ML20206C072

Ack Receipt of Transmitting Rev 88 to Vol 9 to Site Emergency Plan.Emergency Action Levels Described in Ltr Requested within 90 Days for Final Review

ML20206C072
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	11/09/1988
From:	Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 8811160085
Download: ML20206C072 (2)

Text

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NOV 0 91988 Occket No. 50-155 Consumers Power Company ATTN: David P. Hoffman Vice President  :

Nuclear Operations 212 West Michigan Avenue Jackson, MI 49201 Gentlemen:

This is to acknowledge receipt of your letter dated September 1,19PP, which

] transmitted Revision 88 to the Big Rock Point Site Emergency Plan (SEP), '

Volume 9. This revision included an updated list of Letters of Agreenent in 4

Appendix A to the SEP and a major revision in format and structure for the Emergency Action Level (EAL) Tables in Appendix M of the plan. We have no ,

questions regarding the u3 dated list of Letters of Agreement in Appendix A. '

We had sore conserns on tie proposed revisien of the EALs in Appendix M.

The EAL concerns have been discussed by Ms. M. Pebe, Energency Preparedness Coordinator, of your staff and Pr. J. Patterson of my staff on October 24 and ,

October 27, 1988. As a result of these discussions your staff has agreed to '

4 change two EALs relating to the primary coolant system, naecly those EALs found ,

on Page 3 of 13 and Page 6 of 13 in Appendix M to the SEP. Currently each of 1 these EALs lists a cocbination of eight conditions which could result in a Loss

, of Coolant Accident (LOCA) being classitted as an Alert. Our concern is that sone operating staff may interpret the phrase "any cerbination of" to mean any two ccnditiens, while others could interpret it to mean more than two conditions must be satisfied before an Alert would be declared. Yeur staff is reevaluating ,

i these two EALs. Your staff also intends to incorporate some of the eight l

, conditions. (e.g., "steam flow /feedwater ficw mismatch" and ' CAM high alarm, ,

turbine or exhaust,") into the Energency Cperating Procedures (EOPs). This ,

should reduce the chance for misinterpretation when using these two EAls. The [

3 changes would also result in the EALs being better intcgrated into the recently l

revised ECPs. r The revised EAL tables have also been arranged in an ascending order of energency classifications according to the Key Words" column for the event. -

which should increase the useability of the tables. The Big Rock Point plan has also included EALs which relate to loss of shutdown cooling. These two l

. EALs for Alert cnd Site Arca Er.ergency were added in response to a previous i inspection concern, (Inspection Report No. 50-155/87028) which was initiated

, in conjunction with the NRC Integrated Plant Safet Evaluation Progran for Big Rock Point (h0 REG-0828)y Assessment Systeratic 1

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We request that the EAL changes described in this letter be submitted to our office for final review within 90 days of the date of this letter. At that time we will make our final decision on the acceptability of these emergency plan changes.

Please be reminded that 10 CFR 50.54(q) requires NRC appron1 of any changes to your plan which may decrease the effectiveness of the plan. However, if your safety review indicates no decrease in emergency preparedness effectiveness, then changes can be made without prior NRC approval. In all cases, you must furnish copies of each proposed char.ge to the NRC in accordance with 10 CFR 50.54(q). Also, any changes to the Emergency Plaa Implementing Procedures should be made in accordance with the requirements of 10 CFR Part 50, Appendix E, Section V (Implementing Procedures).

In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter will be placed in the NRC Public Document Room.

If you have any questions concerning this letter, please contact Mr. Jaines P. Patterson of my staff at (312) 790-5536.

Sincerely, Vf Aq~

L. Robert Greger, Chief Emergency Preparedness and Radiological Protection Branch cc: Mr. Kenneth W. Berry, Director Nuclear Licensing Thomas W. Elward, Plant Manager DCD/DCB (RIOS)

Licensing Fee Management Branch Resident Inspector, RIII Ronald Callen, Michigan Public Service Commission Michigan Department of Public Health W. Travers, EPB, NRR W. Weaver, FEMA, RV kf*

RI!! f o' RIIL/,k RIII R 4W Patterson/mb

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