ML19351D393
| ML19351D393 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 10/02/1980 |
| From: | Olsen F AFFILIATION NOT ASSIGNED |
| To: | DAIRYLAND POWER COOPERATIVE |
| Shared Package | |
| ML19351D387 | List: |
| References | |
| ISSUANCES-SC, NUDOCS 8010100056 | |
| Download: ML19351D393 (4) | |
Text
_ _ _ - - _ _ _ - _.
o e
FREDERICK M. OLSEN III's FIRST ROUND INTERROGATORIES TO LISCENSEE'.
All parties are asked to bear with any redundancies in interrogatory questions.
The questions submitted by C.R.E.C.
and the questions submitted by Mr. Olsen are the results of separate efforts.
RESPECTFULLY SUBMITTED, SLWWW FREDERICK MILTON OLSEN, III i
l 8010100 G56 l
l INTERROGATC U:S 1.)
WLle Dames and Moore may say that the soil under the LACBWL facility has beccane denser, and therefore more resistant to liquefaction, how will this make any difference if the soil around ther plant is not as dense? If the soil around the LACBWR facility liquefies, can it be shown that LACBWR will remain stable?
2.)
If the soil around the LACBWR facility liquefies, vill this not cause the earth pressure arouni the mare stable sub-LACBWR soil to lessen ?
If the earth pressure around the sub-LACBWR soil lessens, will there not be a lessening of resistance to liquefaction of the sub-LACBWR soil?
3.)
Referencing the Dames and Moore report of 21 March 80 How closely did the predicted' values mentioned at the top of page 13 correlate with the actual resulting b low count data? ' Provide figures, please.
4.)
'How much money has the Dairyland Power Cooperative spent on Dames and Moore Studies since the NRC started to question initial studies by D & M? How much money has been spent trying to fight the installation o f a de-watering system at LACBWR7 Hcv much money could Dairyland recoup by selling the devatering system ccuponents after the useful life of the LACBWR facility, providing it does not became a spent fuel dump?
5.)
How was the figure of 0.20 gravity lateral accelleration produced by an SSE for the TIBONE energy park project arrived at? Was this the work of a sensultant, and if so, who? Please provide address.
6.)
If a figure of 0.12 g was considered sufficient for a lateral acceleratica count during a proposed LACbWR SSE, why did not Dairyland Power Cooperative ask that this figure be used for TYROIE energy park project, in which DPC was a partner?
. 7.) '
Can DPC show any instance where Dames and Moore have used the very same equations, theoriea and methods. used in their LACBWR studies to predict liquefaction (or non-liquefaction) at a cite where an earthquake later occurred, and the soil reacted as predicted by D&M7 8.)
Can DPC show that D&M bas been consistently successful at predicting liquefaction (or non-liquefaction) hy any means?
9.)
Has nhanging water levels in the water table, or changing river water levels been taken into account in any D & M calculations?
Please show calculations taking changing water levels into account.
10.)
Please provide the probabiliatic studies used to show DPC's statement of 10,000 years return period for a SSE producing 0.12g 1ateral acceleration at LACBWR is true.
4 e
l i
i 1
l 1
M
p j.% 11.)
Please show, by diagram, the area of geological influence exerted by a driven pile of the type or types used at LACBWR.
Specify the extension of influence to the sides of and below the driven piles.
12.)
Do the driven piles at the LACBWR site affect the the entire volume of soil subject to liquefaction at the site?
13.)
Will there not be a waning effect of soil densification by driven piles at the perimeter of the area occupied by the driven piles as soil stresses or soil pressures are transferred outward from the area occupied by the piles?
Could this phenomenon of transferring of soil pressures to outer areas of lesser soil pressures penetrate a significant distance into the area of driven piles?
14.)
Could significant soil movement not termed liquefaction (i.e., less than liquefaction or different from liquefaction) occur at the LACBWR site, and for what reasons?
15.)
What has been used as " historical record" of seismic activity in the LACBWR area?
Please name sources of information libraries, etc., used to develop the " historical record" used to estimate return period for a SSE at LACBWR.
16.)
What is considered to be the " modern period" of observation and record keeping concerning seismic events?
At which point in history must we start relying on modern estimates of historical events, instead of modern-type observation, measurement and record keeping?
17.)
The Mississippi River and surrounding water tables are every day being exposed to more and more industrial, agricultural, and residential water effluents, especially effluents previously used as wetting agents.
Could changes in the water chemistry of the Mississippi River and the surrounding water tables affect liquefaction potential?
18.)
Does DPC inject gases or liquids into the LACBWR site soil for any reasons?
me o
q J woJu o[M A N L
.