ML20148P238

Ack Ltr of 781018 from Delta Chapter of Sierra Club Re Subj Facils.Nrc Is Currently Considering a re-review of Financial Quals of Gsu.Exam of Recent Hydrocarbon Drilling Also Made; No Potential Hazard to Constr Site Found to Exist

ML20148P238
Person / Time
Site:	River Bend
Issue date:	11/20/1978
From:	Harold Denton Office of Nuclear Reactor Regulation
To:	Fryling C Sierra Club
Shared Package
ML20148P242	List: ML20148P238
References
NUDOCS 7811280157
Download: ML20148P238 (4)

Text

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• UNITED STATES c 4 b,, ,t NUCLEAR REGULATORY COMMISSION g/3 h (/.) , . WASHINGTON, D. C. 20555 l go-438

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Mr. Charles Fryling, Jr.

Conservation Committee Delta Chapter, Sierra Club 1068 East Lakeview Drive Baton Rouge, LA. 70810

Dear Mr. Fryling:

I am pleased to respond to your letter of October 18, 1978, providing a recent resolution adopted by the Delta Chapter of the Sierra Club relative to the River Bend Station, Units 1 and 2. The resolution stotes:

" Delta Chapter of the Sierra Club speaks for the Club mem-bers living in Louisiana on Louisiana issues. The Sierra Club is concerned about the financial qualifications of Gulf States Utilities to ' continue the River Bend Nuclear Power Plant in West Feliciana Parish, La. and to meet the NRC's safety requirements. It is equally concerned about the possible impacts on the proposed plant by the oil and gas drilling, production, and transportation which is occurring at the present time. It believes that the company has not been conscientious in meeting its reporting require-ments to the NRC. Wherefore, Delta Chapter, Sierra Club supports a complete NRC investigation of Gulf States Utilities' financial qualifications, and of the oil and gas drilling, production, and transportation as it may impact on the proposed nuclear power plant."

In May 1978, Gulf States Utilities (the applicant) announced and advised us that the anticipated fuel loading date for River Bend Unit 1 would be delayed one year until the spring of 1984 and that Unit 2 continues to be deferred indefinitely. The applicant stated that the inability to obtain adequate rate relief in Louisiana and the lack of timely participation by other interested parties led to this decision.

We are currer,tly considering whether to undertake a re-review of the financial qualifications of Gulf States Utilities Company. We have recently asked the applicant to submit the results of its comprehensive analysis of its nuclear construction program and other financial information. If such a re-review is determined to be warranted, the NRC staff will be guided in its assessment of the applicant's financial qualifications by the " reasonable assurance" standard of Section 50.33(f)

' of 10 CFR Part 50 and the Comission's 'recent interpretation of that standard to mean "a reasonable financing plan in the light of relevant circumstances."

7811280/57 4

Mr. Charles Fryling Our decision must await receipt of the requested financial information.

We will inform you of our decision once it has been reached.

Your resolution also expresses concern regarding oil and gas drilling activity near the site for the River Bend Station, Units 1 and 2. We are aware that wells are presently being drilled as close as 18,000 feet from the site, and have considered the potential effects of (1) ground subsidence on seismic Category I structures, and (2) an explosion at a high pressure gas well or pipeline near the plant site either damaging the facility or causing it to be evacuated while in operation.

Considerable hydrocarbon exploration and some production have been undertaken in the general vicinity of the River Bend Station within the past two years. Exploration, gas discoveries and production are from the Cretaceous Tuscaloosa Sand at depths ranging from about 16,000 feet to depths in excess of 20,000 feet. The closest commercially successful gas well to the site, the Georgia Pacific No.1, is eight I

miles from the plant in East Baton Rouge Parish which produces from the Tuscaloosa below 17,000 feet. This is not a high-pressure well.

Three well permits were issued in the recent past in West Feliciana Parish: two in August,1976 and one in August,1978. The nearest of the test wells resulting from these permits, Rosedown Plantation l

No.1, is about 18,000 feet northwest of the River Bend Station and l is projected to reach a depth of 19,500 feet.

We have reviewed these developments for the potential for subsidence resulting from hydrocarbon production and find that no potential hazard exists to the River Bend site. The potential for subsidence due to hydrocarbon production was addressed in the Safety Evaluation Report, both by the NRC staff (page 2-29) and by the U. S. Geological Survey (Supplement No. 2 to the Safety Evaluation Report, page -5). Both the NRC staff and the U. S. Geological Survey concluded subsidence was very unlikely when associated with hydrocarbon production from formations at extreme depth, such as the case for the Tuscaloosa.

The Cretaceous Tuscaloosa hydrocarbon reservoir is deeply buried at a depth in excess of 16,000 feet and consists of well compacted sandstone not prone to subsidence. Furthermore, in cases such as the River Bend Station, where there exists no known near-surface structure underlying the site (i.e., no faults or other geologic abnormalities), the vertical movement associated with deep reservoirs would be essentially uniform across the plant site. Such uniform subsidence would not create stress in plant structures and consequently would be of no significance.

Mr. Charles Fryling, Jr. Our safety review of the proposed nuclear facility and site, prior to issuance of the Construction Permits, included evaluations of the effects of three potential types of explosive or deflagration accidents. One type assumed the detonation and deflagration of 116 metric tons of liquid petroleum (propane) gas at a distance of 6,000 feet from the nuclear plant. A second type assumed a double-ended break of a high pressure pipeline carrying natural gas and petroleum products and located two miles from the nuclear plant. The third type assumed the detonation of two tons of explosive (i.e., TNT) one mile from the plant. In each case, we concluded that safe operation of the plant would not be affected l by these postulated events. The effects at the plant from potential accidents at the test drillings located at 18,000 feet, even assuming they become producing high-pressure wells, would be much less than the accidents we postulated during our safety review.

We have also considered the possibility that a high pressure gas well or pipeline might cause evacuation of tne nuclear facility while in operation. The design of the control rooms for River Bend Station, Units 1 and 2, includes provisions to preclude the need for evacuation, such as due to the presence of dense outside smoke or gas. Redundant ventilation systems normally provide filtered air to the control room from outside air intakes. When necessary, the ventilation system provides for operation in an isolated mode in which the intake and exhaust air ducts are closed off and breathing air for the control room is recirculated through a special filter train containing charccal filters. In this mode, the design also provides a positive pressure above atmospheric pressure to prevent outside air and building air leakage into the control room.

This design and additional provisions are described in Sections 6.4 and 9.4.1 of the applicant's Preliminary Safety Analysis Report. We reviewed this system and found it to be acceptable, as indicated in Section 9.3.1 of our Safety Evaluation Report for River Bend, issued in September 1974.

However, while the plant is designed to cope with such occurrences, the distance to the present test drillings and existing pipelines make it highly unlikely that these design provisions would actually be needed for such purposes.

In accordance with Section 50.55(e) of 10 CFR Part 50 and 10 CFR Part 21, applicar',s are obligated to promptly notify the Commission of any deficiency found in design and construction which could adversely affect the safe operation of the plant, or that the facility contains defects which could create a substantial safety hazard. We do not consider the applicant to be obligated to inform the Commission of the specific items in your letter concerning the Tuscaloosa hydrocarbon exploration and discovery within the region of the River Bend site. The recent activity, even assuming the Rosedown Plantation well to be successful, presents no previously unconsidered or unresolved safety implication.

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Mr. Charles Fryling The Commission maintains a general awareness of developments at the River Bend site through periodic audits conducted by our Office of Inspection and Enforcement, Region IV, located in Arlington, Texas. We will continue to follow developments in the area through our Office of Inspection and Enforcement and re-examine such activities as they occur. Also, the applicant will include the regional status of oil and gas development in the Final Safety Analysis Report, and will be required to address the safety impact of such production at that time for our detailed review for operating j licenses.

We appreciate your interest in this matter and trust this letter has been responsive to the concerns in your resolution.

Sincerely, ayut WV4 U?

E.c C?e Harold R. Denton, Director Office of Nuclear Reactor Regulation 1

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