ML19340D325

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Requests Revision of Emergency Plan to Include Description of Potential Complicating Factors Caused by Earthquakes Which Might Initiate Accidents.Concerns Should Include Availability of Support to Onsite Staff
ML19340D325
Person / Time
Site: Rancho Seco
Issue date: 11/24/1980
From: Reid R
Office of Nuclear Reactor Regulation
To: Mattimoe J
SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
NUDOCS 8012300276
Download: ML19340D325 (3)


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Occket No. 50-312 a

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<n Mr. J. J. Mattimoe c.W Assistant General Manager and M]

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Chief Engineer "5

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P. O. Box 15830 Sacramento, California 95813

SUBJECT:

EFFECT OF EARTHQUAKES ON EMERGENCY RESPONSES AT RANCHO SECO

Dear Mr. M'attimoe:

We are requesting that your enargency plan be revised to include a descrip-tion of potential complicating factors which might be caused by earthcuakes which either initiate or follow the initiation of accidents.

Factors te be considered for your facility plans should include the impacts due to pctential disruption of comunications networks and transportation routes.

Your concern should be the availability of resources and personnel to aug-cent onsite staff, transit tc and among emergency response facilities and that equipment to be used in such circumstances (gements should be made such communications with offsite organizations. Arran such as helicopters, off-road vehicles, etc.) will be dedicated for use by the plant even under pres-sing and competing needs such as offsite rescue missions.

The procedures to be used to detennine the protective actions recommended to offsite authorities should be revised to incorporate consideration of earthquake effects offsite. Evacuation time estimates also should be revised to incorporate consideration of earthquake activity.

The revisions to the protective action detemination methods and evacuation time estimates should be done in coordination with offsite officials responsible for protective action decision making and implementation.

We are requesting FEMA to review the adequacy of State and local capabilitics with respect to response during earthquakes. A copy of our memo to FEMA is enclosed. The response to this concern should be incorporated in a revised site Emergency Plan submitted in accordance with the provisions of the revised 10 CFR Part 50 of the Comission's regulations.

Sincerely,

/// b /.

l Rifoert W. Reid, Chief Operating Reactors Branch #4 Division of Licensing

Enclosure:

11/3/80 Memo cc w/ enclosure: See next page 8012300 $

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Sacramento Municipal Utility District ccw/ enclosure (s):

David S. Kaplan, Secretary and Christopher Ellison, Esq.

General Counsel Dian Grueuich, Esq.

6201 S Street California Energy Commission P. O. Box 15830 lill Howe Avenue Sacramento, California 95313 Sacramento, California 95825 Sacramento County Ms. Eleaner Schwart:

Board of Supervisors California State Office 827 7th Street, Room 424 600 Pennsylvania Avenue, S.E., Rm. 201 Sacramento, California 95314 Washington, D. C.

20003 Business and Municipal Department Docketing and Service Section Sacramento City-County Library Office of the Secretary 523 I Street U.S. Nuclear Regulatory Commission Sacramento, California 95814 Washington, D. C.

20555 Resident Inspector Director, Criteria and Standards P. O. Box 48 Division Fair Oaks, California 95628 Office cf Radiation Procrams (ANR 453)

U. S. Environmental Protection Agency Dr. Richard F. Cole Washington, D. C.

20460 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U. 5. Environmental Protection Agency Washington, D. C.

20555 Region IX Office ATTN: EIS COORDINATOR Mr. Frederick J. Shon 215 Fremont Street Atomic Safety and Licensing Board San Francisco, California 94111 Panel U.S. Nuclear Regulatory Commission Mr. Robert B. Borsum Washington, D. C.

20555 Sabcock & Wilcox Nuclear Power Generation Division Elizabeth S. Bowers, Esc.

Suite 420, 7735 Old Georgetown Road Chairman, Atomic Safety and Bethesda, Maryland 20014 Licensing Board Panel U.S. Nuclear Regulatory Commission Thcmas Baxter, Esq.

Washington, D. C.

20555 Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Mr. Michael R. Eaton Washington, D. C.

20036 Energy Issues Coordinator Sierra Club Legislative Office Herbert H. Brown, Esq.

1107 9th Street, Room 1020 Lawrence Coe Lanpher, Esq.

Sacramento, California 95814 Hill, Christopher and Phillips, P.C.

1900 M Street, N.W.

Atomic Safety and Licensing Board Washington, D. C.

20036 Panel U.S. Nuclear Regulatory Commissicn Helen Hubbard 1,'ashington, D. C.

20555 P. O. Box 63 Sunol, California 94536 e-n.

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Sacramento Municipal Utility District Atomic Safety and Licensing Appeal Scard Panel U.S. Nuclear Regulatory Commission

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20555 California Department of Health ATTN: Chief. Environmental Radiation Control Unit Radiological Health Section 714 P Street, Room 498 Sacr.amento, California 95814 l

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November 3,1980 MEMORANDUM FOR: John McConnell, Assistant Associate Director for Population Preparedness, FEMA FROM:

Brian K. Grimes, Program Director, Emergency Preparedness Program Office, NRR

SUBJECT:

REQUEST FOR FEMA ASSISTANCE TO REVIEW EFFECTS OF EARTHQUAKE AND VOLCANIC ERUPTION ON STATE / LOCAL EMERGENCY PLANS As we have discussed, in the course of our review of licensed utility emergency plans, volcanic eruptions and catastrophic earthquakes have emerged as two issues of high public interest. To insure that these issues are being adequately addressed, we request that FEMA review the State and local planning efforts for the areas around California nuclear power plant sites and the Trojan site with respect to the complications which might arise in the event of extreme natural phenomena and how the e can best be addressed in the planning process.

In conjunction with the Trojan plant evaluation for compliance with the new NRC emergency planning regulations, the Comission has directed that the problems of effective protective measures and evacuation-during or soon after volcanic eruption (giving due consideration to the possible effects of severe ashfall, mudflows, floods, and landslides) be closely examined.

In this regard, we are requesting the licensed utility to revise its emergency plan to explicitly address the possible problems associated with an eruption. This will include considerations of site access during an emergency, assured comunications and appropriate revision of the J

evacuation time estimates used in protective action detenninations. The Oregon State Department of Energy, has already addressed the feasibility l

of implementing effective protective measures during an eruption (enclosure 1).

The earthquake issue has particular relevance to nuclear plants in California (i.e., Diablo Canyon, Humboldt Bay, Rancho Seco and San Onofre).

We understand from the FEMA news release of September 29, 1980 that FEMA will lead a team consisting of personnel from Federal, State and local agencies to accelerate efforts towards improving the state of readiness to cope with potential major earthquakes in California.

In this regard l

we request that FEMA include in its evaluation of offsite emergency plans, a qualitative evaluation of complicating factors which might be caused by earthquakes for California nuclear power reactor sites. Specifically,

2-John McConnell such evaluation should include the impacts on State / local emergency plans due to potential disruption of communications networks and evacuation routes.

In this regard, we are requesting the affected licensees to revise their emergency plans to explicitly address the possible problems associated with an earthquake to include the type of potential complications discussed above for the Trojan facility.

Thank you for your assistance in these matters.

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LABOR & INDUSTRIES BUILDING, ROOM 102. SALEM, OREGON 97310 PHONE 373-4040 September 11,1980 Dr. Beth Packer Portland Chapter of Physicians for Social Responsibility 1715 S.E. Pine Portland, OR 97214

Dear Dr. Packer:

At the Energy Facility Siting Council.(EFSC) meeting on August 8,1980 you resubmitted a petition from the Portland Chapter of Physicians fer Social Respcasibility (PSR) requesting that the site certificate for Trojan be imediately revoked due to volcanic activity of Mt. St.

Helens. The resubmitted petition was identical to the one you submitted at the July 11, 1980 EFSC meeting except for some additional signatures.

The original submittal was responded to by a letter from the EFSC Chairman to you on July 14, 1980. That letter stated that based on review of an Oregon Department of Energy (ODOE) staff report on this matter, EFSC and the 000E Director had determined that no breach of warranty, f ailure to cogly with EFSC rules or site certificate conditions, or clear and imediate danger to the public exists. A copy of the 000E staff report was provided to you.

In your oral presentation resubmitting the petition you contended that several issues have not been adequately considereo by EFSC and 000E.

The EFSC Chairman and the 000E Director have evaluated your verbal contentions and conclude that they do not provide a substantive basis for either reycking Trojan's site certificate or ordering curtailment of operations. Specifically, no breach of warranty, f ailure to comoly with EFSC rules or site certificate conditions, or clear and immediate danger to the public was identified. Also, we do not believe any rules or regulations of the Nuclear Regulatory Comission (NRC) have been violated. Recent actions by NRC to deny similar petitions support this belief. The basis for this decision are documented in the attached report. We will discuss any coments that you have on this issue at our meeting with PSR on September 17, 1980.

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September 11, 1980 Page Two At the two EFSC meetings where you submitted the petition, you requested immediate action, but you also called for a scientific approach to address this matter. As the EFSC Chairman stated to you on August 8, 1980, these demands are not consistent.

It is unreasonable to pose several technical questions and then demand immediate and carefully considered answers and actions. We urge that if you have further concerns on this matter that you review them with our staff and others knowledgeable in the particular areas of concern. If you have substantive concerns that are not resolved it would then be appropriate to submit them to us for consideration. Such submittal should document in writing your concerns and the basis for them.

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EFSC/000E Response to Additional PSR Concerns Regarding Potential Effects of Mc. St. Helens Eruptions on Trojan Sackcround At the April 1980 Energy Facility Siting Council (EFSC) meeting the Oregen Department of Energy (000E) staff presented an evaluation of the potential effects of a volcanic eruption of Mt. St. Helens on the Trojan The 000E staff concluded that Trojan had been adequately Nuclear Plant.

designed for volcanic hazards and that appropriate precautior,ary measures have been taken or will be implemented such that volcanic activity in conjunction with operation of Trojan does not present an undue risk to the public health and safety. Mt. St. Helens subsequently began experiencing major eruptions on May 18, 1980.

11, 1980 EFSC meeting Dr. Seth Packer of the Portland Chapter At the July of the Physicians for Social Responsibility (PSR) petitioned EFSC to reycke the Trojan site certificate based on contentions that Trojan was not adequately designed to withstand the effects of volcanic eruptions and that the Trojan emergency response plan was inadequate.

In a letter to Dr. Packer on July 14, 1980, the EFSC Chairman stated that volcanic activity at Mt. St. Helens was being closely monitored to ensure that the safety of Trojan was not degraded. Regardis.g the PSR petition, he stated that EFSC had reviewed a detailed report prepared by 000E staff on this subject. The 000E staff report concluded that Trojan had been prcperly designed to prevent eruptions of Mt. St. Helens from causing an accident at Trojan. EFSC concluded that the 000E staff report adequately Further, the EFSC concluded that no respended to the PSR contentions.

breach of warranty or failure to cocply with EFSC rules or site certificate conditions had been identified. The letter also noted that the 000E Director concluded that a clear and immediate danger does not The Chairman then encouraged Dr. Packer to provide EFSC with any exist.

further specific, information she might have that ODCE staff did not adequately consider in the report.

27, 1980 to EFSC and the 000E Director, Dr.

. In telegrams dated July Packer again requested that Trojan be ordered immediately shut down due to volcanic activity of Mt. St. Helens.

In a letter to Dr. Packer dated Jcly 28,1980, the 000E Director stated that af ter consultation with the EFSC Chairman, both EFSC and ODOE concluded that the telegrams offered no substantive basis for reaching a conclusion different from the earlier EFSC and CDOE conclusion that no breach of warranty, f ailure to conply with EFSC rules or site certificate conditions had been identified o*

that a clear and immediate danger to the public does not exist.

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At the August 8,1980 EFSC meeting, Dr. Packcr resuhitted the original PSR petitten with additional signatures. The written petition centained no further contentions. However, in her oral presentatien, Dr. Packer stated five reasons fer resuMitting the petition. These reasons were related to alleged inadequacies in the 000E staff repcrt cf July 14, 1980 and the manner in which it was prepared, and failure of the EFSC to do its duty by allowing the CDCE Directer to unilaterally decide on the petition.

Dr. Michael Wall, PSR and Barbara LaMentecella, concerned citi:en spcke in support of Dr. Packer's cencerns.

Cenclusien EFSC and CDCE have reviewed each of the PSR concerns and conclude that there is no substantive basis for reaching a cenclusion different than that previously reached by EFSC and 000E. On August 5 and 13,1980, MRC rescended to several similar petitions and concluded that "the Trojan site remains suitable from a volcanic ha:ards viewpoint." In a 13, 1950, Jchn Beaulieu, Deputy State Geologist, discussion en August stated that both Ocnald hull, State Geolcgist, and he continue to believe that the assessment of volcanic hazards asstned during Trojan design remains valid and censervative in view of the actual volcanic activity experienced and therefere they centinue to suppert the earlier EFSC/000E conclusien.,

The Each of the P5R concerns are discussed separately in detail below.

follcwicg discussion also refers to the ODCE staff re;crt of July la, No infermation has been devele:ed that would cause 000E to change 1950.

that re;crt.

EFSC did not do its duty in evaluating the PSR petition but Cententien 1:

ratner allowed the 000E Director to unilaterally decide on the petition.

As stated at the July 11, 1980 EFSC meeting, EFSC requested the ODCE staff to prepare a detailed repcrt decrenting the earlier cenclusions The EFSC Chair:an stated the re;crt wculd be prior to startup of Trejan.

distributed to all EFSC mexers and that he would consult with each i

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=e=er prior to res;cnding to PSR. The 000E staff coccleted and l

celivered the re:crt to the EFSC me-ters on July 13, 1980. The EFSC i

Chair =an consulted with the other EF50 meters on July 14, 1980. In a letter to Dr. Packer dated July 14, 1980 the EFSC Chairman stated: "We appreciate your concerns and that ycu articulated specific areas that We believe the staff has rescended to them in their required review.

Regarding breach of warr'.nty or failure to coccly with EFSC recort."

"Our reading of ycur rules or site certificate cenditiens, he stated:

petiticn did not identify any allegations that such conditions exist."

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In rescense to the PSR telegrus of July 27,1980, the 000E Directer "I have reviewed this matter again with Brother Wilscn. Ycur stated:

telegrus, while reaffirming ycur earlier concerns, offer no substantive basis for reacning a different conclusion."

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At the August 3,1980 EFSC meeting, the EFSC Chairman and other EFSC members clearly stated to Dr. Packer that they had reviewed this matter and reached the same decision separately from the decision of the 000E Director.

The above discussion demonstrates tnat the EFSC reached its own conclusion on the petition.

Contention 2: The 00CE staff report of July 14, 1980 only addressed a simultaneous eruption and radiological accident. PSR intended the following cases be addressed:

A radiological accident caused by an eruption, a.

b.

A radiological accident occurring simultaneously with, but not related to, an eruption.

Evacuation around Trojan complicated by ashf all, mudflows, and c.

flooding.

The 000E staff report of July 14, 1980 stated that evacuation during or immediately af ter a major volcanic eruption with consequences in the vicinity of Trojan could be difficult but that appropriate protective This action through either evacuation or sheltering would be possible.

statement applies regardless of whether a radiological accident is caused by an eruption or occurs simultaneously with, but is unrelated to, an eruption.

Regarding ashf all, local and state law enforcement and transportation officials in Washington who experienced the effects of the May 18, 1980 eruption state that although not desirable, it would be possible for people to travel in automobiles on roads during or immediately after a These officials likened the effects on road conditions of heavy ashfall.

the May 18, 1980 eruption to be equivalent to or less severe than the effects of recent ice storms.

. Regarding mudflows and flooding, these effects may also complicate The basis for this statement evacuation but do not make it impossible.

results from an evaluation of the worst-case volcanic induced flood (which has wider area effects than mudflows). For the worst-case l

volcanic induced floods, (resulting from failure of all three dams on the Lewis River) local portions of Highway 30 and Interstate 5 south of Trojan and large portions of the Longview and Kelso areas could be Hcwever, Highway 30 and Interstate 5 north of Trojan and flooded.

In Highway 411 out of the Longview/Xelse area would remain open.

adoition, most of the smaller roads leading away from Trojan would remain Therefore', if flooding and mudflows were to occur, they would not open.

As stated in the 000E staff report of July 14, foreclose evacuation.

1980, to minimize the probability and consequences of this worst-case flood, the water level of at least one of the reservoirs contributing to such flood has been lowered.

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Based on the'above discussion, evacuation during or imediately after a J

major volcanic eruption with consequences in the vicinity of Trojan could However, the discussion of evacuation be difficult but not impossible.

under such circumstances does not reccgnize the small probability of a l

simultaneous accident and eruption or that other protective actions, such as sheltering, may be more appropriate than evacuation. For example, for a single puff release of radioactive noble gases, sheltering would probably result in less radiation exposure than evacuation under such circumstances since sheltering would provide less contact time and possibly better shielding.

14, 1980 the need to As discussed in the 000E staff report of July evacuate for radiological reasons during or immediately after an eruption is extremely unlikely for the following reasons:

Technical evaluations by 000E, NRC, and PGE of the potential 1.

effects of an eruption upon Trojan conclude there should be no adverse effects upon plant operation.

In the event an eruption does affect Trojan operation, the plant 2.

can be safely shut down. 000E and NRC monitor plant operations to ensure appropriate actions are taken.

In the event of an eruption that has severe effects in the 3.

Trojan area, PGE may decide to shut down Trojan due to the lack of need for power since industrial users may not be operating or difficulty that Trojan employees may experience in driving to

. the plant.

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In the event that a radiological accident occurs at the same

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time or immediately after an eruption, all specific details at that time would be evaluated to determine what, if any, protective actions will be taken. The specific details include l

j the amount, type, and duration of radioactivity released from the plant (if any); the stability of plant conditions and i

likelihood of future releases; meteorology; population density i

in direction of release; and road conditions.

If protective actions are required, the actions will be chosen on the basis of

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For the unlikely conditions postulated by PSR, minimum risk.

sheltering would probably be chosen as the protective action in lieu of evacuation since:

evacuation could be conplicated by' the effects of an j

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eruption upon transportation, a.

sheltering is an effective protective action to reduce b.

radiation exposures, in general, because of ashf all, people would already be c.

indoors with the windows and doors closed.

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Contention 3: The ODCE staff report of July 14, 1980 was hastily drawn up ano only the 000E Director made the decision on the PSR petition.

This contention is similar to contention 1 and therefore the above response applies. Further, 000E, EFSC, NRC, and PGE began evaluating this subject up to nearly two months prior to the first major eruption on May 18,1980.

Contention 4a: The 00CE staff report of July 14, 1980 only considered evacuation complicated by ashfall. The complicating effects of mudflows, flooding, food control, and fires need to be considered. The annual evacuation drill should simulate these effects.

This contention is similar to contention 2 and therefore the above response applies. The control of radioactively contaminated foodstuffs could be coglicated by the effects of an eruption. On the other hand, the disruption effects of such an eruption would tend to help prevent movement of contaminated foodstuffs to the market. However, as stated above, a simultaneous eruption and radiological accident (especially one releasing large amounts of radioactivity from the plant that would require large-scale control of foodstuffs) is unlikely. The effects of fires in such an event would probably be small and localized. Further, this risk is always present at any other time.

The annual emergency response drill has in the past sitfulated evacuations. Future drills will include simulation of events which tend to co@licate evacuation and of alternate protective actions, such as sheltering, which may be more appropriate.

Contention ab: The 000E staff report of July 14, 1980 states that during a simultaneous eruption and radiological accident evacuation of people could be difficut. Would evacuation be difficult or impossible?

This contention is similar to contentions 2 and 4a and therefore the above responses apply. Evacuation under such circumstances would be difficult but not impossible. However, even in these extremely unlikely l

circumstances, sheltering would probably be chosen as the protective action since it would result in the least risk and in some cases would be the preferred course of action to minimize radiation exposure.

Contention ac: The 000E staff report of July 14, 1980 states that in the unlikely event of loss of cooling water from the intake structure that adequate cooling can be maintained by backup means. Can adequate cooling be provided for both the reactor core and spent fuel pool simultaneously using the backup meins?

Yes. The statement on page 10 that " adequate ccoling can be provided for a minimum of 165 hours0.00191 days <br />0.0458 hours <br />2.728175e-4 weeks <br />6.27825e-5 months <br /> (nearly a week) by the circulating water system I

and the cooling tower basin" applies to all sir:ultaneous heat sources.

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The FSAR didn't consider the pcssibility that a Contention 4d:

River) could affact the river bottom at downstream river (the Cowlit:What effect does the observed 15-foot decrease in Is it valid to predict the effects Trojan.

have upon the FSAR flooding analyses?of future eruptions when the ri While the FSAR did not consider the possibility that a downstream river could affect the river bottom at Trojan, the FSAR addressed a more severe i

Therefore the case of flooding and nudflows from an upstream river.The FSAR concluded conclusions in the FSAR are valid and conservative.

safe operation of Trojan would not be degraded by volcanic induced flooding and mudflows.

The effect of the change in the Columbia River bottom contour as a result of the May 18, 1980 eruption has been evaluated. This evaluation concludes that the effect upon the flooding analysis and valid.

In general, the Columbia River basin in the vicinity of Trojan has a wide For floods around Trojan, the limiting flood plane (several miles wide). restriction occurs about 2 miles dow The flood plane at Carroll's Bluff at an elevation sufficient to causeThe cross sectional ar flooding at Trojan is greater than 1 mile wide.

at this point has been increased slightly from that asstrned in the FSAR flooding analysis due to ingroved measurements and additional dredging since the FSAR flooding analysis was done in the early 1970's and has been decreased slightly due to deposition of mud and silt from the May 18, 1980 eruption. At the worst time af ter the May 18, 1980 eruption, the cross-sectional area had a conservatively calculated n decreased less than 1%, indicating that the limiting area for flood less than 1%.

remains at Carroll's Bluff.

Dredging since the May 18, 1980 accuracy and therefore are negligible.

eruption has further reduced the magnitude of this effect.

In a discussion on Septenter 5,1980, George Holme, Chief District

  • by them conclude that there is a negligible effect u Also, in the Columbia River due to the observed bottom contour changes.

a discussion on September 5, 1980, Day'd Weiss, Hydrologist, U.S.

In a Geologic Survey, agreed this conclusion appears reasonable. Donald K discussion on Septenter 11,1980, National Weather Service, stated that separate analysis by them support this conclusion.

Regarding the effects of future eruptions on the river bottom contour an flooding at Trojan, it is not expected that subsequent eruptions will 18, 1980 eruption due involve significantly greater effects than the May to the large amount of material removed from Mt. St. Helens during that eruption and the resulting weak spots which would tend to channel future I

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is conducting monthly soundings of the river in the vicinity of Trojan.

EFSC and 000E will require PGE to evaluate the effects of future major changes in the Columbia River bottom contour upon the FSAR flooding analysis.

If the results of the analysis are significantly altered by changes in the river bottom contour, PGE will be required to implement appropriate actions.

PSR contends that the 000E staff report of July 14,1980 Contention Ae:

did not consider internal radiation exposure due to inhalation of ash that can be suspended and resuspended in air.

As discussed on pages 16 and 17 of the 000E staff report of July 14, 1980, 000E did consider internal radiation exposure due to inhalation of Using the highest ash concentrations reported in the Portland area, ash.

000E 000E calculated an initial internal dose rate of 0.0015 mrem / hour.

noted that this dose rate would then decrease to insignificant levels.

This decrease is due to the relatively short half lives (on the order of 30 minutes) of the significant dose-contributing isotopes and therefore the 00CE conclusion applies regardless of whether the ash settles or in continuously suspended in air. 000E noted that use of masks would eliminate this source of radiation exposure.

Contention 4f: The 000E staff report of July 14, 1980 states that during periods of impending or significant volcanic activity, PGE is imediately PSR contends that this is not the case. Specifically, for notified.

changes in seismic activity were detected at 9 a.m., the July 22, 1980 For eruption occurred at 5:13 p.m., and PGE was notified at 5:28 p.m.

August 7,1980 changes in seismic activity were detected at noon, the The eruption occurred at 4:25 p.m., and PGE was notified at 4:32 p.m.

. report states that Trojan has not detected any seismic forces due to The University of Washington in Seattle, 200 miles volcanic activity.

from Mt. St. Helens, has detected such seismic activity. Why doesn't Trojan equipment detect such activity?

The following is the notification chronology for the last two major eruptions:

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Reference

Date, Time Event 7/22/80 10:00 am Series of shallow earth-

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quakes detected

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2:00pm-5:00pm Increasing frequency and l

magnitude of earthquakes

)Washington Depart-ment of Emergency Services (WDES) l

) message to Fed-

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) Emergency (Services

) Division OESD) 5:14 pm Eruption to 45,000 ft.

5:20 pm Trojan notified of PGE(Zimerman) eruption by PGE 5:35 pm Trojan (Taylor) notified 000E Trojan 000E(Dixon) of eruption Log U.S. Forest Service (USFS)

OESD Incident 5:35 pm notified Oregon State Police Report (OSP) and OESD of eruption 8/7/80 1:45 pm USFS notified Trojan of PGE(Zimmerman) l increased seismic activity 2:50 pm Trojan (Yundt) notified 000E Trojan ODOE(Dixon) of potential Log eruption WDES message 4:23 pm Eruption to 44,000 ft.

to FEMA /0ESD 4:28 pm USFS notified OESD of OESD Incident Report eruption USFS notified Trojan of PGE(Zimmerman).

4:30 pm eruption 4:40 pm PGE(Zimerman) notified 000E Trojan 000E(Dixon) of eruption Log l

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Based on the above chronology, PGE is being notified of igending or significant volcanic activity. Oregon is also being notified on a timely basis by at least two separate sources.

Regarding detection of seismic activity at Trojan, the installed instruments are triaxial accelerometers which are designed to detect seismic forces at the plant site as small as 0.01 g.

An earthquake of this magnitude during the day would be felt indoors by many, outdoors by few. At night some people would be awakened. As stated in the 0]CE staff report of July 1980 even though sizeable earthquakes occur ort Mt.

St. Helens, these have not been felt at Trojan due to the localized nature of volcanic seismic forces, the damping effect of the ground between Mt. St. Helens and Trojan, and the apparent sturdiness of the bedrock upon which Trojan is built.

In discussions with John Beaulieu.

Deptuy State Geologist and Dick Couch, Associate Professor of Geophysics, Oregon State University, both men stated they are familiar with the type of equipment installed at Trojan, consider it appropriate for its intended function, and believe that it should not have detected any of the seismic forces from Mt. St. Helens.

Regarding the instrumentation at the University of Washington in Seattle, Beaulieu and Couch stated that a system of seismographs are installed throughout Oregon and Washington, including some in the vicinity of Mt.

St. Helens, for which the measurements are transmitted to Seattle. These instruments have a sensitivity two orders of magnitude less than human detectability (down to 0.0001 g). Therefore they would expect the University of Washington i~n Seattle to detect seismic forces that Trojan does not. The U.S. Geological Survey has a similar system which feeds information to Menlo Park, California.

Contention Sa: PSR is concerned that the evacuation plan for the ten-mile radlus around Trojan has not yet been approved by the NRC.

On August 19, 1980, NRC published a rule to become effective on Noventer 3,1980 that specified requirements for emergency response plans. The rule stated that within 60 days of its effective date, revised emergency response plans meeting these requirements must be submitted to NRC. The NRC must find these plans provide reascnable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. By April 1,1981 these revised plans must be implemented.

Any deficiencies that still exist at that time must be corrected within four months.

Prior to adoption of this rule there were no specific requirements or NRC approval needed for emergency response plans.

While the plan and agreements as they exist today provide an adequate framework for responding to a Trojan radiological emeroency revisions are being made to comply with the NRC rule and efforts will continue to make further igrovements.

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PSR is concerned that the control building modifications Contention 5b:

liave not yet been conpleted.

The control building modifications are being made to allow continued operation af ter an earthquake up to 0.15 g.

Currently, the plant is The Atomic Safety required to shut down af ter an earthquake of 0.0S g.

and Licensing Board, NRC, ODOE, and PGE all agree that adequate strength exists for Trojan structures and equipcent so that a safe shutdown condition can be achieved and maintained following a large earthquake up to 0.25 g.

Therefore, the only significance of these modifications is that they will permit PGE to continue operating Trojan during and after larger magnitude Even without earthquakes than they currently are permitted to do so.

these modifications, safe shutdown for large earthquakes is possible.

14,1980 on This issue was addressed in the 000E staff report of July page 5.

PSR is concerned that on August 7,1980 the red zone Centention Sc:

Therefore, Trojan is arounc M:. St. Helens was expandad to 20 miles.If the red zone was expanded only 11 miles away from the red zone.

another 5 miles, Trojan would only be 5 miles away from the red zone.

The size of the controlled access area around the volcano has no direct The controlled access area bearing on the safety of Trojan operatien.

has been periodically adjusted depending on recent or expected volcanic As discussed above, activity and to facilitate ease in ac:ess control.

Trojan is advised of significant or it:;ending changes in volcanic activity and takes. appropriate actions.

Further, the information presented by Pft on the distance between Trojan and the red zone and the change to the red :ene size are not accurate.

In The PSR contention assts::es Trojan. is 31 miles frera Mt. St. Helens, l

actuality, the distance is approximately 34 miles.

Access around Mt. St. Helens is controlled in the Gifford Pinchot

  • National Forest by the U.S. Forest Service (USFS) and in other areas by In a discussion the Washington Depart:nent cf Emergency Services (WDES).

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Paul Stenkanc, Director, Emergency Coordination on August 14, 1980, Center, USFS, stated the following:

On March 25, 1980, access was restricted (i.e., red zone established) above the tinterline on Mt. St. Helens (2 to 3 mile a.

- i radius).

On April 30, 1980, access was rastricted (i.e., red :ene l

b.

expanded) in all of Gifford Pinchot National Forest except the The radius of this restriction was up to 30 Mineral area.

(In the direction of Trojan, the restriction was about miles.

16 miles.)

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On June 4,1980, the restriction was lifted (i.e., red zone c.

reduced) for National Forest land north of Highway 12 (this had no effect on the restriction distance in Trojan's direction).

d.

On July 25, 1980, the restriction was reduced (i.e., red zone reduced) to about 14 miles in all directions. The recreational restriction zone (i.e., blue zone), which permits industrial activity but prohibits recreation, was also reduced accordingly to about 20 miles.

In a discussion on August 13,1980 Ken Olsen, Red Zone Coordinator, WDES, stated the fc11cwing regarding the state-itposed access restrictions (i.e., red zone):

On April 1980, WDES restricted access to permit only permanent a.

residents and emergency workers within 20 miles of Mt. St.

Helens, On July 29, 1980, the restriction was reduced to about 16 miles b.

from the volcano in Trojan's direction to allow access to Lake Merwin.

WDES is currently considering further reductions in the c.

restrictions.

'ctions Based on the above, it is apparent that the access of increased arcued Mt. St. Helens have recently been reduced as stated in the contention.

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