ML20056C330
| ML20056C330 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 05/13/1993 |
| From: | Cross J, Walt T PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-0396, RTR-NUREG-396 NUDOCS 9305190206 | |
| Download: ML20056C330 (37) | |
Text
_____ _ __________ _ ___
su m num um Portland General Bectric Company i!
James E. Cross Vice President and Chief Nuclear Officer May 13, 1993 Trojan Nuclear Plant Docket 50-344 License NPF-1 U. S. Nuclear Regulatory Commission Attn: Document ControlDesk Washington, DC 20555
Dear Sirs:
State and County Comments Received on the Trojan Permanently Defueled Emergency Plan This letter transmits written copies of comments received by Portland General Electric (PGE) from the State ofOregon and Columbia County ori the Trojan Permanently Defueled Emergency Plan. Also enclosed are PGE's respenses to those comments. These items are being provided to the Staff for their use in reviewing the Trojan Permanently Defueled Emergency Plan.
Sincerely, T. D. Walt for J. E. Cross enclosures c:
Mr. John B. Martin Regional Administrator, Region V U. S. Nuclear Regulatory Commission Mr. David Stewart-Smith State of Oregon Department ofEnergy Mr. Kenneth Johnston NRC Resident Inspector Trojan Nuclee Plant 9305190206 930513 PDR ADOCK 05000344 1
F PDR gik 121 SW Salmon Street, Portland, OR 97204 i
503/464-8897
Trojan Nuclear Plant Document Control Desk Docket 50-344 May 13, 1993 i.icense NPF-1 Enclosure State and County Comments Received on the Trojan Permanently Defueled Emergency Plan And PGE's Responses to Those Comments
COIRNRIA C001rry unw:ENCY SERVICES COURTHOUSE, ST. N M S, OREGOK 97051 Phones 397-2100 February 12, 1993 Mr. Tom Walt, General Manager
._--. Technical Punctions Trojan Nuclear Plant 71760 Colu=bia River Highway Rainier, Oregon 97048
Dear Tom,
I am concerned with the time schedule and the process PGE is apparently following to write the new emergency plan for Trojan (as a radiological materials waste storage site).
It appears to me that the logical flow of risk analysis and emergency plan development is "out of syne" and that the time schedule will not allow for ti=ely comments from the state and County before submittal to the NRC p
and EFSC, as I was told was PGE's intent.
V What follows is a chronology of my opportunities to receive and study the draft revised risk analysis and the draft emergency plan:
I received a copy of the draft emergency plan on Thursday, January 28, 1993.
On Wednesday, February 3,1993, I discussed the draft emergency plan with Nick Goevelinger, Rose Bennett, Jim Maza, Jerry Thale and Linda Klein.
I shared with them several concerns I had with the plan, ie, types, need for clarification, and the lack of public infor=ation coordination with the County. I requested a ecpy of the revised risk analysis (on which the enrgency plan is supposed to be based). I was told I would receive that on February 5th or 8th.
I was also told PGE and CDOE wanted us to meet PGE's schedule of submitting the draft emergency plan to the NRC on March 1,1993; that in order to do this PGE war.ted our initial co=ments on the emergency plan by the morning of February lith, and any other comments on February 16th (which was to be the day before it was submitted to PGE's Plan Review Board).
This same group met on February 8.1993, and I received a revised copy of the draft emergency plan. The revised draft emergency plan corrected or dealt with the concerns I had expressed at the February 3rd meeting.
I i
did not receive a copy of the draft revised risk analysis - it was not finished yeti i
February 12, 1993 Letter to Tom Walt Page 2 We were to meet again on February 10, 1993, to develop combined comments regarding the draft emergency plan to be given to PGE the next day.
We decided not to meet - that there was too much to look at and not enough time to adequately respond.
- - _.-- - On February 10, 1993,.I received from Rose Bennett a faxed copy of the draft revised risk analysis.
I was finally able to read that document.
I was surprised to read in the paragraph
" OBJECTIVE" that one of the cbjectives of the risk analysis was:
"The results of this calculation are intended to be used to justify (1) the elimination of offsite emergency planning ef forts if the dose is less than 1 res..."
On February 11, 1993, I discussed the draft revised risk analysis and draft emergsney plan with Rose Bennett and Nick Goevelinger.
I decided there were too many questions, too few answers, and too little time to adequately comment on the draft revised risk analysis and the draft emergency plan prior to its submittal to PGE's Plan Review Board.
I have several concerns with the process PGE is followings
/D 1.
.It appears PGE has pre-determined what the risks will be.
The draft emergency plan states that little or no offsite (State or County) response planning will be needed.
The only offsite assistance may be some communications assistance (as well as continued contract of fire and medical support).
The draft emergency plan appears to have been drafted not only before the draft revised risk analysis was co=pleted, but even before the auther of the emergency plan had an opportunity to read the risk analysis!
One of the stated objectives of the risk analysis is
...the elimination of offsite emergency planning efforts..."
2.
It appears PGE is not or will not consider a full range of possible risks.
At the February 3,1993, meeting, when asked about the possible risk from loss of water in the Spent Fuel Pool and/or terrorist activities my concern was su=marily dismissed with the statement that "...this is not m issue to be concerned with since Security will preclude it from happening."
At the February 8,
1993, meeting we also raised concerns with possible risks during clean-up activities and decommissioning, such as a fire that might spread radioactive contamination. This concern is apparently not to be considered since the " fire plan" will take care of this.
February 12, 1993 Letter to Tom Walt Page 3 3.
The new Fire Plan and new Security Plan apparently will not be ready for consideration at the time the draft emergency plan is submitted to the NRC and EFSC.
PGE may be relying on the existing Fire Plan and Security Plan.
These may be good plans, but when they are changed how are they reviewed and how is the change integrated into what will by then be the new and reduced emergency plan?
4.
PGE's time schedule was too short for me to do anything other than a quick, cursory review of the draft emergency plan.
I had a copy of the revised draft emergency plan for less than four (4) working days (Feb 8-11, 1993) - the assumption was that I was t'o get a first set of conunents to PGE by February.11, 1993.
The "due date" of February 16, 1993, for a second set of comments to the emergency plan was changed.
On February 10, 1993, I was advised the due date would be February 12, 1993, since the draft emergency plan would now be submitted to the Plan Review Board on February 15, 1993 (not February 17th as previously scheduled).
Unfortunately my concerns and questions will not be resnived prior to PGE's Plan Review Board seeing the draft emergency plan, and I assume the draft revised risk analysis.
I had sincerely h e d to have comments to the emergency plan ready for your review prior to its submission to the Plan Review Board.
My efforts (and those of Energy, Health, and Emergency hanagement) have been simply overwhelmed by the material to be reviewed and the time allowed.
I will continue to look over this material and will offer comments to you, hopefully before the end of February.
I would appreciate hearing from you regarding my concerns (1 - 4 above) with the process PGE is following.
Thank you.
sincerely, John T. DeFrance Emergency Services Director
(
CC:
David Stewart-Smith, Oregon Department of Energy Myra Lee, Oregon Emergency Management Division Ray Paris, Radiation Control Section, Oregon Health Division Dale Helmuller, Columbia County Board of Commissioners
(503) 731-4014 FAX (503) 731-4cSI TDD-Nonvoice (503) 731-4031 February 18,1993 DEPARTMENT OF HUMAN RESOURCES Mr. Tom Walt, General Manager Technical Functions HEAT.TH DIVISION Trojan Nuclear Plant 71760 Columbia River Highway Rainier, Oregon 97048 e
Dear Tom:
I have made a cursory review of the Licensing Document Change Request (LDCR) for content only.
Because of PGE's desire to move rapidly on this issue i will try to give it as much attention as I can, as fast as I can. Clearly that will cause sacrifice to detail and an occasional oversight.
The contents of the LCDR is based on two accident scenarios. No attention has been given as to the cause, only the potential results. That's fine. But I would like to know the results of incidents involving:
1.
Earthquakes, beyond the "1947 Olympia, WA design basis" earthquakes that are now known to occur in the region. The combined effect of a resulting Columbia River flood.
2.
Windstorms, power outage.
3.
Lightning strikes, power surge, fires.
4.
Accidents during cleanup including fires, spills and contaminated and injured workers in various locations.
5.
Criticality accidents.
6.
Sabotage or terrorism. This could be an explosive device placed under a number of fuel assemblies outside of the fuel storage area or possibly a fueled fire under several assemblies.
I'm sure this is a short list, some issues of which have been already answered and can be addressed with a small statement. Others, that because of a low probability of occurrence combined with low commurity impact will not be considered in the county or state emergency plan.
However, we clearly need to work together to develop a complete " Vulnerability Analysis" based on the new status of the facility. Since FEMA has a great deal of experience in developing Vulnerability Analysis, it might simplify and expedite things if we invited Richard Donovan to help us with the final report. Mr. Donavan's intimate knowledge of the area and the Trojan facility could prove invaluable.
Sincerely,
""c'","n
- 21 ngf3hropnM h, Ponland, OR 97232 (503) 731-4030 Emergency Myra Lee. EMD; David Stewart-Smith, ODOE (503) 252-7978 TDD c:
Emergency John DeFrance. Columbia County ES numa Ray Paris. OHD: Richard Donovan, FEMA
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tortland General Electric Company Trojan Nuclear Plant 71760 Colu bla River Hay.
Rainier. Oregon 9748 (503) 556-3713 March 3,1990 TDW-062-93TF Nick Goevelinger Health Physicist Oregon Health Division 800 NE Oregon Street, No. 21 Portland, Oregon 97232 Dear Nick;
SUBJECT:
Troian Closure Process Thank you for your letters dated February 16 and 18,1993 concerning the Trojan c:osure process. These letters expressed concern about the rate at which PGE was proceeding with the closure process, including not having a completed hazards analysis before the l
emerEency P an was drafted and the disposition of equipment purchased by PGE to support the State and County response to an accident at Trojan.
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1 appreciate the efforts you and the other members of the Oregon Trojan Steering Cemittee have put forward to review the Trojan defueled emergency plan. I understand that it has appeared that PGE prepared the draft plan prior to performing a hazards analysis. You had no way to know that PGE talked with and received several analyses from other defueled plants, or that the analyses showed offsite doses from a permanently defueled plant were well below that which required offsite protective actions. Our preliminny evaluations confirmed these conclusions and were the starting point for development of the Trojan defueled plan.
Our hazards analysis followed not only the standard Fmal Safety Analysis Report methodology which evaluates the design basis accident scenarios, but also addressed other credible accidents. As you suggested, we contacted Richard Donovan and per his suggestion, have also utilized the methodology outlined in NRT-1, " Hazardous Matadak Emergency Pinnning Guide".
A meeting has been scheduled at Trojan on March 8,1993 to present the results of this evaluation to members of the steering committee and interested parties. PGE subject area experts in fire protection, security, radiation protection, natural phenomena, and safety analysis will be present to answer questions. " Ibis will be followed by a tour of the facility.
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TDW-062-93TF 7
March 3,1993 Pare 2 With regard to the disposition of equipment, I want to assure you we will work with the i
State and counties within the constraints provided by rules affecting equipment purchased with PGE funds for use in supycit of Trojan operation. Jerry Thale and 4
linda Klein will be working with you on this important matter.
I I agree continued excellent comnnmic. tion is required during this transition period. I 3
know the actiore that will be taken to move Trojan to a permanently defueled status i
cause significant personal difEculties for the State and County officials who have worked '
so well on Trojan emergency prepW I suggest the Oregon Trojan Steering Committee be an Mw focal point for this communication.
We look forward to continning to work with you on refinement of a defueled Trojan '
emergency plan and appreciate your M d -= '..g efforts.
Sincerely,
/n f
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- Manager, 1
Technical Functions c: David Stewart-Smith, ODOE Myra Lee, OEMD l
John DeFrance, Columbia County 1
Ray Paris, OHD l
Richard Donovan, FEMA i
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March 18,1993 Tom Walt Trojan Nuclear Plant 71760 Columbia River Highway Rainier, Oregon 97048
Dear Mr. Walt:
Here is a list of the documentation needed by the Oregon Department of Energy (ODOE) and the Oregon Health Division to complete our review of offsite radiological hmrds. This is part of ODOE's review of PGE's Trojan defueled emergency plan. 'Ibe hazard mimbers shown are those used in the Trojan Hazards Summary, Revision A (March 1993).
Hmrd Number Docnments/Informntion Needed I-A PGE-1037 l
I-B None (previously supplied) l I-C PGE-1037 I-D None (previously supplied) i II-A None II-B Emergency diesel test program (what is done now and what is expected to be done in the future)
III-A State review of new Seemity Plan l
l III-B State review of new Security Plan
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III-C State review of new Security Plan lf HI-D State review of new Security Plan V
625 Manon Street NE Salem. OR 97310 l
(503) 371M040 FAX (503) 373-7806 Ton-Free 1-800-221-8035
Tom Walt Q
March 18,1993 i
i Page 2 i
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IV-A How close to nearest radiation area (need to see FI:e Plan)
IV-B Same as IV-A l
IV-C Same as IV-A IV-D What is in the building that could contntute to a fire V-A Hydrazine quantities and Chlorine location V-B None V-C FSAR Section ? ? '4.1 VI-A Final earthquake report when done V
VI-B None I
IV-C (Add'l Weld gasses) None i
As I mentioned at the Oregon Energy Facility Siting Council's Trojan subcommittee meeting March 11, we also need the documentation PGE is preparing on the additional scenario regarding loss of water in the spent fuel pool and its possible com equences as des nted in NUREG-1353.
We appreciate the efforts you and your staff have made to respond promptly to our requests for information.
Sincerely, Al Rosemary Matson Bennett Nuclear Emergency Coordinator Facility Regulation Division
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Rainier, Oregon 97048 (503)$56-3713 March 23,1993 Troian closure Process TDW-074-93TF John DeFrance
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Emergency Services Director Columbia County Emergency Services Courthouse St. Helens, OR 97051
Dear John:
Thank you for your letter dated February 12, 1993 concerning the Trojan closure process.
Your letter expressed concern about the rate at which PGE was proceeding with the closure process, and the appearance that the plan development and risk analysis. vere "out of sync".
(7 I appreciate the efforts yet and the other members of the Oregon s -
Steering Committee have put forward to review the Trojan defueled emergency plan.
I understand that it has appeared-that PGE prepared the draft plan prior to performing a risk analysis, giving the appearance that PGE predetermined what the risks would i
be.
You had no way to know that PGE talked with and received several analysis from other defueled plants, or that the analysis showed offsite doses were well below that which required offsite l
protective actions.
Our preliminary evaluations confirmed these conclusions and were the starting point for developnent of the j
defueled plan.
l You also expressed concern that PGE had not considered a full l
range of possible risks.
Our initial evaluation followed the l
Final Safety Analysis Report methodology which evaluates design l
basis accident scenarios.
As suggested by you and Nick Goevelinger, we have since concluded a full hazards assessment of the defueled condition.
The results of this assessment were presented to you and other members of the Oregon Steering l
Committee at Trojan on March 8, 1993.
l Another concern was the new fire and security plans will not be.
l available for consideration at the time the draft. emergency plan.
is submitted to the NRC.
As discussed during the Match-11, 1993 EFSC Trojan Subcommittee meeting, the security plans will require
']
ODOE approval prior to implementation.
In addition, I agree to provide the fire plan to ODOE.
This will assure that the l
emergency plan as drafted remains compatible with these supporting plans.
-l
b Trojan Closure Process l
O March 23, 1993 t
Paae 2
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t I realize our time schedule was short and appreciate your efforts to complete your always thorough review prior to submittal of the plan to our Plant Review Board.
We look forward to continuing to work with you on refinement of a defueled Trojan emergency plan and appreciate your continuing i
efforts.
i Sincerely,
/s/ T.D. Walt T. D. Walt, General Manager i
Technical Functions c:
David stewart-smith, ODOE Myra Lee, OEMD Ray Paris, OHD Nick Goevelinger, ODOH Dale Heimuller, Columbia Co.-Board of Commissioners j
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' rtland General Electric Company i
..rojan Nuclear Plant 71760 Columbia River Hwy.
l Rainier. Oregon 97048 (503) 556-3713 March 25,1993 Request for Additional Information l
TDW-089-93TF l
I Rosemary Matson Bennett Nuclear Emergency Coordinator 1
Oregon Depanment of Energy 625 Marion St. NE Salem, OR 97310
Dear Ms. Bennett:
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"Dtis is in reply to your letter dated March 18,1993, requesting additional information for use by the Oregon Department of Energy (ODOE) and the Oregon Health Division in their review J
of offsite radiological hazards.
l The following information and documents are provided in response to your request. The hazard numbers shown are those used in the Trojan Hazards Summary.
Hazard Number Discussion / Documentation l
l I-A/I-C In 1983, PGE increased the storage capacity of the spent fuel pool. As part of process, PGE prepared a topical report, PGE-1037, Trojan Nuclear Plant Spent l
Fuel Storage Rack Replacement Report (enclosed), which evaluated the impact i
of the increased storage capacity on the nuclear, thermal hydraulic, and structural safety of the spent fuel pool. The NRC performed an independent evaluation of the impact (also enclosed). They concluded, as did PGE, that the spent fuel pool, as modified, was acceptable and continued to meet all design criteria.
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Request for Additional Information
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March
,1993 Pace 2 l
I l
l II-B An emergency diesel test program is maintained in the form of periodic operating I
tests which assure diesel availability The currently applicable test procedures are POT 12-1, POT 12-4, and POT 12-5 (copies enclosed). The emergency diesel generator and its use are further discussed in the Trojan Hazard Summary, Revision B (enclosed), Section II-B. PGE will continue to maintain a diesel generator so long as it is required by NRC regulations to have onsite emergency power.
l l
III The existing Security Plan is being revised to reflect the permanently defueled status of the Plant. The Permanently Defueled Security Plan is scheduled for submittal on May 27,1993. EFSC is scheduled to review t'.s plan on June 3 or 4, 1993.
IV-A/IV-B/ The storage of flammable and combustible liquids is addressed in the topical IV-C report, PGE-1012, Trojan Nuclear Plant Fire Protection Plan, Section 5.2.4 (enclosed). Combustible liquids such as fuel oil are stored both in underground and aboveground tanks. The diesel oil storage tanks are located approximately i
70 feet from the outside of the Fuel Building. Hydrogen storage tanks are located
^
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south of the cooling tower, approximately 1,000 feet from the outside of the Fuel Building. The locations of these tanks are shown on Trojan Final Safety Analysis Report (FSAR) Figure 12.3-1 (enclosed). There are no tanks inside buildings l
which contain flammable liquids.
All contaminated areas are located within radiologicaliy controlled areas.
Contaminated material is stored in the Radioactive Waste Building (RWB),
discussed under IV-D below. The RWB is located approximately 500 feet northeast of the Fuel and Auxiliary Buildings.
The existing Fire Protection Plan is being revised to reflect the permanently defueled status of the Plant. The Permanently Defueled Fire Protection Plan is scheduled for implementation sometime after June 15,1993. The description of the Permanently Defueled Fire Protection Plan will be presented to the EFSC l
Trojan Subcommittee on April 22,1993.
~
Request for Additional Information m
hfarch
,1993 Pace 3 IV-D The storage of radioactive material in the RWB is controlled by Trojan Procedure RPhfP-26, a copy of which is enclosed. Radioactive waste intended for storage in the RWB must be approved by supervision and appropriately packaged prior to storage. Unpackaged, combustible waste is prohibited from being stored in the RWB.
'Ibe quantity of radioactive material stored and its tracking is discussed in PGE hiemorandum PBC-005-93, dated 3/18/93, from P. B. Chadly to C. hi. Dieterle,
Subject:
Response to Questions Regarding Inventory of Radioactive hiaterials Located in the Radwaste Storage Building (enclosed).
V-A During Plant operation, hydrazine was used as a secondary-side corrosion inhibitor and an oxygen scavenger. It is no longer used. Currently, twelve 55-gallon drums of hydrazine are located in the warehouse.
Chlorine was used as a biocide in treating Plant service water up until a few years ago when it was replaced with sedium hypochlorite. Chlorine is transported with l
sufficient frequency via the railroad on the west side of the Plant to require analysis. This analysis is contained in FSAR Section 2.2.3.2, Toxic Chemicals (enclosed).
V-C Shipments of commercial cargo past the Plant create the possibility of nearby explosions. Explosions of these type are analyzed in FSAR Section 2.2.3.1 (enclosed). Explosions unrelated to transportation are not considered significant.
VI-A The spent fuel pool is designed such that it can easily withstand the design basis earthquake which is 0.25 g horizontal ground acceleration. This design basis earthquake is based upon the 1949 Olympia Earthquake. PGE has sponsored investigation of the potentialimpact of the Cascadia Subduction Zone Earthquake I
upon the Trojan Plant. Results of these evaluations have been reponed to EFSC.
Recent work has determined that the potential ground acceleration from this very large canhquake is 0.38 g. Engineering evaluations have concluded that the spent fuel pool can withstand, with sustained margin, even this larger earthquake. The final results of the evaluation will be presented to the EFSC Eanhquake Subcommittee on June 3 or 4,1993.
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Request for Additional i
Information o
March
,1993
~
Pare 4 1
Additional information, listed below, is also enclosed which provides background material and supporting details for the Trojan Hazards Summary.
1.
Trojan FSAR.
l
- Section 2.2.3.3, Fires
- Section 2.2.3.4, Ship Collision with Intake Structure
- Section 2.4.2.2, Flood Design Considerations i
- Section 3.3.2, Tornado loadings
- Section 3.5.1.6, Aircraft Hazards
- Section 3.8.4.1.1.2, Fuel Building 2.
Trojan Nuclear Plant Procedure PSP 3-27, Compressed Gas Cylinders, Revision 11.
l l
Other information requested in your letter included a final earthquake report, and additional j
information regarding the potential major loss of water from the spent fuel pool and its possible consequences. The NRC has not yet determined if the scenario desenM in NUREG-1353 is i
applicable to Trojan spent fuel storage. The results of the final earthquake evaluation of spent
,e fuel storage will be presented to the EFSC Earthquake Subcommittee on June 3 or 4,1993.
\\
Regarding the Security Plan and the Fire Protection Plan, it is important to reemphasize that the Permanently Defueled Emergency Plan should be reviewed with the understanding that it will.
be implemented under the existing Security Plan and Fire Protection Plan. - When these plans are prepared, the Permanently Defueled Emergency Plan will be reviewed for continued adequacy under the new plans and revised if necessary.
Please contact me if additionalinformation or clarification is needed.
Sincerely, T. D. Walt, General Manager Technical Functions Enclosure
]
l c: David Stewart-Smith (w/o enclosure)
Victor Sarte (w/o enclosure)
Adam Bless (w/o enclosure)
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DEPARTMENT OF April 7, 1993 ENERGY Tom Walt General Eanager, Technical Functions Trojan Nuclear Plant Rainier, OR 97048
Dear Mr. Walt:
Thank you for providing us with the meno from Cross to NRC entitled " Permanently Defueled Emergency Plan for the Trojan Nuclear Plant", and for PGE Topical Report PGE 1008 " Permanently Defueled Energency Plan for the Trojan Nuclear Plant", both dated March 9, 1993.
Here are ny comments.
Comments on the Cross to NRC meno:
- p. 5:
You have stated that a Hold Up Tank rupture is the highest potential atmospheric release source in the Volume Control System, but that there such a rupture would not result in doses i
beyond the exclusion area boundary that could exceed EPA guidelines.
Please provide the results of any samples taken from the Hold Up Tanks, along with the dates of those samples and the volume of material contained.
- p. 7:
Please describe the calculations performed by the DOSES computer code, along with a description of the methods used to benchmark that code.
- p. 9:
We note that PGE did not analyze for a cask drop accident.
We recognize that at this time, there are no plans to put a cask in the pool.
But, at some time in the future it will be necessary to use casks, in order to get the fuel either offsite or into alternate storage faciltiies.
The emergency plan should have a contingency for damage due to a cask drop, or PGE should show by analysis that a cask drop will not damage the pool.
Otherwise, the plan vill have to be amended if there is a need to use fuel casks in the future, and you may not have the ge nom staff to prepare such an a=endment.
Gwems@
625 Marion St:eet NE Salem, OR 97310 (503) 378-4040 FAX (503) 373-7506 Toll-Free 1-800 221-8035 l
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I Tom Walt April 7, 1993 t
Page 2
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General Comment:
Most of the analysis you have provided indicates doses at the exclusion area boundary of less than 50 mR.
To nuclear professionals, these are small doses which do not warrant offsite
(
action.
But to a non-technical audience 50 mR may sound like a lot.
The emergency plan should have provisions to inform the public, notify appropriate county and local officials, and periodically educate local police and firefighters.
We are concerned that, in the event of a credible accident or fire, members of the local public may be unduly alarmed when they learn that an " alert" is in progress and are unable to get meaningful information from local authorities.
l Comments on PGE 1008:
p 11: For the benefit of reviewers, EFSC members, and interested Q
me=bers of the public, it would be helpful if ARM's and PERM's V
are referred to by name or location, not simply by number.
For seismic events, please state the location of operable seismic monitors.
The seismic monitors with audible alarms in the control room are currently in containment.
Will these be maintained?
Also, the plan refers to the Security Plan, the Fire Protection Plan, and the EPIP's.
EFSC reviews the Security Plan, but not the other two.
Pletise be sure to send all Fire Plan and EPIP information to ODOE.
ODOE site inspectors should be notified when your staff will present these plans and procedure for review by the PRB.
1 p 13:
refers to plant operator.
This should be changed to Certified Fuel Handler when the NRC approves the Certfied Fuel Handler Program.
p 14:
Currently, the ODOE duty officer reports to the TSC during an Alert.
Your new plan has no TSC.
Based on experience with Unusual Events at Hanford, WNP-2, and transportation events, we predict that state and local governments (includina'the Director and possibly members of the Governor's staff) will want detailed information on an alert even if no offiste PAG's are required.
Please identify at least one technical person will be responsible u
for questions posed by the ODOE Technical Advisor or designee.
Tom Walt
,]
April 7, 1993 Page 3 i
p 18:
there is a phone communicator assigned to the NRC.
There should also be one assigned to ODOE, or ODOE questions should be j
explicitly stated as the job of the NRC phone communicator.
l p 19:
Co=munications - section 6.1 should discuss provisions for l
radio contact with the State Emergency Response Organization, if comnercial phone lines are not functional.
p 26:
Please describe the criteria used to determine if a change l
to the plan qualifies as one which does not decrease the effectiveness of the plan, per 10CFR50.54.
Indicate who will r.ake this determination.
l Other co= rents:
There is no mention of either a TSC or OSC.
What is the highest number of people expected in the control room during the worst credible alert condition?
At a minimum, the control room will have people responsible for operations, offsite communications, engineering, radiation protection, dose assessment, and possibly O,
fireilghting.
That is a lot to ask of your current control room layout.
At the minimum, drills should be performed to assess the current control room's ability to accomodate this many functions.
Also, describe any prevision for control room inhabitability due to fire or toxic gas.
Please note that these comments are those of the onsite inspection staff and do not include comments by the E=ergency planning coordinator or the Health divison.
Also, I am happy to report that Victor Sarte has reviewed a preliminary copy of your security plan, and he finds it satisfactory in most respects.
Sincerely,
/AWj YL Adam Bless Trojan Resident Inspector Facilities Regulation Division c:\\ work \\eptan.w51
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Ponland General Electric Company jTrojan Nudear Plant
' 71760 Columbia River F j Rainier, Oregon 97048 (503) $~6-3713 April 19,1993 ODOE Request For AdditionniInformntion TDW-116-93TF I
Rosemary Matson Bennett Nuclear Emergency Coordinator Oregon Department of Energy 625 Marion St. hT Salem, OR 97310 3
l
Dear Ms. Bennett:
I ()
Your letter dated March 18,1993, requested the documentation PGE is preparing on the additional scenario regarding loss of water in the spent fuel pool and its possible consequences as desenbed in NUREG-1353,' Regulatory Analysis for the Resolution of Generic Issue 82, "Beyond Design Basis Accidents in Spent Fuel Pools".' PGE's position 4
is that NUREG-1353 does not apply to Trojan's spent fuel pool structure. The risk from the potential accident described in NUREG-1353 is dominated by the beyond design basis earthquake accident scenario. Based on PGE's recently completed earthquake evaluation of spent fuel storage, Trojan's spent fuel pool structure is capable of withstanding well in excess of the worst earthquake postulated for this area. A report on the earthquake evaluation, entitled, " Performance of the Trojan Spent Fuel Pool t
Structure if Subjected to Seismic Margin Earthquake Ground Motions,"is being prepared and will be sent to you once it is completed, which is expected by April 30.
The earthquake evaluation assessed the capability of the Trojan spent fuel pool structure to resist ground motions that would result from a postulated Seismic Margin Earthquake (ShE). The SME is based on conservative evaluations of the Cascadia Subduction Zone earthquake determined to be bounding for the Trojan site. Speci5c, detailed information on the ShG is being provided to ODOE in a separate letter, expected by April 20.
As part of the earthquake evaluation, an assessment was performed to determine the capability of the spent fuel pool to withstand structural damage due to a very large
,j earthquake which could cause an unacceptable loss of water (water level less than 10 feet above the stored fuel). It was determined that the spent fuel pool could withstand J
an earthquake causing a 2g ground acceleration, many times the present Safe Shutdown
i TDW-116-93TF i
April 19,1993 Page 2 i
Earthquake level cf 0.25g or the SME level of 0.38g. The probability of spent fuel pool damage due to such an earthquake was calculated to be less than 5x10 per year. The 4
size of an earthquake which could cause a ground acceleration of over 2g cannot be calculated since no data for this large of an canbquake exist. However, such a large canbquake would have to be larger than the worst postulated M 9 Cascadia Subduction Zone earthquake.
NUREG-0396 (EPA 520/1-78-016) discusses the pinnning basis for the development of state and local government radiological response plans. In the attached excerpt, that document concludes that both the design basis accidents and less severe core-melt accidents should be considered when selecting a basis for planning predetermined protective actions and certain features of the more severe core-melt accidents should be considered in pinnning to assure that some capability exists to reduce the consequences of even the more severe accidents. The annual probability of a design basis accident is given as 5x10'5. The annual probability of occurrence of the most severe core damage accident is 9x10", according to the Reactor Safety Study, WASH-1400 (excerpt attached).
i WASH-1400 was a basis document for NUREG-0396. Again, PGE has calculated the annual probability of spent fuel pool failure to be less than 5x10.
4 O
t The probability of an canhquake causing failure of the Trojan spent fuel poolis over 1000 times less than the probability of a core-melt accident and nearly 20 times less than the most severe accident evaluated. The probability is so low that it is outside the emergency planning basis for operating reactors and should not be pan of the pinnning basis for a defueled plant.
I PGE is in discussion with the NRC concerning the need for emergency response planning for the potential major loss of water accident. I and my staff will keep you apprised of our discussions with the NRC on this matter.
Sincerely, l
T. D. Walt, General Manager Technical Functions Attachments c:
David Stewan-Smith, ODOE Victor Sane, ODOE Adam Bless, ODOE Nick Goevelinger, OHD John DeFrance, Columbia County
Anschment 1 I
TDW-116 93TF Page 1 of 2
.^.
NUREG-0396 EPA 520/178416 i
- i PLANNING BASIS FOR THE DEVELOPMENT OF
~
STATE AND LOCAL GOVERNMENT i
RADIOLOGICAL EMERGENCY RESPONSE PLANS IN SUPPORT OF LIGHT WATER NUCLEAR POWER PLANTS A Report Prepared by a U. S. Nuclear Regulatory Commission and U. S. Environmental Protection Agency
-:^-
Task Force on Emergency Planning
,l:
- b-l H. E. Collins
- 3. K. Grimes **
Co-Chairmen of Task Force F. Galpin'**
Senior E?A Representative Manuscript Completed: November 1978 Date Published: December 1978 a
- Office of State Programs
- Office of Nuclear Reactor Regulation U.S.Nuc!sar Regulatory Commission Washington. D.C. 20555
- 9. '
- Office of Radiation Programs U.S. Environmental Protection Agency Washington, D. C. 20460 e
I.
~ ~. - -
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A m ^ mant 1 TDW-116-93TF Page 2 of 2 I-9 The degree of uncertainty is.such that no differentiation can l
be confidently made, on a probabilistic basis, between the DEA /LOCA and the releases associated with less severe core-melt l
categbries.
l As discussed in Appendix III, the Task Force has ; concluded that -
i both the design basis accidents and less severe core-melt accidents i
should be considered when selecting a basis for planning pre-determined protective. actions and that certain features 'of the more severe core-melt accidents should be considered in planning i
to assure that some cacability exists to reduce the consecuences of even the most severe accidents. The low probabilities associated with core-melt reactor accidents (e.g. one chance in 20,000 or 5 x 10-5 perreactor-year)arenoteasytocomprehendandadditional perspectives are useful. Within the next few years, there will have been accumulated approximately 500 reactor-years of civilian nuclear power plant operation in this countiy. Less than 30t of
~
all core melt accidents would result in high exposure outside the recomended planning distances. Therefore, over this time period
- the probability of an accident within the USA with expcsures exceeding the plume or ingestion PAGs outside the planning basis distances would be about 15 x 10' ~ x 500 or about 1 chance in
- The Reactor Safety Study explicitly limits its analyses to the first 100 reactors and five years (through 1980).
- ** This estimate is based upon the assumptions of the RSS. It shculd be noted that there is a large uncertainty on this number.
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Awhment 2 l
TDW-116-93TF Page 1 of 2
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TABLE 5-1 SORARY CF ACr.La.sT5 INVOLVING CORE r_ m o. =W = ::; r
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CATEGQItY Reactor-Tr (Br)
(Er)
(Br)
Oteters) (10 Sta/Br) 3e-Er Org. I 1
CD-2 Te-D Se-Br Du Za Pun 1 lta10'b 2.5 0.5 1.0 25 520III 8.9 640 0.7 0.4 0.4 0.05 0.4 2 2a'
- 3 Pun 2 aco
2.5 0.5 1.0 0
170 0.9 va10'3 0.7 C.5 0.3 0.06 0.02 4an*
Fwa 3 aco
5.0 1.5 2.0 0
6 0.s 6a10'3 0.2 0.2 0.3 0.02 0.03 mai m4 Sec'3 2.0 2.0 2.0 0
1 0.6 2:10'3 0.0s 0.04 0.02 5 10 3,3,-s,,3g
-2 PWR 5 7:10
2.0 4.0 1.0 0
0.3 0.3 2x10'3 0.03 9 10 5:10'3 la10 6a10 Tan
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- I PWR 6 Ea10
12.0 10.0 1.0 0
m/A 0.3 2x10 sala tale 1:10'3 9x10 9,g,-5 Iz2i
- 3
-5 Pwn 7 dald 10.0 10.0 1.0 0
m/A 4x10 2a10 2x10 g,gg 2x10-5 g,gg la10 2:2i
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-5
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-6 paa a 4x10'3 0.5 0.5 m/A 0
m/A 2co 540 l e 0
- 54 0
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1 10
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Put 9 dalo 0.5 0.5 m/A 0
IVA 2a[ 710 la10' 6 10' lalt la10' O
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w sum 1 lalo 2.0 2.0 1.5 25 130 1.0 7 10'3 C.40 0.40 0.70 0.05 0.5 Sass SWE 2 6a10 30.0 3.0 2.0 0
30 1.0 1 10'I c.90 0.50 0.30 0.10 0.03 4a20 '
-5 awa 3 2x10 30.0 3.0 2.0 25 20 1.0 7a10'3 0.10 0.10 0.30 0.01 0.02 3s2r
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5.0 2.0 2.0 25 m/A 0.6 7 10 4x10 SalD 4a10 6a10 6a10 12!
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2.5 5.0 s/A 150 m/A Sala 2x10 6x101 4x10'3 am10'U 340'3' O
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(d A disenssion of the imetapes used la the study is found in Appendia TI. Background on the imotape progs and aslease anchanisms is found im Appendia 1:1.
l Od Imelades ns. Rh. Te, Co.
h) Includes 34. T. Ca. Pr. la. m, Am Sm. Ps. sp, tr.
(d) A lower snarry release rate than this vaine applies to part of the period over which the radioactivity is being taleased.
The affeet of lower energy relenae rates on consequences is found la Appendia TI.
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I firW2"*IA COURIT muranrier=r EERVICES
,wentura, gT. EELENs, camecer 97051 1
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Phoast 397-2100 April 19, 1993 1
Mr. Tom walt, General Manager 4
Technical Functicas Trojan Nuclear Plant 71760 col.unbia River Highway Rainier, 0$gim~ 97048
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Dear Tom,
I After looking through the new emergency plan for Trojan, the " Permanently Defueled 2:nergency Plan for the Trojan Nuclear Plant", I have the following commects:
l 1.
6.1 needs to be changed to read
- cclumbia County Emergency Services via Columbia County Emergency 8"-aications District (cc3co} via commercial telephone within one hour of elaeeification.'
'd 2.
The last mentence in 6.1 needs to speak to *how" communication is maintained.
Notification using methods in (1)
(7) is fine, but not for Updated information.
~,
i 3.
Public information coordination is mentioned in 5.2.
State and County public i
information is mentioned in 5.3.
Public information is not shown in Figure 5-1 nor in Tables 5.1 and 5.2.
Public information is not diseassed 12 Sectica 6.0.
t 4.
Why are ODOE on-site inspectors not mentioned in 6.27 5.
The protecti measure of *...ezclusion or removal of the general public from the trclusion Area..." would restire coordination with columbia county for its actual implementation (on that portion of the Exclusion Area which is on the west side of Eighway 30) and for public information.
6.
The roadblocks referred to in E.3.1 satst be done by columbia County and must have public infermatica coordination with columhta county (as well as should any closure of the columbia River).
7.
Either in section 5.0 or 7.0 discussion should speak to
- ingestion
- e 42rns, even if they are nothing more than " Oregon Health Division may dispatch a field monttering team to surtwy for radiological relsaaes and environmental impac
- as mentioned in 5.3.
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April 19, 1993 Letter to Tom wait Page 2 8.
PCI needs to understand that cm will not do " fan-out* actification on behalf of Columbia county & :v.cy Services since Colsabia County Emergency services will not have funding to contract with CCrcD for this servios (see 6.1 and 4.2).
Assuming PGE does not provide funding for Columbia county's off-site emergency response / planning expenses, it would be best to add van-out notification sa directed by columbia county Emergency services
- to the contract PGE will have with CcECD.
9.
TrainiS'g of~the Rainier Rural Fired 31'st'rilft fire respeaders should be done annnaily. See 9.2, 4th paragraph.
t
- 10. "- Fi Preparedness Tests, 9.5, should call for communications Tests to be conducted at least monthly.
I will be happy to discuss those with you at your earliest convenience.
na the plan review procoes contimees and with these questions answered and changes made we will move closer to agreement. Thank you.
Sincerely, i
f John T. DeFrance i
l Emergency Earvices Director
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David stewart-saith, Oregon Department of Energy Myra Lee, Oregon amet?ency management Division Ray Paris, Radiation Control Section, Oregon Health Division
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P:nland General Elee:ric Company
^ Trojan Nuclear Plant
)
.1760 Columbia River Hwy i
Rainier, Oregon 97048 (503) 556-3713 April 22,1993 Resident Inspector Comments on Defueled Emercenev Plan TDW-115-93TF
~
Mr. Adam Bless Trojan Resident Inspector Trojan Nuclear Plant 71760 Columbia River Highway i
Rainier, OR 97048
Dear Mr. Bless:
Thank you for providing review comments on Jim Cross' letter to che Nuclear Regulatory 3
Commission dated March 9,1993 entitled, " Permanently Defueled Emergency Plan for the Trojan Nuclear Plant".
Your comments addressed both the letter and the attached Defueled Emergency Plan. Our responses to your comments are provided on Attachment 1 to this letter.
I appreciate your review. If you have any remaining questions or require further explanadon, please contact me or a member of the Emergency Ljudness staff.
Sincerely, T. D. Walt, General Manager Technical Functions Attachment et Mr. David Stewart-Smith, ODOE Mr. Vic Sarte, ODOE Mr. Nick Goevelinger, OHD Mr. John DeFrance, Columbia County
O g
L Pase 1 of 5 RESOLUTION OF C0!'MENTS Cement (Page 5):
"You have stated that a Hold Up Tank rupture is the hi hest 5
pctantial atmospheri release source in the Volume Control System, but that such a rupture vould not result in doses beyond the exclusion area boundary that co21d exceed EPA guidelin*s. Please provide the results of any samples taken from the Eold Up Tanks, along with the dates of those samples and the volu=e of material contained."
Resnense: This analysis was included to bound any potential future liquid radvaste tank rupture. The above conclusion was not based on a specific samplin5 program. The Trojan Final Safety Analysis Report (FSAR), Chapter
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15, Paragraph 15.7.3.1, discusses the postulated Hold Up Tank rupture scenario during power operations. Since radioactive gases are no lonSer being generated, and due to the continuous and ongoing decay of radioactive gases, the Hold Dp Tank rupture scenario in the permanently shutdown condition is bounced by the FSAR analysis. Paragraph 15.7.3.3 provides the conservatively calculated doses as 0.325 rem whole body and 0.122 rem thyroid for a two-hour dose at the nearest site boundary assu=ing power operations. These values are the basis for the conclusion that a liquid radwaste tank rupture vould not result in doses beyond the exclusion area i
boundary that could exceed Environmental Protection Agency (EPA) guidelines.
l v
Coment (Page 7): "Please describe the calculations perfor=ed by the DOSES co=puter code, along with a description of the methods used to benchark that code."
Rernense: The calculation perfor:ed by the DOSES ce=puter code is docu=ented in Calculation RPC 93-003, Revision 1, dated March 9,1993.
It was used in the evaluation. I:s inputs included release activi:ies in curies, at=ospherie dispersion factors, ga:nma shielding factors, breathing l
rate, decay ti=e, and iodine decontamination factors. Code outputs ga:nma i
whole body dose and thyroid dese.
I The DOSES code is used to provide offsite noble gas doses for use in the Trojan annual opera ing report (PGE-1015). It uses FRC Reg Cuide 1.109 methodoloE7. has no site-specific coding, and is applicable to a=y nuclear plant. The validation calcula: ion for the DOSES code is documen:ed in Calculation TNP 82-046, Revision O.
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Page 2 of 5
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Coment (Page 9):
"We note that PGE did not analyre for a cask drop accident.
We recognize that at this time, there are no plans to put a cask in the pool.
But, at some time in the future it vill be necessary to use casks, in order to get the fuel either offsite or into alternate storage facilities. The emergency plan should have a contingency for damage due to a cask drop, or PGE should show by analysis that a cask drop will not damage the pool. Otherwise, the plan vill havr. to be amended if there is a need to use fuel casks in the future, and you may not have the staff to prepare such an amendment."
Reseense: Trojan's current license prohibits moving a spent fuel assembly
~
shipping cask into the Fuel Building. At some point in the future a decision vill be made to do this. At that time, the cask type and specifications vill be available for a full safety evaluation to be i
performed and a license change amendment processed. If the results of the safety evaluation vere to indicate that the emergency plan required revision, the emergency planner, identified as part of the long-term organization, would prepare and implement that revision.
Comment (General): "Most of the analysis you have provided indicates doses at f
the exclusion area boundary of less than 50 mR. To nuclear professionals, these are small doses which do not warrant offsite action. But to a non-technical audience 50 =R may sound like a lot. The emergency plan should have provisions to inform the public, notify appropriate county and local
'i officials, and periodically educate local police and firefighters.
"We are concerned that, in the event of a credible accident or fire, members of the local public may be unduly alarmed when they learn that an ' alert' is in progress and are unable to get meaningful information from local j
authorities."
i Reseense: We agree that it is important that offsite authorities are knowledgeable of events and are able to obtain meaningful information. In addition to event information, the initial notification to offsite authorities vill include a call-back name and telephone number. Updated information will also be provided as needed. PGE Corporate Communications will be responsible for developing and coordinating news releases with state and county representatives prior to information being released.
We vill continue to conduct annual training of Rainier Rural Fire District fire responders and assist the state and county with training specific to Trojan when requested.
We intend to maintain a continued strong relationship with state and county
~ - '
response personnel.
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Page 3 of 5 l
l Cem ents on PGE-1008 i
Cement (Page 11): "For the benefit of reviewers, EFSC ne=bers, and interested me=bers of the public, it would be helpful if AR2i's and PEFJi's are referred to by na=e or location, not simply by number."
Restonse: PEElis and AFJis are discussed in Section 8.4 of the Plan. Both j
the locatien and the function description is given. A footnote directing
.=-
the reader to Section 8.4 vill be added to the referenced page.
Cor: rent (Page 11):
"For seismic eve.ts, please state the location of operable seismic monitors. The seismic monitors with audible alar:s in the control room are currently in conainment. Vill these be maintained?"
Restonse: The classification of an emergency in the event of an earthquake is not based on seismic monitors. At this point in time, we intend to maintain the seismic monitors.
Cor=ent (Page 11):
"Also, the plan refers to the Security Plan, the Fire Protection Plan, and the EPIP's. EFSC reviews the Security Plan, but not the other tvo.
Please be sure to send all Fire Plan and EPIP information to ODOE.
ODOE site inspectors should be notified when your staff vill present these plans and procedures for review by the PR3."
i 9 V
Reseense: We vill notify you when the Security Plan, the Fire Protection l
Plan, the E=ergency Plan, and the EPIPs, as revised to reflect Trojan's permanently defueled condition are scheduled to be presented to PR3.
Cement (Page 13): " Refers to plant cperator. This shocid be changed to certified Fuel Handler when the NEC approves the Certified Fuel Handler Program."
Resoonse: The title of " plant operator" refers to the craft position identified in the Trojan long-ters organitation which reports to the Shift lianager, who vill be a certified fuel handler. The plan does not require the plant operator position to be a certified fuel handler, j
Coment (Page 14): " Currently, the ODOE duty officer reports to the TSC j
during an Alert. Your new plan has no TSC. Based on experience with Unusual Events at Hanford, UNP-2, and transportation events, we predict that state and local govern =ents (including the Director and possibly me=bers of the Governor's staff) vill vant detailed information on an alert, even if no offsite PAG's are required. Please identify at least one technical person -
~ ~ ~ '
vill be responsible for questions posed by the ODOE Technical Advisor or designee."
Resoonse:
The Engineering Coordinator vill be responsible for responding to questions posed by the ODOE Technical Advisor or designee.
In addition, the
)
ODOE Technical Advisor vill have access to the Control Room area in an s
emergency.
0..
4 Page 4 of 5 Cemment (Page 18):
"There is a phone communicator assigned to the NRC. There should also be one assigned to CDOE, or ODOE questions should be explicitly i
stated as the job of the NRC phone communicato
- i Resnonse: There vill be no dedicated NRC communicator. There vill be a l
single communicator responsible for notifications to the NRC, ODOE, and other offsite agencies.
Cemment (Page 19): " Communications - Section 6.1 should discuss provisions r
for radio contact with the State Emergency Response Organization, if
}
commercial phone lines are not functional.*
Resnonse: Offsite notifications will be added to the PGE load dispatcher's notifications should the commercial telephone system be lost. This vill be added to Section 8.2(1) of the plan.
t Cemment (Page 26): "Please describe the criteria used to determine if a e b ge to the plan qualifies as one which does not decrease the effectiveness of the plan, per 10CR50.54 Indicate who will make this deter =ination."
Resnonse: Trojan Plant Procedure (TPP) 18-1,10 CFR 50.54 and 10 CHL 50.59,
" Screening and Evaluation", vill continue to govern how 10 CFR 50.54 l
evaluations are performed.. ' The criteria vill continue to be 10 CFR 50.54(g) less the exemptions approved by the NRC. A person r,calified under TPP 18-1 vill amir. the 10 CFR 50.54 determination.
m l
l Cemments (Other): "Tnere is no mention of either a TSC or OSC. What is the
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hi hest number of people expected in the control room during the worst j
5 credible alert condition? At a minimum, the centrol room vill have people j
responsible for operations, offsite communications, engineering, radiation protection, dose ascessment, and possibly firefi hting. That is a lot to ask l
5 of your current control room layout. At the minimum, drills should be I
performed to assess the current control rooms ability to accommodate this many functions."
j t
l Resnonse: As currently planned, six responders vill be located in the l
Control Room in addition to shift Operations personnel. We vill perform an exercise using this planned configuration. Currently, the exercise is scheduled 'for July 13, 1993. This exercise, as well as drills and exercises scheduled periodically, will test the integrated capability of the plan and procedures. Actions will be taken to correct items identified during drills i
and exercises.
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.GRaatng (other):
"Also, describe any provision for control room Shahitability due to fire or toxic gas."
i Rereonse:
The control room will continue to be equipped with self-contained I
breathing apparatuses (SCluLs) in order to mitigate the effects of a control l
room inhabitability scenario. Furthermore, unlika an operating power plant, temporary evacuation of the control room will not result in significant operational problems.._This fact is demonstrated in the hazards st== mary, which states that all cooling to the spent fuel pool could be lost for seven j
days before boiloff would reduce level below ten feet above the fuel assemblies.
An alternate location for response could be established using existing control room evacuation procedures.
Should a fire force personnel out of the control room, personnel would relocate and amhtain cp=i as j
required.
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'e Fr P;;rtland General Electric Company 3, Trojan Nuclear Plant
/71760 Columbia River Hwy Rainier, Oregon 97048 (503) 556 3713 April 22,1993 Trojan Permanently Defueled Emereenev Plan TDW-122-93TF John DeFrance, Director Columbia County Emergency Services Counhouse St. Helens, OR 97051
Dear John:
Thank you for providing comments on the Trojan Permanently Defueled Emergency Plan.
Our response to your comments is attached to this letter.
I I want to reaffirm our commitment in working with you to ensure our plans and procedures s
are adequate and coordinated properly.
If you haie any additional questions or would like further explanation, please contact Jerzy Cooper at (503) 556-5723 or me at (503) 556-5670.
Sincerely, T. D. Walt, General Manager Techn~ cal Functions Attachment 1
l c:
David Stewart-Smith, ODOE Ray Paris, OHD l
Myra Lee, OEMD
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TD'J-122-93TF Page 1 of 3 PGE Response to Columbia County Comments
)
Coment 1: "6.1 needs to be changed to read: ' Columbia County Emergency Services via Columbia County Emergency Comunications District (CCECD) via comercial telephone within one hour of classification *."
3 Resoonse: Plan Section 6.1 will be reworded to read as requested above.
Comment 2: "The last sentence in 6.1 needs to speak to 'how' comunication is maintained. Notification using methods in (1) - (7) is fine, but not for updated information."
Reconse: The initial notification will include a callback name and telephone number.
In addition to follow-up notifications and updates, the designated callback person can be contacted to provide additional information. As part of the review process for the EPIPs, we intend to work with you to ensure the proper and adequate coordination where needed.
Comment 3: "Public information coordination is mentioned in 5.2. State and County public information is mentioned in 5.3.
Public information is not shown in Figure 5-1 nor in Tables 5.1 and 5.2. Public information is not discussed in Section 6.0."
Response: A dedicated Trojan Emergency Response Organization (ERO) l (^
position for public information is not planned. As currently planned,
'u PGE Corporate Comunications will be responsible for developing and coordinating news relea,ses with state and county representatives prior to information being released. The news releases will be developed using Corporate Communications procedures. The Emergency Coordinator will be responsible to provide support to the Corporate Comunications media representative on news releases (Table 5-1). At the Alert level, in addition to the Emergency Coordinator, the Administrative Assistant will serve as a comunication contact for the Corporate Comunications media representative (Table 5-2).
A short description of public information measures will be egged to Section 6.0 Comment 4: "Why are ODOE inspectors not mentioned in 6.2?"
Response: The ERO position of Engineering Coordinator will be responsible to work with ODOE. The specific response role of CDOE inspectors will be defined by ODOE procedures.
4
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TDW-122-93TF Page 2 of 3 PGE Response to Columbia County Coments Coment 5: "The protective measure of '... exclusion or removal of the general public from the Exclusion area..." would require coordination with Columbia County for its actual implementation (on that portion of the Exclusion Area which is on the west side of Highway 30) and for public information.
Response: We agree. We intend to work with you to detennine the level and type of coordination that is necessary and then include the necessary guidance in our EPIPs which are being drafted. As currently planned, excluding or removing the general public from the Exclusion Area will not be an automatic protective action, but an action that would be implemented on as-needed basis. A statement will be added to Section 6.3 of the Plan that this action will be coordinated with affected offsite authorities.
Coment 6: "The roadblocks referred in 6.3.1 must be done by Columbia County and must have public information coordination with Columbia County (as well as should any closure of the Columbia River)."
Response: See responses to Coments 3 and 5.
Coment 7: "Either in Section 6.0 or 7.0 discussion should speak to
' ingestion' concerns, even if they are nothing more than ' Oregon Health Division may dispatch a field monitoring team to survey for radiological
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releases and environmental impact' as mentioned in 5.3."
Response: The statement in Section 5.3, paragraph 2, will be broadened to better reflect what Oregon Health would do. It will be reworded to i
read, ' Oregon Health Division may dispatch a field monitoring team to survey for radiological releases and to monitor environmental impact, includino incestion concerns." Wording to the effect that, "the Emergency Coordinator will coordinate appropriate actions with offsite authorities," will be added Section 6.0 and Section 7.0.
Coment 8: "PGE needs to understand that CCECD will not do " fan-out" notifications on behalf of Columbia County Emergency Services since Columbia County Emergency Services will not have funding to contract with CCECD for l
this service (see 6.1 and 8.2). Assuming PGE does not provide funding for Columbia County's off-site emergency response / planning expenses, it would be best to add " Fan-out notification as directed by Columbia County Emergency Services" to the contract PGE will have with CCECD."
Response: While the need for fan-out notifications to support a Trojan response will be reduced, the level at which they will be needed has not yet been determined. We intend to work with you to determine what the actual notification needs will be and to accomodate those needs.
Coment 9: Training of the hainier Rural Fire District fire responders should be done annually. See 9.2, 4th paragraph.
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s Response: We agree. Training of the Rainier Rural Fire District fire l
responders will continue to be conducted annually.
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i TDW-122-93TF Page 3 of 3 PGE Resoonse to Columbia County Coments Coment 10: " Emergency Preparedness Tests, 9.5, should call for Comunications i
Tests to be conducted at least monthly."
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Response: There is no need to conduct tests of the comercial telephone system, which is the primary notification system, due to its routine use. As currently planned, the Blue-Band Radio System, which is the back-up notification system, will be tested weekly or more often.
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