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NORTN ANNA E.WlRONMENTAL COALITION P.O. BOX 3951 Dr. David Okrent, Chairman (80 293-6039 North Anna Subcomittee June 8, 1977 Advisory Comittee on Reactor Safeguards U. S. Nuclear Regulatory Connission 1717 H Street Room 1046 Washington, D. C.
Dear Dr. Okrent:
As you doubtless recall, the North Anna Environmental Coalition (NAEC) wrote to you on May 5, suggesting that in the light of continuing serious problems at the North Anna site that the Advisory Connittee en Reactor Safeguards (ACRS) withdraw its letter giving Operating License approval.
On May 5, NAEC enclosed its April 20 letter to RRC In-spection and Enforcement Director Ernst Volgenau so that the ACRS might also consider the problem areas listed therein:
remedial drainage for excessive groundwater, abnormal and differential settling, micro-earthquake indications, earth-quake design deficiencies, and severe leakage problems in Westinghouse steam generators.
On May. 22, NAEC mailed to ACRS its May 20 letter to ASLB Chairman Frederic J. Coufal so that the ACRS might also question the " Design Deficiency" which necessitated rock anchors for Reactor 3 because of water under the structure although Reactors 1 and 2 on the same wet fault have no rock anchors.
Since all of the correspondence described above, NAID has continued to study the North Anna situation and to listen carefully to testimony offerred at the May 31 through June 2 Operating License Hearing here in Charlottesville.
As an outgrowth of the foregoing, the Coalition would
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like to submit the following additional information to the Advisory Connittee on Reactor Safeguards:
1.
Regarding saprolite-halloyaite In response to the Volgenau letter described above, Dr. Antonio V. Segovia, Associate Professor of Structural Geology, Engineering Geology, and Environ-mental Geology at the University of Maryland, wrote NA3D on the " unsuitability of halloyaite as a foun-dation material for Any structure expected to last for a while."
The relevant parts of Dr. Segovia's letter are en-closed as Attachment A, 8508220496 850722 f
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kI Regarding saprolite-halloysite (cont.)
Another geologist has expressed concern to RAEC that "halloyaite 'and other clays are thizotropic, and un-der any serious shaking may well turn liquid and flow."
We are told that certain government geologists stress how little is known about the behavior of saprolite and halloysite.
Its tendency to " creep, sag, and move about" lea 4 them to consider it a " mistake" as a foun-dation for a nuclear power station.
The Coalition would urge the ACRS to consult with the U. S. Geological Survey on the foundation safety sig-nificance for North Anna of the saprolite reports of the Army Corps of Engineers, Dr. R. Torrence Martin, and Geotechnical Engineering, Inc.
NAEC would question whether " expansion coup 1ings" and " remedial drainage" can provide adeguate sta.
bility for the life of a plant on such unpredictable foundat ions.
2.
Regarding remedial drainage for excessive groundwater Testimony by the NRC Staff on June 2 gave a very con-fused impression as to what would be the effects of dewatering efforts upon pumphouse settlement.
There seemed to be little awareness of the contra-diction between the 1976 SER entry which said that groundwater control would preve_nt, rapid settlement, and the 1977 FSAR entry which predicted that "such a dewatering system would cause additional settlement of the service water pumphouse." (P3.8 3, 5-6-77)
Evidently additional settlement will be a problem whether the dowatering method is that of well-points or that of horizontal drains.
If well-points were abandoned because of difficulty with clay particles, as well as difficulties with drawdown, how will the particle problem be avoided in the drains?
" Loss of fines through the system would indicate that internal erosion or ' piping' is occurring," according to the FSAR, which also sys that "no rational basis exists for establishing acceptable limits" in regard to suspended solids or turbidity.
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~0" Regarding remedial' drainage...h ont.)
The PSAR also notes that " piping is a consnon cause of failure of earth dams."
l Is optimistic monitoring sufficient protection?
" Daily measurement taken following drain installa-tion should decline steadily and serve to confirm that piping is not occurring.
Inspection guidelines will include baseline values for each drain, estab-lished after a period of initial observation."
(S2.21-1, 12-22-76)
It was NRC testimony on June 1 that " excessive loss of fines could result in unsafe conditions."
It was also NRC. testimony on that date that Unit #1 at North Anna must shut down if the remedial ground-water drainage system was not completed by December 31, 1977.
Surely so experimental a system, one with "no rational basis" for turbidity limits, one which influences pumphouse stability, should be totally installed and tested before reactor operation. The Coalition would expect that to be the safeguards position.
We would question the relation of the NRC December 31 deadline to the September I completion date in VEPCO's letter of April 15.
Since predictions regarding the North Anna station have been so multiply in error in the past, the Coalition would urge the ACRS to require a demonstra-tion that the experimental drains can maintain foun-dation equilibrium at the North Anna site before any fuel-loading is permitted.
The Coalition would also urge the ACRS to review the groundwater _ questions raised by Dr. Robert Mueller and Dr. John Funkhouser in testimony pre-pared for the Show Cause fault hearing of 1974.
3.
Regarding abnormal settlement and prediction errors, A groundwater level prediction error of 14 feet at North Anna is now a matter of record.
A foundations material and settlement prediction error was also made by Dames & Moore.
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_4 Regarding settlement and errors...jcont.)
On Msgr 8,1969, after a cover letter describing
" foundation conditions at the site" as " generally excellent," Dames and Moore's Foundation Studies made the following erroneous statements on the materials beneath the pumphouse, now known to be
" erratic and anisotropic" soils:
"The results of o tr investigation indicate that relatively fresh rock will be encountered beneath the pumphouse.. fresh rock will provide suitable support... residual settlements will be negligible."
Given Dames and Moore's consistent record of diam-nostic failure at North Anna, from the faulting beneath reactors #1 and 2 to the saprolite beneath the pumphouse, the Coalition believes the ACRS should question YEPCO's continued reliance upon this unfortunate company.
In particular, the Coalition would question the validity of the April 15, 1977 Dames & Moore report on Neuschel's Lineament and the Stafford i
Pault Zone. Dames and Moore's original handling of Neuschel's Lineament - failure to submit the map with this regional structure marked - became the basis for a " material falso statement" in 1975.
The Coalition, in keeping with the June 2,1977 GAO Report on North Anna, would urge the ACRS to require an independent audit of the relation be-tween Neuschel's Lineament and the Stafford Fault
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Zone, as well as the relation between Neuschel's Lineament and clustered seismic activity at Lake Anna.
(The ACRS and the ASLB may wish to inquire into the reason for the 1973 submission of the 1969 Domes & Moore Foundation Studies.)
4.
Regarding steam generator leakage and corrosion Question 3 e in the Coalition's April 20 letter to Mr. Volgenau inquired about the effects of con-tamination in Lake A=== water upon steam generator tubing. Testimony at the Operating License hearing implied that fresh water might circumvent Surry's problems with brackish water.
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. Regarding steam generator leakage and corrosion (cont.)
Nevertheless, an April 29, 1977 letter from VEPCO to the NRC describes
...a fouling and corrosion problem due to the high iron content, the presence of sulfate-reducing bacteria, and the general corrosive nature of the lake water..."
The Coalition would urge the ACRS to explore the implications of the foregoing in regard to the in-tegrity of steam generator tubes, and also to ex-plore the effects of the proposed cooling tower solution.
(The VEPCO April 29 letter is enclosed as Attach-ment B.
NAEC's February 16 steam generator summary is enclosed as Attachment C.)
In August of 1976, the Coalition suggested that there might be geological parallels and construction parallels (grouting, leaks) between the North Anna das and the Teton dam.
Today we would suggest a regulatory parallel between the
- North Anna eituation and the Teton eituations public ageneles whose staff and documents express doubts about an " exception or worst case" situation fail to protect the public from an ad-mitted risk.-
Fortunately, protection is still possible against the defectively sited and constructed North Anna Power Station.
It is the profound hope of the Coalition that the Advisory Committee on Reactor Safeguards will exercise the powers given it by Congress, warn the public of the risk involved, and actively move against it.
j We look to your responsible action.
Sincerely, l
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l June Allen (Mrs. P. M.)
l President, NAEC i
l Enc.
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