ML20063E111
| ML20063E111 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/24/1982 |
| From: | Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Miraglia F Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0895, RTR-NUREG-895 SBN-312, NUDOCS 8208300142 | |
| Download: ML20063E111 (6) | |
Text
PUBLIC SEAVICE S M W STA M e.,;.u., om:
Company of New Hampshw e 1671 Worcester Road Framinoham, Massachusetts 01701 (617) - 872 - 8100 August 24, 1982 SBN-312 T.F. B7.2.3 United States Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Mr. Frank J. Miraglia, Chief Licensing Branch No. 3 Division of Licensing
References:
(a) Construction Permit CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b)
USNRC Letter, dated July 30, 1982, " Comments on Seabrook DES", F.J. Miraglia to W.C. Tallman
Subject:
Applicants Response to Comments on the Seabrook DES
Dear Sir:
In response to your request in Reference (b), our responses to comments you received on NRC's Draft Environmental Statement related to the Operation of Seabrook Station, Units 1 and 2 (NUREG-0895) are attached.
Very truly yours, s)
John DeVincentis Project Manager RAM /so Attachment 06 F208300142 820824 gDRADOCK 05000443 PDR
ATTACBMENT Applicant's Response to Comments Received by NRC on the Draft Environmental Statement - Seabrook Station (NUREG-0895)
DEPARTMENT OF HEALTH AND HUMAN-SERVICES, 6/21/82, PAGE 1, BOTTOM PARAGPAPH-Additiona1 'information on this subject was supplied to the sta'ff in applicant's response to ER-OLS RAI 240.25._ While some of the assumptions-differ between the NRC.and applicant's analysis, the conclusions are basically
-the same.
It may te helpful to refer the commenter to the complete Liquid Pathway Generic Study (NUREG-0440).
\\
SEACOAST ANTI-POLLUTION LEAGUE, 7/1/82, COMMENTS BY MR. RICHARD L. KAUFMAN, PAGES 1-2 4
Biocide U age, Question Number 2:
s Previous to the decision to utilize continuous low-level chlorination, sodium hypochlorite solution was to be applied as a supplemental treatment to thermal back flushing primarily for slime control. As the primary method in the control of hard shell fouling organisms, a higher level of 2.0 mg/l applied at the intakes and monitored at 0.2 mg/l at the discharge transition structure is needed to effectively control hard shell and slime organism growth.
Biocide Usage, Question Number 3:
The concentrations of chlorine and bromine residuals discharged at Seabrook Station will be minimal (as addressed in applicant's response to ER-OLS RAI 291.19) and should not add to the concentrations in the systems of marine organisms. As a result, buildups should not occur in the human food chain.
Biocide Usage, Question Number 4:
6 Table 4.3; chemicals added to discharge should read as 5.5 x 10 instead of-5.5 x 105 for chlorine yearly discharge in pounds.
The sodium hypochlorite solution utilized as the biocide at Seabrook Station will be produced on-site through an electrolytic process using seawater from the Cooling Water System. 7his will not influence the existing supply of chlorine in the surrounding region.
Biocide Usace.,Qgstion Number 5:
A cost, analysis for both generaticc'unita indicates that backflushing on a schedule of twice a month during the fouling season and once a month during
- the rest of the year would cost approximately $3 million per year.
If a schedule of backflushing only once a month during the biofouling season is possible, the cost will be reduced to approximately $1.5 million per year.
Continuous low-level chlorination during a similar fouling season at an injection _ level of 2.0 mg/l will cost approximately $1.4 million per year.
Whilo tha crato fer backflu-hing cnd chlorination cra cicilor fcr th2 cinimun expected treatment, backflushing poses the potential of a much greater economic loss. The procedure to reverse the circulating water flow is complex and has the potential of inducing hydraulic and thermal transients which could result in a plant shutdown. The resulting loss of electrical generation could be considerable, approaching $1 million just to bring the two units back to 100% power.
Additional losses could also be incurred including the delay required to realign mechanical and electrical systems before the plant could resume full power operation (from RAI 291.19).
SEACOAST ANTI-POLLUTION LEAGUE, 6/28/82, COMMENTS BY MS. JANE DOUGHTY (SAPL), PAGE 14 Biocide Usage, Firs t Paragraph :
The booster dose concentration applied within the Cooling System to provide additional fouling control will depend upon the degree and nature of the fouling within the system.
In any event, the residual oxidant in the discharge transition structure will not exceed 0.2 mg/l during any application of booster dosages.
Alternative Locations For Structures In the Floodplain:
Second paragraph from bottom on Page 75.
As pointed out in the DES on Page 5-5, the Executive Order 11988 was signed in
-~
at which time construction at the site had already begun.
1977) _
Also, as clearly shown on DES Figure 5.1, site encroachment on the floodplain is negligible.
A site-specific Design Basis Flood Analysis has been performed for the Seabrook Station.
This analysis is presented in FSAR Section 2.4 and is further addressed in applicant's responses to RAI's 240.29, 240.30, 240.31, 240.32, 240.33, 240.34, 240.35, 240.36, 240.37, 240.38, 240.39, 240.40, and 240.41.
This analysis presents the design basis for flooding of safety-related facilities, systems, and equipment of the station.
This hypothetical flooding condition produces the maximum flooding levels which the site could possibly be subjected to during its design life.
This design basis meets the intent of Regulatory Guide 1.59 (Revision 2).
Therefore, data and studies specific to the site have been performed and reviewed.
MISCELLANEOUS COMMENTS, SEACOAST ANTI-FOLLUTION LEAGUE, 5/26/82, C., PAGE 1 Encroachment on the flood plain has been verified by field inspection several times during previous NEC staff site visits.
MISCELLANEOUS COMMENTS OF SAPL, PAGES 1-8 Paragraphs 2, 3 and 4, Page 1:
The water quality at the station discharge will not be af fected by the discharge of minimal amounts of chlorine and its associated by products.
Paragraphs 2 and 3, Page 2:
(Comments made on the Environmental Report, Operating Stage.) The effluent limitations referenced in Section 5.1.1 of the ER-OLS for Seabrook Station pertain to the thermal component of the discharge and not the chemical components.
Paragraphs 3 and 4, Page 2:
(Comments of ER-OLS Section 5.1.3 and 5.1.4.) Inf ormation available on the effects of chlorine on representative species in the Seabrook Region is provided in applicant's response to ER-OLS PAI 291.19. No increased impact will be produced as a result of chlorine / heat interactions in discharged cooling waters over those discussed in the Seabrook Station ER-OLS.
Paragraph 2, Section g, Page 3:
Continuous monitoring of chlorine discharged at Seabrook Station is provided at the discharge transition structure which will be used to regulate the input of sodium hypochlorite solution at the intake structures.
Paragraph 3, Section g, Page 3:
Impacts associated with the use of the continuous low-level chlorination are provided in the response to ER-OLS RAI 291.19.
Section 6.B, Page 8:
Continuous monitoring of chlorine discharged by Seabrook Station is provided at the discharge transition structure which will be used to regulate the input of chlorine at the intake structures.
NOAA, OFFICE OF MARINE POLLUTION ASSESSMENT, 6/30/82, COMMENTS BY ANDFEU ROBERTSON Question Number 1, Page 1:
The applicant intended that there would be no measurable residual oxidant af ter mixing at the station discharge.
Question Number 2, Page 1:
Sodium hypochlorite solution, generated on-site, will be used to control biofouling within the Cooling Water Systems at Seabrook Station. The amperometric-type analyzer utilized in monitoring at the discharge transition structure measures the equivalent amount of chlorine within the cooling waters..
Quentim Numbr.r 3, Pag 7 la' The chemicals added to the discharge during normal operation as identified in Table 4.3 need not be included in a monitoring program. None of these chemicals, except chlorine, has been identified as harmful to marine organisms in the concentrations postulated.
(U.S. Atomic Energy Commission, " Toxicity -
- of Power Plant Chemicals to Aquatic Life", WASH-1249, June 1973)
Question bhaber -4, Page 1:
The values depicted on Figure 4.8 are the discrete monthly means connected with a straight line. The points plotted represent the average for each month which, of course, varies throughout the year. The values for December and January should not, consequently, "matchup"; as is the case for any other consecutive month, e.g., June and July.
Question Number 7, Page 2:
Differences are due in part to the different environments of the outfalls, estuarine and oceanic.
Question' Number 5, Page 1:
Response to ER-OLS RAI 291.19 describes the expected interactions between the physical and chemical components of ambient water and the types and amounts of compounds produced through sodium hypochlorite injection at Seabrook Station.
Question Number 6, Page 2:
Due to the inability to accurately duplicate conditions of heat and pressure changes within the Cooling Water System during station operation at Seabrook, studies conducted to match such conditions would not accurately project the actual effect of these parameters on chlorine decay. Operational experience will be used to determine residual oxidant concentrations, which will be limited to 0.2 mg/l in the discharge transition structure,- for varying injection concentrations.
AUDUBON SOCIETY OF NH, 7/6/82, PACE 146 Imst Paragraph, Page 1:
The introduction of low-level chlorination to control foulicg organisms within the Service and Circulating Water Systems at Seabrook Station should not alter conclusions made earlier by EPA. Discharged by products from chlorination will not accumulate in the local environtent, as dilution within ambient waters and replacement of these waters prohibits this.
EPA, Region 1.7/7/82, Rage 1, Third Paragraph:
The rationale for the utilization of low-level chlorination over backflushing is presented in applicant's response to ER-OLS RAI 291.19.
CONSERVATION LAW FOUNDATION OF NEW ENGLAND, 7/19/82, PAGE 2, WATER QUALITY (5.3.1) it the present time, there is no provision to store sodium hypochicrite o n-si t e. The sodium hypochlorite solution will be ' generated continuously by an electrochemical process using seawater taken from the Cooling Water System. The hypochlorite solution will be injected at the intakes as soon as it is generated.
Second Paragraph, Page 5:
The concentrations of chlorine and associated by products released by Seabrook Station will be minimal and even extended exposure, if it were possible, through attraction to warmer waters will not affect individuals.
Fgdrological Alterations (5.3.2), Page 2:
A site specific Design Basis Flood Analysis has been performed for the Seabrook Station.
This analysis is presented in FSAR Section 2.4 and is further addressed in applicant's responses to RAI's 240.29 through 240.41.
This analysis presents the design basis for flooding of safety-related facilities, systems and equipment of the station. This hypothetical flooding condition produces the maximum flooding levels which the site could possibly be subjected to during its design life.
This design basis meets the intent of Regulatory Guide 1.59 (Revision 2).
The station is designed and protected to this flooding design basis.
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