ML20041B811
| ML20041B811 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/28/1981 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20041B806 | List: |
| References | |
| EA-81-082, EA-81-82, NUDOCS 8202250224 | |
| Download: ML20041B811 (2) | |
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David P Hoffman Nuclear Licensurg Admmustr.utur General offices: 1945 West Parnail Road, Jackson, MI 49201 * (517) 788 1636 October 28, 1981 Victor Stello, Jr, Director Office of Inspection and Enforcement US Nuclear Regulatory Co= mission Washington, DC 20555 DOCKET 50-255 - LICEN3E DPR PALISADES PLANT - RESPONSE TO NOTICE OF VIOLATION EA 81-82 NBC letter dated September 22, 1981 contained a Notice of Violation to which a response is required.
Consumers Power requested a one week extension which was acceptable (DPHoffman phone conversation with ABDavis on October 22,1981).
The Notice of Violation and response thereto are as follows:
Violation As a result of the July 2h,1981 submittal from Consumers Power Company in response to the July 1,1981 NRC request for information on emergency planning and in accordance with Interim Enforcement Policy, h5 FR 6675h (October 7, 1980), the following violation was identified:
10 CFR 50.5h(s)(2) and Section IV.D.3 of Appendix E, require that by July 1,1981, each nuclear power reactor licensee demonstrate that administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway of Emergency Planning Zone'vithin about 15 minutes.
Contrary to the above, Consumers Power Company was unable to demonstrate that means had been established for alerting and promptly providing public instruction within the plume exposure pathway of the Emergency Planning Zone within about 15 minutes.
Response
Consumers Power Company acknowledges the item of non-compliance.
- However, Consumers Power did install and demonstrate that administrative and physical means for alerting and providing prompt instructions to the public for a five (5) mile radius from the Palisades Plant site had been established prior to July 1, 1981.
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DESIGNATED ORIGIN 8202250224 810104 Certified W _ AMod AMI '"
N PDR ADDCK 05000255
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Victor Stello, Jr, Director 2
y Yalisades Plant October 28, 1981 At the same time, Consumers Power was developing a position to demonstrate that five miles was the appropriate radius for immediate notification within j
the Palisades Plant Energency Planning Zone (EPZ).
This position has been strengthened by our current calculations which use plant-specific meteorology and regulatory guidance provided in a letter to Consumers Power Company from James G. Keppler dated October 1h,1981, plus source term considerations addressed in NRC Memorandum from William J. Dircks, Executive Director for Operations, to Samual J. Chilk, Commission Secretary, dated May 29, 1981.
Despite our continued belief that immediate notification should be required only for the first five miles of the 10-mile EPZ, Consu=ers Power intends to expand the siren system around the Palisades Plant out to a 10-mile radius.
Consumers Power Company will make a concerted effort to have the additional sirens installed by the new proposed implementation' date of February 1, 1982. This action should bring our emergency planning activities into total compliance with the NRC staff interpretations of 10 CFR 50, Appendix E.
Finally, Consumers Power Company requests that this Notice of Violation be classified as a Severity Level V violation.
Our initial responsiveness to emergency planning requirements (ie completion of an operable siren system prior to July 1,1981 and completeness of our Site Energency Plans) and our intent to keep the NRC staff informed (albeit informally) of the status of the Palisades Plant early warning system demonstrates a positive attitude on this issue.
David P HofDnan Nuclear Licensing Administrator CC Director, Office of Nuclear Reactor Regulation Director, Region III, USNRC NRC Resident Inspector - Palisades u
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a CONSUMERS POWER COMPANY Palisades Plant NOTICE OF VIOLATION EA 81-82 Docket 50-255 License DPR-20 At the request of the Commission and pursuant to the Atomic Energy Act of 195h and the Energy Reorganization Act of 197h, as amended, and the Co= mission's Rules and Regulations thereunder, Consumers Power Company submits our response to Notice of Violation EA 81-82 dated September 22, 1981.
Consuners Power Company's response is dated October 28, 1981.
CONSUMERS POWER COMPANY
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BY J' W Reynolds, Executive Vice President Energy Supply Sworn and subscribed to before me this 28th day of October 1981.
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Helen I Dempski, Notary Public Jackson County, Michigan My commission expires Decmeber ib, 1983
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