ML20040C782

Ack Receipt of Re Emergency Planning.Pamphlet Has Not Been Submitted to NRC for Review.Fema & NRC Will Review Public Info Program

ML20040C782
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	02/20/1981
From:	Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Christamaria BIER, MILLS, CHRISTA-MARIA, ET AL
Shared Package
ML20040C778	List: ML20040C777 ML20040C782
References
NUDOCS 8201290234
Download: ML20040C782 (16)

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NUCLEAR REf3ULATORY COMMISSION

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February 20, 1981 Ms. Christa-Maria Rt. 2, M-66, Box 108C Charlevoix, Michigan 49720

Dear Ms. Christa-Maria:

Thank you for your letter of January 7,1981, concerning public education and infomation for Emergency Planning around the Big Rock Point (BRP) Nuclear Facility. The emergency planning information pamphlet which was attached to your letter has not yet been formally submitted to NRC for our review. The public 'infomation program will be reviewed by both NRC and the Federal Emer-gency Fanagement Agency, and your coninents about the pamphlet will be taken into account during our review.

Enclosed are answers to emergency planning concerns raised in your letter.

Please do not hesitate to call us if we can be of further assistance.

Sincerely, G.

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Brian K. Grimes, Director Division of Emergency Preparedness Office of Inspection and Enforcement l'

Enc 1chure:

Answers to Emergency i

Planning Concerns cc: Big Rock Pt. Nuclear Facility C

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ENCLOSURE

' Concern:

When is the Emergency Planning Public' Education and Information program to be implemented?

Response

The new rule for emergency planning,10 CFR 50.54 (s) (2),

(copy enclosed) states that, for operating power reactors, the licensee, State and local emergency response plans shall be im-plemented by April 1,1981. This means that the licensee shall have in place a Public Education and Information Program which meet our criteria (NUREG-0654, Section G).

Concern:

What area around Big Rock Point (BRP) will receive the Public Information pamphlet?

Response

BRP and other plants less that 250 MWE may use a plume Exposure Planning Zone (EPZ) of about 5 miles and an ingestion pathway EPZ of about 30 miles.

This conclusion is based on the lower potential hazsrd from these facilities (i.e., lower radionuclide inventory).

Accordingly, we expect the public information program to be pro-vided to the permanent and transient population in the 5 mile EPZ.

Concern:

The Public Information Program should give clear information that children and pregnant women need special attention.

Response

We agree with your concern. The Public Education pamphlet is generally weak in providing useful information about radiation hazards. We will address this as part of our review.

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Concern:

BRP has a higher than unusual plutonium inventory in the fuel and therefore poses a greater concern for offsite emergency planning.

Response

For a core melt type accident resulting in an atmospheric release thru containment, plutonium and uranium are not the limiting radionuclides. The significant radionuclides which could con-tribute to the dominant exposure modes are radio iodines, noble '

gases (kr&Xe), cesium, telluruim, and ruthenium.

Concern:

Lack of training to school officials located within the 5 mile EPZ.

Response

We agree with your concern.

Proper training for school boagds, superintendents and teachers regarding their action during a nuclear power plant emergency is extremely important. We expect the State and local plans, together with the licensee plan to address this training. This area will be reviewed by FEMA and the NRC.

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We are prepared YOUR GUIDE TO Tile CilARLEVOlX AND Ehth1ET COUNTY Eh!ERGENCY OPERATIONS PLANS Evacuation Routes y

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b INFORh1 ATION FRON! Tile SIIERIFFS DEPARTh1ENTS AND F.51ERGENCY SERVICES DIRECTORS 1000 GRANT ST., Cil ARLEVOlX,51149720 m-i ve-we 450 BAY ST., PETOSKEY, h!! 49770 l'hy

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r Excessive exposure to radiation, however, can be harm-EVaCllatillD OIle S fui-even ietnai. aust== overexposure to suniioni can cause painful sunburn, exposure to certain levels of other kinds of radiation can have adverse effects.

HoIIIe or Property The eerm thet can ceme te veu frem reeiet'en oivee eff by radioactive materials which could be emitted in ab-normally large quantities in a nuclear plant incident would depend on several factors. They include the na-

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I ture and power of the rays and invisible particles that strike you, the length of time you are exposed to them, For most Charlevoix and Emmet County citizens, having and how much material you breathe or ingest into your to evacuate their homes or property may be the most

body, unsettling consequence of a natural disaster, a hazard-a, ous material trer'sportation accident, or a serious inci-dent involving Big Rock Point Nuclear Power Plant. Your county government is required to actin the event of such X O Sllre 0 emergencies, and has deve!oped comprehensive plans to safeguard both people and property.

Radioactive Materials Radiatioll n Waai are ihe chances of me or mr famiiv eino ex-s Q* posed to radioactive materials from the nuclear plant?

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. What is radiation?

6 The chances are extremely remote. Since it began Radiation is a physical phenomenon which is nei.

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}* ther new nor mysterious. All of us are exposed to Rock plant has not experienced any event which endan-radiation every moment of our lives. We receive radia.

gered area residents.

tion from the sky in the form of cosmic rays. Rocks and minerals give off natural radiation. We breathe and eat very small am,unts of radiation without even knowing it.

X-rays and other forms of penetrating radiation have brought us medical and scientific benefits.

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messages identifying shelter

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everyone gets the word.

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p information about an emergency

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include:

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WJML Radio, Petoskey (24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />)

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s-WVOY/WKHQ-FM, Charlevoix f

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(24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />)

%g WCLX-FM. Boyne City (5:30 a.m.

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W he How is radiation detected?

hefe t occurs Radiation is invisible, tasteless and soundless, but sit can be detected with the aid of rEdiological and civil defense instruments. Using a Not necessarily, but pos-c-i these instruments, plant and Ile sibly. This will depend c.1 i

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4 State health experts con-such things as the manner in b;M

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tinuously monitor radia-which radioactive materials FM

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tion levels around Big are accidentally released,

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Rock. If a serious in-the amounts released and

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this monitoring speed of the wind. For would be expanded example, should a small to areas beyond the puff or" plume" of i

plant and would provide the radioactive material L

t basis for recommendations on rise from the plant what steps you, as a citizen, should and move fairly quick-take to protect yourself.

ly away, people within a predictable area downwind from the plant may be directed to go indoors and remain there until the cloud passes and the hazard no longer exists.

If radioactive materials are released in a nuclear Qe plant accident, how willi know it?

n if I arn advised to remain indoors, what else should Q. I do?

l A You will be notified of the fact by Emergency Close all outside doors i

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He Broadcast System (EBS) radio or television broad-e and windows and leave casts, by telephone, or in some cases, through personal them closed. This will help C

contact by appropriate authorities.

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You may hear a siren giving an unwavering, steady, three to live-minute blast to alert you to turn on your which may be outdoors.

l radio or television.* You may hear voice warnings being Turn off air conditioners

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broadcast by police or fire vehicles equipped with loud-and other air intakes.

j speakers. Those residents within two miles of the plant if you have just come in from

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will receive a telephone callinforming t.1em of the emer-outside, wash your f ace and I

hands, particularly before f

you handle or eat any food.

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s containers. This will keep any radioactive materials which might seep into the house from contaminating foodstuff.

It will be safe to eat or drink anything in cans, bottles or sealed containers. Do not eat fresh fruit or vegetables taken from your garden during the time of the incident.

Via the Emergency Broadcast System, you will be noti-s fied of any other necessary protective actions.

h,Who will be told to evacuate?

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a This willdepend upon theintensity 1

II.of radiation released in an inci-dent, and the circumstances prevailing 3

at the time,if the hazardous materials are released in abnormal quantities into the air, the direction and speed ' O m

of the wind willdetermine which i

areas should be evacuated.

Because Big Rock is a t..

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relatively small nuclear County need to be evacuated, they would go to public schools in Petoskey.

plant (less than 250

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where they live, they would go to Reception Centers at deal with a general g ?@W\\

public schools in either Mackinaw City, Alanson or Pell-emergency place ini-tici emphasis on the ston.

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radius of the plant.

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You may be ab,le to get a ride from a neighbor. if 2}e this is not possible, listen to radio or television for in the the "p. path of particles settling from a puff or " plume"'

ume exposure emergency planning zone." The the locations to which you may walk for special trans-five-mile zone includes the following areas: in Charle, portation. If you live too far to walk, call for a nde by voix County, portions of Hayes and Chadevoix Town, dialing the number being broadcast over television and ships and the City of Charlevoix and in Emmet County, radio.

portions of Resort Township. Only people in certain por-tions of these areas might be advised to evacuate.

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1 O If I am told to evacuate, what should I do and W where should I go?

p Ae er plant incident, the duration of the resulting haz-Depending upon the seriousness of a nuclear l

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ard could range from several hours to several days. The hazardous area could vary from a few feet from the plant j

to a several square mile area surrounding or downwind

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from the plant. In most cases, evacuation would be or-dered as a precaution, well before you would be cen-fronted with any danger.

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If an evacuation is ordered, you should close all doors and windows; tum off stoves, heaters, fans and air con-g-Q E M

ditioners; and leave the area calmly in your own vehicle.

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You should follow routes which will be identified on the radio, television or other means, if you live in Charlevoix 1

4 County, you would be directed to go to Reception Cen-ba ters designated for Charlevoix County residents. They

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are Boyne City, East Jordan and Ellsworth high schools.

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agencies will have a record of their needs and will pro-i vide special transportation.

h.What about evacuation of the elderly or disabled?

he What should I take with me in event of evacuation?

For temporary shelter, Aa senior citizens and the

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J Take with you only those things that you would As need, for example, for a short visit to someone's physically disabled will be

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evacuated by special teams

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i If I am boating on Lake Michigan or Lake Charle-

• voix or vacationing at one of the several recrea-Bedding or sleeping bags would be useful, along with tional areas near Big Rock Nuclear Power Plant, how personal items. Remember your presenption medicmes will i be alerted about a general emergency?

and supplies for inf ants (diapers, bottles, formula). Bring your pets with a supply of dry or canned food.

The Charlevoix County and Emmet County Sher-As a general precaution for any emergencies, it is a eiffs Departments will initiate marine communica-good idea to keep your vehicle supplied with emergency tions to advise boaters and fishermen of an emergency and to inform them of safe waterways or docking areas.

equipment, If my children are in school when an evacuation

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Students from area schools which are within a five-

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Ae mile radius of the plant (Charlevoix elementary,

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m sori Children's House) would be transported by school d,

buses to East Jordan High School.

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3E The U.S. Coast Guard, the Michigan Department of Na-C *w tural Resources and the Sheriff's Marine Patrol will di-l I

SJ Z Z 1'"^J rect t'ils operation. Park managers will be alerted by I

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telephone, radio or personal contact. Shelter for these l

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L We Have Faith in Our Misfortunes Can Occur Emer0enPU agn$HH Severe winters, fires, tornadoes or other natural disas-UJ RAAAAU ters can endanger a population. We've learned to live with the possibility that such misfortunes can occur; We have faith in our e nergency planning, which is the we're comforted in part by the knowledge that through result of cooperation by a number of county and state experience, humans have learned to plan for the pos-agencies. This faith was borne out on June 24,1980, sibility of such disasters and to cope with their effects.

when we had a successful" rehearsal" of an evacuation.

The information contained in this booklet is designed to contribute to a greater public awareness of our emer-m-

J gency planning, which is essential to dealing success-fully with any eventuality.

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Emergency planning must also take into account the possibility of man-made incidents, such as rail or high-OIHmon Sense #

wer eccieeete. er ire unniennee re'eeee ef reeieiooicei materials from the Big Rock Point Nuclear Power Plant.

Because of the abundance of safeguards designed into 00mm0n Courtesy nu*er now 9-reno <=iiities. * *n== o' e serious incident requinng an area evacuation are re-mote. Nevertheless, prudent planning and Federal law and CarefuI PIaHBlHD require that you, as a citizen, be informed about what to expect in'the event of a radioactive materials release which exceeds safety levels.

Common sense, common courtesy and careful planning Local and State authorities have made special plans to are inseparable in effectively handling any emergency, handle the special circumstances which could accom-We may never be confronted with a need for anyone to pany such an incident. This pamphlet is designed to evacuate an area in our counties. If we are, we have the answer your questions about what precautionary meas-people and the procedures to do what must be done.

ures citizens should take in the event of a general emer-gency at the Big Rock Point Nuclear Power Plant.

w-F. Earl Muma Charlevoix County Emergency Services Director

h. d J n A. Theisen Emmet County Emergency Services Director i

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.. l. F To: Phil. Loomis, Big Rock PB director

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Rei Meeting, Friday 6 5.81 to discuss revision of

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Dear Phil,

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Although it is very much appreciated that I was envited to participate ih the revision of the emergency e.:

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pamphlet and certainly was allowed to participate in the 3.

discussion I want to make it very clear, that my prescnce and input should not be equated with agreement for printing or distribution.

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Sinos your company made it known, that since there is no n-statue or law to have the pamp hlet edited or fully

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screened before printing by the NRC ( which in this case I fc feel is the only qualified source for editing)my concern y'

I:j lies in the area.that a pamphlet printed by Consumers j...

Power should make more of an effort to ver 1.,'

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material and-wording that itlenot used to "y objective useel sell nuclear t,

"..,,' ' power or " blast" it,but strictly adheres to the NUREG 0654

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guideline in full.

We, the people that have to live within Big Rock's shadow deserve nothing less,4nd a take it or leave'dattitude may m.,

just backfire.

w We encourage further coorperation on this subjectrare willing to participate.

Sincerely,

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Public Education and Information (continued)

Applicability and Cross Evaluation Criteria Reference to Plans Licensee State Local 2.

The public inf onnation program shall provide the permanent and transient adult population j

within the plume exposure EPZ an adequate opportunity to become aware of the information annually. The programs should include provision for written material that is likely to be available in a residence during an emergency. Updated information shall be disseminated at least annually.

Signs or other measures (e.g., decals, posted notices or other means, placed in hotels, motels, gasoline stations and phone booths) shall also be used to disseminate to any transient population within the plume exposure pathway EPZ appropriate information that would be helpful if an energency or accident occurs.

l Such notices should refer the transient to the telephone directory or other source of l

local emergency infonnation and guide the visitor to appropriate radio and television X

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frequencies.

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Each principal organization shal'1 j

designate the points of contact and physical locations for use by news media during 8

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Each licensee shall provide space which may be used for a limited number of the news media at the nearsite Emergency X

Operations Facility.

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Each principal organization shall designate a spokesperson who should have access to all necessary information.

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Each organization shall establish arrangements for timely exchange of informa-X X

X tion among desirmated spokespersons.

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Each organization shall establish coordinated arrangements for dealing with X

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rumors.

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Public Education and Information (continued)

Applicability and Cross Evaluation Criteria Reference to Plans Licensee State Local 5.

Each organization shall conduct coordinated programs at least annually to acquaint news media i

with the emergency plans, infonnation concerning i

radiation, and points of contact for release i

of public infonnation in an emergency..

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999 TECHNICAL CONSULTANTS ON ENERGY & THEENWRONMENT Due G. Bridenbaugh Richard B. Hubbard 1723 Hamilton Avenue-Su te K Grrgory C. Minor San Jose. Ca!.fom.a 95125 December 23, 1981 a ne soa) 266 2776 Ms. Jo Anne Bie r Concerned Citizens for Charlevoix P. O. Box 222 Charlevoix, MI 49720

SUBJECT:

Big Rock Point Spent Fuel Storage Expansion 1

Dear JoAnne:

I have reviewed the document package you sent me l

on the spent fuel storage expansion at Big Rock Point.

I concentrated primarily on the Blanchard Affidavit as it addressed the changes that are being made to the cooling system.

find little to challenge there.I did look at the Sacramo statement briefly, but My general impression of the proposed changes is that they are relatively minor and will have little impact on the current safety of the plant.

risk at a nuclear plant The largest source of increasing the quantity of aged spentis the operating reactor core, and fuel on site does not mate riall however, y increase the public risk.

that the storage pool can become a de.The danger does exist, facto disposal facility with the attending long term risks facility imposes, that such a by advice to you is to attempt two things:

(1)

Try to negotiate a commitment from the utility to remove spent fuel from the facility as soon as reasonably possible.

"Reasonably possible" would entail the establishment of a viable Federal high level waste disposal capability.

It also should address the question of shut l

down and decommissioning of the plant l

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December 23, 1981 Page Two Ms. Bier itself at the end of its useful life.

There is no way to fully cican the site of hazardous material until the plant is decommissioned.

You may wish to consider a negotiated settlement with Consumers Power to the effect that you would drop (with your contentions if they commit enforceable guarantee) to rapid removal i

from the site of the spent fue l.

There is an opportunity to improve the (2)

The safety of the existing facility.

4 connection to the spent fuel pool of the ECCS makeup line would provide a capability It could be made more not now present.

effective by designing it so as to withstand The schematic a single failure challenge.

indicates a shown in Blanchard's Figure 2 single line taken off the core spray header inside the containment for delivering a 2 It is controlled gpm bypass flow to the pool.I have calculated the size by a singic valve. required to restrict the pool of the orifice flow to about 2 gpm and find it is quite small.

Assuming a core spray header pressure of the orifice (or approximately 150 psig, throttled valve) would be only about 0.1 in Since this system would be used in diameter.

for the recirculation mode, there is a good the coolant will contain a lot chance that of dirt and debris.

It would be partially aro tected by the core spray suction s trainers, aut 0.1 inch is a small hole and it couldThe easily plug, making it non-functional.

in a redundant flow solution would be to put control path and to locate the valves and to assure orifices outside the containment i

(See attached copy of marked-up operability.

They Figure 2 for a possible improvement.)

would have to be properly designed as they would become part of the containment boundary, that can be done if proper codes and but j

standards are followed.

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Ms. Bier Page.Three December 2 3, 1981 1

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I have no objection to your reading the above recommen-dation into the record if you wish, but I cannot afford the time I

to prepare an Affidavit or present testimony on this case.

am aircady fully committed for the months of January and February and I do not consider fuel pool expansion an issue that should be seriously challenged.

(That is not to say that it does not need to be done properly and with appropriate review and care.)

The review I have performed is superficial and there is no consulting charge for this advice.

I I hope this information is of some use to you.

encourage your interest and participation in these licensing It is very helpful and conducive to safety, I believe, cases.

when the utility and the NRC know that someone is looking over their shoulders.

Best of Holiday Wishes and a Happy New Year.

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Dale G. Bridenbaugh DGB:cv Enclosbre l

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j WASHINGTON, D. C. 20555

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November 20, 1981

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Docket No. 50-155 L505-81-11-046 Mr. David P. Hoffman Nuclear Licensing Administrator Consumers Power Company

,1945 W. Parnall Road Jackson, Michigan 49201

SUBJECT:

SHIFT STAFFING - BIG ROCK POINT By letters dated June 22. 1981, and July 7.1981. you requested a deferment for the establishment of a 10-man

• operating shift at Big Rock Point until completion of your evaluation of the number of personnel needed to respond in the event of an emergency. We will consider deferring some of the increase shift staffing; however, as you know, the NRC has already recognized the uniqueness of the Big Rock Point facility by reducing the size of the Emergency Planning Zones (EPZ) in a letter dated June 13. 1980. The inhalation pathway was reduced from 10 to 5 miles and the ingestion pathway was reduced from 50 to 30 miles. The letter states that facilities with less than 250 MWt have a lower potential for hazard due to lower radionuclide inventory and longer times to release significant amounts of activity.

You have proposed a 7-man operating shift. identified as follows:

1 Shif t Supervisor (SRO) 2 Control Room Operators (RO) l 2 Auxiliary Operators ( AO) 1 Shif t Technical Advisor (STA)

,1 HP-Rad / Chem Technician-7 Minimum Total

• The minimum on-shif t staffing as stated in Table B-1 of NUREG-0654 is as follows:

1 Shif t Supervisor (SRO) 1 Senior Reactor Operator (SRO) 2 Reactor Operators (RO) 2 Auxiliary Operators ( AO) 1 Shif t Technical Advisor (STA) 1,HP Technician 1 Rad / Chem Technician J Individual responsible for Notification /Comunication 10 Minimum Total

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r Mr. David P. Hoffman November 20, 1981 l

You proposed this shif t complement on the basis of the small size of the Big Rock Point facility (240 MWt, 70 MWe), plant simplicity, past operating experience, and the results of a Probabilistic Risk Assessment (PRA). The PRA cc:icluded that the proposed staffing (listed above) is more than adeqt%e to protect the public and that essentially no acute fatalities will cur as a result of a reactor core damage event.

Your proposal is divided into three issues:

1) The necessity for two SR0s (one of them to be the SS) and one STA,

2) The necessity for two HP-Rad / Chem Technicians, and

3) The necessity for a separate individual as the Comunicator.

Each issued will be discussed separately.

1.

Requirement for Two SR0s and One STA During the back shif t operations, the shif t supervisor (SRO licensed) is responsible for all activities at the site, including control room operations. As such, the shif t supervisor is expected to have duties and responsibilities away from the control room. This is particularly true during emergency situations when the shif t supervisor may be needed at that location in the plant where the emergency situation exists. At the same time, there is a potential need for the knowledge and experience of an SR0 licensed individual in the control room to direct the activities of the licensed and unlicensed operators, especially during emergency I

situations. Accordingly, NUREG-0737 specifies that two SR0 licensed individuals shall be present on each shif t to assure SRO coverage in the l

control room while freeing the shif t supervisor to oversee all site activities and the actions of all site personnel.. An implementation date of July 1,1932, is specified for operating reactors currently licensed on the basis of_ only one shif t SRO.

i The SR0 in the control room is responsible for:

o observing and coordinating actions of the operators, recognizing plant conditions requiring emergency operating procedures, o

o establishing priorities, determining additional equipment and/or support required, and o

o determining steps or procedures required to recover from an emergency.

Since January 1,1980, the NRC has also required a Shif t Technical Advisor to be on site to assure the availability of engineering exper-tise to assist in the diagnosis of off-normal events and to provide advice to control room personnel.

Your proposal of one SR0 whc ds also the SS is not acceptable.

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., f Mr. David P. Hoffman

!' November 20, 1981 r

In view of the small size of the facility, its simplicity (controls are less i-complex than those of a larger nuclear plant), and past operating experienc I

we would consider an alternative to combine the second SRO a l

Technical Advisor.

(SRO licensed) and a single STA/SRO who is an SRO licensed in appropriate qualifications and training to enable him to perform STA duties ual with Combining these two functions would enable you to r r of expertise in the control room deemed necessary by the NRC.

times that the reactor is being operated, even if the Sh The reduced leave.

as to and experience deemed necessary by NUREG-0737.In conclusio n

ons activities could be accomplished with one lest, individual. size be met by a combined STA/SRO.the criginal purpose and intent of an STA (en We also feel that u

still 2.

HP-Rad / Chem Technician Shift Coverage In your letter dated June 22, 1981, the HP-Rad / Chem Technician (Rad / Chem Techs):you made the following conrnents regarding

" Presently, an on-shif t HP Technician'is not provided.

staff within 60-ninutes. involves ' call-up' of required personnel who can augme Current shift The basis for providing only one technician traditionally combined and this is reflected in our Site Implementing Procedurets.

of this technician for amergency situations are quite limited in theIt s first few hours of Emergency Plan implementation."

During an emergency Rad / Chem Technicians are responsible for the fo functions (NUREG-0654,Section I, Paragraphs 7-10. Table B-1):

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In-plant sample collection and analysis o

In-plant monitoring o

Out-of-plant monitoring o

o Decontamination o First aid / rescue During Site or Gen ral Emergency conditions, in-plant sample collection a minimum of two persons. analysis and monitoring and out-of-plant monitoring Therefore, your proposal of one HP-Rad / Chem Technician is unacceptble without additional justification, including how each of the above functions would be accomplished during an emergency.

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r Mr. David P. Hoffman November 20, 1981 3.

Recuirement for Separate Communicator Your letter of July 7,1981, indicates that the Shif t Supervis'or (SS) will l

perform or designate the connunicator role during emergency situations until the Site Emergency Director arrives to fulfill that role. This proposal, for the performance of the con:unication functions during the onset of an emcreency by the Shif t Supervisor, is unacceptable.

During an emergency, the Shift Supervisor must be able to devote full attention to mitigating the emergency. The additional burden of communicator may dilute both the concentration and effort needed to direct immediate actions to prevent a further escalation of the emergency. We,believe the responsibility of a communicator should be accomplished by someone other than the Shif t Supervisor, the Shift Technical Advisor, the Reactor Operators, and the HP-Rad / Chem Technicians.

i You are requested to propose another individual on the normal shift couple-ment who will be used as the cormunicator. For example, an Auxiliary i

Operator (AO) who is appropriately trained in the necessary connunicator skills might be acceptable. You should specify and document what training, i

as a cormunicator this individual will receive, and how connunicator duties will not detract from emergency duties.

Please provide the following information within 30 days of the receipt of this jetter:

1.

How you will provide adequate staffing of the STA and SRO functions, both before and af ter July 1,1982-2.

How the duties and responsibilities of the HP-Rad / Chem Technician specified in NUREG-0654 will be performed and by whom; and 3.

Provide an ' adequately trained individual, not the Shif t Supervisor, who will be delegated the role of connunicator.

Since this request is being sent only to Consumers Power Company and relates to an approval requested by Consumers Power Company concerning

• an issue specific to Big Rock Point, no clearance from the Office of Management and Budget (OMB) is required.

Sincerely, t)

Dennis M. Crutchfield, Chief Operating Reactors Branch #5 j

Division of Licensing t

6 as

GJ486 Fedecal Regleter / V:1. 45. No. In2 / Tu:oday. August 19. 1980 / Rules cnd Remslations reduce ambiguity and provide epecificity capability ofimplementation of State and longer times to release significant 12 the finct regulation.

and local plans.

amounts of activity in many scenarios).

Dased on the above. the Commission

4. To make dacisions with regard to Cuidance regarding the radionuclides to h:s decided to modify the proposed rule the overall state of emergency be considered in planning is set forth in ch:nges in the areas discussed in preparedness (i.e Integration of the NUREG-G)96; EPA 520/1-76 010.

paragraphs I through X below.

bcenaeve emergency preparedness as "Planninn Basis for the Development of determined by the NRC and of the State and local Govemment I. FEMA /NRC Heletionship State / local govemments ee determined Radiological Emergency Response Plans In issumg this rule. NRC recognizes by FEh!A and reviewed by NRC) and in Support of Lixht Water Nuclear th3 sigmficant responsibdities assigned issuance of operating licenses or Power Plants.** December 1978.

to FEhtA. by Executive Order 12148 on shutdown of operating reactors.

July 15.1970. to coordmate the in addition. FFMA has prepared a IV. Ratlocale for Alternatives Chosen amergency planning functions of proposed rule regarding " Review and In a few areas of the proposed rule, exIcutive agencies In view of ET.MNs Approval of State Radiological the Commission identified two nIw role. NRC agreed on September 11 Emergency Plans and Preparedness"(44 alternatives that it was considering.

1979. that FDtA should hanceforth chair W 4:342. dated Jane 24,1980).

Many public comments were received the Federal Interagency Central Acwrdma to the proposed FEMA rule, on these alternatives; based on due Coordinatma Committee for FEh!A will approve State and local consideration of all comments received R;diological Emergency Response emergency plans and preparedness.

as well as the discussions presented Planning and Preparedness (FICCC). On w here appropnate, ba sed upon its dunng the workshops, the Commission December 7.1979. the President issued a findmus and determmations with has determined which of each pair of directar assigmna FEh!A lead respect to the adequacy of State and alternatives to retain in the final rule, responsibihty for offsite emergen y local plans and the capabilities of State In Sections 50 47 and 50 54 (s) and it).

preparedness around nuclear facihties.

and local governments to effectively the alternatives dealth with conditioning The NRC and int A immediately implement these plans and the issuance of un operating license or initiated negotutmns for a preparedness measures. Dese findings continued operation of a nuclear power ht:morandum of Understanding (h100) and determinations will be provided to plant on the existence of State and local that la> s out the agencies' roles and the NRC for use in its licensing process, government emergency response plans provides for a smooth transfer of II. Emergency Planning Zone Concept responsibihties it is recognized that the difference between alternatives A and D De Commissi i n tes that the in these sections was that.under h100, which became effective lanuary 14.1980. supersedes some aspects of regulatog basis for adoption of the alternative A. the proposed rule would previous agreements. Specifically, the Emergency Planning Zone (EPZ) concept require a determination by NRC on is the Commission a decision to have a issuing a license or permitting continued htOU identifies FEhtA responsibdities with respect to emergency preparedness c neerV8tive emergency planning policy operation of plants m those cases where in additmn to the conservatism inherent relevant State and local emergency cs they relate to NRC as the following:

1. 'I.o make fmdmgs and in the defense-in. depth philosophy. This response plans had not received NRC deternunations as to whether State and polmy was endorsed by the Commission concurrence. Denial of a license or local emergency plans are adequate.

in a pohey statement published on shutdown of a reactor would not follow October 23.1979 (44 FR 61123). At that automatically in every case. Under

2. To serify that State and local time the Commission stated that two alternative B. shutdown of the reactor emergency plans are capable of bemd Emergency Planning Zones (EPZs) would be required automatically if the implemented le R. adequacy and should be established around each light-appropriate State ano local emergency m mtenance of procedures, training.

water nisclear p'ower plant. He EPZ for response plans had not received NRC resources. staffing levels and airborne exposure has a radius of about concurrence within the presenbed time quahfication. and equipment).

10 miles;'the EPZ for contaminated food periods unless an exemption is granted.

3 To assume responsibihty for and water has a radius of about 50 After consideration of the public emergency preparedness traimng of miles. Predetermined protective action record and on the recommendation of its St:te and local officials.

plans are needed for the EPZs. The staff, the Commission has chosen a test

4. To develop and issue an updated exact sire and shape of each EPZ will be for Sections 50.47 and 50.54 (s) and (t) saies of mteragency assignments that decided by emergency planning officials that is similar to. but less restrictive dehneate respective agency capalnhties after they consider the specific than, alternative A in the proposed rule.

and responsibihties and defme conditmns at each site.These distances Rather than providing for the shutdown procedures for coordmation and are consiJered large enough to provide a of the reactor as the only enfore snent direction for emergency planmng and response base that would support action and prescribing specific respuse.

activity outside the planning zone preconditions for the shutdown remedy.

Specifically. the NRC responsibdities should this ever be needed.

the final rule makes clear that for for emergency preparedness identified in the N100 are.

. Pos t P anning Dasts for Small emergency planning rules. like all other 1, To asst ss brensee emergency plans Light. Water Neactors an Ft. St. Vrain rules, reactor shutdown as outbned m the rule is but one of a number of for adequacy.

He Commission has concluded that possible enforcement actions and many

2. To senfy that licensee emergency the operators of smalllight-water. cooled factors should be considered in plans are adequately implemented le g.

power reactors (less than 250 htWt) and determining whether it is an appropriate cdequacy and maintenance of the Ft. St. Vrain gas-cooled reactor may action in a given case. This Commission procedures, traming. resources. staffing estabbsh smaller planning zones which choice is consistent with most of the les els und quahhcations, and wdl be evaluated on e esse by case comments received from State and local equipment).

basis. This conclusion is based on the 3 To review the FEhtA findmgs and lower potentisl hazard from these see secuan y for a di cussion concemig determmatmns on the adequacy and facilities (lower radionuclide inventory cencurrence