ML19323E490

Addl Comments on Intervenor 800507 Pleading Re Resumption of Work.Urges Commission to Consider Encl Affidavits Re Whether IE Should Have Confidence in QC Program & Whether New Madrid Seismic Zone Extension Should Be Made

ML19323E490
Person / Time
Site:	Marble Hill
Issue date:	05/14/1980
From:	Dattilo T DATTILO, T.M., SAVE THE VALLEY - SAVE MARBLE HILL
To:
Shared Package
ML19323E491	List: ML19323E490 ML19323E493 ML19323E498 ML19323E502 ML19323E506 ML19323E513 ML19323E517
References
NUDOCS 8005230601
Download: ML19323E490 (5)

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O MAY 141980 > :

BEFORE THE NUCLEAR REGULATORY COISIISSIONERS Dd CTse tA th CarDE & 3e:Aa IN RE THE PROPOSED MARBLE IIILL ) DOCKET IJOS. 50-546, 547

% -bk ifUCLEAR POWER PLANT, PUBLIC ) ' ' "" \ ~ /

SERVICE IllDIANA, LICEllSEE )

SAVE THE VALLEY ADDITIOtJAL COMMENTS TO CONfJISSIOITERS COliCERIIIfJG RESUI.iPTION OF WORK AT MARBLE HILL Comes now Save The Valley by its attorney, and states:

1. That on May 7, 1980, Save The Valley presented its comments regarding the consideration of the reopening of Mar.ble Hill.

2. That this pleading incorporates herein a 'nd makes a part hereof said May 7, 1980 comments.

3. That in response to a request of the Honorable Peter Bradford, a Commissioner of the flRC, regarding a Sassafras Audubon Society filing of September 1, 1979, and more particularly concerning " heavy fault" in the base of the ~ reactor containment building, Save The Valley presents the July 7, 1979 Affidavit of one Jewel W. Rogers, the Affidavit of one, Michael L. Walston dated July 8, 1978 and the Affidavit of one, Stanley J. Mortensen dated July 8, 1979; that said Jewel W. Rogers, Michael L. Walston and Stanley J. Mortensen were concrete finishers ac I arble Hill who exposed certain glaring concrete workmanship defects in and around containment and certain alleged improper attitudes of the flewberg-Marble Hill Construction Company; said Exhibits are entitled "1", "2" and "3".

THIS DOCUMENT CONTAINS POOR QUALITY PAGES 8 005 230 h0L G

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4. That further Save The Valley includes herein and makes a part hereof a copy of a certain Charles Edward Cutshall deposition of May 8 3 1979; please see Page 5, 'Line 22 through the end regarding

" water leaking ... at a fast rate", also see Page 18, Line 18 through i

the bottom regarding " patches as large as S... feet in square . ..,

that are patched in"; also see Page 19, Line 1 through end redarding observation of honeycombs; said sworn statement is entitled Exhibit "4".

5. Also find enclosed an Affidavit of James E. Henry, Jr. dated September 1, 1979, regarding United States Testing, one of the sub-contractors at Marble Hill, said Exhibit is entitled "S".

6. Find enclosed an Affidavit of Gary Huttsell regarding quality of concrete pores and entitled Exhibit "6".

7. That the remainder of the additional comments shall center upon the New Madrid Seismic Zone and the Wabash Valley Seismic Zone;

a. Earthquakes east of the Rocky Mountains differ from their western counterparts in being more perceptible and more damaging.

Eastern earthquakes may be 100 times more perceptible in terms of area.

effect. In effect, the ground shaking has a larger duration at distant points. Geology in the Siting of Nuclear Power Plants, The' Geological Society of America, 1979. . i.

Earthquakes in the center of the United States have received less attention than those in the West. Only in'the New Hadrid Seismic Zone is one able to delineate an active fault system.S Similar studies in

, e other areas should enable one to outline other active faults. Karble Hill is located at the northeastern edge of a l'arger damage cone of the 1811 I ew Madrid earthquake; magnitude - recurrence . curves (Page 88, Figure 3) show that almost as many earthquakes of similar magnitude Page 2. .

s occurred in three (3) months in the New Madrid Seismic Zone as in 40 years in Southern California. Geology In The Siting of Nuclear Power Plants.

f j b. During 1978 and 1979 seismic refraction experiments were carried out in Southeastern Illinois and Southwestern Indiana as part i

of an integrated geological - geophysical research program directed i

toward understanding the seismo-tectonics of the New Madrid Seismic Zone and its extenstion to the Northeast. Recent geophysical results from this program suggest that a basement structural feature extends from the New Madrid area Northeast across the 38th parallel structural feature and northeasterly into Indiana. The Wabash River Valley Fault Zone occurs along the Northwestern margin feature but at an angle to it.

Baldwin, J.L., Crustal Seismic Studies Related to the Northeast Extension of the New Madrid Seismic Zone; from Abstracts with Programs, North-Central Section of Geological Society of America, April 10, 11, 1980 Annual Meeting.

Essentially the New Madrid line runs from the Southeast corner of Mississippi and extends up' into Kentucky, Arkansas and Tennessee; the New Madrid extension according to the above Baldwin Survey may be quite close to Marble Hill and was not considered in the environmental hearing on Marble Hill.

In North-Central Kentucky near Harmony Landing and in Southeastern Indiana near the Charlestown, Indiana Powder Plant, there exists structurally deformed late ordovician to early silurian straca ( a considerable amount of crushed and cracked rock and soil deformation).

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4 Marble Hill lies approximately 13 miles from Harmony Landing, Kentucky and Charlestown, Indiana. Geological Society of America Bulletin, September, 1969, Volume 80, Page 1881.

Because of the New Madrid' Extension Seismic Zone and because of the crushed and cracked rock and soil deformation, it would seem that the earthquake possibilities at Marble Hill are greater than those i

stated in the environmental studies on Marble Hill.

Further studies would seem to be indicated from Mr. Baldwin who is' presently with the Department of Geoscienses at Purdue University in Lafayette, Indiana.

c. Dr. Stanley M. Totten, Professor of Geology at Hanover Collede in Hanover, Indiana, has granted this writer the right to include his relevant comment regarding the archaeologic'al strata located at Marble Hill; "One of my major concerns is what might happen. if radioactive fluids leak from the reactor containment build'ing. 'The fluid would enter cracks in the bedrock (at Marble Hill) and would flow laterally along the top of the shale and seep out along the river bluff as springs. The fluid would then flow down the steep slopes, soak into the gravel terrace near the river and probably reach the river itself.

Once the fluid became free of the containment building, it would be difficult if not impossible to recapture it."

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d. Dr. Totten specifically studied and observed the Charlestown, Indiana and Harmony Landing, Kentucky crushed rock, stone and soil deformation and believes said conditions to cause Marble Hill to be worthy of further seismic studies and believes said results may not ,

necessarily be the same as those made in the environmental findings of the IIRC at the time the original construction permit was granted.

WHEREFORE, the Petitioner respectfully requests the Commissioners to more fully examine the Affidavits and evidence herein to determine for themselves whether the NRC, Division of Inspection: and Enforcement should have confidence that the PSI Quality Control Program is properly rehabilitated, and secondly, whether or not there should be a further study made of the !!ew Madrid Seismic Zone Extension and its implications regarding Marble Hill.

RESPECTFULLY SUBMITTED, SAVE THE VALLEY e

BY: /* S-t % I/i y'IN, ..b THOMAS M. DATTILO, ATTORNEY FOR SAVE THE VALLEY THOMAS M. DATTILO -

ATTORNEY FOR SAVE THE VALLEY 311 EAST MAIN STREET

!!ADISON, INDIANA 47250 PHONE: 812-265-6355 Page 5.