ML20080L884

Response Opposing Util Motion for Summary Disposition of Eddleman Contention 75 on Clams.Statement of Facts as to Which There Are Issues to Be Heard Encl

ML20080L884
Person / Time
Site:	Harris
Issue date:	09/27/1983
From:	Eddleman W EDDLEMAN, W.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20080L879	List: ML20080L877 ML20080L884 ML20080L888 ML20080L894 ML20080L899 ML20080L907
References
82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8310030369
Download: ML20080L884 (8)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMI3SION sept 27, 1983 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman

(

In the Matter of Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al. ) 50 401 OL (Shearon Harris Nuclear Power Plant, ) -

Units 1 and 2) ) ASLBP No. 82-h68-01

) OL Wells Eddleman's Response to Motion for Summary Disposition on Eddleman 75 (Clams )

Contention 75 says that biofouling by Corbicula or other organisms could block the Harris condensers and access to its ultimate heat sink.

Applicants, ignoring my responses to their discovery, say this can't happen. But it can. NRC Inspection & Enforcement Information Notice IN 81-21, dated July 21, 1981 (accession No. 810330402), at nage 3, says (after describing the massive failure of the RHR system at another CP&L plant, Brunswick, due to biofouling, p.2) that "Under conditions of an inoperable RHR system, heat rejection to the ultimate heat sink is typically through the main condenser or through the spent fuel pool coolers. This latter path consists of the snent fuel pool punps and heat exnhanger with the reactor building closed cooling water system as an intermediate system which transfers the heat to the service water system via a single pass heat exchanger. These two means (i.e. main condenser or spent fuel pool) are not considered to be reliable long tern system alignments under accident conditions."

B310030369 830927 PDR ADOCK 05000400 0 PDR

That is, given biofouling of the RHR system, eidher the main condenser or the service water system is required to maintain access to the ultimate heat sink, and neither of these means is censidered reliable. Note that both the service water system and the RHR were biofouled at CP&L's Brunswick plant (IN 81-21 at 2).

CP&L claims extensively (alleged" facts" 4 through 8 re sunmary disposition on Eddleman 75, 9/1/83) that they can and will detect and eliminate Corbicula as a biofouling organism at Harris. This, however, is not very credible given the information contained in December item 7 of the NRC's October-Maxamban 1981 Renort to Congress on Abnormal Occurrences (hereinafter, "81 Renort"). At nage 2 it describes biofouling of the service water system and RHR at Brunswick and in other heat exchangers in that nuclear plant. It notes that Three RHR heat exchangers (both of those on Unit 1 and one on Unit 2) . ..

were inoperable" (ibid). At page 7, under "Cause or Causes", it says:

"At Brunswick, the chlorinstion program, which was part of the program to control the growth of marine organisns, was stonned for approximately 14 months dues to potential operat! onal problems and environmental effects. Although the operational and administrative controls at ... Brunswick were inadequate to detect early signs of the eroblem, the plants were shut down when the techaial specifi-cation limits could nc longer be met."

This is the matter about which Applicants are resisting discovery.

l Their failure to chlorinate is quite significant, ad it caused the 81 Brunswick problem, which was a serious safety problem. The4 report continues:

"'As previously discussed, the incident at Brunswick had the most safety significance of the incidents described in this report.

Unit 1, which was shutdown on April 17, 1981, ... experienced a total loss of the residual heat renoval system on Anril 25, 1081.

• *

• the similar heat exchangers on the onerating Unit 2 were examined. . . . the Baffle plate was found disolaced for RHR heat exchanger 2B. ...".

_ , - . - ,._m, ,

,. ,. - , _, .-.m.,. ---..--.m...__.-

i Tha 81 Rcoort sxplaina the probicm in more datail on n:goa h et seq. It says, "During normal operation, particularly if an adequate control program is not being followed, fouling organisms can grow in f large diameter piping if the flow velocity is low." This imulies that biofouling can occur even if an adequate control nrogram is followed.

Thus, even if true, Applicants ' alleged " facts" h through 8 are irrelevant.

In addition, the failure to chlorinate at Brunswick for some lh months casts doubt on Applicants' ability to fully ca"ry ouc their tromises to prevent biofouling. Each of " facts" h through 8 is a promise: each uses the word "will" and is sunnorted only by the opinion of a CP&L employee. The Staff DES at 5-20 does not deal with these matters l excent to note that chlorination of the service water system should not harm other living things outside the plant (presumably including other Corbicula and other potential biofouling organisms).

Leaving for now the other issues (e.g. Corbicula is NOT the only potential biofouling organism for Harris -- see Eddleman discovery responses to Anplicants on contention 75; Corbicula veligers (larvae) can easily get through a 1/16 inch screen and enter the plant; these veligers are produced in huge numbers), let's return to the 81 report's safety analysis of such biofouling, which it says can occur even with an adeouate control program (p.lt).

At pp 4-5, it continues: "'b. Fouling organisms also thrive in stagnant runs of niping in onerating systems or in nining systems which have been inactive for long periods of time. " ?

There is no evidence that one cleanup run a m nth wS11 remove Corbicula from Anplicants ' service water niping or emergency intakes.

L.B. Goss et al (CP&L discovery document 00000!4, p.1hl) state thtt l "any dead spaces where velocities are decreased allow for attachment and growth of clams within the tunnel to a size which can block con-densers." A velocity of 2.1 meters per second is needed to prevent

_g.

l clan agttachment, they say. (ibid). With a once-monthly nump -

l test, the dead space which will occur is the whole ESWS intake l

and auxiliary cooling intake, for virtually the whole month.  !

The 81 report goes on to show how Corbicula can cause or contribute to loss of heat sink during accidents -

" Seismically diked emergency ponds utilized by some power plants as the ultimate heat sink could also sunport the growth of (siatic clans. If makeup to the pond is from a waterbody in which the Asiatic clams are known to be present, then it is likely that the clams will be found in the ultimate heat sink and possibly in the service water suoply header leading to the plant f rom the ultimate heat sink" (n.5)

Applicants and Staff both agree this is possible at Harris. See Staff 6-24-83 interrogatory response, at 96, interrogatories 26 and 27.

Note this response was filed AFTER the DES issued. Apolicants' VIII.5.83 resconses to interrogatory 75-8(a) and (b) at page 9.

Note also the resnonse to 75-8-e-lii: with Corbicula in the reservoir, Applicants can't assure it won't get into the niant. As shown above, and further below, their protection plan is inadequate to prevent entry and growth of Corbicula; and as noted above they may not carry out their plan: They failed to at Brunswick, see IN 81-21 and 81 Report.

l 1

The 81 Report then d /cribes (pp 5-6) degradation of heat sink, noting that" dead clams may oe more of a problem than live organisms ,

since they are more easily swept along by the flow." TVA (CP&L discovery document 0000Q45-. at ikO) has bad severe problems with dead clams in condensers at Browns Ferry. "The fouling was so extensive that condensers had to be dismantled and cleaned with brushes" l (ibid). Even if the heat sink doesn't degrade in perfornance due i

i to dead clams, evcn a small percentage of dead clans"could overburden automatic backwash service water strain 6rs." 81 Report at 5, botbom.

The 81 report notes on page 6 that in normal oneration, the building up "of fouling organisms or co'rrosion products may not noticeably degrade system performance", but during a seismic event, debris could be broken loose; this could also happen due to pipe flexure, simultaneously degradning both redundant trains of the emergency cooling system. Pump failures due to bu!1 dup of fouling organisms are also discussed. It concludes (pp 6-7)

"The safety concern identified by these events is the possible degradation of the heat transfer capabilities of redundant safety systems to the point where system function is lost.

Preventive measures and methods of detecting gradual degradation have been inadequate in certain areas to preclude the occurrence. The above postuinted events involve a conmon cause failure mode that can affect redundant systems. Aquatic organisms, mud silt, and corrosion nroducts have been the main source of flow blockage in the a coolant pining system and associated heat exenangers where events have occurred."

The above establishes that Corbicula can cause serious safety (see e.g. 81 Report under 61-7 nt 1st page) problems at Harris, including ones where the main condenser or ESWS is required to establish access to the plant ultimate heat sink, thus disposing of the issues raised in CP&L's Loflin affidavit.

ON3- kr Oeged %cP9 %2re OG CesAW Awe Cedzda w & SA0 It reamains to show why Aoolfcants ' proposed control measu=es MbN  :

gr are not adequate. Note, though, that the 81 report, pp 8-9, t V%uq'f Me o assigns only " varying degrees of effectiveness" to the sorts of fLg 4 I Y

measures Applicants paropose in their Hogarth affidavit. f'fbbusq Sid Ison, *

._ . . (CP&L discovery document 00000h, copies provided '

herewith for Board, Staff, and NRC Docketing & Service) notes that veligers reaching the cooling tower basin (aeration basin) "are apparently protected from the chlorination procedure by the aeration p.2 process." This directly contradicts Hogarth's item 11 (p. of his affidavit). Isom notes that plants that maintain o.5 upm chlorinat'on "at pump intakes experience no oroblems with Asiatic clans or other biological nuisance organisms." But CP&L does not commit-to this.

They only pronose this concentration at the heat exchanger outlet

(Hogorth, item 11, p.4).

The error of his item 12 has been noted ~

above, citing Goss et al at 141 (CP&L discovery document 000005, copy also provided for Board, Staff and NRC Docketing and Service).

Hogarth's argument about the intake depths (item 13, p.5) ignores

. entrainment, particularly of Corbicula valigers (larvae) in the ESWS intakes. Hogarth also asserts that a 1/16" mesh will nveclude any passage (of Corbicula larvae, it can be inferred from his previous

( sentence), but Goss says (p.141) that "Use of straining alone eventually results in the need for manual cleaning of the (service water) system comnonents". Corbicula valigers are much smaller than a 1/16" radius.

Hogarth does not describe what flow and nressure tests CP&L will do. The 81 report is clear that flow must be measured on b6th sides of a pump during pump tests to detect biofouling. (item as, p.6)

If CP&L fails to commit to this obvious reouirement, what trust can be given to their vague and general suggestions? Again, I cite their lk month failure to chlorinate at Brunswick as evidence that they don't even keep their commitments in all cases, so there is still en issue on this noint. It doesn't need a discovery resnonse to cubstantiate it -- it 's right in the 81 recort at page 7.

Hogarth, item 15 at page 6, says that tests "are designed to monitor plant service water systems for any flow reductions",but does not state what degree of flow reduction can be detected. As noted above, in normal operation the degree of flow reduct$on may be minimal, thus difficult to detect (81 report at h).

Other organisms can cause biofouling at Harris {eeEddleman resconses to Anplicants ' discovery on this; see also 81 Recort at9; IN 81-21 at 3). Applicants ignore this, but the above contradict their alleged fact no.2)

(p.1h0,Severe documentblockage of condensers by Corbicula is noted by Goss.

000005).

Corbecula in the cooling wower basins

can be getting into the condensers without going through the areas CP&L will effectively be able to chlorinate. CP&L in its affidavits makes no mention of chlorinating in the condenser or outlets of the cooling tower basin, from which water reciarculates to the condensers.

CP&L's "falt" 10 admits, by using the word "therefore",

that it depends on the above alleged " facts"', all of which excent

1. 1 and #3 are contradicted above by known facts. Thus there are genuine issues of fact re Eddleman 75 in this proceeding and Applicants ' Motion for summary disposition of this contention should be denied. (Fact #1 merely states tne contention's thrust in general terms; Fact #3 is that Corbicula isn't in the Harwis lakes yet; but all parties agree they can readily get into them.

Thus, these last two facts don't help ADD 11 cants at all. )

2 son--

j NOTE: IN 81-21 and the 81 Report were only recently located by me; the above discussion of them nay be viewed as a l

supplenenttodiscoveryonEddleman75andconiesEfthesedocuments, auxantima are being sent to Anolicants as well as to the Staff',

Board, and Docketing and Service, with this Resnonse.

I affirm the above is true, 9.27.83 gy Wells Eddleman l

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STATEMENT OF FACTS AS TO WHICH THESE ARE ISSUES TO BE HEARD ON EDDLEMAN 75 -

1. Asiatic clams and other organisms (as identified in -

discovery resnonses by Eddleman, 7-29?-83) can infest the Harris plant, and foul numps, pipes, heat exchangers and the condenser.

2. No combination of measures is guaranteed to nrevent growth of such organisms in the Harris niant.

3 Corbicula veligers (larvee) can enter the plant and reach the cooling tower pools where they will be secure against normal chlorination since the aeration above them removes chlorine.

4 Corbicula will get into the Harris reservoir and auxiliary reservoir eventually.

5. screening won't keen Corbicula veligers out oc e2e Harris plant.

6/ Intakes from the auxiliary lake will be niaces Corbicula can flourish. One monthly flush won't remove them as they attach to the surfaces of nipes (Goss, p.1kl, CP&L document 000005).

7. CP&L is not guaranteed to chlorinate at Harris because they didn't for 14 months at Brunswick.

8. Chlorination will not keen Corbicula out of the Harris condensers if they are in the cooling tower basins. Even if killed by it on the way to the condenser, they'll becone debris.

9. CP&L's in-plant nonitoring is inadequate to detect buildun of Corbicula or debris or other organisms, and inadequately enecified.

10. Biofouling of the RHR from Corbiculs is nossible at Harris.

so is biofoulind ogf the service water system, ESWS, and main condenser.

11. When the RHR is biofould, the main condenser or ESWS is i needed to shut down the Harris plant, but neither is reliable to

(

t maintain long term shutdown, and both can be infested with Corbicula or j debris.

12. Lack of adeguate cooling for reasons as des ribed above cancausesevereaccidentsatHarr,isoranynuclearn$antsodesigned.

l

I STATEMENT OF FACTS AS TO WHICH THESE ARE ISSUES TO BE HEARD ON EDDLEMAN 75 -

1. Asiatic clams and other organisms gas identified in -

discovery resnonses by Eddleman, 7-29?-83) can infest the Harris j plant, and foul numps, pines, heat exchangers and the condenser.

2. No combination of measures is guarant usd to nrevent growth of such organisms in the Harris niant.

3. Corbicula veligers (larvee) can enter the plant and reach the cooling tower pools where they will be secure against normal chlorination since the aeration above them removes chlorine.

4 Corbicula will get into the Harris reservoir and auxiliary reservoir eventually.

4

5. Screening won't keen Corbicula veligers out c e dhe Harris plant.

6/ Intakes from the auxiliary lake will be niaces Corbicula can flourish. One monthly flush won't remove them as they attach to the surfaces of nipes (Goss, p.1kl, CP&L document 000005).

, 7. CP&L is not guaranteed to chlorinate at Harris because they didn't for 14 months at Brunswick.

8. Chlorination will not keen Corbicula out of the Harris condensers if they are in the cooling tower basins. Even if killed by it on the way to the condenser, they'll becone debris.

9. CP&L's in-plant nonitoring is inadequate to detect buildun of Corbicula or debris or other organisms, and inadequately snecified.

10. Biofouling of the RHR from Corbiculs is nossible at Harris.

so is biofoulind ogf the service water system, ESWS, and main condenser.

11. When the RER is biofould, the main condenser or ESWS is needed to shut down the Harris plant, but neither is reliable to maintain long term shutdown, and both can be infested with Corbicula or debris.

12. Lack of ade can cause severe ace!untedents cooling,is at or Harr any nuclear nlantfor reasons as described so designed.above,

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