ML20137X062

Intervenors Testimony Scheduled for 860311 Re Contention 7 Concerning Groundwater Contamination.Related Correspondence

ML20137X062
Person / Time
Site:	Vogtle
Issue date:	02/23/1986
From:	CAMPAIGN FOR PROSPEROUS GEORGIA (EDUCATIONAL)
To:
References
CON-#186-279 OL, NUDOCS 8603050190
Download: ML20137X062 (8)

Text

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DOCHETED dELATED CORRESPONDEt%

'86 MAR -3 All :53 February 23, 1986 0FFICE Of 00CKETING. :t BRANCH United States of America Nuclear Regulatory Commission i

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In the Matter of Georgia Power Company, et al. (Vogtle Electric Generating Plant, Units 1 and 2); Docket Nos. 50-424 (OL), 50-425 (OL)

Intervenors' Testimony Before the Atomic Safety and Licensino Board March 11.

1986: Contention 7.

Groundwater Contamination I

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8603050190$hbo24 Summary PDR ADOCK PDR T

The summary includes groundwater contamination comments from this

document, and from intervenor documents previously presented to the ASLB board.

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1.

The hydrogeologic data collected by VEGP appears to be in-adequate for a number of reasons, e.g.,

insufficient exploration, bb

9 no inferential treatment of the data, and insufficient data.

2.

There has been no statistical treatment on the recently col-lected marl thickness and permeability-groundwater treonitoring data.

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3.

The settlement of tne marl may lead to.a reauction in the in-i tegrity of the marl and, as a result of the deformation, may provide pathways for contamination of the pquifers under VEGP.

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4.

The numerous wells and other structures through the surface and subsurface soils may become pathways for contaminants to breech the marl.

Although the data indicates not exclusively so, Dupont has postulated that well casings were the pathway for.the contamination that has occurred at the SRP.

5.

The standard deviations of the hydraulic conductivities i

recentl y collected for ' subsurface soils under the VEGP power

.I block exceed customary and acceptable levels.

6.

The well-grouting method, used by VEGP to close covered

wells, may not have filled all well voids (Intervenors' Analysis).

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7.

NRC Staff should provide groundwater contamination results

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from all other NRC licensed facilities in order for the public and the intervenors to be able to test the efficacp_of the NRC

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j licensing process / procedures on the potential for groundwater contamination.

B.

The VEGP groundwater monitoring program's first monitoring report was recently received by intervenors, but without chemical analysis of any of the monitored wells.

Monitoring results I

without chemical analysis of chemical and, hazardous constituents is deficient and inadequate.

The adequacy of the VEGP baseline can not be confirmed without this data., VEGP should not be al-i lowed to operate without first publishing a

current chemical j

analysis of the groundwater.

9.

The VEGP area &lready receives significant levels of tri' tium

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l and strontium-90 releasod from the SRP (Lawless, 1985).

10. The improved surface runoff and apparently significantly dif-ferent K's between the power block and surrounding area subsur-face soils may be a.cause of some concern.

11.

~6-groundwater travel time, calculated'by VEGP.;cpuld lead to

,a significant undercalculation of.the actual travel times as was done by SRP.

.Whereas VEGP is attemptLng to

mprove its hydrogeologic

data, intervenors are not saticfied wiyh the data at this point.

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12.

Intervenors. agree psith the A9LB Ruling om the direction of groundwater flow and have nothing more to. add at this time.

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yn;c,a Introduction In the NRC Atomic Safety and Licensing Board's (ASLB) Memorandun' and Order of November 12, 1985, Ruling on Motion for Summary Dis-Groubdeater Contamination, position of Contention 7

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hereinafter referred as the ASLB Ruling, khe ASLB denied the mm-j tion to strike except for N genuine issues of m.aterial fact raised by intervenors.

In accord with the request -by the ap-plicants for Plant Vogtle (VEGPt, the ASLB did agree to strike all other~intervenor isMues with respect to the groundwater contention.

Subsequently, the ASLB -has requested testimony f rom each of the parties on this contention.

.The testimony for inter-venors en the groundwater contention, as requested by the ASLB, is contained herein or has been previously submitted to the ASLD 1

in prier documents.

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The discussion by intervenors of the November 12th ruling by the ASLB was submitted to the ASLD December 15,1983: Analysis of the Atcmic Safety and Licensing _Soard's November 12.

1985 Memorandum and Order (Rulino _on Motion f or Summa 1Qisposi tion of Contention I

i; 7 re: Groundwater Contentical.

This discussion will be referred

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to in the interbenors' testimony as the intervenors' Analysis.

Other information that will be referred to is the Intervenors' Response to Aoolicants' Notion for Summary Disposition of Conten-1 tion 7, described as,the intervenors' TJJ!itgqgnsy.

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9-Adequacy of Geological / Hydrological Exploration i.

Intervancrs had previously alleged that applicants had not 1

statistically treated the VEGP hydrological datag Applicants

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agre,ed (Eulinn, p.10),

but the ASLB stated the burden of proof 3

was on the intervenors to show that such treatments were customary, or that the VEGP data was flawed.

This suggests that the interveners, with negligible resources, by def aul t era responsibla to prove the worthiness of applicants engineering practices or hydrological data, especially if such anal ysi s even-4 tually finds deficiencies; and that only customary industrial nucinar practices are the acceptable practices. Both of these, if truly suggested, could

. lead to the licensing and' the improper operation of another nuclear facility in the Central Savannah River Area (CSRA) with the' potential to damage the local environ-i ment as has the Savannah

'Ri ver Plant (SRP)

(Lawl ess, 1985).

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Instead, it would be better to have stronger engineeding lander-4 ship and oversight from the NRC Staf f. Tne lack of strong leader-ship and ineffectual oversight by the DOE at th.e SRP contributed l

1 to significant environmental problems at GRP and si gni ficant releases into the 4EGP operational area flawlass, 19952.

4 The lack of a,stati sti cal treatment may be related to the in-adequate exploretion of VEGP hydrogeology.

For

example, ap-o i

plicants recently completed hydrogeol_ogi c _ te.stina_at_the VEGP J

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, s' power block (Papadopulos, 1986).

The average hydraulic conduc-tivity K calculated from only 4 power block wells at this testing has a standard deviation greater than is customary practice, im-i plying that the engineering procedures used to determine K by-a VEGP may be questionable at worst, or the new data collected is confounded cr uncertain at.best (Bouwur,

1978, p.132).

Therefore, since a statistical reatment is an important con-sideration whenever hydrologeological data is being gathered,.the VEGP hydrological data should be statistically treated.

Further, the 4 power block wells &rie lo0&ted in backfilled and compacted material that has been in a subsurf ace area of plastic deformation (Analysis; Bechtel, 1986).

The defornaation may have had thG effect of changing at random the fill's hydrologic coefficientsy and may have opened or may contribute to addi tional flow pathways such as the observation wells at the power block, or with head-reversals, via well TW-1 or well NU-1 down through the blue marl (Bechtel, 1986, figures 4,6,7,and 10s Ana)vsis).

i Uncertainty in data on Marl ThicPnuss and Permeability Statistical treatment of the marl thickness and perceability data should be provided (Bouwer, 197.9).

Applicant or staff should au-i csrtain whether the collected data fits within a chance distribu-l l

ti on or not (cf. G_n a l vsi_ s).

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s Data on Marl Continuity e

Part of the concern on marl continuity is that the marl charac-terization data cet appears to be deficient, and also because of VEGP, settlement centributing to the potential for numerous path-ways into and through the earl via wells (Analysis).

Go the cne

hand, the marl must be satisf actorily mapped, but on the other, breeching the integrity of the marl f ri order to moniter the marl may be self-defeating by adding the potential for additional con-taminant flow pathways.

Statistical treatments of the data n.ay.

increase confidence in the data already collected and prevent the need to punch random holes into the marl ( Anal ysi s).

C Direction of Grouindwater Flow Intervenors have nothing to' add to the Ruling at this time, i

Groundwater Travel Time Of concern to intervenors is not only water travel time through the power bic:k suusurface outward by predicted Darcian flow, but I

since the power block subsurf ace soil has a significantly dif-l f erent hydraulic cunductivity than subsurf ace soil

nearby, the

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,r' potential for rapid water transpcrt throuch fissure-s in the back-filled material exists.

One of the methods for ascertaining the sufficiency of the hydrogeologic is to use statistical inference on the data sets.

The lack of the use of inference in the past may have unnecessarily confounded the data that has been ecl-lected te date.

Such may be the case with the use of the slug test to collect hydrogeologic data in an unconfined aquifer at VEGP frera only 4 power block wells or source poin ts (Bouwer, f

1978; Papedopulos, 1986; Analysis).

1 Intervencro believe that their discussion from Snalzgin on groundwater travel time is relevant and include it here.

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