ML20234C893

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Forwards DE Pesonen to Jt Conway,For Discussion W/Newmark at ACRS Meeting Tomorrow.Related Info Encl
ML20234C893
Person / Time
Site: 05000000, Bodega Bay
Issue date: 11/06/1964
From: Christopher Henderson
US ATOMIC ENERGY COMMISSION (AEC)
To: Price H
US ATOMIC ENERGY COMMISSION (AEC)
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ML20234A767 List: ... further results
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FOIA-85-665 NUDOCS 8709210449
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{{#Wiki_filter:i l - -__-___.._.j ra R October 6, 1964 NOTE TO HAROLD PRICE ite: PESONEN LETTER TO CONWAY DATED 9/14/64 As mentioned in staff meeting yesterday, you l wanted to discuss the attached with Newmark j 1 l i l at ACRS meeting tomorrow. + ~' -.,g. P# .=*=..,,,n- - n ..;u.

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1 I.S ' ? DB-1277 1 ) N rthcrn C:llf2rnia Acsociati:n To Preserve Bodega Head and Harbor a p. \\ ) 8 2820 Telegraph Avenue Berkeley 5, California p Aovisop ce g,, September 14, 1964 f CJ U-@, 5 j Diend no, N l 4*ha8""a'a* Mr. John T. Co'nvay, Executive Director U1 [ H.e.W oin n Joint Comittee on Atomic Energy N4 U C wo f n Con 6ress of the United States i C; ~ l Washington, D.C., 20510 g w w,g,,, n,,y t-y l

Dear Mr. Conway:

Pmncis H.oring 0

  • Lva This is in response to'the letter of August 27 from Mr. Harold l

wilii.en Pena **. Jr. L. Price, Director of Reguhtien for the Atomic Energy Comiss{on, l i therno. Pwun n commenting on my letter to you of July 31. We vould like to emphasia:e l that we appreciate the thorough and prompt attention you have paid j l g ,3 n,,,,,6 l to this matte'r and we respect Mr. Price's official position as spokes- ,3,g man for the AEC. Dodd L P.aon.n Eacuuu secmary However, Mr. Price's letter is not particularly responsive to the issues raised in our letter of July 31. We did not question the precedent for " secret" meetings between the applicant and the ACRS and the AEC. But we did point out that the procedure in no vay can I be considered judicial or quasi-judicial. The record developed at hearings before the Atomic Safety and I [ Licensing Board, to which Mr. Price refers, must necessarily stem l from the existing docket, including amendments to the Pacific Gas and i Electric Company application developed throu8h discussion at these meetings. Amenttient No. 7to the company's preliminary hazards analysis, dated March 31, 1964, embodies what Mr. Price describes as a "signifi-cant change in the seismic design" of the reactor. We understand on I good authority that this design concept was suggested to the company by the AEC's own consultant, Dr. Nathan M. Revmark, retained by the Comission's staff to review the company's application. Thus, to pursue the parallel with judicial procedure, ve have here an agent for I l the judge acting as counsel for the applicant. This procedure must be viewed au more quasi than judicial and should not be used to argue i agair legislative action on S. J. Res. 167 l Secondly, Mr. Price offers no explanation for exclusion of. the U.S. Geological Survey personnel from the meeting of the ACRS subcom-mittee at Sodega Bay on June 3 Geology is a field discipline and j the issue of safety at the Bodega site now seems to turn on interpre-tation of field evidence of a fault through the reactor site. PG&S t I consultants--who did accompany the subece ittee--contend that the fault is a " minor offset." The U.S. Geological Survey report of December 1963, on the other hand, describes this fault as "an important I zone of weakness." It is difficult to see how the subcommittee could l receive the 1%11 benefit of its visit to the site, accompanied by e [ spokesmen 'for only one of these two opposing points of view. E9-1277 Purpo. To wrork f.e pree.rvation of the scannc and historte h.odtonds of Sod.go hoy and ec. Insure the j .conoow ini.orier et th. ,=vndine.norine.nw n n.nt. Rec'd Off. Dir. of R I j Oate__ h I _b_r_h__ _ Tire __/p________ B e tn._ __ _ _ __ __ __ __ _ _ _

, ' 5onv$y, JCAE--9/14/64 ' g ) Finally, Mr. Price implies that the public attention paid to this project has had no influence on the abruptly broadened scope of examination by the ACRS c.nd the Commission's regulatory staff. The first introduction of the U.S. Geological Survey into the Bodega matter came as an attachment to a letter of May 20, 1963, from Secretary Udall to Chaiman Seaborg. The attachment contains a preliminary assessment o of the geology and seismology of Bodega Head and, significantly, relies heavily on fMngs by Dr. Pierre St.-Amand, a consultant retained by our citisens' Association. L, More comprehensive findings by Dr. St.-Amand are again cited for authority in the U.S, Geological Survey's report on seismology of the site in September 1963 In light l of this and the subsequent U.S.G.S. report which generated major design changes by the company, ve can reasonably infer that public participation has had a tangible effect i' on the technical evaluation of the Bodega, site. It is interesting to note, in view of later developments, that the Secretary of the Interior's letter of May 20, 1963, appears to take for granted that dise3very of l a fault thmugh the reactor site vould almost automatically result in denial of PG&E's The U.S.G.S. attachment rightly places great emphasis on the statement 7 application. by M&E consultant Dr. George V. Housner, that "it is quite impossible to design a power plant to survive without damage the large permanent ground surface displacements that might occur if the e hquake fault slippage occurred on the site." Since the j date of the Secretary's le r, the U.S.G.S. has confirmed the possibility, of fault displacement at the site. his possibility was sedepted by the company to the extent l that it has submitted two major design changes--Amendments Nos. 7 and 8--in an attappt to compensate for fault movement that the company's own consultant stated could not f be compensated for. These designs are only theoretical, having virtually no basis in operating experience--a fact which is hardly calculated to instill public confidence. That public attention is varranted in these paceedings is further indicated by a j comparison of the Bodega experience with the history of PG&E's application for the i Humboldt Bay reactor, as reviewed in the enclosed article from Fuelear Safety. l June 1960..This publication, prepared by the AEC staff at Oak Ridge, has an unblemished record for objectivity. The vriter finds that out of 19 reactor license applications reviewed, major ambiguities exist in the record of only one application--PG&E's at Rumboldt Bay. The writer finds substantial technical grounds for concern over the i safety of the Humboldt Bay installation. For a number of reasons, including a deceptivea public relations campaign by the company, the Humboldt Bay installation faced no significant public scrutiny. In view of this co=pany's, record vith its first and only other nuclear installation, we consider that comparable ambiguitica /' / I --affecting the public safety of the San Francisco Bay Area--very likely vould / ; remain in the record of the Bodega application vere it not for public participation i / i early in the licensing procedure. / j As conservationists ve are anxious to support the proper developent of nuclear } l power in California, to insure unpolluted air, to censerve water, and to ccuserve / energy. But nuclear power development requires a reservoir of public confidence in the reactor developer and in the ASC's regulatory procedures. Whether or not thi confidence can be assured depends entirely on experience vith the first large reactf' 1 j The Humboldt experience, though with a relatively small reactor, is not encouragin/ Bofega is the State's first large Power reactor--although other applications in / Souern California for comparable plants have since progressed further. Public / ophon recognizes the unique hazards posed by the Bodega site and by the exotic! design scheme devised to cope with them. Therefore, approval of the Bodega / installation vould irreparably damage the public confidence so crucial to sounf / develo pent of the peaceful atom in California. // Since 1 [ f Encit f D6 E. Pesonen a' cc: Mr. Harold L. Price hxecutive Secretary .3 l $l

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v. 1, No. 4, June 1960,,epp.,61-82.'

~ 6 o . [ j '.. 4 -._ t-._- .g-3 i s T l CONSEQUENCES OF ACTIYlTY RELEASE y ,h L !l 'j i r 4 j! Geologic and Hydrologic

structun, but a power Mactor h morethanthat J,

4 and raises special problems. L j; Considerations in Potver Another old but less routine problem is pre. E Reactor Site Selection

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i reactors are situated near some large body of - l ] It is required thr,t a reactor-hazards report

cases the reactor'is'within a very few feet of I a water for condenser cooling, and in several I r

3 {; provide, among otherthings,the meteorological, l past or predicted maximum flood or high-tide '! c .); hydrological, geological, and seismologicaldata t levels. The economic desirability of alowpump. [., g necessary for evaluating the measures proposed , ing head is obvious, but the art of flood predic< ! ,j for protecting the public against possible radio-tion has repeatedly fallen victim to what one J active hazards. Since meteorologists had their distinguished hydrologist called "the concatena. L l previous expeilence with industrialairpollution tion of circumstances." Flood crests farhigher - l to guide their early work with respect to the 1:ttian the predicted' maximum have not infre. i hazards of radioactivity, the new methods of - .quently confounded the best of prophets. None 3 1 analysis that they developed duringtheir studies j ,of the reactor sites appears to be indanger, but of reactor sites were immediately applicable to h M had ou can me ma Ws appa n i reactor-hazards analyses. Studies of the p,or A.2 be 'less than that used to guard against some. l qj j' tions of current hazards reports -H that deal 8 i . h h mon spuh* huuds. k q evd with hydrology, geology, and seismology show, - i )the: flooding of a reactor does not seem to offer j~ j however, that earth scientists must learn to ' serious hazard to the surrounding area un. j. provide a more complete picture of thephysical i. less other misfortunes occur at the same time. l ji environment if they are to discharge their re, O sponsibilities. The various hazards reports do.: ., "g, g, ,,,gg l 1 not approach the problems in the same way,and ; ' y.The possibility of earthquake damage has ; U I'

j the differences are only in part due to differW (apused.cmidwable inted," pubably mom an t generaHy dems. M M &e hazare i

ences in the sites. J Despite the differences, the discussions are h @ Pets pmide me infwmanon nquindonW, of two general types. In the first, the ways in ? i M h a iM hkmW h h W W h j k' i which the site might affect the reactor are h lan ana when ear &quaku an infoquenW analysed; and, in the second, the ways in which -ij w intmHy, and knefm he hazad W j ,them is negligible. Such statements are usually y, the reactor might affect the surrounding area ~l are considered. Few reports attempt to cover ]l, band on data taken imm pubHcaum W W an uc umy. In say cap.- j' {.' both aspects of the problem.

reactors are constructed so that they are not ;

O Effect of SI'te on iteoctor ~ ,susupubh a damage imm any but memodin ' j t ,j 1 ' tense shocks. There might, however, be an to-l '1 The reports that are primarily concerned " y direct hasard through damage to underground i ji with the effect of the site on the reactor include I pipes or wires outside the reactor or through l ~ } studies of foundation conditions, safe bearing ; landslides er. tidal waves, either of whleh might j, loads, and results of the special test drilling, gcause/ ooding; but,.even including these some* fl done to obtain information about these points. $what remote possibilities, the total earthquake _ {[ ]- Several reports are almost ' exclusively con- ,hasard is very small in most areas.. cerned with such data. They were prepared,in' M %An' exception to this generalization would be q j general, by engineers in the regular employ of "j fthe case of a reactorbuiltbythe water's edg r the petitioning company. Such investigations], weak foundation materialin an area of frequent _ are, of course, routine, for say large, heavy - . earthquakes of high intensity. One suggeste{ f ii i ? .I ; a

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~ ~ ~, w i ,/.* . /. 6$ CONSEQUENCES OY ACTIVITY RE1, EASE [ Cd: {'nearly meets these conditions. It is on the N in building a large bridge or dam and can be e of a bly and is underlair, to n depth of 20 ft,h' solved by almost routine methods. Flood pre-diction is a little more difficult, but the reactor jely by recently depostled unconsolidated'" s el clay ahd silt. T. ya_ture of the material M as such offers no novel problem in raising the t Ethis is not clear. Athe geology section question: liow much can we cut the pumping Ce safeguards report,@ the material is de.% llit and still be safe above floodcrest?" Earth-d be-( clays with the majority consist!ng of the (,3 quake damage is far more dramatic, Ibed as "allshtly consolidated gravels sa'nds, e /; cause no area can be said to bequite free of the sr graintd materials"; that is, largely clay danger of a heavy earthquake, there has been p silt. In the section on earthquake hazards, much public interest. The danger to a well-eever, the same material is referred to as ' built reactor situated on firm foundation mate-i and is described as a " fairly well indu. rial appears, however, to be negligib;e. ed seri:s of mudstones, siltstones, sand-t nis, andconglomerates." Thedrilling record Effect of Reactor on Site is the material clay and sandy soils with On the other band, the reportswhichinterpret se sand and gravel, p the question of site evaluation as "what will a I There is also some ambiguity as to the in. ] reactor accident do tn the surrounding area 7" inties of the earthquakes to blexnected. The deal with a very complex and novel problem, as i l ati n on carthquake hazards listseightshocks ll i ., has been suggested by the several attempts to kntensity VH1 (modified Mercalli scale) and establish criteria for site evaluation.22.22 The I' s Cf intensity IX over roughly thelasthundred.f'ihazards reports in which an attempt has been irs, but the shock of intensity IX is dis- ; made to evaluate in any way the vulnerability of inted because the record is oldanduncertain. Q tuthors conclude that intensity VIH is the.l the surrounding area to release of radioactive aximum shock which should be expected inthe '1 materials give data relevant to some parts of I the problem, but in no case has an attempt been i ture. The ambiguity is in the word " expected." I ith at 11ast nine shocks of intensity VIH a - j' made to follow a nuclear incident through to its conclusion and evaluate its consequences. Ad-atter of record, more shocks should certainly q mittedly, such an analysis would require the , expected, but the report appears to give the l ' joint efforts of agroupotexperts,but.the largely l ipression that there is no need to plan for. ; ything of greater intensity. There is a very _l uncoordinated and separatelycomposedsectionsw l pat difference between a reactor situated on ~ today do npt seem toprovide as complete a basis i t k and subjected to an earthquake of intensity _ as could be wished for such a study. Even with ll!7nd'one situated on water-saturated clay. the best available data, however, the attempt i I s'ilt En'd' subjected to a shock ofintensity IX. would be faced at every step by problems for ~ be principal hazard in this case appears to be which there are at present not even order-of- ' to the reactor but to the proposed under-magnitude solutions, . und waste-storage facilities. ! Shock intensities VH1 and IX are defined as The analysis should probably begin with the maximum credible accident, already a time-flows: need mawer, een in 2 WaM %sh TIII. Damage slight in specially constructed build-Next, having decided how much of what particu- ' ngs: considerable in ordinary substantial buildings, lar isotopes would escape and in what physical i with partial collapse.... Sand and mud ejected and chemical form, the meteorologists would in small amounts. IX. Damage considerable in spelally designed st uctures, great in substantial have to decide where tha air-borne material buildings.with partial collapte.... Ground cracked would land and the hydrologist would have to conspicuo* sly. t)nderground pipes broken. plot the paths, rate of movernent, and dilution In general, it may be stated that the site of any escapingliquid. Som ' thisllquid might studles which have tried to answer the question seep into the. ground, and,. might leach ra. 'is the environment safe forthe reactor?" have - dior.ctive material from the fallout area and ) xen able tofurnish convincing reliable answers, carry this also into the ground water, sothe di-tery largely because the problems are not new. rection and rate of movement of the ground The foundation problems even for a large reac-water would hsve to be considered. Next, the 1

or are minor compared with those encountered ecologist would have to attempt to dete2 mine 7... 2 b

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~,c..- ) m _9._ m m _1 o r GA j o o v I. I 80 .NUCLEARSAFETY,. ? 'o i sidered tq be significantly different from th..e%

7. J. H. M'acMillan, Babcock and Wilcox*Co., Junel, 1959. (Unpublished) t.

4 deposition values calculatedfortheNCRP stand.

8. Puerto Rico Water Resources Authority and Gen.

33. ard man. As expected, the internaldose(iodine, nal Nuclear Endwing Corp., Bo!Hng Nuclear l i 1 thyroid) that would resu*t from breathing while Superheater (BONUS) Power Station: Preliminar; I l 1 submerged in the grep fuel-element release Design Study and Hazards Summary Report. g cloud was, measured to be about three orders USAEC Report TID-8524, four volumes, to to ] of magnitude greater than the extegral dose. published. 26* 4 The measured external gamma-ray dose under 9., Commonwealth Edison Co. and General Electric i I lapse conditions (at 400 meters) was about one. Co., Preliminary Hazards Summary Report for j I Dresden Nuclear Power Station, September 1, half that predicted. No more than 5 per cent of 1957, with amendments, AEC Docket No. 50-10. ( any aerosol, except fodine, was found to pene-f j trate the pleated filter of the high-volume air.-,10;' b sh d) r sampler. However, it was found that about 25to

11. Pacific Gas and Electric Co., Humboldt Bay Power 45 per cent of the iodine, based on total iodine l

collected by both the pleated illter and backup Summary Report, Report NP-7512, Ap"'I r.15.1959, i l carbon cartridge, had penetrated the pleated

12. D. L. Fischer et al., General Electric Vallecitos 28.

g- } filter. This is attributed to the interaction of Bolling Water Reactor Final Hazards Summary the local dust and the lodine and depended upon Report, Report SG VAL-2(2nd Ed.), General Elec. I tric Co., Vallecitos Atomic Laboratory, May 8. the concentration of the. dust. As a result, more L 4 1958. penetration was observed closeinthan atfarther

13. Allis-Chalmers Manufacturing Co., Mar.12.19H distances downwind.

.IU"PublI8h'd) 29. E j Tests such as these are valuable, not only

14. J. Jacobson, ed., Preliminary Safeguards Report for the additional informsMon they provide on -

i r the Pipa Organic moderated Reactor (Re. [ I release fractions and' diffusion under particular ^ ^ ' ' ' '^ E f' ,l field conditions, but also to point out areas * - . International, Apr. 13, 1959. j ls such as deposition velocity, in which further

15. S. E. Bealt and S. Visner, Homogeneous Resetor i

t,1 ,i study is needed. (T. J. Burnett) Test' Summary Report forthe Advisory Committee 30. on Reactor Safeguards, USAEC Report ORN1,. J ,I 1834(Del.), Oak Ridge Nationa1 Laboratory,Jan.l. 31. I ,l References 1gss.

16. Carolinas Virginia Nuclear Power Associates.

b i f.

2. F. A. Gifford, Meteorology in Relation t-Reactor Inc., Preliminary Hazards Summary Report, Vol-32.

III. Part B, License Application,ReportCYNA.11 i Hazards and Site Evaluation, inSixth! international r i Congress and Exhibition of Electronics and Atomic July 15,1959. l

  • f Energv, Rome, Italy, June 1959, U. S. Papers,
17. American Electric Power Service Corp. and General Nuclear Engineering Corp., App!!ca*

p ) USAEC Report TID-7579, pp. 59-67, October l tion for USAIC Licenses by Florida West Coad j 1959.

2. Yankee Atomic Electric Co., Nuclear Power Sta-Nuclear Group. Part B. Preliminary Hazards l

Summary Report, Report NP 8251, Dec. 7,IPH 33, tion Technical Information and Final Hazards Summary Report. Part B, License App!! cation,

18. Kaiser Engineers Div. of Henry J. Kaiser Co.aml j

i Allis-Chalmers Manufacturing Co., Experimental i j AEC Docket No. 50-29, USAEC Report YAEC-167 Gas-cooled Jteactor; Preliminary Hazards Sus

  • i' (Vols. I and II),1959.
3. Westinghouse Electric Corp. Bettis Atomic Power mary Report USAEC Report OR'%296 andSvP*

Div., Description of the Shippingpert Atomic plement, May 1959. j '{ Power Station, USAEC Report WAPD-PWR 970,

19. Atomic ' Power Development Associates, Inc.

34 Enrico Fermt Atomic PowerPlant, Report APD& ' t f June 1957.

4. Alco Products, Inc., Hazards Summary Report 124, January 1959.

I for the Army Package Tower Reactor, USAEC

20. Atomics International. (Unpublished) r
21. Aseismic. Reactor. Design, Nuclear Safety, !@

f Report APAE 2, July 27,1955. f 32-33 (December 1959). ,k

5. Intermediate Hazards Summary Report, Consoll-
22. Site Selection Criteria, Nuclear Safety,1(2):!*I j

g ,[ dat.ed Edison Reactor, AEC Docket No. 50-3, May (December 1959). 6.1. R. Finfrock, Jr., et al., Appilcation to U. S.

23. Appendix: Notice of Proposed Rule Making,Fe*

[ 3! 1959. clear Safety,1(1): 8-9 (September 1959). Atomic Energy Commissionfor Reactor Construe-

24. R. E. Brown et al., Experience in the Disposald j

l tion Permit and Operating License. Part B, Pre. Radioactive Wastes to the Ground, A/ CONT.3) ilminary Hazards Summary Report, Report NP. 7757, Saxton Nuclear Experimental Corp.,1959. P/1767, Second International Conference os tar 4 j s 1 I. j l A -y l

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y . " A.4,3800 Dissent NB g Y I A d No. 7, filed before the United States Atomic Energy Comission, in I the matter of P.G.& E., Docket No. 50-205. The original building-I l plan submitted to this Co= mission conte =placed that the reactor strtetureshouldbeonso5.idrock;whereas,anewdesignsubmitted j in that amendment to the Atomic Energy Commission, contemplates I construction upon a layer of granular material such as sand. Why ..this change in design? What does it mean? Who were the experts l. whose subsequent opinions apparently changed the judgment of P.G.& E.'s original experts and the original expert opinion to ion-l struct upon solid rock? Is it possible that there is,a growing

  • l awareness by P.G.& E. that it has a risky proposition upon its hands l

l and is trying to improve it? In the battle of press releases, one press report appar-ently states that Dr. Quaide, one o'f P.G.& E. 's original experts, l '.cs been replaced by another expert. Dr. Quade allegediy stated: "There is a chance that the fault could break beneath the plant's site in case'of an earth-t quake. I think the probability is low. But it is necessary to face the moral issue. 'If there is even a sli ht chance of danger, should we go ahead and uild the plant?' This is but one of the multiplicity of doubts and questions which s q-l arise. All of which could easily be satisfied--or at least the effort should be made to do so--upon proceedings reopened (either. ] " by this Com=ission, or by request of P.G.6 E.) to present new and l l' }relevantmaterialtous. ~ In conclusion then, upon the motion of this Commission in .c view of the changed circumstances and events subsequent to'the ' original granting' of authority, I woul.d reopen this case. c / j~ /s/ William M. Bennect WILLIAM M. BU NFTI, Commissioner May 21, 1964 ..s, s,. e 3 w ~. -. j.' s

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i I A.43008 Dissent NB i i ~, 1 the fact of the matter is that no member of the staff of this Commission ever testified in these proceedings, and no expert witness of P.C.& E. ever testified. I repeat again, the only evi-I I dence furnished to this Con =ission was' rank, unsupported hearsay ~ l which in nor ul administrative' proceedings would not be s'fficient ] 4 u { i 7 'l as the basis for findings. And yet in a matter of such importance i t' \\ and consequence as this, the Commission.has seen fit to. grant j e ,.'r, 1 4 { . authority to build a nuclear plant with all of the great doubt as.',- to its safety and with all of its harmful consequences upon.th'a ' ' z r. \\ beauty of Bodega Bay, with no more than unsupported,.second-rate ) testimony.- The question is legitimately asked as to why P.C.& $. I . failed in the past and' continues to fail to produce before this ) p -l l Co= mission, its seismologists, its, soil experts, and all the others l I who apparently are available to the press, to other governing I j. bodied--to all but the Connission having the sole state responsi ' I bility upon this matter' I I In Northern Cal. Assn. to Preserve Bodega Head & Harbor, Inc. v. Public Util. Com.. et al., 61 A.C. 100, the Supreme Court i I. ' told us that we have the authority, and tl m. fore the duty it seems; f to me, to inquire into safety questions. This would certainly " include consideration of the earthquake risk at Bodega. As said,. so much was not presented to this Commission! 'The record'was l l

  • reviewed upon the belief by a majority of this Commission that

.v. safety was not our concern; and so.much additional evidence', state- [ ments and opinions have c.ome forth from all. parties (and particularly from P.C.6 E.), that I consider it our duty to reopen these proceed. ings to determine whether the certificate was properly granted in the first instance and, additionally, whether subsequent events : ~ 'have had so=e impact upon our original grant.. j I am also concerned.at what appears to be~a change, seem-ingly drastic but perhaps not so; by P.C.& E. in Amendment, ' v. .. - 5 . {., ., f., m ---e-e ,... ~ -...<).,,,,..,.,.,.,---.;- .,( .v....,., ..,., ; e, ,.,' ' f d *,...

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which P.C.& E. so readily adopts against all arguments, opinions,- . and reports which fail to coincide with its self-assumed attitude of. infallibility. 'Despite mounting concern upon the part of,the public, we have now advanced-from the proposition.that earthquakes may be the.,' O.. cause of only slight concern to the proposition that fault.. lines are: now ideal locations for nuclear plants. This is being spoon-fed'to the public against all the warnings of reason, logic, experience and y. I common sense.. + 'If P.G.6 E.'s press reports be accurate, the damage ^ estimates in Alaska.and the concern of state government there*were I entirely misplaced.; Apparently, P.G.& E.'s' Alaskan emissaries' ~ ll evidently found little or no' damage of consequence...These opinions' will furnish great, consolation'to the people of Alaska. I In my opinion this Commission never faced up squarely to l the issue of safety. -To begin with, the' showing of' safety by, P.G.& E, was most deficient. Then, when the issue of safety was ' ] ~ k [ safety was no concern of ours, from which I conclude' that this presented, the majority went off upon the erroneous notion that 1 p' l ^ negative attitude prevented proper consideration of the safety 3 features of this plant, since apparent 1y'the record and exhibits, 3 I 1 were being read as though safety were none.of our, concern.. And importantly there is no finding by this Commission upon.?' safety"' of.' ^ 4 the plant' t 1 'I point out,that the concurring opinion rendered in con-y4 'nect. ion with the Order Danying 'Recpening,. issued en July,9,1963 e t Z. l ~ j founded its judgment upon the basis that ' commission personnel J l l'- especially trained in the nuclear field, experts produced "oy the I applicant, and other (. disinterested experts have all testified before. .the commission in 'sepport of the plant at Bodega' Bay."In short, i e j . 4..,_, i t f.*. ,,.'{...,., a, '

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1 i i.) -) - i .} ,v A.43808 Dist.ent NB j -) n g y l f 4 Apprehension over the possibility of widespread public. injury has always been a legitimate conc'ern.in these proceedings.~. -{ l Indeed, P.C.& E., itself.used this argument to resist,the proposi ; -{ 1 tion that unsightly overhead transmission' lines should be pieced j l . underground; as the Commission stated in its original. decision' f~ 1 I .herein (Interim opinion, Decision No. 64537, Application No.'43808, i -) { November 8, 1962): " Applicant objected to the proposal'for k}; undergroundconstructionuponthebasesthat,first,tho'additionai! l \\ w u g: cost would not be justified, and second, that the underground ' con-a attuction would be unreliable and hazardous as it would direc'tly 1 1, c2 >ss the San Andreas fault and, in the eve,nt of an earthquake. the b underground conduits, undoubtedly, would be ruptured. releasing ~ ~ p# 120,000 gallons of inflammable insulating oil, and complete restor- '

1,.

ation of the circuits would take three or four weeks. On the oth'er I hand, applicant's witness testified that an overhead line would' h probably not be affected by an earthquake, but even if it' ware, it t-could be restored to service within a matter of hours." (Underscor-inn supplied.) P.G.& E. is entitled to be' greatly concerned that in its" i opinion underground, conduits " undoubtedly, would be ruptured." The public of Northern California is likewise entitled to its opinion that the containment unit housing the' fissionable material might -4 ' also rupture and, if so, that the consequences therefroin would be greater than.the damage ensuing from the release of inflammable r insulating ci1. 'It is di,fficult to reconcile the probability, if ^ ' #[l2 5. [ ' not inevitability', of damage to underground lines, as advoosted by. u, - f P.G.6 E., on the one hand,' with its contrary position on the other j'. . hand that earthquakes are highly.unlikely to be the cause of damage t' to the plant itself. Have we reached the age of ' controlled ear.th-f quakes? This stri's.es me as being more of the self-serving attitude s. a ...,.v. .~ .-3 .t- .'y" ' l" ' 7. * .*- - 'i' ;T5. p,4

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.} . t. 43808 Dissent - NB l ~ been quick to issue pronouncements'to the press'as to the' safety of the plant and tio meet' a11' objections upon 't;he battleground of news media. I' suspect that this contest in which the overwhelming forces of the public relations department of'a public utility are more than i 1 adequate, is at most times one-sided, and perhaps explains'the \\ ~ willingness to decide this matter at pres's conferences rather than'.--- to make a complete exposure of all features of tho' project on the l i . record where'it counts. Y \\ .In my judgment, this. Commission is compelled to reopen the' l' Bodege proceedings. The reason is quite simple--the fact $of'the Alaska earthquakes!,It has been said that the opponents of the ' Bodega plant are seizing upon the Alaska quakes. to exploit their' ~ y s case in opposition to Bodega, and logically it would follow that'

such opponents may have caused the Alaska quakes for this purpose!

h re'is an overriding and compelling connon sense which gives pause' toonecontemplatingthelocationofanuclearplantimponanactive fault line, 'and this is particularly so in view of the harsh fact of the Alaska quakes. One is not an alarmist in taking the Alaska experience into account; indeed, P.C.& E. itself had some concern as-I' to the lessons to be learned from the earthquakes in Alaska as evidenced.by its_ dispatching experts to Alaska to examine'the s . relevancy of conditions there to Bodega. In my opinion, these experts should come before this Comnission; and the P.G.& E. on its [ own, rather than resting in the havens w.hich technical legal, minds

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i . n.: .{ i,. can create, should be ask.ing this Comnission to receive the testi-p c. O .[ mony of such experts. 'Their opfnfons in'the press ance onessided and, e i

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untested and show clearly that the events in Alaska may have'a real relevancy to the grants of authority already made..,I am also quite. t t ;, - ~ g-concerned that some of P C.& E. 's experts.may now have changed. i i positions. y 3 .e ,,1, i, e' ,% i . r. { 2- ' + ',, f. [ 5s e e g a 4 Q., r-r a -e a-; -*- - -t -+ , i,? p};- ,,.-**gr.. e- . , :,., ; '*,....r..'.' ~\\'; ! & p: :..y. .n >3,. t ;.:.%,. ';,.... n \\,,L. i .t',.y [,'; p . ~. ,1,. <.. a A.,, .,, ; * /. r.. '. s.. ...; ? e .o ., p ,4!, ;.' /

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f... o-i b ? i, ?' A.430QS l. ~ r =/ f: g.yd$ NI BENGTT, William M., Cocnissioncr, Dissenti,ng Opinion' t. I would reopen 'these proceedings upon the iditiative of the Counission to meet our responsibility to the people and i l environs affected by the proposed nuclear plant. ~ .b The petition to rescind the certificate order filed by. ~ i t se protestants herein and the answer of the Pacidic Gas e and ' E.ectric Company (P.G.& E.) are both the expected, narrow approach f

}

which legil documents sometimes' fasten on a great pub'lic contro, i i versy. The rcply of P.G.& E. dredges up all of the minutiac to. F defeat a complete sciutiny of its proposal.which technicalities might better be left to ancient common law proceedings. There is l a great body of public opinion whic'h for sound reasons opposes this plant and whose doubts have never been satisfied by the { oP.G.6 E. under oath in any proceeding before this or any other I { . regulatory body. As I pointed out in my original dissenting opinion, the P.G.6 E. has never presented to this Counission for examination and testing the very experts whose judgments it is relying upon. r Not a single one of those experts was ever.a witness and of course was never subjected to the challenges of cross-examination. One can only speculate as to the cause of the reluctance upon the part of P.G.& E. to throw its cr.;mplete case before the public. ti That crucial exhibit dominated Exhibit No. 48 was filed

J long after the proceedings were closed. It is; it self, centra?.ie -

l I tory to the opinions ventured as to safety, and no party to the' i proceeding was ever given opportunity to test it. By contrast, with the testimony and evidence which was omitted in the proceedings before this Coi=nission, the P.G.& E' has I } t s. t s c r. ~1-O l ~ g*.~ .~ d

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1 c. 2 s.ty'3 q \\ v NORTHERN CALIFORNIA ASSOCIATION TO PRESERVE BODEGA HEAD AND HARBOR, INC. 2820 Telegraph Avenue Berkeley 5, California PRESS RELEASE: For'Belease Tel: Prospect 5-2970 (David Pesonen) Vednesday, September 16, 1964 BODEGA PLANT THREATENS ATOMIC POWER PROGRAM San Francisco (Sept. 16)--If the Atomic Energy Commission approves the Pacific Gas and Electric Company's proposed atomic power plant at Bodega Bay, it could irreparably damage the progress of nuclear power in California. This warning was contained in a letter to the Joint Congressional Atomic Energy Committee, released today by the Northern California Association to Preserve Bodega Head and Harbor. Development of nuclear power, such as envisioned in the California Water Plan, vill require "a reservoir of public confidence," the letter stated. And the presence of an l earthquake fault through the Bodega site makes it impossible to have confidence in any nuclear plant located there--because of the " unique hazards" and the " exotic design scheme" proposed by FG&E engineers to cope with them. (Last De'cember the U.S. Geological Survey reported an "importsnt zone of weakness" I through the reactor site. Last March PG&E proposed a " floating design" to withstand { i t violent shaking from the nearby San Andreas Fault while simultaneously riding over slip-I l page through the plant's foundations on a layer of specially graded sand.) ) "PG&E has consistently misconstrued the issue as nuclear vs. non-nuclear power," said David Pesonen, Executive Secretary of the Bodega association and author of the letter. "But the real issue is safe vs. reckless development of this new energy source." He noted that the utility "has insisted also that the plant would be perfectly safe, while frantically submitting new designs for the AEC's approval. The latest scheme is so far out that it has never been attempted for any building anywhere, mu~ch less an atomic If the AEC OK's this one," Pesonen said, "it will mean only one thing: that they reactor. care more abcut building reactors than defending public safety. And the public confidence in their expertise, necessary for sound development, vill be hard to restore." -end-Y. ,w,

1 o. s. g q ~ Northern C alifornia Associatiotr To Preserve Bodega Head and Harbor 2820 Telegraph Avenue Berkeley 5, California Aovisots September 14, 1964 oovid trewer Jda'Ema=aa Mr. John T. Co'naay, Executive Director HoroW G % m Joint Co:=nittee on Atomic Energy Joei o gova.n Congress of the United States w,w,, p, g,gg Washington, D.C., 20510

      • ' "*d*'"

Dear Mr. Conway:

Fr ncis Herring D8"a This is in response to the letter cf August 27 from Mr. Harold w a om Pean mott,Jr. L. Price, Director of Regulation for the Atomic Energy Coex21ss{on, Thomas P.,kinson commenting on my letter to you of July 31. We vould like to emphas$ae ,3,.,,,,3 that we appreciate the thorough and prompt attention you have paid a ma e and we re QM k. MCe's oMCM psMon as s%es-T. Eric Reynolds I man for the AEC. oovid E.Pesen.n zucusiw secretary However, Mr. Price's letter is not particularly responsive to the issues raised in our letter of July 31. We did not que.stion the precedent for " secret" meetings between the applicant and the ACRS and the AEC. But we did point out that the procedure in no vsy can be considered judicial or quasi-judicial. l f The record developed at hearings before the Atomic Safety and Licensing Board, to which Mr. Price refers, must necessarily stem from the existing docket, including amendments to the Pacific Gas and Electric Company application developed through discussion at these meetings. Amendment No. 7to the company's preliminary hazards analysis, dated March 31, J964, embodies what Mr. Price describes as a "signifi-cant change in the seismic design" of the reactor. We understand on good authority that this design concept var suggested to the compny by the AEC's own consultant, Dr. Nathan M. Newmark, retained by the Comission's staff to review the company's application. Thus, to pursue the parallel with judicial procedure, we have here an agent for the judge acting as counsel for the applicant. Thic procedure must be viewed as more que.si than judicial and should not be used to argue against legislative action on S. J. Res. 167 Secondly, Mr. Price offers no explanation for exclusion cf the U.S. Geological Survey personnel from the meeting of the ACRS subc.om-mittee at Bodega Bay on June 3 Geology is a field discipline and the issue of safety at the Bodega site now seems to turn on interpre-tation of field evidence of a fault through the reactor site. PG&S consultants--who did accompany the subco=mittee--contend that the fault is a " minor offset." The U.S., Geological Survey report of December 1963, on the other hand, describes this fault as "an important zone of weakness." It is difficult to see how tLe subcommittee could receive the full benefit of its visit to the site, accompanied by spokesmen for only one of these two opposin6 points of view. Purpose To work for preservation of the scenec ond historic hoodlands of Sodego Soy and to insure the ecolsgical integ:ity of the surrounding anor ne environment. A Catilernia Non pro)lt Corporetm i 3 A_

I s i r e, Cpnyuy,JCAS--9/lW6h Q Finally, Mr. Price implies that the public attention paid to this project has j l had no influence on the abruptly broadened scope of examination by the ACRS and the Comoission's regulatory staff. The first introduction of the.U.S. Geological Survey I into the Bodega matter came us an attachment to a letter of May 20, 1963, from Secretary Udall to Chairman Seaborg. The attachment contains a preliminary assessment of the Ecology and seismology of Bodega Head and, significantly, relies heavily on l findings by Dr. Pierre St.-Amand, a consultant retained by our citizens' Association. j Hore comprehensive findin6s by Dr. St.-Amand are again cited for authority'in the l U.S, Geological Survey's report on seismology of the site in September 1963 In light of this and the subsequent U.S.G.S. report which generated major design changes by l the company, we can reasonably infer that public participation has had a tangible effect f on the technical evaluation of the Bodega site. i It is interesting to note, in view of later developments, that the Secretary of l the interior's letter of May 2G, 1963, appears to take for sranted that disedvery of j a fault through the reactor site vould almost automatically result in denial of pG&S's { application. The U.S.G.S. attachment rightly places great emphasis on the statement by PG&E consultant Dr. George W. Housner, that "it is quite impossible to design a power plant to survive without damage the large permanent ground surface displacement i that might occur if the earthquake fault slippage occurred on the site." Since the j date of the Secretary's leter, the U.S.G.S. has confirmed the possibility.of fault { displacement at the site. This possibility was nedepted by the company to the extent j that it has submitted two major design changes--Amendments Nos. 7 and 8--in an attempt to compensate for fault movement that the company's own consultant stated could not be compensated for. These designs are only theoretical, having virtually no basia j t in operating experience--a fact which is hardly calculated to instill public confidence. t That public attention is warranted,in these proceedings is further indicated by a comparison of the Bodega expe ience with the history of PG&E's application for the Humboldt Bay reactor, as reviewed in the enclosed article from Nuclear Eafety. June 1960..This publication, prepared by the AEC staff at Oak Ridge, has an unblemished record for objectivity. The writer finds that out of 19 reactor license applications reviewed, major ambiguities exist in the record of only one application--PG&E's at Humboldt Bay. The writer finds substantial technical grounds for concern over the safety of the Humboldt Bay installation. For a number of reasonn, including a deceptive. public relations campai n by the company, the Humboldt Bay installation 6 faced no significant public scrutiny. In view of this company's record with its first and only other nuclear installation, vc consider that comparable ambiguities --affecting the public safety of the San Francisco Bay Area--very likely vould remain in the record of the Bodega application vere it not for public participation early in the Ideensina procedure. As conservationists ve are anxious to support the proper development of nuclear power in California, to insure unpolluted air, to conserve water, and to conserve energy. But nuclear power development requires a reservoir of public confidence in the reactor developer and in the ASC's regulatory procedures. Whether or not this confidence can te assured depends entirely on experience with the first large reactors. The Humboldt experience, though with a relatively small reactor, is not encouraging. Bodega is the State's first large power reactor -although other applications in Cothern California for comparable plants have since progressed further. public opinion recognizes the unique hazards posed by the Bode 6a site and by the exotic design scheme devised to cope with them. Therefore, approval of the Bode 6a installation would irreparably damage the public confidence so enicial to sound development of the peaceful atom in California. Sincerely, Encl: cc: Mr. Harold L. Price David E. Pesonen i Executive Secretary 34. .o.meyJ.- 1

I' 4 s I / j i, ) October 6, 1964 j NOTE TO HAROLD PRICE 4 1 PESONEN LETTER TO CONWAY DATED 9/14/64 i l Re: i As mentioned in staff meeting yesterday, you '~ wanted to discuss the attached with Newmark i s ~ at KRS meeting tomorrow, ...:- a.6 x.. ;wn v_: m e.; :.. ~;.:.;__-;,, ~..:.. : + ;;;:- '.$2 ..,:o.$;. l ~7. 2 W,. ---e 3 ; s..'.~" ~ C* L* Eenderson 2.;;; ; C'E+ =ym e ~= =,.,.=. :~S...~.y*g'p..--"-- +.. egl; ,M".'~ . j., - Xi2' 9 = j WW.Y [g:- w' %'-'.>g?. R^ a. r Y.:h;*;~* -' L;w._ ",'

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t, Northern Callfernis Acccclition 4 .i To Preserve Bodega. Head and Harbor y. 2820 Telegraph Avenue Berkeley 5, California p y t ce Aowsops pf c/ ,4,i 44,,,,, September 14, 1964 'K 5 d* o wn== Jeha 8""aa'a Mr. John T. Co'nvay, Executive Director DN ilk f f N =ad omena Joint Committee on Atomic Energy 5Q:? U J s ou # Congress of the United States ~% 5 l Washin6 ton, D.C., 20510 g m w,ig,,,, y,,gg 3 u.)

Dear Mr. Conway:

Fr.ack Meertas This is in response to'the letter of August 27 from Mr. Harold 0 Sh w e. air.an s.*,Jr. L. ~ Price, Director of Reguhtion for the Atomic Energy Comniss$on, I thenin p.,iua n commenting on my letter to you of July 31. - We would like to emphassae that we appreciate the thorough and prompt attention you have paid l [ a,,,,,h nu eh t to this matte'r and we respect Mr. Price's official position as spokes-J ,, g g uan for the AEC. o.wd s. p a n 8 = su8he h er. eury However,,Mr. Price's letter is not particularly responsive to the ) issues raised in our letter of July 31. Wd did not question the precedent for " secret" meetings between the applicant and the ACRS and the AEC. But we did point out that the procedure in no way can be considered judicial or quasi-judicial. The record developed at hearings before the Atomic Safety and Licensing Board, to which Mr. Price refers, must necessarily stem l from the existing docket, includin6 amendments to the Pacific Gas and 3 Electric Company application developed through discussion at these meetings. Amend:nent No. 7to the company's prelindnaty hazards analysis, i dated March 31, 1964, embodies what Mr. Price describes as a "signifi-cant change in the seismic design" of the reactor. We understand on - good authority that this design concept was suggested to the company by the AEC's own consultant, Dr. Mathan M. Newmark, retained by the Conuission's staff to review the company's application. Thus, to pursue the parallel with judicial procedure, we have here an agent for the judge acting as counsel for the applicant. This procedure must be viewed as more quasi than judicial and should not be used to argue l aga legislative action on S. J. Res. 167 Secondly, Mr. Price offers no explanation for exclusion of 'the U.S. Geological Survey personnel from the meeting cf the ACRS siiabcom- } mittee at Bodega Bay on June 3 Geology is a field discipline and i the issue of safety at the Bodega site now seems'to turn on-interpre-j tation of field evidence of a. fault through the reactor site. PG&E I consultants--who did accompany the subcommittee--contend that the fault is a " minor offset." The U.S. Geological Survey report of Decen.ber 1963, on the other hand, describes this fault as "an important zone of weakness." It is difficult to see how the subcommittee could receive the full benefit of its visit to the site, accompanied by spokesmen for only one of these two opposing points of view. CP-1277 ,u., ., a. .#,.e s. i_,,,,,, + wes W., *. e=adme amir..aw-aai.ai. Rec'd Off. Dir. of Reg. d * "** C" ~ Date__f2:S_r_6_V__ Time __ /_j$_'_____ __ ; B e th._ __ _............

~ hd ..., ' Convey, JCAE--9/14/64 ) \\ 1 J Finally, Mr. Price implies that the public attention paid to this project has 1 had no influeno on the abruptly broadened scope of examination by the ACRS and the i Commission's regulatory staff. The first introduction of the U.S. Geological Survey into the Bodega matter came as an attachment to a letter of May 20, 1963, from The attachment contains a prelhiney assessment o Secretary Udall to Chairman Seaborg. of the geology and seismology!of Bodega Head and, significantly,' relies heavily on findings by Dr. Pierre St.-Amand, a consultant retained by our citizens' Association. f More comprehensive findings by Dr. St.-Amand are again cited for authority in the U.S, Geological Survey's report on seismology of the site in September 1963a In light l of this and the subsequent U.S.G.S. report which generated major design changes by i { the company, we can reasonably infer that public participation has had a tangible effect on the technical evaluation of the Bodega site. t e 's f It is' interesting to note, in view of later developments, that the Secretary of l the Interior's letter of May 20, 1963, appears to take for granted that disedvery of I a fault through the reactor site would almost automatically result in denial of PG&E's The U.S.G.S. attachment rightly places great emphasis on the statement application. T by IU&E consultant Dr. George W. Housner, that "it is quite impossible to design a [ power plant to survive without damage the large permanent ground surface displacements that might occur if the e hquake fault slippage occurred on the site." Since the date of the Secretary's le r, the U.S.G.S. has confirmed the possibility..of fault j his possibility was acdepted by the company to the extent displacement at the site. that it has submitted two major design changes--Amendments Nos. 7 and 8--in an attappt ( to compensate for fault movement that the company's' own consultant stated could not f be compensated for. These designs are only theoretical, having virtually no basis l in operating experience--a fact which is hardly calculated to instill public confidence.. } That public attention is warranted in these proceedings is'further indicated by a j comparison of the Bodega experience with the history of PG&E's application for the f Humboldt Bay reactor, as reviewed in the enclosed article from Eggagar Safety. June 1960..This publication, prepared by the ABC staff'at Oak Ridge, has an unblemished ~ record for objectivity. The writer finds that out of 19 reactor license applications reviewed, major ambiguities exist in the record of only one application--PG&E's at Humboldt Bay. The writer finds substantial technical grounds for concern over the safety of the Humboldt Bay installation. For a number'of reasons, including a deceptivea public relations campaign by the company, the Humboldt Bay installation faced no significant public scrutiny. In view of this company's, record vith its first and only other nuclear installation, we consider that comparable ambiguities / d --affecting the public safety of the San Francisco Bay Area--very likely would j remain in the record of the Bodega application vere it not for public participation eszly in the licensing procedure. As conservationists we are anxious to support the proper development of nuclear / }{ / l power in California, to insure unpolluted air, to conserve water, and to conserve But nuclear power development requires a reservoir of public confidenceW energy. in the reactor developer and in the ASC's regulatory procedures. confidence can be assured depends entirely on experience with the first large reactr* j The Humboldt experience, though with a relatively small reactor, is not encouragin/ a Bo$ega is the State's first large power reactor--although other applications in /' So%ern California for comparable plants have since progressed further. Public opinion recognizes the unique hazards posed by the Bodega site' and by the exotie j l design scheme devised to cope with them. Therefore, approval of the Bodega / installation would irreparably damage the public confidence so crucial to soun development of the peaceful atom in California. l Since / [ f Enc 1: cc:.Mr. Harold L. Price d E. Pesonen ecutive Secretary J ~ j.

r

3..." -; -

o 1 a-1 u _._ m - _ _ _.a _ m._ o 7 .U* NUCLEAR SAFETY, U.S. Atomic Energy Comnission[l.,,,, ' Oa f 9

v. 1, No. 4, June 1960,fpp. 64-82.

4 ^.4 f w. , -- - e -~ - - g 3s-l 9 1 CONSEQUENCES OF ACTIVITY RELEASE lj j. r [ j. l! .i f. ceologic and nydrotogic

structure but a power reactor <= =orethanthat l

j and raises special problems. ..j.- Considerations in Power Another old but less routine problem is pre. l i Reactor Site Selection sented by the possibility of floods. Most power I k i reactors are situated near some large body of h j t water for condenser cooling, and.in severa! ) It is required that a reactor-hazards report cases the reactor is within a very few feet of j provide, among other things, the meteorological, f past or predicted maximum flood or high-tide ); hydrological, geological, and seismologicaldata ' levels. The economic desirability of alowpump. I p. ] necessary for evaluating the measures proposed $ng head is obvious, but the art of flood predic. j for protecting the public against possible radio-tion has repeatedly fallen victim to what one ] ,t active hazards. Since meteorologists had their distinguished hydrologist called "theconcatena. ll previous experience with industrialairpollution h of chmtam h mb far@ to guide their early work with respect to the 1tthan the predicted maximum have not infre-E hazards of radioactivity, the new methods of guently confounded the best of prophets. None j. 'I analysis that they developed duringtheirstudies ,of the reactor sites appears to be indanger, but of reactor sites were immediately applicable t reactor-hazards analyses. Studies of the p.or,. sin at least one case themarginof safety appears ! j qj Ito be 'less than that used to guard against some j' tions of current hazards reports -" that deal jof the more spectacular hazards. In any event, 8 with hydrology, geology, and seismology show,. !the flooding of a reactor does not seem to offer i s j j however, that earth scientists must learn to serious hazard to the surrounding area un. i j. provide a more complete picture of thephysical ;. lless other misfortunes occur at the same time, ,p 'y environment if they are to discharge their re. ,as is, of course, possible. sponsibilities. The various hazards reports do : A 4 not approach the problems in the same way, and. e j; The possibility of earthquake damage has aroused. considerable interest,88 probably more . 5 j l

i the differences are only in part due to differ'- "l lih
an it generally deserves. Most of the hazards ences in the sites.

Despite the differences, the discussions are [: yeports provide the information requiredonthis g' ' subject by a short statement that the site is in ~ of two general types. In the first, the ways in 1 which the site might affect the reactor are ii inn area where earthquakes are infrequentandof l g analyzed; and, it the second, the ways in which :ij. low intensity, and therefore the hazard from [.them is negligible. Such statements the reactor might affect the surrounding area "l' based on data taken from publications of the are considered. Few reports attempt to cover ] / i j U. S. Coast and Geodetic Survey. In any case. 1 4' both aspects of the problem. , reactors are constructed so that they are not y l ~ 8u8ceptible to damage from any but the mostin-Effect of SI'te on Reactor tense shocks. There mi@t, however, be an in- .i The reports that are primarily concerned a direct hazard through damage to underground l I j with the effect of the site on the reactor include pipes or wires outside the reactor or through ~ i studies of foundation conditions, safe bearing . landslides or tidal waves, either of whleh might ] loads, and results of the special test drilling.

cause;' flooding; but, even including these some-I done to obtain information about these points.

.what remote possibilities, the total earthquau f f Several reports are almost exclusively con- , hazard is very small in most areas. I cerned with such data. They were prepared,in' ' M An ' exception to this generalization w'ould be, the petitioning company. Such investigations]j general, by engineers in the regular employ of,* the case of a reactor builtby the water's edge on, , weak foundation material in an area of frequent ! I are, of courst, routine, for any large, heavy eartbouakes of high intensity. One suggested H jl g f L i l- . n } ~s t.. i. 3 A h ____i. _________I__ ?

b 'e .i CONSEQUENCES OE ACTIVITY REl E ASE 65 l i t C. J. ; l "nearly meets these conditions. It is on the U n building a large bridge or dam and can be i L solved by almost routine methods. Flood pre-e of a bsy and is underlain ton depth of 20 ftU icly by recently deposited unconsolidated diction is a little more difficult, but the reactor s of clay and silt. The nature of thematerial $ as such offers no novel problem in raising the q_this is net clear. Athe geology section. question: "How much can we cut the pumping Ce safeguards report,6the material is de.% lift and still be safe above floodcrest?" Earth-q clays with the majority consisting of the I ; quake damage is far more dramatic, a Ited is "silshily consolidated gravelse sandse$ l / cause no area can be said to bequite free of the l 3r grained materials"; that is, largely clay danger of a heavy earthquake, there has been 9stit. In the section on earthquake hazards, much public interest. The danger to a well-eevsr, the same material is referred to as built reactor situated on firm foundation mate-i and is described as a " fairly well indu-rial appears, however, to be negligible, ed seriss of mudstones, siltstones, sand-l nes, and conglomerates." The drilling record Effect of Reactor on Site L 1s the material clay and sandy soils with On the other hand, the reports whichinterpret l de sand and gravel. [ the question of site evaluation as "what will a I I there is also some ambiguity as to the in-i reactor accident do to the surrounding area?" sities of the earthquakes to be exnected. The tion on Garthquake hazards lists eight shocks ] deal with a very complex and novel problem, as kntensity Vm (modified Mercalli scale) and : has been suggested by the several attempts to l i 4 cf intensity DC over roughly thelasthundred.} establish criteria for site evaluation.22 23 The l I Ers, but the shock of intensity DC is dis-j hazards reports in which an attempt has been made to evaluate in any way the vulnerability of inted because the record is oldanduncertain. i Q cuthors conclude that intensity VM is the.f 'the surrounding area to release of radioactive materials give data relevant to some parts of aximum shock which should be expected inthe.l the problem, but in no case has an attempt been

nre. Th2 ambiguity is intheword " expected." I made to follow a nuclear incident through to its tth at least nine shocks of intensity VM a conclusion and evaluate its consequences. Ad.

atter of record, more shocks should certainly , ' mittedly, such an analysis would require the l

expected, but the report appears to give the Gression that there is no ne.ed to plan for'. '

joint efforts of a group of experts,but,the largely j ything cf greater intensity. There is a very.__ l uncoordinated and separately composedsections whicn comprise the typical hazards report of l jat difference between a reactor situated on today do not seem toprovide as complete a basis t,1 and subjected to an earthquake of intensity as could be wished for such a study. Even with ~ di"and'one situated on water-saturated clay. the best available data, however, the attempt i I s'ilt 55d slbjected to a shock ofintensity IX. would be faced at every step by problems for ~ . be' principal hazard in this case appears to be which there are at present not even order-of-lt to the reactor but to the proposed under-magnitude solutions. tound waste-storage facilities. Ebock intensities VI:1 and IX are defined as The analysis should proba'oly begin with the maximum credible accident, already a time-allows: need mawer, even in m Wam %q. 'vm. Damage slight in specially constructed build-Next, having decided how rnuch of what particu- ' ngs; considerable in ordinary substantial buildings, lar isotopes would escape and in what physical i t-ith partial collapse.... Sand and mud ejected and chemical form, the meteorologists would l .in small amounts. DC. Damsge considerable in specially designed structures, great in substantial have to decide where the air-borne material . buildings,with partialcollapte.... Ground cracked would land and the hydrologist would have to conspicuously. Underground pipes broken, plot the paths, rate of movement, and dilution in general, it may be stated that the site of any escaping 11guld. Some of thistiquidmight studies which have tried to answer the question seep into the. ground, and rain might leach ra- 'is the environment safe forthe reactor?" have - dioactive material from the fallout area and , )een able to furnish convincing reliable answers, carry this also into the ground water, sothe di-tery largely because the problems are not new. rection and rate of movement of the ground The foundation problems even for a large reac-water would hsve to be considered. Next, the 'or are minor compared with those encountered ecologist would have to attempt to determine . - ~. g.....: R3;

- -.... : L _. p ~ l _ ) i, Q. ~ @e ._m s m . 3, _..m { o ,~ 3 l. 80 . NUCLEAR SATETY ..s q l sidered to, be significantly different from th,e;* - 7. J. H. MacMillan, Babcock and Wilcox*Co., Juel, ) s. 1959. (Unpub11shed) deposition values calculatedforthe NCRP stand-

8. Puerto Rico Water Resources Authority and Gen.

2 5. ' ard man. As expected, the internaldose(iodine, i u al uchar Enginming Corp., BoWng Nekar t thyroid) that would result from breathing while Superheater (BONUS) Power Station: Preliminary d submerged in the grep fuel-element release Design Study and Hazards Summary Report. e 4 5 l cloud was measured to.be about three orders USAEC Report T1D.8524 four volumes, to te { of magnitude greater than the external dose. published. 26. I The measured externsi gamma-ray dose under 9 commonwealth Edison Co. and General Electric I lapse conditions (at 400 meters).. as about one. Co., Preliminary Hazards Summary Report for w Dresden Nuclear Power Station, September 1, half that predicted. No more than 5 per cent of 1957, with amendments, AEC Docket No. 50-10. any aerosol, except iodine, was found to pene. Northern States Power Co., Mar. 10,1959. (Un. 27. ( I. trate the pleated filter of the high-volume air..10; liublished) t y sampler. However, it was found that about 25to

11. Pactfle Gas and Electric Co., Humboldt Bay power 45 per cent of the iodine, based on total iodine

"*'I f, collected by both the pleated filter and backup Summary Report, ' Report NP-7512, Apr.15.199 carbon cartridge, had penetrated the pleated 12, D. L. Fischer et al., General Electric Vallecitos 28. i g j filter. This is attributed to the interaction of Boiling Water Reactor Final Hazards Summary the local dust and the iodine and depended upon Report, Report SG. VAL-2(2nd Ed.).GeneralElec. r. tric Co., Vallecitos Atomic Laboratory, May 4. the concentration of the. dust. As a result,more i 4 1958. [ penetration was observed closeinthanatfarther

13. Allis-Chalmers Manufacturing Co., Mar.12,19H.

1 distances downwind. I . (Unpublished) 29. h j Tests such as these are valuable, not only

14. J. Jacobson, ed., Preliminary Safeguards Report l

for the additional information they provide on. i r the Na Organic modnakd Reactor W. I release fractions and' diffusion under particular I .l field conditions, but also to point out areas * - International, Apr. 13,1959. f js g j such as deposition velocity, in which further

15. S. E. Beall and S. Visner, Homogeneous Reactor j.1 i

study is needed. (T. J, Burnett) Test Summary Report for the Advisory Committee 30. I on Reactor Safeguards, USAEC Report ORNL-l 1834(Del.), Oak Ridge NationalLaboratory,Jan.5..> 31, s References

1gss, l

t ,f

16. Carolinas Virginia Nuclear Power Associates.

k l h i f.

1. F. A. Gifford, Meteorology in Relation to Reactor Inc., Preliminary Hazards Summary Report, Vol-32.

5 Hazards and Site Evaluation, inSixth1 international H1. Part B, License Appilcation, Report CYNA !!. I i Congress and Exhibitionof Electronics and Atomic July 15,1959.

  • }

Energy, Rome, Italy, June 1959, U. S. Papers,

17. American Electric Power Service Corp. ad General Nuclear Engineering Corp., App!!ca-

') USAEC Meport T!D.7579, pp. 59-67, October tion for USAEC Licenses by Florida West Co*8 } 1959.

2. Yankee Atomic Electric Co., Nuclear Power Sta.

Nuclear Group. Part B. Preliminary Haaards ' l 4 tion Technical Information and Final Haaards Summary Report, Report NP-8251, Dec. 7,19H 33, Summary Report. Part B, License Application,

18. Kaiser Engineers Div. of Henry J. Kaiser Co.ad i

f 4 AEC Docket No. 50 29, USAEC Report YAEC.167 Allis-Cha!.mers Manufacturing Co., Experimerd Gas. cooled Eeactor; Preliminary Hazards Sum-(Vols. I and II),1959. j

3. Westinghouse Electric Corp., Bettis Atomic Power

.mt.ry Report, USAEC Report ORO.196 and SvP, 1 j Div., Description of the Shippingport Atomic plement, May 1959. i i Power Station, USAEC Report WAPD PWR.970,

19. Atomic Power Development Associates, far-34 Enrico Fermi Atomic Power Plant, Report APDA-I
f June 1957.
4. Alco Products, Inc., Hazards Summary Report 124, Jancary 1959.

r .t f i for the Army Package Power Reactor, USAEC

20. Atomics International!. (Unpub!!shed)
21. Aseismic Reactor. Design, Nuclear Safety, !@

ll l Report APAE.2, July 27,1955 L

5. Intermediate Haaards Summary Report, Consoll.

32-33 (December 1959).

22. Site Selection Criteria, Noctrar Safety, !(2h !d

{ ,j dated Edison Reactor, AEC Docket No. 50 3, May l (December 1959). 1959. 3' 6.1. R. Fin!*ock, Jr.,. et al., Application to U. S.

23. Appendix: Notice of Proposed Rule Making.M-p clear Safety,1(1): 8-9 (September 1959).

Atomic Energy Commissionfor Reactor Construe.

24. R. E. Brown et al., Experience in the Dispost d l

tion Permit and Operating License. Part B, Pre. Radioactive Wastes to the Ground, A/ CONT.d liminary Hatards Summary Report, Report NP. 7757, Saxton Nuclear Experimental Corp.,1959. P/1767, Second International Conference on tp l g 1 '. l 2 1 s I ':? .l. d%d

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