ML20072S570

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Forwards Citizens for Employment & Energy Concerns Re Draft of Proposed Nuclear Facility App to Monroe County Emergency Operations Plan. NRR Requested to Leave Investigation Open Until County Approves Plan
ML20072S570
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 04/01/1983
From: Minock J
CITIZENS FOR ENERGY & EMPLOYMENT, MINOCK, J.
To: Harold Denton
Office of Nuclear Reactor Regulation
Shared Package
ML20072S573 List:
References
NUDOCS 8304070242
Download: ML20072S570 (6)


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LAW OFFICES JOHN R. M INOC K J 1500 BUllL BUILDING DETROIT, MICilICAN 48226

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(313) 963-1700 April 1, 1983 Mr. Harold R. Denton Office of Nuclear Reactor Regulation Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Denton:

Enclosed is documentation of the concerns of Citizens For Employment and Energy (CEE) regarding the evacuation plans in the event of an accident at Detroit Edison's Enrico Fermi Atomic Power Plant, Unit II, in Monroe, Michigan. This information is to be considered in your investigation, under 10 CFR 2.206, of the emergency planning issues raised by the County and CEE. You suggested that this information be submitted to your office at this time so that FEMA could in-clude consideration of it in their May 1, 1983, report addressing the issues the County and CEE raised concerning the adequacy of offsite emergency planning.

The enclosed information evaluates the proposed draft of the Nuclear Facility Procedures Appendix to the Monroe County Emergency Operations Plan. That plan is only in draft form, because Monroe County has never approved or adopted it. The draft consists of the " Basic Plan" outlining the overall response to a radiological emergency and twelve annexes de-tailing the various actions necessary. We believe that the draft. plan is severely inadequate and cannot protect the health, safety, and welfare of the citizens of the surrounding area.

In addition, a closer look at the plan reveals that the County does not have the resources to implement the plan as written.

Monroe County's limited resources with which to respond to such an emergency have led the responsible County officials to seriously question its draft of the proposed plan and the County's ability to protect the people within the ten mile EPZ surrounding Fermi II. Recently, some revisions were made in the Basic Plan shifting responsibilities from local govern-ment to State and/or Federal authorities. There has not yet been a response on those changes from the State or Federal levels. The County is convinced that the entire plan needs to be restructured, but they will not pursue that task until the State agrees to the shift of certain responsibilities.

8304070242 830401 PDR ADOCK 05000341 F PDR

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- AprilL l',- 1983 L Harold R.rDenton

[ page two Mr. Jon R. Eckert, Director of the Monroe County Office

of Civil Preparedness. stated in a letter to Mr. Arden T. Westover, Sr.,' Chairman of the Monroe County Board of Commissioners, dated

~ March 18, 1983, that:

i- If and when the State of Michigan agrees to the' revisions of the " Basic Plan" the Office ,

_ of Civil. Preparedness will at that time meet with:all: department heads and' restructure the

, following annexes: . Direction _and Control, i= Warning, Communications, Radiological Defense, Police Services, Fire Services, Health / Medical, ,

, Public Services, Social Services, and School I Services.

(See enclosed letter ~from Mr. Eckert to Mr. Westover and enclosed

. -letter'from'the County to the Michigan State Police.)

These annexes need' restructuring and there is need to research the possibility of adequately implementing the annexes  ;

, once they have been' restructured. In addition, the Damage p Assessment and Public Information~ annexes need reconsideration.

The_ enclosed critique focuses on_some of_the shortcomings

._of the draft Basic Plan and then reviews the shortcomings of

'the annexes themselves.. Each-annex establishesLthe process by ,

which an evacuation would be carried out.

As Mr. Eckert states in his March 18, 1983, letter to Mr.

Westover,' Monroe County realizes.the need to revise the draft.

l The' letter also makes it clear that.this process could take

many; months. As the County-involves itself in revising the

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! plan during the coming months, we will continue to evaluate the changes.- We therefore request the right to forward to f ,your_ office. relevant information: generated by that process.

As you stated- in-your response'to the Monroe County 2.206

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petition,-the emergency planning ~ issues must be resolved prior.to the Commission's' decision on whether to authorize a Lfull power license. Clearly.those concerns will not be resolved until-there is a plan approved by the County which is proved to

' fully. implementable. We request'that your investigation of these matters remain open.until then.

Sincerely,

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cc:,. Karen Cyr-L-

ohn R. Minock fhff Attorney for CEE

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Monroe City-County Office of Civil Preparedness MONROE COUNTY COURTHOUSE 106 E. FIRST STREET TELEPHONE (313) 2416400 MONROE MICHIGAN 49161 2 'Cc,mmunity Teamwork JON R. ECKERT for Survival" DIRECTOR JOHN K. STOUT ASSISTANT DIRECTOq l

March 18, 1983 Mr. Arden T. Westover, Sr.

Chairman, Monroe County Board of Conunissioners 106 E. First Street Monroe, Michigan 48161

Dear Chairman Westover:

Attached are recommended changes to the " Appendix I, Nuclear Facility Procedures, to the Basic Plan." As per our agreement with the Federal Emergency Management Agency. and the State of Michigan at the meeting held in Battle Creek, Michigan on Tuesday, March 1,1983. We aorced to prepare a draft of the "Apoendix I, Nuclear Facility Procedures to the Basic Plan" to present to the State of Michigan for review and hopefully their consensus. .

At this time I would recornnend to the Board the adoption of the attached changes and authorize the Office of Civil Preparedness to submit them to the Michigan State Police / Emergency Manaaement Division for their review and approval. '

If and when the State of Michigan agrees to the revisions of the " Basic Plan" the Office of Civil Preparedness will at that time meet with all department heads and restructure the following annexes: Direction and Control, Warning, Communications, Radiolooical Defense, Police Services, Fire Services, Health / Medical, Public Services, Social Services and School Services'. .

I will be happy to attempt to answer any questions you may have in reaard to the recommended changes.

. ocerely,

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Jon R. Eckert

. Di rector / Coordinator Office of Civil Preparedness JRE

BOARD DF C MMISSIONERS MONRO UN . , . ICHIGAN g.

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Lt. James Tyler Michigan State Police /

Emergency Management Division 111 S. Capitol Avenue Lansing, MI 48913

Dear Lt. Tyler:

As per our agreement on March 1,1983 at Battle Creek, Michican, the County of Monroe agreed to rewrite the "llppendix I, Nuclear Facility Procedures, to the Basic Plan" and present it to you and your denart-ment for review and approval.

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The l'.onroe County Board of Commissioners has reviewed and aporoved the attached changes. Monroe County can only accept the Board's approved revisions, as we do not have the personnel and/or the re-sources to fulfill the original draft. If I can be of any further assistance please feel free to call me or contact the Monroe City-County Office of Civil Preparedness.

Sincerely, i

Arden T. Westover, Sr.

Chairman, Monroe County Board of Commissioners ATW/jrm Attachment cc: Governor James Blanchard Honorable John Dingell Honorable Carl Levin

- Honorable Donald Riegle, Jr.

John Anderson, Region V, FEMA Director Rick Anthony, FEMA - Battle Creek Dan Bement, FEMA - Battle Creek l

Col. Gerald Hough, MSP/EMD Director Capt. Peter R. Basolo, MSP/EMD Deputy Director I

    • Recomended Changes to the " Appendix I, (Nuclear Facility Procedures) to the Basic Plan".

BP"1-4 2. In- the event of a nuclear incident where offsite effects occur, or there is the imminent threat therof or at the alert level as soecified in the Monroe County Emergency Response Plan for the activation of the County Emergency Operating Center, The Governor will declare a " State of Disaster" pursuant to Act 390, Public Acts 1976. The Richigan Emeroency Preparedness Plan will be activated by this action along with the local plans, if not already activated. Once a state of disaster is delcared, compensation and liabilities will be resolved according to the statutory authority contained within the act.

BP 1-7 VI. B. Radiological Monitoring

1. Initially, monitoring will be done by the Plant. As soon as the County Emergency Operating Center is activated, the Radiological Defense Of ficer shall appoint trained personnel to accompany each plant monitoring team and transmit data to the County Emergency Operations Center and the State Emergency Operations Center for plotting. Plotting will project plume direction and will show the area affected. The plottino will be corrdinated in the County E.0.C. by the Radiological Defense Officer in accordance with. the Radiological Defense Appendix. The affected area will be detennined according to wind direction, atmospheric conditions and the type of release.

BP 1-8 D. Evacuation

1. Off-site monitoring and sampling will be necessary to determine any changes in the plume. Plant Personnel will assume this responsibility in Monroe County until the Michigan Department of Public Health monitoring teams arrive. The Monroe County Radiological Defense Officer will assian a liaison to the Plant monitoring teams and the Michigan Department of Public Health monitorino teams to assure County E.O.C. personnel adeouate and timely infonnation for necessary decision making purposes. The Radiological Defense Appendiz describes monitorino capabilities. Initially, the Plant and County RADEF liaison and later the Michigan Denartment of Public Health and County RADEF liaison will provide the radiological monitoring for the County.

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2. The Michigan Department of Public Health will be responsible for radiological monitoring at the decontamination centers and congregate care facilities with assistance as may be necessary, from county radiological defense personnel l BP 1-9 F. Emergency Worker Exposure Control
1. The Monroe County Radiological Defense Office is responsible for maintaining a record of exposure for all county and local municipality officials and volunteers involved in the emergency response and an estimated record of e exposure for the populace.

BP 1-10 H. Food or Water Contamination

1. Upon notification of an incident that may cause food product and/or water contamination, the Civil Preparedness Director / Coordinator will follow the recomendations of State Officials in alerting users of the affected food and/or water. Appropriate protective measures will be taken in-cluding intensive sampling by the Michigan Department of Public Health and the County RADEF personnel to determine what further actions may be' needed.

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Recommended Changes Page: 2 BP 1-10 I. Reentry and Recovery

3. ' Local Government is responsible for reentry and recovery. Tasks reouired during this period include:

(A) Scheduling, controllino and coordinating reentry based on recommendations of the Michigan State Police / Emergency Management Division.

=(B) Preparing a summary report of the emergency with recormendations for

~ further actions and information to the local " Emergency Operations Plan".

4. State and/or Federal Government is responsible for the recovery of an reentry into areas evacuated and/or contaminated due to an off-site release. They will receive advice and assistance from the Michigan Department of Public Health and coordinate the recovery and reentry through the Chairman of the

. Monroe ' County Board of Commissioners and the County E.0.C. Tasks required during-this period include:

A. Decontamination of people, property and food.

B. Continued security of evacuated areas to prevent unauthorized ent'y.r and vandalism.

C. ' Health and Medical Services f6r evacuees.

D. Mass ' Care and Welfare.

E. Monitoring of people and property.

F. - Transporation.

G. Radioactive waste disposal.

H. Engineering Support.

I. Long-term monitoring.

BP 1-12 L. Exercise of Plan

1. Monroe County may at the direction of the Chairman and/or the Monroe County Board of Commissioners participate in a major joint Federal, State, County, and Plant Operator exercise prior to the adoption of the " Nuclear Facility Procedures" portion of the Monroe County Emergency Operatio'ns Plan, and thereafter as required. A major exercise will be held prior to operational licensing of.the Enrico Fermi Atomic Power Plant Unit 2.

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