ML20203A844
| ML20203A844 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 02/02/1998 |
| From: | Harris P NRC (Affiliation Not Assigned) |
| To: | Powers K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| TAC-M99688, NUDOCS 9802240126 | |
| Download: ML20203A844 (12) | |
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February 2, 1998 Mr. Kenneth P. Powers .
Plant General Manager Big Rock Nuclear Flant Consumers Energy Company 10269 US-31 North Charlevoix, MI 49720
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION CONCERNING BIG ROCK POINT NUCLEAR PLANT DEFUELED EMERGENCY PLAN (TAC NO. M99688)
Dear Mr. Powers:
We are continuing our review of your proposed changer to your Defueled Emergency Plan as detailed in your letter to us dated September 19,1997. During our review of your submittal, questions have arisen for which we require additionalinformation and clarification. Please provide the responses to the enclosed request for additional information within 30 days of the date of this letter. In accordance with 10 CFR 50.30(b),
. your response must be executed in a signed original under oath or affirmation.
, if you have any questions regarding this review, please contact me at (301) 415-1169.
Sincerely, ORIGINAL SIGNED BY:
Paul W. Harris, Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No. 50-155 4
Enclosure:
f
, As stated i cc w/ enclosure:
See next page . ,,
DISTRIBUTION:
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- s.,...../ February 2, 1998 Mr. Kenneth P. Powers Plant General Manager Big Rock Nuclear Plant Consumers Energy Company 10269 US 31 North Charlevoix, MI 49720
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION CONCERNING BIG ROCK POINT NUCLEAR PLANT DEFUELED EMERGENCY PLAN (TAC NO. M99688)
Dear Mr. Powers:
We are continuing our review of your proposed changes to your Defueled Emergency Plan as detailed in your letter to us dated September 19,1997. During our review of your submittal, questions have arise for which we require additionalinformation and clarification. Please provide the tOnses to the enclosed request for additional information within 30 days of tht, ac,;p of this letter. In accordance with 10 CFR 50.30(b),
your response must be executed in a signed original under oath or affirmation, if you have any questions regarding this review, please contact me at (301) 415-1169.
l Yi Pau'l W. Hdrris, Project Manager Non Power Reactors and Decommissioning Project Directorate i
Division of Reactor Program Management l Office of Nuclear Reactor Regulation l
Docket No. 50-155 i
Enclosure:
As stated
! cc w/ enclosure:
See next page
Mr. Kenneth Powers Big Rock Point Nuclear Plant Docket No. 50155 (PAGE 1 OF 2) cc: -
Mr. Thomas A. McNish, Secretary Lake Michigan Federation Consumors Energy Company ATTN: E. Roemer, Attorney 212 West Michigan Avenue 59 E. Van Buren #2215
- Jackson, Michigan 49201 Chicago, Illinois 60605 Judd L. Bacon, Esquire Ms. Irene Kock Consumers Energy Company Nuclear Awareness Project 212 West Michigan Avenue Box 2331 r Jackson, Michigan 49201 Oshawa, Ontario L1H7V6 7
l Ms. Jane E. Brannon, County Clerk Michigan Department of. Attorney i County Building Annex General 4
203 Antrim Street Special Litigation Division Charlevoix, Michigan 49720 '630 Law Building P.O. Box 30212
! Office of the Governor Lansing, Michigan 48909 l Room 1 Capitol Building j Lansing, Michigan 48913 Mr. Rich Bachus Traverse City Record - Eagle Regional Administrator, Region ll1 7401 Middle Road
- U.S. Nuclear Regulatory Commission Harbor Springs, Michigan 49740
- 801 Warrenville Road i Usle, Illinois 60532-435i Ms. Angela S. Greenman U.S. NRC Region lli Michigan Department of 801 Warrenville Road Environmental Quality Lisle, Illinois 60532
- Drinking Water and Radiological l . Protection Div_ision Ms. Janenne trene Froats
- .3423 N. Martin Luther King Jr. Blvd. P.O. Box 528
- P.O. Box 30630 Petnskey, Michigan - 49770
- Lansing, Michigan 48909 8130 i
Mr. Henry Peters U.S. Nuclear Regulatory Commission . Route 1 Resident inspector Office Ewen, Michigan 49925 Big Rock Point Plant
- 10253 U.S. 31 North Ms. Doris Schaller Charlevoix, Michigan 49720 2310 M 119 Lakeside Condo E
Unit #55 Mr. Robert A. Fenech Petoskey, Michigan 49770 Senior Vice President f Nuclear, Fossil Operations Mr. Michael Winnell
' Consumers Energy Company 3250 Krouse Road
, _ Jackson, Michigan 49201 i Mr. James S. Rang j Ms. Kay Cumbow Consumers Power Company
. _ ,n.. _
y -, , ,_ _ .~. .._.,u , . -. .. , , . . - . , . , . - _.a
k Mr. Kenneth Powers Big Rock Point Nuclear Plant Docket No. 50-155 (PAGE 2 OF 2) cc:
Mr. Brennain Lloyd --
Northwatch l P.O. Box 282 North Bay, Ontario P1B 8H2 Mr. John W. Campbell Executive Director Eastern U.P. Regional Planning.
& Development Commission 524 Ashmun Street P. O. Box 520 Sault Ste. Marie, Michigan 49783 4
Lake Michigan Federation
. Attn: T. Cabala, Director 425 W. Western Avenue
! Muskegon, Michigan 49440 Citizens Awareness Network
,. Box 83 i Shelburne Falls, Massachusetts 01370
- - Jonathan M. Block, Esquire Main Street P.O. Box 566 i Putney. VT 05346-0566 l Ms. Deborah B. Katz, President j Citizens Awareness Network P. O. Box 83 l Shelburne Falls, Massachusetts 01370 0083 Ms. Corinne Carey 2213 River Side Drive NE
- Grand Rapids, MI 49505 i
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ENCLOSURE HEOUEST FOR ADDITIONAL INFORMATION CONCERNING BIG ROCK POINT NUCLEAR PLANT DEFUELED EMERGENCY PLAN The Big Rock Point Defueled Emergency Plan (BRP DEP) was evaluated against the applicable criteria in NUREG 0654, " Criteria for Preparetion and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants." The following information is needed to determine whether the BRP DEP meets these criteria or if other means are provided to meet the regulations for emergency plans contained in 10 CFR 50.47 and Appendix E to 10 CFR Part 50, The requests for additionalinformation are grouped under the applicable NUREG 0654 sections. The licensee may provide the rationale for why the specific criterion is not applicable for BRP in its permanently shutdown state in lieu of justification for how the criterion is met in the plan.
NUREG-0654, Section ll.A, Assignment of Responsibility
- 1. Criterion la under this section statei that "Each plan shall identify the State, local, Federal and private sector organizations (including utilities), that are intended to be part of the overall response organization..."
The BRP DEP did not identify the local organizations that are part of the emergency response. Please modify the BRP DEP to meet this criterion or justify the deviation.
- 2. Criterion 10 under this section states that "Each orgenization shall provide for 24-hour per day emergency response, including 24-hour per day manning of communications links."
The BRP DEP did not specify that 24-hour per day emergency response would be provided. Please modify the BRP DEP to meet this criterion or justify the deviation.
- 3. Criterion 2a under this section states that "Each organization shall specify the functions and responsibilities for major elements and key individuals by title, of emergency response, including the following: Command and Control, Alerting and Notification, Communications, Public Information, Accident Assessment, Public Health and Sanitation, Social Services, Fire and Rescue, Traffic Control, Emergency Medical Services, Law Enforcement, Transportation, Protective Response (including authority to request Federal assistance and to initiate other protective actions), and Radiological Exposure Control."
k 2-A. The BRP DEP also specifies that the minimum backshift staffing will consist of the following personncl who have the following emergency duties.
Site Emergency Director:
- initiate initial actions to bring facility to a stable conditions e classify the event
- make initial notification to NRC, State of Michigan and Consumers Energy Company personnel e augment plant staff
- perform initial dose assessment a perform initial emergency radiological protection activities Security:
- respond to security threats e perform accountability
- assist in evacuation of on site personnel e serve as a Fire Brigade member o provide first aid support The BRP DEP also states that an individual qualified in radiation protection will be on shif t.
Please justify how this number of personnelis sufficient to provide adequate response to an emergency at BRP. Please clarify whether the individual qualified in radiation protection will be someone other than the Site Emergency Director and the security staff member.
B. The BRP DEP states that it will augment the onshift emergency response organization (ERO) with the following personnel.
Radiological Assessor: Responsible for radiation protection, chemistry and dose assessment activities.
Technical Coordinator: Responsible for accident assessment and repair of plant equipment and systems.
Please justify how this number of personnelis sufficient to provide adequate response to an emergency at BRP.
C. The BRP DEP states that radiological monitoring personnel will take measurements and samples as directed. These personnel were not included in ths ERO. Please 1 justify why tt 3rsonnel were not included in the ERO.
- 4. Criterion 3 under this section states that "each plan shallinclude written agreements referring to the concept of operations developed between Federal, State, and local agencies and other support organizations having an emergency response role."
3-The BRP DEP did not include any written agreements. Please modify the BRP DEP to meet this criterion or justify the deviation. Please provide a copy of these written agreernents.
- 5. Criterion 4 under this section states that "each principal organization shall be capable of continuous (24-hour) operations for a protracted period. The individualin the principal organization who will be responsible for assuring continuity of resources (technical, administrative, and material) shall be specified by title."
The BRP DEP did not describe the capability for continuous operations for a protracted period. Please modify the BRP DEP to meet this criterion or justify the deviation.
NUREG-0654, Section ll.B, Onsite Emergency Organization
- 6. Criterion 1 under this section states that "Each licensee shall specify the onsite emergency organization of plant staff personnel for all shifts and its relation to the responsibilities and duties of the normal staff complement."
The BRP DEP did not provide a description of the onsite emergency organization of plant staff personnel for all shifts and its relation to the responsibilities and duties of
, the normal staff complement. Please modify the BRP DEP to meet this criterion or
., justify the deviation, i
- 7. Criterion 5 under this section states that "the licensee must be able to augment on-shift capabilities within a short period of time after declaration of an emergency."
The BRP DEP states that additional parsonnel may be called in at the discretion of the
, Site Emergency Director (SED) to augment on-shift personnel.
Please provide the criteria upon which the SED will make a determination to augment the on-shif t personnel and state the relationship of this criteria to the event classification level. Please provide the time goal for completing augmentation after the i decision '.o augment has been made.
. 8. Criterion 7d under this section states that "[Each licensee shall specify the corpora'e
! _ management, administrative, and technical support personnel who will) release ...
Information to news media during an emergency (coordinated with governmental j _ authorities)."
The BRP DEP identified the person (i.e., Public Aff airs Director) who is responsible for releasing this information, however, it does not identify this position as a part of the ERO. Please justify why the Public Aff airs Director was not included in the ERO.
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- 9. Criterion 9 under this section states that "Each licensee shallidentify the services to be provided by local agencies for handling emergencies, e.g., police, ambulance, medical, hospital, and fire-fighting organizations shall be specified."
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The BRP DEP did not identify the local agencies to provide these services. Please modify the BRP DEP to meet this criterion or justify the deviation.
NUREG 0654, Section ll.C, Emergency Response Support and Resources
- 10. Criterion 1 under this section states that "The Federal government maintains in depth capability to assist licensees, States and local governments through the Federal Radiological Monitoring and Assessment Plan (formerly Radiological Assistance Plan (HAP) and Interagency Radiological Assistance Plan (IRAP). Each State and licensee shall make provisions for incorporating the Federal response capability into its operation plan, including the following:
A. specific persons by title authorized to request Federal assistance;"
The BRP DEP did not specify a person authorized to request Federal assistance. Please modify the BRP DEP to meet this criterion or justify the deviation.
- 11. Criterion 3 of this section states that "Each organization shallidentify radiological laboratories and their general capabilities and expected availability to provide radiological monitoring and analyses services which can be used in an emergency."
The BRP DEP did not identify the available radiologicallaboratory f acilities. Please modify the BRP DEP to meet this criterion or justify the dev!ation.
NUREG-0654, Section ll,D, Emergency Classification System
- 12. Criterion 1 under this section specifies that "An emergency classification and emergency action level scheme as set forth in Appendix 1 must be established by the licensee. The specific instruments, parameters or equipment status shall be shown for establishing each emergency class, in the in-plant emergency procedures. The plan shallidentify the parameter values and eaulpment status for each emergency class."
A. The licensee's plan provided a " list of initiating conditions and the classification levels." but did not provide the specific emergency sctions levels (EALs)', Most of the initiating conditions provided in Appendix I do not apply to a defueled plant; however, the following type of events did not appear to be adequately covered by an initiating condition in the BRP DEP:
e- fuel damage events at an Alert classification level; e loss of fuel pool water level which could or has caused uncovering of fuel (classified at the Alert level);
e fire extinguished within 15 minutes (Unusual Event classification level); and.
' Note: some " initiating conditions" provided in the BRP DEP cppear to be EALs because they include specific setpoints.
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- fire involving radioactive material (Alert classification level).
Please provide the specific emergency actions levels for BRP and describe how the EAL scheme is adequate for classifying any potential event at BRP.
B. One of the BRP initiating condition /EAL was " Unplanned, uncontrolled offluant release to the environment greater than 20 DAC or 20 EC." Please provide the basis for these initiating conditions, in addition, please provide information regarding how these conditions will be detected.
- 13.Section IV.B of Appendix E to 10 CFR Part 50 states that EALs "shall be discussed and agreed on by the applicant and State and local governmental authetities..."
Please provide documentation of discussions and agreements with State and local governmental authorities regarding the BRP EALs.
NUREG-0654, Section ll.E, Notification Methods and Procedures
- 14. Criterion 1 under this section states that "Each organization shall establish procedures which describe mutually agreeable bases for notification of response organizations consistent with the emergency classification and action level scheme set forth in Appendix 1. These procedures shallinclude means for verification of messages. The specific details of verification need not be included in the plan."
The BRP DEP did not describe the procedures developed to meet this criterion. Please modify the BRP DEP to meet this criterion or justify the deviation.
- 15. Criterion 2 under this section states that "Each organization shall establish procedures for alerting, notifying, and mobilizing emergency response personnel."
i Please provide a copy of these procedures.
- 16. Criterion 3 under this section states that "The licensee in conjunction with State and local organizations shall establish the contents of the initial emergency messages to be sent from the plant. These messages shall contain information about the class of emergency, whether a release is taking place, potentially affected population and areas..."
Please describe the emergency messages which have been established and information or the coordination of the establishment of the messages with the State and local organizations.
- 17. Criterion 4 under this section states that "Each licensee shall make provisions for follow up messages from the facility to offsite authorities which shall contain the following information if it is known and appropriate..."
Please describe your provisions for follow-up messages.
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- 18. dection IV.D.3 of Appendix E to 10 CFR Part 50 specifies that noufication of State and local government agencies must occur within 15 minutes of the declaration of an event, in a letter dated October 29,1997, you requested, among other emergency planning exemptions, an exemption to allow this time be changed to 30 minutes and to allow notification to be made to only the State government agencies.
A. In your October 29,1997 letter, you provided justification for the change in the notification time from 15 to 30 minutes. However, you did not justify the change to only require the State to be notified.
This change is not considered to be apppriate. Please revise your exemption request to restore the provision for notifi Con of local government agencies or provide justification for this exemption.
B. Contrary to the request for changing the isotification time to 30 minutes, the BRP DEP states that notificatica of the State of Michigan will be within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of declaration.
Please modify the BRP DEP or justify this discrepancy.
NUREG-0654, Section ll.F. Emergency Communications
- 19. Criterion 1 of this section states that "Each organization shall establish reliable primary and backup means of communication for licensees, local, and State response organizations. Such systems should be selected to be compatible with one another."
Please describe how your emergency communication system meets this criterion.
- 20. Criterion la of this section states that each plan shallinclude " provision for 24-hour per day notification to and activation of the State / local emergency response network; and at a minimum, a telephone link and alternate, including 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day manning of communications links that initiate emergency response actions."
Please describe how your communications arrangement meets this criterion.
- 21. Criterion le of this section states that each plan shallinclude "p.ovision for alerting or activating emergency personnelin each response organization."
Please justify how your plan meets this criterion.
NUht.G-0654, Section ll.G, Pubhe Educr: ion and Information
- 22. Criterion 2c of this section states that "Each organization shall establish coordinated arrangements for dealing with rumors."
Please describe how the BRP DEP meets this criterion.
NUREG-0654, Section ll.H, Emergency Facilities and Equipment
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- 23. Criterion 8 of this section states that "Each licensee shall provide meteorological instrumentation and procedures which satisfy the criteria in Appendix 2, and provisions to obtain representative current meteorologicalinformation from other sources."
Please describe how this criterion is met. In addition, describe any onsite meteorological measurement system that may be used during an emergency.
- 24. The BRP DEP states that the Emergency Support Center may be activated at the discretion of the Site Emergency Director.
Please provide the criteria which will be used to determine when the center will be activated. Please modify the BRP DEP to describe the location and habitability of the Emergency Support Center or justify not including this information in the plan.
- 25. Criterion 5d of this section states that each licensee shallidentify " fire and combustion products detectors."
Please describe how this criterion is met.
NUREG 0654, Section ll K, Radiological Exposure Control
- 26. The planning standard for this section is "Means for controlling radiological exposures, in an emergency, are established for emergency workers. The means for controfing radiological exposures shallinclude exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides."
Please describe how the dose limits provided in Table 10.1 of the BRP DEP are consistent with the EPA Protection Action Guides.
NUREG-0654, Section ll.J. Protective Response
- 27. Criterion 5 of this section states that "Each licensee shall provide for a capability to account for allindividuals onsite at the time of the emergency and ascertain the names of missing individuals within 30 minutes of the start of the emergency..."
The BRP DEP states that " accountability for Industrial Area personnel will be
, accomplished within 90 minutes."
Please modify the BRP DEP to meet this criterion or justify the deviation.
NUREG-0654, Section 11.0, Radiological Emergency Response Training
- 28. Criterion 3 of this section states that " Training for individuals assigned to licensee first aid teams shall include courses equivalent to Red Cross Multi-Media."
. Please describe how this criterion is met.
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- 29. The BRP DSP provided the following description of the training of plant personnel, "All plant personnel assigned emergency responsibilities wil: receive annual (t 15%)
training in accordance with plant procedures. Training for these individuals may be obtained through drill and exercise participation or other alternative training."
Please modify the BRP DEP to provide a more detailed description of the training program or justify how this description is adequate to ensure ERO receive appropriate training.
NUREG 0654, Section ll.P. Responsibility for the Planning Effort
- 30. Please provide details on how the BRP DEP will be reviewed to meet the requirements of 10 CFR 50.54(t).
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