ML13304A637
| ML13304A637 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/15/1980 |
| From: | Roberts J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML13304A634 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8008200198 | |
| Download: ML13304A637 (38) | |
Text
ATTACHMENT 2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
SOUTHERN CALIFORNIA EDISON COMPANY,
)
)
50-362 OL (San Onofre Nuclear Generating
)
Station, Units 2 and 3)
)
AFFIDAVIT OF JACK 0. ROBERTS CONCERNING STAFF MOTION FOR
SUMMARY
DISPOSITION ON INTERVENORS' CONTENTION 9 (URANIUM PRICES)
JACK 0. ROBERTS, being first duly sworn, deposes and says that if called as a witness herein, he is qualified to testify as follows:
- 1. I am currently Senior Technology Assessment Analyst, Utility Section, Utility Finance Branch, Division of Engineering, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission. In my position I am responsible for cost-benefit analysis, need for power and system reliability, financial qualifications of applicants and indemnification under the Price-Anderson Act.
- 2.
I have been employed by NRC and the Atomic Energy Commission since 1976 as a Senior Technology Assessment Analyst.
- 3. I obtained a B.S. degree in Chemical Engineering from the University of Colorado in 1949. In addition, I completed the Oak Ridge School of O 82n q
-2 Reactor Technology Program at Oak Ridge, Tennessee in 1956. My formal educational program has encompassed mathematics, physics, chemistry, engineering and economics as they relate to industrial processes and production plants. A copy of my professional qualification sheet is attached to this affidavit.
- 4. I have read the San Onofre Units 2 & 3 Draft Environmental Statement, NUREG-0490, relating to cost-benefit analysis of the proposed action, in particular pages 8-1, 8-3, 8-4, 9-15, 10-2, and 10-3. In that document the Staff predicted a favorable cost/benefit balance for SONGS 2 & 3. The forecasted fuel cost for SONGS 2 & 3 used a $42/lb. price for U 308 in 1977 dollars and assumed a constant escalation rate of 7%
resulting in a fuel cost of $51.43/lb. in 1980 and a total fuel cost for the plant of $87.9 x 106 per year in 1981 dollars. Since, at the OL stage, the plants are already constructed, the only costs which can be affected by licensing decisions are the operating costs. These consist of fuel and a small part of operation and maintenance costs.
Compared to nuclear, coal plants are the next lowest cost to operate for providing the same amount of electricity as would be provided by SONGS 2 & 3.
The fuel cost in 1981 to operate coal plants in the West is forecasted to be about $140 x 106 per year in 1981 dollars* to supply the same amount of power as SONGS 2 & 3. This fuel cost is in
/
Coal price forecasts are based on U.S. Department of Energy, "Annual Report to Congress - Projections of Energy Supply and Demand and Their Impacts," Vol.
II, 1977.
-3 addition operation and maintenance costs, which generally are higher for coal plants than for nuclear. Thus, the savings to the buyers of the electricity is expected to be at least $52 x 106 in 1981 dollars if SONGS 2 and 3 operate rather than 2 comparable coal plants. However, both nuclear and coal prices are expected to escalate because a fixed resource is being depleted in both instances. The long run rate of escalation for each fuel source will depend upon the rate of use of each.
- 5. The cost of uranium as U308 makes up about 40 percent of the total cost of operating costs of the plant and carrying charges on the U308 make up an additional 20 percent. Because of the high forecast of the cost of coal to furnish power from a coal plant (described in paragraph 4 above) equal to that of SONGS 2 and 3, the cost of U308 and carrying charges for the fuel would have to double (assuming the coal prices remained unchanged) before the cost of producing electricity from SONGS 2 and 3 would be as high as operating a coal plant. In addition, since the uranium fuel costs including carrying charges mentioned above are only 12% of the total generation cost of the nuclear plant, the cost of uranium prices would have to increase astronomically before the plant would become uneconomical to operate.
- 6. For the reasons listed above, I therefore conclude the cost-benefit conclusions reached in the DES are correct and SONGS Units 2 and 3 are a lower cost means of producing electricity than the next lowest cost
-4 alternative. Accordingly, even if uranium fuel prices were to increase drastically, (which does not appear to be happening, see Patterson Affidavit) I would not expect the SONGS 2 & 3 cost/benefit balance to be upset.
ack 0. Roberts I hereby certify that the information listed above is true and accurate to the best of my personal knowledge.
Personally appeared before me this 15th day of August, 1980, was Jack 0.
Roberts who swore that the information above is true and accurate to the best of his personal knowledge.
Notary Publit MX COMMISSION EXPIRES JULY 1, 82
STATEMENT OF QUALIFICATIONS OF JACK 0. ROBERTS I am employed as a Senior Technology Assessment Analyst with the Cost-Benefit Analysis Branch, Division of Site Safety and Environ mental Analysis, Office of Nuclear Reactor Regulation, located in Bethesda, Maryland.
My educational and professional qualifications are set forth below.
Education I obtained a B.S. degree in Chemical Engineering from the University of Colorado in 1949.
In addition, I completed the Oak Ridge School of Reactor Technology Program at Oak Ridge, Tennessee in 1956.
My formal educational program has encompassed mathematics, physics, chemistry, engineering and economics as they relate to industrial processes and production plants.
Experience I joined the Cost-Benefit Analysis Branch of NRC in June 1976 as a Senior Technology Assessment Analyst.
I am responsible for reviewing and analyzing Applicant's Environmental Reports and preparing cost benefit portions of environmental statements.
I am responsible for developing the criteria and methodology for analysis of alternative sites, alternative fuels and alternative cooling systems to be used in environmental statements. In addition, I conduct and manage technical and economic research on topics related to environmental impacts of nuclear power plants.
In this connection I oversee the performance of outside consultants and contractors and arrange for expert review of the technology and economic research performed by these organizations.
I prepare testimony and participate in environmental hearings regarding cost-benefit analysis, in particular, cost analysis of alternative energy producing systems and alternative fuels, land use impacts of power plant siting, regional impacts, and the need for the facility.
Other activities include review and propose revisions of Regulatory Guides, in particular Regulatory Guide 4.2 which pertains to preparation of Environmental Reports.
From the inception of NRC until I joined the Cost-Benefit Analysis Branch, I was Senior Task Leader on a special study, "Nuclear Energy Center Site Survey," where I was involved in the early planning and organization of the study.
After the study plans were approved, I was responsible for developing the section of Assumptions and Bases and for overseeing the development of chapters on Heat Dissipation and Reactor Facility Siting - Layout and Construction.
I was with the 4tomic Energy Commission from 1953 until that organization was terminated in 1975. The following is a summary of the more signifi cant programs I was involved in while with the AEC.
From 1964-1975 I was with the Division of Reactor Research and Develop ment and was involved in the following programs and studies:
Economic and technical assessment of nuclear and coal based systems for meeting the process industry energy needs particularly in those areas of the U.S. where gas could no longer be considered a firm source of energy.
Economic and technical evaluation of the potential of nuclcar systems for meeting high temperature (1000 0-20000F) process heat needs.
Economic and technical feasibility studies relating to the use of dry cooling towers for disposing of waste heat from power plants.
Studies to assess the economic and practicality of beneficially using waste heat from power plants.
Studies to investigate home and commercial space heating and cooling methods including an assessment of the
impact of changing energy cost on the economics of space conditioning methods and its effect on the electric utility industry.
Studies relating to the use of nuclear energy for dual purposes (desalting sea water and electric power pro duction) applications. These studies involved economic and technical feasibility assessment of nuclear dual purpose plants and comparing the alternative system of producing the same products.
General studies relating to the siting of nuclear power plants including underground, offshore, siting characteristics associated with dry cooling, and the California siting study which investigated the economic and technical feasibility and impacts of about seventeen siting concepts for the western part of the country.
From 1962 to 1964 I was on loan to the International Atomic Energy Agency where I participated in the development and' implementation of international safeguards system.
From 1958 to 1962 I was with the Division of Reactor Development, Evaluation and Planning Branch. I was involved with the evaluation of the technical status and the economic potential of Various reactor concepts and planning the direction of research and development programs for the development of the more promising concepts.
From 1953 to 1958 I was with the Division of Nuclear Materials Management.
This group was responsible for establishing material control methods and monitoring the accountability of AEC's nuclear materials.
My involvement related to the technical aspects of processes and related measurements for material control.
From 1949 to 1953 - Sandia Corporation. I was associated with the surveillance and modification'of the nuclear components of atomic weapons at storage sites.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
SOUTHERN CALIFORNIA EDISON COMPANY,
)
)
50-362 OL (San Onofre Nuclear Generating
)
Units 2 and 3)
)
NRC STAFF MOTION FOR
SUMMARY
DISPOSITION ON CONTENTION 1(a) (Dewatering Well Cavities)
L. Dow Davis, IV Counsel for NRC Staff Lawrence J. Chandler Counsel for NRC Staff
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
SOUTHERN CALIFORNIA EDISON COMPANY,
)
Docket Nos. 50-361 O.L.
50-362 O.L.
(San Onofre Nuclear Generating
)
Station, Units 2 and 3)
)
NRC STAFF MOTION FOR
SUMMARY
DISPOSITION ON CONTENTION 1(a) (Dewatering Well Cavities)
I. Introduction On June 6, 1980, Southern California Edison Company and San Diego Gas and Electric Company (Applicants) moved for summary dispositionl! of Joint Inter venors'Z/ contention number 1(a)3/ which reads as follows:
la:
"Whether the cavities caused by the Applicants' temporary dewatering of SONGS 2 & 3 site will have an unacceptable adverse effect on the capability of structures and equipment of the SONGS 2 & 3 to withstand the design basis seismic events."
1/ Motion for Summary Disposition of Intervenor Friends of the Earth, et al.'s Contentions la (Dewatering Wells) and 9 (Uranium Fuel Costs) dated June 6, 1980. The Staff Response to the Uranium portion of the Applicants' Summary Disposition Motion is addressed in the separate pleading entitled "NRC Staff Motion for Summary Disposition on Intervenors' Contention 9" dated July 23, 1980.
2/ Friends of the Earth, Mr. and Mrs. August Carstens, Mr. and Mrs. Lloyd von Haden, Mr. Donald May and Mrs. Donis Davey and GUARD.
3/ The stipulated contention was admitted by the Licensing Board in its Memorandum and Order dated January 27, 1978 at 3.
-2 For the following reasons, the NRC Staff also moves the granting of Sum mary Disposition on Intervenors' Contention 1(a)4/ regarding on dewatering 5/
cavities.
II. Applicable Law The Commission's rules provide that a moving party is entitled to summary disposition if it can be shown that there are no material issues of fact to be adjudicated at the hearing and that he is entitled to judgment as a matter of law. 10 C.F.R. §2.749. That section states:
Summary Disposition on Pleadings
§2.749 Authority of presiding officer to dispose of certain issues on the pleadings.
(a) Any party to a proceeding may, at least forty five (45) days before the time fixed for the hearing, move, with or without supporting affidavits, for a decision by the presiding officer in that party's favor as to all or any part of the matters involved in the proceeding.... [by demonstrating that]...there is no genuine issue to be heard.
Under the Commission's regulations, the "applicant or the proponent of an order has the burden of proof" of an issue. 10 C.F.R. § 2.732. Both the Commission, whose rule governing summary disposition contained in 10 C.F.R.
4/ This pleading is considered by the Staff to be a submission in support of Applicants' Motion for Summary Disposition on the same subject within the provisions of the stipulation of Counsel attached to the Licensing Board's Memorandum and Order on Prehearing Conference of July 17, 1980 dated August 6, 1980.
5/ One Licensing Board has indicated that a motion for summary disposition may be improper where the OL SER is not yet issued. Duke Power Company (William B. McGuire Nuclear Station, Units 1 and 2), LBP-77-20, NRC 680, 681 (March 18, 1977).
-3
§ 2.749 is analagous to the summary judgment provisions of the Federal Rules of Civil Procedure,-/ and the Supreme Court have held that it is the party seeking summary judgment (or disposition) which has the burden of showing the absence of a genuine issue as to any material fact in contest in the disputed proceeding. Cleveland Electric Illuminating Company, (Perry Nuclear Power Plant, Units 1 and 2), ALAB-443, 6 NRC 741, 753 (November 8, 1977); Adickes v. Kress & Company, 398 U.S. 144, 157 (1970); J. Moore, Federal Practice, Vol. 6, § 56.15 [3] (2d ed. 1966). To meet this burden, the movant must eliminate any real doubt as to the existence of any genuine issue of material fact. Poller v. Columbia Broadcasting Company, Inc.,
368 U.S. 464 (1962); Sartor v. Arkansas Natural Gas Corporation, 321 U.S.
620, 627 (1954). The record and affidavits supporting and opposing the motion must be viewed in the light most favorable to the party opposing the motion. See Public Service Company of New Hampshire (Seabrook Station, Units 1 and 2), LBP-74-36, 7 AEC 877 (1974) and cases cited therein at 878-79. The opposing party need not show that he would prevail on the issues but only that there are genuine issues to be tried. American Manu facturers Mutual Insurance Co. v. American Broadcasting - Paramount Theaters, Inc., 388 F. 2d 272, 280 (2d Cir. 1967); accord Virginia Electric Power Co.
(North Anna Nuclear Power Station, Units 1 & 2), ALAB-584, 11 NRC 451, 453 (March 24, 1980).
6/ Alabama Power Company (Joseph M. Farley Nuclear Plant, Units 1 and 2),
ALAB-182, 7 AEC 210, 217 (1974).
-4 Affidavits setting forth the material facts about which there are no genuine issues to be heard may accompany the motion to dispose of issues in the pleadings, and the affidavits may be supplemented or opposed by depositions, answers to interrogatories of further affidavits. 10 C.F.R. §2.749(b).
While it is not necessary to present evidence in order to defeat a motion for summary disposition since the motion itself and accompanying affidavits must discharge the movant's burden (and no defense to an insufficient show ing by movant is required), the rule clearly states that the party opposing the summary disposition motion may not rest upon mere allegations or denials in his answer but rather must provide by affidavit, deposition or answers to interrogatories, specific facts showing there is a genuine issue of fact in controversy. 10 C.F.R. §2.749(b); Perry, supra, at 754; accord, Virginia Electric Power Company (North Anna Nuclear Power Station, Units 1 & 2),
ALAB-584, 11 NRC 451, 453 (March 24, 1980).
In this regard, a Licensing Board has said that:
In order to defeat a motion for summary disposition the Intervenor must establish (or the Board perceive from the record) that there does exist a genuine issue of material fact with respect to each contention so attacked. At this stage, mere allegations in the pleadings are not sufficient to establish the existence of an issue of material fact.
10 CFR §2.749(b); See Orvis v. Brickman, 95 F.Supp. 605 (USDC, D.C. 1951), affrd. 196 F.2d 762 (D.C. Cir. 1952); see also 6 Moore §56.151j7.
To defeat summary disposition an opposing party must present facts in the proper form; conclusions of law will not suffice.
The opposing party's facts must be material, substantial, not fanciful, or merely suspicious.
-5 One cannot avoid summary disposition "on the mere hope that at trial he will be able to discredit movant's evidence; he must, at the hearing, be able to point out to the court something indicating the existence of a triable issue of material fact". 6 Moore's Federal Practice §50.15[4]. One cannot "go to trial on the vague supposition that something may turn up."
6 Moore's Federal Practice §56.15[3]. See Radio City Music Hall v. U.S. 136 F.2d 715 (2nd Cir. 194)
In Orvis v. Brickman, 95 F.Supp. 605 (D.C.D.C. 1951), the Court, in granting the defendant's motion for summary judg ment under the Federal Rules said:
All the plaintiff has in this case is the hope that on cross-examination...the defendants...will contradict their respective affidavits. This is purely speculative and to permit trial on such basis would nulify the purpose of Rule 56....
Moreover, the rule itself provides that "all material facts set forth in the statement required to be served by the moving party will be deemed to be admitted unless controverted by the statement required to be served by the opposing party."
10 C.F.R. § 2.749(a).
Summary disposition is desirable in administrative hearings because it makes possible the prompt disposition of a case on its merits without a formal hearing by permitting a party to pierce his opponent's pleadings by presenting material evidence in affidavit form which establishes that no factual dispute existsY The Staff submits that such a pro cedure for conserving hearing time by culling out baseless allegations is particularly appropriate in the instant case since, as will be shown 7/ Gulf States Utilities Company, (River Bend Station, Units 1 and 2),
LBP-75-10, 1 NRC 246, 248 (March 20, 1975) (Footnotes omitted).
8/ Gellhorn and Robinson, Summary Judgment in Administrative Adjudication.
84 Harvard L.Rev. 612 (1971L
-6 below by affidavits, there is no factual basis for the Intervenors' conten tion number 1(a). Moreover, Intervenors' July 28, 1978 answers to interroga tories propounded by Southern California Edison at 12-13 (which have not been updated) do not provide a factual basis for opposing the motions for summary disposition. For these reasons, the Staff believes that Intervenors contention la should be dismissed as a matter of law.
III. Discussion A. The Applicants' Affidavit In support of their Motion for Summary Disposition on Intervenors' conten tion regarding dewatering well cavities, Applicants submitted the sworn affidavits of five witnesses 9/ to show that no material fact remains to be litigated as to the safety significance of certain voids created beneath the site of the San Onofre Nuclear Generating Station, Units 2 and 3 (SONGS 2 and 3), during the dewatering process.
Applicants maintain that excavations and borings show that the subsurface cavities discovered at the site did not exist prior to the installation of the dewatering system, whose purpose was to facilitate construction of foundation below the water table. Hersh at 5,7. An additional study showed that the voids did not occur naturally but rather were created during the process of dewatering. McNeil Affidavit at 5. After filling wells 4, 5 and 8 with sand as was the customary decommissioning practice, settling occurred 9/ Affidavits of Lucien Hersh, John A. Barneich, Robert L. McNeill, Jay L.
Smith and Kenneth P. Baskin concerning dewatering were attached to the Applicants' June 6, 1980 Motion.
-7 at well 6, indicating the existence of a potential subsurface cavity. Hersh at 8. Following this discovery, a program of exploratory drilling was con ducted and all cavities filled with either sand, gravel, concrete, pressure grout and/or a combination of such materials. Hersh at 13-26.
In order to demonstrate that the filled dewatering cavities presented no undue hazard to the ability of seismic category I structures to withstand the design basis earthquake (now known as the safe shutdown earthquake),1Q Applicants conducted dynamic analyses as to the effects of the most signifi cant cavities by evaluating how the filled cavities in their most unstable configuration could effect the soil supporting adjacent structures and thereby influence structural behavior. Barneich at 10. Using an assumption that the cavity at well 8 was 25 times larger than its known size and a pore pressure ratio which was stated to be conserative, the results of the analysis of the stability of well 8 was extrapolated to wells 6 and 7, thus covering all three wells which were found to be of controlling significance due to their size and proximity to the seismic category I structures.
Barneich at 8, 13. The results of the static and dynamic analyses of the possible effects of the cavities were found to result in a maximum reduction in soil stiffness for any structure of 8%, well within the 30% variation used in the design of the structures, and a calculated maximum settlement of less than one-tenth of an inch, well within the maximum settlement of the original design which was estimated to be less than 1/2 inch. Barneich at 14-15; McNeil at 13.
Based on these analyses, Applicants concluded that all 10/ See Part V of Appendix A to 10 C.F.R. Part 100.
-8 cavities at the site had been detected and accurately evaluated and that they would have no detrimental effect on the operation of SONGS 2 and 3, since they had been adequately demobilized by backfilling with sand, gravel, and/or grout. Barneich at 18; McNeil at 15, 16.
B. The Staff Affidavits The attached affidavits submitted by the Staff's expertsz11 support the conclusion that the Applicants have adequately investigated the site for voids and cavities and that existing voids and cavities have been adequately filled. Moreover, analyses done by the Staff support the conclusion that even if it is conservatively assumed that the fill materials were assumed to fail in the worst possible manner, the voids would pose no significant hazard to the seismic category I structures on site.
The affidavit of John T. Greeves, Staff geotechnical engineering reviewer for the SONGS 2 and 3, shows that exploratory drilling, mechanical measure ments and geophysical surveys conducted at the site in accordance with Reg Guide 1.132 and the investigation of the twelve dewatering wells at or adjoining the site12/ were performed to define the location and extent of each and every cavity at the site.
Greeves at 2.
Sand, grout and concrete 11/ Affidavits of J. Greeves (Attachment 1) and of R. Lipinski (Attachment 2).
We would note, however, that contrary to Applicants' assertions (e.g.,
Motion at 11, 16, 17, Statement of Facts at 3, Affidavit of Hersh at 10),
the NRC Staff has not previously approved or authorized any activity with respect to natural treatment of the dewatering cavities or the adequacy thereof.
12/ Two wells are located offsite. Greeves at 3.
-9 were used to fill the cavities in accordance with standard practice. Greeves at 3. In addition, analyses were performed on dewatering wells 6, 7 and 8, the only cavities of sufficient size and proximity to the SONGS 2 and 3 to have an effect on them. Greeves at 2. An analysis done on well 8 and extrapolated to wells 6 and 7 shows that the generation and dissipation of excess pore pressure (the potential reduction in stiffness and support characteristics of the filled cavity) showed a maximum reduction in overall soil stiffness of only 4 to 5% (Greeves at 5), a reduction which was thought by the Staff to be small when compared with the 30% variation the plants' seismic category I buildings were designed for.
However, in addition to seismic category I buildings, the Applicants' inves tigation of the dewatering well cavity situation revealed that dewatering well cavity 8, assumed to be some 25 feet in width and underlying an elec trical cable tunnel of safety significance, had the potential to affect plant safety. Greeves at 6. The affidavit of Romuald Lipinski, the Staff expert on structural engineering and the SONGS 2 and 3 reviewer for design and analysis of seismic category I structures, revealed that the Applicants had performed an analysis which assumed a combination of the three components of seismic response, assumption of a box-type beam response for the tunnel for flexural conditions, and seismic loading calculated at 1.5 times the peak response of the applicable response spectrum. Lipinski at 4. Although the results of the analysis appeared to be conservative in that the study assumed that the tunnel would be completely unsupported in the area of the
10 cavity and the study appears to indicate that there will be no safety degrada tion of the tunnel due to the cavities, questions remained since the analysis did not use the SRSS method. In addition, the Staff believed that stresses in the discontinuity of the tunnel might be higher when an abrupt change in conformity of the cross section of the tunnel might produce "stress risers" which could become a critical section of the tunnel's structural analysis.
Lipinski at 5. Accordingly, the Applicants were asked by the Staff for additional information in the form of a confirmatory analysis designed to verify that their previous analysis submitted for review is conservative.
Lipinski at 6. As noted in the Lipinski Affidavit, the results of the additional analysis submitted by the Applicants confirmed the Applicants' earlier conclusion that dewatering well cavity number 8 would have no adverse effect on the electrical cable tunnel or any other seismic Class I structure.
Lipinski at 6-7.
IV.
Conclusion For the foregoing reasons, the NRC Staff believes that there is a reasonable assurance that the SONGS 2 and 3 seismic category I buildings will not be adversely affected by dewatering cavities and that no genuine issues of material fact remain to be litigated as to this issue, such that summary disposition should be granted as a matter of law. For that reason, summary
11 disposition should be granted on Intervenors' contention 1(a) concerning dewatering well cavities and the matter dismissed.
Respectfully submitted, L. Dow Davis, IV Counsel for NRC Staff Lawrence J. Chandler Counsel for NRC Staff Dated at Bethesda, Maryland this s tL day of August, 1980.
IV. NRC STAFF STATEMENT OF MATERIAL FACTS AS TO WHICH NO GENUINE ISSUES EXIST TO BE HEARD AS TO SAN ONOFRE UNITS 2 AND 3 AND THE ISSUE OF DEWATERING WELL CAVITIES Pursuant to the provisions of 10 C.F.R. § 2.749(a), the NRC Staff hereby states the following as material facts as to which no issues remain to be litigated:
- 1. That the Applicants have adequately investigated the SONGS 2 and 3 site for voids and cavities.
- 2. That existing voids and cavities have been adequately filled with grouting material.
- 3. That detailed analyses using conservative assumptions show that even if fill materials were assumed to fail in the worst possible manner, the voids would pose no significant hazard to the seismic category I structures on site.
- 4. That a detailed analysis of the void cavity 8 shows that a worst case failure of that cavity's fill materials would not have an adverse
-2 effect on the SONGS 2 and 3 electrical tunnel, the closest seismic category I structure to that filled void.
L. Dow Davis, IV Counsel for NRC Staff Lawrence J. Chandler Counsel for NRC Staff
ATTACHMENT 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In The Matter of
)
SOUTHERN CALIFORNIA EDISON COMPANY, Docket Nos. 50-361 OL ET AL.
)
50-362 OL (San Onofre Nuclear Generating
)
Station, Units 2 and 3)
)
AFFIDAVIT OF JOHN T. GREEVES CONCERNING INTERVENORS' CONTENTION 1(a) (DEWATERING WELLS)
- 1. I am employed as a Geotechnical Engineer in the Geotechnical Engineer ing Section of the Hydrologic and Geotechnical Engineering Branch, Division of Engineering, U.S. Nuclear Regulatory Commission. In this capacity, I am responsible for evaluating sites with respect to geo technical engineering aspects to assure adequate design measures to prevent adverse safety problems.
- 2. I hold a Bachelor of Science Degree in Civil Engineering from the University of Maryland (1968). In addition, I have completed nine (9) credit hours of graduate level studies in Civil Engineering at the University of Maryland. I am a Registered Professional Engineer with current registration in Mississippi and Virginia.
- 3. I have about twelve years of experience working in areas related to foundation design, construction and analysis required for both nuclear
-2 and conventional electric generating plants. These include nearly seven years with Bechtel Inc. in Gaithersburg, Maryland and six years with the U.S. Nuclear Regulatory Commission (formerly USAEC) in Bethesda, Maryland.
- 4. As the geotechnical engineering reviewer assigned to this case, I reviewed those sections of the FSAR dealing with geotechnical aspects of the site, all special submissions dealing with dewatering voids, attended a large number of meetings on that subject and conducted several site visits, inspecting the investigation and demobilization activities associated with the dewatering wells located at SONGS 2 and 3.
- 5. Southern California Edison Company (SCE) and San Diego Gas and Electric (Applicants) have investigated, identified, filled and evaluated a number of dewatering cavities at the San Onofre site. For the follow ing reasons, in my opinion the techniques used to identify the cavities and procedures used to fill the cavities were suitable and satisfy the need to identify and stabilize all these cavities. Further, their evaluation of the response of the foundation soil and cavity fill material to dynamic loading is conservative.
- 6. Exploration drilling, mechanical measurements and geophysical surveys were performed by SCE to identify and define the location and extent of
-3 each and every cavity at or near the site.1/ These standard geological investigating techniques for nuclear power plants are in conformance with and exceed the standard practice contained in Regulatory Guide 1.132 entitled "Site Investigations for Foundations of Nuclear Power Plants",
dated September 1977.
- 7. In the investigations of the twelve dewatering wells at the site, the most intensive effort was applied to wells 6, 7 and 8, the only cavities of sufficient size and proximity to the San Onofre units to have an impact on seismic category I structures. All other wells were free of large cavities.
- 8. Based on inspection of the Applicants reports and my own site investi gations, I found that grout was placed in cavities to fill any void spaces and provide some densification of the in-fill sand within the disturbed zone. Grouting was performed in stages on a grid pattern.
The water-cement ratio varied from 5:1 to 3/4:1 for the grout mixes used. Grout pressures were generally limited to one psi per foot of depth. These grouting procedures and the close spacing of the grout holes constitutes an intensive effort for the application of standard foundation treatment techniques and provide a great assurance that cavities have been filled. In addition, substantial efforts to verify the results of the grouting techniques have been provided in the Applicants' reports and reviewed by the Staff. The staff found these 1/ Two of the cavities in question are located offsite.
-4 procedures used by the Applicants to be adequate and the results have been satisfactorily documented.
- 9. The cavities at wells 6, 7 and 8 were evaluated to determine the effects on adjacent seismic category I structures. These structures included the Auxiliary Building, the Fuel Handling Buildings for Units 2 & 3 and the Unit 3 containment structure.-2 These evaluations were made by calculating the potential reduction in stiffness and support character istics of the foundation soil which would be caused by an increase in pore water pressure in an adjacent grouted cavity. These valuations were provided in a report titled "Report on the Results of Analyses Performed on Well 8 at the SONGS Units 2 and 3, San Onofre, California,"
which is reference number 7 in the Applicants' Motion for Summary Disposition.
This report provides analyses of the potential effects of seismic shaking on the cavity at Well 8, and the resulting potential effects on the adjacent structures. The results of the analyses for Well 8 were extrapolated to the Well 6 and 7 cavities. There are two basic elements to this report: (1) the evaluation of the generation and dissipation of, excess water pore pressure in the soil foundation during seismic loading; and (2) evaluation of the overall reduction in stiffness of the soil supporting the containment structure.. Two very conservative
/ Unit 1 structures and the Unit 2 containment building are located too far from the cavities to be affected by them.
-5 assumption were considered with respect to excess pore water pressure generation and dissipation. These assumptions were: (1) the geometry of the sand fill within the cavity at Well 8 is two-dimensional (plane strain or axisymmetric) and (2) the shortest drainage path beneath the containment structure is equal to the diameter of the basemat. The first assumption implies that the volume of the pore pressure generating source is much greater than the actual size of the cavity. For the axisymmetric case, which is considered to model the cavity size more realistically than that of the plane strain case, the volume of the cavity is calculated to be more than one order of magnitude larger than the actual cavity size. The second assumption increases time required for dissipation of excess pore pressures and overestimates pore pressure at any given time during periods of dissipation as compared to the actual field condition. Regarding the applicants' assessment of the generation and dissipation of excess pore pressure, although many assumptions are required in this analysis, for the reasons listed above, the analysis is a conservative estimate of design conditions.
The report concludes that the maximum effects on the Unit 3 containment building is a 4 to 5% reduction in overall soil stiffness, the effects of the cavity on settlement (less than a 1/10 inch increase) and bearing capacity of the containment structure are very small and will not affect the containment or other structures on site. Staff review of that report has shown that conclusion to be conservative.
-6
- 10.
In addition to the above structures, on electrical tunnel (described further in the Lipinski Affidavit, Attachment 2), passes over the Well 8 cavity and for that reason has been assessed by the applicants. The effect of the cavity on the tunnel was based on the assumption that the tunnel would be unsupported in the area of the cavity. The staff found that the applicants' analysis uses a conservative assumption for geotech nical engineering considerations for the tunnel. The reasons for this finding and the structural spanning capabilities of the tunnel are discussed by the Structural Engineering Branch in the affidavit of R. Lapinski (Attachment 2, infra.)
- 11.
For the reasons listed above, the staff finds that the applicants have performed acceptable geotechnical investigations, treatment and analyses to determine the extent of all the cavities existant at the site and to assess their potential impact on adjacent structures during seismic or other conditions.
fdohn T. Greeves I hereby certify that the information listed above is true and accurate to the best of my personal knowledge.
Personally appeared before me this f-day of August, 1980, was John T.
Greeves who swore that the information above is true and accurate to the best of his personal knowledge.
wy c U
YS
,EXPfRES JULY 1, tow
ATTACHMENT 2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
SOUTHERN CALIFORNIA EDISON COMPANY,
)
)
50-362 OL (San Onofre Nuclear Generating
)
Station, Units 2 and 3)
)
AFFIDAVIT OF ROMUALD E. LIPINSKI CONCERNING INTERVENOR CONTENTION 1(a) (DEWATERING WELLS)
- 1. I am currently a structural engineer, Office of Nuclear Reactor Regula tion of the U.S. Nuclear Regulatory Commission, (NRC). In my position I am responsible for review and evaluation of safety analysis reports with regard to structural and earthquake engineering aspects of nuclear power plants. A detailed resume of my professional qualifications is attached.
- 2. Southern California Edison Company (SCE) has identified and evaluated the dewatering wells which might have a potential effect on structures at SONGS 2 amd 3. Out of the twelve dewatering wells, wells 6, 7 and 8 have been identified as those which because of their size and proximity
,'to Category I structures, might be of concern.-/
The results of analysis well 8, the largest and most proximate well to seismic Class I structures, were extrapolated to wells 6 and 7.
1/ Two wells are located offsite.
-2 The information concerning the techniques used for investigation of the cavities has been reviewed by the Hydrology and Geotechnical Engi neering Branch (see Affidavit of John T. Greeves) and have been found acceptable. For my part, I reviewed the "Report on the Results of Analyses Performed on Well 8 at the SONGS Units 2 and 3, San Onofre, California" by Woodward-Clyde Consultants, August 25, 1980, and Enclo sure 4 to the letter from J. C. Haynes to Robert Baer, dated January 21, 1980, which contained Reanalysis of Electrical Cable Tunnel Structure, Proprietary and Confidential, dated December 27, 1979. (Reference 7 of the Applicants' Motion for Summary Disposition), as well as confirmatory calculations submitted on the electrical tunnel
- 3. Basically, the Applicants' analyses consisted of comparing the present stiffness of the soil, due to the cavity, to the stiffness of the original foundation material at the site.
The applicants determined that the maximum increase in settlement do decrease in stiffness.due to the cavity occurs at wells 7 and 8 and is about 8 percent at the fuel handling structure, Unit 3, and about 5 percent at the containment structure, Unit 3 (less than 1/10 inch).
- 4.
The effects of the cavity on the settlement of structures were also investigated by calculating the potential change in volume of the soil in well 8 beneath the containment structure due to the drainage of excess pore water pressures. Since the pore water pressure exerted by water occupying the voids in the soil is related to shear strength of
-3 the soil, by calculating volumetric changes in soil voids, its bearing capacity and hence the amount of settlement can be estimated.
The maximum settlement of the containment structure calculated this way was less than 1/10 inch.
- 5. Based on the foregoing, the applicants determined and the Staff con curred, that the only Category I structure which might be affected by the dewatering wells is the seismic Category I electrical tunnel struc ture which is located next to the containment base of Unit 3 and spanning across the cavity of well 8. The Bechtel Power Corporation analyzed the capability of the tunnel to span across the cavity for a distance of 25 feet. This electrical tunnel extends from the safety equipment building to the fuel handling building between the contain ment structure and the tank building and houses safety-related electri cal cables. It is 17'-0" high and 13'-0" wide on the outside dimensions; its roof and floor slabs are 2'-0" thick and the walls are l'-6".
- 6. In order to assess the width of the cavity, the analysis was performed using finite element method. In that analysis, soil and the structures were postulated as a combined system and the dynamic response of the soil-structure system was evaluated using the computer program FLUSH.
The model incorporated the Unit 3 containment structure, the tunnel structure, the grout and the soil filled cavity. The artificial time history of acceleration representing the postulated design basis earth quake (DBE) previously developed for SONGS 2 and 3 was used as the
-4 control motion for the response computations.
The control motion was specified at the finished grade of the plant site; a peak acceleration of 2/3g and total duration of 80 seconds was used.
- 7. The structural analysis of the tunnel was performed by the applicants and the major assumptions used are listed below:
- a. The stiffness of the foundation material was reduced to zero within the area where the ratio of pore pressure is greater than 0.3. The span of 25 feet, for the tunnel, was estimated on that basis.
- b. Combination of three components of seismic response was done using the method described in the NUREG/CR-0098, "Development of Criteria for Seismic Review of Selected Nuclear Power Plants" by N. M. Newmark Consulting Engineering Services, Urbana, Illinois, May 1978.
- c. The tunnel was assumed to behave as a box-type beam for flexural consideration. The change in cross-section has been disregarded.
- d. Seismic loading has been calculated using 1.5 times the peak response of the applicable response spectrum. The response spectra used are the same as those used for other Category I structures of the San Onofre Plant Units 2 and 3.
- 8. The analysis submitted by the applicants was reviewed by the Staff.
Although we agreed with the mechanics of the analysis, several questions were brought up regarding the basic assumptions. The most critical
-5 of these questions are with reference to assumptions (b), and (c) as listed above. The reasons for these questions are as follows:
- 1. With respect to assumptions (b), the calculations did not use the method approved by the Staff, i.e., SRSS. (Square root, sum of the squares) (SRP § 3.7.2). Consequently, the Staff felt that combination of the three-dimentional components of seismic motion should not be based entirely on these criteria.
In view of the above, the Staff could not confirm the correctness of the calcula tions, and for that reason the applicants were requested to perform a confirmatory analysis based on the criteria delineated in the Standard Review Plan, Section 3.7, in order to verify that the method used by the applicant to combine the three components of ground motion was conservative.
- 2. With respect to assumption (c), although we concur with the appli cants that the assumption that the tunnel has a uniform cross section will result in the lower foundamental frequency, which is the most significant because it results in the highest amplitude of vibratory motion and hence produces the highest stresses, we felt that the stresses in the area of discontinuity of the tunnel may be higher when the abrupt change in the cross-section is considered, and for this reason we believed that the actual con figuration of the tunnel should be investigated. This conclusion was based on the commonly accepted fact that a break in uniformity
-6 of the cross-section of a member produces "stress risers" and very often it becomes the critical section from the point of view of structural design. Furthermore, the analysis did not consider stresses due to longitudinal wave propagation.
- 9. In view of the above, we requested that applicants provide additional information which would verify that the analysis submitted for our review is conservative. In response to our request, the applicants demonstrated that the technique of combination of three components of seismic responses based on the NUREG/CR-0098 methodology is equivalent to square root of sum of squares (SRSS). They reanalyzed the tunnel for the condition with one end fixed and the other simply supported.
This condition does represent the tunnel framing into the gallery structure which would provide complete fixity due its mass. The appli cants also performed another analysis which accounted for the stresses due to longitudinal wave propagation. On the basis of the above, we concluded that the structural design of the tunnel is conservative and would not be adversely impacted by any of the dewatering well cavities.
- 10.
For the reasons listed above, the Staff finds that the applicants have adequately performed structural investigations and analyses which show that the cavities existing at the site will not have any adverse effect
-7 on the electrical tunnel or any other seismic Class I adjacent structures at SONGS 2 and 3.
Romuald E. Lipinski V
I hereby certify that the information listed above is true and accurate to the best of my personal knowledge.
Personally appeared before me this
/.5s'-day of August, 1980, was Romuald E.
1ipinski who swore that on his personal knowledge the information above is true and accurate.
N 0MSary S
E1ig iy/
M OOMMISSION EWIRM~.LULV 1, 16a
ROMUALD E. LIPINSKI PROFESSIONAL QUALIFICATIONS STRUCTURAL ENGINEERING BRANCH.
I am a Structural Engineer in the Structural Engineering Branch of Nuclear Regulatory Commission. I am responsible for the review and evaluation of adequacy of criteria used in the structural design and analysis of Seismic Category I structures, systems and components of nuclear power plants assigned to the branch.
I received a B.S. degree in Civil Engineering in 1957 and the degree of Master of Science in Civil Engineering in 1961, both from the Newark College of Engineering, Newark, N.J..
From 1954 to 1955 I worked-as a designer-draftsman on the design of highway bridges under the employment of the consulting fim of Proctor,.Urquhart and Beavin in Newark, N.J..
My duties were related to design and detailing of highway overpasses and checking shop draw ings. From 1955 to 1956 I worked as a designer in Ebasco, Inc.,
(4 months) and Parco Inc., both of New York, N.Y.. My duties were' in design, checking and detailing of various parts of chemical plants
- and hydro-electric power generating plants.
From 1956 to 1965 I was employed.by the Public Service Electric and Gas Co., Newark, N.J. as a structural designer. My assignments were in design and preparation of layout plans and detailing of various portions of conventional power.generating plants, switching stations and substations.
AS From 1965 to 1969 1 worked as a structural engineer for the Naval Facilities Engineering Command, Electronic Support Branch.
My duties consisted of reviewing structural designs and plans and preparation of designs and specifications of radio communication antennas.
My assignments involved also supervision of similar tasks performed by others related to design of communication facilities.
From 1969 to 1972 I was employed as a structural engineer by the U.S. Atomic Energy Connission, Di.visioon df Materials Li,_nsing.
My duties involved review of structural designs of shipping casks for transportation of irradiated fuel elements or other radioactive materials, From 1972 to'present I have been working as a member of Structural Engineering Branch.
In that capacity I have participated in devel oping criteria for structural design and analysis of seismic Cate gory I structures in nuclear power plants, performed evaluation of technical reports concerning structural behavior under various loading conditions and reviewed the safety analysis reports of nuclear power plants of Millstone Unit 2, Nine Mile Point, Davis Besse Unit 1, Beaver Valley Unit 1, Alvin W. Vogtle etc. In the areas relating to the design and analysis of seismiq Category I structures.
I am a member of the American Society of Civil Engineers, I am also a member of the ACI-ASME 359 Technical Comittee: on Concrete Pressure Components for Nuclear Service and I participated i.n the development of ACI Standard; Code Requirements for Nuclear Safety Related Concrete Structures (ACI-349).
I am a registered professional engineer in the states of New York and New Jersey and a.fallout shelter analyst certified by the Defense Civil Preparedness Agency.
I 1
t-
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of SOUTHERN CALIFORNIA EDISON COMPANY,
)
)
50-362 OL (San Onofre Nuclear Generating Station, )
Units 2 and 3)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF MOTION FOR
SUMMARY
DISPOSITION ON INTERVENORS' CONTENTION 9 (URANIUM PRICES)" and "NRC STAFF MOTION FOR
SUMMARY
DISPOSITION ON CONTENTION 1(a) (DEWATERING WELL CAVITIES)" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as-indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 15th day of August, 1980:
Ivan W. Smith, Esq., Chairman*
David R. Pigott, Esq.
Atomic Safety and Licensing Board Samuel B. Casey, Esq.
U. S. Nuclear Regulatory Commission Chickering & Gregory Washington, DC 20555 Three Embarcadero Center Dr. Cadet H. Hand, Jr., Member Twen ird Floor Director, Bodega Marine Laboratory University of California Alan R. Watts, Esq.
P. 0. Box 247 Rourke & Woodruff Bodega Bay, CA 94923 10555 North Main Street Suite 1020 Dr. Emmeth A. Luebke, Member Santa Ana, CA 92701 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Richard J. Wharton, Esq.
Washington, DC 20555 Wharton and Pogalies 2667 Camino Del Rio South Janice E. Kerr, Esq.
J. Calvin Simpson, Esq.
Suie 106 Lawrence Q. Garcia, Esq.
California Public Utilities Commission Mrs. Lyn Harris Hicks 5066 State Building GUARD San Francisco, CA 94102 3908 Calle Ariana San Clemente, CA 92672 Charles R. Kocher, General Counsel James A. Beoletto, Esq.
David W. Gilman Southern California Edison Company Robert G. Lacy 2244 Walnut Grove Avenue San Diego Gas Electric Co.
Rosemead, CA 91770 P.O. Box 1831 San Diego, CA 92112
-2 Phyllis M. Gallagher, Esq.
Atomic Safety and Licensing Board 1695 West Crescent Avenue Panel*
Suite 222 U.S. Nuclear Regulatory Comission Anaheim, CA 92701 Washington, DC 20555 A. S. Carstens Secretary 2071 Caminito Circulo Norte U.S. Nuclear Regulatory Commission Mt. La Jolla, CA 92037 ATTN:
Chief, Docketing & Service Branch Atomic Safety and Licensing Appeal Panel (5)*
U.S. Nuclear Regulatory Commission Washington, DC 20555