ML20079M013

Testimony of Hh Woodard on Contention 106 Re seismic-related Site Problems Discovered Subsequent to Issuance of Cp. Certificate of Svc Encl.Related Correspondence

ML20079M013
Person / Time
Site:	Byron
Issue date:	02/22/1983
From:	Woodard H BELOIT COLLEGE, BELOIT, WI, LEAGUE OF WOMEN VOTERS OF ROCKFORD, IL
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8302230544
Download: ML20079M013 (10)

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1 C'9lrJrc 23 FE9 22 pg gy UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION  ?,]:;; ,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

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Conunonwealth Edison Company ) Docket nos. 50-454 and 50-455

) Operating License Byron Station, Units 1 and 2)

)

PREPARED DIRECT TESTIMONY OF HENRY H. WOODARD ON BEHALF OF ROCKFORD LEAGUE OF WOMEN VOTERS REGARDING CONTENTION 106 SEISMOLOGY i February 1983 l

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l I. INTRODUCTION

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Q. 1. What is your name and position?

A. Henry H. Woodard, Chairman of Geology Dept., Beloit College Q. 2. What are your qualifications and. experience?

A. I have been Chairman of the Geology Department at Beloit College, Wisconsin since 1955.I have an A.B. degree in Geology from Dartmouth College and and M.A Degree in Geology from Dartmouth College. I also have a Ph.D. degree in Geology from 1 the University of Chicago. I have worked for the U.S.G.S.

and have been consultant and done research for geological work in the U.S. and 30 different countries.

My current research is cm structural geology and metamorph-ism of precambrian rocks in the eastern contact zone of the Vermilion Batholith in northern Minnesota; mineralogic dev-velopment of the basal unit of the St. Peter Sandstone along

_along: the eastern flank of the'Wiscohsin Arch; the relation- '

ship between sanidine feldspar and lead-zine mineralization in the Mississippi Valley-type deposts of western Wisconsin and south-central Missouri. A complete list of my experience, research and a partial list of Professional Papers is attached.

II. STATEMENT OF CONTENTION Q.3 What is the purpose of your testimony?

A. The purpose of this testimony is to respond to contention 106 as admitted by the Board as follows:

There exist serious seimic related site problems dis-covered aubsequent to the construction permi* herein which indicate that the seismic design for Byron is not such

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2 that there exists assurance that these problems are adequa-tely resolved in accordance with applicable regulations, in-cluding, but not limited to, 10 CFR 50.57 (a) (3) (1), 50.57 (a) (6) and 10 CFR Part 100, Appendix A. Specifically, the Rockford League of Women Voters contends that due to the lack of reliable information regarding the causes of earth-quakes which have been experienced in northern Illinois, Edison should be required to perform strain gauge tests on faults cutting basement rock located in the northern Illinois region where earthquakes of Modified Mercalli VII or greater intensity are expected to occur.

Further, recent evidence from the central poertion of the U.S. shows that neither the Byron designated safe shut down earthquake peak ground acceleration value of 0.20 g nor the operating basis earthquake peak ground acceleration value of 0.09 g are sufficeently conservative. Ground acceleration significantly greater than both of these values are possible at the Byron site.

In addition, it is not known if the recently discovered Plum River Fault is a capable fault. This fault is known to '

approach the Byron site within 5.3 miles and may even be closer if the fault extends further to the east.

. The results of my review of some of the important matters en-  :

compassed by this contention are summarized in the following paragraB hs.

R III. DISCUSSION OF ISSUES l

Seven " strong" earthquakes have been generated in northern Illinois since the first one was. recorded in 1804. According

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to various records summarized by Heigold (19721 none of the [

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earthquakes exceeded VIII on the Modified Mercalli scale. Very little is known about the origin of any of these seven earth-quakes. Theory of earthquake generation within most parts of the central United States is poorly developed but most geolo-gists and seismologists assume that the earthquakes are gen-erated on old fault structures which are present within the crystalline basement rocks of.the earth's crust. At least two ,

of these old basement structures are known to exist within the near vicinity of the Byron nuclear power station site, the Sandwich Fault zone and the Plum River fault zone. One of these, the Plum River fault zone, is known toexist within 5.3 -

miles of the site. The Byron site is a few miles north of the apparent junction of these two differently oriented fault zones.

If theory is correct regarding the generation of earthquakes in northern Illinois then presumably either of these two extant major zones could produce earthquakes. One way of testing the

usibility of this would be to collect information from basement rocks on either side of these fault zones to see if differential strain developed in opposite sides. Rapid relief of differential l strain developed in opposite sides of fault zones is what causes the generation of most earthquakes. To my knowledge no such strain data are known from either the Plum River or the Sandwich fault

! zpnes. In f act , there probably isn't andy such data available from l

anywhere in the basement rocks of northern Illinois.

Data from an earthquake swarm from the central U.S. recently l ,

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have been collected near Conway, Arkansas (Johnston, - 1982)2 . This j data suggests that MM intensities are not satisfactory for deter-mining seismic design characteristics of engineering projects.

Specifically, on July 5, 1982 an earthquake was recorded t

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which had a magnitude of 3.8 (approximately equal to MM IV-V).

The S waves of this earthquake generated peak horizontal ac-2 celeration values at the recording station of 0.59 g . This is far in excess of either the Safe Shutdown value of 0.20g or the Operating Basis value of ) .)9g designed into the Byron nuclear, power station.

No ground acceleration data are available for any of the -

seven earthquakes that have occurred recently in northern Ill-inois, and until such data are available, the effect on the Byron structure of potential earthquakes ranging in intensity from IV to VIII on the Modified Mercalli scale remains unknown.

References Cited 1.Heigold, P.C. ,1972, Notes on the earthquake of September 15, 1972 in northern Illinois: Illinois State Geological Survey, Environmental Geology Note # 59. l

2. Johnston, A.C., 1982, Arkansas earthquake laboratory: EOS,

v. 63, # 50, December 14, 1982.

Q. 4. Why is this issue one of importance in the licensing process for Byron?

A. Current regulations (CFR 50.57 (A) (3) (i) and CFR 50.57 (a)

(6) require that conservative seismic design values be used for siting of nuclear power plants and the subsequent building of plant structures and equipment. The seismic design for Byron needs to be reevaluated and also there is a potential need to reevaluate calculations for Class 9 accidents which are required to be considered in Emergency Planning. j According to 10 CFR Part 100, Appendix A, if the Plum River Fault is a capable fault and is within 5 miles of the Byron 4

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nuclear power station site boundary, the plant must be built to a stronger seismic design.

'IV.RECOMMENDA5 IONS.i

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A careful reevaluation of the seismology of the Byron plant site should be made, using strain gauge tests and other current in-formation.

A site specific PRA for Byron may be needed.

Although the major plant structures are completed, some mod-ifications could be made if the seismic design is not conservative enough.

The analysis of Class 9 accidents required for Emergency Planning could be evaluated.

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BIOGRAPHICAL SKETCH WOODARD, HENRY HERMAN, JR.

Education A.B. Geology, Dartmouth College 1948 M.A. Geology, Dartmouth College 1949 Ph. D. Geology, University of Chicago 1955 Professional Experience

1) LT, U.S. Navy 1945- 1952

2) Teaching Fellow, Dartmouth College 1948- 1949

3) Instructor, Illinois Institute of Technology 1950

4) Instructor, Northwestern University 1951 *-1952

5) Instructor to Professor, beloit College 1953- 1983

6) Chairman, Dept. of Geology, Beloit College 1955 .1983

~7) Geologist,US' Geological Survey, Lake Lahoutan 1947- 1948 Proj ect, Nevada

8) Geologist and Party Chief, Newfoundland Geological 1955 Survey, NW Coast Project

9) Geological work in more than 30 different countries 1962-1983 i

dealing chiefly with major structural features, igneous activity, metamorphism and active volcanism

10) Leader of field parties to most major geological 1958- 1983

-areas overseas of North America and to several localities

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11) Consultant on several projects in the Northern 11.1952- 1983 Southern W1. area dealing with local geological conditions and their inf]uence on groundwater flow and contamination, and possible production of var-

ious mineral substances Current Research

1) Structural geology and metamorphism of precambrian 1971- 1983 rocks in the eastern contact zone of the Vermillion Batholith, northern Minnesota l

, 2) Mineralogic development of the basal unit of the St. Peter Sandstone along the eastern flank of the Wisonsin Arch.

3) Relationchip between sanidine feldspar and lead-zinc mineralization in the FEssissippi Valley-type deposits of western Wis. and south-centrhl

Missouri..

4) Chemical and mineralogical zonation in rocks of Montazuma Basin, central Colorado.

Partial list of Professional Papers:

l 19.51 The geology and paragenesis of the Lord Hill Pegmatite, Stoneham,  !

Maine: American Mineralogist, v. 36, p. 869-883 l' 1951 Report on the Geology of a por~ tion of the Spencer Lake Area, Maine: Report of the State Geologist, Maine Development Commis-sion, p. 68-77.

1957 Geology of Port Saunders-Castor River area, West Coast:

Newfoundland Geological Survey, Report, No. 10, 45 p. s 1957 Diffusion of Chemical alements in some naturally occurring sil-  :

, icate inclusions; Journsi Geol.ogy, v v.65, p. 61-84.

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1968 Contact alteration in the north wil of the Cape Neddick gabbro, Maine:.Jounal Geology: v. 76, p. 191-204, 1972 Syngenetic Sanidine beds from Middle Ordovician Saint Peter Sandstone, Wisconsin: Jounal Geology, v. 80,p. 323-332.

1972 (with Krueger, H.W.) Potassium-argon dating of sanidine-rich beds in the St. Peter Sandstone, Wisconsin: Geological Society America, Abstracts with Programs, v. 4, no. 7, p. 568-569.

1974 Syngenetic sandine beds from Middle Ordovisian St. Peter Sandstone, Wisconsin: a reply: Jounal Geology, v. 82, p. 116-119.

1978 Field excrusion to the Big Island and Maui, Hawaii Dept. . ~ .

Geology, Beloit College, 275 p.

1980 (with Flemming, A, Heinz, D. , and Lee , R.) Geology of the south-vastern contact zone of the Vermilion Batholith, Minnesota:

Institute on Lake Superior: Geology, 26th Annual Proceedings and i

Absrracts.

1981 Southeastern Arizona geology field trip guide book: Dept. of 4

Geology, Beloit College, 3rd Ed., 100 p.

1982 (With Burrell, S. and Stenstrom, R.) Field guide to the geology of Samoa, Tonga and New Zealand: Vol I, Samoa, Tonga and North Island, 250 p., Vol. II, South Island, 109 p; Dept. of Geology, Beloit College.

1982 (With Wirth, K. , and Crouse, G.) Geology of the Friday Bay quadrangle, Minnesota: Institute on Lake Superior Geology, 28th

~. Annual Proceedings and Abstracts.

1983 Geologic field guide to the central and sou,thern Appalachian Mountains: Dept. of Geology, Beloit College, 9th Ed., 150 p.

1983 (with Daszuba, J. ) Folded rocks in the eastern contact zone of the Vermilion Batholith: Institute on Lake su 29th Annual Proceedings and Abstracts (in press)perior Geology, .

1983 Geologic field guide to part of central Wisconsin: Dept. of Geology, Beloit College, 9th Ed., 12 p.

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, UNITED STATES OF AMERICA

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.- f[gpg P2:pg BEFORE THE ATOMIC SAFETY AND LICENSING BOARD . . -. .

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In The Matter of )

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COMMONWEALTH EDIS0N COMPANY ) Docket Nos. 50-454 OL

) 50-455 OL (Byron Nuclear Power Station, Units 1 & 2) )

)

AFFIDAVIT OF HENRY H. WOODARD Attached is the Direct Testimony of Henry H. Woodard on behelf of the Rockford League of Women Voters regarding Contention 106 Seismology. The testimony is true and accurate to the best of my knowlege, information and belief.

9 Q A*f f 9 Hen", ... Woodard l

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. ' I, t ; r Subscribed and sworn to before me this /5 day of Feruary, 1983 M<:Lc.

NOTARY PUBLIC - 4/ w r W p [

My commission expires h</-ef /f, /9 3  !

SERVICE LIST . ; > .,, , ,

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COMMONWEALTH EDISON COMPANY--BYRON STATION Docket Nos. 50-454 and 50-455 '83 g 22 pp,.g Ivcn W. Smith, Es .

Administrative Ju ge and Chairman Mr. Steven Ms. Mitzi A. C.Young Goldberg/gMCI'gv Atomic Safety and Licensing Office of.the Executive Board Panel Legal Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Richard F. Cole Joseph Gallo, Esq.

Administrative Judge Isham, Lincoln & Beale Atomic Safety and Licensing Board Suite 840

, U.S. Nuclear Regulatory Commission 1120 Connecticut Ave., NW.

Washington, DC 20555 Washington, D.C. 20036 l Dr. A. Dixon Callihan Douglass W. Cassel, Jr.

Administrative Judge Jane Whicher Union Carbide Corporation BPI P.O. Box Y Suite 1300 Ock Ridge, TN 37830 109 N. Dearborn Chicago, IL 60602 .

Alan Bielawske Isham, Lincoln & Beale Ms. Diane Chavez Three First National Plaza SAFE Chicago, IL 60602 326 N..Avon.St.

Rockford, IL 61103 David Thomas, Esq.

Kent Law School Clinic Dr. Bruce von Zellen 77 So. Wacker Dr. Depart. of Biological Sciences Chicago, IL 60621 Northern Illinois University DeKalb, Illinois 60115 -

j Atomic Safety and Licensing l Board Panel Atomic Safety and Licensing {

! U.S. Nuclear Regulatory Commission Appeal Board Panel (

l Washington, D.C. 20555 U.S. Nuclear Regulatory Commission  ;

i Washington, D.C. 20555 -

Chief Hearing Counsel Office of the Executive Secretary Legal Director Attn: Chief Docketing & Service ' .. -

U.S. Nuclear Regulatory Commission Section Washington, D.C. 20555 U.S. Nuclear Regulatory Commission i Washington, D.C. 20555 i

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e CERTIFICATE OF SERVICE 1 I hereby certify that copies of the testimony of Dr. Henry Woodard in the above captioned proceeding have been served oV\ the service list by deposit in the United States mail, first class, this 15th day of February, 1983.

h k$ Y s+n h Betty Jofirpon, Chairman of the t B ron Nuclear Power Plant Intervention Com. L o the League of Women Voters of Rockford,IL J