ML19322E588
| ML19322E588 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 03/25/1980 |
| From: | Linder F DAIRYLAND POWER COOPERATIVE |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19322E589 | List: |
| References | |
| NUDOCS 8003280469 | |
| Download: ML19322E588 (12) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Director of the Office of Nuclear Reactor Regulation In the Matter of
)
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DAIRYLAND POWER COOPERATIVE
)
Docket No. 50-409
)
(Show Cause)
(La Crosse Boiling Water
)
Reactor)
)
LICENSEE'S ANSWER TO ORDER TO SHOW CAUSE Pursuant to 10 C.F.R.
S 2.02(b), Dairyland Power Cooperative (DPC or Dairyland), the holder of Provisional Operating License No. DPR-45 for the La Crosse Boiling Water Reactor (LACBWR) and the Licensee in the above-referenced proceeding, hereby submits its answer to the Order to Show Cause (Show Cause Order) issued by the Director of the Office of Nuclear Reactor Regulation on February 25, 1980, -1/ as follows:
1/
The Order specifically provides that "the licensee may file a written answer within twenty-five (25) days of the date of this Order."
Show Cause Order at 9.
- However, the Order was mailed to Dairyland.
Under NRC's Rules of Practice "whenever a party has the right or is required to s
take some act
. within a prescribed period after the E 't service of notice.
upon him.
. and the notice is y'.
%e s
served upon him by mail, five (5) days shall be added to o
the prescribed period."
10 C.F.R. 5 2.710.
This provision g g
governing the computation of time in NRC proceedings applies to show cause proceedings.
See 10 C.F.R. 5 2.700.
- Thus, Gr. g Ng Dairyland was not required to serve its nr.swer (i.e.,
3 deposit it in the U.S. mail (10 C.F.R. 5 2.712(d)(3)) until March 26, 1980.
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-2 1.
For the reasons outlined below and set forth in greater detail in the attached " Response To NRC Concerns On Liquefaction Potential At La Crosse Boiling Water Reactor (LACBWR) Site Near Genoa, Vernon County, Wisconsin," dated March 21, 1980, prepared for Dairyland by Dames & Moore in con-sultation with Dr. H. Bolton Seed (the D&M Response) and the references cited therein, Dairyland disagrees with the NRC Staff's assessment of the liquefaction potential of the soils at the LACBWR site under conditions of seismic stress.
Moreover, Dairyland emphatically disagrees wit'a the Staff's observation that a "potentially hazardous condition may exist at the LACBWR site with respect to continued operation of the plant for an extended 2/
period of time. " -
-2/
Show Cause Order at 6.
It should be noted that the NRC Staff also concluded that "the general level of seismd.c hazard at the LACBWR site is sufficiently low that opera-tion of the plant for the next twelve months would n:>t endanger the health and safety of the public" (Show Cause Order at 7).
Dairyland believes that the seismic hazard is so low that operation af the plant for a longer period of time would also "not et. danger the health and safety of the public."
In this regr.rd, the Director recently denied a petition requesting suspension of operation of LACBWR "to the extent that [the] petition requests suspension while the liquefaction issue is being resolved."
(emphasis added).
Dairyland Power Cooperacive (LACBWR),
DD-80-9 (Director's Decision Under 10 C.F.R. 5 2.206 at 10 (February 29, 1980)).
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-3 2.
Dairyland admits that the general discussion contained in Part II of the Show Cause Order adequately sum-marizes the events leading up to the issuance of the Show Cause Order, as well as the positions of the various parties involved in the analysis of the liquefaction issue.
- However, Dairyland denies each allegation, charge, and/or statement of fact contained in Part II to the extent that it is contrary to the information, data, and conclusions contained in the D&M Response.
3.
Dames & Moore submitted a report on September 28, 1979 which demonstrated that the " threshold liquefication resis-tance level for the LACBWR site corresponds to a Safe Shutdown Earthquake (SSE) producing an acceleration between 0.18g and 0.20g at the ground surface."
Based on its review of the soils data contained in this report, the Staff has concluded that if sustained strong ground motion with peak accelerations of.12g or higher occurs at the LACBWR site, liquefaction can occur down to a depth of 40 feet.
The Staff determined that the soil strength curves contained it. this D&M report, based on the ad-dicional soils samples taken by D&M pursuant to the NRC-approved soils properties investigation program designed to determine the resistance of the soils at the LACBW3 site to liquefaction, were 3/
"not adequately conservative." ~
The Staff then adjusted 3/
The bases for this conclusion appear to be the Staff's belief that Dames & Moore (a) did not properly account for the effects of soil densification during sampling and testing, and (b) incorrectly adjusted the N values (i.e., blow counts) from the Standard Penetration Test (SPT) for use in comparison with the empirical correlations between N values and lique-faction at a site in Japan.
Show Cause Order at 4-6.
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-4 downward the factors of safety against liquefaction which D&M had calculated.
This downward adjustment essentially forms the basis for the Show Cause Order.
4 However, neither the September 28 Report nor the NRC Staff's review of that report quantify, or adequately take into account in any other way, the fact that the safety factors against liquefaction which Dames & Moore had originally calculated should actually be increased due to the following considerations:
(a) the significant increase in density in the soils under the reactor due to the hundreds of closely spaced piles which were driven under-the reactor contain-ment vessel and throughout the site area; (b) the increase in the lateral coefficieint of earth pressure due to the driving of the piles themselves which also in-creases resistance to liquefaction; (c) the counterbalancing effects of structural disturbance and increase in densities of soil resulting from sampling, handling and testing; and (d) the D&M technique of minimizing friction by frequently oiling the rope and pulley while performing standard penetration tests which 5
L
-5 results in fewer blow counts when com-pared to the procedures normally used in compiling SPT data for the empirical approach.
5.
Accordingly, it is DPC's position (a) that the actual factors of safety against liquefaction under the contain-ment vessel at the LACBWR plant are significantly higher than those presented in the D&M report of September 28, 1979, in which calculations were made for free-field conditions, and (b) that the corrections which the NRC Staff made to the factors of safety presented in the report were inappropriate.
6.
In response to the Staff's specific concerns, any density changes which occurred during sampling, freezing, thawing, and consolidating the test specimens on which the September 28 Report was based are more than offset by the fact that these samples (obtained away from driven piles) are less dense by 3 to 6 lb/cu.ft. than the soils under the containment.
Moreover, the measured N values used in the September 28 Report should be upgraded to account for the presence of driven piles.
Using these upgraded N values in Dr. Seed's empirical approach for correlating N values with liquefaction occurence, it becomes evident that the soils under the containment vessel at the LACBWR site will not liquefy even upon the occurrence of a magnitude 7.5 earthquake, let alone the other extrapolated magnitude curves recommended by Dr. Seed.
Thus, it is Dairyland's position that it is entirely inappropriate and unnecessary to decrease the cyclic J
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-6 triaxial test strengths to account for the changes in densities pointed out by the NRC Staff or to use average N values.
The factors of safety identified in the September 28 Report and the D&M Response are valid and high enough to demonstrate that no measures are necessary to mitigate against the liquefaction potential associated with seismic conditions producing a peak ground acceleration of.12g at the LACBWR site.
7.
In any event, the Staff has itself concluded that the general level of seismic hazard is sufficiently low to permit continued operation of LACBWR.
This conclusion is based upon the Staff's determination that the return period for an earthquake resulting in a peak acceleration of.12 g "would be at least 1,000 years" and that "the actual return period could be an order of magnitude higher."
Show Cause Order at 6-7.
The LACBWR site is located in the Central Stable Region where historically the seismic activity is very low.
Using seismicity data developed by the TERA Corporation for Lawrance Livermore Laboratory and the NRC, in conjunction with a computer program designed to perform seismic risk analysis, Dames & Moore has determined that the return period for an earthquake of this size is at least 10,000 years and more likely between 10,000 and 100,000 years.
The seismic hazard perceived by the Staff is thus low enough to permit continued operation of LACBWR for the 4/
anticipated remaining life of the plant. -
4/
Dairyland's management recently approved plans to phase out the operation of LACBWR by 1990.
An amendment to the pending FTOL application which will reflect this development is now being prepared.
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-7 8.
To summarize the D&M Response, the results of extensive studies and analyses conducted during 1973, 1978, and 1979 pertaining to the geology, seismology, and lique-faction potential of the LACBWR site demonstrate that:
(a) the predicted SPT blow counts under the containment building are so high that there is no potential for liquefaction, even during a Magnitude 7.5 earthquake, using the empirical approach; (b) the estimated cyclic shear strength of the soil under the containment building is sufficiently high to provide an adequate factor of safety against the potential for liquefaction under a peak acceleration of
.12g, using the analysis-testing approach; (c) the soil conditions throughout the site are more or less uniform, and driven piles are present over much of the site area.
The SPT N values, the in-place densities, and the cyclic shear strengths of soils below pile-supported structures other than the containment building are also likely to be higher than the reported free-field values.
Thus, the overall mar-gin of safety against potential for lique-faction under an earthquake producing a
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-8 peak ground surface acceleration of
.12g at the LACBWR site is adequate.
(d)
Seismic activity in the vicinity of the LACBWR site is virtually non-existent. -5/
The SSE of Intensity VII corresponding to a peak ground surface acceleration of
.12g designated by the Staff for the LACBWR plant site is the result of a very conservative interpretation of the historical seismicity of the area within a 200-mile radius of the plant site; (e)
The seismic risk corresponding to the SSE producing.12g peak ground surface acceleration at the LACBWR site is extremely low.
The estimated return period of more than 10,000 years for such an event, when compared with the antici-paced remaining life of the plant, provides insufficient grounds for suspending opera-tion of LACBWR at any point during the next decade due to the liquefaction concerns identified by the NRC Staff.
-5/
As the Director himself noted in his recent Decision Under 10 C.F.R. 5 2.206 (see n. 2, supra), "The highest intensity near the site historically was estimated to be Intensity V due to the 1811-1812 New Madrid earthquake, 800 kilometers from the La Crosse site The site is not located near any known localizers of seismicity."- Director's Decision at 10.
-9 8.
For all the foregoing reasons, Dairyland believes that good cause exists as to why it should not be required to submit a detailed design proposal for a site dewatering system by May 27, 1980 and make such a system operational no larer than February 25, 1981.
9.
In the event that the Staff does not consider 4
this answer and the attached D&M Response to constitute suf-s ficient cause for not undertaking the steps outlined in the Show Cause Order concerning site dewatering, Dairyland specifi-cally requests a hearing on this matter.
Respectfully submitted, DAIRYLAND POWER COOPERATIVE Dated:
March 25, 1980 I
. rirNETEDt SFAN.. STOF.'J0 ERICA'.c NOGDAR. REstrLVlORW CDBMISSIOT s
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Director of the Office of Nuclear Reactor Regulation In the Matter of
)
)
DAIRYLAND POWER COOPERATIVE
)
Docket No. 50-409
)
(Show Cause)
(La Crosse Boiling Water
)
Reactor)
)
CERTIFICATE OF SERVICE Service has on this day been effected by personal delivery or first class mail on the following persons:
Charles Bechhoefer, Esq., Chrm.
Docketing & Service Section Atomic Safety and Licensing Office of the Secretary Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Atomic Safety and Licensing Mr. Ralph S. Decker Board Panel Rcute 4 U.S. Nuclear Regulatory Box 190D Commission Cambridge, Maryland 21613 Washington, D.C.
20555 Dr. George C. Anderson Atomic Safety and Licensing Department of Oceanography Appeal Board University of Washington U.S. Nuclear Regulatory Seattle, Washington 98195 Commission Washington, D.C.
20555 i
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-2 Colleen Woodhead, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Steve Burns, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Richard Shimshak Plant Superintendent Dairyland Power Cooperative La Crosse Boiling Water Reactor Genoa, Wisconsin 54632 Fritz Schubert, Esquire Staff Attorney Dairyland Power Cooperative 2615 East Avenue, South La Crosse, Wisconsin 54601 Coulee Region Energy Coalition P. O. Box 1583 La Crosse, Wisconsin 54601 Attn:
Anne Morse Mr. Harold Denton, Director Director of Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555
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O. S. Hiestand Dated:
March 25, 1980
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