ML19241A714
| ML19241A714 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/29/1979 |
| From: | William Ward MID-AMERICA COALITION FOR ENERGY ALTERNATIVES |
| To: | Bradford P, Gilinsky V, Hendrie J NRC COMMISSION (OCM) |
| References | |
| NUDOCS 7907090321 | |
| Download: ML19241A714 (6) | |
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Mid-America Coalition For Energy Alternatives
$130 Mi&SION ROAC SN.ketNIE adl1SION MS 64105 1913)3e2 5932 June 29, 1979 Joseph Hendrie, Chairman Peter Brad ford, Commi.s s i.oner Vi.c tor G i.1i.ns ky, Commi.s s i.oner Richard Kennedy, Commi.s s i.oner John Aherne, Comnissi.oner U.S.
Nuclear Regulatory Commi.ssion iashington, D.C.
20555
Dear Commissi.oners:
I wrote you on January 19, 1979, on behalf of my client aski.ng that you suspend the constructi.on permit for the Wolf Creek project in vi.ew of documented quali ty control problems specifi.cally related to the base mat of the reactor contai.nment bu ild i.ng.
You responded by publi.shing a noti.ce of our request i.n the Federal Regi. ster.
Thi.s letter i.s to advise of certain new determinations wi.th respect to the sei.smi.c character c" the area and to renew our request for at least a partial suspensi.on of the constructi.on permi.t in vi.ew of the si.gni.fi.cance of those determinati.ons i.n conjuncti.on wi.th exi.sti.ng unresolved i.ssues r egar d i.nt; base mat int egr i.ty.
Your attenti.on is directed to a report of the Kansas State GeoloBi. cal Survey (KSGS) prepared under contract to vour Di.vtsi.on of Reactor Safety Research, Of fi.ce of Nuclear 9 2gulatory Research, enti cled " A Revi. sed and Augmented Li.st of Earthquake Intensi.ti.es for Kansas, 1367-1977" NB EG /CR -
0294, August, 1973.
The report detai.ls the conclusi.on of the KSGS that the largest hi.storical earthquake i.n Kansas occurred at a di.fferent location and was of a different magni.tude than had been previ.ously beli.eved.
Thi.s earthquake was used as the basi.s for the design of the non-standardi zed Category I (safety related) portions of the plant.
Commonly known as the 1867 Manhattan earthquake and thou6ht to have been o f the sizo Modi.fi.ed Mercalli. VII, i.ts epi center was assumed to have been approx 1.mately 22 miles northwest of
\\lanhattan, isans as.
The appilcants argued that the earthquake was related to a presumed " zone of weakness" asscci.ated with the contact of the Keween
'an mafi.c volcanic belt and the Nemaha Ridge (Nemaha Upli.ft).
The nearest b
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NRC Commissioners -- 2 approach of the zone, according to the SNUPPS PSAR Wolf Creek Addendum, is 75 miles from the ;!alf Creek site.
On
' asis the applicants urged the adoption of a safe that shutdown earthquake (SSE) with a.10g horizontal acceleration.
Finding insufficient basis for the applicants' assumption that the earthquake was related to such a zone of weakness, your staff apparently insisted that the SSE be based on the assamption that the 1967 >lanhattan earthquake could occur on the Nemaha Ridge at its closest approach to the Wolf Creek site, 50 miles.
Such an assumption would, concluded the staff, yield a safe shutdown earthquake of.12g, and the site was licensed accordingly.
In light of the new information developed by the KSGS concerning the size of the 1867 earthquake and the actual location of its epicenter, and recent microseismicity recorded along the long inactive Humbolt Fault, the postulated.12g horizontal acceleration safe shutdown earthquake does not now appear to be conservative.
The KSGS report concludes, on the basis of extensive review of historical records, that the 1867
">1anhattan" earthquake was at least a Modified >!ercalli VII-VIII
-- stronger than the SDI VII that both applicants and staff had assumed.
It concluded also that its epicenter was in the Wamego vicinity, and was, accordingly, associated with the Humbolt Fault.
The Humbolt Fault defines the eastern boundary of the Nemaha Ridge and passes eithin 50 miles of the Wolf Creek site.
In addition, since January, 1978, numerous microearthquakes have occurred along the trace of the Humbolt Fault north of the Wolf Creek site and south in Oklahoma.
Whtle the KSGS has not yet concluded that this means stress is building in the vicinity of the nearest approach of the fault to the plant site, they site success ful earthquake prediction experience elsewhere in the country which indicates that such is often the case.
The size of the appropriate safe shutdown arthquake for the Wolf Creek site can be determined by reference to your staff's Safety Evaluation Report for another of the SNUPPS units, Tyrone.
Both Tyrone, in Wisconsin, and Wolf Creek are located in the Central Stable Region Tectonic Province.
The following Tyrone SER discussion elucidates the reason for setting the Tyrone SSE at.2g horizontal acceleration:
" Based on historical accounts, the area of :he Central Stable Region in which the Tyrone site is located is seismically very quiet.
No historical earthquakes have been reported within 100 miles of the site, and only ten earthquakes of intensity >D1 IV or greater have been reported within 200 miles of the site.
The nearest historical earthquake in the vic tnity of the Tyrone site, which occurred sometime between 1865 and 1370, had an estimatedk
NRC Commissioners -- 3 intensity >DI VI-VII and occurred slightly more than 100 miles west of the site. "The Slidcontinent Geophysical Anomaly is located approximately 45 miles northwest of the Tyrone site. This feature corresponds to a region characterized by gravity and magnetic anomalies, which over much of its extent, coincide with mapped basement faulting. The Slidcontinent Geophysical Anomaly extends generally from the Lake Superior region south-west through Slinnesota, across Iowa, and into Kansas where it trends i.nto the Nemaha Uplift. The largest historical earthquakes which have been located along this feature have had reported epicentral intens ttles of SD1 VIII. However, as has been noted above, the characteristics associated with at least one of these intensity 3D1 VIII events, the Keewenaw Peninsula earthquake of 1906, would indicate that the intensity level may have been influenced by local geology. If it is assumed that an intensity FBI VIII earthquake could occur on structures associated with the Slidcontinent Geophysical Anomaly at its closest approach to the site; i.e. 45 miles, the intensity at the site due to attenuation would be reduced to intensity >DI VII-VIII. "In 1954 Neumann developed an empirical relationship between earthquake intensity and ground acceleration. 31 ore recently Trifunac and Brady (1975) have published a relation between intensity and acceleration whiob was developed using many additional observations. Trifunac and Brady's data essentially corroborate the relationship published by Neumann. Uttliaing either the Neumann or the Trifunac-Brady relation between intensity and acceleration, the mean acceleration corresponding to intensity 3D1 VII-VIII is 0.2g. Based on this analysis we consider 0.2g to be the appropriate acceleration for the seismic design of the proposed plant at the Tyrone site." pp. 2-16, 17, 18 With respect to the base mat of the Wolf Creek reactor butiding, the significance of setting the safe sLutdown earthquake at.2g horizontal acceleration is substantial. Your staf f has been unable tc donclude that the 90-day concrete cylinder tests, w ich showed that the base mat concrete failed to meet the des tnn specification of 5000 pourds per square inch, were in error. Accordingly, it ordered the applicants, who carry the burden of proof on all 309 115
NRC Commissioners -- 4 such matters, to show thtt the concrete is of sufficient strength, on the basis thmt the 90-day tests are assumed to be accurate. The Wolf Creek architect / engineer, the Bechtel Power Corporation, performed the reanalysis by first determining that actual concrete strength as shown by the 90-day tests was 4460 pounds per square inch (by working backward from the acceptance cri.teria) and then by performing computer simulations to show that the base mat was adequate at that strength to permi.t the safe shutdown of the plant even if it is subjected to a horizontal acceleration of.2g -- greater than the.12g earthquake for which, as noted above, the Wolf Creek site is licensed. The standardized portion of all SNUPPS plants must be built to be shut down safely after a.2g earthquake. The Bechtel Report notes that this safe shutdown earthquake is " controlled by a site other than Wolf Creek", but does not specify which one. The Report states that the use in the reanalysis of the greater than required.2g assumption "is consi. stent with the general methodology used for the project, is in accordance with the commitments made in PSAR Section
- 3. 7 and provides additional conservatism. " " Seismic loads were conservatively determined at the SNUPPS envelope "g" level, which is considerably higher than that for which the site is licensed", states the Report in its conclusion.
We submit that the reanalysis was, for the reasons discussed above, not conservati.ve -- that the Bechtel Report shows, if it is valid, only that the base mat is not expected to crack during the largest probable earthquake, if the concrete undorenes no doterioration. However, no allowance i.s made in the Bechtel Report for normal deterioration of the base mat due to routine plant operati.on. In addition, evi.dence t sts that the base mat concrete is presently undergoin6 spontaneous deterioration due to some as yet unknown cause. As you are aware, some of the 90-day test results were lower than the 28-day test results. Unless the reason for this anomaly is explained, it constitutes evidence that deterioration is taking place -- evidence which, under your agency's rules, it is the responsibility of the applicants to refute. Yet, on June 7, 1979, your staff issued a summary of the public meeting held.1n Burlington, Kansas on May 15, 1979, to review with the applicants the Bechtel Report and the base mat problem generally, a principal conclusion of which was-. "1. There is no clear cut answer as to why some of the 90-day cylinder test results are lower than 3000 pcunds per square inch. Neither is there a cleo cut answer as to why some of the 90-day strength res$"lts 309 116
5 NRC Commissioners are lower than those obtained with the 23-day cylinders." Je understand thc. your staff has now enli.sted the technical services o f the U.S. Army Corps of Engineers in an effort to illuminate the deterioration issue, and that several factors and combinations of factors are being investigated. We are aware of one such possibility, which we communicated to your staff two months ago. It involves the possible presence of opaline in the aggregate portion of the concrete mixture. Opaline has, after numerous investigations, been determined to be Lesponsi.ble for the unusual phenomenon attending concrete made ui.th river sand aggregate taken from northern Kansas rivers, including the Kaw, or Kansas, River: the concrete tends to expand and weaken over time, although this effect is seemingly somewhat unpredictable. It is our understanding that the source of the fine aggregate for the Wolf Creek base mat was originally to have been a limestone quarry near Ottawa, Kansas, operated by the Haworth Company, but that Daniels, the Wolf Creek general contractor, with the assumed knowledge of the applicants, changed the source to Kaw River sand, to be suppli.ed by Holi. day Sand and Gravel of Bonner Spri.ne;s, Kansas. The change precipi.tated a lawsuit by Holi. day, whi.ch i.s pending in Coffey County. He do not know that your staff has addressed this. Accordingly, we inquire whether the ultimate source of the aggregate was properly approved by your staf f and whether the presence of opaline aggregate has been determined and evaluated for its si nificance to the deterioration issue. 6 In sum, (1) the largest historical earthquake in Kansas was bigger than your staff and the applicants were aware and took place on a fault which passes 50 miles from the plant s i. t e, atich is only now known to be active, and whi.ch may be developing a "sei.smic gan" in the vicini.ty of the nearest approach to the planr,(2) no evidence exi.sts that the base mat euuld survive such an earthquake after a period of wear and tear due to normal plant operations, or at anv time if spontaneous deterioration is taking place, and (3) evidence that such deterioration is taking place exists. It is therefore imperative that those maki.ng decisions about the Wolf Cre~ek project know all that can possibly be known about the nature of the concrete i.n the base mat. .ie ask that you provide us a complete explanation of all the steps taken by you, otaer governmental agencies, the applicants or their agents to determine whether deterioration of the base mat can be expected. F i.na lly, we ask that you take action on our petition of January 19, 1979, concerning the Wolf Creek construction 309 1I7
NRC Commissioners -- 6 permit. It is your staf f's position, expressed repeatedly, that the applicants' decision, without staff authorization, to remove the voluntary " hold" placed on construction of the containment building, would cause the staff to seek an immediate order frcm you, which they expect would be granted, requiring that such work be stopped. In fact, a vice-president bf applicant KG&E advised your staff in writing at the time of the May 15, 1979 Eurlington meeting that they indended to resume concrete placement in the reactor containment building within a few days. It is our understanding that " jawboning" by your staff dissuaded them. It remains our position that a partial construction permit suspension is the only effective way for your agency to protect the public interest in this situation, and we hereby renew our request that you act accordingly. V 'O sincp
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// / / 'bg4rv L. William H. Ward Attorney for MACEA WHN:bw cc: Domenic Vassallo, NRC Roger Boyd, NRC t/ Olin Parr, NRC Carl Seyfrit, NRC H. D. Thornburg, NRC Stephen H. Lewis, Esq., NRC S. J. Chilk, Secretary, NRC Jay E. Silberg, Esq. Kansas Congressional Delegation 3Oh}}