. Two barge line companies, each with one barge, are engaged in this trade.

Between them they make about 20 trips per year and the captains estimate that they come I

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no closer than about three to four miles from the plant.(9) Thus, the occurrence of a barge accident with consequences severe enough to affect the-safe operation of the plant is extremely unlikely and does not constitute a credible risk to the plant. Similarly, the main shipping route in Lake Michigan which is located about 40 miles northwest of the plant is not a threat to plant operation.

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. The necrest airport to the plant is Charlevoix Municipal Airport which is located approximately five miles southwest. Tre airport has one paved runway 3,500 feet in length oriented,

an east-west direction and two turf runways.

Charlevoix Municipal is a general avaiation facility used primarily by ligat single engine aircraf'. There u re a t'otal of 16,800 itinerant and local operations at the field in 1976 and this is projected to increase to 71,000 operations in 1997 according to the airport master, plan.00)

The master plan recommends that Charlevoix Municipal Airport should be upgraded to a I

basic transport facility, i.e.

re capable of handling turbojet powered aircraft up to 60,000 pounds gross weight. Using the analytical model given in SRP 3.5.1.6, we conservatively cakit: the the probability of an aircraft from Charlevoix Airport crashing into the Big Rock Point plant is 8.5 X 10-7 per year. Conservatisms in our calculation include the use of the projected 1997 level of operations, the assumption that all aircraft arriving or departing the airport fly over the plant area, and the consideration of the entire plant as a potential " target area".

In fact, since the vast majority of aircraft operating at Charlevoix Airport are expected to be light, general aviation aircraft, only a small fraccion of postulated aircraft strikes would seriously affect the safety of the plant. The probability of an accident resulting in severe radiological consequences would, therefore, be even lower than the probability value given above. We conclude that the Charlevoix l

Airport does not represent an undue risk to the safe operation of the nuclear plant and meets the acceptance criteria of SRP 2.2.3.

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, ' A military low level training route (IR 600/601) currently passess 6.5 miles northeast of the plant measured to the centerline of the route at its closest

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i point of approach.(II) The route includes'a radar bomb scoring range over Lake Michigan and is flown primarily t,y Strategic Air Command B-52s and FB-111s.

No live weapons are involved in these bomb scoring runs. At the request of the -staff, the U.S. Air Force undertook a study to update an earlier analysis

.of the risk of a military aircraft on IR 600/601 crashing into the plant. The study was based on recorded data on flight frequency, navig'ation error, and crash rate. The ' Air Force calculated that the probability of a crash at the plant (represented by a square target area 3.45 miles on a side) was approximately 10-8 per year.(12) The staff has reviewed the Air Force analysis and is in essential agreement with the methodology employed and the finding that a military aircraft crash at the plant is an extremely remote event.

Furthermore. -in the

. course of this review, the staff was informed by the Air Force that permission had been requested from the FAA to adjust route IR 600/601 so that in effect it would be located at a. greater. distance.from the plant. The staff was subsequently informed that the request had been approved (13) and the Air Force expects to formally publish the new route on May 15, 1980.(14) The adjusted route will pass approximately 12 miles west of the plant. We conclude that the risk to plant safety of military aircraft on route IR 600/601 in its present configuration is acceptable and meets the acceptance criteria of SRP 2.2.3.

In addition,.the planned. adjustment to the route' will reduce the risk of a military aircraft accident at the plant to,an even lower. level.

We. conclude that the Big Rock Point plant is adequately protected and can

be operated with an acceptable degree of safety with regard to industrial, transportation,.and military activities in the ' vicinity of the plant. We have E

e g identified' possible toxic combustion products from a fire at a thermoplastics i.

facility located one mile from the plant as an item for further consideration in the cherall ehaluation of the habitability of the control room. This completes the ehaluation of SEP Topic II-1.C.

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REFERENCES 1.- - Personal communication with Michael Johnson of Lexalite Corporation, Charlevoix, Michigan, November 7,1979.

2.

Persona! comunication with Gordon C ibb, Woodland Oil Company, Charlevoix,. Michigan, November 15, 1979.

Meeting with-John Hess, Charlevoix County Planner, Charlevoix, Michigan,

3. -

. July.19, - 1979.

4.- " Analysis of Truck Accidents-in Michigan"., TSD-350-77, Michigan Department of State Highways and Transportation, data from Sandra Cornell, Traffic Technician, Michigan DOT, December ~12,.1979.

5.

"A Modal Economic and Safety Analysis of the Transportation of Hazardous Substances in Bulk," Arthur -D.

Little, Inc., Report No. COM-74-11271, 1974

6. - Letter from R. G. - Rayburn, Vice President - Transportation, Chessie System to F. Kantor, NRC, December 6,1979.

7.

' Michigan _ Major Gas Pipelines and Franchise Map", compile'd by Consumers Power C.ompany, ' January,-1977 and " Michigan Oil Pipeline Map", Public Service Comission, Michigan Department of. Comerce, July 1976.

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Waterborne Comerce of the United States, Calendar Year 1974, Department of the-Army, Corps of Engineers.

9.

Personal comunication with Jules Gi'espie, Filespie Oil Company, and Wayne Chapman, _ Midnight Oil Company, November 16, 1979.

10. Charlevoix Municipal Airport, Master Plan, prepared for the City of Charlevoix.by Arthur A. Ranger, Consulting Engineer, Jul.y 1977.
11. " Area Planning, Military Training Router, North and South America",

000 Publication AP/18,-January 24, 1980.

12.. Letter from Col. David L. Nichols, Deputy Director for Operations and Training, Headquarter United States Air Force, Washington, D.C.

to F. : Kantor, NRC, _ January 9,1980.

13. _ Personal comunication with Lee Schuldt, FAA Air Route Traffic Control Center,- Minneapolis, Minnesota,. February 5,1980~.

.14.

Personal comu'nication with Lt. Col. James Scherer, U.S. Air Force,

,Barksdale Air Force Base, Louisiana,_ February-8,1980.

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