ML20052G130
| ML20052G130 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 05/10/1982 |
| From: | Axtell C CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML20052G119 | List: |
| References | |
| ISSUANCES-OLA, NUDOCS 8205140336 | |
| Download: ML20052G130 (75) | |
Text
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..t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
) Docket No. 50-155-OLA CONSUMERS POWER COMPANY
) (Spent Fuel Pool
)
Modification)
(Big Rock Point Nuclear Power Plant)
)
TESTIMONY OF CHARLES E. AXTELL WITH RESPECT TO CERTAIN SUBCONTENTIONS OF CHRISTA-MARIA'S CONTENTION 9 REGARDING EMERGENCY PLANNING My name is Charles E.
Axtell.
I have been employed for twenty years at Consumers Power Company
(" Licensee") Big Rock Point Nuclear Plant, Charlevoix, Michigan.
I have held the position of Plant Health Physicist for the last fourteen years and have recently been promoted to the position of Chemistry and Health Physics Superintendent.
In this position, I am respo'nsible for radiation protection of plant personnel, the general public, chemistry aspects of plant l
operation and, for the last fourteen years, I have been l
responsible for the Big. Rock Point Plant Emergency Preparedness Program as the Emergency Planning Coordinator.
My resume is attached to my affidavit dated October 2, 1981, responding to Christa-Maria Contention 2 and O'Neill Contention IIA.
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820514o336 82051o PDR ADOCK 05000155 T
t The purpose of this testimony is to respond to Subcontentions (2), (4), (5), (7), and (8) found at page 13 of the April 20, 1982, Memorandum and Order of the Licensing Board, which relate to Christa-Maria's Contention 9 regarding emergency planning.
With the exception of Subcontention (6),
which deals with the Licensee's duty to maintain adequate radiation monitors, all of these subcontentions deal with elements of emergency preparedness for which state and/or local governments, rather than the Licensee, bear primary or at least a shared responsibility with the Licensee.
I would like to explain this fundamental misconception before dealing with the specific allegations of the subcontentions.
The emergency planning concept embodied in Appendix E to 10 C.F.R. Part 50 is based on a division of responsibi-lity between the Licensee and state and local government units and on the cooperation of these three entities in effecting a coordinated response to an emergency.
NUREG-0654, page 23, states:
"Each party involved (in emergency planning) must have a clear understanding of what the overall level of preparedness must be and what role it will play in the event of a nuclear accident.
There must also be an acceptance by the parties and a clear recognition of the responsibility they share for safeguarding public health and safety."
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This concept of division of responsibilities between the Licensee and state and local authorities has been implemen-ted at Big Rock Point Plant.
The Licensee's Site Emergency Plan and Implementing Procedures are found in Volumes 9 and 9A of the Big Rock Point Manual.
The state and counties' emer-gency plans are found in the following documents: State of Michigan Emergency Preparedness Plan; Emergency Operations i.
[
Plan for Charlevoix County, Michigan; Nuclear Power Plant l
Incident Procedures for Emmet County, Michigan.
In our f
situation, the're is a clear division of responsibilities i
between the Licensee, local, and state officials, which is reflected in the respective emergency plans.
The Licensee's I
responsibilities include making the initial evaluation of the.
i incident, notifying the responsible government officials of i
)
projected off-site radiation doses (if any) providing initial recommendations for protective actions, and, most'important, maintaining the plant and its site in a safe condition.
The responsibilities of the State of Michigan, acting through its Department of Public Health, include evaluating the Licensee's classification of the incident and determining whether public protective actions, including evacuation of the local popula-tion, are necessary. The responsibilities of the Charlevoix County Sheriff's Department include carrying out any required evacuation of residents.
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' To assure that the requirements of Appendix E to 10 C.F.R. Part 50 are met, the emergency plans are reviewed by i
two Federal agencies.
Review and approval of the Licensee's emergency plan is primarily the responsibility of the NRC.
Review and approval of the state and counties' plan is l
primarily the responsibility of the Federal Emergency Management Agency (FEMA).
Subcontention 2:
Consumers Power Company (Appli-cant) should improve its public information pamphlet to more adequately inform people about radiation hazards, particularly to children and pregnant women.
In addition, the public, local officials, and school officials should be more completely educated in problems of radia-tion exposure.
Response
This testimony addresses the education of local and school officials.
The remainder of this subcontention is addressed in the testimony of Phillip Loomis.
NUREG-0654 recommends that the Licensee provide 1
l emergency response training for the off-site emergency organi-zations who may be called upon to provide assistance in the event of an emergency.
(NUREG-0654 at p. 75).
The responsi-bility of the Licensee under NUREG-0654 interfaces with f
Michigan state law and the state emergency plan.
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Under its plan, the state has assumed primary responsibility for training of local officials in their respective emergency duties.
Appendix I to Annex A to the T
State of Michigan Emergency Plan, entitled " Nuclear Accident l
l Procedures," is Attachment 1 to this testimony.
The section
" Nuclear Accident Training" at page A-36 states in part:
II.
A.
The Emergency Services Division of the State Police shall coordi-nate all nuclear emergency training programs held within the state for state and local officials.
'C.
It is the responsibi-lity of each state and l
local agency committed to a nuclear power plant response to annually train and I
maintain the capabili-ty of its staff in order to carry out assigned functions.
III. A.
The training unit, Emergency Services Division, has the I
responsibility to develop, implement, and evaluate state level training pro-grams dealing with radiological planning l
and response.
t
. Thus, the Licensee has no responsibility to train local officials under the state plan.
However, the Licensee does provide training to organizations which may be called upon in an emergency, as recommended by the guidelines of NUREG-0654 and, in addition, the Licensee does participate in the state's program of training local officials.
As recommended by NUREG-0659, the Big Rock Site Emergency Plan and the Implementing Procedures provide for training of off-site emergency organizations which may be called upon to provide assistance in an emergency., The training regularly includes education in the problems of radiation exposure.
The staff and doctors of the emergency rooms of the Northern Michigan Hospitals, Inc. in Petosky and the Charle-voix Hospital receive annual training in the care of contami-nated accident victims.
Ambulance crews also receive annual training which includes a lecture and a practical drill at the plant.
Through the course of the training, the emergency room staff and doctors and the ambulance drivers are familiarized with the problems of exposure to radiation.
Area fire departments receive annual training in relation to the Big Rock Plant.
The fire departments'for Charlevoix Township, Charlevoix City, and the City of Petosky
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4 participate in this training, which includes educational information on radiation.
j In addition, five Charlevoix. school bus drivers and the Superintendent for the Charlevoix Public Schools attended an emergency procedures class held at the Charlevoix Public Schools in May 1981.
The class included the presentation of a i
radiation demonstration.
The Licensee participates in the state's program of training of local officials.
I have personally attended 1
numerous training courses conducted by the state for local officials.
The most extensive course was held August 27, l
1979, for twenty-four city and county officials from Charle-voix, Boyne City, and East Jordan.
This training included a nuclear power plant incident scenario and a lengthy discussion of radiation effects including thyroid uptake of radioactive iodine.
t I participated in a training course in the fall of 1979, for approximately eighty-five members of the state police, emergency services personnel,'and local officials.
My discussion concerned radiation effects and various responsi-bilities of the Licensee as outlined in the Plant Emergency l
Plan.
Since then, I have attended approximately six " table top" training courses conducted by the state for local offi-cials and, as I recall, each course contained a discussion of i
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, radiation.
Additionally, I attend about five luncheon meet-ings annually with local officials (usually local emergency preparedness officials) where we discuss mutual interest, common problems, solutions, and radiation items such as estimates of dose projections off-site.
In addition to the Licensee's training program and its cooperation with the state's training program, the Licen-see offers tours of the Big Rock Plant and lectures conducted by Big Rock Plant personnel to interested persons and organiza-tions.
Participants in tours and lectures very often include local and school officials.
The lectures and tours routinely include a discussion of the effects of radiation exposure.
Discussion of radiation and radiation effects given to tour groups are normally presented by me personally or by a member of my staff.
This presentation discusses background radiation and a breakdown ~of that radiation into its respec-tive parts and place of origin, means of adding to the annual l
l radiation exposure by medical x-rays, the biological effects of ionizing radiations, Federal law setting maximum radiation 1
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exposures for plant workmen and the general population, and a 1
demonstration of radioactivity versus radioactive contamina-tion.
Participants in such tours and lectures have included, i
l but have not been limited to, the following local and school
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officials:
eight members of the Charlevoix County Board of l
=.
Commissioners (March 1981); seven members of the Emmet County Board of Commissioners (June 1981); fourteen members of the Emmet County Emergency Operating Center, which included several school officials (June 1980); thirteen members of the Charlevoix County Emergency Preparedness Team, which also included several school officials (April 1980); the Charlevoix School Superintendent and three of his staff members (January 1980); officials of Hayes Township (September 1981); the Mayor, City Manager, and Public Works Director of Petosky (February 1981); five members of the Charlevoix City Council (April 1980); and the City Manager of Charlevoix (November 1981).
In addition, numerous civic organizations, such as women's clubs and the Chamber of Commerce, grade school and high school science classes, and interested individuals have participated in the tours and lectures.
A special NRC appraisal team reviewed the Emergency Preparedness Program at Big Rock Point, November 30 to Decem-ber 10, 1981.
Their review was based on the NRC's Emergency Preparedness Appraisal Program which was formulated to assure that the guidelines of NUREG-0654 are met.
Thus, the apprai-sal program requires Licensee training programs to contain provisions for training the various off-site agencies.
The appraisal program specifies that these off-site agencies "will include the orotective action decision making, local s
ambulance / rescue services, the off-site medical treatment facility, local fire companies and local emergency planning personnel."
Further, the Appraisal Program provides: "The
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purpose of the training should be to ensure mutual under-standing of roles, procedures, and interfaces."
This area of training was reviewed by the NRC Appraisal Team.
Their conclusions are found in the NRC Emergency Preparedness Appraisal' Report (Attachment 2) and, in regard to training programs, the NRC did not indicate any criticism.
In my opinion, the. education of local and school officials in the problems of radiation exposure is completely adequate.
This opinion is based on the training program provided by the Big Rock Point Site Emergency Plan and Imple-menting Procedures, the actual implementation of that training program, and my knowledge of and participation in the state and counties' training programs under their emergency plans.
Subcontention (4):
Applicant should be required to l
assist persons without vehicles l
to leave the area during an emergency evacuation.
Response
According to Michigan law, the emergency evacuation of a population with or without vehicle transportation is j
. primarily the responsibility of State and local officials.
Under 10 C.F.R. Part 50, the primary responsibility of the Licensee during emergency situations is to assess the emergency situation, notify the state and local authorities, and maintain the plant in a safe condition.
The Charlevoix County Emergency Operations Plan at page 148 provides that the Plant will make the initial classi-fication of the incident and that subsequent evaluation and possible reclassification will be made by the Michigan Depart-ment of Public Health.
The plant is to provide the initial recommendations for protective actions.
Based on the recom-mendation of the Plant and the Public Health Department, the Chairperson of the County Board of Commissioners is to take action to implement the necessary protective actions.
There-fore, under the Charlevoix County Plan, it clearly is the responsibility of local officials to provide transportation for hardship cases if evacuation is required.
The Letters of Agreement contained in Appendix A to the Big Rock Point Site Emergency Plan further document the division of emergency responsibilities between the counties, the state, and the Licensee.
This appendix contains all Letters of Agreement State'and Federal officials.
The Letter of Agreement between Consumers Power and Charlevoix County is to this testimony.
This letter was signed by G.
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. T.
Lasater, Sheriff for Charlevoix County.
The Agreement clearly defines the responsibility of the Sheriff's Depart-ment, which includes "the evacuation of residents".
A similar Agreement has been signed by the Emmet County Sheriff on behalf of Emmet County.
In reference to a June 4, 1981, meeting between Christa-Maria, representatives of Consumers Power, and local and state officials, Intervenors stated in their testimony that the Licensee refused to participate in the planning of evacuation for persons needing transportation, over the objections of county officials.
Testimony of Christa-Maria, at 9.
I attended that meeting, and I believe that Christa-Maria has mischaracterized the situation.
The local and state officials did not present a request that we participate in any evacuation plan.
Only Christa-Maria made a demand that we assist persons without vehicles to leave the area during an emergency evacuation.
We denied her demand based on the clear division of responsibiltiies under the emergency plans.
There was no objection from the local and state officials present.
During the short discussion on this topic, the local officials appeared to me to be aware of their responsibilities.
I personally have discussed our respective responsibilities concerning emergency situations with local officials on several other occasions and to the best of my knowledge, the
- local officials have consistently demonstrated a knowledge and acceptance of their responsibility.
In summary, it is the clear responsibility of state and local officials to provide assistance to persons without vehicles during an emergency evacuation based on Michigan law, and state and local emergency plans.
In my opinion, county and local officials are capable of fulfilling this responsi-bility, based on my several years of working with these groups.
Subcontention (5):
A current list of invalids should be kept so that they can be assisted in time of emergency.
Response
A list of invalids who require assistance in time of emergency is maintained by the Sheriff's Department.
The Charlevoix County Plan at page 187 requires that upon warning of an incident at Big Rock, the Sheriff vill take actions which include the following:
Coordinate.the warning of persons with special situations, such as the elderly, handicappers, etc.
with the Sheriff and the County Health Depart-ment.
The maintenance of a list of invalids is the responsibility of the County Sheriff.
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- In keeping with his duty to maintain a list of invalids, the Charlevoix County Sheriff has made announcements on several local radio stations on numerous occasions request-ing invalids or people without transportation to contact his office to have the caller's name and address added to the list l
of persons requiring assistance in case of evacuation.
This same announcement was published in the local newspapers (Petoskey News and Charlevoix Press) on more than one occa-sion.
In addition, it is my understanding that Licensee's new emergency planning pamphlet being prepared in cooperation with local officials will contain a mail-in card soliciting this needed information for the Sheriff.
To the best of my knowl-edge, the Sheriff's list of invalids is current.
l Subcontention (6) :
(
Applicant should comply with regulations requiring adequate radiation monitoring.
Response
l Although the testimony of Christa-Maria does not l
refer to any specific aspect of radiation monitoring, I am assuming that the High Range Noble Gas Effluent Monitor and the Containment High Range Gamma Monitors are the subject of this subcontention, since they are the relevant radiation monitors for emergency planning purposes.
s
, The Big Rock Point Plant has had a Noble Gas Efflu-ent Monitor in operation'since plant start-up in 1962.
Events at Three Mile Island caused the NRC and Consumers Power to reevaluate the adequacy of effluent monitors.
As a result, an interim High Range Noble Gas Effluent Monitor was installed in January 1980.
NRC guidance requires that the " interim" effluent monitor be replaced with a permanent effluent monitor.
Consumers Power requested a delay in the date by which such a monitor must be installed due to difficulty in purchasing the necessary equipment.
Delivery date is expected to be June 15, 1982, with set-up, calibration and in-service shortly there-after.
The NRC has accepted this postponement as long as the interim High Range Noble Gas Monitor remains in operation.
The High Range Containment Gamma Monitors were installed as an interim measure in January, 1980.
These monitors were replaced with permanent monitors to comply with the guidance of NUREG-0737 and have been in operation since April, 1982.
The monitors were calibrated at the vendor's
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calibration facility over their entire range and are certified to remain in calibration for eighteen months.
These monitors will te calibrated at the annual refueling and maintenance l
outage.
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- In summary, Big Rock Plant has employed High Range Containment Monitors and a High Range Noble Gas Effluent Monitor since January 1980.
Also at that time, the Licensee added appropriate procedures to its Site Emergency Plan Implementing Procedures for use during emergency situations.
The High Range Noble Gas Effluent Monitoring procedures detail the method of obtaining release rates on the basis of monitor readouts.
Public protective actions have been formulated on the basis of off-site doses which are projected from the indications of the radiation. monitors and conservative dose calculations.
In addition, the Site Emergency Plan requires the radiation protection technicians to go off-site and monitor the actual activity from the release to determine the extent of the release and the area in which the doses are the greatest.
The combination of the existing monitors (High Range Containment Gamma Monitors and High Range Noble Gas Effluent Monitor), conservative calculational techniques, and actual off-site determination of the dose assure that the health and safety of the public are protected.
The NRC reviewed these monitors as part of its Emergency Preparedness Appraisal and their report did not indicate any criticism.
In addition, the Site Emergency Plan I
and Implementing Procedures, which establish the methods and procedures for calculating off-site doses and determining the l
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proper protective actions for the public, have been tested on two (2) separate occasions.
The NRC and FEMA jointly conduc-ted emergency preparedness exercises in June 1980, and April 1982.
Both large scale exercises were deemed satisfactory by the NRC and FEMA.
Subcontention (7):
Applicant's emergency plan should be revised so that it relies only on people who exist and have been properly identi-fied and so that there will be adequate coordination among responsible personnel.
Response
A review of the Intervenors' testimony (page 9) and Intervenors' Specification of Changes Required in Emergency Planning Under Christa-Maria Contention No. 9 (page 3) on which the Licensing Board relied in its Memorandum and Order of April 20, 1982 (page 11), indicate that Subcontention 7 should properly be directed to the Administrator of the Charlevoix County Emergency Plan.
All of the points raised by Intervenors relate to deficiencies in the County's plan, not the Licensee's.
However, since the Subcontention, as worded, refers to the Licensee's emergency plan, the following response is given.
The Site Emergency Plan and the Site Emergency Plan Implementing Procedures as found in Volumes 9 and 9A of the l
)
Big Rock Point Manual do rely "only on people who exist and have been properly identified."
Specifically, in March, 1982, I reviewed Section 9.5, Organizational Control of Emergencies,, and found only minor updating necessary.
All positions relied on in the emergency plan have been filled with identified persons who have been trained in their respec-tive emergency functions.
I routinely conduct such a review of the personnel assigned the emergency positions every three months as part of the quarterly updating and verification of telephone numbers which will be needed in the event of an l
emergency.
This quarterly procedure is part of the Site Emergency Plan, and it is found at.Section 9.8.3.3.
Subcontention 7 also raises a question concerning
" adequate coordination among responsible personnel."
Inter-venors Specification of Changes Required in Emergency Planning under Christa-Maria Contention No.
9, filed March 19, 1982, indicates at page 3 that this question relates to the nuclear incident response exercise conducted June 24, 1980.
This i
exercise was conducted in response to a scenario written by the Licensee which involved a core-melt situation with a l
release of radioactivity off-site of the magnitude to cause a simulated evacuation and in-place sheltering for local resi-dents.
Participants in this exercise included, but were not limited to, the plant emergency teams (on-site and off-site),
4
- the Charlevoix and Petosky County Commissioners, h'ospital and ambulance personnel, the Emmet and Charlevoix County Sheriff's Department, the state police, local newspaper and radio representatives, and a representative of the state governor.
That exercise was observed and evaluated by FEMA.
A copy of the FEMA report of the evaluation and conclusions pertaining to the June 24, 1980 exercise was forwarded to our offices by Peter R. Basolo, Deputy State Director of Emergency Services, for the State of Michigan and is attached as Attachment 5.
As indicated by the cover letter of Patrick H.
McCollough, Chairman of the Regional Advisory Committee of FEMA, the exercise was evaluated using the FEMA-REP-1/NUREG-0654 criteria of January 1980.
The report states that it was the clear opinion of all 16 members of the evaluation panel for the Regional Advisory Committee that the June 24, 1980, exercise was a successful exercise in which the state and local staffs demonstrated a high degree of competence in executing the emergency plan.
Specifically in regard to communication, however, a criticism was registered regarding a lack of communication between the on-scene Emergency Operations Center (EOC) and the Big Rock Point Plant.
On FEMA's recommendation, a dedicated l
line was established between the EOC and the Plant soon after the report was released.
Otherwise, the report commended the l
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. communication, coordination, and cooperation demonstrated during the exercise.
Subcontention 8:
Applicant should have separate emergency plans appropriate for summer and winter.
Response
Intervenors' Specification of Changes, page 4, makes clear that this subcontention is concerned with the difficul-ties of evacuating the area in an emergency situation.
All evacuations, regardless of whether they are caused by an incident at the Plant or a natural occurrence, are under the
' direction and control of state and local officials.
The division of responsibilties has been clearly established previously in my testimony.
Specifically in regard to evacua-tion routes, the Charlevoix County Emergency Plan, at page 9, provides that the engineer of the County Road Commission has year-round responsibility to maintain roads, streets, and bridges, to coordinate damage assessment of streets, roads, and utility systems, to provide traff,ic control materials, barricades, routing signs, etc., to assist in traffic movement and control, to store fuel for vehicle use, and to maintain designated routes to shelters in Charlevoix County.
In addition, the Licensee has a Letter of Agreement from the Charlevoix County ' Road Commission under which the County has 9
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n agreed to assume responsibility for providing emergency transportation for supplies as requested by the County Emergency Operating Center during a declared emergency or disaster.
The Letter of Agreement further specifies that this responsibility would include assisting Radiological and
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Environmental Monitoring teams in assessing certain areas in adverse weather conditions.
I do not have sufficient detailed information at hand to explain how these various responsibilities are implemented.
However, I will address the general nature of the Intervenors' concern as it relates to the responsibility of the Licensee in an emergency situation.
As stated pre-viously, the primary responsibility of the Licensee in an emergency situation is to maintain a safe plant shutdown.
The concern thus appears to be whether the Plant will be able to have the personnel on hand to meet this responsibility since adverse weather or congested roads could hamper the transpor-tation of personnel to the site.
The Licensee is capable of meeting this responsibility since a minimum emergency team capable of dealing with all conceivable emergency situations j
is required to be on-site at all times as outlined in Section l
9.3 of the Site Emergency Plan.
Section 9.5, Organization Control of Emergencies, states that the initial phase of any emergency will involve a i
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relatively small number of individuals, and these individuals must have the capabilities to (1) determine that an emergency exists, (2) provide initial classification and assessment, (3) promptly notify other personnel and cognizant groups that an emergency exists.
During off-normal work hours (other than day shift), the Plant is staffed with a Shift Supervisor, two (2) Control Room Operatc s, one (1) Shift Technical Advisor, two (2) Auxiliary Operators, and one (1) Chemical and Radia-tion Protection Technician.
This team is qualified to com-plete items 1 - 3 above, including notification of Plant Emergency Teams not on site.
We have conducted studies to determine the time required for Emergency Teams to drive from their home to the plant during off-normal hours.
Approximately 86% of the time requirements specified in Table B-1 of NUREG-0654 were met in l
the first drill, and 100% were met in the second drill.
These drills were conducted in the summer.
Winter drills will be scheduled pursuant to an oral agreement with the NRC Appraisal Inspection Team.
The Big Rock Point Site Emergency Plan Implementing Procedures authorize the Site Emergency Director to direct an evacuation of all nonessential personnel from the site if radiation levels exceed 100 millirems per hour.
Evacuation off-site is easily accomplished during the summer months.
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'. paved road leads from the Plant to the highway.
Snow removal equipment is maintained on-site by the Licensee during the winter months.
Thus, should an evacuation be directed, the Licensee is fully capable of carrying out the evacuation of its own personnel.
General
Conclusion:
The Site Emergency Plan and Implementing Procedures were written to meet the requirements and recommendations of Federal law, namely, 10 C.F.R.
Section 50.34, Appendix E to 10 C.F.R. Part 50, NUREG-0654, and other documents.
The Plan and.
associated procedures have been established to cope with the various types of emergencies in an orderly and effective manner.
The Plan establishes the concepts, evaluations and assessment criteria, and protective actions that are necessary to mitigate the consequences of the four classes of emergen-cies defined by the NRC Staff in NUREG-0654.
The primary objective of the Plan is to provide the necessary prearrange-ments, directions and organizations so that all plant emer-gencies can be effectively resolved in order to safeguard plant personnel and the general public.
As already discussed, the NRC has conducted a special appraisal of the Emergency Preparedness Program at the
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Big Rock Point Nuclear Plant.
The objective of the appraisal was to " evaluate the overall adequacy and effectiveness of emergency preparedness and to identify areas of weakness that need to be strengthened."
The NRC Appraisal report (Attach-ment 2) states:
"During their review, it was noted by the inspectors that significant improvements have been made in the Emergency Preparedness Program at the Big Rock Point Nuclear Plant.
However, deficiencies still exist in the Program."
The NRC deemed several "significant improvements" to be necessary, as found in Appendices A, B,,and C to the Appraisal report.
Despite the NRC's recognition that an explicit regulatory requirement pertaining to each item identified in Appendices A, B, and C may not currently exist, we were requested to submit a written statement within thi'rty (30) days describing planned actions for improving each of the items identified in Appendix A and the results of our consi-deration of each of the items in Appendix B.
l hereto contains our responses to the NRC request.
We met all commitment dates established in Appendix A to the Appraisal l
Report.
t In summary, Plant Manual Volumes 9, Site Emergency l
Plan, and 9A, Site Emergency Plan Implementing Procedures, meet all Federal Regulations pertaining to emergency prepared-ness.
FEMA and the NRC are of the opinion that the Big Rock l
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i Point' Nuclear Plant Emergency Preparedness Program will safeguard plant personnel and the general public in an acci-dent situation.
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