ML19290F682

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Informs Commission of Directors Denial Re Suspension of Plant Operations in Light of Volcanic Activity at Mount St Helens.Recommends Effects of Activity on Evacuation Be Considered in Conjunction W/Required Emergency Planning
ML19290F682
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 09/15/1980
From: Malsch M
NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:
Shared Package
ML19290F683 List:
References
FOIA-92-436, TASK-CA, TASK-SE SECY-A-80-138, NUDOCS 8009290452
Download: ML19290F682 (117)


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Cn June 3, 1980, the Alliance request was refer-red to the NRC Staff for consideration under 10 cu,,

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the Acting Director, NRR denied the request.

The Director briefly addressed the two kinds of problems posed by Mt. St. Helens, i.e.

1) the effects of volcanism on the Trojan site and the operation of the reactor, and 2) the effects Of volcanism on evacuation ability for the area sur-rounding the Trojan Plant.

The Director's deci-sion is primarily based on a report on potential volcanic hazards prepared for a Licensing Ecard proceeding in April 1978, long before the Mt.

St. Helens eruption.

Notwithstanding three exceptions listed in his denial, the Director believes that the report remains an accurate assessment of the suitability of the Trojnn site.

The three exceptions are: 1) underestima-tion of the volume of debris associated with a potential mudflow; 2) failure to include a discussion of volcano-induced earthquakes; and

3) a statement that historical data indicates that the volcano has been substantially more active in the 19th century than in the 20th century.

'dhile admitting that the massive May 13, 1980 eruption exceeded that envisioned by the NRC and the U.S.

Geological Survey, the Director concluded that the effects on the plant site of this recent eruption (including mudf1ows, earthquakes and ashfall) have been minimal.

The decision notes that volcanic-induced earth-quakes have been small and apparently have not been felt at the Trojan site.

The plant is designed to safely withstand seismic levels many times greater than those generated by the volcanic-induced earthquakes.

The Direu-tor also states that mudflows in the Toutle, Kalama and Lewis River Valleys have not compro-mised the safety of the plant.

Ashfall at the plant from the recent eruptions has been slight.

The 1973 study enclosed.11th the Director's decision concludes that ashfall at the Trojan site would be minimal because the pre-valling winds blow fror west to east, that is, away from the plant.

(The Trojan site is ecuthwest of Mt. St. Helens.)

Although no complete or forral

3 reanalysis has been made, the Staff has been in contact with numerous state, government agency and university scientista cince the eruption, and NRC Staff representatives visited the Trojan site and environs on June 18, 1930 to assess the safety cf Trojan.

The Director concludes, based on the pre-eruption evaluation of volcanic phenomena as well as on an assessment of the volcanic effects since March 20, 1970, that this Trojan site remains suitable from a volcanic hazards standpoint.

The problem of evacuation under conditions resulting from volcanic activity is discussed only in the context of severe ashfall condi-tions.

The decision states that severe ashfall conditions can cause transportation problems similar to those produced by road icing or heavy snowfall.

The Director acknowledges that seeking shelter as opposed to evacuating "would have to be given greater weight under ashfall conditions, depending on its (sic) severity."

However, he further states that "[3]eek_ng shelter in homes is an effective protective measure under most circumstances."

He then continues-

"Beyond about five miles, sheltering followed by relocation within several hours is essentially as effective as immediate evacuation.

'dithin five miles, sheltering is still an effective protec-tive measure.

Under ashfall conditions, consideration would have to be given to limiting the evacuation area, depending on the exact circumstances.

This would reduce the difficulty of evacuating those persons exposed to the greater risk.

Therefore, if an accident occurred in com-bination with transportation difficulties due to severe volcanic ashfall, effective prott etive measures can still be imple-mented, albeit with greater difficulty.

The probability of these two events cccur-ing simultaneously is, however, extremely low."

4 ile find no abuse of discretion in the Director's denial.

The three noted exceptions to the April 1978 evaluation seem to be adequately explained.

Although the May 13, 1930 eruption did exceed that envisioned by the NEC and the U.S. Geological Survey, it does not appear that the earlier safety evaluation of the Trojan plant was entirely dependent on a particular postulated eruption.

The earlier safety evalua-tien was not premised on the low probability of an eruption.

The underestimation of the volume of debris associated with a potential mudflow does not seem to affect the earlier safety evaluation which depended on the fact that any mudflows would flow down river valleys that do not impinge on the plant and that mudflows in the relatively flat terrain near the plant would move very slowly.

Also, the seismic design of the plant is based en a large postu-lated earthquake that would produce accelerations many times greater than those induced by the recent eruption.

The Director's conclusions en evacuation are a little more troublesome.

It is conceded that effective protective measures would be more difficult under severe ashfall conditions but concluded that the probability of an accident and an eruption occurring at the same time is extremely low.

It strikes us that shculd Mount

30. Helens remain active ever the next few years, the possibility of a simultaneous erup-tion and serious plant accident may be more credible.

The problem of effective protective measures under severe ashfall conditions should be examined more closely next year when the plant must be evaluated for compliance with the new emergency planning regulations.

Ir addition, the Director could consider problems of evacua-tien posed by volcanic conditions other than

ashfall, e.g., mudflows, flocds, landslides.

We do not believe that the Director abused his discretion denying relief at this point in time.

5 Recommendation:

Commission approval of Director's decision, and issuance of staff requiremer.3 memc reccmmending staff consideration of evacuation problems due to volcanic activity of Mcunt St. Helens, in the evaluation of the Trojan plant for compliance with the new emergency planning regulations.

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':artin G. Malsch Deputy General Counsel Commissioners' ccmments should be provided directly to the Office of the Secretary by c.o.b. Monday, September 9,1980.

Commission Staff Office comments, if any, should be sucmitted to the Commissioners NLT September 22, 1980, with an information copy to the Office of the Secretary.

If the paper is of such a nature that it requires additional time for analytical review and corrcent, the Commissioners and the Secretariat should be apprised of when coments may be expected.

Distribution:

Commissioners Commission Staff Offices EDO Secretariat

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"" LEAR REGULATORY CC:"~I55 ION SEFORE THE ATOSi!C SAFETY A.'!D LICE! SI:!G ECARD In the Matter of PO?.TLAND GENERAL ELECTRIC COMPANY, )

Decke: flo. 50-344 ET AL.

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(Proposed Amendment to Facilitv

)

Operating License NPF-1 to Perbit (Tecfan Nuclear Plant)

)

' Storage Pool Modificatien)

AFFIDAVIT OF RICHARD S. !icMULLEN STATE OF MARYLNID

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COUNTY OF MONTGCMERY

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u I, P,fch'ard B. McMullen, being duly sworn, depose and state:

1.. I am a Geologist in the Geoscienc's Branch of the Office of Nuclear Reactor Ragulation, U.S. Nuclear Regulatcry Comission, 'lashington.

D.C.

20555.

2.-

I have prepared the statement of Professional Qualifications attached hereto, and, if called u,pon, would testify as set forth therein.

3.

I have prepared the a'ssessments on landslides and volcanism attached hereto in response to the Atcaic Safety and Licensing Board's Order of January 9,1978 and I hereby certify that the statements made herein are true and correct to the best of my know1 edge.

/ / 2/3 W e ? &

Richard B. McMullen Subscribed & scurn to

- tef:re me this \\am day of A;ril,1978 s

h-S O %.As0

. i"!ary PuDlQ My C:=ission expires: AA 1, R*1%

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48 RTC:!ARD n. Mc.'!ULI.CN PROFESSIONAL QUALIFICATIONS CEOSCIENCES BRANC11 DIVISION OF SITE SAFETY AND ENVIRO:.HENTAL ANALYSIS NUCLEM'. REGL1ATORY CCM:1ISSION I am a geologist in the Ccosciences 3 ranch, Division of Site Safety and Environinental Analysis, Nuclear Regulatory Commission. My present duties in this position include:

(1) the evaluation of the geological aspects of sites for nuclear power generating facilities; (2) analyzing and interpreting the geological data submitted to the NRC in support of applications for construction and operation of nuclear facilities; (3) developing criteria; and acting as consultant to the Regulatory staf f on cngineering and construction atters. After completion of three years in the Marine Corps I attended the University of Florida and graduated in 1959 with a 3.5. degree in Geology.

During =y pro-fcssional employment, I completed correspondence courses in soils engineering and quarrying sponsored by the Army Engineer School at Ft. Belvoir, Va., and short courses in the effects of ground motions on structurcs, and airphoto interpreting.

I am a registered Geologist and Engineering Ccologist in the State of California.

Af ter graduation I worked as a field geologist with the Corps of Enginecra in Florida conducting field geological investigations for flood control structures, levees, canals, military installations, radar sites, and inissile launching complexes.

I evaluated and wrote reports concerning the stratigraphy, geologic structure, groundwater conditions, and foundation engineering aspects regarding these facilities in Florida, Puerto Rico, Bahama Islands, several of the '.* cst Indies Islands, and Pa nama.

In 1963 I was assigned to the Corps of Engineers

-averal District of fice at Cape Kennedy, Florida, first as a stam

,ineering geologist, and later as District Geologist. My duties were to plan, direct and evaluate the results of geological and foundation studies for missile launch rids and associated facilities for the NASA Manned Lunar Landing Program, the Air Force, and the Navy.

I acted as con-sultant to other government agencies and architectural engineers in developing design features of structural foundations, monitored the performance of foundations during and af ter construction, and reco= mended and monitored necessary fntindation treatment techniques such as vibra-flo ta tien, grouting, surc!iarcing, dowatering and compaccion.

I wrote reports on the inve tiga t ions, geology, foundation design, and construction regarding these projects.

In 1967 and 1963 I spent 5 months and 1 month respectively participating in the geological investigations for proposed sea level c.,nal routes in Panama.

The region investigated consisted of co= plex structures of volcanics and folded and faulted sedimentary strata.

Among the tech-niques employed in this study were field geologic mapping, geophysical surveying, bora hole photography, and core borings.

.In 1968, I was

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b transferred to the !'untsville, Alabca Corps of T.ngineers Division which was responsible for t.he siting, design and construction of 15 to 20 (later reducad to 4) safeguard antibalistic =issile installations throughout the United States.

y dutics there were to plan, direct and participate in in cstigations to determine the suitability of these sites for construction of the missile complexes.

I perfor ed geolegical studies and seine soil mechanics work to develop design para =cters for feundations and excavations.

I also served as technical consultant during design and construction to other govern =ent agencies, architectural engineers, and contractors.

I have been a member of, the Regulatory staff since January 1971 and have participated in licensing activities for at least twenty-five nuclear f acilities including Su==er, Nine-Mile Point, Washington Nuclear 2, Febble Springs, and Indian Point.

Thesa activities con-

.sisted of review of the geological aspects of the sites as presented by applie r ts add usually an independent evaluation conducted by a review of the cast pertinent literature, site visits, and conversations with knowledgeable individuals or agencies.

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1.

  • RC Posi f ons Af ter CP dnd OL Reviews In its.Cafety Evaluation Report (SER) for the Trojan site dated Octc_

ber 19, 1970, the staff concluded that " Based on'the evidence provided by the applicant and field observations of our geologists and our GeoloCical consultants, we have concluded that the existing geological structure is acceptable for the construction and operation of the proposed plant at the Trojan site."

The U. S. Geological Survey concluded that, i'the applicant proposes to found all =ajor plant structures in the volcanic rocks.

Boring logs and test data indicate that the rocks are sound and will provide an adequate foundation for the proposed facility." In its SER following the OL review, the staff reaffirmed its originalacenclusiens.

2.

Cyrent Staff Positions It is the staff's position that landsliding in the site area does not present a threat to the Trojan plant.

This conclusion is based en our review of several recent publications on landsliding in the region and the results of geological investigations in the site area including horings, scismic profiling, surface geologic =apping and the geophysical investi-cations that were supervised and evaluated by the Trojan Geophysical

.Wviwry Poned comprised of Dr. Peterson, Dr. Llhite and Mr. Dodd. Tae results of these studies indicate that the i==ediate site area does noe have the characteristics which typify large landslides along the Columbia River.

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2 3.

G. olonv.on! Laoi ranh. eif L.e r" i. I :nn! f i.les in the f:oluchi., River Corte Pal c: (1977) studied several large landslides that have occurred within the Cole =bia River Corge.

These slides were in an area

=

characterized by steep terrain with relief on the order of 1200 ccters, high rainfall (::30 cn/yr.), e::posure of water saturated plastic clay layers under permeable rock masses, and regional dips of rock strata from 5 to 30' into the gorge.

A thick stratigraphic section of the Eocene to Oligocene Chanapecesh formation underlies the area studied by Pal =er.

This for=ation is made up of varied claystone to pebble conglomerate of both sedimentary and volcanic =aterials.

Portions of this rock have been weakened by weathering.

An angular unconformity in the Miocene caused the develop-cent of a zone of soft clay rich saprolite on top of the chanapecosh f o rma tion.

The Miocene Eagle Creek formation overlies the Chanapecosh.

The Eagle Creek is similar in composition to the Ohanapecosh'but is less weathered and contains larger rock fragments.

On the 'a'ashington side of the river, the strata within these formations dip tcvard the Colu=hia Corge, while en the Oregon side they dip away from it.

Basalt overlies the Eagle Creek formation.

River banks were overstcepened as the Columbia River cut through the b a t,a l t into the weak Eagle Creek and Chanapecesh for=aticns.

Most large seale Pleistocene and !!olecene landsliding occurred on the "ashington shore where oversteepened'sicpes intersected the bedding plancs of c:iposed incor:petent rock', which dip to the south into the gorge.

i. esser slides are found on thc.Cregon :5hore where several thousand feet of

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The combination of exposure by crosion of the clays and the weight of the basalt caused squeezing updip of the clays, eventually undermining the basalt and causing large rock falls.(Palmer,1977).

4 Geolony and_Tonournnhv af the Site Bedrock bcncath the Trojan site consists of volcanic rocks of the.

Upper Eocene Coble series.

Boring, seismic, and laboratory test data show that the rock is relatively sound and composed of tuff, flow breccia, tuf f b reccia, agglomerate, and basalt.

3cdding planes within the rock are poorly developed, but those that have been capped generally dip toward the west-southwest or southwest, away from the Columbia River.

Coophysical data indicate that the volcanic rock also underlies the Columbia River cast of the site thus precluding the exposure to crosion of continuous clay strata like those described in the Colombia River Corge (Palmer,1977).

The topography along the river valleys in the site regien is characterized by many steep arcuate features.

The Trojan site is located on a bedrock ridge just cast of one of these steep arcuate features within the Columbia River Valicy.

This valley was subjected to intense flooding during post slacial time (3reta 1969).

It is likely, based on geologic evidence at the site, that the arcuate feature is the result of river.

bank scouring and erosion from rapid flood stage flow through a since-O MbM@ b 6 vj

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abandoned channel of the Columbia ?.iver, rather than landsliding.

Similar abandoned channels were reportad by Piteau (1977) followin3 his study of landslides in the Fraser River Valley in southern British Colu=hia.

Piteau also presented evidence to show that the major single cause of landslides in tha. area was the presence of alluvial fans or earlier landslide debris on the opposite s'ide of the river, which deficceed the river laterally and caused undercutting and oversteepening of slopes.

Such processes are not active at the site.

5.

_B_a.ses for Staff Position Although landslides are evident in the site region, landeliding is not likely to pose a hazard to the Trojan site.

The staff concludes that the Trojan site is not susceptible to landsliding for the following renscas:

1.

Availcele data indicate that the velcanic bedrock in the site area is continue.us from the hills vest of the site, beneath the alluvial valley, through the site ridge, beneath the Columbia River, and on to the 1:ashington side, and is not an active slide block.

2.

Interpretive seisal: profiles shew that the surface of the bedrock bcncath the alluviated channel is s:cothly rounded, as would be expected in a rapidly eroded bedrock channel, and not sharp and angular as onld characterize a relatiecl recent and unstable slide block.

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5 3.

Rock strata bcncath the site and the area around the site on the Oregon shore dip, with relative consistency, southwest or west-southwest. away from the River; and data presented by the applicant indicate that joints and shear zones are either not continuous or dip at secep angles, thus precluding the existence of a potential slide plane sloping toward the river.

Geologic maps of the site vicinity on both sides of the Columbia

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h.

Figure 2.5-16 in the FSAR, which is the Geologic Map of Final Foundations, shows that joints and shear zones are either dis-continuous, dip away from the river, or dip at a high angle such that a projection of that dip would not intersect the river valley.

c.

Correlation of bedding from boring to boring and interpretation of geophysical data show that, locally, bedding planes below founda.

level are generally horizontal or dip away from the river.

d.

On a broader scale, based on geophysical data and surface mapping, the site lies on the eastern flank of a northwest trending syncline within which the bedding dips to the west, away from the river.

Dips of strata beneath the site show no evidence of rotation-of e.

beds as would be expected within a landslide mass.

(,

f.

The (;SCS reviewer examined the excavation for the plant on 1 October,1970, and reported that although no real bedding plancs were visible, some nearly horizontal, crude separations were observed that were consistent with observations cade in natural exposures of these rocks nearby.

4.

3ased on a projection from mapped outcrops, the volcanic rocks underneath the site rest on the Cowlitz formation, which is described by the Applicant as well compacted but sometimes loosely ce=ented sandstones and siltstones.

Sandstones or siltstones are generally less suceptible to landslide development than clays, such as those described (Palmer 1977) as being part of the Eagle Creek and Chana;ecosh formations.

It is possible that there are clay zones in the Cowlitz for:ation beneath the site, either from deposition or weathering. However, the Cowlitz formation was subjected to the same deformation as the overlying volcanics, and bedding planes would likely dip in a westerly direction, away from the Columbia River Valley in contrast to the bedding in other parts of the gcrge where large landslides have occurred.

5.

Aeremagnetic and gravity profies shcw no ancmalous break that might be associated with bedrock sliding.

6.

A major landslide upstream could tenpararily block the Columbia River; hc,.ever, the site intake facility is located at a sufficiently low elevation relative to sea level, that the source of emergency cooling water c.culd not be cut off.

7.

In its report entitled " Geologic Hazards Review Trojan fNclear Power Plant Site Columbia County, Oregon," the Oregon State Department of Geclogy and Mineral Industries concluded that "available geophysical data and geologic information collectively indicate that tiie site area is underlain by continuous bedrock and that deep mass movement is not a factor".

is therefore our conclusion that landslides do not pose a potential threat to the site including the Spent Fuel Fool Facility.

References for Nrt 5. Landslides l

1.

' retz, J. H.,1959, The Lake Missoula #1:.:ds and the Channeled J

i Scabland:

Jour. Geology, V. 77, :o. 5, p. 505-543.

i 2.

Palmer, L.,19/7, large Landslices of the Columbia River Gorge, Oregon and '!asnington, Geological Society of America, Reviews in Engineering Geology, Volume III, pp. 69-83.

3.

Peterson, R. A., J. E. '.!hi te & R. K. C:dds,1972, Geophysical Survey Report Trojan fluclear Power Plant Site; Prepared by the Trojan Geophysical Advisory Board for the U. S. Atomic Energy Camnission, Augus t,1972.

4 Piteau, D. R.,1977 Regional Slope - stability Controls and Engineering Geology of the Frazer Canyon, British Columbia; Geological Society of America Reviews in Engineering Geology, Volume III 1977.

5.

Portland General Electric Ccmpany,1973, Final Safety Analysis Report, Volume 1.

J 6.

Portland General Electric Cor.gany,1969, Preliminary Saf ety Analysis Report, Trojan ::uclear Plant, Volume 1.

7.

State of Cregon Department of Geology and Mineral Industries, 1978, Geologic Hazards Peview Trojan ?;uclear Power Plant Site Columbia Ccunty, Oregon, Cpen File Report 78-1, March 14, 1978.

S.

U. S. Atomic Energy Commission,1970, Safety Evaluation Report Trojan I;uclea r Plant, Docket I;o. 50-344, October 7,1974.

7 9.

U

5. Atomic Energy Ccmission,1970, Safety Evaluation Report by the Division of Reactor Licensing, L'S AEC, In the Matter of Portland General Electric Company, City of Eugene, Oregon, Pacific Power and Light Co., Trojan !!uclear Plant, Cocket flo. 50-344, October 19, 1970.

O L j-3 1

l i

3.

Yolcanism 1.

Staf f Position Af ter CP and OL Reviews and Current NRC Position In its Safety Evaluation Report dated October 14, 1970, following the Construction Per=it review, the staf f concluded that:

"The applicant has evaluated potential lava flows, mud flows, and volcanic ash falls and deter =ined that they would not adversely affect the safe operation of the Trojan reactor. We and our consultants, LSGS, have reviewed the applicant's evaluations.

h'e conclude that the assumptions and evaluation techniques used by the applicant were reasonable and we agree i

vith the applicant's conclusion."

In the Safety Evaluation Report (October 7,19 74), af ter reviewing

' the Final Safety Analysis Report, in support of the application for an operating license, the staff concluded that:

" based on this review, we conclude that investigations conducted since the issuance of our Safety Evaluation Report dated October 19, 1970, have disclosed nothing tha(would alter our original conclusion regarding the suitability of tya' Trojan Plant Site."

Since publication of the SER, new information hEs becoce available. We have reviewed these data and we see no reason to change our original conclusion.

2.

3 asis for the Staf f's Conclusions Following the CP and OL Review During the review for the Trojan site the following potential volcanic hazards were evaluated as to their significance to the Trojan site:

ashfall, =udflows, pyroclastic flow, flooding, and lava.

Crandell and e

6

..11dron (1969) indicate that if one of :he Cascade volcanoes erupts, "we believe that ash erup tions and =udflews are the two greatest hazards."

a.

Volcanic Ash. Ash is made up of fine volcanic particles that have been blevn high into the air by explosions in a volcano. The extent and thickness of ash fallout is influenced by the altitude

~

to which it has been erupted, sizes of the particles, the directions and velocities of the winds, and other =eteorologic conditions.

Mount St. Helens is the closest (33 miles east northeast) and most likely source of ash that could affect the site. The applicant stated in the PSAR that even if the ash fall from the Crater Lake eruption were superi= posed over Mount St. Helens, the resuiting ash fall would not have damaged the plant, nor caused interruption of the cooling water supply.

Crater Lake is located in the Cascade Mountains in southern Oregon and was for=ed by violent eruptions of a volcano O tt. Ma a=a) about 7003 years s.c.

The staff agreed with that conclusion on the bases that :

(1) the site lies near the maxi =ua extent of ashfall when the contours showing the distribution of ash from the Mt. 3Mrana eruptions tecording to

'a'illiams (1942) are superitposed en Mount St. Helens and other nearby volcanoes (PSAR Figure 2.3-15) ; (2) the prevailing winds blow away from the plant tavard th 2 volcano rest of the time and apparently hcve done so for thousands of years; and (3) the source of energency cooling water is the Cole:bia River.

e

L.

Mudflows.

"Mudflevs are = asses of water sa turated reck debris which cove downslope in a canner resembling the flowage of vet co ncr e t e. "

(Crandell, 1976). Mudflows have been know.. to move many tens of kilometers devn valley floors at speeds of 35 km/hr or more (Crandell,1976).

The possibility of a mudflow from Mount St. Helens endangering the site was considered during the CP scage.

The applicant concluded that, "A large mudflow on Mount St. Helens would likely move either devn the Kalaca River Valley or the Lewis River Valley.

The =outh of the Kalama River is close to the Trojan site, but on the opposite side of the Columbia River.

It does not seem credible that a debris flow down the Kalama would even reach the Columbia River, let alone that it could block it.

If it reached the Columbia River, its probable worst ef fect would be to muddy the river deenstream as the Columbia removed and diluted the flow of debris e=ptying into it.

The slopes are so flat at the point where the Kalama discharges into the Columbia that a mudflov e:< tending tha t far would be moving very slowly." The staff also concluded that rudflows did not constitute a hazard to the plant.

c.

Floods.

Ficods can be caused by melting of snow on the flanks of a volcano.

These fleedwaters can carry large amounts of rock debris which can be deposited many kilometers from the volcano.

An analysis of the flooding potential due to volcano eruption was

-4 nada by PCI during the CP stage of the licensing process.

The worst case situation was failure of dans and reservoirs along the Lewis River.

It was concluded that flooding from the Lewis River reservoirs would not raise the Columbia River enough to inundate the plant.

A similar analysis was not done by the staff; however, the staf f's hydrological engineering analysis showed that the plant was safe from flooding even assuming the failure of upstream dams including Grand Coulee Dam.

Any flooding caused by volcanic activity would be less severe than the failure of upstream dams on the Columbia River.

d.

Pyroclas tic flow.

As defined by Crandell (1976), pyroclast'ic flow is a mass ef hot, dry rock debris that coves rapidly down the flanks of volcances.

Because of the distance that Trojan lies from the nearest velcano, and the topography, pyroclastic flow vas not regarded as a hazard to the site, e.

Lava Flous. According to Crandell (19 76) lava flows generally erupt quitely, but can be proceeded by explosive activity. Lava flows are usually confined to the immediate sicpes and toe of the volcano.

In order for lava to reach the site it cust be highly fluid and o f areat volu a.

This is not characteristic of "ount St. Helens and there is no evidence that lava frc this volcano reached the e

, Colu=hia River.

For these reasons lava flows were considered not to present a hazard to the Trojan site.

3.

Variation of Volcanic Activity in the Pacific Northwest The staff finds no evidence indicating that there has been a recent increase in activity of Cascade volcanoes.

Evidence is that future activity will continue much as it has in the past 10,000 years.

The volcanoes nearest to the Trojan site:

Mt. St. Helens, Mt. Rainier, I

and Mt. Hood are considered active volcanoes.

The available evidence indicates that activity has been essentially constant though episodic for at least the last 10,000 years. Historic data show that Mount St. Helens was substantially more active during the 19 th Century than during the 20th Cent try.

The enclosed figure is a compilation of known activity of several Cascade volcanoes including.those most significant to the Trojan site.

The illustration is base ~d on data published by several investigators.,vhich was presented in Portland General Electric's report entitled " Volcanic Hazard Study, Potential for Volcanic Ash Fall, Pebble Springs Nuclear Site, Gilliam County, Oregon."

It can be seen from this illustration that Mt. Rainier and Mt. Hood have underg:ne sporadic activity for at least the last 10,000 years and Mount St. Helens for 4,000 years.

This type of activity is expected to continue in the future.

"orldwide data on plate tectonic activity support this interpretstion.

The volcanic activity is related to processes at the plate boundary in o

- this regi:n. Data indicate that plate tectenic activity in the L' nit ed States Pacific ::orthwest is either continuing at a relatively sica rate as co: pared to ::st tectonically active regions around the world, or has s topped co=pletely.

This would explain the relative inactivity of the Cascade volcances, when ccepared to world wide data.

For exa=ple, in the vicinity of the Aleutian Trench, where the Pacific Plate is actively subducting beneath the Alaskan Plate, volcanoes have erupted far core frequently historically and with greater violence than in the U. S. Pacific !!orthwest.

It is not possible to absolutely rule out that Mt. Hood, Mt. Rainier, or Mt. St. Helens could experience similar eruptions like those that for:ed Crater Lake. Crater Lake was created after violent eruptions o f Mt. "a:a:a ab out 7000 years 3.C.

Houever, such an occurrence is considered to be vary unlikely within the next few centuries (Crandell and :allineaux,1975).

It would represent a complete change in activity frem that deconstrated during the last 10,000 years for Mt. Hood and Mt. 22inier.and 4000 years for l'ount St. Helens.

Such an eruption at oce o f these volcanoes occurring si=ultaneously with the wind blewing toward the site is extremely renote.

Therefore it is re=senable to assuna that the cors t events that have occurred in the geologic past at a specific volcano could occur there again.

, It is_ the staff's position that any increase in volcanic activity that is postulated, based on a study of the activity of the Cascade volcanoes for the past 10,000 years is not likely to present a hazard to the Trojan site.

k'e believe that there will be no increase in activity based on the experience of the past 10,000 years.

Evidence from the plate tectonic theory supports this position.

4.

Data Subsecuent to the SER's Considerable additional studies have been made of the volcanic hazards of the Pacific Northwest since publication of the Safety Evaluation Reports. Many of these studies have been conducted in regard to the siting of nuclear power plants, such as the Washington Public Power Supply System (WPPSS) Nuclear Project 3 and 5, the Puget Power Skagit site, and the Portland General Electric Pebble Springs site.

The data included in the reports supporting license applications for these sites are compilations of data from many investigators.

The USGS has published studies of volcanoes in the Pacific Northwest, among which are volcanic hazard assessment naps (Crandell,1976 and Mullineaux, 19 76).

The analysis of volcanic hazard for the WPPSS 3 and 5 site, which is 80 miles from the nearest volcano (Mt. Rainier and Mount St. Helens) indicated that only ash could affect the site.

It further showed that less than 2 inches of ash would fall at the site even if the assu=ption is =ade that a Mt. Macama type eruption occurred at Mt. Rainier or Mo un t S t. Helens.

-S-Based on a reconnendation frca the USGS, Tu;et F:wcr pestula:ed that a mudflow sinilar to the Osceola r.edfice fres Mt. Rainier could occur at Mt. Eiker, which is about 22 niles east of the Skagit site.

The analysis showed that such a mudflew would not adversely affect the site. Ashfall is believed to be the only forn of cruption that poses a direct ha:ard to the Skagit site (USGS,1977).

The Skagit site is located about 56 =iles from Glacier Peak, the nearest volcano with an explosive his tory. Based on the superposition,of the 1912 Kat=ai Alaska eruption on Glacier Peak, about 2 inches of ash would fall at the site. The Applicant assumed a maximun ash accumulation of 6".

The s taf f and the USGS concluded that this was a conservative approach.

Unlike the 'a7PSS 3 and 5, Skagit and Trojan sites, the Pebble Springs site is located cast and downwind of the Cascade volcanoes.

During the reviee of the volcanic hazard for the Pebble Springs site, it was o'tr position, and that of the U. S. Geological Survey, that a conservative and reasonable es timate of a maxi =um potential ash fall at the site shculd be codeled af ter the Yn ash layer which was erupted from Mt. St. Helens be tween 3,000 and 4,000 3.C.

This analysis resulted in the assumption of a thickness of 81/2 inches of uncompacted ash at the site, which is located 80 =iles and 105 miles east of Mt. Hood and Mount St. Helens respectively.

Since publication of the SER's the USGS has published 2 Volcanic Hazards Maps (Crandell,1976 and Mullineaux, 1977). The former designates :enes in the state o f '.ashington within

9 which specific volcanic hazards are possible.

The latter shows volcanic hazard zones in the western United States.

The USGS also open filed a report entitled Potential Hazards from Future Eruptions of Mount St.

Helens Volcano, R&:hington (Crandell and Mullineaux,1976).

5.

I=nact of Subsecuent Data on original Conclusions Based on the data that the staff is aware of, which has come to light since the CP & OL proceedings, the only form of volcanic eruption that could directly affect the Trojan site is dsh fall.

However, new infornation has become available regarding several of the other potential hazards.

These will be addressed first, followed by a discussion of ashfall.

Crandell (1976) and Figure 2.5.1S of the WPPSS Nuclear Project No. 3 Prelininary Safety Analysis Report, which is based on data presented by Crandell (1973), shows mud flow deposits just north of Longview,

.'ashington in the Cowlit: River Valley.

During its evaluation of this phenomenon PGE concluded that because of the distance from the volcano, and consideration that the intersection of the Cowlit: and Columbia Rivers was located downstream from the plant there was no potential hazard to the Trojan plant. Crandell (1976) also shows a

~

potential mudflow hazard within the Kala =a River Valley extending to about 8 miles from its intersection with the Columbia River.

This does not present a threat to the Trojan site.

Much larger mudflows have occurred in the region such as the Osceola mudflow from Mt. Rainier, m.

, which t_s used as a codel for the =axinum pessible sudflow during the Skagit site rerir..

However, since Mount St. Helens is a relatively young and unal:ered volcano, one vould not expect su:h large quantities of potential =udflev naterial to be available on its flanks as on those of the o*_ der altered volcanoes like Mt. Rainier and Mt. Baker.

According to C ardell and Mullineaux (1976), "The absence of an appreciable areunt of clay in nudflows from Mount St. Helens suggests that large areas of hydrothermally altered rock did not exist on the volcano in the past; nor are they present today.

For this reason,

=udflows as large as the larges t from riount Rainier volcano (Crandell, 1971) are not ~_i~uely to occur in the foreseeable future at Mount St.

Helens." Because ef the distance from the Trojan site to the volcano, the nature of the intervening topography, the site being outside of the tudflow ha:ard zone specified by Crandell (1976), and the youthfulness o f Mount S t.

Helens, we consider our earlier conclusion

..at mudflows do not constitute a threat to the Trojan site, as being still valid.

Crandell (;9 5) shows the potential for volcano induced floeding at the Kalans nd levis Rivers. As stated earlier, flooding fron these sources would le less than the assusption of failure of upstrean dans on the Colushis ?.iver.

The site is considered to be safe from such events.

. The distribution and thickness of ash deposits east of the Casc:Je volcanoes are relatively well documented, at least those that originated within the last 10,000 years. The distribution of ash to the west of the volcanoes is not well documented, partly because the prevailing winds blow costly toward the east, therefore, most ash has been trans-ported in that direction; and partly because investigations have not been conducted west of the volcanoes to the extent that they have to According to Crandell (1976) "No siinificant amount of the east.

tephra has fallen in the western sector beyond the base of the source volcano during the last 4,000 years at Mt. St. Helens, or during the last 10,000 years at the other large volcanoes in 5.'ashington." Crandell (1976) and Mullineaux (1976) selected the respective tephra hazard

enes west of each volcano to be 25% as great as those in the eastern sector, although the few ash beds known to exist west of their source vents are less than 10% of the distance that similar beds extend east of the source vents (Mullineaux 19 76).

This number is not completely arbitrary as it is based on the knowledge that not only do the prevailing winds blow to the east cost of the time, but on the rare occasions when they are blowing to the west, velocities are significantly less.

This is demonstrated by at;2ched tables 3 and 4 from Crandell and Mullineaux (1976).

The Trojan site is near the outer beundary d.signated as zone 3 by Mullineaux (1976), and described as an area suoject to 5 cms or more

. of ash from a "large" eruption sinilar to the '::unt St. Helens eruption about 3,400 years cgo.

The site is located in an area designated by Crandell (1976) as one of very low to lew potential hazard to kncun

~

human life and health, and one of probable naximum tephra thickness of less than 5 cms. With regard to the spent fuel building, the weight of 5 cm of uncompacted ash on the fuel building roof would i= pose loads well within the design limits of the roof.

(FSAR Table 3.8-2 gives live load design limits for facility roo,fs.)

The staff concludes that infor=ation that has become available since publication of the SER's does not cause us to alter our original conclusior.s that the site is suitable from a volcanic hazards stand-point including the spent fuel pool.

6.

Conclusiens a.

It is the staf f's position that there is no present increase in volcanic act '-ity in the Cascade volcanoes. Available evidence d

indicates that activity has ~aeen relatively consistent over the past 10,000 years.

The historic record shows that !!ount St. Helens was far more active during the 19th Century than during the 20th Century.

Future activity is expected to be similar to that which has occurred during the past 10,000 years.

A very large eruption, like the Crater Lake eruptions, of one of th. larger Cascada volcanoes cannot be ccapletely ruled out.

However, such an occurrence sinultaneous with high altitude winds blewing toward e

e se

- the site is cons!dered to be extre=ely re=cte.

Any increase in volcanic activity that is postulated, based on the activity of the Cascade volcanoes for the past 3",000 years is not likely to present a hazard to the site.

b.

Because the Trojan site was ~ own to be safe from a more severe hydrologic event (failure of upstream da=s on the Colu=bia River, including Grand Coulee Dam), floods caused by volcanic activity will not present a hazard to the site.

(

Due to the distance of the Trojan site from the Cascade volcanoes c.

and the tocography, pyroclastic and lava flows do not pose a threat to the site.

d.

Mount'St. Helens is a young, unaltered volcano; therefore, large

-quantities of potential =udflow material are not likely to be avail-able on its flanks. We conclude that mudflows are not likely to threate e site.

e.

Ashfall is considere represent the greatest potential h'azard in this part of the Northwest.

It is u._ 'ely that any ash will fall on the Trojan Plant because the prevailing winds ' v away from the plant and toward the volcano; and even during those rare t...

when

'N they blev toward the plant, velocities are significantly lower.

Superposition of the ash distribution from the Mt. Mazama erupticas Je dount St. Helens would not adversely af fect the safe shutdown

apabil1~ty of the site.

14 -

f.

In its !! arch IS,19 78 report to the State Departnant of Energy entitled "Ceologic Ra:ards Review Trojan Nuclear Fo er Plant Site, Columbia County, Oregon," the State of Oregon Department of Geology and Mineral Industries concluded that "no new evidence has come to light to require modification of conclusions regarding volcanic hazards as they are presented in the FSAR."

g.

The Applicant committed in the SAR's to take the necessary steps to mitigate the effects,of a volcanic eruption including shutting down the plant.

References in ite=e (a) through (e) to the " site" include the spent fuel pool.

Eased on the above, the staf f reaffirms its conclusion following the licensing reviews, that the Trojan site, including the spect fuel pool, is suitable from the volcanic harcrds point of view.

e y

eoeew

-e

=**=*

so

REFERENCES FOR PART B - VOLCANISM 1.

Crandell, D.R.,19 71, Postglacial lahars from Mount Rainier volcano, Washington U. S. Geological Survey Professional Paper 677, 75 pages.

2.

Crandell, D. R.,19 76, Preliminary Assessment of Potential Hazards from Future Volcanic Eruptions in Washington, U. S. Geological Survey Misc. Field Studies Map MF-774.

3.

Crandell, D. R.,1973, Map Showing Potential Hazards from Future Eruptions of Mount Rainier, Washington, USGS LSp I-836.

4.

Crandell, D. R., and H. H. Waldron,1969, " Volcanic Hazards and the Cascade Range," Of fice of Emergency Preparedness, Region Seven, Geologic Hazards and Public Problems Conference Proceeding, Santa Rose, Calif. (May 27-28, 1969).

5.

Crandell, D.

R., and D. R. Mullineaux,1976, Potential Hazards from Future Eruptions of Mount St. Helens, Volcano, Washington, U. S.

Geological Survey Open File Report 76-491.

6.

Mullineaux, D. R.,1976, Preliminary Map of Volcanic Hazards in the 48 conter=inous United States, MF-786.

7.

Portland General Electric Company,1973, Final Safety Analysis Report, Volu=e 1.

8.

Portland General Electric Company,1969, Preliminary Safety Analysis Report, Troje.n Nuclear Plant, Volume 1.

9.

Puget Sound Power and Light Company,19 73, Preliminary Safety Analysis Raport Skagit Nuclear Power Project, Volume No. 4.

10.

Shannon & Wilson, Inc.,19 76, Volcanic Hazard Study Potential for Volcanic Ash Fall Pebble Springs Nuclear Plant Site, Gilliam County, Oregon, Revision 1, iby 17,19 76, Report to Portland General Electric Company.

11.

U. S. Atomic Energy Commission,1970, Safety Evaluation Report by the Division of Reactor Licensing, US AEC, In the Matter of Portland General Electric Co., City of Eugene, Oregon.

Pacific Poser &

Ligh t Co.

Trojan Nuclear Plant, Docket No. 50-344, October 19, 1970.

12.

U. S. Atomic Energy Commission, 1974, Safety Evaluation Report Trojan Nuclear Plant, Docket No. 50-344 October 7,19 74.

eem e6

- em 4 4+

4 m-rM

) '

g 13.

U. S. Geolegical Survey,1977, Status of Revier ?uset Sound Power and Light Co:pany, Skagit Nuclear Power Proj ect. Units 1 & 2 Project No. 514, Skagit County,1:ashington, N?.C Docket Nos.

50-522 and 50-523.

14.

State of Oregon Department of Geolog and Mineral Industries,1978,

" Geologic Hazards Review Trojan Nu: lear Power Plant Site Colu=bia County, Oregon," Open File Report 78-1, March 14,1978.

15.

U. S. Nuclear Regulatory Commission,1973 Supple:ent No. 3 Safety Evaluation Report related to construction of Pebble Springs Nucl ear Plants Units 1 and 2, Docket Nos. 50-514 and 50-516.

16.

Uashington Public Power Supply System, 1974, Preliminary Safety Analysis Report WPPSS Nuclear Project No, 3, Volume 3.

~

17.

Willians, H. A.,1942, "The Geology of Crater Lake National Park, Oregon," Carnegie Institution of k*ashington Publication 540, 1942.

9 e

8 3

Table 3.--ftean winti s pemis, in knots _(1 knot = 1.15 mi/h or 1.85 km/h), at various a.ltit -

B.ned on 20-year record (T95W1970) at Quillayute, Wash. (Winds Alof t Summary of tin "r Weather Service, U.S. Air Force, available from the flational Climatic Center, Ashe.ilie, fl.C.)

F R 0ii-- -- -

N tlME flE EllE E

ESE SE SSE S

SSW SW WSW W

WfiW f;W titiu TOWARD---

S SSW SW WSW W

WilW tiW titlW N

NNE ttE ENE E

ESE SE SSE Approx.

alt.

(m) 3,000 18.6 16.3 14.8 11.5 11.6 12.4 13.8 18.1 24.2 25.7 25.4 24.2 23.5 21.8 22.4 21.2 C

4,300 26.7 21.7 18.7 15.1 13.7 15.5 18.2 21.5 27.2 30.7. 31.3 31.1 31.0 29.4 29.6 28.5 5,500 33.2 27.8 27.9 18.5 17.6 16.8 20.8 22.9 32.2 36.6 38.6 38.3 38.4 37.3 35./ 36.9 9,100 48.6 43.8 36.5 29.9 30.2 26.4 32.2 38.0 46.8 52.5 55.9 55.4 56.2 50.8 51.6 53.9 12,200 40.9 31.5 30.3 14.9 19.7 16.9 18.8 28.0 35.8 43.8 48.5 50.3 50.9 46.2 46.3 45.4 16,200 20.1 12.4 11.3 6.3 6.4 9.0 9.7 13.8 15.5 21.1 23.7 25.8 26.2 25.1 23.7 21.4 Avera9e-- 31.4 25.6 23.2 16.0 16.5 16.1 18.9 23.7 30.3 35.1 37.2 37.5 37.7 35.1 34.9 34.6

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TERA Docket File TNovak ACRS (16)

Gray File-ORB #3 NSIC NRC PDR (w/inc.)

Glainas PPAS GreenTicketFile-L PDR (w/inc.)

J01shinski BSnyder ORSF3 Decket No. 50-344 ORB #3 Rdg JHeltemes,AE0DBGrimes EDO Rdg RAClark RVollmer JDiCamillo NRR Rdg PMKreutzer Dross ON WDircks CTrammell SHanauer HRDenton OELD RMattson EGCase CMiles, PA JJackson DEisenhut AFerguson RPurple GErtter (ED0-9103)

Mr. Eugene Resolie RTedesco I&E (3)

Trojan Decomissioning Alliance Schilk, SECY (5) (80-1154)*

3926 Northeast 12th Street CStephens, SECY (W/ incoming)

Portland, Oregon 97212 LBickwit, GC

  • JMurray, ELD *

Dear Mr. Rosolie:

ARosenthal, ASLAB ASLBP This is written in response to your request on behalf of the Trojan Decoirissioning Alliance that operation of the Trojan Nuclear Plant be suspended on the basis of recent volcanic activity at Mount St. Helens in Washington State. Your request has been treated under 10 CFR 2.206 of the Cccc:ission's regulations.

For the reasons stated in the attached decision, your request is denied.

A copy of this decision will be filed with the Secretary for the Comission's review in accordance with 10 CFR 2.206(c).

Copies will alsc be filed in the Cor.ission's Public Docurent Room at 1717 H Street, N.

W., Wasnington, D. C.

20355, and in the local public docu; cant room at the Colur.bia County Courthouse, Law Library, Circuit Courtroom, St. Helens, Oregon 97501.

As provided in 10 CFR 2.206(c), this dccision will become the final action of the Comission 20 days after issuance unless the Comission elects on its own motion to review this decision.

Sincerely, J\\

{dsonG. Case, Acting. Director Office of Nuclear Reactor Regulation

Enclosure:

Director's Decision Under 10 CFR 2.206 cc w/ enclosure:

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b' 0D-80-26 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of

)

Docket No. 50-344

)

PORTLAND GENERAL ELECTRIC COMPANY

)

(10 CFR 2.206)

(Trojan Nuclear Plant)

)

DIRECTOR'S DECISION UNDER 10 CFR 2.206 By telegram dated May 29, 1980, the Trojan Decomissioning Allianu of Portland, Oregon, requested that the Comission suspend operation of the Trojan Nuclear Plant on the basis of potential dangers posed by recent volcanic activity at Mount St. Helens in Washington State.

On June 3,1980, the Comission referred this request for action to the NRC Staff for con-sideration under 10 CFR 2.206 of the Comission's regulations.

For the reasons stated in this decision, the Alliance's request is denied.

The potential irpact of volcanic activity on the safety of the Trojan facility was investigated thoroughly by government geologists (Atomic Energy Comission and the U. S. Geological Survey) before the plant was allowed to be constructed and again before the operating license was issued.

This in-vestigation and reassessment of volcanic-related hazards has continued as attested by the enclosed affidavit which was filed with the Atomic Safety and Licensing Board in the Trojan spent fuel pooi expansion proceeding in Ap ri l, 1978.

Although this report was filed prior to the recent volcanic activity, it is with few exceptions considered an accurate assessment today.

Ex-ceptions to the report include (1) the underestimation of the volume of debris associated with a potential mudflow, (2) exclusion of a discussion cf volcano-induced earthquakes, and (3) the statement that historic data

. indicates that the volcano has been substantially more active in the 19th century than the 20th century.

Notwithstanding the above exceptions, the report's conclusion that the Trojan site is suitable from a volcanic hazards point of view remains accurate.

The recent massive eruption of May 18, 1980 exceeded that envisioned by the Nuclear Regulatory Comission and by our advisors, the U. S. Geological Survey.

Neverthelets, the effects of the recent volcanism (mudflows, earth-quakes and ashf all) at the Trojan site have been minimal.

Mudflows in the Toutle, Kalama, and Lewis River valleys have not compromised the safety of the Trojan plant. Volcanic-induced earthquakes have been small and have neither been felt nor recorded instrumentally at the site. Ashfall at the Trojan plant resulting from the May 25, 1980 eruption has been slight (not exceeding 1/8 of an inch) and fell at the site in the form of a nuddy rain or mist.

The only other indication of ash occurred on April 29, 1980 when a thin coating of the ash was noted at the Trojan site.

According to University of Washington seismologists, the volcanic-

~

induced earthquakes mentioned previously have not exceeded Richter Magnitude 5.1 and have been concentrated in an area roughly coincidental with the volcano crater which is 35 miles northeast of the Trojan plant.

None of the larger events (Magnitude 5.0 and above) have occurred closer than 35 miles to the plant.

For the most part, the volcanic earthquakes have occurred at shallow depths and have consequently been felt only in the immediate vicinity of the seismic event.

However, there have been unconfirmed reports of volcanic-related earthquakes (originating at

. Mount St. Helens) being felt in the Longview-Kelso, Washington area, roughly five miles north of the Trojan plant.

Apparently those feeling the tremors were located in areas where soil overlies bedrock.

The plant is designed to safely withstand seismic levels of 0.259 peak ground acceleration.

This corresponds to earthquake levels many times greater than those generated by the volcano-induced earthquakes.

We have been in constant contact with numerous state, governmental agency, and university scientists since initiation of earthquake activity and subsequent volcanic activity in the vicinity of Mount St. Helens on March 20, 1980.

This surveillance, accumulation of information, and assessment will continue as long as the volcano remains active.

In addition, representatives of the NRC staff visited the Trojan site and environs on June 18, 1980 for the specific purpose of assessing the safety of Trojan in light of the recent volcanic activity.

Our conclusion, based upon an evaluation of volcanic phenomena prior to construction, coupled with an assessment of the effects of the activity beginning March 20, 1980, is that the Trojan site remains suitable from a volcanic hazards viewpoint.

As to evacuation under severe ashfall conditions, this can cause transportation problems somewhat similar to those produced by road icing or heavy snowfall.

The first protective action to be taken following a radiological emergency at a nuclear facility is to alert the public to take shelter and await further instructions.

Seeking shelter in homes is an effective protective measure under most circumstances.

A decision to evacuate is ased on an assessment of the potential injury to the

. public from the accident and aust be balanced against the risk to the public from the evacuation itself and against the conditions that prevail at the time.

Seeking shelter would have to be gis.. greater weight under ashfall conditions, depending on its severity.

Beyond about five miles, sheltering followed by relocation within several hours is essentially as effective as immediate evacuation.

Within five miles, sheltering is still an effective protective measure.

Under ashfall conditions, consideration would have to be given to limiting the evacuation area, depending on the exact circumstances.

This would reduce the difficulty of evacuating those persons exposed to the greatest risk.

Therefore, if an accident occurred in combination with transportation difficulties due to severe volcanic ashfall, effective protecting measures can still be implemented, albeit with greater difficulty.

The probability of these two events occurring simultaneously is, however, extremely low.

Based on the foregoing, your request on behalf of the Trojan Decocmissioning Alliance that operation of the Trojan Nuclear Plant be suspended on the basis of the recent volcanic activity at Mount St. Helens is denied.

N

./EdsonG. Case,ActingDirector Office of Nuclear Reactor Regulation I

Enclosure:

Affidavit of Richard B. McMullen Dated at Bethesda, Maryland this 13th day of August, 1980

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.1 4-0871u85150 05/29/80 ICS IPMRNCZ CSP WSHB 5032826377 HGM TDRN PORTLAND OR 197 05-29 1026P EST r-CHAIRMAN UNITED STATES NUCLEAR REGULATORY COMMISSION

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WASHINGTON DC 20555

'l (THE FOLLOWING IS A COPY OF THE HESSAGE SENT TO PRESIDENT JIMMY CARTER, WHITE HOUSE, a'ASHINGTON, DC 20500)

WE HERE5Y REQUEST THAT YOU ORDER THE IMMEDIATE CLOSURE AND SUSPENSION OF ALL OPERATIONS OF THE TROJAN NUCLEAR POWER PLANT >HICH IS LOCATED ONLY 34 AIR MILES FROM MOUNT ST HELENS, WE HAVE REVIEaED DOCUMENTS

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SUBMITTED BY THE OPERATORS OF TROJAN AND THE NUCLEAR REGULATORY COMMISSION. HENCE WE HAKE THIS REQUEST NOT OUT OF BLIND FEAR BUT FROM A REAL CONCERN, THE aEIGHT OF THIS TESTIMONY IS THAT AN ERUPTION OF

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MOUNT S'

'ELENS IS HIGHLY IMPROBABLE AND IF AN ERUPTION WERE TO OCCUR THE liq u H000 0F IT CAUSING AN IMPACT ON TROJAN IS " EXTREMELY REMOTE" THE IMPROBABLE AND REMOTE ARE OCCURRING, DO NOT WAIT FOR A l

NUCLEAR DISASTER TO PROVE THE REMAINING ODDS WRONG. THESE STUDIES HAVE ALSO FAILED TO ADDoESS THE DIFFICULTY OF EVACUATION UNDER PRESENT CONUITIONS, EMERGENCY SERVICES ARE ALREADY SPREAD THIN, ROADS C

AND BRIDGES ARE aASHED OUT, TRAVEL BY CAR IS HAZARDOUS OR IMPOSSISLE DUE TO ASM FALL-0UT. WE IN THE PACIFIC NORTHWEST 00 NOT WISH TO LIVE

  • ITH THE ADDITIONAL BURDEN OF NL'CLE AR FALL-0UT, THE VOLCANO AND ITS l

HAZARDS AkE ENDUGH, YOUR IMMEDIA.TE ACTION ON THIS MATTER IS OF THE UTM ST I M P O R T A N C E,-

C TROJAN DECOMMISSIONING ALLIANCE

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