ML20041A987

Responds to NRC 810621 Request for Info Re Prompt Alerting & Notification of Population.Util Will Provide Prompt Notification Sys for 10-mile Radius to Meet NUREG-0654 Requirements.Installation Schedule Outlined

ML20041A987
Person / Time
Site:	Midland
Issue date:	02/15/1982
From:	Jackie Cook CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-0654, RTR-NUREG-654 15926, OC0182-1268A100, OC182-1268A100, NUDOCS 8202230126
Download: ML20041A987 (4)

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Consumets Power ..l

- James w cook

. ONhbf i Vice President - Projects, Engineering and Construction

- c.n.r.i ome : so4s w.a Pern n no.d. Jack n. ui 4e201. (si7) 7ss o4ss i

February 15, 1982 i

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Mr Harold R Denton, Director \ +

Office ~ of Nuclear Reactor Regulation EECEjVED -

Division of' Licensing 7r 47 US Nuclear Regulatory Commission 2279825 Washington,.DC 20555 r;h. T g .

l' MIDLAND PROJECT. 4 g

-DOCKET NOS 329 AND 330 PROMPT ALERTING.AND NOTIFICATION OF THE POPULATION g g Rfd FILE B13.3 SERIAL 15926

REFERENCES:

.A.-~CP CO (J W COOK) LETTER SERIAL-13821, DATED SEPTEMBER 24, 1981 B. NRC (R L TEDESCO) LETTER DATED DECEMBER 8,1981 C. NRC (R L TEDESCO) LETTER DATED JUNE 21, 1981 i In Reference A. Consumers Power Company made a request for a change in the size.

of- the area for promptly notifying the populace from those located within ten.

miles to those located within five miles of the Midland Plant in the event of

, a'significant radiological emergency. NRC denied this request (Reference B)..

The purpose of this letter is to address the issue of prompt public i notification with respect to the Midland Plant and to provide the information

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NRC requested in Reference C.

A review of Reference B indicates that there is a. misunderstanding among the

, NRC Staff regarding the Consumers Power Company request. The request concerns only the area ~ covered'by the prompt notification system - not the area defining the size of the primary Emergency Planning Zone (EPZ). The five j _ points expressed in Reference B supporting the NRC denial all relate primarily-to the size of the EPZ. The EPZ concept was. developed in November 1978 (pre;

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THI-2) and~ discussed in detail in NUREG 039_6 as you stated. The 15-minute 4- prompt notification' requirement is contained'in NUREG 0654 and in 10 CFR 50, Appendix E, which were developed after the THI-2 incident. 'However, it should be noted that-NUREG 0396 only concluded that time frames, radiological characteristics of releases and other supporting'information for planning and 1 preparedness.must be established. These documents do not provide technical' justification by NPC for. requiring a' 15-minute prompt notification of the In fact, when one reviews NUREG-0396, one .

public throughout the primary EPZ.

draws the conclusion _that a prompt notification system at most need o'nly cover W9 an area of-five-mile radius surrounding the plant. S I

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Reference B also indicated four isotopes which the Consumers Power Company calculations did not consider. Upon' consideration of these isotopes, it was found that they indeed contributed further to the total dose but not enough to change our conclusion. Also contrary to the NRC contention in Reference B, containment integrity was not assumed in our calculations. Rather a uniform release rate over a .24-hour period was assumed leading to the release of 100%

of the noble gases and 25% of iodines in the inventory (per Regulatory Guide 1.4).

Reference B also indicated that Consumers Power Company did not consider thyroid and lung doses. It is. recognized that when one applies all of the assumptions of Regulatory Guide 1.4 to a Class 9 accident, the doses to the lung and thyroid as well as the whole body gamma dose are significant even at 10 miles from the plant. But one must also recognize that some of those assumptions cannot physically occur in nature and others are obviously unrealistic. For example:

1. The assumption that the plume have infinite speed (ie, no decay).

2. The assumption that no deposition occurs.

3. The assumption that the cloud is infinite in size ar.d has a uniform radionuclide distribution.

4. The assumption that a person (for dose calculation purposes) is always located at the centerline of the plume for the duration of the accident. I l

5. The use of theoretical X/Q values, rather than actual measured values.  !

6. The source term assumptions, including the amount of activity available I for release and Midland's lower core thermal power rating.

-The assumptions listed above build upon each other and create a compounding of conservatism which grossly over-estimates total dose. We have'found that the

. guidance provided by Regulatory 1.4 and other more recent NRC documents is not sufficient to address a Class 9 accident. Our calculations based on worst case- accidents postulated in WASH-1400, using conservative but realistic assumptions, continue to demonstrate that prompt notification can reasonably be limited to distances of five miles or less from the plant. Any prompt public notification system which covers an area of greater than a five mile radius from the plant is counterproductive and may unnecessarily alarm the public. When one takes into account a realistic model, it becomes evident that a five-mile prompt notification area ~is sufficient for the protection of the public's health and safety.

While we continue to believe that a five-mile prompt notification radius is more appropriate and technically justifiable for Midland, Consumers Power  %

Company will provide a prompt public notification system for the entire ten-mile Midland primary EPZ vhich meets the design objectives of NUREG 0654, Appendix 3. The reasons for making this commitment are: (1) the fact that this is a regulation (10 CFR 50, Appendix E)~and our observance of NRC enforcement actions in this regard; (2) to minimize possible schedule impact oc0182-1268a100

3 due to short lead times for procurement, installation and testing; and (3) to avoid additional project costs associated with pursuing this issue further.

, Reference C requested that a schedule for installation and system description for.the prompt public notification system be provided by March 1, 1982. The schedule for installation is provided below:

Milestone Date Determine Warning Method 03/04/82 and System Control Award Contract for Warning Units 06/07/82

. Complete System Description 06/28/82

' Install Poles.for Warning Units 09/15/82 Install Control Units (Eacoders) 09/29/82 System Checkout 10/27/82 System In Service 12/06/82 The December 6, 1982 system in service date coincides with the beginning of the requested NFC emergency preparedness appraisal. The FEMA exercise is scheduled for March 17, 1983.

The system description is not yet available as evidenced by the schedule.

However Consumers Power Company plans to model the Midland system after the Palisades system. For a description of the Palisades system see Consumers Power Company (B D Johnson) letter to NRC dated. January 25, 1982, Docket 50-255, License DPR-20.

The Midland Site Emergency Plan will be revised accordingly as information becomes available, f

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4 CC PRBasolo, Director, Emergency Services, _ Mich State Police RJCook, Resident Inspector, Midland RBDeWitt, P-26-117B WJDircks, NRC JDuso, Admin Assistant to City Manager,, Midland WMFreer,' Director, Emergency Services, Midland County BKGrimes, NRC RWHernan, NRC JLMathis, NRC RMerdler, Director, Emergency Services, Saginaw County DBMiller, Midland VStello, Jr, NRC DEVanFarowe, Mich Dept of Public Health CRVanNiel, NRC DDWoods,' Director, Emergency Services, Bay' County f

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