ML20137D440

States Concern on Outstanding Safety Issues Re Remedial Drainage for Excessive Groundwater,Settling of Structures Into water-filled clays,micro-earthquake Indications & Earthquake Design Deficiencies

ML20137D440
Person / Time
Site:	North Anna, 05000000
Issue date:	04/20/1977
From:	Allen J NORTH ANNA ENVIRONMENTAL COALITION
To:	Volgenau E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20136A555	List: IA-85-363, Submits Topics for Discussion at Commission 830708 Meeting W/Acrs.Topics Include Seismic Design Margins ML20136A550 ML20136E176 ML20136E418 ML20136E423 ML20136E621 ML20136E929 ML20136F618 ML20137D336 ML20137D440 ML20137D455 ML20137D472 ML20137D477 ML20137D494 ML20137D511 ML20137D540 ML20137D551 ML20137D557 ML20137D562 ML20137D570 ML20137D576 ML20137D583 ML20137D588 ML20137D598 ML20137D601 ML20137D609 ML20137D616 ML20137D621 ML20137D627 ML20137D635 ML20137D641 ML20137D646 ML20137D652 ML20137D659 ML20137D665 ML20137D670 ML20137D849 ML20137D867 ML20137D881 ML20137D911 ML20137D924 ML20137D951 ML20137D978 ML20137E016 ML20137E026 ML20137E044 ML20137E056 ML20137E075 ML20137E098 ML20137E113 ... further results
References
FOIA-85-363 NUDOCS 8508220483
Download: ML20137D440 (8)

Text

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AdRTH ANNA ENVIRONMENTAICOALITION P.O. BOX 3951 CHARLOTTESVILLE, VIRGINIA 22903 Er. Ernst Volgenau (800 293-6039 Director April 20, 1977 Office of Inspection and Enforcement U. S. Nuclear Regulatory Commiseion RECEIVED Aovis0RY copulTTit OM ,

Washington, D. C. 20555 IM ,- q3Y ., . I i77rlAtten SARGUARos

' "E Dear Mr. Volgenaus Hs It is our understanding that no nuclear plant in thev

• United States can be licensed to operate until you and yo'er. 3,10 11,12,1,2,3,4,5 #

staff of the Office of Inspection and Enforcement have g cleared any outstanding safety issues.

The following safety issues are of particular concern to the Coalition and developed after the 1974 fault hearings

a. Re=edial drainage required for -

exceseive grcundweter

b. Abncrmal and differential settling of key structures into water-filled clays (saprolite/halloyalte)

c. Micro-earthquake indications

d. Earthquake design defiolencies

e. Severe leakage problems in Westinghouse steam generators Supporting reascus for the Coalition's concern regarding YEPCO's Forth Anna nuclear station are stated briefly be-low, accompanied by questions which we would respectfully ask you to answer at your earliest ocnvenience.

a. Remedial drainage required for ozoossive groundwater Groundwater control is listed as a problem on page 2-19 of FRC's SAFElf E7AIDAT10N RIPCRT (SER) of June 1976 and remains a problem or " outstanding itema through the six EER Supplements issued to date.

L l

Although the latest supplement (#6--2/77) liets a

" system of. mall reints for groundwater control" as ons of the outstanding items, our interpretation of recent documents is that well points have been abandoned as an unsuccessful technique in favor of a system of drains.

NBC questions 'to VEPC0 on drain design _ (11/24/76)give the impression of an experimental approach, and raise'~g 0500220403 050722 bp l

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Remedial drainare (cont.) l doubts as to whether "the dewatering system will l protect the ptusphouse." If YEPC0 consultants made a " groundwater level prediction error" of 14'.

it would seen prudent to be skeptical of their engineering solutions for that error.

i Q. 1-as Ese any other nuclear plant been required

- to install a comparable system of reedial drainaget if so, where is it located, and what has been its orperience to datet Q. 2-as What length of time have you specified as an adequate pre-operational testing period for the drainage systes at North Annaf Q. 3-as If the drainage systen fails after the North

! Anna operating license is granted. what i sceoffic measure will ERC take at that timet i

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b. Abnormal and differential settling of key structures into water-filled clays learrolite/hallersite)

It would appear that the clay in the now famous faalt at North Anna was only the borinning of l foundation problems at the site.

"...an unerrected_ amount of settlement has been experi- <

enced by the service water pumphouse...several inches in magnitude and includes some tilting. This movement may have caused leaxage paths for impounded water to ,

leave the reservoir...

"By controlling aroundwater levels under the pasphouse, additional soaking and softening of the supporting sacrolites will be prevented, so that rapid settlement or tilt of the pumphouse should not occur. The seismie '

resistance of the soils...is enhanced by preventing excess pore pressures prior to a seissio event...a SIR 6/76 i '

But VIPC0's Amendment 53 appears to contradict the fore-going: " Operation of the dowatering erstes and local lowering 31 the groundwater to elevation 264' will cause an additional increase in effective stress...It is espected

, that the operation of such a dowatering system would there-fore gguse additional settlement, of the servloe water pump house..." Thus our first question must be:

4 1-bs Maa it been arperimentally determined yet at North Anna whether controlling groundwater levels will prevent settlement or g.gu,Ls,q, settle-ment beneath the service water pumphonsef 3

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Ab no m al e et tl ing. . . e apro11 t e/halloys i t e ( cont . )

The more that is learned about saprolite, the less desirable it becomes as foundation material at North Anna.

"...its compressibility under foundation and dike loadings is more than originally anticipated...these neantly detemined properties of the saprolites have significantly changed from those criginally presented

)Ly, the apolicant...the capability of this foundation is less than originally expected." 5.tl 6/76 "Most of the clay in the saprolite is halloyaite, a mineral difficult to orient and one which contains much water...The halloyaite content may account in part for the low relative densities obtained for the saprolite." Dr. R. Torrence Martin, 6/76 Am. 53 Dr. Martin had endeavored to determine "if tho'somewhat unusual field observed settlements were related to change in the fabrio of cisy t .terial." He emphasises that all samples contain halloyaite, a hydrated fona of kaolinite, Surely such analyses should hare been made at least as ,

early as 1970. It should not be g 1976 that the NRC is admitting that it has "little or no data on the cyc1fo response of a, saprolite," is finding that the  !

Army Corps of Engineers is in the suo "no data" position, with the consequent need to order cyclio triartal tests on samples of saprolite frcm North Anna in May of 1976 (In layman's tems, triazial testir.g determines the bearing capacity of a soil or how Isrge a load it can carry without settling, Cyclic data gives test informa tion on soil integrity during simulated earthquake con-ditions. " Low relative _ density" in the saprolite means the soil is " loose," according to the Corps, an i undesirable quality in nuclear foundation materials.)

The saprolite analysis of the Corps of Engineers, re-ceived by NRC on March 11, 1977, describes the North Anna semples as " highly plastic," " moderately plastio," "very mioaceous" with soveral repetit!cna of " silty sand,"

" silty clay," "spndy silt " "poorly graded." i When NAE 0 asked the Corps what the foregoing analysis in-plied in tems of the safety and integrity of the North  ;

Anna nuclear site, the answer was that "the report was  ;

not meant to head toward conclusions."

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Abnormal s et tl ing. . . s aprol it e/halloya it e ( cont. )

Since the Operating License Hearing for North Anna began over 3 months before the KRC received the Army's saprolite report. urcent questions regarding

, " conclusions" must be raised:

Q. 2-b Since the North Anna nuclear station was designed and built without information on "the dynesia behavior of saprolitio soils,"

now found to be weaker than anticipated, how asa North Anna's design withstand pos-sible lack of integrity in saprolitio foundations?

Q. 3-b: What is the extent of saprolitio " soft nones" beneath other structures exhibiting abnormk1 settling such as the turbine' and auxiliary buildings?

Q. 4-b s What is the significance of a new report ,

of "overstressed service water pipe...due to the differential settlement of the ser-vice and turbine butidinge" for Unit 27 (IE Xpt. Nos.' 50-338/77-2&50-339/77-1)

Q. 5-b Given that saprolitio soils are only now being intensely studied, on what experi-ential or experimental basis can prediations be made about the future ocurse g settle-men _t at North Annaf

o. Micro-earthquake indications In 1974, the Atomic Safety and Licensing Board of the Show Cause Hearing on North Anna's fault siting "found reasonable assurance that Lake Anna would not induce seismio activity."

Subsequent microseismio events have proved the Board wrong.

Not only do microcarthquakes ring Lake Anna (please see attached Dames & Woore map), but "microsarthquake activ

,_i y, in the vloinity of Lake Anna appears bounded,~ cr nearly so, to the northwest arrrerlmately coinoident with ar), astrapolation o_f, the plant site faulting_,o t_c, gt northeaet."

XRC's gafety 8urriesent #:! goes on to say that "because there is a tenuous relatlorship between the limite g

. .. " I  ;

Micro-es.rthquake indications (cont.)

occurrence of microcarthquakes and a boundary approxi-mately defined by an extrapolation of, the faults in the vicinity of the plant site, we require continued opera tion of the 17 station network for at,least t one yer conciencing Auguet 1.1976 in order to provide dati. to determine if this relationship dissipates or char.ges in such a way that additional action may be 1equirt.d..."

Q. 1-os If the minimum one year cf monitoring of activity along the Kc:th Anna fault will not be concluded until August 1,1977, n:ust not the board for the Operating License delay its decision until that datt;f Q. 2 es If the correlation between seiseio activity and the Forth Anna fault grows, what speciffo

" additional action" would the 701C requirst FRC's Regulatory Guide 1.127 notes in regard to an artificial lake that "several years may pass before the foundation and structures have fully adjusted to the loade." The movement ar,cund Iake Anna is partioularly disturbing in that "the largest rate of activity seems _

to be coeurring at the intersection of Feuschel's_

Linoament (a possible recional fault) and the lake" per NRC seismelogist Reiter.

Q. 3-os Given that the science of microseismio monitor-ing and prediction is considered in its in-fancy by its own practitioners, on what basis will the IUIC decide that microseismio activity at Forth Anna augurs adequate stability for

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the 30-year life ,of g reactore?

4 4-ce What studies has the FRC done of the possible relationships between mieroseismic activity, regional faulting (Feusehol's Lineament, Staf- '

ford faulting et al), and the weakness of

.saprolite a3 a, foundation asterialt 4 ,Marthauake _deslan_ deffef eno tes North Anna reactore are 40% defielent in solanio destEn, j

In its January 17, 1977 letter on North Anna, the Advisory Committee on Reactor Safeguards (ACRS), recognizing *unter-i tainties" about Eastern earthqukkes, recournended that new reactors have a "minimu:n safe shutdown earthquake (CCE) ,

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of 0.2g acceleration" whereas North Anna's SSE design is only .12g, just 60% of the recommended minimum.

Evidently the fact that North Anna is already con-structed makes its 40f, deficiency " acceptable,"

although Drs. Page and Okre st admit to uneasiness.

Q. 1.d Does !UtC Inspecticn snd Enforcement, in the light of cumulative foundation problems at Korth Anna (abno11 cal settling, excessive groundwater, suspect saprolite) also find a 40% design deficiency " accept-able"?

Westinghouse's Seismic Unacceptability "The seismic testing of Westinghouse...is unacceptable.

It cannot be determined that the equipment and instru-ments can perform their safety functions during and sub-.

sequent to a seismio event."

The foregoing 10t0 statezent of January 3,1975 is essentially repeated in Mr. Stello's evaluation of June 26, 1975. It is our understanding that the sano evaluation was current in 1977.

Q. 2-d Is it still the position of the 19tc that E electrical and ocutrol equipnent aannot per-form safely during a selsnio event?

4. 3-4: If the KRC evalu ition has changed eince 1975, what chsnges in J, equi;rnent have brought it about? Are there still "re-qualification" procedures required at North Annaf

_Seismio design of the Ker,th Anna dam Uhen the North Anna dam was built, neither MRC nor the public knew that there were 12 faults beneath it.

r Neither did they know that a microsetemio network would pick up a cluster g earthquakes northwest of the dem, some strong enough to "exet,ed the dynario range of the instrumentation" bd all suggesting a " Dip-Slip Fault." _

Q. 4-d Is the Forth Anna dar designed to withstand activity on a nearby fault or activity from from.the point where Neuschel's Lineanent transects the reservoirt

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e. Severe leakage problems in Westinghouse steam generatore YZPCO's nuclear operation at Sarry has been badly crip-pled by leaking steam generators. Its September 15, 1976 steem generator tube rupture was reported to Congress in NUREG 0090-5which repcrted "generio implications" under study.

VEPCC onlis North Anna a " mirror image" of Surry, and 20tC/

Atlanta as of 4/22/77 reports the leakage problem in W ,_

steam generators of this vinta6e still " hot" and "not solved." NRC also said that brackish water has not been proved the cause of the problem. ( This would appear to cast doubts on the statements of the Y1PCO chairman that "no significant deterioration of steam generator tubes" is anticipated at North Anna. )

Q. 1 es Since NRC considers the leaking steam generator problem unsolved, how can there be " reasonable assurance" of .

proper steem generator operation at North Anna?

Q. 2-es Since steem Benerator leakage causes significant increased radioactive emissions, and since TDD0 has been unable to calculate or control these emissions properly at Surry, what

" reasonable assurance" is there re-garding proper calcult.tions er con-trols at North Anna?

(N.B. IE Inspection Report Nos.

50-280/76-18 and 50-281/76-18)

4. 3-e What tests have been done to determine the effect of the pessible presence of heavy metals in the water at North Anna upon ohemistrf in the otosm generator tubing?

This last question encampasses all of the foregoing:

4. a es Will the Office of Inspection and Enforcement e

provide knowledgeable persons to give testi-mony on safety issues a, b, o, d, and e at the Esyi2 Operating License Hearing?

In relation to the last question, we ohn11 send a copy of this letter to the Atomio Safety and Licensing Board and ask them to consider it the Coalition's formal request for t hem to explore these issues on the record, noting that all. of the problems have developed since_ the 1974 Show Cause fault hearing and lack ASLB evaluation. Thank you.

Most sincerely, cca ASL3 June Allen NAEC President

a-AT$Acm. B .'

t o' KK RAD tus O N O 9  ;

MICROEARTHQUAKE g*e ib g , , EPICENTER MAP  ;

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%g 1 JANUARY 24, 1974 JANUARY 1, 1976

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1973-D&tES & MOORE Report dismissed Lake Anna's seismic influence as

" insignificant." r

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1974 --Atomic Safety and Licensing Board "found reasonable assurance that Lake Anna will not induce seismic activity. The Licensing Board for Units 3 and 4 agreed with this ccnclusion, but required, as a condition of the construction permits fcr Units 3 & 4, the installa-tion of a dense seismic network to conclusively dernenstrate whether seismic activity is asscelates with the faults at the site and whether Lake Anna is af fecting that activity..."

1976 - 108 micrcearthquakes at site since 1974 86 within 10 Km, almost all clustered around Lake Anns... notable inerense in micrcearthquake

' activity daring time of heavy rains vihen lake level rose one foot...

22 events concentrated near the de appear to outline a DTr7 fault.

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