ML20210H096
| ML20210H096 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 08/05/1997 |
| From: | Addy R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9708110228 | |
| Download: ML20210H096 (3) | |
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ConsumersEnergy A CMS begy Ceyuny Big Mk Pant Micar PU't Kenneek R Peeners 1039 #31 hth Punt General Atanager Cha*e. At 497N August 5,1997 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001
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DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - EXEMPI' ION REQUEST FROM TIIE BIENNIAL OFFSITE Eh1ERGENCY PREPAPIDNESS EXERCISE - REVISION 1.
t The purpose of this letter is to provide additional information with regard to an exemption mquest submitted July 17,1997.
Big Rock Point will permanently cease to generate power by August 30,1997, as duumented in correspondence forwarded to the NRC dated June 26,1997. Therefore, Consumers Energy Company is formally requesting an exemption pursuant to 10 CFR 50.12 from conducting Big Rock Point's 1997 Biennial Offsite Emergency Preparedness Exercise as required by Part 50, Appendix E(IV)(2)(c) for operating nuclear power plants. The exercise is scheduled for October 21,1997. This exemption is necessary because the current regulations do not provide clear guidance for nuclear power plant emergency plans when j
facilities are transitioning from an operating to a permanently shutdown status. After cooling I
. for several days after the shutdown, the spent fuel will be removed from the reactor and O
placed in the spent fuel pool. The defueling of the reactc is scheduled to be complete by September 15,1997. A letter of certification attesting to permanent fuel removal from the reactor will be submitted to the NRC in accordance with 10 CFR 50.82(a)(1)(ii) at that time.
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When the letter is docketed, the 10 CFR Part 50 license no longer r.llows ooeration of the fg reactor or emplacement or retention of fuel into the reactor vessel. Therefore, by the sclieduled date of the biennial exercise, the reactor will be defueled and permanently shutdown and all of the spent fuel will be in the spent fuel pool. In this configuration, the i
risk to public health and safety will be greatly reduced in comparison to an operating nuclear power plant.
Conducting an annual exercise for an operating nuclear power plant involves significant resource expenditure by the Company and outside agencies. Specifically, the following would be required:
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Ov:r 75 % of full-time Big Rock Point Plant personnel to participate.
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Appmximately 30 additional support personnel from Palisades Nuclear Plant and Midland Training Center.
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Up to 200 State and County personnel.
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HRC Inspectors would require travel time, lodging, and participation on site to l
evaluate and report to the public on exercise performance.
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Federal Emergency Management Agency (FEMA) personnel would require travel time, lodging, and participation on site to evaluate and report to the public on exercise performance.
In addition, no modifications to the spent fuel pool system are scheduled during this period.
Accidental dmining of the spent fuel pool has already been dispositioned during the Spent Fuel Pool Expansion Hearings in the early 1980's as not being cmdible. Consumers Energy Company concluded at that time that accidental draining of the fuel pool was unlikely, and to pmvide added assurance additional makeup sources for the fuel pool were installed.
As during reactor operation, spent fuel pool water level will nonnally be maintained at elevation 630' 6" by the discharge overnow weir. In the event of a loss of spent fuci pool cooling pump flow, fuel pool level would drop approximately two inches to th: elevation of h
the siphon breaker (approximate elevation of 630' 4"), providing approximately 20 feet of water above fuel stored in the storage racks.
Based on the above, a makeup source with a capacity of 20 gallons per minute flow to the spent fuel pool through the spent fuel pool emergency makeup line is sufficient to maintain water level in the Spent Fuel Pool under off-normal conditions involving loss o Spent Fuel r
Pool cooling. This is accomplished by using the currently existing equipment:
The electric fire pump is capable of supplying 20 gpm to the emergency makeup line a.
via the fire water header inside containment.
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A diesel generator is capable of providing power within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to operate the electtic fire pump, and one off-site source of ac power is maintained.
At least one hose station inside containment is capable of supplying 20 gpm of fire c.
water to the spent fuel pool, wiQ sufficient hose available inside containment to reach from the designated hose station to the spent fuel pool.
The Decommissioning Emergency Plan is scheduled to be in effect December 1,1997, contingent upon NRC approval of the plan. The plan is currently under review by the Plant Review Committee and is expected to be submitted to the NRC in August,1997. This plan limits protective actions to the site boundary. Therefore, before year-end, the surrounding Counties and State of Michigan will have minimal responsibility for a radiological emergency at Big Rock Point; the State is in agreement that an exemption from.nc upcoming exercise should be granted (reference letter dated 7/29/97 to Mr. A. Beach from Mr. R. Tarrant).
FEMA has also been contacted by the State of Michigan, and has agreed that hn exemption to^ conducting this exercise should be pursued. Conducting an exercise on October 21,1997, would utilize Emergency Plan procedures and practices that would exist only until December 1,1997, and does not appear to be a pmdent un of resources for a facility that is
l rmanently shutdown. To ensure a smooth transition from an operating Panergency Plan to o
a Decortmissioned Emergency Plan, the Big Rock Point staff will be conducting a Decommissioning emergency event exercise the first quarter of 1998. The appropriate training and procedures will be utilized in support of the Decommissioning Plan. NRC participation or observation of this exercise would be welcome.
As a matter of record,- Big Rock Point's last Annual Emergency Preparedness Exercise was conducted on September 10,1996, and was evaluated by NRC Region III Inspectors.
Overall performance was accepta~ ole and no significant issues were identified. Furthermore, an annual Routine Inspection conducted in March,1997, by NRC Region III Inspectors reported that the overall effectiveness of the Emergency Planning program was very good and no significant issues were identified. Big Rock Point will continue to adhere to the existing Emergency Plan to ensure our preparedness to protect the health and safety of the i
public.
Consumers Energy Company considers it prudent not to expend the Utility, State, County l
and Government resources necessary for an operating nuclear power plant biennial offsite emergency exercise in 1997. Preparing procedures, training and scheduling an exercise for 1998 for the plant's projected configumtion in October (defueled, all spent fuel in the spent fuel pool, operable makeup sources to the spent fuel pool) is the proper course of action to l
continue to protect the health and safety of the public. Until the emergency plan is reviewed and approved by the Nuclear Regulatory Commission, Big Rock Point's current emergency plan will continue to be implemented.
Your response is requested by August 15, 1997.
Respectfully, d
Robert J Addy Plant Manager CC: Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point Dan Sibo, Michigan State Police KMHaas, Palisades
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