ML20238E808

Forwards Revised Big Rock Point Defueled Emergency Plan. Rev to Plan Resulted from NRC Questions Raised During 980813 Meeting

ML20238E808
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	08/28/1998
From:	Powers K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20238E810	List: ML20238E808 ML20238E814
References
NUDOCS 9809020210
Download: ML20238E808 (4)

Text

_ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - .

M RNWS gy A CMS Energy Company Big Rock Point Nuclear Plant Kenneih P. Sceners 10269 US-31 North Site General Manager Olarlevoir, MI 49720 August 28. 1998 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 - 0001 DOCKET 50 155 LICENSE DPR 06 - BIG ROCK POINT PLANT SUPPLEMENTAL INFORMATION WITH REGARD TO ADDITIONAL STAFF QUESTIONS CONCERNING THE DEFUELED EMERGENCY PLAN.

On August 13, 1998, members of the Office of Nuclear Reactor Regulation (NRR) and Consumers Energy Company staff met to discuss the progress of the Defueled Emergency Plan and the Defueled Technical Specifications. At the end of the meeting. the Staff identified additional questions with regard to the Defueled Emergency Plan. l l

As a result. additional revisions to the Defueled Emergency Plan have been made and are provided as attachments to this letter:

Attachment 1: Additional NRC questions.

Attachment 2: Defueled Emergency Plan (marked to show changes from the current defueled emergency plan submitted to the NRC in a letter dated i July 30. 1998).  ;

i Attachment 3: Defueled Emergency Plan (as proposed). l If you have any further questions regarding this information, please contact Karen A. Wooster at (616) 547-8288, or Michael D. Bourassa at (616) 547-8244.

nneth P Powers Site General Manager

\

CC: Administrator. Region III. USNRC NRC Resident Inspector - Big Rock Point Plant NRR Project Manager - OWFN. USNRC g ATTACHMENT (s) 9909020210 990929 <

PDR ADOCK 05000155.

F PDR

L-

' ATTACHMENT 1' CONSUMERS. ENERGY COMPANY.

BIG _ ROCK POINT-PLANT-

- DOCKET 50-155.

Additional NRC Questionss

(

i i

NRC QUESTIONS These questions were given to the Big Rock Point Staff on August 13. 1998 by the NRC Emergency Plan reviewer. They have been paraphrased by the Big Rock Point staff. Where appropriate, the Defueled Emergency Plan has been revised to address the question.

1. More information is required with regard to the Emergency Support Center (ESC) -- how is it equipped, habitability, access, etc.

Inserted additional information on contents of ESC, location, and habitability. See Section 6.1.1.

2. Ensure Emergency Response Organization (ERO) staffing is mandatory at Alert in lieu of the Site Emergency Director's discretion.

Changed text as necessary to ensure ERO would be automatically activated at Alert. See Sections 3.0 (second to last paragraph), 6.1.1 (second paragraph), 8.2.1, and 8.2.2,

3. With regard to Table 10.3 - where did the respirator criteria come from?

A corresponding Table in Trojan's Defueled Emergency Plan was utilized as the basis and then modified to meet site specific requirements for Big Rock Point.

4. With regard to Emergency Action Level (EAL) for Radioactive Releases or Abnormal Radiation Levels: why is the EC limit of 10 CFR 20. Appendix B.

Table 2 averaged over 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> vs 15 minutes?

The 1-hour average aligns with the Offsite Dose Calculation Manual (0DCM) and the Technical Specifications.

5. Consider adding an EAL for elevated general area radiation levels (vs just unexpected manipulation of components).

Added wording (in capital letters) to EAL for Radioactive Releases or Abnormal Radiation Levels " Unexpected manipulation of or damage to irradiated component OR OTHER PADI0 ACTIVE MATERIAL results in ..."

6. More information is required with regard to assembly areas -- criteria for selection, protection, accommodation of all people, etc.

Wording was added to indicate that assembly areas would be in low dose l areas and would accommodate number of personnel expected to assemble in the area. See Section 6.1.2. As the facility is " reconstructed." these areas may have to be relocated.

7. With regard to the declaration of an Unusual Event (UE). ensure that a public address (PA) announcement will be made. Consider using the sirens for UE notification.

Section 9.2.1 already included a step to make an announcement over the PA system. However, this sequence for the response to an unusual Event was revised to make-the PA announcement second (was fourth originally) and added that the announcement would be made over the plant paging system at backuo system if reauired.

Currently, the sirens are not used in the emergency plan for UE notification. Therefore, based on past practice, the defueled emergency plan will not require the use of the sirens for UE notification.

8. For on-site communications, primary AND backup mediums are required (at least 1 available). Consider identifying these mediums.

Added wording to Section 7.0 to indicate that the plant paging system serves as the crimarv on site communication method and that the plant two way radio system, site siren and telephones serve as backuo communications methods.

9. With regard to the Emergency Response Organization (ERO)- need to ensure that licensee response is capable of continuous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> operations, ie.,

have 2-3' persons for each position .

Added wording to Section 8.2 that sufficient personnel will be trained to ensure 24-hour ERO coverage during a site emergency.

10. With regard to ERO response for augmentation: consider making a goal of reporting in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after Alert is declared instead of a requirement.

Changed Section 8.2.2 to read "The goal for ERO personnel is to report to the site within one hour of declaration of an Alert."

l I

l C____.___________________._____.___