ML19343B628
| ML19343B628 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 12/10/1980 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Christamaria BIER, MILLS, CHRISTA-MARIA, ET AL |
| Shared Package | |
| ML19263G361 | List: |
| References | |
| NUDOCS 8012240475 | |
| Download: ML19343B628 (2) | |
Text
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- fi c%jb e-UNITED STATES y
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NUCLEAR REGULATORY COMMISSION e
W ASHINGTON, D. C. 20$55 t
December 10, 1980
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Docket No. 50-155 oE f'
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Christa-Maria u
Route 2, Box 108C 4
0 Charlevoix, Michigan 49720 g
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Dear Ms. Christa-Maria:
Your letter to me dated March 18, 1980 addressed several concerns you have about the Big Rock Point Plant.
I apologize for the delay in the response to your letter. In order to provide a more complete response, we wanted to include the results of our review of Consumers Power Company's request for a delay in the implementation of certain plant modifications identified by the NRC. This review was recently completed.
In particular you referred to a Consumers Power Company cost-benefit study, the safety of operation pending completion of studies and modifications, the acceptability of the Big Rock Point Emergency Plan, and a cost-benefit analysis of the proposed increase in spent fuel storage at the Big Rock Point Plant.
Each of these matters is discussed below.
By letter dated February 22, 1980 and supplement dated April 2,1980 Consumers Power Company proposed an overall risk assessment for the Big Rock Point Plant and requested deferral of ten plant modifications identified by NRC. A copy of our respons'e dated October 14, 1980 to Consumers Power Company is enclosed and addresses this assessment and requested deferrals.
None of these items are considered by us to be so critical to the assurance of public safety as l
to require shutdown of operating nuclear power plants until the items are implemented.
It is our judgement that existing safety requirements and i
changes resulting from our short term lessons learned (from TMI) requirements I
provide reasonable assurance that the health and safety of the public will not be endangered.
However, our evaluation of the TMI accident indicates it is l
prudent and reasonable to require an enhanced level of safety for long term operation.
You indicated that one of the items resulting from our Three Mile Island accident evaluation which is of special concern to you is the matter of insufficient shielding. The adequacy of the shielding at Big Rock is the subject of a letter sent by you to Commissioner Ahearne. Your letter is being treated as a request under 10 CFR 2.206, and a response to your request will be issued shortly.
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Christa-Maria
-2 December 10, 1980 With respect to emergency planning, Consumers Power Conpany has an existing emergency plan which conforms to our current regulations. An upgraded emergency plan is under review and should be implemented within the next several months. We expect this upgraded Big Rock Point Emergency Plan, along with upgraded state and local emergency plans, to provide effective evacuation plans which consider a range of weather conditions, transient population and existence of nearby schools. Our evaluation of the pro-posed upgrading of the Big Rock Point Emergency Plan will be placed in the local public document room at the Charlevoix Library.
With respect to a cost benefit analysis regarding the proposed increase in storage capacity of the Big Rock Point spent fuel pool, the Atomic Safety and Licensing Board's memorandum and Order dated Septenber 12, 1980, admitted Mr. O'Neill's contention which was restated by the Board as follows:
"An environmental review of the proposed spent fuel pool expansion is necessary under Section 102(2)(c) of NEPA and would indicate that the environmental costs of this expansion exceed the benefits."
As you know, this matter is the subject of litigation in the spent fuel pool modification proceeding.
I hope that this reply fully responds to the concerns addressed in your letter.
Sincerely, WW Harold R. Denton, Director Office of Nuclear Reacter Regulation
Enclosure:
October 14, 1980 I
letter to CPCo i
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October 14, 1980 Doci.et No. 50-155 Mr. Russell B. DeWitt Vice President Nuclear Operations Consumers Power Company 1945 Parnall Road Jackson, Michigan 49201
Dear Mr. DeWitt:
Your letter dated February 22, 1980, indicated that Consumers Power Cogany intends to perform an overall risk assessment of the Big Rock Point Plant and proposed that certain plant modifications required by the NRC be deferred until a risk assessment to assess the feasibility of continued plant operation is co gleted.
This proposal was discussed at our meeting of March 20, 1980. Your letter of April 2,1980, sumarized certain issues discussed during the March 20, 1980 meeting, provided additional information fnr our consideratier. and indicated that this effort could be completed within one year. Recent discussions with your staff indicate that the work will be cogleted by April 1981. Additional information was provided in your letters dated August 25, 1980, and September 2,1980.
We have reviewed the list of ten items that you proposed to be deferred until the risk assessment is completed (Enclosure 1). Based on our review, we con-l clude that the ATWS recirculation pump trip modifications (Item 6) and the alternate shutdown panel (Item 4) cannot be deferred in view of the Comission Orders addressing these subjects. The Commission Confirmatory Order dated February 21, 1980, discusses the need for implementation of the ATWS recircula-tion pump trip modifications and establishes a schedule for its implementation, and we believe that this implementation schedule should not be modified.
Requirements regarding the alternate shutdown panel are covered by the proposed Appendix R to 10 CFR Part 50. The cogletion date for this item shall be covered by the requirements of the proposed Section 50.48 to 10 CFR Part 50 when it becomes effective.
You also requested a delay for the c (Item 9). We are currently developi implementation dates for meteorologi DUPLICATE DOCUMENT sites. We expect to issue this gui current position is that by April 1 Entire document previously meteorological data capability shoul entered into system undar:
we believe that an interim meteorl h0/// Ddkh
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ANO constructed by that date.
The remaining seven items deal with No. of pages:
7 requirements that flow from NUREG-p ooL %
Christa-Maria Rt. 2. M-66, Bar 108C Charinoix. Michigan 49720 Ph (616) 547 2?84 3.18.80 To Connissioner of the NRC Harold Denton
Dear Sir,
This letter is in regard to the Big Rock Point Nuclear Plant, from which I live appro. 6 miles.
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As an intervenor in the spent fuel case I am familiar with the plant, it,s design and most of the material the NRC is providing for the public
,b to see at the Charlevoix library.
Recently Consumers Power has released to the Press that they wish to -
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M 6." r have cost-bebefit study made ofr all the equipment the NRC wishes to II, T, % M them to implement now.
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From the newspaper it appears that all these request come out of the ct}-T TMI incident.
From our research we know that a lot of these items were ordered long before
'lMI ever happened.
Some of these items are also in the contentions of Joann Bier and Shirley Johns presently before the NRC.
Your letter to them was presented to me and in my opinion it is still to dangerous to let the plant operate until all items of concern are fina-
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lized and implemented.
I Of special concern to me is the matter and insufficient shieldinh Also living here it is next to impossible to come up with a workable evacuationplan.We habe extreme weatherconditions in this area, very few highways and an almost double population in summer, sporadic increase in winter. Of immediate concern is the location of an elementary school 4 miles from the plant.
Returning to the matter of cost-benefit analysis. Recently in the course of the intervention, Consumers and the NRC felt that the Board should not rule an order for a cost-benefit anal.ysis. Our answers try to prove why such a i
l study should be ordered, John 0,N ill a fellow intervenor did the same.
All those documents should be available to your through the NRC legal staff c/o Janice Moore.
We feel it is time that the NRC orders a study made of all_ items, including the shielding and pool expansion, before further permit is given to operate the l
plant. As a ratepayer of CP I am sure that my rate will be higher no matter what.Eithee for implementation of all ordered items or for decommissioning the plant.
Is anybody eve.luating the cost for Charlevoix county on extra safety, communication l
l equipment,Healthdepartmentsgp-up,etc.t For the 15 power this company is providing Consumer power with,' all of the 1
dangers or the precautionsx to an incident do just not seem to be worthwhile.
l People in this area survive largely from the tourist-trade and I feel that go/
l this area may become unpopular for a vacation because of the dangers 3
t Big Rock Point presents.
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Thank you, (pas,2%
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Consumers Power Asks N RC i
For Support on Safety Study By NANCY JARVIS would require replacement comments came in conjunction outof theway."
"We need more of an CilARLEV0lX - Consumers powerto be transmitted several with the presentation of thePresident's Power Co., operator of the Big hundredmiles.-The plant has operated over honor Big Rock's 115 em Rock Point nuclear plant, has for the third absolute _ safety' has to be i
requested Nuclear Regulatory 17 years with many of the same have earned ~ ddled. The NRC, OSHA Commission support on a study staff members. "The continuity consecutive year."We all feel we are pawns in (O mo what safety equipment and experience of the staff is Administration) and
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f ofshould be installed at the plant believed to be a significant the hands of the bureaucracy.ls Health (En l
and at the same tmie keep the contributor to overall plant there anything we can do Administration) safety "You can be safe. And do u mustallbe balanced.
plant eost effective, uncertainity to the public."
l The'utibty proposes to hire a Calhng the NRC " drunk with your own desires tell you. Don't
" Poverty can kill also.. "
! cor.sultant to conduct an overall power." Selby told Big Rock be afraid to speak up," Selby l
i risk assessment by identifying Wednesday that answered.
Selby said, relating that
' the plant characteristics that ' employees be too Selby said regulation iy "a regulations at too great a cost
$ ave the greatest effect on NRC directives may the _real problem" and one that can be just as serious to the i
h to warrant
! pubbe health and safety. Any expensiveoperation of the 18-could be solvedin a few yearsif consumer as continu.-
modifications to reduce risk would be evaluated year old plant. Selby's the regulators would just "get measure iproposed would achieve and the costs of i
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to determine the benefits they i
obtaimng those benefits.
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Consumers has asked for an b
e NRC response to the proposal
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by Aprill.
Some of the items proposed 1 tot study art the reed for a
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the plant's contal.1 ment
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,a building and a techn'ca' support l,,,.'-
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duplicate monitorin6 of plant T]
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r-Officials say the program is i
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the most ccet effective way to
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- Earber this week, the NRC i
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l $650.000 shut off unit on the plant's recirculating pumps.
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i Consumers may also be
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