ML20217P365

Forwards Response to 980202 RAI Re Defueled Emergency Plan, Submitted on 970919.Revised Defueled EPIPs & Revised Defueled Emergency Plan,Encl

ML20217P365
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	03/02/1998
From:	Powers K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217P371	List: ML20217P365 ML20217P381
References
NUDOCS 9803100229
Download: ML20217P365 (23)

Text

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l A CMS Energy CanparV Big Rock Point Nuclear Plant Keanen A M l

10269 LG 31 North Site General Manager

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Charlevoix, MI 49720 March 2, 1998 l

Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 - 0001 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - REPLY TO A REQUEST FOR ADDITIONAL INFORMATION CONCERNING BIG ROCK POINT NUCLEAR PLANT DEFUELED ENERGENCY PLAN l

By letter forwarded February 2, 1998, additional information and clarification were requested with regard to the review of Big l

Rock Point's Defueled Emergency Plan (DEP), which was submitted l

to the Nuclear Regulatory Commission on September 19, 1997. The response to this request, pertinent pages of the DEP Implementing procedures, and the revised DEP have been included as attachments to this letter.

As a matter of general comment, it is apparent that the NRC I

reviewer referenced NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Responte Plans and Preparedness in Support of Nuclear Power Plants, to determine the l

adequacy of the Big Rock Point Defueled Emergency Plan. This l

document was published in November, 1980, and does not make the distinction between an operating nuclear power plant and one that i

has been permanently defueled and is being decommissioned. The Big Rock Staff understands that rulemaking has been proposed in order to establish appropriate emergency planning requirements for permanently shutdown nuclear power plant sites (SECY-97-120 RULEMAKING PLAN FOR EMERGENCY PLANNING REQUIREMENTS FOR PERMANENTLY SHUTDOWN NUCLEAR POWER PLANT SITES 10 CFR PART l

50. 54 (q) AND (t) ; 10 CFR 50.47; AND APPENDIX E TO 10 CFR PART 50; l

dated July 10, 1997). The Big Rock Point staff also understands l

that this NUREG is the only guidance currently available; however l

the unique and current circumstance that the plant is permanently

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shutdown does not correspond to the conditions discussed in the l

NUREG. Consumers Energy Company requests that the NRC staff take this into consid ation during the review of this plan.

p. &

Kenneth P Powers Site General Manager CC:

Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point NRR Project Manager - OWFN 10VV01 13111ll111111ll1lll11 e

ATTACHMENT (s) a i a o a * -

9803100229 900302 PDR ADOCK 05000155 F

PDR

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CONSUMERS ENERGY COMPANY l

To the best of my knowledge, information and belief, the contents of this submittal are truthful and complete.

I By Kenneth P Powers Site General Manger l

Sworn and subscribed to before me this 2nd day of March 1998.

bonnnu/h blX

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enni pr Lynn/ elms, Notary Public H

Charl% voix County, Michigan My commission expires August 29, 1999 l

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l ATTACHMENT CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT DOCKET 50-155 I

REPLY TO A REQUEST FOR ADDITIONAL INFORMATION CONCERNING BIG ROCK j

POINT NUCLEAR PLANT DEFUELED EMERGENCY PLAN l

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REPLV TO REOUEST FOR ADDITIONAL INFORMATION CONCERNING BIG ROCK POINT NUCLEAR PLANT DEFUELED EMERGENCY PLAN 1.

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 devfation.

Step 12.1.2 of the Big Rock Point (BRP) Defueled Emergency Plan (DEP) states the local' emergency support would include fire-fighting, hospital, ambulance and law enforcement personnel.

Specific names and phone numbers are arovided in the Defueled Emergency Plan Implementing -

Procedures ()EPIPs). DEPIP-3. Attachment 1.

2.

The BRP DEP did not specify that 24-hour per day emergency response would be provided. Plene modify the BRP DEP to meet this criterion or justify the deviation.

As stated in 8.1. Paragraph 2. of the DEP. minimum backshift staffing will-include a Shift Supervisor / Control Room Operator and an individual qualified in radiological protection. This provides 24-hour Site Emergency Director availability. 24-hour emergency notification coverage, and 24-hour radiological protection. Other emergency response personnel would be called in as needed.

3A. The BRP DEP also specifies that the minimum backshift staffing will consist of the following personnel who have the following emergency dutles:

Site Emergency Director:

k e

initiate initial actic-bring facility to a stable condition e

classify the event e

make initial notificattor, io NRC. State of Michigan and Consumers Energy Company personnel e

augment plant staff e

perform initial dose assessment e

perform initial emergency radiological protection activities Security:

e respond to security threats e

perform accountability e

assist in evacuation of on-site personnel e

serve as a Fire Brigade member e

provide first aid support The'BRP DEP also states that an individual qualified in radiation protection will be m shift.

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Please justify how this number of personnel is 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 0irector and the security staff member.

There will be a minimum of three (3) back. shift staff personnel, as listed above:

1.

Shift Supervisor / Control Operator - Site Emergency Director c

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REPLY TO REQUEST FOR ADDITIONAL INFORMATION CONCERNING BIG ROCK POINT NUCLEAR

. PLANT DEFUELEO EMERGENCY PLAN t

2.' 'One individual qualified in radiological protection (NOT #1 above) 3.

One security staff member With the reactor.being'defueled, the site can only achieve an Unusual Event or an Alert classification. With minimal staffing, no accountability or evacuation of nonessential personnel will be required.

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~Backshift staffing will be able to adequately assess the situation and can supplement personnel for emergency response as needed.

38. 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.

L Technical Coordinator:

Responsible for accident assessment and repair of plant equipment and systems.

l Please justify how this number of personnel is sufficient to provide adequate response to an emergency at BRP.

The extent of emergencies will only warrant an Unusual Event or an Alert classification. Any accident would only cause a ground level release.

Any loss of spent fuel pool (SFP) cooling can occur for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> U thout exceeding the limit of 150 degrees which is more than enough time to reasonably assure that the loss of SFP cooling can.be mitigated.

These i

events could be readily assessed and managed by the proposed DEP ERO.

In short, it is.no longer possible to have an emergency event in which i

numerous personnel are required to return the site to a safe condition.

As the event is assessed, additional support personnel could be called in as needed for specific site analysis and/or restoration.

J In addition..this emergency organization is in place at a much larger i

site. Yankee Rowe, and had been approved as adequate by the NRC.

3C. The BRP DEP states that radiological monitoring personnel will take measurements and samples as directed.

These personnel were not included in the RO. Please justify why these persGnnel were not included in the ERO.

One radiologically qualified employee will be on site at all times, who can perform immediate monitoring and analysis. Additional radiologically qualified personnel will be called in as needed.

Due to the nature of emergencies that could occur in the site's defueled condition, there would be time to call in as many support personnel as required for the event.

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'4.

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 agreements.

As stated in Paragraph 2 of Step 6.1.4 and in the last paragraph of Step 8.3 of the DEP, Letters of Agreement with off-site snoport organizations

REPLY TO REQUEST FOR ADDITIONAL INFORMATION CONCERNING BIG ROCK POINT NUCLEAR l

PLANT DEFUELED EMERGENCY PLAN i

will be included in the DEPIPs (currently in Appendix A of the current l

plan).

5.

The BRP DEP did not describe the capabi11ty for continuous operations for a protracted period. Please modify the BRP DEP to tr:m D V criterion or justify the deviation.

The Shift Supervisor / Control Operator is on site at all times.

He will act as the Site Emergency Director and perform initial response actions.

At his discretion, he will augment additional emergency response staff as needed for as long as the event continues.

6.

The BRP DEP did not provide a description of the onsite emergency organization of plant staff personnel for all shi'ts and its relation to the responsibilities and dutiea of the normal star f complement.

Please modify the BRP DEP to meet this criterion or justify the deviation.

This is described in Sections 8.1 and 8.2 of the DEP. Augmented personnel not a part of the formal Emergency Response Organization will perform in their day-to-day assigned roles, eg, radiological monitoring.

engineering, etc.

I 7.

The BRP DEP states that additional personnel 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-shift personnel and state the relationship of this criteria to the event classification level.

Please provide the time goal for completing augmentation after the decision to augment has been made.

All augmentation would occur as needed depending on the type of event, eg, dose levels, fuel damage, or loss of spent fuel pool cooling and the type of support needed, eg. Health Physics. Enginee.-ing. Security, etc.

Step 8.2.2. Paragraph 2. of the DEP has been revised to reflect an augmentation reporting time of one hour after notification.

4 8.

The BRP DEP identified the person (i.e.

Public Affairs Director) who is responsible for releasing this information, however. it does not identify i

this position as a part of the ERO.

Please justify why the Public Affairs Director was not included in the ERO.

The Public Affairs Director would not have an effect on mitigating the incident.

Staff on site would make required and courtesy notifications to the NRC and State.

The Public Affairs Director could respond to media inquiries from any location, as needed.

Currently, the Public Affairs Director is not called to an. emergency response facility until a Site Area Emergency is declared, which is no longer possible to attain.

9.

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.

S3ecific identification of these agencies along with emergenc. contact pione numbers is listed in DEPIP-3. Attach 1.

BEPLY TO REQUEST FOR ADDITIONAL INFORMATION CONCERNING BIG ROCK POINT NUCLEAR PLANT DEFUELED EMERGENCY PLAN 10.

The BRP Dep did not specify a person authorized to request Federal assistance. Please modify the BRP DEP to meet this criterion or justify l

the deviation.

The Site Emergency Director has full responsibility and authority for taking any action necessary to bring the facility to a stable condition.

11.

The BRP DEP did not identify the available radiological laboratory facilities. Please modify the BRP DEP to meet this criterion or justify the deviation.

This information will be listed in the Letters of Agreement. DEPIP-2.

Attach 5 (currently in Appendix A of the current plan).

12A. Please provide the specific emergency actions levels for BRP and describe how the EAL scheme is adequate for classifying any potential event at BRP.

See DEPIP-1. Attachment 1. which describes determination criteria for entering the DEP per accidents that could occur in the site's current defueled state.

128. On? of BRP initiating condition /EAL was " Unplanned, uncontrolled effluent 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.

See DEPIP-1, Attachment 1. for specific parameters for initiating conditions.

13. Please prnvide documentation of discussions and agreements with State and local governmental authorities regarding the BRP EALs.

Documentation of annual meetings with the State and County regarding EAL and PAR updates is on file at BRP DCC. The last meeting was held June 13. 1997.

However. EALs and PARS will no longer be in effect off site. Therefore review of EALs and PARS is irrelevant to State and County officials.

However. State and County law enforcement personnel will be invited to participate in an annual plant status review session annually.

14.

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.

See response to Number 13 above. This is no longer required or appropriate because of the defueled condition of the plant.

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15. Criterion 2 under this section states that "Each organization shall establish procedures for alerting. notifying, and mobilizing emergency response personnel."

l Please provide a copy of these procedures.

This information is included in DEPIP-3. Attachment 1.

REPLY TO REQUEST FOR ADDITIONAL INFORMATION CONCERNING BIG ROCK POINT NUCLEAR i

PLANT DEFUELED EMERGENCY PLAN

16. Please describe the emergency messages which have been established and information on the coordination of the establishment of the messages with the State and local organizations.

As stated in Steps 7.3. 8.2.1. 9.2.1.7. 11.0 and 11.1.2 of the DEP. the State will be notified via primary or backup communications ASAP but within one hour of classifying the emergency.

See DEPIP-3. Attachment 3 for the Offsite Notification Form.

17.

Criterion 4 under this section states that "Each licensee shall make provision for tollow up messages from the facility to offsite authorities which shall contain the following information if it is knowri and appropriate..."

Please describe your provisions for follow-up messages.

Follow-up messages would occur as mutually agreed upon by the site and the State.

18A. In your October 29.19971etter, 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 appropri"e.

Please revise your exemption request to restore the provision fo, tification of local government agencies or provide justification for chis exemption.

It is not considered appropriate to notify County governmental agencies directly since there are no design basis or other credible events which would result in doses beyond the site area boundary that would exceed the EPA 400 release guidelines.

Notification to the state is a courtesy contact. and they will be the link to the County governmental agencies if deemed appropriate by State personnel.

188. Contrary to the request for changing the notification time to 30 minutes, the BRP DEP states that notification of the State of Micht an 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.

The DEP was changed reflect that the State of Michigan should be notified within 30 minutes after the classification of an event. This is noted in Steps 9.2.1.7 and 11.1.2 of the DEP.

19.

Please describe how your emergency cortmunication system meets this criterion.

i Our emergency communications systems will remain as they have been during 4

plant o)eration.

Primary communication lines via Ameritech are available in the Emergency Support Center along with a base radio which is the backup communication system for notifying the State.

20.

Please describe how your comunications arrangement meets this criterion.

The Site Emergency Director is staffed by the Shift Supervisor / Control Operator who is on site 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. As stated in Step 8.2.1 of the

l REPLY TO REQUEST FOR ADDITIONAL INFORMATION CONCERNING BIG ROCK POINT NUCLEAR PLANT DEFUELED EMERGENCY PLAN DEP, the Site Emergency Director performs initial response actions which includes notifications to off-site agencies. Arrangements will continue-that the State contact will be automatically transferred to a State Police Post which is staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day (Gaylord, Michigan) as is the current practice.

21. Please justify how your plan meets this criterion.

As stated in Step 11.1.1 of the DEP, alerting on-site personnel of an emergency on site will be accomplished via the paging system, personal pagers, telephone and/or the siren.

22. Please describe how the BRP DEP meets this criterion.

Currently the Rumor Control function during an emergency is activated l.

-after a Site Area Emergency has been declared. This emergency level is no longer credible because of the plant's defueled condition.

Media communications will be handled by the Public Affairs Director or his designate.

23, Please describe how this criterion is met.

In addition. describe any onsite meteorological measurement system that may be used during an emergency.

Site meteorological sensors will provide wind speed and direction.

Complete weather information, including stability class and forecast data is available via telephone or autodial through the Emergency Support Center computer to Weather Services International (WSI).

24. Please provide the criteria which will be used to determine when the l

center will be activated Please modify the BRP DEP to describe the location and habitabi1ity of the Emergency Support Center or justify not.

including-this'information in the plan.

The Emergency Support-Center (ESC) location is s)ecifically described in DEPIP-4, Step 3.1: it is not necessary to have t11s information in the l

DEP.

ESC activation will be determined by the Site Emergency Director depending on the severity of the emergency and the level of support required to bring the site back to a safe and stable condition.

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25. Please' describe how this criterion is met.

Provisions for firefighting and control are' described in the Big Rock L

Point Fire Protection Plan.

This is noted in Step 6.3.4 of the DEP (revision).

26. Please describe how the dose limits provided in Table 10.1 of the BRP DEP are consistent with the EPA Protection Action Guides.

The original table has been replaced with Table 2.2 from the EPA 400

" Manual of Protective Action Guides and Protection Actions for Nuclear Incidents" to ensure alignment.

27. Please modify the BRP DEP to meet this criterion or justify the deviation.

i REPLY TO REOUEST FOR ADDITIONAL INFORMATION CONCERNING BIG ROCK P01,lT NUCLEAR l

PLANT DEFUELED EMERGENCY PLAN Due to the types of emergency events possible and the fewer number of l

personnel necessary to mitigate an event, it is not necessary to assemble l

personne1'within the former requirement of 30 minutes post-incident.

28. Ple se describe how this criterion is met.

First Aid is required training for HP Technicians and Decomm Worker III's who would respond to a medical emergency as documented in Admin 1.7.2 and Admin 5.0. Attachment 1.

29. 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.

See DEPIP-10. Emergency Response Organization Training, which details the courses required by each ERO role, how this training can be obtained, and how the training is requalified each year as required by the DEP.

30. Please provide details on how the BRP DEP will be reviewed to meet the requirements of 10 CFR 50.54(t).

As stated in Step 12.5 of the DEP. audits of the DEP will be conducted according to CPC-2A. Appendix D in Rev 19 of CPC-2A. which has been accepted by the NRC. states that the Site Emergency Plan and implementing procedures will be audited at least once per 12 months.

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ATTACHMENT 2 l

CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT DOCKET 50-155 DEFUELED EMERGENCY PLAN IMPLEMENTING PROCEDURES REFERENCES 4

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VOLUME 9 SITE EMERGENCY PLAN Revision 130 BIG ROCK POINT PLANT - APPENDIX A Page 1 of 12 1

LETTERS OF AGREEMENT Letters of agreement.between the Big Rock Point Nuclear Plant and off-site agencies shall be reviewed and updated. if required, at least annually by the Palisades Plant Emergency Planning Section.

Life and Link Inc.

Charlevoix Fire De)artment Northern Michigan lospital. Inc Charlevoix Area Hospital Charlevoix Townshi) Board Teledyne Isotopes ildwest Laboratory Holiday Inn of Petoskey Boyne City 1

i 9APPA 08/11/97

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l VOLUME 9 SITE EMERGENCY PLAN Revision 130 BIG ROCK P0lWI PLANT - APPENDIX A Page 2 of 12 A 045 Energy Company g

I 10269 05-31 North Charlevoix. MI 49720 Life + Link 501 W Mitchell. Suite 300 Petoskey, MI 49770

SUBJECT:

LETTER OF AGREEMENT WITH CONSUMERS ENERGY Life + Link agrees to respond to medical emergencies when requested by Big Rock Point Plant personnel. Consumers Energy's staff will escort Life + Link personnel on site.

I Signed &&

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V Executh e Director Tme eds)

IN. (9 77 Date I

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VOLUME 9 SITE EMERGENCY PLAN Revision 130 BIG ROCK POINT PLANT -

NDIX A Page 3 of 12 D

A CMS Energy Company Big Rock Point Nuclear Plant 10269 U5-31 North Charlevoix. MI 49720 Charlevoix Fire Department 210 State Street Charlevoix MI 49720

SUBJECT:

LETTER OF AGREEMENT WITH CONSUMERS ENERGY This letter is to confirm the policy of the Charlevoix Fire Department in response to an emergency at the Consumers Energy's Big Rock Point Plant.

Charlevoix. Michigan.

The responsibility of the Charlevoix Fire Department as outlined in the Site Emergency Plan is to provide fire fighting assistance as agreed to in the Charlevoix County Mutual Aid Agreement and ambulance service if necessary.

J Plant personnel will escort members of the Charlevoix Fire Department when J

inside the fenced areas.

This agreement shall be for a term of one (1) year and from year to year thereafter unless and until terminated as provided below:

Any party, upon sixty (60) days prior written notice to the other party, may terminate this agreement at the expiration of any successive one (1) year term.

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I VOLUME 9 SITE EMERGENCY PLAN Revision 130 BIG ROCK POINT PLANT - APPENDIX A Page 4 of 12 D

A CMS Energy Company Big Rock Point Nuclear Plant 10269 US-31 North Charlevoix, MI 49720 Northern Michigan Hospitals, Inc 416 Connable Avenue Petoskey. MI 49770

SUBJECT:

LETTER OF AGREEMENT WITH CONSUMERS ENERGY This letter is to confirm Northern Michigan Hospital's willingness to provide medical care for radiologically-contaminated injured 3atients due to an accident at the Big Rock Point Nuclear Power Plant.

lealth physics support personnel will be provided to the hospital by either Consumers Energy and/or the State of Michigan.

This egreement shall be for a term of one (1) year and from year to year thereafter unless and until terminated as provided below:

Any party, upon sixty (60) days prior written notice to the other party, may terminate this agreement at the expiration of any successive one (1) year term.

Signed

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l A CMS Energy Company Big Rock Point Nuclear Plant 10269 US-31 North Charlevoix. MI 49720 Charlevoix Area Hospital Lake Shore Drive Charlevoix, MI 49720

SUBJECT:

LETTER OF AGREEMENT WITH CONSUMERS ENERGY This letter is to confirm Charlevoix Area Hospital's willingness to nrovide medical care for radiologically-contaminated injured 3atients due tc,an accident at the Big Rock Point Nuclear Power Plant.

lealth physics support personnel will be provided to the hospital by either Consumers Energy and/or the State of Michigan.

This agreement shall be for a term of one (1) year and from year to year thereafter unless and until terminated as provided below:

Any party, upon sixty (60) days prior written notice to the other party, may terminate this agreement at the expiration of any successive one (1) year term.

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9APPA 08/11/97

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VOLUME 9 SITE EMERGENCY PLA,N Revision 130 BIG ROCK POINT PLANT - APPENDIX A Page 6 of 12

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A CMS Energy Company Big Rock Point Nuclear Plant 10269 US-31 North Charlevoix MI 49720 Charlevoix Township Board Petoskey Road Charlevoix MI 49720

SUBJECT:

LETTER OF AGREEMENT WITH CONSUMERS ENERGY This letter is to confirm the policy of the Charlevoix Township Fire Department in response to an emergency at the Consumers Energy's Big Rock Point Plant. Charlevoix. Michigan.

The responsibility of the Charlevoix Township Fire Department as outlined in the Site Emergericy Plan is to provide fire fighting assistance.

Plant personnel will escort members of the Charlevoix Township Fire Department when inside the fenced areas.

This agreement shall be for a term of one (1) year and from year to year thereafter unless and until terminated as provided below:

Any party, upon sixty (60) days prior written notice to the other party, may terminate this agreement at the expiration of any successive one (1) year term.

., 42 Signed Ah OltrM)

Tine 7-/ V - 9 7 o.t.

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VOLUME 9 SITE EMERGENCY PLAN Revision 130 BIG ROCK POINT PLANT - APPENDIX A Page 7 of 12 i

W TELEDYNEISOTOPES MIDWEST LABORATORY dba TELEDYNE BROWN ENGINEERING ENVIRONMENTAL SERVICES 700 Landwehr Road.Northbrook. it 60062 2310 Phone 547) 5644700. Fax #47) 5644511 February 24. 1997 Ms. Karen L. Penrod Emergency Planning Coordinator Consumers Power Palisades Nuclear P1 ant 27780 Blue Star Memorial Highway Covert, MI 49043

SUBJECT:

TBEESML Emergency Response Plan - Big Rock and Palisades Nuclear Generating Plants l

Dear Ms. Penrod:

As per your request I arr providing you with the updated information concerning the response TBEESML can provide to Consumers Power in case of an emergency at the Palisades or Big Rock Nuclear Generating Plants. Also, included is a list of TBEESML personnel to be contacted in the event of an emergency.

A.

Response Time 1.

During Normal Working Hours A.. Laboratory The lab will be alerted immediately.

If it is anticipated that the samples will be arriving after normal working i

hours, a sufficient number of staff members will stay to handle the analyses. The rest of the staff will be placed on 24-hour alert.

B.

Field Travel A team from the lab can be on the road to the station within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. We maintain a special emergency box l

containing all necessary sampling equipment and containers i

for such a contingency.

Estimated travel time to Palisades i

Nuclear Plant is approximately 5-6 hours.

9APPA 08/11/97

.4 VOLlHE 9 SITE EMERGENCY PLAN R -4sion 130 BIG ROCK POINT PLANT - APPENDIX A 3 of 12 2.

During Non-Working Hours and Weekends A.

Laboratory The staff can arrive at the laboratory within 15 minutes to 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> depending on the distance to the residence.

There may be difficulty in meeting these response times during long weekends and holidays.

B.

Field Travel Team can be dispatched within 2-3 hours or as soon as personnel can be located. The same comment about holidays in 2a applies to field travel.

If you have any questions please do not hesitate to contact me at (847) 564-0700.

Sincerely

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Administrative Lead AMG/lsd 1

Enclosure:

. Emergency Telephone Numbers List List of Emergency Box contents j

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VOLUME 9 SITE EMERGENCY PLAN Revision 130 l

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J W TELEDYNE ISOTOPES l

M!DWEST LABORATORY dbaTELEDYNE BROWN ENGINEERING ENVIRONMENTAL SERVICES 700 Landwehr Road a Northbrook,IL 60062 2310 1

Phone $47)5644700 + Fax 547)564451T EMERGENCY TELEPHONE NUMBERS (Revised January 9. 1997)

Personnel at TIML to be Contacted in Case of Emeraency:

Alan Green. Administrative Lead Office:

(847) 564-0700 6:00 a.m. - 3:00 p.m.

Home:

(414) 697-0909

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Bronia Grob. Technical Lead Office:

(847) 564-0700 8:30 a.m. - 5:15 p.m.

4 Home:

(847) 298-2949 I

If Mr. Green or Ms Grob cannot be reached, the following people should be contacted:

Tony Coorlim. Special Projects Coord.

Office:

(847) 564-0700 8:30 a.m. - 5:15 p.m.

Home:

(847) 949-0669 Ellen Saar, POC Comed Office:

(847) 564-0700 8:30 a.m. - 5:15 p.m.

Home:

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$1TE EMERGENCY PLAN Revision 130 BIG ROCK POINT PLANT - APPENDIX A Page 10 of 12 W TELEDYNE ISOTOPES MIDWEST LABORATORY dbaTELEDYNE BROWN ENGINEERING ENVIRONMENTAL SERVICES 100 Landwehr Road.Northbrook. IL 60062 2310 Phone $47) 564 8100. Fax 54T) $644511 l

EMERGENCY FIELD BOX CONTENTS (Verified September 24. 1996) 36 One (1) gallon cubitainers with caps 30 Quart cubitainers with caps 1

Flashlight 1

Pair of rubber gloves 1

Box of disposable gloves 1

Plastic bucket with nylon rope (for water) 1 Plastic pitcher (for milk) 1 Grey notebook j

1 Protective suit Plastic bags - Large Plastic bags - Small 2

Plastic funnels 20 4 oz containers with lids

" Radioactive Material" warning labels Paper towels 1

Grass cutting shears 1

Box filter papers (Gelman 47mm) 100 ct 1

Shovel 1

Hand scoop 1

Roll tape 1

Pair tweezers i

Pens and marker pens 1

Knife l

9APPA 08/11/97 l

l.

l VOLUME 9 SITE EMERGENCY PLAN Revision 130 BIG ROCK POINT PLANT - APPENDIX A Page 11 of 12 l

A CMS Energy Company Big Rock Point Nuclear Plant 10269 US-31 North Charlevoix. MI 49720 Holiday Inn of Petoskey PO Box 678 Petoskey. MI 49770

SUBJECT:

LETTER OF AGREEMENT WITH CONSUMERS ENERGY This letter is to confirm the agreement between Holiday Inn of Petoskey and the Big Rock Point Nuclear Plant concerning your participation in the plant's Emergency Public Information Policies and Procedures.

Should an event occur at Big Rock Point which requires activation of the

)lant's Site Emergency Plan it may become necessary to activate a Joint

)ublic Information Center (JPIC).

Such a center will be located in the Bayview Room of the Holiday Inn of Petoskey. Activation of the JPIC will also require the reservation of approximately 20 rooms as close to the JPIC as possible for use by personnel from Consumers Energy, the State of Michigan, the US Nuclear Regulatory Commission. Charlevoix County and Emmet County.

Every effort will be trade by Consumers Energy to give the Holiday Inn as much advance notice as possible of the JPIC activation.

This agreement shall be for a term of one year and from year to year thereafter unless and until terminated as provided below:

Any party, upon sixty (60) days prior written notice to the other party, may terminate this agreement at the expiration of any successive one (1) year term.

signed

• ohm

m. JmA a 2

Date i

9APPA 08/11/97

1 VOLUME 9 SITE EMERGENCY PLAN Revision 130 BIG ROCK POINT PLANT - APPENDIX A Page 12 of 12

{

t A CMS Energy Company Dig Rock Point Nuclear Plant 10269 LS-31 North f

Charlevaix. MI 49720 j

Boyne City PO Box 68 319 N Lake Street Boyne City. Michigan 49712

SUBJECT:

AGREEMENT WITH CONSUMERS ENERGY FOR USE OF THE BOYNE CITY MECHANICS GARAGE FOR THE DECONTAMINATION OF BIG ROCK POINT PLANT EVACUEES Boyne City agrees to provide the use of its fire station, machine shop / garage area, and the south parking lot for radiological screening and decontamination of Big Rock Point Plant Personnel and vehicles in the event of a site evacuation.

Consumers Energy personnel will provide monitoring and decontamination equipment to perform all screening and decontamination of vehicles. )ersonnel, and city facilities.

All efforts will be made by Consumers Energy personnel to minimize radiological c

'ination of the city property.

If contamination of city property occur:

_amers Energy shall be responsible for all cleanup.

Initial notification will be via the Charlevoix j

County EOC.

Any party, upon sixty (60) days prior written notice to the other i

party, may terminate this agreement at the expiration of any i

I successive one (1) year term.

signed Aoy OA my m.

7-9-n o,.

9APPA 08/11/97 1