ATTACHMENT D

|

r

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

| In the Matter of ) I ) Docket No. 50-155-OLA | CONSUMERS POWER COMPANY (Spent Fuel Pool ) , ) Modification) (Big Rock Point Nuclear Power ) ' Plant) )

AFFIDAVIT OF JACQUELINE MERTA I, Jacqueline Merta, first being duly sworn, state that the attached questions and answers are true and accurate to the best of my knowledge and belief.

0. .-n , i, ~ . 9' 4> Jacqueline Merta

SUBSCRIBED AND SWORN TO before,yme this /v day of N/WL. , 1983.

, .% )?lat )61 I*h Notary Public

rHMM3 G. La0'ANCE. .. .r, rsie. enre,yyx e..i;nty, ,, ., , _ , ...... ,. I

l

8304220531 830419 " gDRADDCK 05000155 PDR I

,.

| |' ;

' , Ql. Please state your name, occupation and background. 1 A1. My name is Jacqueline Merta. I am the Executive Director j of the Charlevoix Chamber of Commerce. I have held that 1 ) position since July, 1975. I have been with the Chamber | | of Commerce since May, 1971. I was born and raised in Petoskey, . I have an Associate of Arts degree

from North College. *

As Executive Director, I am responsible for managing the budget and programs of the Charlevoix Chamber of

Commerce. As part of this responsibility, I promote

tourism and attractions in Charlevoix. I provide travel

information to tour groups and individual tourists. We also receive many walk-in inquiries at our office.which is located in the business district of Charlevoix.

I am also active with the Charlevoix Yacht Club. In 1980-1981, I served as Commodore of that club after

holding several other offices in prior years. I am presently on the Board of Directors for the Charlevoix Yacht Club as a past Commodore.

02. What is the purpose of this affidavit? A2. The purpose of my affidavit is to explain my observations concerning the transportation needs of tourists visiting the Charlevoix area.

|

I .

. ! ' . i , t ! -2- i ! i s

Q3. Does Charlevoix attract many tourists? , f I t A3. Yes. Charlevoix is well known as.a resort area. We | , receive tourists year round but the summer and fall , i ! ! attract the most numbers. Charlevoix does not attract as : ! many winter tourists as surrounding areas since ! t c ' Charlevoix does not have any skiing facilities except for j Mt. Mesauba which is basically a beginner's hill.

Mt. McSauba does not have rental equipment and is used

primarily by local youths. Tne nearest major ski f f ;

{ facility is Boyne Mountain which is about twenty miles' ! southeast of Charlevoix. However, we do attract people | who are interested in cross-county skiing since we do | | 4 i have several groomed trails. {

> I : | | ; Q4. What are your observations concerning the transportation i 4 needs of tourists visiting the Charlevoix area? | | * j A4. Most tourists to the Charlevoix area arrive and depart by | | their own automobile or a rental automobile. An automo- i bile is virtually essential for anyone visiting the-area

since there is no public transportation for the area i except for one taxi cab. (There is a County Transit

System but it primarily serves the needs of county

residents.)

Many people visit the area by boat. Some boaters come and stay for the season and live on board their boats.

I .

- -- _ _ _ _ _ mw e EJ R < a d ye oj o p-- ) y 3g G e e { e egw e i s go - - - -e m--a -,o an smm#. men *

| ' . _

-3- ~

_

. Virtually every one of these people also bring an

automobile to the area for their use. Charlevoix also has 44 transient boat slips which are used by boaters staying for up to two weeks. (Approximately 8 of these

are used by seasonal or permanent residents.) Some of the boaters making use of the transient slips also have.

access to their own car or a rental car. ~

Many tour groups visit the Charlevoix area, but these groups always arrive by a charter bus which always stays with the group. The buses stay with their respective

. groups at their lodging (if they stay overnight) and transport them to restaurants and attractions. - As with

other tourists, it is essential that tour groups.have their own means of transportation since there is no other I way for them to get around. This is especially true of j any ski groups that stay in Charlevoix. Their only means of getting to the ski facilities would be by their own

bus.

Charlevoix is served by one bus line, the North Star Bus Line. Presently, there is only one daily passenger stop

in Charlevoix and it comes only from the south. Any | ' person wishing to head south would have to go to Petoskey' or some other neighboring community to catch a southbound bus. I talked with the local agent for North Star Bus

I - ______i

~ . r I i, | -4- >a i Line and he told me that the bus is used mainly by

residents and the children of residients going to or from | ) ' i i college. However, he did remember an occasion where ' ! someone arrived by bus and asked for a motel. |

Some people arrive in Charlevoix by small private'or charter aircraft at the Charlevoix Municipal Airport.

Many of these people are also seasonal residents. Most

of the people arriving by plane either have their own- automobiles which they keep at the airport or they rent a

car.

Although it is possible for tourists to come here without

personal transportation, it is rarely done. To e'njoy Charlevoix and the area, a tourist must have an automo-

bile or charter bus. There is no public transportation

to serve this purpose. It is simply a matter of common

sense that transients would not come to Charlevoix without their own means of personal transportation and it

is my observation that this is true for Charlevoix.

05. If there was to be an emergency evacuation of Charlevoix, what options are there for a boater docked in Charlevoix?

AS. Boaters could leave Charlevoix by their boats to Boyne City or East Jordan by . I have made that

trip myself many times. Lake Charlevoix is an inland

. . . ______- ______- - ' E -.. . - - _ . - - - _y me a .

. .

A

~5- l

lake and there are no obstructions such as bridges between Charlevoix and those cities. Boaters could also go out into if they can get under the draw bridge

(which I understand will remain down during an emergency).

.

4

(

J

l |

\

-- _ _ . _ _ . . . ______. _ _ . . . ______. ______. ______. _ _ _ . ______. ______- ______- _ _ _ _ _ - ______- _ - ______- _ _ _ .

. . .

addressed by AECM-81/103, dated April 10, 1981, is no longer a licensing requirement for GCNS and should be removed from GGNS SER Sections 13.3.2.8 and III.A.2.2 compliance requirements. MP&L maintains communication with the Jackson Area National Weather Service if backup meteorological data is necessary.

"

4.2 Use of NRC/ Industry /0wners Group Guidance Documents | 4.2.1 BWR Owners Group Reports - MP&L was an active member of the BWR Owners Group on Reg. Guide 1.97 which developed a position report on each of the variable requirements addressed by | Revision 2 of the guide. This report represents significant input by the BWR representatives and consultants to determine

; the appropriateness for both the general and specific BWR requirements for post accident monitoring. The BWROG concurs with the intent of R.G. 1.97, Revision 2 to ensure that necessary and sufficient instrumentation exists at - each nuclear power station for assessing plant status and ; ~ environmental conditions during and following an accident, as required by 10CFR Part 50 Appendix A and General Design criteria 13, 19, and 64 Implementation of R.G. 1.97 i requirements is recommended except in those instancas in which deviations from the letter of the guide are justified technically and when they cen be implemented without disrupting the general intent of the Guide. > MP&L will use this BWROG position report as a basis for initial determinatien of general post accidcut monitoring acceptability, but will specifically justify any deviations from the regulatory guide based on the srecific need at GGNS.

' The BWR Owners Group also established an ICC committee as an outgrowth of the R.G. 1.97 committee. A study of ICC detection in BWRs was commissioned in response to the NRC request as , reflected in the requirements of R.G. 1.97 and TMI Action Item II.F.2. The results of the report indicates that the relationship between reactor water level and fuel cladding temperature under accident conditions demonstrates that water level is a conclusive indicator of the adequacy of core cooling. MP&L will continue to work with the owners group and the NRC to reach a mutual agreement ICC detection.

4.2.2 Revision 3 to Regulatory Guide 1.97 - Revision 3 of R.G. 1.97 has been issued for comment by the NRC based on the NRC's own interval review, commissioned studies, and industry input. Even though this document holds no present licensing standing within the NRC for response, it does represent the latest NRC guidance. MP&L will also consider this document in our position review efforts. 4.2.3 NUTAC Accident Monitoring Instrumentation Report - The NUTAC for Emergency Response Capability will also be addressing accident monitoring instrumentation for respor.se to Supplement

-15- !

I _ _ _

_ - ______. --_ -- _ _ _ _ _ - - _ _ _ - . - - . . . . . _ . - - . . - . - . . - . .

- .

UNITED STATES OF AMERICA

, NUCLEAR REGULATORY COMMISSION

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

In the Matter of ) ) CONSUMERS POWER COMPANY ) Docket No. 50-155-OLA ) (Spent Fuel Pool (Big Rock Point Nuclear Power ) Modification) Plant) )

CERTIFICATE OF SERVICE I hereby certify that copies of LICENSEE'S REPLY

TO COMMENTS OF INTERVENORS AND NRC STAFF CONCERNING THE SEPTEMBER 14, 1982 DECISION were served on all persons listed below by deposit in the United States mail, first-

class postage prepaid, this 19th day of April, 1983.

Peter B. Bloch, Esquire Atomic Safety and Licensing I Administrative Judge Board Panel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel , Commission ! U.S. Nuclear Regulatory Washington, D.C. 20555 Commission | Washington, D.C. 20555 Atomic Safety and Licensing | Appeal Board Panel Dr. Oscar H. Paris U.S. Nuclear Regulatory Administrative Judge Commission Atomic Safety and Licensing Washington, D.C. 20555 Board Panel U.S. Nuclear Regulatory Docketing and Service Station Commission Officc of the Secretary Washington, D.C. 20555 U.S. Nuclear Regulatory Commission

Mr.. Frederick J. Shon Washington, D.C. 20553 Administrative Judge i Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

I ! - ______. _ . _ . _ _

* . -2-

Richard J. Goddard, Esquire Judd Bacon, Esquire Counsel for NRC Staff Consumers Power Company | U.S. Nuclear fiegulatory 212 Avenue | Commission Jackson, Michigan 49201 i Washington, D.C. 20555 Ms. Christa-Maria Richard G. Bachmann, Esquire Route 2, Box 108C Counsel for NRC Staf f Charlevoix, Michigan 49720 U.S. Nuclear Regulatory Commission Mr. James Mills Washington, D.C. 20555 Route 2, Box 108 Ferbert Scmmel, Esquire Urban Law Institute Ms. JoAnne Bier Antioch School of Law 204 Clinton 2633 1Gth Street, N.W. Charlevoix, Michigan 49720 Washington, D.C. 20555 l Mr. John O'Neill, II t I Route 2, Box 44 Maple City, Michigan 49664

c/) . Victor G. Copeland '

I

. 1

1