ML19345D992
| ML19345D992 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 12/09/1980 |
| From: | Greeves J Office of Nuclear Reactor Regulation |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19345D986 | List: |
| References | |
| NUDOCS 8012220335 | |
| Download: ML19345D992 (5) | |
Text
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O NUCLEAR REGULATORY COMMISSION UNITED STATES OF AMERICA BEFORE THE AT0"IC SAFETY AND LICENSING BOARD In the Matter of DAIRYLAND POWER COOPERATIVE
)
Docket No. 50-409-SC
.l (La Crosse Boiling Water Reactor)
)
(Order to Show Cause)
AFFIDAVIT OF JOHN T. GREEVES I, John T. Greeves, do hereby depose and state:
I am a Geotechnical Engineer employed by the Nuclear Regulatory Commission in the Hydrologic and G;Jtechnical Engineering Branch of the Division of Engineering in the Office of Nuclear Reactor Regulation.
I have been employe'd by the NRC since 1974 A statement of my professional qualifications are j
attached to this affidavit.
I have reviewed the Motion for Summary Disposition and the Statement of Material Facts As to Which There Is No Genuine Issue to t
Be Heard submitted by Dairyland Power Cooperative in this proceeding on Novem-ber 14,1980.
I have also reviewed the Affidavits of Mysore S. Nataraja and John D. Parkyn attached to the Motion.
It is my opinion that reasonable i
assurance exists that liquefaction will not occur beneath pile supported structures in the event of an earthquake up to maanitude 5.5 with a peak ground accelera-l l
tion of 0.129 or less, and in this event a dewatering system is not necessary.
I I agree with most of the statements made in the Licensee's Motion for Summary Disposition to the extent that they support the above conclusion.
Upon reading i
l the Licensee's Motion for Summary Disposition, I believe the following points need to be clarified.
1 I
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. d 1.
The Licensee does not state the magnitude of the event considered. My review, and the conclusions reached, as stated in my affidavit submitted with the Staff's Motion for Sumnary Disposition, considered events up to magnitude 5.5.
2.
The Licensee repeatedly refers to other key structures.
It is not always clear what structures it is referring to. My conclusions refer only to pile supported structures at the LACBWR site as identified in my previous affidavit.
3.
Under DISCUSSION on page 6 of its Motion for Sumary Disposition, the Licensee characterizes the conclusion of the December,1978 WES report in a manner with which I would not agree. The WES Report indicated that the soils are predicted to strain badly under an earthquake producing a peak ground level acceleration of.129 and are predicted to experience excessive strains and liquefaction under an earthquake producing a peak ground level i
acceleration of 0.29 4.
The Licensee mentions the Genoa-3 stack and provides its conclusions re-garding impact on LACBWR. A fonnal report on the Genoa-3 stack has just l
been submitted to the NRC for review.
I have not yet received a copy of this report for review and I cannot agree or disagree with any conclusions the Licensee makes regarding the Genoa-3 stack in its summary disposition motion until I have completed a review of this report.
5.
An evaluation of the need for dewatering at LACBWR does not involve con-sideration of the Genoa-3 stack.
l l
l l
l 6.
WES findings and conclusions are based on their independent studies.
WES findings and conclusions agree with and support the staff conclusions.
h f
no wL fJohn T. Greeves Subscribed and sworn before me this 9th day of December
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Notary Public My Comission expires:
July 1, 1982 Attachment Professional Qualifications
l John T. Greeves Professional Qualifications i
l fy name is John T. Greeves.
I am responsible for geotechnical engineering j
evaluations for nuclear facilities. This includes evaluation of the soil mechanics, rock mechanics, earthquake engineering, and foundation engineering I
aspects to assure that adequate siting and foundation design measures have i
been taken to prevent adverse operational and safety problems.
This includes
[
development of criteria and standards for evaluating the above geotechnical engineering matters as they affect the safety of nuclear power plants, fuel recrocessing plants, fuel storage, waste disposal, and other nuclear facilities.
I a responsible for analyzing, interpreting and evaluating the soil mechanics, rock r:echanics, and foundation engineering information submitted to the NRC in support of applications for the construction and operation of nuclear facilities, j
These evaluation duties are accomplished through the application of standard and state-of-the-art procedures to assess the safety of nuclear facilities.
I an responsible for conducting reviews of the site geotechnical conditions, and the adequacy of foundation construction procedures, i'ncluding instrumentation proposed for collection of data; discussing the adequacy of these programs with technical officials in applicant's organization and their consultants and providing liaison with the U.S. Amy Corps of Engineers offices in matters i
of soil and rock mechanics, dam design, foundation engineering, and earthquake engineering.
This includes appearances before the Advisory Committee on Reactor Safeguards, the Atomic Safety and Licensing Board Panel, and at public hearings, as required, to present and justify technical analyses and evaluations in geotechnical engineering matters.
I received a Bachelor of Science Degree in Civil Engineering from the University of Maryland ir.1968.
In addition, I have completed r.ine credit hours of graduate level studies in Civil Engineering at the University of Ma ryland.
I have also completed numerous short courses in soil mechanics, earthquake engineering and nuclear power plant design.
I have about 12 years of professional experience working in areas related to I
foundation design, construction and analysis required for both nuclear and conventional electric generating plants. These include nearly seven years i
with Bechtel Inc., in Gaithersburg, Maryland and over six years with the
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U.S. Nuclear Regulatory Commission in Bethesda, Maryland.
I an a member of the American Society of Civil Engineers, International Society of Soil Mechanics and Foundation Engineers, the Earthquake Engineering Research Institute, and the Interagency Committee on Seismic Safety in Construction.
In addition,I am a registered professional engineer in Virginia and Mississippi
i e
i UNITED STATES OF AMEIRCA NUCLEAR REGULATOP,Y COMMISSION BEFORE THE ATOMIC SAFETY & LICENSING BOARD In the Matter of DAIRYLAND POWER COOPERATIVE
)
Docket No. 50-409-SC (La Crosse Boiling Water Reactor)
)
(Order to Show Cause)
CERTIFICATE OF SERVICE I hereby certify that copies of the NRC STAFF ANSWER IN SUPPORT OF LICENSEE'S MOTION FOR SUMf'.ARY DISPOSITION in the above-captioned proceedina 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 Comission's internal mail system, this 9th day of December,1980.
f Charles Bechhoefer, Esq.*
- 0. S. Hiestand, Esq.
Chairman Kevin Gallen, Eso.
Atomic Safety & Licensing Board Morgan, Lewis & Bockius U. S. Nuclear Regulatory Comission 1800 M Street, N. W.
Washington, D. C. 20555 Washingotn, D. C. 20036 Dr. George C. Anderson Atomic Safety & Licensing Board Panel
- Department of Oceanography U. S. Nuclear Regulatory Comission University of Washington Washington, D. C. 20555 Seattle, Washington 98195 Atomic Safety & Licensing Apoeal Panel
- Mr. Ralph Decker U. S. Nuclear Regulatory Commission Route 4, Box 190D Washington, D. C. 20555 Cambridge, Maryland 21613 Mr. Frederick M. Olsen, III Coulee Region Energy Coalition 609 N. lith Street Attn: Ms. Ann K. Morse La Crosse, Wisconsin 54601 P. O. Box 1583 La Crosse, Wisconsin 54601 Docketing & Service Section U. S. Nuclear Regulatory Comission Fritz Schubert, Esq.
Washington, D. C. 20555-Staff Attorney Dairyland Power Cooperative 2515 East Avenue, South La Crosse, Wisconsin 54601 Mr. Frank Linder General Manager s
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Dairyland Power Cooperative 2615 East Avenue, South Steven G. Burns La Crosse, Wisconsin 54601 Counsel for NRC Staff
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