ML20105D195

Forwards Response to Issues 1 & 2 of Commission Order Re Consideration of Earthquakes & Emergency Planning,Per 840409 Request

ML20105D195
Person / Time
Site:	05000000, Diablo Canyon
Issue date:	04/25/1984
From:	Jordan E NRC/IE
To:	Chandler L NRC Office of the Executive Legal Director (OELD)
Shared Package
ML20105C680	List: ML20105C725 ML20105C773 ML20105C964 ML20105D081 ML20105D120 ML20105D186 ML20105D195 ML20105D218 ML20105D290 ML20105D311 ML20105D383
References
FOIA-84-378, NRC-2022-000198 NUDOCS 8405140573
Download: ML20105D195 (3)

Text

{{#Wiki_filter:_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ - _ _ e c.ww .:n .. _ _ _ = ~. = f 9 o~ i. )ii / 'o UNITED STATES ~,, l' NUCLEAR REGULATORY COMMISSION g wasmuoros, o. c. 20sss April 25, 1984 1 1 l NOTE T0: Lawrence J. Chandler Deputy Assistant Chief Hearing Council Office of the Executive Legal Director FROM: Edward L. Jordan, Director t Division of Emergency Preparedness and Engineering Response Office of Inspection and Enforcement

SUBJECT:

DIABLO CANYON - COMMISSION ORDER REGARDING CONSIDERATION OF EARTHQUAKES AND EMERGENCY PLANNING l ii l .j l This is in reply to ELD's April 9, 1984 request. Enclosed is a proposed staff. l response to Issues 1 and 2 of the subject order. !} '1 l ward L. ordan,' Director [- Divisi f Emergency Preparedness l and ineering Response Office of Inspection and Enforcement lJ I;

Enclosure:

[]1 Response to Issues 1 & 2 l ec: R. C. DeYoung, IE j J. M. Taylor, IE S. A. Schwartz, IE J. N. Grace, IE D. B. Matthews, IE 'F. G. Pagano, IE K. Perkins, IE John B. Martin, Region V Robert Minogue, RES Robert Bernero, RES ( 910519 e57 3

s.x w_ m: .a _w o d 1-Issue 1 "Whether NRC emergency planning-regulations can and should be read to require some review of the complicating effects of earthquakes on emergency planning for Diablo Canyon;" it i Consistent with the Commission ruling in the San Onofre case (CLI-81-33), the staff still considers that the NRC regulations do not, and should not, contain y requirements for considering the effects of earthquakes on emergency planning for nuclear power plants. The applicable emergency planning regulations in 10 CFR 50.47 and in Appendix E to Part 50 contain no explicit reference to any seismic considerations. Although previous correspondence to the Commission contained documentation of the basis for the staff's position, it also contained a staff statement which may have clouded whether the staff continued to hold to the above position and q whether this is a closed item. The staff statement appeared in the memorandum j dated January 13, 1984 to the Chairman from William J. Dircks: "Further clarificatior, or refinement of current requirements and y 4 guidance might reduce the impairment of emergency response to conse-quences resulting from earthquakes beyond the SSE, but the value of il such reduction is uncertain." This statement can be generalized to almost any area having an impact on protec-tion of the public health and safety. However, because of the cost benefit considerations, this statement was in no way intended to precipitate changes to the NRC's rules and regulations regarding emergency planning. Rather, it j was part of a sumary statement characterizing the staff's consideration of the !j subject--it was not a recommendation to promulgate additional regulatory require-jj ments. The staff holds to the treatment of this subject as presented in the January 13 memorandum, including the sumary conclusions, but wishes to iterate a conclu-sion reached earlier.in that same memorandum: "For those ~1sk dominant earthquakes which cause very severe damage to both the plant and the offsite area, emergency response would have !j marginal buefit because of its impairment by offsite damage.- The ll expenditure of additional resources to cope with seismically caused

I offsite damage is of doubtful value considering the ' modest benefit in

l overall risk reduction which could be obtained."

Based on our previous consideration of this issue, the staff believes that the current residual risk is acceptable and that a review of the complicating effects of earthquakes on emergency planning for Diablo Canyon is not required nor worthy of further consideration. The staff also concludes that no additional regulationt are required in the area of emergency planning to address.the potential impacts of seismic events on emergency response capability. 4 ,e m e w

e e _. ;_s m._ _ m_ _ m_ _ ,_, m _uw - Issue 2 4 .i "If the answer to Issue 1 is no, should such a review be performed for Diablo Canyon on the ground that it presents special circumstances under 10 CFR 2.758. If so, what are the special circumstances that would permit consideration of the effects of earthquakes on emergency j planning for Diablo Canyon?" The seismic design criteria for Diablo Canyon were selected based on seismic activity and severity for that site. These criteria resulted in the safety

I related portions of the reactor facility being designed and constructed to withstand a more severe earthquake than reactors sited in areas of lower seismic activity. Because of accomodation of site specific seismic considera-tions in the reactor facility design, the staff is of the view that there is no ground for application of special circumstances under 10 CFR 2.758.

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g - ~ ~ .. l ]T ] i_ m_.m _.._._._..2 9' .3 ,,T') , u. ~' / UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COM41SSION In the Matter of f h, PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 OL ) 50-323 OL (Diablo Canyon Nuclear Power Plant ) Units 1 and 2) ) t 3 1 NRC STAFF'S MEMORANDUM RtGARDING CONSIDERATION OF EFFECTS OF I EARTHQUAKES ON EMERGENCY PLANNING (CLI-84-4) o i) {t Lawrence J. Chandler Special Litigation Counsel

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May 3, 1984 l t: ~ 'l LM y } (r /50.>,S y i O [' ' y',0):/4 %r-

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) PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 OL ) 50-323 OL N s (Diablo Canyon Nuclear Power Plant ) Units 1 and 2) ) b 3 '? 1 NRC STAFF'S f1El10RANDUti REGARDING CONSIDERATION OF EFFECTS OF 4 EARTHQUAKES ON Ef1ERGENCY PLANNING (CLI-84-4) d 't 1 Lawrence J. Chandler l Special Litigation Counsel -,l itay 3,1984 'l s Il ri i ~, ?

w.- 2 .-.-.L 9 = i UNITED STATES OF A!! ERICA NUCLEAR REGULATORY COMt1ISSION BEFORE THE COMf1ISSION } In the flatter of ) -l ) PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 OL ) 50-323 OL (Diablo Canyon Nuclear Power Plant ) g Units 1 and 2) ) l NRC STAFF'S MEl10RANDUM REGARDING CONSIDERATION OF EFFECTS OF EARTHOUAKES ON Ef1ERGENCY PLANNING (CLI-84-4) I. INTRODUCTION By Order issued on April 3,1984, the Comission requested that the I parties to this proceeding provide their views on the following issues: i

l 1.

whether NRC emergency planning regulations can and should be read to require some review of the complicating effects of earthquakes on emergency planning for Diablo Canyon; 2. if the answer to question (1) is no, should such a re-view be performed for Diablo Canyon on the ground that it presents special circumstances under 10 C.F.R. 5 2.758. If } sa, what are the special circumstances that would permit consideration of the effects of earthquakes on emergency planning for Diablo Canyon? 3. if the answer to (1) or (2) is yes, then the following information should be provided: 3 l ~ (a) The specific aspects of emergency planning at j .j Diablo Canyon on which the impacts of earthquakes should j be considered. I ~ (b) The specific deficiencies in the consideration already given to the impacts of earthquakes on emergency plans for Diablo Canyon.... 4 (c) The appropriateness of limiting to the Safe Shut-down Earthquake the magnitude of the largeit earthquake to be considered. (d) The substantive criteria for reviewing the effects of earthquakes on emergency planning,

( . ~. ~.. - -.. =-. i 1 \\ 1 ' (e) The necessity for litigatiun of this matter, in-cluding the general scope of (i) proceedings, if any, that should be held, and (ii) issues that should be litigated. CLI-84-4, slip op, at 2-3. i The views of the NRC staff follow. s l II. DISCUSSION 4 Issue 1 Uhether NRC emergency planning regulations can and should be read to require some review of the complicating effects of earthquakes on emergency planning for Diablo Canyon. ] NRC Staff's Views t j Consistent with the Consnission's ruling in the San Onofre proceeding, CLI-81-33, 14 NRC 1091 (1981), the NRC's regulations cannot and should not be read to require review of the complicating effects of earthquakes on emergency planning for nuclear power plants including Diablo Canyon. The applicable emergency planning regulations in 10 C.F.R. 9 50.47 and in i Appendix E to 10 C.F.R. Part 50 contain no explicit reference to any seismic considerations. See, San Onofre, supra,14 NRC at 1092. Moreover, 9 NUREG-0654/ fella-REP-1, Rev. 1, (NUREG-0654), which provides guidance for implementing the for. going regulations, contains no provisions for sub-j stantive protective measures or actions or for evaluations which are expressly intended to address the complicating effects of earthquakes.1/ The bases for the Staff's position were alluded to in the Staff memo-randum of January 13, 1984, atta'hed to the Commission's Order. There 1 1_/ Those provisions of NUREG-0654 cited by the Staff"in its January 13, 1984 memorandum that do explicitly address seismic considerations, II.H.S.a and II.H.6.a, do so from the standpoint of equipment necessary to determine the occurrence of an initiating event. i i J

m _m ._._:a appears to be some misunderstanding of the Staff's position; contrary to the Comission's statement (Order at 2), the Staff does not "believe that some specific consideration of the effects of seismic events on emergency planning may be warranted for plants located in areas of relatively high i seismicity." While such statement was made by the Staff in its 1982 memo- ? j randum, the subsequent 1984 memorandum intended to make clear that such consideration is no longer deemed warranted.2_/ The rationale underlying the Staff's position must be understood in light of the different levels of earthquakes which were addressed by the Staff in the January Memorandum - earthquakes up to the Operating Basis Earthquake (OBE); earthquakes above the OBE but less than or equal to the Safe Shutdown Earthquake (SSE), and 1 j earthquakes exceeding the SSE. As discussed therein, the probability of the cuincident occurrence of an earthquake up to the SSE and an independently I caused accident with offsite radiological releases sufficient to warrant emergency response is sufficiently low (i.e. less than 10-6) that it need not be considered in emergency planning. (Cf., Public Service Electric j and Gas Company, Atlantic City Electric Company (Hope Creek Generating j Station, Units 1 and 2), ALAB-429, 6 NRC 229, 234 (1977) (facility need not 3 .\\ 2/ While the Staff states, in the January 13, 1984 Memorandum, that 4 " Seismic events are considered and evaluated to a limited extent as I part of our current emergency planning reviews," the Staff's efforts j in this regard, are infomal and do not reflect a required licensing .l element which must be satisfied in order to warrant issuance of a 'i license. Such reviews are of necessity performed on an ad hoc basis, .l there being no established review criteria. Stated othe Wise, defi-ciencies found in this area may, in circumstances not present here, costitute a basis for imposing additional requirements on the basis of "special circumstances" but in the absence of such special circumstances, no further consideration or requirements are warranted. See, e.g., 10 C.F.R. 5 2.758. It is with this in mind that the Staff cited NUREG-0654, II.0-4 and II.J.10.k in the January 13 Memorandum (at 4; see also Memorandum at 5).

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w_mu.w a __. _ _ _.:,m 1 4-1 be designed for event, the probability of which is less than about 10-6 )) (See January 13, 1984 Memorandumat3).E The third level of earthquake includes events exceeding the SSE. These events, much as an OBE or SSE, are considered as initiating events j (see NUREG-0654, Appendix 1 at 1-13, item 15.a., and 1-19, item 7.) The ~ l! probability of such events is significantly less than the probability of an SSE, but the absolute probabilities of events at and beyond the SSE level are subject to large uncertainties. (Id.) Nevertheless, from a risk perspective, the Staff has concluded: ,f i .g 3/ For Diablo Canyon, the OBE is 0.29 and the SSE is 0.759 While the OBE is considered an initiating event for purposes of emergency planning (see NUREG-0654, Appendix 1, at 1-5, item 13.a.), its 1 occurrence would not itself be expected to cause an accident leading to a radiological release. The return period for such event at Diablo Canyon is approximately 275 years, ALAB-644, 13 NRC 903, 992 (1981), or, stated another way, t Canyonisapproximately3.6x10gefrequencyofanOBEatDiablo per year. The frequency of i occurrence of a severe core damage or core melt event with offsite releases sufficient to requirg emergency response is generally

l estinated to be about 1 x 10 per year. See e.g., Technical Guidance For Siting Criteria Development, NUREG/CR-2239, SAND 81-159 (1982),

Foreword, also at 2-11, n.a., and Table C-1. Thus, the combined frequency of occurrence of an OBE and an independently caused severe core damage or core melt event with offsite ccnsequgnces is at most the product of the frequencies or approximately 10 per year. Of course, if one wished to calculate this value with precision, one would also have to factor in the conditional probability of the coincidental occurrence of these two events which would significantly reduce the probability of occurrence. ]: As with the OBE, the occurrence of an SSE, while an initiating event i,; for purposes of emergency planning, (see NUREG-0654, Appendix 1, at 1-10, item 17.a), would not in and of itself be expected to result in the occurrence of an accident with offsite radiological

3 consequences. The frequency of occurrence of the SSE is typically estimated to be on the order of one in a thousand or one in ten thousand per year.

(January 13, 1984 Memorandum at 3.) The frequency of the coincident occurrence of the SSE and an independently caused accident with potential offsite radiological consequences in j approximately one in a million per year or less. ( Id_. ) P

. ~ - x, .aw.ma a s Based upon the PRA results, the staff finds that for most earthquakes (including some earthquakes more severe than the SSE) the power plant would not be expected to pose an immedi-ate offsite radiological hazard. For earthquakes which would cause plant damage leading to immediate offsite radiological hazards but for which there would be relatively minor offsite damage, emergency response capabilities ar.ound nuclear power i plants would not be seriously affected. For earthquakes i which cause more severe offsite damage, such as, for example, i disabling a siren alerting system, the earthquake itself acts as an alerting system. For those risk dominant earthquakes which cause very severe damage to both the plant and the offsite area, emergency response would have marginal benefit because of its impairment by offsite damage. The expenditure of additional resources to cope with seismically caused off-site damage is of doubtful value considering the modest bene-fit in overall risk reduction which could be obtained. January 13, 1984 Memorandumat5.0 Based on its consideration of this issue, the Staff believes that the current residual risk is acceptable and that consideration of the compli-cating effects of earthquakes on emergency planning for Diablo Canyon i is not required. 1 4/ Although the Staff's previous memoranda to the Cocinission contained 1 documentation of the basis for the staff's position, it also con-tained a staff statement which may have clouded the issue of whether the staff continued to hold the above position. The staff statement i appeared in the memorandum dated January 13, *i984 to the Chairman from William J. Dircks: "Further cicrification or refinement of ccrrent require-ments and guidance might reduce the impairment of emergency J response... [resulting from earthquakes beyond the SSE,] ] but the value of such reduction is uncertain." Memorandum j at 6. See also, Memorandum at 5. I This statement.can be generalized to almost any area having i an impact on protection of the public health and safety. However, because of the cost benefit considerations, this statement was in no way intended to reconinend changes to the NRC's regulations regarding emergency planning. See January 13, 1984 Memorandum at 5. Rather, it was part of a summary statement characterizing the staff'.s consideration of the subject. ~ i t

? x- . a. -.. L.x.& 6-Issue 2 If the answer to question (1) is no, should such a review be per-formed for Diablo Canyon on the ground that it presents special i circumstances under 10 C.F.R. 9 2.758. If so, what are the special circumstances that would permit consideration of the effects of earthquakes on emergency planning for Diablo Canyon? I l NRC Staff's Views i The seismic design criteria for Diablo Canyon were selected based on seismic activity and the severity thereof for that site. These criteria resulted in the safety-related portion's of the reactor facility being designed and constructed to withstand a more severe earthquake than reactors sited in areas of lower seismic activity. Because of the accommodation of site specific seismic considerations in the reactor facility design, t the Staff is of the view that no basis has been shown in this proceeding for application of special circumstances under 10 C.F.R. $ 2.758. See, g ALAB-728, 17 NRC 777, 795-796 (1983); LBP-81-17, 13 NRC 1122 (1981) (the proximity of Diablo Canyon to the Hosgri fault does not give rise to special circumstances warranting analysis of Class 9 accidents). It also I warrants mention th6t there is no significant difference in the seismic l considerations applicable to Diablo Canyon and San Onofre pertinent to this issue; both facilities are located in California in the near field j of potentially high magnitude earthquakes. None of the parties has previously I established any factual distinction that would otherwise warrant a departure from the Consnission's San Onofre decision. l ' Issue 3 ~ I If the answer to (1) or (2) is yes, then the following information should be provided: (a) The specific aspects of emergency planning at Diablo Canyon on which the impacts of earthquakes should be considered. ~

- __ am. ___.a__ .i 7-(b) The specific deficiencies in the consideration already given to the impacts of earthquakes on emergency plans for Diablo Canyon.... (c) The appropriateness of limiting to the Safe Shut-down Earthquake the magnitude of the largest earthquake j to be considered. .t (d) The substantive criteria for reviewing the effects

i of earthquakes on emergency planning.

[I (e) The necessity for litigation of this matter, in-t cluding the general scope of (i) proceedings, if any, that should be held, and (ii) issues that should be } litigated. NRC Staff's Views In light of the Staff's responses to Issues 1 and 2, no response to j Issue 3 is necessary. If, however, the Comission desires, the Staff f will provide a response to this issue.5/ i -5/ Prior to the Comission's decision in San Onofre, the Staff filed several docaments which provide some perspective on Issue 3(a), (c) and (d). In particular, we would draw the Comission's attention to NRC Staff Views With Respect To Questions Posed By The Atomic Safety and Licensing Board In The Area of Emergency Planning, June 22, 1981, at 2-10, and attached Affidavit of Brian K. Grimes at 1-7; Affidavit of Robert T. Jaske (FDiA) transmitted by letter from Richard K. Hoefling to James L. Kelley, et al. dated June 23, 1981, { at 2; NRC Staff Coments With Respect Tolhe Board's Order of July 29, 9 1981 Raising An Issue Concerning Earthquakes and Emergency Planning, '3 August 4,1981 and attached Affidavit of Brian K. Grimes; and, NRC 'l Staff's Response To Applicants' Request For Certification To The 1 Nuclear Regulatory Comission, dated August 31, 1981. Copies of the ] foregoing are attached. o 5

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-_.a..... a 1 -1 i , IV. CONCLUSION Based on the foregoing, it is the Staff's position that: (1) the Comraission's reguiritions cannot and should not be read to require consideration of the complicating effects of earthquakes on emergency planning for Diablo Canyon, and (2) such review is not warranted for Diablo Canyon on the basis of special circumstances under 10 C.F.R. 5 2.758. Respectfully submitted, } Mk i Lawrence J. Chandler Special Litigation Counsel Dated in Bethesda, Maryland this 3rd day of flay 1984 i d 14 l 3 l'; .- ) i j q 4

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wasmuotou. o. c. rosss i I.- e June 23.1981 1 i t Mrs. Elizabeth B. Johnson, i James L. Kelley, Esq., Chaiman Administrative Judge Administrative Judge Atomic Safety and Licensing Board Oak Ridge National Laboratory P.O. Bqx X, Building 3500 U.S. Nuclear Regulatory Commission Oak Ridge, TN 37830 Washington, DC 20555 Dr. Cadet H. Hand, Jr., Administrative Judge c/o Bodega flarine Laboratory i University of California l P.O. Box 247 l Bodega Bay, CA 94923 In the Matter of Southern California Edison Company, et al. (San Onofre Nuclear Generating Station, Units'T and 3) Docket Nos. 50-361 OL 50-362 OL

Dear Licensing Board Members:

j the NRC Staff served the "NRC Staff Views with Respect to On June 22, 1981, Questions Posed by the Atomic Safety and Licensing Board in th Emergency Planning." Enclosed is a that pleading but was not included in the materials served. f copy of that affidavit. Sincerely, W / ichard K. Ho f ing Counsel for NRC Staff [ I Enclosure j As Stated 1 / cc: See Page Two qp ~ lVf .-+.w, ,r r --

v.. .- ~ .s w... .;_z. a ua.a u.w. . _ _...: _wa a l' 2 cc w/ encl: Janice E. Kerr, Esq. J. Calvin Simpson, Esq. Lawrence Q. Garcia, Esq. David R. Pigott, Esq. Samuel'B. Casey, Esq. John A. Mendez, Esq.

1 Edward B. Rogin. Esq.

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3 Alan R. Watts, Esq. Daniel K. Spradlin Richard J. Wharton, Esq. Mrs. Lyn Harris Hicks Charles R. Kocher, Esq. James A. Beoletto, Esq. David W. Gilman Robert G. Lacy Phyllis M. Gallagher, Esq. Charles E. McClung, Jr., Esq. 4 A. S. Carstens

g Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Appeal Board

/ Secretary 'i i. 4 %e F Il 1 J

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a. Cth# ' ' ~ be.:w :s %J A --..,.is- " ' > ' a& m da UNITFD STATES Of AERICA NUCLEAN REGULATORY COMMISSION (- _tBETUNE THE ATUMIC SArETY AND LICENSING BOARD In the Metter or ) ) SOUTERN CALIFORNIA EDISON COWANY ) Docket Nos. 50-X)1 0.L ) 50-%2 0.L. (Sen Onorre Nucleer Generating -) Station, Units 2 and 3 ) U ) l;j Afridsvit or Robert T..laske I ma the Acting Director, Radiological Emergency Preparedness Division, Federal Esergency Henegement Agency. This erfidevit le intended to set forth the position of the Radiologiest Emergency Properedness (NEP) starr of the rederal Emergency Management Agency,(FEMA) 1 with respect to areas or concern identified by the Licensing Board on the above 4, captioned proceeding with respect to the proper determination of Emergency Pionning Zones and to the proper consideration to be given to off-site gilanning j ror earth, e.. l ' FEMA has applied the 10 ord 50 mile Ea.orgency Planning Zone stros in accordance with NUREG-0654/rEMA-REP-1 REV-1 and the Nuclear Regulatory Cometes1on's regulo-i tions, specifically 10 CFH 50.47 and 10 CTR Part 50, Appendix E. These zones are established by emergency pionning orricsels and are enemined for adeque'cy by the FEM 4 REP etaf f when conducting its review or alte-specific plans. With respect h to the detailed application of EPZe to speelric sites ineorer se rederal actions i ji ero concerned, the FEMA HEP 'sterr interperte the zone sizes as being ro @ ly circular with allowable variet tons in demography, topography, land charseteristics, access routes and local, jurisdictional boundaries to ensure that the boundaries ore clearly defined, con be readily consunicated to the public and eccount for local conditione near the nominal 10 mile or 50 mile boundary. my2p.4

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_m e ( C 2 \\ tfith respect to earthquakes it is the TCHA REP staff view that eerth qualce effects must be taken into account in the off-site amargency plans' , given the seismic situation in California. The TEMA REP staff accepts es adequete for planning purposes an earthquake not more severs than the Safe Sh td u own Esrthquake (SSE) se defined in 10 CTR Part 100 I ~ i ( No specisi seismic design of p@lic alerting and notification {! systema or a environmental capability is controplated. 'In its evolustion, the TEMA REP staff believes there should be nesurance of. continued com the powe station and outside agencies in order to obtain dama en ge estimates both to the site and to transportation and communication faciliti i i es off-site } es port of the coordinated response. Emergency Operating Centers (EOC) or sech of the juriedletions involved in the emergency planning effort shou'Id i have suitably distent backup roeilities to permit continued f unctioning of e jurlediction's emergency response including notifiestion to the

p411c, given the possiblif,ty or faliture of a primary EOC or its escociated 3

communications. { I declare under penelty of perjury that the foregoing is true and correct. I Executed on June 23, 1961. Robeyrt I. (Jaske

1 .x-ca s.k,;,_mwww,; . Laguh,gM4 l7 1 s nov s 1980 ' 22 DISTRIBUTION: KPerkins BGr % s Central Files NRC/ FEMA @agano) NRR Reading Steering Com'it n am ED0 Reading '7 TMcKenna EPPO Reading., r GErtter (ED0-09707) EPLB Reading SCavanaugh (NRR-4375) WDircks -EPeyton KCornell Attorney, OELD TRehm MEMORANDUM FOR: Chairman Ahearne HShapar l. Comissioner Gilinsky HRDenton i Comissioner Hendrie EGCase Comissioner Bradford PPAS SHanauer THRU: William J. Dircks li@liam ' DEisenhut rationI_ Din %g' Executive Director for Dross FSchroeder FROM: Harold R. Denton, Director BSnyder Office of Nuclear Reactor Regulation RVollmer

SUBJECT:

EXTREME NATURAL PHENOMENA CONSIDERATIONS IN FEMA EMERGENCY PREPAREDNESS REVIEWS This is to infonn the Comissioners that the Federal Emergency Management Agency (FEMA)isbeingrequestedtoprovideassistanceinreviewingthe i impact of earthquake and volcano eruption on emergency plans for certain sites. A copy of the letter sent to FEMA is attached for your information. ~ This action is being taken in response to the October 9.1980 memo from the Secretary's office. regarding the considerations of volcanic activity 4 in the Trojan site etea and also in response to interest expressed in earthquake hazards at California sites. )' The evaluations received from FEMA will allow us to address the volcanic eruption issue in evaluation of the Trojan emergency plans and the earthquake issue in our evaluation of the energency plans at and around California nuclear power plant sites. .j ' :HI x\\g Harold R. Denton Director 'kq ^ .;.a ; e j Office of Nuclear Reactor Regulation j

Enclosure:

j Memo dtd. NOVEMBER 1 1980 to FEMA l cc w/ enclosure: [ ] OPE f OGC 9 s.Y m l g b g r' SECY l g-1 o I // f ff 2 ornet).N ,0 OE NRR:D/DIR NRR:DIR

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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 a } efforts for the areas around California nuclear power plant sites and the 1 1 Trojan site with respect to the complications which might arise in the event of extreme natural phenomena and how these can best be addressed in the planning process. ] In conjunction with the Trojan plant evaluation for compliance with the i 1 new NRC emergency planning regulations, the Commission 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 j; its emergency plan to explicitly address the possible problems associated with an eruption. This will include considerations of site access during j an emergency, assured communications and appropriate revision of the il evacuation time estimates used in protective action detenninations. The li Oregon State Department of Energy, has already addressed the feasibility 1 of implementing effective protective measures during an eruption (enclosure i 1). 1

i The earthquake issue has particular relevance to nuclear plants in

] California (i.e., Diablo Canyon, Humboldt Bay, Rancho Seco and San Onofre). 1 We understand from the FEMA news release of September 29, 1980 that FEMA 't will lead a team consisting of personnel from Federal, State and local 1 agencies to accelerate efforts towards improving the state of readiness to cope with potential major earthquakes in California. In this regard we request that FEMA include in its evaluation of offsite emergency plans, p a qualitative evaluation of complicating factors which might be caused e by earthquakes for California nuclear power reactor sites. Specifically. .. J f /n p yjA' dJ a n

Es .a o _ m._ l 2-John McConnell such evaluation should include the impacts on State / local emergency plans i due to potential disruption of comunications 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 3j with an earthquake to include the type of potential complications discussed above for the Trojan facility. 1j Thank you for your assistance in these matters. J I l w Brian K. Grimes, Program Director l Emergency Preparedness Program Office Office of Nuclear Reactor Regulation i

Enclosure:

Oregon DOE Study 4 } Report Measures I i i l 1 EI 1 t } O

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1 --Q- .yw.y-s_ ~ Department of Energy i g*** Lt.90R & INDUSTRIES BUILDING, ROOM 102 SALEM, OREGON 97310 PHONE 37&4040 September 11, 1980 d;! 1 ~. d Dr. Seth Packer Portland Chapter of Physicians for Social Responsibility 1715 S.E. Pine Portland, OR 97214

Dear Dr. Packer:

AttheEnergyFacilitySitingCouncil.(EFSC)meetingonAugust8,1980 you resubmitted a petition from the Portland Chapter of Physicians for Social Responsibility (PSR) requesting that the site certificate for u Trojan be innediately revoked due to volcanic activity of Mt. St. l 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 1 review of an Oregon Department of Energy (0D0E) staff report on this d matter EFSC and the 000E Director had determined that no breach of warranty, f ailure to conply with EFSC rules or site certificate conditions, or clear and innediate danger to the public exists. A copy of the 000E staff report was provided to you. In your oral presentation l resubmitting the petition you contended that several issues have not been adequately considered by EFSC and 000E. [ The EFSC Chairman and the 000E Director have evaluated your verbal d contentions and conclude that they do not provide a substantive basis for J either revoking Trojan's site certificate or ordering curtailment of operations. Specifically, no breach of warranty, failure to comply 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 Commission (NRC) have been violated. Recent actions by NRC to deny similar petitions support this p" belief. The basis for this decision are docunented in the attached report. We will discuss any connents that you have on this issue at our meeting with PSR on September 17,1980. ( ' - - - WM h-g,..,

',2 - 7s_ m. . f,g. wa-ca m mm j Dr. Beth Packer ~ ~ I ~ September 11, 1980 ~ ) a. Page Two .t i At the two EFSC meetings where you submitted the petition, you requested h innediate 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 cart. fully j considered answers and actions. We urge that if you have further concerns on this matter that you review them with our staff and others a, knowledgeable in the particular areas of concern. If you have j substantive concerns that are not resolved it would then be appropriate D to submit them to us for consideration. Such submittal should document 1 in writing your concerns and the basis for them. f Sincerely, other Raphael Wilson Chairman, EFSCj 4 o Lynn Frank Director, ODOE 8W:LF:B0:aj/md 9054A o ~ Attachment h i 'i g y 0 d 4 9 e ? __.n_, . + - -. _..

- ww u aa gu pi~ a l .l EFSC/000E Response to Additional PSR Concerns Regarding Potential Effects of 1 Mt. St. Helens Eruptions on Trojan i ~,

===. Background=== At the April 1980 Energy Facility. Siting Council (EFSC) meeting the Oregon Department of Energy (ODOE) staff presented an evaluation of the potential effects of a volcanic eruption of Mt. St. Helens on the Trojan i d The 000E staff concluded that Trojan had been adequately d Nuclear Plant. designed for volcanic hazards and that appropriate precautionary 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

I the public health and safety. Mt. St. Helens subsequently began m

experiencing major eruptions on May 18, 1980. 11, 1980 EFSC meeting Dr. Beth Packer of the Portland Chapter At the July of the Physicians for Social Responsibility (PSR) petitioned EFSC to revoke 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. Regarding the P$R petition, jl he stated that EFSC had reviewed a detailed report prepared by 000E staff on this subject. The ODOE staff report concluded that Trojan had been properly designed to prevent eruptions of Mt. St. Helens from causing an .4 accident at Trojan. EFSC concluded that the 000E staff report adequately responded to the PSR contentions, further, the EFSC concluded that no breach of warranty or failure to conply with EFSC rules or site certificate conditions had been identified. The letter also noted that 0 the ODOE Director concluded that a clear and immediate danger does not i, exist. The Chairman then encouraged Dr. Packer to provide EFSC with any further specific information she might have that 000E stdf did not 'l adequately consider in the report. . In telegrams dated July 27,1980 to EFSC and the 000E Director, Dr. Packer again requested that Trojan be ordered immediately shut dowa due to volcanic activity of Mt. St. Helens. In a letter to Dr. Packer dated the ODOE Director stated that after consultation with the July 28, 1980, EFSC Chairman, both EFSC and 000E concluded that the telegrams offered no substantive basis for reaching a conclusion different from the earlier D EFSC and 000E conclusion that no breach of warranty, failure to comply with EFSC rules or site certificate conditions had been identified or,- that a clear and inunediate danger to the public does not exist. o 4

I 1L l

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f-i + 4 (2) IP* i At the August 8,1980 EFSC meeting, Dr. Packer resubnitted the original PSR petition with additional signatures. The written petition contained no further contentions. However, in her oral presentation, Dr. Packer stated five reasons for resubmitting the petition. These reasons were related to alleged inadequacies in the 000E staff report of July 14, 1980 q and the manner in which it was prepared, and failure of the EFSC to do its duty by allowing the 000E Director to unilaterally decide on the petition. A-1 Dr. Michael Wall, PSR and Barbara LaMontecella, concerned citizen spoke j in support of Dr. Packer's concerns. lf Conclusion 1 EFSC and 000E have reviewed each of the PSR concerns and conclude that 'I there is no substantive baris for reaching a conclusion different than 4 that previously reached by EFSC and 000E. On August 5 and 13,1980, NRC responded to several similar petitions and concluded that "the Trojan site remains suitable from a volcanic hazards viewpoint." In a 13, 1980, John Beaulieu, Deputy State Geologist. discussion on August stated that both Donald Hull, State Geologist, and he continue to believe H.. that the assessment of volcanic hazards asstaned during Trojan design 1: remains valid and conservative in view of the actual volcanic activity experienced and therefore they continue to support the earlier EFSC/000E l conclusion., ~ ~ Each of the PSR concerns are discussed separately in detail below. The following discussion also refers to the 000E staff report of July 14, j' 1980. No information has been developed that would cause 000E to change I that report. Contention 1: EFSC did not do its duty in evaluating the PSR petition but rather allowed the 000E Director to unilaterally decide on the petition. As stated at the July 11,1980 EFSC meeting, EFSC requested the 000E i staff to prepare a detailed report doctanenting the earlier conclusions N prior to startup of Trojan. The EFSC Chairman stated the report would be C distributed to all EFSC members and that he would consult with each menber prior to responding to PSR. The 000E staff completed and delivered the report to the EFSC menbers on July 13, 1980. The EFSC !) Chairman consulted with the other EFSC members on July 14, 1980. In a l letter to Dr. Packer dated July 14, 1980 the EFSC Chairman stated: "We appreciate your concerns and that you articulated specific areas that i required review. We believe the staff has responded to them in their d report." Regarding breach of warranty or failure to conply with EFSC

1 rules or site certificate conditions, he stated: "Our reading of your petition did not identify any allegations that such conditions exist."

In response to the PSR telegrams of July 27,1980, the 000E Director stated: "I have reviewed this matter again with Brother Wilson. Your telegrams, while reaffirming your earlier concerns, offer no substantive basis for reaching a different conclusion." l l

- ww - ~ (3) 4 ,p At the August 8,1980 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 that the EFSC reached its own ]ni conclusion on the petition. !l Contention 2: The 000E staff report of July 14, 1980 only addressed e. l simultaneous eruption and radiological accident. PSR intended the following cases be addressed:

1 A radiological accident caused by an eruption.

a. 4 b. A radiological accident occurring simultaneously with, but not related to, an eruption. i Evacuation around Trojan coglicated by ashfall, mudflows, and c. Ii flooding. 11 The ODOE staff report of July 14, 1980 stated that evacuation during or l imediately after a major volcanic eruption with consequences in the j i vicinity of Trojan could be difficult but that appropriate protective i This action through either evacuation or sheltering would be possible. l statement applies regardless of whether a radiological accident is caused by an eruption or occurs simultaneously with' but is unrelated to, an eruption. M 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 i heavy ashfall. These officials likened the effects on road conditions of the May 18, 1980 eruption to be equivalent to or less severe than the l {- effects of recent ice storms. l ] . Regarding mudflows and flooding, these effects may also coglicate evacuation but do not make it igossible. The basis for this statement results from an evaluation of the worst-case volcanic induced flood d (which has wider area effects than mudflows). For the worst-case li volcanic induced floods, (resulting from failure of all three dams on the j Lewis River) local portions of Hignway 30 and Interstate 5 south of Trojan and large portions of the Longview and Kelso areas could be H'2 flooded. However, Highway 30 and Interstate 5 north of Trojan and In Highway 411 out of the Longview/Kelso area would remain open. addition, most of the smaller roads leading away from Trojan would remain l> Therefore', if flooding and mudflows were to occur, they would not open. foreclose evacuation. As stated in the 000E staff report of July 14, 1980, to minimize the probability and consequences of this worst-case flood, the water level of at least one of the reservoirs contributing to l such flood has been lowered. 9 --.r--,----- - - --.- -, - - --- m

_w. a n. ll I (4) d.k ~ Based on the'above discussion, evacuation during or immediately after a l major volcanic eruption with consequences in the vicinity of Trojan could be difficult but not inpossible. However, the discussion of evacuation under such circumstances does not recognize the small probability of a simultaneous accident and eruption or that other protective actions, such as sheltering, may be more appropriate than evacuation. For example, for i a single puff release of radioactive noble gases, sheltering would y probably result in less radiation exposure than evacuation under such Lj ~ ciretsnstances since sheltering would provide less contact time and lj;j possibly better shielding. i As discussed in the 000E staff report of July 14, 1980 the need to 'l evacuate for radiological reasons during or immediately after an eruption is extremely unlikely for the following reasons: 1. Technical evaluations by 000E, NRC, and PGE of the potential effects of an eruption upon Trojan conclude there should be no adverse effects upon plant operation. t 2. In the event an eruption does affect Trojan operation, the plant

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

3. In the event of an eruption that has severe effects in the 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 l' . difficulty that Trojan engloyees may experience in driving to ld the plant. ,j !? 4. In the event that a radiological accident occurs at the same ] time or immediately after an eruption, all specific details at that time would be evaluated to determine what, if any, 1 protective actions will be taken. The specific details include i the amount, type, and duration of radioactivity released from J the plant (if any); the stability of plant conditions and likelihood of future releases; meteorology; population density L; in direction of release; and road conditions. If protective d); actions are required, the actions will be chosen on the basis of ij minimum risk. For the unlikely conditions postulated by PSR, sheltering would probably be chosen as the protective action in J lieu of evacuation since: a. evacuation could be complicated by the effects of an j eruption upon transportation, ~ b. sheltering is an effective protective action to reduce radiation exposures, in general, because of ashf all, people would already be c. indoors with the windows and doors closed. 1 .-m. m .m.

j y .2 J 1 (5)' ~ Contention 3_: The ODOE staff report of July 14, 1980 was hastily drawn up ant! cr.iy the 000E Director made the decision on the PSR petition. This contention is sidlar to contention 1 and therefore the above response applies. Further, 000E, EFSC, MRC, and PGE began evaluating this subject up to nearly two months prior to the first major eruption on 1 May 18,1980. I Contention 4a: The 000E staff report of July 14, 1980 only considered l i

)

evacuation complicated by ashfall. The complicating effects of mudflows, l flooding, food control, and fires need to be considered. The annual i evacuation drill should simulate these effects. This contention is similaf 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 mounts of radioactivity from the plant that would 4 require large-seale contrel of foodstuffs) is unlikely. The offacts of i 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 simulated evacuations. Future drills will include simulation of events which tend to coglicate evacuation and of alternate protective actions, such as sheltering, which may be more appropriate. i 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 conteniiion is similar to contentions 2 and Aa and therefore the ~ above responses apply. Evacuation under such circumstances would be difficult but not impossible. However, even in these extremely unlikely o W circumstances, sheltering would probably be chosen as the protective .j . action since it would result in the least risk and in some cases would be the preferred course of action to minimize radiation' exposure.

1 Contention de: The 000E' staff report of July 14, 1980 states that in the unlikely evant of %ss of cooling water from the intake structure that adequate ecoling can be maintained by backup means. Can adequate cooling be provided for both the reactor core and spent fuel. pool sinultaneously

/ J using the backup means? The statement on page 10 that(" adequate cooking can be provided for Yes. , a minimum of 165 hours (nearly a week) by the circulating water system and the cooling tower basic applies to all simultaneous heat sources. m. t

" ' ~ - ._u .n _ (6) i Contention 4d: The FSAR didn't consider the possibility that a j downstream river (the Cowlitz River) could affect the river bottom at Trojan. What effect does the observed 15-foot decrease in river depth have upon the FSAR flooding analyses? Is it valid to predict the effects of future eruptions when the river contour may be continually changing? 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 t j case of flooding and nudflows from an upstream river. Therefore the conclusions in the FSAR are valid and conservative. The FSAR concluded i safe operation of Trojan would not be degraded by volcanic induced ]i flooding and nudflows. i O 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 results 1 contained in the Trojan FSAR is negligible and therefore the FSAR remains valid. In general, the Columbia River basin in the vicinity of Trojan has a wide flood plane (several miles wide). For floods around Trojan, the limiting i restriction occurs about 2 miles downstream at Carroll's Bluff. The j flood plane at Carroll's Bluff at an elevation sufficient to cause j flooding at Trojan is greater than 1 mile wide. The cross sectional area h at this point has been increased slightly from that assumed in the FSAR flooding analysis due to inproved measurements and additional dredging since the FSAR flooding analysis was done in the early 1970's and has l been decreased slightly due to deposition of mud and silt from the May 18, 1980 eruption. At the worst time after the May 18, 1980 eruption, l the cross-sectional area had a conservatively calculated net decrease of I less than 1%. The cross-sectional' area of the flood plane at Trojan also decreased less than 1%, indicating that the limiting area for flooding remains at Carroll's Bluff. These reductions are within the analytical accuracy and therefore are negligible. Dredging since the May 18, 1980 eruption has further reduced the magnitude of this effect. i In a discussion on Septenber 5,1980, George Holme, Chief District j Hydrologist, Army Corps of Engineers stated that separate analysis done j

• by them conclude that there is a negligible affact upon flooding along the Columbia River due to the observed bottom contour changes. Also, in a discussion on Septec6er 5, 1980, David Weiss, Hydrologist, U.S.

Geologic Survey, agreed this conclusion appears reasonable. In a discussion on Septenter 11, 1980 Donald Kuehl, River Forecast Center, i National Weather Service, stated that separate analysis by them support this conclusion. Regarding the effects of future eruptions on the river bottom contour and - flooding at Trojan, it is not expected that subsequent eruptions will involve significantly greater effects than the May 18, 1980 eruption due 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 ..e l .+

--x-(7) ll f major eruptions to the same area of the mountain for which much of the availhble material has already been removed. However, there are nudflows which did not enter the Columbia River which could enter it later due to subsequent eruptions or heavy precipitation. The Army Corps of Engineers is closely monitoring this situation and a significant change in the river bottom contour will be apparent since the deepwater ship channel will fill first thereby restricting ship traffic. As an overcheck, PGE is conducting monthly soundings of the river in the vicinity of Trojan, y .3 i 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. Contention 4e: PSR contends that the 000E staff report of July 14, 1980 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 ODOE staff report of July 14, 1980, 000E did consider internal radiation exposure due to inhalation of ash. Using the highest ash concentrations reported in the Portland area, 'q 000E calculated an initial internal dose rate of 0.0015 mrem / hour. 000E 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 000E 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 ODOE staff report of July 14, 1980 states that during periods of impending or significant volcanic activity, PGE is insnediately notified. PSR contends that this is not the case. Specifically, for July 22, 1980 changes in seismic activity were detected at 9 a.m., the eruption occurred at 5:13 p.m., and PGE was notified at 5:28 p.m. For Q August 7,1980 changes in seismic' activity were detected at noon, the j eruption occurred at 4:26 p.m., and PGE was notified at 4:32 p.m. The . report states that Trojan has not detected any seismic forces due to q) volcanic activity. The University of Washington in Seattle. 200 miles from Mt. St. Helens, has detected such seismic activity. Why doesn't H Trojan equipment detect such activity? The following is the notification chronology for the last two major 1 eruptions: 1 i. l e t ___.__,,-..-..,,,._m_ y-

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

) quakes detected ) ) 2:00pm-5:00pm Increasing frequency and magnitude of earthquakes ) j Washington Depart-ia ment of Emergency 1 Services (WDES) .i ssage to Fed- ~ eral Emergency Management Agency (FEMA) and Oregon p/ Emergency (Serv J0ivision CESD) 1) 5:14 pm Eruption to 45,000 f t. 5:20 pm Trojan notified of PGE(Zimerman) .l eruption by PGE ~! 5:35 pm Trojan (Taylor) notified 000E Trojan 000E(Dixon) of eruption Log

• I 5:35 pm U.S. Forest Service (USFS)

OESD Incident notified Oregon State Police Report (OSP) and OESD of eruption 2 8/7/80 1:45 pm USFS notified Trojan of PGE(Zimmerman) increased seismic activity j 2:50 pm Trojan (Yundt) notified 000E Trojan ODOE(Dixon) of potential Log l eruption 4:23 pm Eruption to 44,000 ft. WDES message to FEMA /0ESD 1 ll 4:28 pm USFS notified OESD of OESD Incident eruption Report

j

'l >1 4:30 pm USFS notified Trojan of PGE(Zimmerman):- ' i eruption ) 4:40 pm PGE(Zimerman) notified 000E Trojan ODOE(Dixon) of eruption Log i m

(9) Based on the above chronology, PGE is being notified of inpending 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 1 t seismic forces at the plant site as small as 0.01 g. An earthquake of

j this magnitude during the day would be felt indoors by many, outdoors by 1

few. At night some people would be awakened. As stated in the 00CE (' 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 ll 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, i i d Beaulieu and Couch stated that a system of seismographs are installed j throughout Oregon and Washington, including some in the vicinity of Mt. St. Helens, for which the measurements are transmitted to Seattle. These a instruments have a sensitivity two orders of magnitude less than human detectability (down to 0.0001 g). Therefore they would expect the .1 University of Washington in Seattle to detect seismic forces that Trojan does not. The U.S. Geological Survey has a similar systen which feeds information to Menlo Park, California. Contention Sa: PSR is concerned that the evacuation plan for the ten-mile radius around Trojan has not yet been approved by the NRC. On August 19, 1980, NRC published a rule to become effective on Novenber 3,1980 that specified requirements for emergency response plans. The j. rule stated that within 60 days of its effective date, revised emergency response plans meeting these requirements must be submitted to NRC. The ql, . NRC must find these plans provide reasonable assurance that adequate 1 protective measures can and will be taken in the event of a radiological j 3 emergency. By April 1,1981 these revised plans must be implemented. Any deficiencies that still exist at that time must be corrected within y four months. Prior to adoption of this rule there were no specific requirements or NRC approval needed for emergency response plans. 1 While the plan and agreements as they exist today provide an adequate framework for responding to a Trojan radiological emergency revisions are being made to conply with the NRC rule and efforts will continue to make 4 further inprovements.

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~ o- ~ (10) Contention 5b: PSR is concerned that the control building modifications have not yet been cogleted. The control building modifications are being made to allow continued operation after an earthquake up to 0.15 g. Currently, the plant is required to shut down af ter an earthquake of 0.08 g. The Atomic Safety j and Licensing Board, NRC, 000E, and PGE all agree that adequate strength exists for Trojan structures and equipment so that a safe shutdown u condition can be achieved and maintained following a large earthquake up to 0.25 g. Therefore, the only significance of these modffications is that they will permit PGE to continue operating Trojan during and after larger magnitude. earthquakes than they currently are permitted to do so. Even without these modifications, safe shutdown for large earthquakes is possible. j This issue was addressed in the 000E staff report of July 14, 1980 on l page 5. Contention Sc: PSR is concerned that on August 7,1980 the red zone around Mt. St. Helens was expanded to 20 miles. Therefore, Trojan is only 11 miles away from the red zone. If the red zone was expanded another 5 miles, Trojan would only be 6 miles away from the red zone. The size of the controlled access area around the wolcano has no direct bearing on the safety of Trojan operation. The controlled access area has been periodically adjusted depending on recent or expected volcanic j i activity and to facilitate ease in access control. As discussed above, Trojan is advised of significant or igending changes in volcanic activity and takes. appropriate actions. Further, the information presented by PSR on the distance between Trojan l and the red zone and the change to the red zone size are not accurate. l The PSR contention assines Trojan,is 31 miles from Mt. St. Helens, In 1 actuality, the distance is approximately 34 miles.

j 1

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 the Washington Department of Emergency Services (WDES). In a discussion a

on August 14,1980, Paul Stenkamp, Director. Emergency Coordination s j Center, USFS, stated the following: ilb a. On March 25, 1980, access was restricted (i.e., red zone ~ j, established) above the tinberline on Mt. St. Helens (2 to 3. mile l radius). b. On April 30,1980, access was restricted (i.e., red zone expanded) in all of Gifford Pinchot National Forest except the ll Mineral area. The radius of this restriction was up to 30 lI miles. (In the direction of Trojan, the restriction was about 4 16 miles.) ,i;j f .._m ,_,_.,,--,...-.m..,

-- ~.-.-;,_ (11) l c0 On June 4,1980, the restriction was lifted (i.e., red zone reduced) for National Forest land north of Highway 12 (this had no effect on the restriction distance in Trojan's direction). the restriction was reduced (i.e., red zone OnJuly)25,1980, is d. reduced to about 14 miles in all directions. The recreational d restriction zone (i.e., blue zone), which permits industrial a j activity but prohibits recreation, was also reduced accordingly to about 20 miles. 4 j~ In a discussion on August 13,1980 Ken Olsen, Red Zone Coordinator, WDES, stated the following regarding the state-ingosed access restrictions (i.e., red zone): 3 On April 1980, WDES restricted access to permit only pemanent a. residents and emergency workers within 20 miles of Mt. St. Helens. b. On July 29, 1980, the restriction was reduced to about 16 miles from the volcano in Trojan's direction to allow access to Lake j Merwin. ]l c. WDES is currently considering further reductions in the restrictions. 8ased on the above, it is apparent that the access restrictions around Mt. St. Helens have recently been reduced instead of increased as stated in the contention, g i l 80:aj/md 9054A l l d, s

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.s , -.., Pc:t!:nd General EecMc Cent.cny -- -, Mc ,7 8 d- /)' lq Y" July 30,1982 + j Trojan Nuclear Plant Docket 50-344 License NPF-1 Director of Nuclear Reactor Regulation ATTN: Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing U. S. Nuclear Regulatory Commission + l Washington, DC 20555 I

Dear Mr. Clark:

'l Radiological Emergency Response Planning on October 9, 1980, the NRC denied a petition concerning the safety of I the Trojan Nuclear Plant following a volcanic eruption of Mount St. Helens. In doing so, the Commission directed the NRC Staff to examine the effects of volcanic eruptions on emergency response planning at the Trojan site (Attachment 1). i 'I .) In response to this request, the NRC Staff requested the Federal Emergency -{ Management Agency, on November 3,1980, to examine the effects of volcanic eruptions on State and local emergency planning around the Trojan site j (Attachment 2). In the same letter, FEMA was also requested to examine the effects of earthquakes on State and local emergency planning around the nuclear power plant sites in California. [ On December 1,1980, FEMA forwarded the request to FEMA Region I (Attach-ment 3). However, this letter requested a study of the effects of both I volcanic eruptions and earthquakes on State and local emergency planning ] ~ within the region (ie, around the Trojan Nuclear Plant). This was appar-p ently a misinterpretation of the NRC request. This misinterpretation has i not been resolved and FEMA has requested information from PGE concerning seismic activity around the Trojan site (Attachment 4) and from the State and local officials regarding f acilities which may be required in a l radiological emergency (Attachment 5). PGE has, in the meantime, had several discussions with both the NRC W Region V office, (Mr. R. H. Engelken and Mr. Robert Faulkenberry) and j your Mr. Charles Trammell concerning this problem with FEMA. Both Messrs. Faulkenberry and Trammell have informed PGE 'that they have 1: i y N ~; 7 i T S n Samen Sreet 6 : arc. C e;:n F2'?A 7. . m.p.=__ mmmm_,

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.u.....=.. ....m I .%.t.-d C5r.E.-J I'ddi: Cc.- ..y Mr. Robert A. Clark i July 30,1982 . 1 Page Two I d . discussed the issue with B. K. Grimes of the Division of Emergency Preparedness who indicated to them there was no intent to perform any n special investigation of the impacts of earthquakes on emergency planning for Trojan. '{ Discussions with FEMA Region I (Mr. Richard Donovan) indicate that the ';f special seismic study for the area around the Trojan Nuclear Plant is being performed because of instructions from FEMA headquarters office under the auspices of the Earthquake Mitigation Act. Performance of this study will require the expenditure of effort and funds by PGE and State and local government agencies to provide the information requested by FEMA. Subsequent effort may also be required

j to resolve the appropriate magnitude of earthquake to assume for emergency planning versus the licensed plant design basis. None of this eff, ort is required by either NRC or FEMA regulations. There are no bases for performing such a study in the Northwest.

In light of this development, PCE requests your assistance to correct FEMA's misinterpretation of the NRC's original request on this issue. Sincerely. e a tl. > !l Bart D. Withers Vice President Nuclear 4 4 eil rl ~ Attachments 3 1 ; c: Mr. Lynn Frank, Director j State of Oregon 4 Department of Energy g i Mr. William Mayer, Director D j Federal Emergency { Management Agency Region I t 4 I k- -,. -.~ ,;. n.,, gy 3. y, q ,7m 5

~' ~ --- ...........,c.- - -- - ~ - -- - - ~ ~ - - - ~ ~ ~ " ~ ~ ~ ~ " Trojan.Nucloor Plant Roberc A. Clerk Docket'50-344 8". 4 M y 30, 1982 License NPF-1 Attac. h t 3 i Page 1 of 1 y r:EDERAL EMERGENCY MANAGEMENT AGENCY 57 Washington D.C. 20472 ~ ~ 'C December 1, 1980 'C .s .~ lEft0RANDLkt TOR: Neale V. Chaney, Director 1 FEMA Region X FRG4: John W. McConnell i Assistant Associ e Director for Population Preparedness i' j SLBXCT: Review of the Effects of Earthquakes and Volcanic Eruptions on State and Local Radiological Emergency Preparsdness The Nuclear Regulatory Commission has requested their licensees in the I, western States to consider the effects of earthquakes and of volcanic eruptions on the ecomunication networks'and evacuation plans around q licensed faciliti2s and review their emergency plans as appropriate. In our discussions with Brian X. Grimes, Director of the MtC Emergency i >,'] Preparedness Program Office, we have agreed that the FDtA Regions in the West (Regions IX and X) should also consider these events in the evaluation -3 3 of State and local plans. We are interested in a qualitative evaluation of the complicating factors (e.g., disruptions of communications and evacuation routes) seich might require special preparedness if such events occur in parallel with a radiological emergency or are involved in their initiation.

• ')

I see this as a reasonable part of FEMA's overall responsibility for comprehensive emergency management in an area where TEMA has had con-j siderable near-term experience. i. 1 Accordingly, please plan to conduct the analyses of the interactions of severe geophysical events such as volcanic eruptions and earthquakes i (giving due consideration to severe ashfall, mudflows, floods, landslides and associate communication and transportation disruptions) with the plans of Stata and local plans for REP around commercial power plants in your j Region. In the near term, I would appreciate an outline of your study approach and a time schedule with milestone dates for completion. At a later date, we will also rertuest consideration of the interactions of such geophysical events on the balance of non-commercial fixed nuclear -l facilities and with potential radiological accidents. 1:- i- ..J:'.6 - '. L ' ) i ut h,..' .-.A ~- %. E $ "1 = a '*....g \\ "~ ?'-73~50~iX&&?((?. " mix 5 ~ ' W DWWAEM L

.._.._.._?.. ...._._.,.,...:..._..~.. Trojan Nuciocr Plant Robar: A. Clark 't Docket 50-344 July 30, 1982 l License NPF-1 Actachment 4 Page 1 of 2 /[,, h Federal Emergency Management Agency 'i}(( Regio'n X l Federal Regional Center Bothell, Washington 98011 [ .JUL 2 3 EP l' R E C E l'V E D i Bart O. '..hh r.'

• j Yice Pres 4dertt. Nucic :

t Bart Withers, Vice President i Nuclear, Portland General Electric JUL 2 61982 l 121 S.W. Salmon Street j Portland, Oregon 97204 I

Dear Mr. Withers:

As you probably know, my National Office has requested us to perform a review of the effects of earthquakes on the c4pab111 ties of State and local j governments to execute plans for radiological emergency prepardness (REP) around conumercial and non-comme.rcial nuclear power plants in our Region. I We requested and received permission to divo";ce this study frcza FEMA's REP j approval process for offsite emergency response plans and preparedness. 1 One of the reasons for requesting this disassociation was because of the study being performed by Dr. Weaver of the University of Washington.. Dr. Weaver's study concerns a specific seismic zone originating near Mt. Hood, Oregon, and running north / northwesterly to near Olynpla, Washington. We have awaited completion of this study so that we could review all possible concerns. After receipt of this study, we wrote the States of Oregon and Washington requesting that they identify structures that would be critical to the execution of their offsite preparedness plans. t i Mr. Donovan of my staff informed Mr. Walt of PGE of this effort. Based upon 1 that conversation and others, PGE has discussed the matter of our study with j NRC Region V and NRC National Offices. NRC and FDIA have also discussed the j subject in Washington. As a result of their conversations, we have been advised to continue with the study. In order to expedite our consultant's efforts and reduce the potential expenditures, Mr. Donovan asked Mr. Walt if PGE could provide us access to the ( isoseisaal maps prepared as part of your Preliminary and Final Safety Analysis Review with NRC. PGE has indicated that it is unwilling to do this. I would I l like you to review this request and reconsider our request for these maps. l Our review and study is strictly limited to offsit preparedness. It is neither the intention or scope of the study to a ~ tess seismic issues related to the Trojan Plant. However, in view of the ff ings of the Weaver study we feel it important that any potential impact on c. .ical offsite facilities be i investigated. Having access to existing isoseismal maps will not only result in cost savings to the government but will allow us to complete the study i sooner by not having to rado the isoseisaal maps. 4 / "I l?-53.. 7 s:W t NW2.h " ~ ~ '"~ ~ ' ' ' * "TW~CM.Q.B yg ;. 7m n

~~~-.:= - - = " " ^ - - ~. -- .,. a........ .. ~. - ^- Trajan Nuciocr Plant Robert A. C1crk July 30, 1982 Docket 50-344 License NPF-1 Page 2 of 2 2 A single set of maps would give us a common basepoint from which to determine site-specific intensities. This is important as we would have to hire a separate consultant to develop new maps. If these maps are different from those used by.PGE, then the issue can be raised as to which maps and seismic l intensities are correct. !j I would appreciate your reply by August 6,1982. If you have any questions, l please contact me or have your staff contact Mr. Donovan. t sincerely, e Wm. H. Mayer Regional Director i 4 t b a +1 .a 1 -t h < s s g 9 .: 1 t .I 6 i t i .1 1 i ; 1 1 4, e 1 unw . - n m.r-w.i

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Trojan Nucleer Plant July 30, 1982 Docket 50-344 Accachment 5 , ' ' / License NPF-1 Pase 1 of 1 Mpj Federal Emergency Management Agency 1' g! Region X Federal Regional Center Bothell, Washington 98011 RECENED JtA.I Lc32 JUL 6-1985 DEPT.OF ENERM Lynn Fi'ank, Director _8 i Department of Energy .y 'g Labor & Industry Building #111 to Salem, Oregon 97310 f-

Dear Mr. Frank:

h ?. Last spring and summer we exchanged correspondence on the issue of volcanic and earthquake related contingency planning as it pertains to your State and local plans and procedures for the Trojan Nuclear Power Plant. You agreed to revise the State and county plans / procedures with respect to volcanic related contingencies. We asked and received approval from our National office to separate our evaluation of the earthquake issue from the y vs volcano issue in the development of our findings for the Trojan Site. h A study recently prepared by Craig S. Weaver of the U.S. Geological Survey p? depicted a seismic zone originating near Mt. Hood in Oregon and running north / northwesterly to near Olympia, where high magnitude earthquakes at a ~ shallow depth are possible. We have awaited completion of this paper so that {I we could finish our assessment. u., r In order for us to complete our vulnerability analysis of offsite structures, p we need from you a list of structures that would be critical to the execution of your offsite preparedness plan for the* Trojan Site. This list should s include your EOC's, other necessary response centers, communication h i f acilities, and any critical elements of the transportation network (e.g., i bridges). Please specify the address, and refezence the structures on either the 10-mile or 50-mile grid maps for the Projan site, so that we may proceed. we need this information b Q ugust 2, 1982] y If you have any questions, you may contact Mr. Richard Donovan of my staff. j f 5 f 4 Sincerely, l 1 N ^# 9 "" ^ .m... Mayer j Regional Director I l l ] Copy tos John T. DeFrance, Director ) Columbia County Emergency Services 9 1 4 I '] r s.. ,......s

-,a c.a..: :Lw - M w n~ ' " = ..3 l e[- Trojan Nucloor Plant

• ',, Y-7.$, '. UNITED STATES ?-'# 6 ' ' f '.'..'. l.)[.k 1, ';..

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d Robart A. Clark

}

1. boeket 50-344 i.4 $ July 30, 1982 License NPT-1

. I NUCt. EAR REGULATORY COMMISSION,.!';$.$, Attachment 1 e E$ LY$ lh S. s .$Rf{$OcN.... A-~hW 7/l$$&' ;. W"j{&'bt.?;1980'.;,'"', I..?. 7;. h '[:T; 5' 9,E ..e w i 5e*,*.Yk

• $.' Whl.?l?D

.t*J saentrAnv ,'g Q. . g ,i, -.. c.p ;'. .,..y-{g 5 . _S P MEMORANDUM FOR: ' William J. Dircks, Executive Director .~. : F . for atic s ~# e M <e j h k.' ~4N FROM: h Ac g Secretary ,Jo n C. cy A.,. e ..;i

SUBJECT:

DD-80 26, TROJAN NUCLEAR PLANT: ~ DENIAL -. p'. OF 2.206 RELIEF TO TROJAN DECOMMISSIONING h*y* gp' .3 ALLIANCE (SECY-A-80-13 8 ). ~ (COMMISSIONER ACTION ITEM) .j w 3 %.M Y. This is to advise you that the Commission has decided not to 'NE ~~ M review the Director's decision denying the Trojan DecommissioningM Alliance 2.206 request. However, in view of the strong possibility of continued volcanic activity of Mount St. Helens

L )g over the next few years, the Commission believes'that further

~f, l consideration should be given by the Director to the problems f.,g of evacuation during or soon after an eruption. Therefore, the Commission directs the staff to more closely examine, in conjunction with the Trojan plant evaluation for compliance .:.6(+, E wir.h the new emergency planning regulations, 45 Fed. Reg. 55402 W.y,. v. (August 19, 1980, effective November 3,1980), the problems of

+Le effective protective measures and evacuation during or soon

.?;f,QI j after an eruption, giving due consideration to the possible

• y e2fects of severe ashfall,.mudflows, floods, and landslides.

. ; qi .M@ i cc: "s. = Chairman Ahearne .. E Commissioner Gilinsky ? Commissioner Hendrie Commissioner Bradford d General Counsel '.,7,M j Director, Policy Evaluation .N l l Director, Nuclear Reactor Regulation e,i Executive Legal Director .^ i Chief, Docketing & Service Branch, SECY 1 \\ t i

c..

CONTACT: E. W. McGregor (SECY) .l 41410 i 4 i i (4. i u t v > " ' ' #,' OCT H M - i I i e o i f LW' iti:.'s",,;.y s%,;;. d* ? -* F $l-f8 ~ " ~'?h. ~;7i. m. p

._a.1. ,.. m n. Robert A. Clerk ij

y. Tro.j an Nucicar Plant WITED STATES July 30,1982

.;,8 ). Docket 50-344 License NPF-1 UCLEAR REGULATORY COMMISSION wasmacto=.o.c.no m P 1d2 sse..c..f - nevinr4 1980 ) MEMORANDUM FOR: John McConnell. Assistant Associate Director for Population Preparedness. FEMA 1 ' FROM: Brian K. Grimes. Program Director. Emergency Preparedness Program Office. NRR ! I, REQUEST FOR FEMA ASSISTANCE TO REVIEW EFFECTS OF

SUBJECT:

EARTHQUAKE AND VOLCANIC ERUPTION ON STATE / LOCAL 1 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 i ! adequately addressed, we request that FEMA review the State and local planning 1 efforts for the areas around California nuclear power plant sites and the l. l* Trojan site with respect to the complications which might arise in the event of extreme natural phenomena and how these can best be addressed in jj 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 effectsofsevereashfa11.mudflows, floods,andlandslides)beclosely examined. In this regard, we are requesting the licensed utility to revise its emergency plan to explicitly address the possible problems associated 1 with an eruption. This will include considerations of site access during an emergency, assured comunications and appropriate revision of the evacuation time estimates used in protective action deteminations. The Oregon State Department of Energy, has already addressed the feasibility tt of implementing effective protective measures during an eruption (enclosure 3 ij j 1). The earthquake issue has particular relevance to nuclear plants in California (i.e.. Diablo Canyon. Humboldt Bay Rancho Seco and San Onofre).

1,

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

i agencies to accelerate efforts towards improving the state of readiness to cope with potential major earthquakes in California. In this regard i

we request that FEMA include in its evaluation of offsite emergency plans, a qualitative evaluation of complicating factors which might be caused i-by earthquakes for California nuclear power reactor sites. Specifically. i i i l j C ' V_d2 n A ; 3.~2 y -..., si,*p m.g.ypyneewl syypm.

j I . Trajan Nucicer Plant m A. C1cd i.' Docket 50-344 July 30, 1982 License NPF-1 Paga 2 of 2 -2 John McConnell such evaluati6n should include the impacts on State / local emergency plans due to potential disruption of comunications 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 t above for the Trojan facility.

1 Thank you for your assistance in these matters.

1 z,p3 ~ Brian K. Grimes, Program Director e Emergency Preparedness Program Office Office of Nuclear Reactor Regulation

Enclosure:

Oregon DOE Study Report Measures 9 9 4 0 I i. I i s 6 I t I / ei ' ~ ^ - - - - 7... 7..7. e, o w v. e, v........,, -

~2 , -;;g .= -..x.- ~~ ->::.s l c n ..,c-. Z PcfJand General ElecMc Cen ;:eny C 'J u I i l July 30', 1982 1 Trojan Nuclear Plant Docket 50-344 j License NPF-1 t Director of Nuclear Reactor Regulation ATTN: Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555 j

Dear Mr. Clark:

Radiological Emergency Response Planning i On October 9,1980, the NRC denied a petition concerning the safety of the Trojan Nuclear Plant following a volcanic eruption of Mount St. Helens. In doing so, the Commission directed the NRC Staff to examine the effects of volcanic eruptions on energency response planning at the Trojan site (Attachment 1). j In response to this request, the NRC Staff requested the Federal Emergency Management Agency, on November 3,1980, to examine the effects of volcanic eruptions on State and local emergency planning around the Trojan site ] (Attachment 2). In the same letter, FEMA was also requested to examine j the effects of earthquakes on State and local emergency planning around j the nuclear power plant sites in California. I ( On December 1,1980, FEMA forwarded the request to FEMA Region I (Attach-1 ment 3). However, this letter requested a study of the effects of both j volcanic eruptions and earthquakes on State and local emergency planning j within the region (ie, around the Trojan Nuclear Plant). This was apper-ently a misinterpretation of the NRC request. This misinterpretation has not been resolved and FEMA has requested information from PCE concerning f seismic activity around the Trajan site (Attachment 4) and from the State and local officials regarding facilities which may be required in a l radiological emergency (Attachment 5). PGE has, in the meantime, had several discussions with both the NRC W Region V office, (Mr. R. H. Engelken and Mr. Robert.Faulkenberry) and your Mr. Charles Trammell concerning this problem with FEMA. Both l ' Messrs. .' % erry and Trammell have informed PCE that they have i s g .. 7..g,...;.t;

sc 7.. - 7.. _ -u p g g. g._ q sy, g g 9....- ? : f.' ~ d C 2 r.2::1 W.: b C c. = r:; Mr. Robert A. Clark July 30,1982 Page Two discussed the issue with B. K. Crimes of the Division of Emergency Preparedness who indicated to them there was no intent to perform any special investigation of the impacts of earthquakes on emergency planning for Trojan. Discussions with FEMA Region X (Mr. Richard Donovan) indicate that the special seismic study for the area around the Trojan Nuclear Plant is being performed because of instructions from FEMA headquarters office under the auspices of the Earthquake Mitigation Act. Performance of this study will require the expenditure of effort and funds by PGE and State and local government agencies to provide the information requested by TEMA. Subsequent effort may also be required to resolve the appropriate magnitude of earthquake to assume for emergency planning versus the licensed plant design basis. None of this effort is required by either NRC or FEMA regulations. There are no bases for performing such a study in the Northwest. In light of this development, PCE requests your assistance to correct l TEMA's misinterpretation of the NRC's original request on this issue. ll Sincerely, i I --) Bart D. With'ers Vice President Nuclear . -l Attachments c: Mr. Lynn Frank, Director State of Oregon Department of Energy Mr. William Mayer, Director Federal Emergency j Management Agency Region X i 1 I j

.e4

~ - - -

gyyy - = -. - Robert A. Clark Trojan Nu&locr Planc ,. 6 ' + July 30, 1982 Dock:t 50-344 Actachmenc 3 1.f.e nse NPF-1 p,g, g og y \\. FEDERAL EMERGENCY MANAGEMENT AGENCY ....t.. r Washington D.C. 20472 2 December 1, 1980 .s l IEHORANDUM FOR: Neale V. Chaney, Director

,j' fDiA Region X i

}

FRG4: John W. McConnell N Assistant Associ to Director l' for Population Preparedness SLEXCT: Review of the Effects of Earthquakes and Volcanic Cruptions on State and L.ocal Radiological Emergency Preparedness The Nuclear Regulatory Commission has requested their licensees in the western States to consider the effects of earthquakes and of volcanic eruptions on the communication networks and evacuation plans around j; licensed facilities and review their emergency plans as appropriate. 13j! In our discussions with Brian X. Grimes, Director of the NRC Energency Preparedness Program Office, we have ogreed that the FDtA Regions in the West (Regions IX and X) should also consider these events in the evaluation. j of State and local plans. We are interested in a qualitative evaluation of the complicating factors (e.g., disruptions of communications and ji evacuation routes) which might require special preparedness if such events I occur in parallel with a radiological emergency or are involved in their initiation. l I see this as a reasonable part of FEMA's overall responsibility for comprehensive emergency management in an area where FEMA has had con-l siderable near-term experience. Accordingly, please plan to conduct the analyses of the interactions of severe geophysical events such as volcanic eruptions and earthquakes (giving due consideration to severe ashfall, mudflows, floods, landslides and associate communication and transportation disruptions) with the plans of State and local plans for REP around commercial power plants in your Region. In the near term, I would appreciate an outline of your study approach and a time schedule with milestone dates for completion. At a later date, we will also request consideration of the interactions of such geophysical events on the balance of non-commercial fixed nuclear facilities and with potential radiological accidents.- l t Mh '6; l L-.' ) t ua. f..~

• i

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- e. .m.._,_,_ Rob 2rt A. Clark

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.-.. '- Trsjen Nuclear Plant July 30. 1982 Docket 50-344 Attcchment 4 License NPT-1 p g g Federal Emergency Management Agency i K Region X Federal Regional Center Bothell, Washington 98011 - .JUL 2 31952 RECEIVED i f. Cart D. '..h!t.s0 Yice Presadent, Nudc.'.s e,, I: Bart withers, Vice President JUL 2 61982 + l. Nuclear, Portland General Electric k "'

• 121 s.W. salmon Street Portland, Oregon 97204 4

Dear Mr. Withers:

,i ) As you probably know, my National Office has requested us to perform a review of the effects of earthquakes on the c4pabilities of State and local l governments to execute plans for radiological emer Tency prepardness (REP) q around coannercial and non-commercial nuclear powe plants in our Region. Ne requested and received permission to divorce this study from FINA's REP ,j approval process for offsite emergency response plans and preparedness. 3; One of the reasons for requesting this disassociation was because of the stu'dy i, being pe: formed by Dr. Weaver of the University of Washington. Dr. Weaver's srtudy concerns a specific seismic zone originating near Mt. Hood, Oregon, and running north / northwesterly to near Olyngia, Washington. We have awaited completion of this study so that we could review all possible concerns. After receipt of this study, we wrote the States of Oregon and Washington requesting j that they identify structures that would be critical to the execution of their offsite preparedness plans. l. Mr. Donovan of any staff informed Mr. Walt of PGE of this effort. Based upon ie that conversation and others, PGE has discussed the matter of our study with ll NRC Region V and NRC National Offices. NRC and FIMA have also discussed the l{ subject in Washington. As a result of their conversations, we have been 4 advised to continue with the study. Il !} In order to expedite our consultant's efforts and reduce the potential ji expenditures, Mr. Donovan asked Mr. Walt if PGE could provide us access to the l isoseismal maps prepared as part of your Preliminary and Final Safety Analysis Review with NRC. PGE has indicatec. that it is unwilling to do this. I would ] like you to review this request and reconsider our request for these maps. Our review and study is strictly limited to offsite preparedness. It is neither the intention or scope of the study to address seismic issues related l: However, in view of the findings of the Weaver study we ll to the Trojan Plant. feel it important that any potential ingact on critical offsite facilities be ljl investigated. Having access to existing isoseismal maps will not only result ll in cost savings to the government but will allow us to complete the study )! sooner by not having to redo the isoseismal maps. t l

-~ Rob 3rt A. Clcrk Trsjan Nuciccr Plang July 30, 1982 Docket 50-344 Actrehm:nt 4 License NPF-1 Page 2 of 2 2 A single set of maps would give us a comunen basepoint from which to determine site-specific intensities. This is important as we would have to hire a separate consultant to develop new maps. If these maps are different from those used by PGE, then the issue can be raised as to which maps and seismic { l' intensities are correct. I would appreciate your reply by August 6,1982. If you have any questions, please contact me or have your staff contact Mr. Donovan. ~ Sincerely, a n.hy Wm.,H. Mayer Regional Director P i 4 1 j !i 1 1 .i i t t i l 4

.. j..........

• ~ 3 r & m
• y,9 m.g g.

., Troj an Nuclocr Plant Rob 3rt A. Cicrk Dockst 50-344 July 30,1982 ',,, M License NPF-1 F Fvt Federal Emergency Management Agency Pase 1 of 1 u ya. -) Region X ij j Federal Regional Center Bothell, Washington 98011 - t,) ce y RECENED JUL l 1932 JUL 6-282 DEPT. OF ENERM Lynn Frank, Director Department of Energy ..jj Labor & Industry Building #111 Salem, Oregon 97310 'i j Dear Mr. Frank Last spring and summer we exchanged correspondence on the issue of volcanic and earthquake related contingency planning as it pertains to your State and local plans and procedures for the Trojan Nuclear Power Plant. j' You agreed to revise the State and county plans / procedures with respect to volcanic related contingencies. We asked and received approval from our National office to separate our evaluation of the earthquake issue from the l' ]l volcano issue in the development of our findings for the Trojan site. i' A study recently prepared by Craig 5. Weaur of the U.s. Geological survey depicted a seismic zone originating near Mt. Hood in Oregon and running north / northwesterly to near Olympia, where high magnitude earthquakes at a shallow depth are possible. We have awaited completion of this paper so that we could finish our assessment. In order for us to complete our vulnerability analysis of offsiM structures, we need from you a list of structures that would be critical to the execution of your offsite preparedness plan for tho' Trojan site. This list should include your EOC's, other necessary response centers, cocumunication facilities, and any critical elements of the transportation network (e.g., bridges). Please specify the address, and reference the structures on either the 10-mile or 50-mile grid maps for the Trojan site, so that we may proceed. WeneedthisinformationbQugust2,1982] 'l +} If you have any questions, you may contact Mr. Richard Donovan of my staff.

I

'l sincerely, o @ M.b q- ), Wm. H. Mayer Regional Director

l Copy to

T I John T. DeFrance, Director Colur.bia County Emergency Services 1

. c._.- ~.. ,,.,,w,....- 1.3. ',p,,,.~f.,3,'*di Rob 3rt A. Clark Tre.j an Nuclocr Plant, ,,,Q' p'

• f.% -. ).;,; 'T..,,l Docket 50-364

,,,. 4 UNITED STATES %- $

.I v 4 '.' i July 30, 1982 License NPF-1 -. ' NUCl. EAR REGULATORY COMMISSION, f.';-V.j[*'i, Attachment i e I Y. i ' p.h[.iN '.I ^ ~~;' ~ ~'~ - i.. wAsHINcroN,D.c.20sse y, , - 2'y. W. - Page 1 o f 1 .L.i i4 W.$ Y ?V k,,,h

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E p w $....$,..s f ', *, .,..f j( , -.,, g/,47 ,.,. v ,, -[. - ' g,*, ' SECR ETARY

, ircks, Executive Director *;..

l.%[.3

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~ .. ~ ~,, - D .~, (- MEMORANDUM FOR: ' William J. K for ' atic s

• g,

, h- .:.v. ~Q, FROM: , John C. oy , Act.tng Secretary [,.. DD-80-26, TROJAN NUCLEAR PLANT: DENIAL. ..p ~. v .. rp,e s ,.,g-q' i.9

SUBJECT:

Q' '.

OF 2.206 RELIEF TO TROJAN DECOMMISSIONING W-O 'A ALLIANCE (SECY-A-80-138),

ffd,

.A (COMMISSIONER ACTION ITEM) 32 1 g,

r..

u. T. This is to advise you that the Commission has decided not to ?4 'N reviewtheDirector'sdecisiondenyingtheTrojanDecommissioning'N. Alliance 2.206 request. However, in view of the strong possibility of continued volcanic activity of Mount St. Helens J,. p over the next few years, the com=ission believes 'that further ~fg l consideration should be given by the Director to the problems t!y i of evacuation during or soon af ter an eruption. Therefore, 'y the Commission directs the staff to more closely examine, in '.4 conjunction with the Trojan plant evaluation for compliance '.iri:/ m with the new emergency planning regulations, 45 Fed. Reg. 55402#:9(( . i D-4., (Augus: 19, 1980, effective November 3,1980), the problems of . j';$

1

'/ effective protective measures and evacuation during or soon l y after an eruption, giving due consideration to the possible

g effects of severe ashfall,.mudflows, floods, and landslides.

. ; f- .:.g ...A

:V cc:

Chairman Ahearne .j > -{ Co=missioner Gilinsky i Commissioner Hendrie .3 . Commissioner Bradford ',' 7,g - c f General Counsel ,3 Director, Policy Evaluation a j, Director, Nuclear Reactor Regulation o Executive Legal Director Chief, Docketing & Service Branch, SECY y d

i CONTACT:

E. W. McGregor (SECY) 41410 1 y j O sg=ttfTt75 OCT 2 4 L960 o

.:.3 w = .i* Robsrt A. Cicrk .g Tisjan Nucisar Plant UMTED STATES July 30,1982 Docket 50-344 UCLEAR REGULATORY COMMISSION 8 ] License NPF-1 m s mectom.o.c.aosss Page 1 of 2 4 1 v**o.f 1 yg3g, isso I John McConnell, Assistant Associate Director for ll MEMORANDUM FOR: Population Preparedness FEMA Brian K. Grimes, Program Director. Emergency Preparedness l FROM: Program Office NRR e REQUEST FOR FEMA AS$1 STANCE TO REVIEW EFFECTS OF

SUBJECT:

EARTHQUAKE AND VOLCANIC ERUPTION ON STATE / LOCAL j EMERGENCY PLANS i As we have discussed, in the course of our review of Itcensed utility emergency plans, volcanic eruptions and catastrophic earthquakes have emerged as two To insure'that these issues are being issues of high public interest. adequately addressed, we request that FEMA review the State and local plannin efforts for the areas around California nuclear power plant sites and the j j} Trojan site with respect to the comp 1tcations which might a ljj' i the planning process. In conjunction with the Trojan plant evaluation for compliance with the I new NRC emergency planning regulations, the Comission has directed that l: the problems of effective protective, measures and evacuation during or jl soon after volcanic eruption (giving due consideration to the possible j! effects'of severe ashfall, mudflows, floods, and landslides) be closely i In this regard, we are requesting the licensed utility to revise its emergency plan to explicitly address the possible problems associated examined. This will include considerations of site access during with an eruption. an emergency, assured comunications and appropriate rev j Oregon State Department of Energy, has already addre j. l 1). The earthquake issue has particular relevance to nuclear I i 29, 1980 that FEMA !j We understand from the FEMA news release of September will lead a team consisting of personnel from Federal, State and local a I j agencies to accelerate efforts towards improving the state of readinessIn this re t to cope with potential major earthquakes in California. j we request that FEMA include in its evaluation of offsite emergency plans, i a qualitative evaluation of complicating factors which might be causedSpecif by earthquakes for California nuclear power reactor sites. = ma n r-r") n- )9 g o.i y I

u.... e. / Trojan Nuc1 cr Plant Rob 0rt A. Cicrk '~' Locket 50-344 Aly 30,1982 Licenca NPF-1 Page 2 of 2 2-John McConnell ~ such evaluation should include the impacts on State / local ee.ergency plans due to potential disruption of corm:unications networks and evacuation routes. In this regard, we are requesting the affected licensees to revise their emergency plans to explicitly address the possible probler.s associated with an earthquake to include the type of potential complications discussed I above for the Trojan facility. ) Thank you for your assistance in these matters.

j

_A Brian K. Grimes, Program Director 9 Emergency Preparedness Program Office Office of Nuclear Reactor Regulation

Enclosure:

Oregon DOE Study Report Measures + I i l ' 4 '5 s 4 ~ l ~ i

T.'.- ~ J u.a.rh.%h.%%%~n% wa,a [/7 /WR ) (aflfh) - 0 '!' N /O ADlf)- *Til ' .' ~ - :.. m E. c:: =- CO.k /'1" ~ l U' '* Jm, / het/ y,! (p.,J. D "A N hp 6f t..;, l j g/ October 2, 1980 g j/ff k Trojan Nuclear Plant y) f/j k,: Y/E "O r Docket 50-344 l License NPF-1 VU - Radiological Emergency Response Plan Director of Nuclear Reactor Regulation l ATTN: Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 ,l Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555 j Dear Sirs 1 { On May 16,1980, Portland General Electric Company (PGE) submitted a secor.d draf t of the Trojan Radiological Emergency Response Plan (RERP) for your review. Subsequently on July 28, 1980, the NRC Emergency Plan Review Team, headed by Mr. T. McKenna, visited the Trojan site to discuss the resolution of NRC comments on the drafC RERP. The final NRC comments were forwarded to PGE on September 17, 1980. l ,1 We are hereby forwarding to you, attached to this letter, our responses to the remaining unresolved issues identified in the September 17, 1980 letter. In addition to resolving these issues, we are proposing two further revisions to the RERP as follows: 4j 1. Page 2:6.4-5 refers to special telephone lists for schools, hospitals, etc., to be maintained to ensure rapid notifica-tion of these populations. Since a siren system will be g used to warn the public within the plume exposure EPZ, ( these telephone notification lists are no longer necessary 1 and will be deleted. 2. In the Emergency Action Level (EAL) tables (2:4.1-1 to 2:4.1-4) references to specific PRM readings for detecting j iodine will be eliminated, since iodine PRMs are unreliable C[! due to noble gas interference. In practice,,the ranges of the iodine PRMs are too low to be of use in an accident m._ m V V 1 si Ag 4 r

~ Ax.a,num.:6.w:6..w..r> ;. w.. m e - n2nou-w-A. ~ Mr. Robert A. Clark October 2,1980 Page 2 [. situation, so this change will make no difference in

{

the ability to rapidly quantify iodine releases. ) We hope that this response adequately addresses your questions. '~ Sincerely. r,-- Bart D. Withers 1 Vice President Nuclear !I ,r BDW/TDW/SCG/im/4c1958 l1 Attachments iI 4. c: Mr. Lynn Frank, Director w/ attach State of Oregon j. Department of Energy 'I Mr. Richard Donovan wo/ attach Federal Emergency Management Agency, Region X 4 .i l ) 1 i l l l i 4 i i I i i

.:._ - m.m A & w da h r.~ E:.~~~~~4 - M " 4 li ATTACHMEh"I 1 RESPONSES TO NRC ComtENTS l1 CHAPTER 1, OVERVIEW OF MANUAL il lf 1. References Section 6.0, Page 1:6-6 d j8 Comment = i Revise to indicate that NRC inspectors are to be provided by the regional office.

Response

This revision will be made to Page 12 6-6. 2.

Reference:

Section 10.0, Page 1:10-1 Comment 1 j A. Describe the provisions for a " designee" to assure there is a

i capability for 15 min. activation of the alerting system.

B. Restate the capabilities of the warning system in terms of design parameters. i l C. How ves it assured that KEX (1190 AM) can be received (daf and i night throughout the plume EPZ)? I

Response

A. Page 3:6-2 of the Oregon Emergency Plan (Chapter 3 of the Manual) describes the Columbia County notification system in detail, as follows: l "Iasediately upon receiving emergency notification from 'j PGE, the Columbia County Central Dispatch dispatcher shall verify the authenticity of the notification and notify the appropriate Columbia County response organizations. The notification verification method L! is described in the Columbia County Procedures. The Director of the Columbia County Office of Emergency .j Services or, in his unavailability, his designee has the authority and responsibility to implement protec-tive actions and can immediately release, via the KEX Radio Station, predetermined emergency messages describing the protective actions to be taken by the Columbia County public. The Director shall ensure that Columbia County emergency response organizations are notified and activated, as appropriate. A listing of the notification and activation of Columbia County response organizations by emergency clas~sification is presented in Table 3:6-3. Emergency notification

w u.munet.:mi.e.::,uwmwa, =uw. awe s,!i f 1 a l responsibilities are shown in Figures 3:6-1 to 3:6-3. - Normal County emergency communication systems, which are described in Section 7.2, shall be used for notifying Columbia County respon'se organizations." f Section 6.1 of the Cowlitz County Emergency Plan describes the l Cowlitz County notification system in detail, as follows: i

i "I:ssediately upon receiving an emerFency notificat.fon M

from Trojan, the Communications Center dispatcher shall notify the,Cowlitz County Sheriff and Emergency Services and Communications Director. The dispatcher shall verify the authenticity of the notification. In e the event that notification is received from Trojan during other than normal working hours, or if the Sheriff is unavailable, the Sheriff's designee shall assume the Sheriff's emergency responsibilities until the Sheriff is available. The Sheriff, or in his absence the Sheriff's designes, has the authority and responsibility to implement protective actions and can immediately release, via the KEI Radio Station ar.d local radio and television stations, predetermined g emergency messages describing the protective actions to be taken by the public." s 1-sSection 10.0 will be revised to include these descriptions. ! }1 B. The capabilities of the warning system will be restated in terms of the designed coverage and signal strength. ll C. A survey was taken within the plume exposure Emergency Planning Zone (EPZ) during the day and at night 'to ensure i that KZX could be received at all locations. Subsequently, some questions have been raised by local government offi-cials as to the adequacy of KEI coverage in some areas. This matter is under investigation, and adequate radio l station coverage of the plume exposure EPZ will be assured ii by the time the RERP is submitted to the NEC (January 1,1981). 3.

Reference:

Section 11.0, Page 1:11-1 1 Comment

i 1

A. The provisions for public information must include j d' 1. Information available for ready reference durins; an i ,1 amargency. '2. Information for transients (e.g., boaters, hotels). 3. The actions parents art td; take if children are at school. i 4 B. Indicate when the initieIn public education brochure will be submitted to the NRC. r, 5 'V . J

w. a,

2 x:We45a w.c :..1.cz,e e ~ -. a 1, u m a - 4 l; Resoonse A. These provisions will be included in the public education brochure.. Section 11.0 of Chapter 1 has been revised to include this information and is attached to this response (Attachment 2). A special education program is not considered ,8 necessary for boaters on the Columbia River. Many boaters in ,i the plume exposure EPZ reside in the area and will receive the jj public education brochure. In addition, if there is an acci-dent, the U. S. Coast Guard will warn boaters via helicopters with loudspeakers and notices to be dropped to boaters giving l evacuation instructions (see Section 6.4 of Chapter 2). The completed ' lan, which will contain the initial public B. p education brochure, will be sent to the NRC by January 1, 1981. 4.

Reference:

Tables 1:6-2, -3, -4 and -5 Comments A4 Provide fer closeouts (written and verbal) in accordance with NUREG-0610. t B. Provide for prompt (2 hr. not acceptable) notification of offsite officials of Unusual Events. . 1if

Response

!I

I A.

Verbal closeouts will be provided in accordance with NUREG-0610. Written closeouts will be provided by sending copies of reports required by Plant Technical Specifica-cions to State and county authorities. The State and local officials have agreed to this approach as documented in the PGE letter to A. Schwencer dated March 18, 1980. -i B. State and local officials have previously agreed to an initial notification time of 2 hr. for an Unusual Event as documented in the PGE letter to A. Schwencer dated March 1,8,1980. Subsequent discussions have resulted in an agreement on a 1-hr. notification period. If an accident is determined to become an Emergency Alert, Site Emergency or General Emergency, notification to offsite agencies will be nede within 15 min. 5.

Reference:

Appendix 1-A Comment Revise to indicate that recommendation of plume protecti' e actions v beyond 10 miles.any be required. ..i T .-.-n

= - -... a sash.usu_waw _- m. -.-- e= l i 1 i

Response

~ l This revision will be made to Appendix 1-A. 6.

Reference:

Table 1:A-1 h Comment l A. How will failure of Containment to isolate be detected? 1 ] B. If outside monitoring is to be performed, state the criteria .j used to dispatch the monitoring individuals (see. Comment on ? Section 6.2.2.1.1). C. How will release duration (long-or short-tera) be determined? D. Clearly indicate that " shelter" applies to entire plume EPZ.- i E. Why is evacuation phase based on wind direction? I F. How were the shelter factors of local buildings considered? l G. How will evacuation time estimates be used and when will the time estimates be incorporated into the plan? H. An implementation schedule for the siren system must be l provided to include estimated: 1 1. Ordered date; i 2. Delivery date; 3. Installation date; and 4. Test date

Response

A. Failure of Containment isolation will be detected by: g i ) 1. Effluent monitors; or 2. Containment isolation status panel alaras; or 3. Monitoring outside the Plant. These parameters are included in.the EALs. ) 3. See response to concent on Section 6.2.2.1.1. l C. This parameter is usually impossible to predict accurately and must be a judgemental decision by the Plant operators ? + - -, - -, - -.. - +, ,-w- -+.m..:----, ,.e w r~i-,p -e+---

.e: .G-G+;;;L&5s5c$$gw1.:,,mstmi@1::y,ha,3p.s w A gmai O Qwhiesa .\\ 4 i 1 l l based on the source of the radioactivity release. For example, the release from rupture of a waste gas decay tank would be expected to be of short duration while the release due to failure of the Containment coupled with fuel melting i could be long term. 3 D. This revision will be made to Table 1:A-1. 1 fI E. The evacuation, phase is based on wind direction principally g' because of the population distribution and prevailing wind j directions within the plume, exposure EPZ. The prevailing wind directions are up and down the river valley in which ~ the Plant is located and the majority of people within the EPZ are located in the river valley. In addition, meteoro-logical analyses show that winds blowing in directions other than up and down the valley are of very short dura-tion. Therefore, the population living within the river valley is given priority in evacuations in order to more effectively utilize the available local manpower to evacuate j the population which is in the greatest potential danger first. !i F. The plan will be revised to include shielding factors for

}

structures in offsite dose projections. The shielding -) factors will be used to determine doses and protective actions for persons who are sheltered. G. Evacuation time estimates for evacuation sectors will be

4 compared with estimated time allowed to evacuate in order

I to determine whether an evacuation is to be ordered.

.j These estimates will be included in Appendix 1-E and Appendix 1-A, and will be submitted to the NRC by January 1, 1981. lf H. The current schedule fo-the siren system is as follows:

5

i Order date

/80 Delivery: 1. "'O - 12/15/80 Installation: 11/ 3/1/81 Testing: 3/1.41 - 3/15/81 j FEMA approval: 4/1/81 j CHAPTER 2, PGE RADIOLOGICAL DIERGENCY RESPONSE PLAN FOR THE TROJAN NUCLEAR PLANT i 1 7.

Reference:

Tables 2:4.1-1, -2, -3 and -4 1 Comment A. What is the basis for the assumptions used in the calculation of iodine doses? How will the iodine levels be confirmed _ i during an event? (see coesients on Section 6.2.2.1.1.) T

---

a

m w uiad&>asw..x-nuG

. ~, s u

= +-u --m . j 1 1 9 B. Indicate that an emergency will be declared if a condition -- exists that corresponds to the NUREG-0610 class descripcion even if an EAL has not been established for that specific condition. This could be accomplished by addressing the following NUREG-0610 example initiating conditions: Unusual Event #15; 3 Alert #9; and . i Site #16. C. Describe how the EALs submitted are being revised and improved and specify when they will be submitted to the NRC. D. Describe how the EALs and their recognition will be incorporated into Plant procedures. E. Indicate why the Condition II and III occurrences analyzed in the FSAR are not specifically covered by the EALs. t

Response

A. See response to comments on Section 6.2.2.1.1. B. Implementing procedures containing the EALs (see answer } to D. below) will include instructions to declare an emergency i should conditions exist for which an EAL is not defined, l but which ccrresponds to the NUREG-0510 class description. C. The EALs are being revised to incorporate NRC comments and to more accurately describe the Plant parameters and instrument readings which determine the EALs. In addition, the EALs 1 will be modularized to assure fuller response preparation for more serious indicators. D. The EALs will be incorporated into Plant RERP implementing - 3 1 procedures. A step will be added in each existing Plant Emergency Instruction (EI) and Off-Normal Instruction (ONI) directing the operators to proceed to the RERP procedures. 1 E. All occurrences evaluated in FSAR Chapter 15 were con- ' l sidered in writing the EALs. Condition II and III occurrences were found to be less severe than an Unusual Event. A statement to this effect will be added to Section 4.2. 8.

Reference:

Table 2:4.1-1 Comment 1 How were NUREG-0610 Unusual Event, Example Initiation Conditicas 9, _ l 11,13 and 15 addressed?. m- ---n, ,,r-,,, ---m-s- e- --p--,

w :, Q,:.g. g. ~. v-s: ggg;ghgg g,gy-g;; w J; m f g ysu mlf 0 ' g-4

Response

Conditions 9,~ 11, 13 and 15 will be included in the EALs as revised. 9.

Reference:

Tables 2:4.1-2 and 2:4.1-3 -f Comment 1 4 A. How was NUFIG-0610, Alert Condition #14, addressed? B. How was NUREG-0610, Site Condition ill, addressed? C. Why is 30 min. specified for Site Conditions 6 and 7 versus 15 min. as specified in NUREG-06107

Response

A. Alert Condition #14 will be included in the revised EALs. B. Site Condition ill will be included in the revised EALs. C. Thirty min. is specified for Site Conditions 6 and 7 to ] allow sufficient time for operations personnel to diagnose and correct the probles. 9.

Reference:

Table 2:4.1-4 Comment Condition 1 - Include results of field monitoring. Il

Response

t Table 2:4.1-4, Condition 1 will be revised to include field monitoring.

10.

Reference:

Section 5.2.2.5, Page 2:5.2-17 .] Comment U Clarify who will recomend protective measures (ECC or Emergency 2 Coordinator in TSC) once the TSC and ECC have been activated. d

Response

j The Emergency Coordinator recommends protective actions once the TSC and ECC are activated. Section 5.2.2.5 will be revised to clarify j

this point.

11.

Reference:

Section 5.2.3(6.4.1.1), Page 2:5.2-24 Cosament Make provision to assure that Plant evacuees will not be required to weit at the ECC for an excessive amount of time before monitoring and deconenmination during the backshifc.,

W 6 dh usq gam.;mc._,.a:_ a. .. m egg. I

Response

The ECC will.be activated within 60 min. of the declaration of an Emergency Alert, Site Emergency or General Emergency on the backshif t. Equipment-for monitoring and decontamination are stored in the ECC. If Planc evacuation is ordered on the l backshif t,- the ECC will be opened up and the monitoring equipment i set up by Plant Security under the direction of the Security Watch Supervisor. Plant personnel evacuated to the ECC will i perform self-monitoring until Radiation Protection personnel arrive. Decontamination will begin as soon as the Radiation 2 Protection personnel arrive at the ECC (within 1 hr.). Section 6.4.1.2 will be revised to state this. ~. D 12.

Reference:

Section 5.3, Page 2:5.3-1 comment Identify the provisions for additional health physics support. f Responsa j i Health physics support will be obtained from Washington Public Power Supply System, other utilities (through INPO) and through ) i IRAP. Section 5.3 will be revised to state this.

13.

Reference:

Section 6.2.2.1.1 Table 2:5.2-1, Page 2:6.2-3 Coment l A. How will it be determined when the following personnel actions (tasks) required immediately to classify an event as part of the EALs will be performed? .j 1. Taking measurements outside Containment, i 2. Determination of iodine fractina in a release, 3. Taking of " grab" samples, and 4. Exclusion boundary monitoring. B. Assure that there are adequate qualified personnel available during the backshif t to perform the above tasks in a timely Revise Table 2:5.2-1 to show who will perform these manner. tasks during the backshift. C. What assumptions will be used concerning the iodine levels if gross Containment radiation levels and leak rates are used to project offsite doses. 1

Response

A. An a't==4 nation of the EALs has determined that the C&RP Techn1-cian on duty on the backshif t will not be required, as part of ,,_,,,.y .- + m. - =*- -+--^

-A--- m-- s E f, g - A_-A u e_._ _i_ m i t classifying a release as part of the EALs, to perform more than one action at a time. To insure the availability of the C&RP Technician, the plan will be revise'd to state that determination of EALs will take priority over other duties that the C&RP i Technician may have to perform on the backshif t. tj section 6.2.2.1.1 will be revised to describe the actions to be d taken for EALs to quantify a release in order of priority: G ~ j 1. Use PRM readings (noble gases only) i i 2. If noble gas PRMs are offscale or malfunctioning, 1 dispatch a.C&RP Technician to read external dose rate on sample line. 3. Dispatch a C&RP Technician to collect iodine sample using silver zeolite cartridge and count for gross iodine. ) I 4. If the accident is in the Containment, the Containment is isolated and affluent samples cannot be taken (as .i in 2), use Containment ARM readings and Containment pressure readings to calculate release rate. If ARMS are offscale or malfunctioning, dispatch C&RP Techni-cian to take external dose rate measurements outside the Containment. l 5. If the Contairinent is not isolated and PRMs cannot be j used (unsonitared release), dispatch C&RP Technician j { to taka external dose rate measurement at exclusion j area boundary at plume center line in downwind direc-tion plus external dose race measurements outside the ~ ^ Containment. A C&RP Technician will take a sample of Containment atmosphere if possible. The effluent release rate can be calculated from these measurements. e 'i 6. As soon as C&RP Technicians are available, take grab J samples of effluent (if possible) and perform gsama h spectroscopy analysis. l 7. As soon as field monitoring team is available (first two C&RP Technicians to arrive onsite on backshifc) i dispatch field team to perform exclusion area boundary 4] monitoring. 1 >i B. Revised Table 2:5.2-1 is attached to this response as C. The principal means of determining the iodine fraction inside the Containment will be by analyzing a sample of the Containment atmosphere (see response A., above). If an est' mate is needed before a sample can be taken, the following assumptions will be used to determine the iodine fraction: l ---,,-,a

..w. A cm.-, _1gg h-- iT-Iodine release fraction from core is assumed to equal 50 percent of noble gas release fraction. Fifty percent of iodine released to Containment is assumed to plate out. If Containment sprays operate, an additional 99 percent of iodine is washed out (i.e., 0.50

• 0.50
• 0.G1 of iodine remains).

-j This method will only be used as a last resort. 't Section 6.2.2.1'.1 will be revised to include this explanation. [ 14

Reference:

Section 6.2.1.2, Page 2:6.2-4 Comment i Revised the method of determining meteorological parameters to represent current conditions.

Response

i Page 2:6.2-4 will be revised to require the use of current readings j of meteorological parameters, rather than hourly averages. 15.

Reference:

Section 6.2.2.1.2, Page 2:6.2-5 Comment Revised the method used if meteorological instruments are inoperable to be more representative of current conditions.

Response

The meteorological instrumentation is located on two towers. Table 1:7.3-1 shows that wind speed, wind direction and stability can be determined from instrumentation on either tower. In the event that all tower instruments become inoperable, the following procedure will be used to estimate meteorological parameters: h] 1. Wind speed and/or wind direction will be estimated using instrumentation (an==a==ter and wind vane) mounted on the wind generator tower at the Visitors.Information Center (ECC). '} 2. Stability will be estimated using the method outlined in Table 3.3 of Meteorology and Atomic Energy 1968, assuming " slight" insolation during the day, and j( 3/8 cloudiness at night. 16.

Reference:

Sections 6.2.2.1.3 and 6.2.2.1.4, Page 2:6.2-5, -7 Comment Provide the assumptions used to develop the dose assessment equations specified in these sections.

.& w + 4 -ya w en m m _ w -- a ~

Response

These sections will be revised to detail the specific assumptions used to develop the dose assessment equations. See Attachment 4 for details. ,j

17.

Reference:

Section 6.2.2.1.3, Page 2:6.2-5 i q Comment 'llj Revise the system outlined to estimate doses inside the exclusion area so that it will not result in overly conservative thyroid dose estimates. ~, e

Response

The dose equations for the exclusion area assume a ux/Q equal to the building wake factor (0.5/2340 m2) (see Trojan FSAR Sec-tion 2.3.4). We believe that the use of this method to give a j first estimate of doses inside the exclusion area is appropriate, particularly since these dose estimates are to be used to determine whether evacuation of the public from the exclusion s area is to be ordered. Note that this dose projection will not be used to determine if Plant personnel are to be evacuated 3 or ordered to use respiratory protection. These decisions will be based on measurements of radiation and airborne radioactivity levels.

18.

Reference:

Section 6.4.1.1, Page 2:6.4-1 Comment A. Provide the capability for personnel accounting with 30 min. of declaration of the emergency. B. Describe the provisions for continuing accountability.

Response

YJ A. Section 6.4.1.1 will be revised ::o provide the capability for personnel accouncing within 30 min. of the declaration 4 of the emergency. Personnel accounting will be performed by security personnel at the ECC. Plant and contractor 'l personnel evacuated to the ECC will turn in their badges to the security personnel, who will check off their badge nisabers versus the gatehouse list of active badges. B. Continuing accountability will be by security and access control procedures. A statement,to this effect will. he included in Section 6.4.1.1.

19.

Reference:

Section 6.4.1.2, Page 2:6.4-1 7 w e e--e-ee---ww wwo-aww*-*v' v w ---ee rei-e e ~ ---Mw -+-'1mr v *s -w-mmw

Y w,z.= = i:_x.as._ _& > ~ - - + - I t Comment Provide for evacuation of noncssential personnel from exclusion area upon declaration of a " site" or " general" emergency.

Response

1 Section 6.4.1.2 will be revised to provide for exclusion area

{

evacuation upon de'claration of a Site or General Emergency. !,j

20.

Reference:

Section 6.4.1.2, Page 2:6.4-3 '8 ~ Comment Provisions to direct evacuees to offsite monitioring points (if necessary) must be provided.

Response

Plant evacuees report to the ECC for monitoring and decontamination (Section 6.4.1.2). The public will be directed to evacuate along predesignated routes. (See Section 6.4.1.2). State police located at roadblocks will direct the evacuees to assistance centers where sonitoring will be provided if necessary. Plant personnel who cannot be monitored and/or decontaminated at the ECC due to accident conditions or other reasons will be directed to proceed to the Orsgon State Emergency Workers Center, located at the PGE St. Helens j Office, where monitoring and deconrm=fnation facilities are avail-i able. Section 6.4.1.2 will be revised to state this. i 21.

Reference:

Section 6.5.1, Page 2:6.5-1 Comment Clarify how the total dose received by Plant personnel and non-Plant personnel will be recorded.

Response

s Doses received by Plant and non-Plant personnel will be measured using TLDs and pocket dosimeters and will be recorded using normal Plant procedures for maintaining dose records. Population doses to j, the public will be calculated at the Unified Dose Assessaant Center using computer codes maintained at PGE Headquarters. l

22.

Reference:

Section 6.5.2, Page 2:6.5.3 } Comment The second complete sentence at the top of this page indicates that the five following actions will be taken by the Radiation Protection Emergency Teen. With respect to action Nos. 2 and 3, bow can the Team request the team to survey the patient or direct the team to decontaminate?, y v-- m

mm MQs wax.,, gy m, ;, w 2 ;;.,, m we,,g e h c_ i.i x. 6 s J

Response

Page 2:6.5-3 will be revised.co state that: "the Radiation Pro-tection Supervisor will direct the Radiation Protection Emergency Team to perform the following actions: I ei

1) Provide first aid to injured individuals.

1

2). Survey the patient to determine the' extent and location of

-] contamination or direct radiation being emitted from the 1 patient. i

3) Decontaminate the injured person as much as possible using standard methods, including:

a) Removal of the patient's clothes and wrapping him in a sheet. b) Removal of all dosimetry devices for immediate processing and replacement with a pociat ionization chamber. i

4) Prepare. the patient for sabulance transportation, if

< i needed.

5) Dispatch a team member to accompany the patient to the bospital and remain at the hospital to provide radiologi-l cal services to the Environmental Health Physicist and q

hospital personnel.

23.

Reference:

Section 7.1.3, Page 2:7.1-2 Coimaant At the top of this page it states that during the time required to set up the alternate ECC, the Manager, Operations and Mainte-nonce assumes the role of Emergency Coordinator. The effect of this U requirement is not clear because both the Plant General Manager, who b is usually the Energency Coordinator, and the Manager, Operations and Maintenance, are supposed to be in the Technical Support Center. The intent of this requirement appears to be no longer necessary because of the establishment of the Technical Support Center. However, there will be a need to temporarily transfer the duties and responsibilities of the ECC during the move to an alternate ECC

i site. The plan does not presently provide for such transfer.

O l'

Response

This section will be revised to state that the Technical. Support Center will assume the funcef ons of the Emergency Control Center during the time required to set up the alternate ECC.

24.

Reference:

Section 7.1'.5, Page 2:7.1-2 - -l i

%.h 's n.,,:amwau_w.sn. + .mcma m m o. Comment ,3 Specify the expected travel time between the interim TSC and control room. _]

Response

.4 ]' ) Section 7.1.5 will be revised to state that the expected travel time between the iriterim TSC and the control room is approximately j 3 to 4 min. .a j

25.

Reference:

Section 7.1.7, Page 2: 7.1-4 e Comment How will the ECC receive the meteorological data required to perform its functions?

Response

..e, ,j On an interim basis, the ECC will receive meteorological data from the TSC via telephone with an Executone backup. This will be stated I on Page 2:7.3-1. Meteorological and affluent monitoring instrumenta-tion readouts will be installed in the ECC by April 1982. 26.

Reference:

Section 7.2 'i Comment Specify the range of the field monitoring team radios.

Response

d Section 7.2 will be revised to state that PGE field monitoring i team radios will have a range of at least 10 miles. 5j

27. Section 7.3.1.1, Page 2:7.3-1 n

j Comment Where do instruments on the 33 ft. tower display?

• f a

Resnonse All meteorological instruments display in the control room. 1 28.

Reference:

Section 7.3.2.2, Page 2:7.3-7 lI Comment \\ Facilities and response times for an alternative laboratory to l analyze samples containing large amounts of activity (primary water samples) must be specified. 7.-,

, 2 Mk ;h.n ~ a qu, a. mm._ _ L___&n _- Q-.: G u j il

Response

Page 2:7.3-6 will be revised to state that the USDGE contractor laboratories in Richland, Washington, are available through the IRAP to analyze highly radioactive samples. The response time is "? estimated by the USDOE to be less chan 24 hr. from the time that a i sample is received. l ll

29.

Reference:

Table i2:7.3-9 -) Comment

!j An instrument for,use in very high radiation field should be assigned to the rescue team (s).

ji

Response

Table 2:7.3-9 describes the Teletector Model 6112, which has an upper exposure rate limit of 1000 R/hr. This instrument is available to rescue teams. 's 1 30.

Reference:

Section 8.1.1, Page 2:8.1-1 'I comment Describe how personnel will demonstrate the ability to perform their assigned tasks (qualification) and how it will be documented.

Response

Section 8.1.1 will be revised to state that personnel will demonstrate their ability to perform their assigned tasks through: 1. Practical drills 2. Annual exercises of the RERP. '6 fj Drills will consist of a hands-on demonstration of the ability to

)

perform assigned emergency tasks. During the practical drills, Tj on-the-spot correction of the erroneous performance. shall be made ) and a demonstration of the proper performance offered by the j instructor. A record of each individual's performance in training-j' sessions, drills, and exercises shall be kept by the organization i conduction the training. Records shall be retained for a period i of 5 yr. l 31.

Reference:

Section 8.1.2 n Comment 1 An annual test of the public warning system must be provided. n ... r ..m-- r- ~ -. -._._---,I

g.- ..:_-w_Q = W.:, < wu _;_g. ....a.,_,. ,a _ _, .l I. 1

Response

Section 12.2 of Chapter 1 shall be r.evised to state that after the system has been installed, an annual test of the public warning system will be provided in conjunction with the annual exercise. j 32.

Reference:

Section 8.1.2.1, Page 2:8.1-5 'q Comment j = j. The radiological monitoring drill must be revised to include collection of all sample media. .I e

Response

1 Section 8.1.2.1 will be revised to include collection of all sample media in radiological monitoring drills.

33.

Reference:

Appendix A Comment I A. The agreements with the State and local governments and Coast Guard must be revised to endorse the Plan or updated { co reflect the provisions of the Plan. B. Specify when revised agreements and revised State and local plans will be submitted to the NRC. a

Response

1 A. All agreements with State and local governments and the i U. S. Coast Gucrd will be updated to reflect the provisions of the RERP as necessary. A list of agreements and revision dates will be contained in Appendix'A. B. Revised State, county and Coast Guard agreements and plans submitted to the NRC by January 1, 1981. '. l'.

34.

Reference:

Appendix C 3 l] Co==mnt 9 Procedures do not need to be included if described and the '] relationship between the plan and procedure specified. 1

Response

Implementing procedures will be cross-referenced to sections of the RERP in Appendix C.

35.

Reference:

General -I6-e

,;,,_g _ u__,,_,,,.a ggggw,g _ di 4 .,x.,.c .wm -;_ >y . 1;. .w -t .; j Li a Comment ~ i A. The plan submitted to the NRC should not include specific t f individuals ' ca=es or phone numbers. l' B. Provide an updated submittal schedule for those items not contaiusd in the May 1980 draft.

Response

t A. The plan submitted to FEMA and NRC will not include individuals' ,it names or phone numbers. 1 m Lj B. All items not contained in the May 1980 draf t will be submitted 6 to the NRC by January 1,1981. .1 $i i

i j

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,:/n a.Jw.n, ./ 2 g,.y -, g,y 9%, .gu 4 g l 6 ( ATTACHMEhT 2 i ( 11.0 PUBLIC ECUCATION l Columbia and Cowlitz Counties shall institute a continuing public educa- ] tion program with the concurrence of the Oregon DOE and Washington DES to l ensure that members of the public within the 10 mile plume exposure EPZ around the Trojan Nuclear Plant are: (a) able to recognize radiological 2 emergency notification (eg, sirens); and (b) knowledgeable of the proper, j immediate actions (eg,-return to home, close windows and turn on radio) l co be taken. This program shall include education on protective actions t j to be taken if shelter is prescribed and the general procedures to follow if an evacuation is required. The program shall inform the public of the conditions under which they are not to evacuate, but take shelter in their homes and wait for instructions on the radio. Columbia County Office of Emergency Services, Oregon Department of Energy, Cowlitz County Department of Emergency Services and PCE shall cooperate in conducting the program, which shall include: t

1) Public meetings

2) Press briefings I

3) Annual mailouts of a public education brochure

4) A continuing education program.

9 11.1 PUBLIC MEETINGS j l Coincident with the implementation of the plan, public meetings will be 4 j held in Columbia and Cowlitz Counties to inform the public of the exist-a! ence of the plan and of the information and instructions contained t within the public education brochure (Section 11.3). The meetings will be publicized in advance to allow interested members of the public within the plume exposure EPZ an opportunity to attend. 't 1:11-1

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. lay 1 11.2 PRESS BRIEFINGS As part of the public education and training programs, news media brief-ings will be held in the local area of the Plant and in the vicinity 1 of the State EOCs coincident with the issuance of the public educa-tion brochure and annually thereafter. The objectives of the briefic.gs are to 1 1! .. l

3

1) Provide the local news media with an overview of the

~ plan. 'i

2) Provide training for the news media as to their roles and responsibilities during an emergency at the Trojan 4

i plant.

\\

3) Provide additional public education, via the news media, on the plan itself, the emergency notification systes

}l . and the actions the public are to take in the event of an emergency. The local news media will include newspapers, radio and television stations with coverage within the plume exposure EPZ. t e 11.3 PUBLIC EDUCATION BROCHURE j The principal means of public education will be the public education z,- l brochure. The public education brochure will be mailed out to all d residences within the plume exposure EPZ coincident with the implementa- 'f tion of the plan and approximately annually thereafter. The brochure l will contain the following information: ? *i N [

1) A description of the Trojan Nuclear Plant.

2) Basic information about radiation"and its effects on humans.

i 1:11-2 l l ... _. -... _ _,,..,,.....,,.. _, _ _,. ~,

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3) Identification of the emergency notification system and emergency radio station.

1

4) Instructions as to the actions to take:

3 a) Immediately when the notification system is acti-vated (eg, go indoors, close doors and windows, and turn on radio). -} 1] b) To insure maximum protection if sheltering is ordered. } c) If evacuation is ordered.

5) Instructions for parents with school age children.

6) Maps showing evacuation routes and directions.

1 The brochure will be sized to fit inside a telephone took and will also be made available at the local PGE offices in St. Helens and Rainier, 1 9 Oregon, and the Trojan Visitors Information Center. A sample of the public education brochure to be distributed initially to the public is shown in Appendix l-C. ) 11.3.1 Special Populations In addition to asilouts to all residences, public education brochures .j will be asiled to special populations, including: 'i

1) Schools and day care centers 3

2, 1

2) Hospitals and nursing homes

3) Motels and hotels "i

4) Large industries.

~ 1:11-3

h; ' bhan + v. na. _~ _ _..,._ uxag amm e J I These mailouts will consist of packets of brochures, with a cover letrer l to the administrator or person in charge, instructing them to make the j brochures available to their workers and/or tenants. Motel and hotel owners will be instructed to make the brochure available to lodgers. I A special program has been developed for boaters on the Columbia River. If there is an accident requiring evacuation (the only protective action for boaters), the U. S. Coast Guard will notify boaters by helicopter i that they are to evacuate the river and will drop leaflets which direct e the boaters to appropriate boat ramps and include a map showing evacu-3 atica routes (see Section 6.4 of Chapter 2). In addition, many boaters in the plume EPZ reside in the area and will receive the public education brochure. l 11.4 CONTINUING PUBLIC EDUCATION PROGRAM U In addition to the initial press briefings and public meetings,' and the annual public education brochure mailout, a continuing public education l program will be developed by the Columbia County Office of Emergency Services, the Oregon Department of Energy, the Cowlitz County Department of Emergency Services and PGE. The program will consist of a slide show presentation, and will be suitable for presentation to schools, civic j groups and other organizations. The presentation will be included in the education program operated out of the Trojan Visitors Information Center and will also be available to Columbia and Cowlitz County Emergency Services personnel. n .k. 1 3l >i j i 1:11-4 ,n.,,

....d '.i..... h LLiesiL. ~---s ~w ~% * ' M *ML - " - - " ~^ ~ Mi 3 4 ,. + y E .4 ?5 is 9 ,l.. I 1 Sheet I of 4 j. TAti.E 2:5.2-1 AUCMENTATION OF OFF-liOURS SHIFT ENESCENCY ORGANIZATION I' r.' Personnel Aasiansents i Off-Nours Shifts As Auamented Within M Min. Function Area 1.ocation Position Title Manaiaale] Location Position Title Mannind *I I s l Plant operations Control Room Shift Supervisor Control Room Shift Supervisor 1 p c I Shift Technical Shif t Technical Advisor 1 P Advisor ( l Control Operator Contro! Operator .I I Assistant Control 1 Assistant Control 1 t Operator Operator I. Aust!!ary operatore 3 Auxiliary operatora 3 l-A, 8 and C A E and C Dose Assessments Control Room Assistant Control I TSC Duty k nager, Techat-I operator cal Services -Aust!!ary Operator A Duty h intenance I Supervisor h Engineering Emergency 2' Team E [ Determination of Control Room Shift Supervisor I TSC Duty Plant Ceneral [' Recommended knager Protective Actione Offette Communicationes f;- 4 Notification Security Security Watch ECC Duty k nager, Plant I h Building Supervisor Services V Updates Control Room Shift Supervisor ECC Duty k nager, Plant I Services 9 See Sheet 4 of 4 for footnotes. i L t

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= ' ' tp' 3 .s l': k, P ,s t' i Sheet 2 of 4 TABLE 2 5.2-1 i Pereoanet Aastammente Off-Mours Shifte As Auamented Within 60 Min. ,i Function Area Location Position Title Masataalal gacation Position Title ManninaI*I h Plant Security Security Security Watch I ECC Security Watch i ~ aullding Supervisor Supervisor (' + Security Fereoanel lc] Security Personnel [c] gl Personnel Account-Security Security Watch i ECC Security Watch i k-ability and Site But! ding Supervisor Supervisor S Accese Control y' Effluent Release Measurements a Order i A of Friority)I 3 g% A.

3) Measurement la Plant C&ar Technician i

In Flaat C&RF Techalcian 2 of noble gae release rate !{ I] from Jose rate as sample !!aelal A

2) Measurement of In Plant C&RF Technicles In Flant C&kt Techatelan 2

groes todine release rate 14 metas dose rate from grab b sampla of i effluent 3' B. haeurement of, Out of Flant) Out of Flant) (; In Float (or C&RP Techalcian i In Plant (or C&RF Technician 2 o dose rate ide Containment 9 l(i See Sheet 4 of 4 for footnotes. c' il 4 ?. r / l l !.p-e r.

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...._. JCkg; [: .6 b M B p y E. ) i k r 's i Sheet 3 of 4 TABLE 2:5.2-1 F.,.onn., A..i. _.t. Off-Mours Shifte As Augmented Within 60 Min. Function Ares location Position Title Meanimalai Location Position Title Manninaial C. Measuransat of Out of Flaat C&RF Technicina Out of Flant C&RF Technic 1aa 2 uhole body dose l rate at Eactugi p [ Area Boundarylgs 4 8 D. Field Monitorlag Out of Flant Field Moottorlag Tema 2 II E. Gamme Spectroscopy F In Flant C&Rt Technicians 2 Analyste of grah h amaples j 2 lil Radiological Monitor-In Float C&RF Techalcisa i In Flaat C&RF Technician 2 lag and Decostaala-ation of omette BCC BCC C&RF TechalciaaIlg f. 2 6 Personnel Being Evacuated h First Aid In Flaat C&RF Techniciam In Flaat C&RF Technicana 2 Fire Fighting In Flact Designated Licensed I la Plant Designated Licensed I {? IP ' Opera tor Operator h Security Personnel 4ggy ggg Security Fereonnel 4 f f Repair and Corrective In Flaat Aust!!ary Operator 8 I In Plant Maintenance Emergency 2 f Actions Tema gi . t]. See Sheet 4 of 4 for footnotes. s 4 8 e [,, ( Y-e i

' ~ 1.:us 2.% i m.a u G Gd L.. 1 I %.....1x ._L.. 2. wi L.=.. ~. Y' w P g;s b. m {.; U, Ps b I l e if: e i V 1 flr Sheet 4 of 4 l .h TAal2 2:5.2-8 l 4 Personnel Aasianments Off-Mours Shifte As Augmented Within 60 Min, i Function Area location Position Title Manniaalaj Location Foottien Title Manninalal ? Technical Support of TSC Duty Plant Cenaral I Flant Operations and knager Direction of Emer-Duty k nager, I gency Organisation Technical Services a Duty h intenance 1 5-Supervisor e r On-call Shif t Technical i t Advisor h lp. kc' i lel Manning values indicate total number of persons of each poettien onsite, not number performing a particular task k (ie, one person may perfore more than one taek). Augmented meaning values indicate total number of persons guaranteed b)- 8 to be onette within 60 min, lbl Until activation of dose assessment capability at ECC. h. {cl As described in Trojan Security Plan. p (d) "In order of priority" means that A. should be attempted before B., anu 5. before C., etc. fy , lel To be done only if PRNs are offocale or cannot be used. {} ifl Measurement can be taken either in-Plant at Containment well or out of Plant at 50-f t. distance. l3l This is only a quick measurement to allow estimation of release rateeg it is g the same se field monitoring. fj. [h] First tuo C&BF Technicians arriving at ECC from offsite. [i L I l1l Cear Technician will perfore decontamination only (if not needed for affluent release measurements)! all Plant personnel are trained to perfore self monitoring for contamination.

• yI ljj As available if not needed for in-Plant duties.

iki As available if not needed for affluent release measurements. P lIl Indicates number of security personnel on fire brigade, not total number onette. P {q-i la i:. p* 1 I 4 d. ,P.- 1 k l l y s. 4 l I

.g__ s- _~h w w ;n a &w a tuaw.:u naz . ~ = = * "- " : u e.

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ATTACHME.I 4 V 0FFSITE DOSE CALCULATION MODELS Equations (6-2) and (6-6) of Section 6.2.2.1 are based on the semi-infinite cloud model: q ~ FSAk Section 15.5.1.2) I; R, = (0.23E, + 0.25,E ) Qc(ux/Q)

• 3600 (res/hr) (Ref:

g u Equations (6-3) and (6-7) are based on the standard inhalation dose model: Rt = QI

• Br
• DCFT *(ux/Q)
• 3600 (rea/hr)(Ref: FSAR Section 15.5.1.3) u where:

i Eg = average beta energy, Mev i; Ex = average gassa energy, May Br = breathing race (a3/sec) DCFT = Inhalation dose conversion factor in thyroid (res/C1) 3600 = sec/hr Qg/Qg = release rates of iodine and noble gases (C1/sec) ,j u = wind speed (m/sec) .I ux/Q = Atmospheric dispersion factor, (1/m ) 2 Ij For locations within the exclusion area, a conservative ux/Q value of ft 8.6E-4 1/m2 is assumed = building vake (0.5/2340 m ). (Ref: FSAR 2 )l Section 2.3.4.) 11 E Ul 1 I 8 g f1 ij SGG/la/4mg66.52A20 .}}