ML20147B842
| ML20147B842 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/12/1988 |
| From: | Berry G NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20147B847 | List: |
| References | |
| CON-#188-5336 OL-1, NUDOCS 8801190016 | |
| Download: ML20147B842 (16) | |
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4 00CKETED USNRC tlNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 88 Jm 14 P3:56 BEFORE THE ATOMIC SAFETY AND LICENSING BONRD O! SUAIA*1 00cn;IiNG A LUNtu.
BR AllCH in the Matter of )
) Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF ) 50-444 OL-01 NEW HAMPSHIRE, ej al. ) On-site Emergency Planning
) and Safety issues (Seabrook Station, Units 1 and 2 )
NRC STAFF RESPONSE TO LICENSING BOARD ORDER OF NOVEMBER 27, 1987 INT RODUCTION On November 25, 1987, the Commission issued CLI-87-13 1 In which it lifted its January 9, 1987 order staying the Director of the Office of Nuclear Reactor Regulation from issuing a low-power license for the Seabrook facility. In its order, the Commission took note of two contentions that had been remanded for further litigation by the Appeal Board in connection with that tribunal's consideration of the appeals taken from the Licensing Board's initial Decision in the onsite emergency planning and safety issues phase of the proceeding. The Commission therefore directed the Licensing Board to "expeditiously determine whether considering the issues that it is hearing on remand, it is appropriate to renew at this time its authorization of low power or whether low power operations must await further decisions." l d_. , slip op. at 7. On Novembe.' 27, 1987, the Licensing Board issued an order directing that briefs addressing these issues be filed by Applicants and
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1/ Public Service Company of New Hampshire (Seabrook Station, Units 1 and 2), CLI-87-13, 25 NRC (November 25,1987)
DO [
Intervenors by January h, 1988 and by the Staff by January 11, 1968.
Order (Briefing Schedule) at 1-2 (November 27, 1987) (unpublished).
As explained in the following sections of this brief, the remanded contentions do not present any issue relevant to low power operations.
This is because the alleged harmful conditions which form the bases for the remanded contentions are unlikely to arise during low power operations. Moreover, reauthorizing low power operations at this time will not prejudice the intervenors' hearing rights. Low power operations will not affect the ability of the App!! cants or the Staff to take any corrective action made necessary by the outcome of the remanded proceeding. The Board therefore should rule that the pendency of NECNP Contentions I.V and IV do not preclude it from reauthorizing the Director of NRR, upon making the findings required by 10 C.F.R. 6 50.57(a), to issue a low power license for the the Seabrook Station.
DISCUSSION A. Legal Standards it is by now well settled that authorization to commence low power operations need not as a matter of law await the completion of a full power operating license proceeding. 10 C.F.R. g 5 50.57(c); see e Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1),
CLi-83-17,17 NRC 1032 (1983); Pubile Service Company of New Hampshire (Seabrool; Station, Units 1 and 2), A LA B-853, 25 NRC
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(1986), rev'd on other grounds, CLi-87-02, 25 NRC (1987). U Section 50.57(c) of the Commission's regulations permits an applicant in a l contested operating license proceeding to move the licensing board to authorize the Director of the Office of Nuclear Reactor Regulation (NRR) to issue a license "permitting ar.tivities short of full power operation, notwithstanding the pendency of safety contentions before the licensing board." Commonwealth Edison Company (Braidwood Nuclear Power
~~2/ NECNP devotes most of its brief to arguments challenging the authority of the Commission and its adjudicatory boards to authorize low power operations prior to the completion of full power operating license proceedings. New England Coalition On Nuclear Pollution's Brief in Opposition To Renewal Of Authorization To Operate At Low Power, passim, (January 4, 1987) ("NECNP B rief") . This proposition consistently has been rejected by the Appeal Board. See e.c., Public Service Company of New Hampshire (Seabrook Station, IT6 ts 1 and 2), ALAB-875, 25 NRC , slip op, at 5 (October 1, 1987): Public Service Company of New Hampshire (Seabrook Station,
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Units 1 and 2), ALAB-865, 25 NRC 430, 439 (1987). In ALAB-865, NECNP presented the identical argument to the Appeal Board in connection with its request for a stay of the Licensing Board's initial order authorizing the Director of NRR to issue a low power license for the Seabrook Station. The Appeal Board was r.ot persuaded, stating "section 50.47(d) gives applicants an unquallfled right to a ,
low-power ilcense If certain prerequisites are met even if the i Commission has yet to resolve all offsite emergency planning issues, t To the extent that the movants believe that the Commission's regulations themselves violate the hearing requirements of the Atomic Energy Act, they must raise that issue with the Commission the regulations are not subject to challenge before us." ALAB-865, 25 NRC at 439.
Similarly, section 5').57(c) authorizes a licensing board to authorize the Director of NRR to issue a low power license even though the full power operating license proceeding has not been completed provided certain prerequisites are met. To the extent that NECNP believes that the regulation itself vlotates its hearing rights under the Atomic Energy Act, it must raise that issue with the Commission.
The regulation is not subject to challenge beforo the Board, ld. In view of these considerations, it is unnecessary for the S'taff to address the merits of NECNP's challenge to the validity of section 50.57(c).
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-u-I Station, Units 1 and 2), LBP-86-31, 24 NRC 451, 453-54 (1986). Section 50.57(c.) was promulgated "to provide explicitly for early consideration of facility testing in the event of a contested hearing on the issuance of a I cense for full power operation." M.at 454, citing 36 Fed. Reg. 8862 (May 14, 1982). Thus, as noted by the licensing board in Braidwood, "the regulation affords relief to an applicant when the pendency of hearings before a licensing board threatens to delay the apolicant's fuel loading and testing schedule." M.
Section 50.57(c) provides that if an applicant's request for authorization to conduct activities short of full power operation is not opposed, the licensing board shall issue an order authorizing the Director of NRR to, after making the findings required by section 50.57(a), grant the license for the requested operation. M. The sole ground for opposing a request made pursuant to section 50.37(c) is that the "I 50.57(a) findings cannot be made for the requested authority because (a party's contention] is relevant to those operations and must therefore be resolved prior to the issuance of the 5 50.57(c) license." ,ld,. ; see also Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1), CLI-84-21, 20 NRC 1437,1439 (1984) (in passing upon a 5 50.57(c) motion, the regulation involved "must be examined to determine its application and effect for fuel loading or some phase of low power testing"), in such cases, the licensing board must determine whether the contention is in fact relevant to the requested operation, and if it finds that the contention is relevant, 5 50.57 provides that the board itself make those 5 50.57(a) findings "as to which there is a controversy" because of the pendency of a relevant contention. 10 C.F.R. 5 50.57(c).
On the other hand, if the licensing board finds that the admitted contentions are not relevant to the requested operation, and therefore need not be resolved before the requisite 5 50.57(a) findings can be made, the board does not make any 5 50.57(a) findings, but authorizes the Director lof NRR] to do so. M. , citing 10 C.F.R. 6 50.57(c),
Pacific Gas and Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 and 2), L B P-81 -15, 13 NRC 226, 233 (1981), and Pacific Cas and Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 and 2), CLI-83-27, 18 NRC 1146,1149-50 (1983) .
NECNP opposes the roauthorization of low power operations. See NECNP Brief, passim. Thus, the board must determine at the threshold whether either of NECNP's contentions is "relevant to the requested operation [ ]" Braidwood , su p ra , 24 NRC at 454. If they are not relevant to the requested operation, they pose no bar to the reauthorization of low power operations. - Id. ; cf. Shoreham, supra,
'-3/ Applicants rely upon Pacific Gas and Electric Co. (Diablo Canyon Nuclear Power Plant, Frilts 1 and 2), CLI-83-27, 18 NRC 1146, 1149-50 (1983), in support of their position that in determining whether the pendency of the remanded contentions bars the Board from reauthorizing low power operations, the Board should base its decision upon a "balancing of the equities and a consideration of
, pcssibfa prejudice to further action required as a result of the reopened proceeding." Applicants' Memorandum in Support Of Low Power Operations at 2 (January 4, 1988) (Applicants' Memorandum).
The decision in Diablo Canyon is distinguishable from the case at bar. Simply put, the holding in that case is that where a license already has been awarded by the Commission but It is later determined that further hearings must be held to complete the adjudicatory record, "the validity of the license pending the completion of the hearings and decision depends on a balancing of the equities and a consideration of possible prejudice to further action required as a result of the reopened proceeding." M. at (FOOTNOTE CONTINUED ON NEXT PACE)
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CLi-84-21, 20 NRC .at 1439. In this connection it should be noted that
-the test of "relevance" is not whether the contention relates to the conduct of the proposed activitly, but rather whether it is poses an issue relating to the safe conduct of the proposed activity. Braidwood, supra, 24 NRC at 455; see Shoreham, supra, 20 NRC at 1439. As the board explained in Braldwood:
(T)he test for relevancy, under 6 50.57(c) as is general, is whether, if the matters were heard, they could result in a finding adverse to the other party -- in this case under i 50.57(a). Since only matters inimical to the public health or safety can be decided adversely to Applicant under 5 50.57(a),
and intervenors have made no showing that their admitted contention raises a safety matter with regard to fuel loading and precritical testing (the activities sought to be authorized),
they have failed to establish that the contention is relevant to the requested license.
74 NRC at 456. Stated another way: unless the public health and safety is threatened by the danger posited by the admitted contentions if the activity sought to be authorized commences, the contentions simply are not relevant. See Shoreham, su pra , 20 NRC at 1439. In such circumstances, the Scard need not make any of the findings required by section 50.57(a) but authorizes the Director of NRR to do so. 10 C.F.R. 6 50.57(c). As will be explained in the following sections of this brief, neither of the remanded contentions raises a safety matter with regard to low power operations and thus is not "relevant to the activity to be (FOOTNOTE CONTINUED FROM PREVIOUS PAGE) 1149. In contrast, in this case Applicants have only a fuel loading license but does not have a testing or operating license. Thus, unlike the Diablo Canyon case the Board is not fared with a situations where a license has been issued to commence power operations.
authorized." Consequently, the Board should rule that no contention currently pending before it precludes the Board from authorizing the Director of NRR, upon making the finding required by section 50.57(a),
to issue a low power license for the Seabrook Station. EI B. NECNP Contention I.V Does Not Raise A Safety Matter With Regard To Low Power Operations NECNP Contention I.V alleges that:
The Applicants have not demonstrated that they have met GDC 14, 15, 31, and 32 insofar and to the extent that those CDC require a program of in-service inspection of steam generator tubes.
The gravamen of this contention is that in the absence of an adequate inservice inspection prog ram, cracking or leaking steam 3/ It should be noted that are two other matters pending in regard to the onsite emergency planning and safety issues phase of this operating license proceeding, both of which currently are before the Appeal Board. First, the Appeal Board has before it the Massachusetts Attorney General's motion to reopen the record and admit his late-filed contention challenging the adequacy of Applicants' emergency alert notification system for the Town of Newburyport, Massachusetts. Second, in A LA B-875, the Appeal Board deferred making a final determination as to whether the Board's finding that certain coaxial cable used by Applicant was environmentally quallfled is supported by the record evidence. See ALAB-875, slip op, at 39, instead, the Appeal Board directed the Licensing Board to identify the portions of the record which supported its conclusions and invited the parties to address the Board's response, in ALAB-882, (January 8, 1988). The Appeal Board again sent this matter to the Licensing Board safety equipment if the subject cable performed a positive safety function or merely had to avoid compromising to be determine whether this matter need be decided before a low power license was !ssued Id. at 8-9. Thus, in the present posture of this proceeding, it car.n'it' be said that low power operations will commence in the event the Board were to issue a ruling favorable to Applicants. The most that could be said of such a ruling is that the contentions currently pending before the (FOOTNOTE CONTINUED ON NEXT PACE)
generator tubes may go undetected and uncorrected which might result in a tube rupture causing a steam generator safety valve (s) to open and rishing the release of radioactive gases into the air, possibly outside the containment bul' ding. See NECNP Brief at 31. As explained below, there is reasonable assurance that the dangers presented by NECNP's scenario will not occur during low power operations.
- 1. Applicants' program for Inservice inspection of steam generator tubes meets regulatory recuirements.
General Design Criterion 32 requires that:
Components which are part of the reactor coolant pressure boundary [RCPB] shall be designed to permit (1) periodic inspection and testing of important areas and features to assess their structural and leaktight integrity, and (2) an appropriate material surveillance program for the reactor pressure vessel.
10 C.F.R. Part 50, Appendix A, Criterion 32. As the attached affidavit of Her bert F. Conrad establishes, Applicants' program for int rvice inspection of steam generator tubes satisfies these requirements.
Affidavit of Herbert F. Conrad at A4-A5 (January 12, 1987), in this regara and as documented in NUREG-0986, the Safety Evaluation Report >
for the Seabrook Station, the pressure retaining parts of the steam generators have been designed "to meet the ASME Code requirements for ASME Code Class 1 components." M. , 5.4.2.2.2. In addition, Applicants' inservice inspection program provides for the "Inservice inspection of Class 1 and 2 components, including Individual steam (FOOTNOTE CONTINUED FROM PREVIOUS PAGE)
Board do not bar the Board from authorizing the Director of NRR from issuing a low power license for the Seabrook Station, provided he makes the findings required by 10 C.F.R. 6 50.57(a).
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generator tubes." M. In addition, Applicants have "committed to following the recommendations of Regulatory Guide 1.83, Rev. 1, "inservice inspection Of Pressurized Water Reactor Steam Generator Tubes" as well as the standard technical specifications for Westinghouse Pressurized Y!ater Reactors set forth in NUREG-0452. g. : Conrad Affidavit at A 4. Finally, Applicants have committed to conduct the required inservice inspections of steam generator tubes in accordance with the requirements set forth in section XI of the ASME Code. N U REG-0986, 6 5.4.2.2.2; Conrad Affidavit at A4. As Mr. Conrad's affl&vit indicates, the Staff has determined that collectively the measures described above "constitute an acceptable basis for meeting, in part, the requirements of GDC 32." M.
- 2. It is un!!kely that the type of steam generator tube rupture experienced at the Ginna facility will occur at Seabrook during low power o,perations.
The proffered basis for NECNP Contention i.V is that a steam generator tube rupture occurred at the Ginna facility notwithstanding that licensee's adherence to Regulatory Guide 1.83. As will be explained, this circumstance does not lead to the conclusion that NECNP Contention I.V must be resolved before the noard can reauthorize low power operations at the Seabrook Station.
The tube rupture at the Ginna facility was caused by the presence of a foreign object inadvertently left in a steam generator tube. Conrad Affidavit at A6; NUREG-0909, NRC Report On The January 25, 1982 Steam Generator Tube Rupture At R.E. Glnna Nuclear Power Plant" (April 1982). This occurrence is unlikely to repeat itself at the Seabrook Station. As Mr. Conrad and Gregory Kann, the Program Support
. 4 Manager at the Seabrook Station, observe, in April 1986, the Seabrook Station's secondary side steam generator internal areas were Inspected ;
and ah debris or foreign objects observed were removed. Affidavit of Gregory Kann at i 11 (December 22, 1907); see Conrad Affidavit at A6.
In addition, rigorous controls were adopted to ensure that clothing worn or materials used during this inspection was not left behind inadvertenly.
M. Finally, Applicants have in place a system which permits them during plant operation to monitor and detect any "loose parts" which might pose a threat to the Integrity of the steam generator tu bes . M.; Kann Affidavit at i 12; see Seabrook Final Safety Assessment Report (FSAR),
6 4.4.6.4. In the opinion of the Staff's expert in this area, Mr. Conrad, the measures described above "provide reasonable assurance that a rupture caused by a loose part, similar to that experienced at Ginna, will not occur at Seabrook." Conrad Affidavit at A6.
Moreover, there is even less likelihood of a Ginna type steam gencrator tube rupture occurring at 5 percent power than there is at 100 percent or full power. This is because, as explained by Mr. Conrad, "the rate of fluid flow at 5 percent power would greatly reduce the driving force that could be caused by such a pcstulated loose part[ ]"
Conrad Affidavit at A9. "Fluid flow" in this context means the motion of i
the water circulating within the steam generator. The lower the power level, the slower the flow of fluid and hence the weaker the force of the postulated loose part. Consequently, in the unillety ever.. that a part became loose or a foreign object was left in a steam generator, it extremely unlikely that such occurrence would result in a rupture similar to that experienced at the Ginna facility. See Id.
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- 3. It. Is unlikely that the type of steam generator tube rupture experienced at the North Anna facility will occur at Seabrook during low powcr operations.
, in July 1987, the North Anna facility experienced a steam generator tube rupture. Conrad Affidavit at A7. This rupture was caused by "fluid flow induced vibration fatigu e. " M. 'The Seabrook Station, i however, is not susceptible to this type of failure. Id. This is because, unlike the North Anna facility, the steam generator tube support plates 4
used 'at the Seabrook Station are not made of carbon steel. Id.;
NUREG-0986, 5 5.4.2.1. Carbon steel support plates contain drilled holes, which are susceptible to the corrosion process known as "denting." b in contrast, the tube support plates used at the Seabrook Station are made of highly corrosion-resistant ferritic stainless steel and thus are not vulnerable to rust. Conrad Affidavit at A7. Additionally, the Seabrook tube support plates utillze "broached," rather than drilled, I holes. Id.; NUREG-0986, 6 5.4.2.1. "The . broached-hole design promotes high-velocity flow along the tube, sweeping impurities away from support plate locations." g. The Invulnerability to rust and the use of broached holes means that there is no reasonable danger that the Seabrook stearr generator tubes will experience the "denting" phenomena,
! which led to the North Anna steam generator tubo rupture. Conrad Affidavit at A7.
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"Denting" refers to the growth of the Iron oxide corrosion product
, in the annatus between the tube and the drilled hole which can
. result from deformations in the tube caused by gripping or sqeering the tube. See NRC Staff Response To New England Coalition On Nuclear PoliulTiin's First Set Of Interrogatories And Request For The Production Of Documents To The NRC Staff On NECNP Contentions I.V And IV at 7 (December 7,1987),
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d
Moreover, as with a Ginna type of rupture, there is even less likcllhood that a North Anna type of rupture will occur at the Seabrook Station during low power operations. This is because the reduced rate of fluid flow at 5 percent power is not sufficient to cause the "flow Induced vibrations which caused the North Anna tube rupture." Conrad Affidavit at A9.
Finally, it should be noted that the Seabrook Technical Specifications provide that the first inservice inspection of the steam generators be performed six months after full power operations commence or within 24 months of Initial criticality, whichever occurs first. Conrad Affidavit at A8. Low power operations would not alter this requirement. M. Nor would low power operations make inservice steam generator tubes more difficult to perform or augment. Id. In fact, as Mr. Conrad points out, the requirement that "the full length of each tube in each of the four steam generators be eddy current inspected from the point of entry on the hot leg side completely around the U-bend to the top support of the cold leg" provides "additional assurance of steam generator tube integrity for the initial period of operation until the first inservice Inspection [.]"
M. For all of these reasons, no safety issue is presented by NECNP Contention I.V with respect to low power operations.
C. NECNP Contention IV Does Not Raise A Safety Matter With Pegard To Low Power Operations NECNP Contention IV alleces that:
The Applicant must establish a survelllance and maintenance program for the prevention of the accumulation of mollusks, other aquatic organisms, and debris in cooling systems in order to satisfy the requirements of GDC 4, 30, 32, 35, 36, 39, and 39, which require the maintenance and inspection of reactor cooling systems. The design, construction, and proposed operation of Seabrook fall to satisfy these requirements.
4 NECNP argues that this contention "strikes to the very core of plant safety." NECNP Brief at 29. According to NECNP, in the absence of an Ldequate surveillance and monitorir,g program, aquatic organisms and debris might accumulste in the Scabrook cooling systems "which will impair these safety systems, or cause them to fall altogether." M. at 30.
NECNP's assertion does not demonstrate that this contention raises a safety issue with regard to low power operations. As explained below, Applicants in fact have an adequate survelliance and monitoring program to prevent the accumulation of aquatic organisms and debris in the Seabrook cooling systems. Moreover, it extremely unlikely that the danger posited by NECNP will arise during low power operations.
- 1. Applicants have in place an adequate program for preventing the accumulation of mollusks, other aquatic organisms and debris meets regulatory requirements.
An effective program to prevent the accumulation of aquatic organisms and debris (i.e., "blofouling") consists of three elements:
first , a properly designed cooling and service water system; second, a water treatment program; and third, proper surveillance and monitoring.
Affidavit of Dr. Michael T. Masnik at A4 (January 11, 1988). Applicants' program includes each of these elements and, according to the Staff's expert, Dr. Masnik, is "sufficient to control biolfoullng of the (service and cooling water] systems and to detect any significant degradation of the systems due to biofouling." Id.atA5.$I 6/
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Additionally, in NUREG/CR-3054, "Closeout of IE Bulletin 81-03:
Flow Blockage of Coollrig Water to Safety System Components by Corbicula sp. (Asiatic Clam) and Mytilus sp. (Mussel)" (June 1984),
(FOOTNOTE CONTINUED ON NEXT PAGE)
With regerd to the design element, the Seabrook Station has been designed to include a "midwater intake structure," which among other things greatly reduces the intake of debris and macroorganisms, including mollusks. [d . This intake structure is coated with an anti-fouling agent which discourcges the attachment of aquatic organisms. M. Also installed upstream from the individual room and component heat exchangers are screening devices to prevent flow blockage. M. These devices are capable of screening out objects as small as 3/8 inches square in size. Affidavit of Norman Wagner at A7 (January 12, 1988).
The second element of an effective biofouling prevention plan --
water treatment -- also has been incorporated into Applicants' biofculing centrol program. Masnik Affidavit at AS. Typically, a water treatment program consists of chlorinating the cooling water with a solution of sodium hypochlorite injected into the system as far upstream as possible in a concentration sufficient to destroy aquatic organisms downstream from the point of injection. M. at A4. Applicants' biofouling control program includes this technique. g. at AS: Wagner Affidavit at A6. Another water treatment technique employed in the nuclear industry is thermal backflushing. Masnik Affidavit at A4. This technique consists of reversing the flow in the cooling system and elevating the temperature of the water. M. According to Dr. Masnik, elevated temperatures will (FOOTNOTE CONTINUED FROM PREVIOUS PAGE) the Staff determined that Applicants' had an "acceptable program to confirm adequate flow rates in the safety-related systems." Id. at B-9. An inadequate flow rate is the danger presenteT by biofouling. See M. at 1.
result in virtually 100 percent mortality to all macro and micro fouling organisms. M. The Seabrook Station is designed to allow Applicants to employ this technique. ,ld, at A5; Wagner Affidavit at A6.
The third element of an adequate biofouling control plan is proper surveillance. Masnik Affidavit at A4. An effective surveillance program Ideally includes backpressure measurements, heat rejection tests, and pump head testing. M. Additionally, periodic visual Inspections of the systems components including the intake structure, travelling screens, intake inlet and outlet water boxes, Inlet and outlet heat exchanger water boxes should be conducted. M. Finally, the biofouling control system should be monitored to ensure that reduced flow or blockage does not occur. I d_. Applicants' surveillance program is described in the affidavit of Ylinthrope B. Leland, who is the Chemistry and Health Physics Manager at the Seabrook Station. See Affidavit of Winthrope B. Leland at 18.
The Staff has reviewed Applicants' surveillance program and finds it acceptable. Masnik Affidavit at A5; see Wagner Affidavit at A7.
- 2. It is unlikely that mcIlusks, other aquatic organisms, or debris in an amount sufficient to raise a safety issue will accumulate durfng low power operations.
Low power operations are likely to result in decreased biofouling.
This is because the rate of blofouling caused by aquatic organisms is dependent on several factors , including environmental conditions such "salinity, water temperature, lig ht , availability of food, and frequency and degree of submergence [.}" Masnik Affidavit at A6. According to Dr. Masnik, with the exception of water temperature, operation at 5 percent power "would not have a significant e ffec t" on any of these environmental conditions at the Seabrook Station. M. However, since
4 the growth rate of aquatic organisms is "highly dependent" on water temperature, "operation of the facility at 5 percent of rated power would result in much slower growth rates in most of the [ cooling and service water) systems than at 100 percent power [ . ]" g. Thus, there is reasonable assurance that the danger posited by NECNP Contention IV will not occur during low power operations.
CONCLUSION For the reasons stated in this response, the Board should rule that neither NECNP Contention I.V nor NECNP Contention IV raises issues relevant to the sefe conduct of low power operations and thus the pendency of these contentions does not preclude the Board from authorizing the Director of NRR, upon making the findings required by 10 C.F.R. S 50.57(a), to issue a low power license for the Seabrook Station.
hpectfully submitted, Gr gor p
Tan hgb erry Counsel f ,r N i Staff Dated at Bethesda, Maryland this 17th day of January 1988