ML20058C153
| ML20058C153 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 04/30/1982 |
| From: | Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20058C142 | List: |
| References | |
| NUDOCS 8207260278 | |
| Download: ML20058C153 (5) | |
Text
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["&PT E&TI General offices: 1945 West Parnall Road, Jackson, MI 49201 * (517) 788 0550 7pgg 71)g April 30, 1982 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - RESPONSE TO APPENDIX C OF IE INSPECTION REPORT 81-17 NRC IE Inspection Report 81-17, dated January 28, 1982 and entitled " Emergency Preparedness Appraisal," directed Consumers Power Company to respond to the items of Appendices A (Significant Appraisal Deficiencies) and B (Preparedness Improvement Items) and the comments of Appendix C (Emergency Preparedness Evaluation Report). By letted dated February 26, 1982, Consumers Power Company provided its responses to Appendices A and B.
It is the intent of this letter to provide Consumers Power Company's response to the comments of Appendix C.
Consumers Power Company will submit a revision of the Big Rock Point Plant Site Emergency Plan which will incorporate the responses contained in this letter during August 1982.
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b David J'vandeWalle Nuclear Licensing Administrator CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector-Big Rock Point Attachment 8207260278 820720 PDR ADOCK 05000155 G
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i RESPONSES TO APPENDIX C 0F JANUARY 28, 1982 NRC LETTER,
" EMERGENCY PREPAREDNESS APPRAISAL" i
Comment A: Assignment of Responsibility
Response
i Consumers Power Company letters of January 11, 1982 and April 1,.
1982 stated that a Security Officer will be assigned as the on-shift communicator. This shall be implemented by July 1, 1982 and the Site Emergency Plan Implementing Procedures (EPIP) will be revised at that time to reflect this change.
i Letters of Agreement I
Response
All letters of agreement or contracts with State and local agencies as well as with contractors will be included in the Big Rock Point Plant Site Emergency Plan. The revisions to this Plan, including letters of agreement, will be submitted to the NRC in August 1982.
Comment B: Onsite Emergency Organization I
1.
Specify the conditions required for transfer of Emergency Director responsibilities (Volume 9, 9.5.2.1).
Response
T The purpose of the Site Emergency Plan (Volume 9) is to delin-eate the responsibilities of the various emergency organiza-
[
tions involved and provide general guidance of coping with i
emergencies. The actual mechanics of establishing the various response centers is described in the onsite and offsite imple-menting procedures. Furthermore, the Site Emergency Director does not relinquish his responsibilities except for some of the communications functions. Again, the details of the com-munications transfer belong in the onsite and offsite imple-i menting procedures.
No changes will be made to the Site Emergency Plan. The Site Emergency Plan Implementing Procedures and the General Office Nuclear Emergency Implementing Procedures will be reviewed and revisions made as appropriate by July 1, 1982.
2.
Specify how minimum shift staffing requirements of the cri-i teria will be established. 'Specifically, indicate how augmen-tation will be ensured.
Indicate that unannounced drills will i
be conducted, documenting the response achieved. These drills should be conducted during off-normal hours.
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Response
The purpose of the Site Emergency Plan (Volume 9) is to pro-vide general guidance for emergency actions. The Site Emergency Plan Implementing Procedures (Volume 9A) contains call-in checklists which comply with NUREG-0654, Table B-1, guidelines. Volume 9 will be revised to include a commitment to Table B-1 augmentation as applied to Big Rock Point.
Volume 9A will be revised as necessary to include drills dem-onstrating Table B-1 augmentation. These revisions will be submitted to the NRC in August 1982.
3.
Specify how the following emergency functions will be imple-mented 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day:
a.
In-Plant sample collection and analysis b.
In-Plant monitoring c.
Out-of-Plant monitoring d.
Decontamination e.
First aid / rescue
Response
These emergency functions will be performed by Chemical and Radiation Protection Technicians who are part of the onsite emergency response organization. Their duties are defined in the Site Emergency Plan Implementing Procedures, EPIP-2, EPIP-4J, EPIP-4M and EPIP-4AA. These procedures are consid-ered adequate.
L.
Indicate in the plan that a trained dedicated individual, not the Shift Supervisor, will be available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day for performing communication functions.
Response
See Response to Comment A, " Assignment of Responsibility."
Comment C: Emergency Response Support and Resources
Response
Revisions to the Site Emergency Plan, to be submitted in August 1982 will specify each Federal resource relied upon and the support required by the licensee, State and local governments.
These revisions will identify supporting radiological laboratories and their general capabilities and availabilities, oc0482-0646b-43-142
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Comment D: Emergency Classification System
Response
The Emergency Classification System has undergone a complete revision as a result of the Big Rock Point Emergency Preparedness Appraisal, dated January 28, 1982, Appendix A, Item 3.
The Site Emergency Plan, Volume 9, Appendix M, will be revised to reflect this change and this rerrisions will be submitted in August 1982.
Comment E: Notification Methods and Procedures
Response
As stated in Consumers Power Company letter dated February 4, 1982 a public warning system was installed and declared operational by January 28, 1982. A copy of the Public Warning System Policies and Procedures will be submitted with revisions to the Site Emergency Plan in August 1982.
Comment G:
Public Education and Information
Response
The methods to be used for rumor control are defined in the section describing the Joint Public Information Center of Consumers Power Company's Nuclear Plant Emergency Public Information Policies and Procedures.
Emergency Facilities and Equipment
Response
The types and location of equipment, including communications equipment, in the Technical Support Center (TSC) and Emergency Operations Facility (EOF) are provided in Section 3A of the EPIP.
This section will be revised to reflect the aquisition of addi-tional equipment that has been ordered.
Comment I: Accident Assessment
Response
Big Rock Point is currently installing a new meteorological system in response to the Emergency Preparedness Appraisal, dated Janu-ary 28, 1982, Appendix A, Item (1). This project is expected to be completed by May 15, 1982. Upon completion of this project, the Site Emergency Plan and the Site Emergency Plan Implementing Procedures will be reviewed and revised as necessary.
The EPIP revisions will be completed by July 1, 1982 and revisions to the Site Emergency Plan will be submitted in August 1982.
oc0482-0646b-43-142
4 Comment J: Protective Response
Response
Upon sounding of the emergency siren, a Security Officer is dispatched to check the beach for fisherman and other beach users.
This action is required by EPIP-R, EPIP-S and EPIP-T. This method of advising beach users is considered adequate. Furthe rmere,
these actions need not be included in the Site Emergency Plan, Volume 9, due to its general nature (see Response to Comment B).
No further actions will be taken.
Comment L: Medical Support and Public Health
Response
Appendix K of the Site Emergency Plan, Volume 9, specifies those persons responsible for making the decision regarding the seriously onsite injured.
The training received by hospital, emergency squad and ambulance personnel regarding the handling of contaminated patients is described in Section 6I of the EPIP. The identification of an instructor and his qualifications will be included in a revision to the EPIP, scheduled to be completed by July 1, 1982.
Comment P: Responsibility for Planning Effort
Response
A cross-referenced index to NUREG-0654 criteria will be included in the revision to the Site Emergency Plan to be submitted in August 1982.
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