ML20205K598
| ML20205K598 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 02/24/1986 |
| From: | Gonzales R, Heller L Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20205K591 | List: |
| References | |
| OL, NUDOCS 8602270582 | |
| Download: ML20205K598 (31) | |
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c 00CHETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -
'86 FEB 26 A10:14 .
BEFORE Tile ATOMIC SAFETY AND LICENSING BOARD ,
00CMEIi% > Sr W:n .
BR A h C+-
In the Matter of )
)
GEORGIA POWER COMPANY ) Docket Nos. 50-424
--et al. ) 50-425
) (OL)
(Vogtle Electric Generating Plant, )
Units 1 and 2) )
NRC STAFF TESTIP!ONY OF LYMAN W. IIELLER AND RAYPIOND GONZALES ON CONTENTION 7 (GROUNDWATER CONTAMINATION)
Q.1 Please state your names, affiliations and positions.
A.1 My name is Lyman W. Heller. I am currently Senior Task Manager in the Engineering Issues B ranch , Division of Safety Review and Oversight, Office of Nuclear Reactor Regulation, NBC. Prior to the October, 1985 ONRR reorganization , I was the geotechnical engineering section inader in the Structural and Geotechnical Engineering Branch, Division of Engineering, Office of Nuclear Reactor Regulation , and was responsible for supervising the geotechnical review of the Vogtle plant. In carrying out these latter duties , I gained familiarity with a number of geotechnical features of this plant.
My name is Raymond Gonzales. I am a hydraulic engineer within the Engineering Branch of the Division of Pressurized Water Reactor 8602270582 B60224 PDR ADOCK 0 % 4y4 T
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Licensing - A, Office of Nuclear Reactor Regulation, United States Nuclear Regulatory Commission.
Q.2 Have each of you prepared a statement of your professional qualifications?
- A.2 (!!eller , Gonzcles) . Yes. Statements of our professional qualifi-cations are attached to this testimony.
O.3 t' hat is the purpose of your testimony?
i A.3 (Heller) . To address Joint Intervenors' Contention 7 which states that applicants have failed to assure that the groundwater below the Vogtle Electric Generating Plant will not be contaminated by a spill of radioactive water. In response to a motion for summary i
disposition, on November 12, 1985 the Licensing Board ruled that i there were several issues of material fact remaining with respect to l
l this contention. Its concerns related to: (1) the adequacy of geological / hydrological exploration, (2) uncertainty in data on marl thickness and permeability, (3) data on marl continuity, (4) direction of groundwater flow, and (5) groundwater travel time.
l My testimony will address those areas of concern which relate to geology and geotechnical engineering. Mr. Gonzales will address the hydrologic concerns. We shall address material fact (1) jointly. I l
l - . _ . - - - _ _ __ _ _ _ _ . _
- shall address material facts- (2) and (3) and Mr. Gonzales will address material facts (4) and (5).
.l Q.4 Mr. Gonzales, do you agree with Mr. I!eller's characterization of the Board's expressed concerns?
A.4 (Gonzales) . I do.
Q.5 Uhat are the Board's expressed concerns pertaining to the adequacy of geological and hydrological exploration (material fact 1)?
A.5 (Heller) . The Board identified (at pp.12-13) what they perceived to be several unresolved areas in the record concerning geological and hydrological exploration (material fact 1), which included:
a) the staff's SER (at p. 2-32) indicates that well monitoring in the unconfined aquifer and in the beckfill is necessary to establish the design-basis groundwater level; b) the staff's SEP. (at p. 2-32) indicates that additicnal wells in the marl aquiclude are required because previous well monitoring provided only limited information; 2
c) the staff's SER (at p. 2-33) states that the confined Tuscaloosa aquifer should be monitored during plant operation to determine the long-term effect of withdrawing water from this aquifer;
d) the applicants are still conducting laboratory permeability tests on cores taken during drilling of the marl in June of 1985; t
e) the applicants' statement that groundwater data from well series 42 are . still being supplemented and confirmed by data from
. additional wells.
Conecrning material fact - 1, I shall address items b), d) and e).
Mr Gonzales will address items a) and c).
Q.6 Mr. IIcIler, what is your opinion regarding the adequacy of geological exploration at the Vogtle site?
A.6 (lleller) . In my opinion, recent information made available to the staff by the applicant is sufficient to judge that the geologic exploration of the VEGP is now adequate with respect to ground-water contamination concerns. This opinion is based on my review I
of a report entitled "Geotechnical Verification Work -
Ileport of Results" that vras enclosed with a letter
- from J. A. Bailey, Georgia Power Company, to Ms. E. G. Adensam, U.S. Nuclear Regulatory f
Commission, dated August 23, 1985. This report describes the i exploratory work carried out by performing six core borings into i
- the marl formation and the results of pressure tests conducted in i
the cored holes. These holcs will be used as wells to measure I
groundwater elevations in the marl formation.
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My review of the sufficiency of the new geological exploration information was focused on evidence that the Blue Bluff marl i formation would impede the seepage of potentially contaminated l groundwater from the uppcr (unconfined) aquifer in the backfill material above the marl to the confined (Tuscaloosa) aquifer beneath the marl. My review of the boring lors which appear in Appendix D and of the drilling procedures described in sections 4.2 and 4.3 of the above referenced report lead me to the conclusion that the exploration work meets all applicable NRC Regulatory Guides and Standard Review Plan recommendations. In particular, corings were continuous and the rate of bit penetration was recorded; a detailed field log of the material encountered is also presented for each hole; the holes were cored using clean water to remove the cuttings. These procedures and practices are adequate to reven!
the pertinent features and composition of the marl and to assure that pressure test results and later water level monitoring in the six new wells are reliable.
As described in Appendix C of the August 23, 1985 report, ten core samples from the marl were tested in the laboratory to determine their permeability. The results of these tests indicate that the marl permeability is about 10 centimeters per second (cm/sec); this value is consistent with the description and classification of the marl formation.
-G-In reaching _ my conclusion I have also reviewed a recent February,
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1986, applicant report entitled "Vogtle Energy Generating Plant --
Ground-Water f.lonitoring Program -- July - December 1985" attached to a letter from J. A. Bailey, Georgin Power Company, to B. J.
Youngblood, NRC dated February 6, 1986. As set out in this report, the applicants have installed and monitored additional wells to supplement earlier data.
O.7 P.lr. Gonzales , what is your opinion regarding the adequacy of the hydrological exploration at the Vogtle site?
A.7 Since the SER was published the applicants' have drilled new wells, have installed groundwater level monitoring instruments, and have performed additional field and laboratory permeability tests throughout the entire thickness of the marl. Thir data has been compiled by applicant in the August 23, 1985 report mentioned by f.Ir. IIeller and a February 1986 Report entitled "Vortle Energy Generating Plant -- Groundwater P.lonitoring Program -- July-December 1985." The staff has been actively involved in reviewing the cpplicants' proposals to assure the acceptability of the proposals prior to their being implemented. I now conclude that the applicants' hydrological exploration program is adequate and acceptable,
w Q.8 Mr. Gonzales, what is your opinien regarding the Board's first specific concern regarding the monitoring of the backfill and unconfined aquifer (material fact 1)?
A.E (Gonzales) . The Board's first concern (item a) was that the Staff's SER stated that additional monitoring would be necessary to establish the design-basis groundwater level for Vogtle. This SER concern was related to the applicants' design-basis groundwater elevation of 165 ft. msl. Because groundwater levels in the backfill and unconfined aquifer had only been monitored for a relatively short time , it could not be determined conclusively that this elevation could not he exceeded over the life of the plant. The design-basis groundwater level defines the maximum groundwater level used to compute groundwater induced loads on sub-surface portions of safety-related structures. Thus it is a structural eencern as opposed to a groundwater contamination concern.
To address the staff's SER concern, the applicant has instelled four new monitoring wells (LT-1 B , LT-7 A , LT-12 and LT-13) in the plant backfill and two new wells (808 and 809) in the Barnwc!!
sediments. In response to a staff request, two of these wells (808 and LT-13) are now being monitored on a continuous basis and the remaining wells are being monitored on c weekly basis to confirm the acceptability of the appliennts' design-basis groundwater level.
This monitoring will be a license condition for the Vogtle plant.
The frequency of monitoring is subject to change.
Q.9 Mr. IIeller, has the SER issue (item b of material fact 1), pertaining to the need for additional wells in the marl aquielude , been l
[. resolved?
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A.9 (lieller) . Yes. As I have stated, since this issue wac raised in the SER the applicants have performed si:: continuous and carefully controlled core borings into the marl formation. Test results from these borings are set forth in applicants' report entitled "Geotechnical Verification h'ork - Report of Results."
Q.10 Mr. Gonzales, has the SER concern (item e of material fact 1) that i the Tuscaloosa aquifer should be monitored been resolved?
A.10 (Conzales) . Yes. Ilowever, this SER provision does not relate to a groundwater contamination concern. Monitoring in this SER i
< provision is required to encure that the withdrawal of water from the Tuscaloosa aquifer will not adversely impact on other groundwater users. Thus it is more of an environmental concern than a safety one. To meet this reouirement, Staff will require monitoring throughout the life of the plant. The applicants are currently monitoring two wells on a monthly frequency.
Q.11 Mr. Heller, regarding. item d of material fact 1, have the applicants I completed laboratory ; permeability tests on cores taken during drilling on the marl in June of 1985?
a A .11 (IIeller) . Yes. The applicants in their August 23, 1985 report
! presented the results of tests conducted on ten samples obtained during core drilling of the marl. A falling head permeability test was conducted on cach marl sample in accordance with proce-durcs described in Department of the Army Manual EM 1110-2-1906.
The results of these tests showed the permeability of the marl to
-8 ~0 These lab range from about 10 cm/sec. to about .10 cm/sec.
I testr, together with the in situ field tests confirm that the marl
- is nearly impermeable.
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! Q.12 Mr. Heller, regarding item e of material' fact 1, has data from well series 42 been supplemented by data from additional wells?
4 A.12 ( Heller) . I have reviewed the February 1980, report entitled "Vogtle Energy Generating Plant --
Groun d-l'/ater Monitoring Program -- July - December; 1985." Figures 11 and 12 of this l report show plots of the recorded groundwater elevations versus
! time for the six 900 series wells installed in the marl over the interval July to December, 1985. Figure 11, in my opinion ,
I illustrates expected results because the measured levels (marl pore pressures) decreased with time and have essentially stabilzed over i
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the last two months of the measuring interval. In my opinion,
.1 these data supercede information collected from the series 42 wells.
Q.13 Mr. IIcIler, can you address the Board's expressed uncertainty in data on marl thickness and permeability (material fact 2)?
A.13 (lieller) . Pages 14 and 15 of the Order contain the Board's bases I for concluding that an issue of fact exists with respect to uncertainty about the thickness and permeability of the mar!. .
l These bases include:
a) intervenors allegation that thickness and permeability information came from 22 exploratory holes, of which 3 drew I
water and 3 were discounted; l l
l b) applicants reply that (1) their conclusions are based on 200 l exploratory holes , not just the 80 in situ permeability measurements at different levels in 22 of these holes, and (2) l two out of the three wells in which water was drawn were in near-surface , weathered marl, and in the three discounted wells, water leaked around the packers; i
c) the staff has found that additional geological and hydrological exploration is required , and that work is still in progress.
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4 Q .14 Mr. lieller, in your opinion has the work that has been done at Vogtle been sufficient to resolve any uncertainties regarding marl thickness and permeability?
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A.14 (lleller) . With respect ,to groundwater contamination concerns, I believe the investigations of the marl are sufficient to conclude that t
the thickness of tho marl beneath the power block structures is well known. I believe the thicknese is well known because of the unusually large number of holes drilled through the marl in this area by the $pplicant as compared to industry practice and NRC regulatory guides. : Table 2B-2 of the FSAR lists 33 holes drilled into the mari, whereas usual practice v ould call for only a fraction of this number. The marl formation is about 65 feet thick, and extends from about elevation 135 feet (mean sea level (msl) to 70 feet msl. To accommodate the foundation for the auxiliary build-ing, the marl was'; excavated to elevation 108.5 feet msl in a 120 ft by 440 ft area, so the resulting marl thickness is about 38 ft in this area. NUREG - 1137 dated June 1985, Sections 2.5.4.1.2 unc' 2.5.4.1.3 contains the basis for my opinion regarding marl thickness beneath the Vogtle plant. It may also be noted that
- hole 900 (Appendi
- : D of the applicants' August 23, 1985, report "Geotechnical Verification Work - Report of Results") was drilled to an elevation of 73.7 ft tasl without penetrating through the marl, so, at the locatbn s ~ hele 900, the marl extends to depths previously anticipaur .
4 With respect to the permeability of the marl, I have reviewed the applicants' repcrt on recent investigations specifically tailored to measure this parameter. The results of the applicants' work are reported in Appendix 11 and Appendix C of "Geotechnical Verifica-tion Work - Ileport of Results", dated August 1985. The in situ water pressure tests resulted in no measurable water losses and, as previously discussed, the laboratory permeability tests resulted in a value of about 10 cm/sec.
I believe additional confirming data of the marl permenhility can also be found in the applicants' groundwater monitoring report dated February 1986, entitled "Vogtle Energy Generating Plant - Ground-Water Monitoring Program - ,'uly - December, 1985. Figure 11 of this report shows a consistent decrease in the piezometer levels over a two-month period of time for piezometers in holes 900, 901 and 90.7. In my opinion, this datn indicates that the marl has a very low in situ permeability.
Dased on these reports, I conclude that, with respect to ground-water contamination, the thickness of the marl is well known, and the permeability has now been appropriately established.
Q.15 Do you believe that the Board's expressed conecrns have been resolved regarding material fact 2?
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A.15 (IIeller) . I believe the Board's basis (a) (material fact 2) has been. adequatdly addressed by existing and new borings into the raarl and by suitable in situ and laboratory tests conducted by the applicants. I believe the Board's basis (b) has been super-ceded by new information on the marl reported by the applicant in their letters dated August 23, 1985 and February G, 1986.
Concerning the Board's basis (c), it is my opinion that the Staff's requirement for additional geologic and hydrologic explora-tion of the marl formation beneath the plant has been satisfied by the new information provided by the applicant in their letters dated August 23, 1985 and February 6,1986.
Q.16 Mr. Heller, what concerns does the Board express with the dota on marl continuity (material fact 3)?
A.10 (Peller) . Pages 15 and 16 of the Board's Order contain the bases for ccncluding that an issue of fact exists with respect to marl continuity. These bases include:
a) the intervenors allege that applicants' data from the series 42 wells are not adequate to prove that the marl is continuous; b) the applicants state that its data to support an absence of voids, cavities or fractures in the marl include (1) 10,000 feet of marl penetration, (2) 900,000 sq. ft . of inspection on the upper surface of the marl, (3) inspection of 20,000 sq. ft of the
vertical face of the marl excavations and (4) a hydraulic head difference between the aquifers directly above the marl shows that the marl is an effective aquiclude; c) the applicants state that additional data is still being developed to supplement the series 42 well information; d) the additional information from the series 42 wells and new data on the marl has not yet been evaluated by the staff and said evaluations made available to the intervenors.
Q.17 Mr. IIeller, what are your conclusions with respect to marl continuity?
1 A.17 (lleller) . In my opinion, the data set now available for the marl formation beneath the Vogtle plant indicates that the marl is from . a groundwater contamination viewpoint ,
continuous and, provides an effective impediment to groundwater movement from the backfill above the marl to the aquifer directly below the marl formation . I base this opinion on my review of two recent reports:
(1) a report entitled "Geotechnical Verification Work - Report of Result" August 1985, attached to a letter from J. Bailey, Georgia l
Power Company, to Pts. E. Adensam, Nuclear Regulatory Commission dated August 23, 1985; and (2) a February 1986 report entitled "Vogtle Energy Generating Plant - Ground-Water Monitoring Program 3
July .< December , 1985" attached to a letter from J. Bailey to B. J., Youngblood, NPr dated February 6,1986.
Appendix B of the first report (August 1985) presents the geologic drill logs for hole numbers 900, 901, 902, 903, 904, 904B, and 905 which were recently drilled into the marl formation. These logs show the rate of penetration of the core drill in minutes per foot of advance. The logs tabulate notes on drill water levels , water return, and character of drilling as the drill was advanced into the marl. These logs do not indicate the presence of voids, as no rod drops were recorded. The logs show no loss of circulating water in the h oles , as would be expected if pervious materials or marl fractures were encountered which could allow drill water to leak out of the hole. The drill logs also show the result of water pressure tests conducted in the marl to measure the rate of water loss from the hole when sections of the hole were subjected to differing water pressures. The logs show that none of the holes had any measure-able water loss under the test pressures imposed. Thus, in my opinion , Appendix B of the August report provides evidence that the marl is continuous and there are no detectable paths for water to leak into the lower aquifer beneath the marl.
Figure 11 of the second report (Feburary 1986) provides evidence that the marl formation is an effective and continuous aquielude.
This figure shows the measured elevation of the water levels in piezometers 900, 901 and 902 versus time. In my opinion, if the
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4 marl was porous or fractured, the measured pore pressures would have. changed rapidly, in just a few days. Ilowever, the pressure changes took about two months. I also note that the rate of change of the pore pressures in each of these three piezometers is not grossly different , indicating that the average permeability throughout the depth of the marl is consistent and low. For these reasons, I believe the cvidence is now sufficient to conclude that the marl is continuous with respect to its ability to impede the movement of groundwater from the upper aquifer to the lower aquifer.
Q.18 Mr. Gonzales, will you explain what you believe the Doard's concern is regarding the direction of groundwater flow (material fact 4)?
A.18 (Gonzales) . The intervenors had alleged that applicants' data did not agree with applicante,' assertion that contaminated water would flow in a northwest direction toward Mathes Pond. The Board finds there may be merit to this allegation since it has identified three groundwater contour maps that appear to contradict each other.
Q .19 In your opinion are these maps contradictory? If so, in there a possibility that there could be groundwater flow from Vogtle in other directions than towards Mathes Pond?
A.19 (Gonzales) . The Board refers to three groundwater maps for the Vogtle area dated: November 1971, March 1980, and December
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e 1984. Copies of these maps are attached to this testimony and are marked as attachments one through three, respectively.
The November 1971 map shows groundwater conditions prior to construction of the plant. The highest groundwater level data point shown on this map is 162 feet. This highest level is located south of the plant. Northeast of the plant there is another high groun'. water level at elevation 161 feet . Both of these elevations are higher than the groundwater level directly underneath the plant which is at an elevation of 160 feet. These two groundwater levels, being the highest on the November 1971 map, indicate that there is a ridge in the groundwater surface that extends from northeast of the plant to south of the plant. A line drawn between these two high points marks the approximate location of this ridge. If the plant had been located such that it straddled the ridge , then a liquid spill from the plant to the groundwater table could have been considered to flow in more than one direction. Ilowever, this is not the case since the plant is located northwest of this ridge. Since groundwater can only flow downgradient , it is not possible for groundwater to move from an elevation of 160 feet beneath the plant to a higher elevation along the ridge which is located south of the plant.
The November 1971 map also shows that groundwater levels west of the plant are even higher at elevation 165 feet so there cannot be any flow in a westerly direction. Flow in a northerly direction is
4 also not possible because groundwater would have to move from an
- elevation of 160 feet beneath the plant to elevation 155 feet and then back up to an elevation of 160 feet . Clearly this is not possible. The only other direction in which groundwater can flow is in a northwesterly direction as was assumed by both the staff and the epplicant.
The next groundwater contour map is for March 1980. The staff agrees with the Doard that this map suggests that the flow fields around the plant are directed back toward the plant. Ilowever, thin map represents the effects of a temporary construction-related activity. Prior to construction of the plant, the groundwater level, directly below where the plant is now located, was at an elevation of about 160 feet as shown on the November 1971 map. Construc-tion of the power block structures required an excavation that extended well below the groundwater table. The major portion of this excavation bottomed out at elevation 130 feet which was about 30 feet below the groundwater level. In order to prevent sloughing of the excavation side slopes and to ensure dry firm working conditions, the :onstruction area had to be dewatered. The March 1980 contour map reflects the effects of this dewatering program.
Once construction was completed , the dewatering system was terminated . Therefore , the March 1980 map reflects what the staff expected would occur to the water table aquifer because of the dowatering program.
Since dewatering was a temporary condition, it was expected that grotuidwater levels would rise to approximately pre-construction November 1971 levels once the dewatering system was terminated.
T[11s is exactly what has happened as shown on the December 1984 contour map. The Board on page 23 of its November 12, 1985 Memorandum and Order recognized the similarity in the pre-construction and post-construction groundwater levels by stating, "The November 1971 map contours... are sufficiently similar to contours in comparable locations on the December 1984 map . . . to suggest to us the possibility that the 1984 map would , if all contours had been drawn in, look very much like the 1971 map."
The post-construction December 1984 groundwater contour map is similar to the pre-construction November 1971 map in that it indicates a groundwater ridge extending from south of the plant to northeast of the plant. Because of this ridge , there can be no groundwater flow in a southerly direction from the plant as discussed above.
Groundwater levels north and west of the plant are also lower than at the plant, but the gradient in these directions is flatter than it is toward the northwest. Since groundwater flow follows the path of least resistance, flow will be toward the northwest, as was assumed by b.:th the applicants and the staff, because of the steeper gradient.
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Q.20 Mr. Gonzales, will you explain what you believe the Board's concern is regarding groundwater travel time (material fact 5)?
A.20 (Gonzales) . Intervenors had alleged that applicants' calculation of 350 years and Staff's calculation of 15 years for groundwater travel time may be in error. In its Order on page 28 the Board expresses 4
concern that the model used by both the applicants and staff (Darcy's Law) to estimate groundwater velocity, may be inadequate for estiraating groundwater velocity over long distances where, as is the case at VEGP, the water table undergoes marked changes. The Board points out tha+ nt VEGP the water table becomes very steep as f.fathes Pond and the Savannah River are approached, i
The Board also expresses concern that because the observed values of velocity at the Savannah River Plant (SRP) had maxima of 69 and 72 feet / year, while the Darcy velocity at SRP was calculated to be 32 feet / year, the one dimensional Darcy model may underestimate groundwater velocity.
Finally, the Board notes that a three dimensional model may be superior since it would be capable of calculating estimates which take into account flow velocity changes as the water table gradient changes.
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Q.21 Mr. Gonzales, in your opinion , was Darcy's Law adequate for calculating groundwater velocity in view of -the marked changes in the water table in the vicinity of VEGP?
A.21 (Gonzales) . The staff agrees with the Board that the groundwater i
table steepens as it approaches Mathes Pond. !!owever, as discussed in Section 2.4.13 of the SER, the staff in determining 4
groundwater velocity and travel time conservatively considered only the flow through a relatively short distance in the plant backfill.
It was unnecessary to consider flow through a longer distance j toward Mathes Pond since radionuclide concentration from an accidental tank spill would be reduced to less than 10 C.F.R. 20 limits within the plant backfill . The backfill consists of selected sandy material, graded and compacted to meet certain specifications.
This makes the backfill essentially isotropic and homogeneous such that the groundwater gradient within this material is essentially uniform having no abrupt changes. Groundwater flow in isotropic-homogeneous materials is predominately laminar so its velocity can be adequately determined using Darcy's Law. Thus, the Darcy equation utilized at Vogtle was adequate.
i Q.22 Mr. Gonzales, is Darcy's law as utilized by applicant and staff inadequate in view of the observed values of velocity at SRP of 69 and 72 feet / year as opposed to the Darcy velocity at SRP calculated to be 32 feet / year?
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A.22 (Gonzales) . Although it appears that measured velocities are more than.twice the computed Darcy velocities, I do not believe there is an inconsistency because I think the velocities are unrelated estimates that cannot be compared. The 32 feet / year is an average velocity computed over an unknown distance having an average gradient of 0.018, a hydraulic conductivity of 7.4 gallons / day /
square foot (1.0 foot / Pry) which was determined by a pumping test in a sand lens within the Barnwell Formation , and an effective
, porosity of 0.20. In contrast to the 32 fect/ycar being an average velocity , I believe the 69 and 72 fectlycer are point velocities for the following reasons:
The maximum velocity obtained at SRP using the point dilution method is 69 feet / year as pointed out by tne Board. Ilowever, this method also resulted in a minimum velocity of 2.3 feet / year. The average of the two is about 36 feet / year which is approximately equal to the Darcy velocity. The velocities determined using the tracer tests ranged from 26 feet / year to 72 feet / year. The average of these velocities, 54 feet / year, is greater than the Darcy velocity but still within an acceptable range given the difference in the measuring techniques.
As discussed by the staff (Staley affidavit of July 1, 1985, page 2), the SRP velocity of 32 feet / year is an average value computed using Darcy's Law. From a cursory review of SRP reports DP-1M8 and DPST-83-829, the staff could not determine whether the point dilution method measurement of 72 feet / year or the tracer test i
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1 measurement of 69 feet / year were averages measured over defined distances or whether they were point measurements. However, because of the nature of these tests, the staff believes that they were point measurements.
Tracer tests are made by introducing a tracer such as a dye or salt into one point in the groundwater flow field and measuring the time interval for the tracer to errive at a downgradient location in the flow field . Since groundwater moves at a very slow velocity ,
observation locations for tracer tests usually have to be close together or the travel time, which is usually measured in terms of tens of years, will be excessively long. Because of this limitation, tracer tests usually provide estimates of groundwater velocity over a very short distance and can thus be considered point values instead of average values.
The point dilution method also gives an estimate of point velocity because measurenents are made at a single well and the estimated velocity is representative of only the aquifer material near the well screen.
The point to be made here is that average groundwater velocities cannot be compared with point values. An illustration of this can be made by referring to Figure 2.9 of the SER. As shown on this figure , the groundwater contours near Mathes Pond are much steeper when they are closer to the plant. The gradient between
two of the closely spaced contour lines near Mathes Pond is about 0.10. while the gradient over the entire distance from the edge of the plant backfill to Mathes Pond is about 0.006.
This means that the velocity close to Mathes Pond, which can be considered a point velocity because of the short distance over which the gradient was calculated, is about 17 times (0.1/0.006) greater than the average velocity calculated over the entire distance from the plant backfill to Mathes Pond. Thus the two velocities are not comparable.
Q.23 Mr. Gonzales, in your opinion is the use of Darcy's law adequate in view of the Board's concern that a more sophisticated model might i
be more appropriate to take into account flow velocity changes as the water table gradient changes?
A.23 (Gonzales) . Flow velocity changes would not be a factor since, as I have pointed out in ny discussion of flow direction , only the groundwater gradient within the plant backfill needs to be considered since radionuclide concentration from an accidental tank
! spill would be reduced to less than 10 C.F.P. 20 limits within the backfill. Because the . water table gradient does not change within i
the backfill, this Board concern is not a factor.
Q.24 Mr. Gon zales , in summarizing your testimony, do you have an opinion on whether an accidental spill of radioactive water on the l
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site could result in unacceptable levels of radioactive contamination of the water teble, and possibly the deeper aquifers under VEGP?
A.24 (Gonzales) . Besed upon a review of all the information that has been made available to staff, I conclude that there is no need for concern of contamination of the water table and underlying aquifer from normal plant operation or a design basis accident.
O.25 Mr. IIeller, do you also have an opinion on this question?
A.25 ( Heller) . I agree with Mr. Gonzales.
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9 PROFESSIONAL OUALIFICATIONS STATEMENT Lyman W. IIeller, Senior Task Mylager, Engineering Issues Branch, DSRO, NRR Telephone: 492-7646, Mail Stop 144 (Phillips)
I received Bachelor of Science degrees in Agricultural Engineering and Civil Engineering from the University of !!!!ncis in 1950 and 1957, respectively. I received Master of Science and Doctor of Philosophy degrees in Civil Engineering, with majors in soll and foundation engineering, from the University of Florida in 1959 and 1971, respectively. My academic honors include an fra O. Baker (class rank) award from the University of Illinois as well as membership in Tau Beta Pi, Chi Epsilon, and Phi Kappa Phi. Since joining the AEC (nor NRC) in February of 1974, I have reviewed or participated in the review of the geotechnical features of about 35 power plants and other nuclear facilities. Prior to my present position, which I assumed in December, 1984, I was Leader of the Geotechnical Engineering Section, NRR, for the past 11 years. I was employed for 9 years as Chief of the Analytical Section, Soil Dynamics Branch, Soils Division at the Waterways Experiment Station , U.S. Army Corps of Engineers . In this position, I was responsible for special analytical and experimental Corps studies in soil and foundation dynamics as well as earthquake engineering aspects of earth and rock-fill dams. The results of these studies have been published as Corps reports and as papers in national and international symposia and proceedings. Prior to my employment with the Corps of Engineers, I was employed for 6 years as a Research Civil Engineer in the Soile and Pavements Division, Civil Engineering Department, Naval Civil Engineering Laboratory, Bureau of Yards and Docks, Department of the Navy. In this position, I was responsible for soll and foundation l studies related to hurled protective structures to resist the effects of
! nuclear weapons as well as design criteria for piles and other waterfront l foundotions. My other professional experience includes University teaching appointments, from Instructor to Adjunct Professor, employment with a consulting engineering firm , and employment as a project and product engineer in industry. My research contributions have been l
recognized by membership in Sigma Xi-Scientific Research Society of America. I am a member of the American Society of Civil Engineers and have been a registered professional engineer (by examination) in the l
State of Florida (PE 7816) since 1959.
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, Raymond O. Gonzales Structural and Civil Engineering Section Engineering Branch Division of Pressurized Water Reactor Licensing-A Office of . Nuclear Reactor Regulation Professiona.1 Oualifications I am a Hydraulic Engineer in the Engineering Branch of the Division of Pressurized Water Reactor Licensing-A, Office of Nuclear Reactor Regulation.
I received my formal educational training at New Mexico State University where I received a B.S.C.E in 1965. I also attended an eleven month training program sponsored by the Board of Engineers for Rivers and Harbors of the Corps of Engineers in Washington, D.C. My experience prior to joining NRC, consists of seven years as a Hydraulic Engineer (hydrology), three years as a Water Resources Planner, and one year as a construction Engineer, all with the Corps of Engineers in Albuquerque, New Mexico; San Francisco, California and Washington, D.C.
I joined the NRC in February 1978 as a Hydraulic Engineer. In this capacity, I review and interpret the hydrologic and hydraulic aspects of applications for nuclear facility construction permits and operating licenses. These facilities include nuclear reactors, uranium mills, fuel fabrication plants and low level waste repositories. More specifically, I review the adequacy of flood protection designs of plants; determine the adequacy of safety related water suppliers, and evaluate the dispersion and dilution characteristics of nuclear facilities related to hydrologic engineering.
While at NRC I have reviewed the hydrologic engineering aspects of operating license applications for 10 nuclear generating plants and have written applicable portions of Safety Evaluation Reports and Environmental Statements for these 10 plants. I also presented testimony at the Midland and Palo Verde ASLB hearings.
From 1975 to 1978, I was a Water Resources Planner with the Corps of Engineers (COE) in Albuquerque, New Mexico. I was responsible for managing planning studies for flood control, irrigation, hydropower, water supply, fish and wildlife and recreation. In addition, I was responsible for coordinating study input from various planning disciplines including economists, hydrologists, designers and environmentalists, and for preparing cost estimates for planning programs.
From 1974 to 1975, I attended an eleven month training program with the Board of Engineers for Rivers and Harbors (BERH) in Washington, D.C. The purpose of this training was to obtain intensive experience in national water policy and multi-disciplinary water resources planning through direct involvement in BERH review of COE survey reports, basin and project planning, instruction and experience in policy formulation, and instructional methods.
The objective of the program was to increase my professional competence to the level required to perform and successfully direct water and trelated resource planning.
o e
Raymond O. Gonzales .
From'1966 to 1973, I was a Hydraulic Engineer with the Corps of Engineers in l Albuquerque, New Mexico and San Francisco, California. During the early part i of this period, (1966 to 1970) I assisted in hydrologic engineering studies of Corp.s of Engineers projects in New Mexico, Colorado, Kansas, Texas and )
Northern, California. This included collecting and analyzing hydrologic and meteorologic data for use in planning and design, estimating long-term water availability, determining hypothetical flood events for use in sizing structures of such Hydrologic as dams,reports.
Engineering channels,Inand thelevee systems, last part of the and preparing period 1971 to(portions 1973) I was Head of a Hydrology Section. In this capacity, I was responsible for planning, scheduling and assigning studies of water resources projects to engineers and technicians in the Section.
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