ML20070F006

Requests That USGS Evaluate Risk of Catastrophic Explosion of Propane Leak from Underground Storage Wells Into Morton Salt Mine.Fsar & Fes Deny Possibility of Event

ML20070F006
Person / Time
Site:	Perry
Issue date:	12/14/1982
From:	Bimber R AFFILIATION NOT ASSIGNED
To:	Stefano J NRC
Shared Package
ML20070F010	List: ML20070F006
References
RTR-NUREG-0884, RTR-NUREG-884 NUDOCS 8212200051
Download: ML20070F006 (2)

Text

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N 4 T.t m e> ses.sese j i

RUSSELL M. BlMBER 10471 Prouty Road 4

p m anvitts,osso 4.on Dec. 14, 1982 J. J. Stefano, Project Manager, PNPP Nuclear Regulatory Commission Washington, D. C. 20555 UNRESOLVED SAFEIT ISSUE -- FNPP Docket Noe s 50-440 50-441 The possibility of a catastrophic explosion of propano leaking from Lake Underground Storage wells into the Morton Salt Mine was improperly rejected

in the Final Environmental Statement on the Perry Nuclear Power Plant, NUREG 0884, pages 9-14 & 9-15.

4 My concern was with the horizontal extensions of the mine and propane cavities toward each other within the salt strata 2000 feet underground, not with the possibility that the shafts and wells might be inclined toward each other.

The size and location of the Morton Salt Mine is substantially misrepresented

! in both the FES (page 9-15) and in the Final Safety Analysis Report, where Figure 2.5-16 shows it as being entirely under Iake Erie. Morton's Chief Engineer, Mr. Patel, told me it also extends 6000 to 7000 feet south of the mouth of the Gra:xi River, arxi 5000 to 6000 feet west. The mins shafts are about 3000 feet south of the River mouth, so the mine cavity extends a long way south of the shafts, toward lake Underground Storage.

Farthermore, it would be intolerable from the standpoint of mine safety to have the mine shaf ts at the lowest point in the mine, because of the ever-present danger of flooding by Iake Erie. This would be the case if the Mine did not go south of the shafts, because the salt dips to the south, about 25 i feet per mile. The southerly limits of the Mine were excavated more than a decade before lake Undergrou:xi began operation, when mining further south may have been regarded as increasing safety. (See "Who Pulled the Plug on Iake Peigneur?" for a story on Texaco's drilling into and flooding an active salt mine - Science 81, November 1981 or the cctober 1982 Reader's Digest.)

The FSAR denies any knowledge of Iake Underground Storage (LUS) on page 2.5-59, i

when it says the only reported gas storage in the Salina formation in Ohio is near Canton. This must_ be corrected. Tne attached letter shows the AEC learned of it in 1973 and caid it should be documented in the PSAR and considered in the evaluation of postulated accidents in the vicinity of PNPP. The explosion I have envisioned is just such an event. Page 2 5-59 also erra in saying,

" Presently no potential salt cavity storage areas are located adjacent to the site or within a five mile radius." There are many wells extending through the salt, which should be considered potential salt cavity storage areas, tdready documented in the FSAR. Table 2.5-6 and Figure 2 5-17 show several examples, not under CEI control, yet within a mile of PNPP, contrary to a statement on page 9-15 of the FE. Also note that CEI does not control the coa;.encing mineral about rights 3000 feetunder the west of Neff the Perkins PNPP Company's reactors twenty (WAR 2.1-5, acre Am.4 site,/81)). Can.

(10/2 you tell me why the Neff Perkins land is erroneously shown as part of a "tB Reservation" in Fig. 2.1-2 of the WAR?

8212200051 821214 PDR ADOCK 05000440 PDR H

Back to LE : it was said to have the capacity to store 500 minion sanons of prepara in the Cleveland Plain Dealer, Lake Country Edition, 8/30/80, pages 1 and 2. Several cavities, one being 135 minion sanons, were mentioned in The Sunday Paper (Painesville Telegraph) 2/29/76, page 80 The height of these cavities is probably limited to fifty feet (EUAR 2 5-49) since a log of Morton's wen corresponding to Chio Permit 22 shows both the Mine and LUS cavities must be in the "F unit" of the Salina formation (Preliminary Safety Analysis Report, Appendix 2I, Plate 9-10). A fif ty foot high.135 minion ganon cone would have a radius of 587 feet, probably approximating that of a morning glory shape mentioned in the FSAR, 2.5-48.

The northerly extension of LE's underground propane storage cavities, from the wells, is likely to exceed 587 feet because the same factor that causes the morning glory shape -- fresh water being less dense than salt brina --

also causes the cavity to grow mere up-dip, where the Morton Mine is, than down-dip. I expect the propane cavities may extend 1000 feet from the wells I

tcuard the Morten Mino.

Based on the estimated 7900 foot separation of the mine shaf ts and wens, the underground separation of the mine. cavity and the propane might be 2900 feet.

But my calculations are very rough, and solutioning enlargement of the propane )

cavities could cause them to reach the mine cavity because the dip is only 25 l feet per mile. I expect enlargement because I don't believe LW has enough  !

brine storage capacity to match the 168 minion ganons of propane claimed to j be in storage in 1976 or 1977, or the claimed 500 million gallons capacity: 1 Plain Dealer, loc. cit. Also, brine from plastic lined surface ponds, cooler than when it came out of the ground, armi perhaps diluted with rain and snow, 3 is used to recover propane in the wintertime. And accidental losses of brine will require makeup water.

My letter on page A-25 of NUREO 0884 urderestimated the pressure of the prepara in LUS's storage it should have been 750 psig to agree with the FSAR, 2.2-21.

I urge you to have the US Geological Survey, or otner experts, make actual measurements within the mira, and check whatever well logs may be pertinent, and anything else they feel may be desirable, to evaluate this risk to PNPP and to the lives of workers in the Mine.

If I may be of further help, don't hesitate to ask.

Sincerely, 9A wt. %

P. S. : Morton drilled wells around their southern perineter, vented natural gas, and capped the wells when starting the Mine. Now that LW is off in that same direction, I think the pressure in the wells should be limited to a safe value, considering their distance from the mira cavity -- definitely no more than 100 psig. If much pressure is observed, the ratio of propane to methane should be checked to see if much of the propane is from LUS. Tnis is especially true since the alleged discovery of an underground crack rear Madicon by Viking.

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