ML19242D482
| ML19242D482 | |
| 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 7908150298 | |
| Download: ML19242D482 (6) | |
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x Mid-America Coalition For Energy Alternatives
$130 MitSION RO AD SMawNrg sal 15 0N R$ et105 69931382 S932
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June 29, 1979
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Joseph Hendrie, Chairman
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Peter Erad ford, Co = issi.oner t-Vi.c tor G i.] insi ", Cc:r.i.ss toner
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. '. i F-Richard Kenwd:, Commi.ssioner
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achn Aherne, Commissi.cner 1
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D.C. 20555~ Commi.ssion 3
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ES U.S.
Nuclear Regulators
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-ei Dear Commi.ssioners'.
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.14-I wrote vou on January 19, 1979, on behalf o f m:. client askirg that vou suspend the constructi.on permit for the
'iolf Creek project in vi.ew of documented qualtt" control probims spectrically related to the base mat of the reactor contat..ent bu i. ld i n g.
You responded b.
publishing a notice 0: our request in the Federal Register.
This letter i.s to advise o f certain new determinations wi.th respect to the seismic character of the area and to renew our request for at least a parti.al sus pens i.o: of the constructi.on permit in VLew of the si.gni.ficance of those deterninations in conjunction with existing enresolved i.ssues rerardi.ng base mat integrity.
Your attenti.on is directed to a report of the Kansas State Geological Survey (KSGS) prepared under contract to cour Di.vi_s i.on c f Reac tor Sa fety Tesearch, Office of Nuclear
,ee :lator-Research, e nt i.t led "A Rovised and Aucmented,,Li.st
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s.,m..,. -tu/ed-o: tartaqua,e.intenstttes :or k.ansas, 1
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4 0294, Aug st, 1973.
The report detai.ls the concluston of the KSGS that tho largest historical earthquake in Kansas
- ccurred at a different location and tas of a d i f fer en t m cti. rude than had been oreviousl:, bel aved.
This earthquake as 2 sed as the basis for the des tqn o f the non -s tanda-d i.c e!
Catecorv I (safety related) co r t i.o ns of the plant.
C o m.o n i_.
e wn as the '. 36 7 Manhat n ear thquake and thougn: to are beer o f the size Mcdtited Mercalli. VII, i. t s eni. center was assumed to have beea approximately 22 miles northwest of Manhat' an, Kansas.
The applicants argued t' at the earthquake wGb related to a presumed " Zone o[ deakness" aSScci.ated with ti - Contact o l' the KeWeenaw.in
".a fiC.olcan._c belt and the.s O'.aha R idge (Ne%ha C s tft>
ihe nurest uy%m r,'
1908150u3 m3 ~-
FE0r
r NRC Commi.ssi.oners --2 approach o f the zone, accordi.ng to the SNUPPS PSAR Wolf Creek Addendum, i. s 75 mi.les from the Wolf Creek site.
On that Dasi.s the appli. cants urged the adopti.on of a safe shutdown earthquake (SSE) wi.th a. log hori.zontal accelerati.on.
Fi.nd i.ng insu f fi.cien t bas i.s for the appli. cants' assumpti.on that the earthquake was related to such a zone of weakness,
/ cur staff apparently i.ns i.s ted that the SSE be based on the assumpti.on that the 1967 Manhattan ear thquake could occur on the Nemaha Ri.dge at i.ts closest approach to the Wolf Creek s i. t e, 50 mi.les.
Such an assumpti.on would, concluded the staff, yi. eld a safe shutdown earthquake of.12g, and the si.te was li. censed accordi.ngly.
In li.ght of the new i.nformati.on developed by the KSGS concerning the si.ze of the 1367 earthquake and the actual location of its e pi.c en ter, and recent mi.crosei.smi.c i.ty recorded along the long i.nacti.ve Humbolt Fault, the postulated.12g hori.zontal accelerati.on safe shutdown earthquake does not now appear to be conservati.ve.
The KSGS report concludas, on the bas i.s o f extens i.ve revi.ew o f hi.s tori. cal record s, that the 1367
" Manhattan" earthquake was at laast a Modifi.ed Nercalli. VII-VIII
-- stronger than the 91 VII that both appli. cants and staff had assumed.
It concluded also that i.t s epicenter was in the Wamego v i.c i n i. ty, and was, accordingly, associ.ated with the Humbolt Fault.
The Humboit Fault d e fi.ne s the eastern boundary of the Nemaha Ridge and passes v;i.thi.n 50 mi.les of the iolf Creek site.
In addi. tion, since January, 1973, numerous mi.croearthquakes have occurred along the trace of the Humbolt Fault north of the Wolf Creek site and scuth i.n Oklahoma.
cibi.le the KSGS has not yet concluded that thi.s means stress is building i.n the vi.cini.ty of the nearest approach of the fault to the plan: s i.t e, they s ite success ful earthquake predi.cti.on experience elsewhere i.n the country which indicates that such i.s often the case.
The si.ze of the aopropri. ate safe shutdown earthquake for the Wolf Creek si.te can be determi.ned by reference to four staff's Safet> Evaluati.on R >por t for another of the SNCPPS u n i. t s, Tyrone.
Both Tyrone, i.n W i.sc ens i.n, and Wolf Creek are located i.n the Central Stable Regi.on Tectoni.c Province.
The followi.ng Tyrone SER discussi.on eluci. dates the reason for setting the Tyrone SSE at.2g hori.zontal acceleration:
" Based on hi.stori. cal accounts. the area of the Central Stable Region in whi.c!' che Tyrone _ i. t e i. s located i.s sei.smi.cally very quiet.
No histori.cc.1 earthquakes have been reported withi.n 100 miles of the site, and only ten earthquakes of i.ntensi.ty 'M IV or greater have been reported wtthin 200 miles of the site.
The nearest histori. cal earthquake i. n the vi.c i.ni.ty o f the Tyrone s i.te, whi.ch occurred someti.me between 1365 and 1370, had an esti.cated y
NRC Commi_ssi.oners -- 3 i.ntensi_ty >D1 VI-VII and occurred sli.ghtly more than 100 mi.les west of the stte.
"The Midconti.nent Geophysi_ cal Anoualy i.s located approxi.mately 45 mi.les northwest o f the Tyrone s i.te.
This feature corresponds to a regi.on characteri_ zed by gravity and magneti c anomali.es, whi.ch over mucn o f i.t s extent, coi.nci.de wi.th mapped basement f au l t i.n g.
The Slic'conti.nent Geophysi_ cal Anomaly extends generally from the Lake Superi.or region south-west through sli.nnes o ta, across Icaa, and i_nto Kansas where it trends i_nto the Nemaha Upli.ft.
The largest h i.s t or i.c al earthquakes which have been located along thi.s feature have had reported epi _ central i.ntensi. ties of 3D1 VIII.
However, as has been noted above, the characteri_stics associ.ated wi.th at least one of these i.ntensi.ty 3D1 VIII events, the Keewenaw Peni.nsula earthquake of 1906, would i.ndi.cate thet the i.ntensity level may have been influenced by local geolo6y.
I f i.t i.s assumed that an i.ntensi.ty >D1 VIII earthquake could occur on structures associated wi.th the Mi_dcontinent Geophysical Anomaly at its closest approach to the s L t r. ; i.. e. 4 5 m i_ l e s, the i_ntens i t>
at the si.te due to attenuati.on would be reduced to intensi_ty >D1 VII-VIII.
"In 19 54 Neumann developed an empi.rical relationship between earthquake i.ntensi.ty and ground accelerati.cn.
More recently Tri.funac and Brady (1975) have publi_shed a relati.on between intensi ty and accelerati_on whi.ch was developed usi.nq many addi.ti.cnal observati.ons.
Tri.funac and Brady's data es senti. ally corroborate the relati.onship publi.Shed by Neumann.
U t i. li.z ine; either the Neumann or the Tri.funac-Brady r e la t i_ o n between i.ntensi.ty and accelerati.on, the mean acceleration correspondi_ng to i.ntens i.ty 3S1 V C 1 -VIII i. s 0.2g.
Based on this analysi_s t;e consi. der 0.2g to be the appropri. ate accelerati.on for the sei.smic design of the proposed plant at the Tyrone site."
pp. 2-16, 17, 13 With respect to the base mat of the Wolf Creek reactor building, the si.gni.fi.cance o f setti ng tha safe shutdown earthquake at.2c hori.zontal accelerati.on i.s substantial.
Your staf f has been unable to donclude that the 90-day concrete cyli.nder tests, which showed that the base mat concrete fai. led to.aeet the des i, n s pec i.fi.ca t i.on of 5000 nounds per square i. n cl i. were in ;rror.
Acc ord i.ngly, it ordered the appli. cants, who carry the burden of proof on all 60b"4 3
NRC Conmi.ssioners -- 4 such matters, to show that the concrete i.s o f su f fi.c i.ent strength, on the basis that the ")-day tests mre assumed to be accurate.
The Wolf Creek archi.tect/engi.neer, the Bechtel Power Corporati.on, performed the reanalysts 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 per for mi.ng computer simulati.cns to show that the base mat was adequate at that strength to permi.t the safe shutdown of the plant even i f i.t i.s subjected to a horizontal acceleration of.2g -- greater than the.12g earthquake for whi.ch, as noted above, the Wolf Creek si.te i.s li.c ens ed.
The s tandardi. zed porti.on o f all SNUPPS plants
.ust be bu i. lt to be shut down safely after a.2g earthquake.
The Bochtel Report notes that thi.s safe shutdown earthquake i.s
" controlled by a si.te other than Wolf Creek", but ooes not s pec i.f; whi.ch one.
The Report states that the use i.n the reanalysi.d of the greater than required.2g assumption "i.s consistent with the general methodology used for the project,
- i. s in accordance wi.th the commi.tments made i.n PS AR Sec ti.on 3.7 and provi. des addi.ttonal conservatism." " S e i. s m i.c loads were conservatively determined at the SNUPPS envelope "g" level, which is consi.derably hicher than that for which the si.te ts 1Lcensed", scates the Report i.n i. t s c o nc lu s i.o n.
'J e submi.t that the reanalysts was, for the reasons di.scussed above, nor conservative -- that the Bechtel Report shows,
- i. E i. t is valid, only that the base mat i. s not expected to crack during the largest probable earthquake, i '- rhe concrote i md m orm no d-n rioration.
Howe /er, no allowance is "ade in the Bechtel Report for nornal deterioration o f the base mat due to rcuti.ne plant operation.
In addition, ev i.d e nc e ex i.s t s that tLe base mat concrete i. s presently undergoi.ng spontaneous deteriorati.on due to so;ne as.et unknown cause.
As you are aware, some of the 90-day test results were lower than the 23-day test re su l. t s.
Unless the reason f;.
t h i. s anomaly is explai.ned, it constitutes evidence that deteriorati.on is taki.ng place -- evi.dence which, under vcur agency's r'iles, it i. s the responsiblitt) of the appli. cants to refute.
ht, on June 7,
'.979, your staff ssued a summary o f the cubli.c meeti.ng held i.n Burli.n.; ton, Kansas on '!ay 15, 1979, to revi.en wi.th the appli. cants the Bechtel Report and the base mat problem generally, a ari.ncipal conclusion of which was<.
"1.
There i. s no clear cut answer as to w!"
some of the 90-da:. 71iMer test r.sults ir e lower th.n 5000 counds per square tnch.
htcher i. s there a c aar cut answer as to
- h' some of tite 90-day strength resulta gs;
NRC Commi.s s i.oners -- 5 are lower than those obtai.ned wi.th the 23-day cyli nders. "
We understand tnat your staff has now onli.sted the technical servi.ces o f the U.S. Ar:.m Corps of Engineers i_n an ef fort to i_lluminate the deteriorati.on i.ssue, and that several factors and combi nati_ons of factors are sei.ng investi. gated.
We are aware of one such possibili ty, whi.ch we communicated t_o your staf f two months ago.
It i.nvolves the possi.ble presence o f opali.no i.n the aggregate porti.on of the concrete mi.xture.
Opaline has, after numerous investigations, boen determined to be respansi.ble for the unusual phunamenon attendi.ng concrete made ui.th ri.ver sand ay,regate taken from northern Kansas r i.v e r s, i.nc lud i_ng the Kaw, or hansas, R iver s the concrete tends to expand and weaken over ti_me, although this effect is seemingly some'; hat unpredictable.
It is our understandi.ng that the source of the fi.ne aggregate for the Wolf Creek base mat crictnally to have been a li.mestone quarry near Ottawa, was Kansas, operated by the Paworth Company, but that Dan i.e ls, the ciolf Creek general contractor, wi.th the assumed knowledge of the tpplicants, changed the source to Kaw Ri.ver sand, to be suppli_ed by Holi_da:. Sand and Gravel of Bonner Scri.ngs, Kansas.
The chance preci.pi.tated a lawsui.: by do l i.d ay, which is pendi.ng i.n Coffe> County.
.le do not c.;ow that your s taTf has address ed thi_s.
Accordi.ngly, we i.nquire whether the ulti. mate source of the aggregate was properly approved by four staff and whether the presence of opali.ne aggregate has been determined 2nd evaluated for its s i.gni.fi.cance to the deteri_ oration i.ssue.
In sum, (1) the largest hi.stori. cal earthquake i.n Kansas was bi ger than your staf f and the applicants were aware and took place on a fault which passes 50 miles from the plant s i_ t e, whi.ch i_ s o n i; now Known to be active, and whi.ch may be developi.ng a "seismi.c gap" in the vi.c i.ni.ty of the aeares t approach to the plant, (2) no evi. ience ex ts ts that the base mat could survive such an earthquake af ter a period of.iear and tear due to normal plant o per at i.on s, or at a n'.
t i me i. f s pontaneous deteri.orati.on i.s taki.ng place, and (3) evi.dence that such deteri. oration is taki.ng place exi.sts.
It ts therefore imperative that those maki.ng deci.si.ons about the ciolf Cre' k e
project know all that can oossi.bif be snown about the nature of the concrete in the base mat.
ile ask that cou nrovi.de us a complete explanati_on of all the steps takon by jou, otner governmental agencies, the appli. cants or thei.r agents to deterni.no whether deteri.orati_on o f the ba se.nat can be expe'ted.
Fi.r. ally, we ask that you take acti.on on our peti.ti.on of January 19, 1979, concerni.ng the Wolf Creek construction g
m._. %,
NRL Commissioners
--6 permit.
It is your staf f's position, expressed repeatedly, that the app 1Leants' 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 from 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 ne May 15, 1979 Burlington meeting that they indended to "ne concrete placement in the reactor containment building
.. thin a few days.
It is our understandi.ng that " jawboning" by your staf f dissuaded them.
It remains our position that a partial construction permit suspension is the only effective way for your agency to protect the publi.c interest in this s i.tu a t ion, and we hereby renew our request that you act accord ing ly.
Vr,y sincc-roy,, urs,
[
,; 4 f - Le I'c William H. '. lard Attorney for MACEA WHN:bw cc: Domenic Vassallo, NRC Roger Boyd, NRC Olin Parr, ':R C Carl Seyfrit, NRC H.
D. Thornburg, NRC Stephen H. Lewis, Esq., NRC S. J. Chilk, Secretary, NRC v' Jay E. Silberg, Esq.
';ansas Congressional Delegati.on G90222