ML20246B913

Advises That 890420 Changes to Emergency Plan Consistent W/ Provisions of 10CFR50.54(p) & Acceptable,Except for Proposed Rev to Eliminate Biennial Renewal of Agreements W/Offsite Support Agencies.Other Changes May Be Incorporated in Plan

ML20246B913
Person / Time
Site:	University of Michigan
Issue date:	06/30/1989
From:	Michaels T Office of Nuclear Reactor Regulation
To:	Kerr W MICHIGAN, UNIV. OF, ANN ARBOR, MI
References
NUDOCS 8907100171
Download: ML20246B913 (3)

Text

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cket' No 50-2 .

June 30,.1989

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r Dr.LWilliam F. Kerr,' Director i Phoenix Memorial Laboratory Ford Nuclear Reactor.

University of Michigan T' 2301'Bonisteel Boulevard

= Ann Arbor, Mi:higan 48109-2100

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Dear Dr. Kerr:

1

SUBJECT:

REVIEW OF CHANGES IN THE EMERGENCY PLAN FOR THE UNIVERSITY OF MICHIGAN FORD NUCLEAR REACTOR We have reviewed the proposed emergency plan changes for the University of Michigan Ford Nuclear Reactor submitted April 20, 1989, and further clarified

' in a letter submitted May 30, 1989,- against 10 CFR 50.54(q). Our review indi-cates that one proposed change decreases the effectiveness of the currently approved emergency plan. . It is our position therefore, that the proposed change should not be incorporated into the current emergency plan.

The proposed revision would eliminate the biennial renewal of ag7.wents with offsite support agencies. '10 CFR 50, Appendix E.IV.G. requires, in part, that provisions be employed to ensure that the emergency plan is maintained up to date. A statement attesting to the fact that the agreements are in

, effect provides no' assurance that the agreement is current. The purpose of k

' periodic renewal of agreements-is to provide ~ an understanding of the ,

delineation of responsibilities and expected actions of the participating

. agencies. . Annual training does not ensure that the licensee will be made aware of changes in the offsite organizations. Changes in management, concept of operations, capabilities, availability, etc., could have an impact on the "q  : support which the licensee expects. Periodic renewal of agreements provides L an opportunity to assure that any changes in an organization will not affect l the' ability or willingness to provide the expected support. _ ,

r The other proposed changes ao not decrease the effectiveness of the currently approved emergency plan and may be incorporated into the current emergency plan.

Sincerely, 1

!heodoreS.Michaels,ProjectManager l Standardization and Non-Power Reactor Project Directorate Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Pegulation DISTRIBUTION:

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C 20555

%,...../ June 30, 1989 Docket No. 50-2 Dr. William F. Kerr, Director Phoenix Memorial Laboratory Ford Nuclear Reactor University of Michigan 2301 Bonisteel Boulevard Ann Arbor, Michigan 48109-2100

SUBJECT:

REVIEW OF CHANGES IN THE ENERGENCY PLAN FOR THE UNIVERSITY OF HICHIGAN FORD NUCLEAR REACTOR We have reviewed the proposed emergency plan changes for the University of Michigan Ford Nuclear Reactor submitted April 20, 1989, and further clarified in a letter submitted May 30, 1989, against 10 CFR 50.54(q). Our review indi-cates that one proposed change decreases the effectiveness of the currently approved emergency plan. It is our position therefore, that the proposed change should not be incorporated into the current emergency plan.

The proposed revision would eliminate the biennial renewal of agreements with offsite support agencies. 10 CFR 50, Appendix E.IV.G. requires, in part, that provisions be employed to ensure that the emergency plan is maintained up to date. A statement attesting to the fact that the agreements are in effect provides no assurance that the agreement is current. The purpose of periodic renewal of agreements is to provide an understanding of the delineation of responsibilities and expected actions of the participating agencies. Annual training does not ensure that the licensee will be made aware of changes in the offsite organizations. Changes in management, concept of operations, capabilities, availability, etc., could have an impact on the

upport which the licensee expects. Periodic renewal of agreements provides an opportunity to assure that any changes in an organization will not affect the ability or willingness to provide the expected support. i The other proposed chances do not decrease the effectiveness of the currently approved emergency plan and may be incorporated into the current emergency plan.

Sincerely, M [.

Theodore S. Michaels, Project Manager Standardization and Non-Power Reactor Project Directorate Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation cc: see next page

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~ The Univtrsity:cf' Michigan- Docket No. 50 N  : m.

E cc: Chief Environmental and Occupational Health

- Services Administration Michigan Department of Health 3500 N. Logan Street P. O. Box 30035

. Lansing, Michigen 48909

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