ML20126E464

Responds to NRC Re Violations Noted in IE Insp Rept 50-155/77-04.Corrective Actions:Currently Evaluating Independent Decontamination Area for Emergency Use. Necessary Procedures Will Be Implemented by 770701

ML20126E464
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	05/11/1977
From:	Bixel D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20126E463	List: IR 05000155/1977004 ML20126E464
References
NUDOCS 8101280126
Download: ML20126E464 (3)

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u ... 4 ... q Genorni Offices: 212 Wof.t Michigan Avenue, Jac kson, Michignn 4D201 e Area Codo S17 78ft-05SO May 11, 1977 Mr James G Keppler US Uuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 6013T DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLA:'T - RES?OUSE TO IE REPORT 050-155/TT-Oh By letter dated April 19, 1977, Consumers Power Company was requested to respond to certain items addressed in IE Inspection Report 050-155/77-04. The purpose of ',his letter is to provide the requested re.sponses.

Item a

"A facility change for ventilation patterns in the access control area, decon-tamination area and laundry room has not been completed."

Response

The facility change referred to above was determined to require major modifica-tions to the plant ventilation system and not cost effective. The ventilation pattern for these areas is adequate for normal plant operations and, in fact, has been adequate for all applications in the history of the plant. However, should a cevere personnel decontamination problem arise, the ventilaticn pat-terns could present a problem in terms of the potential spread of airborne activity. Therefore, Consumers Power Company is currently evaluating the establishment of an independent decontamination area to be used in the event of such an emergency. This ar m will be equipped with the necessary equipment for personnel decontamination, and vill be in an area of adequate ventilation.

The evaluation vill be complete and necessary procedures implemented by July 1, 1977 Item "The license is in the process of completing a study to determine radiation )

shine dose from the containment sphere and containment penetration leakage which i approximates a ground release in order to deterrine the isopleths necessary in

[ the Site Daercency Plan.

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"Neither the EPA nor the State of Michigan Portective Action Guides for consid- i eration of action levels have been incorporated into the Site Emergency Plan." l l

Resuonse The Big Rock Point Final Hazards Summary Report, Section 13, establishes off-site whole body and thyroid infinite time doses to be 0.6 Rem and h Rem, respectively, for the postulated MHA, 10% core meltdown. Since these projected doses are small relative to both 10 CFR 100 limits and State action guides, the investiga .

tion into the need for additional decisional aids had, in the past, been given a low priority. The study referred to in past inspection reports has concentrated on the determination of radiation levels within the plant due to direct shine since the in-plant levels are substantially more significant than the off-site doses. This study still requires considerable effort but vill be completed by the end of the year. However, the portion of the study involving off-site dose assessment will be completed by mid-August 1977 At that time Consumers Power Company vill submit to the Commission the results of the study. Also at that time, the State of Michigan Emergency Classification Guide vill be incorporated into the Site Emergency Plan. The State Classification Guide is based upon the EPA Protective Action Guidance, and utilises event classifications consistent i with the State's overall emergency response plan. Since the largest portion of our contact during a plant emergency vould be with State and local support agen-cies , and since the State, rather than Consumers Power Company, determines the need for, and implements, off-site protective actions according to State require-( ments, it is prudent that the State Guides, rather than EPA Guides, be provided in the Big Rock Point Site Emergency Plan and, therefore, any changes vill be made accordingly.

In recognition of the increased complexities of radiological emergency plan in-plementation and training, Consumers Pcier Company hired, as of May 1, 1977, an individual with an extensive background in emergency services. The sole respon-sibility of this supervisor vill be to ensure adequacy of procedures, training and coordination rela +1ve to Site Emergency Plans and Procedures. We anticipate that this addition to the General Office staff vill assist in expediting comple-tion of the emergency plan items remaining open with regard to Big Rock Point.

There is one further item pertaining to IE Report 77-Oh that Consumers' Power Company would like to address at this time. This concerns the conformatory measurements, specifically Item 5.c. One portion of this item states: "The analytical contractor failed to properly quantify Sr-89. . . .No explanation was available for the disagreement reported by the analytical contractor."

Investigation into this matter revealed that the reported value had not been decayed correctly. The reported value represented the concentration as of December 31, 1976 while the NRC values represented an r etober 1, 1976 analysis.

Decay correcting the contractor's Sr-89 value to October 1 gives a concentration

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of (5 3 1.0) x 10 ' uCi/ml. This concentration agrees with the'IGC value of

( h.9.1 0.15) x' 10-3 pCi/nl. Therefore, the overall results of the conformatory measurements improves to 31% agreements or possible agreements and 19% disagree-ments.

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