ML20149L071

New England Coalition on Nuclear Pollution (Necnp) Third Set of Interrogatories & Request for Production of Documents to Applicant on Necnp Contention Iv.* W/Certificate of Svc. Related Correspondence

ML20149L071
Person / Time
Site:	Seabrook
Issue date:	02/19/1988
From:	Ferster A HARMON & WEISS, PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	Atomic Safety and Licensing Board Panel
References
CON-#188-5648 OL-1, NUDOCS 8802240100
Download: ML20149L071 (16)

Text

. U$[4[jf

. RELATED CORRESP0f(QM DOC KE TE E+

February 19, 1988 U) NH' UNITED STATES NUCLEAR REGULATORY COMMISSION

,88 R3 22 P4 :17 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD CFFICE vi ucu ns .

) 00CKEINi 4 SEvvlCf' In the Matter of ) 9 RANCH

)

Public Service Company of )

New Hampshire, et al. Docket No. 50-443OL-1gVy-CP[

(Seabrook Station, Units 1 & 2) ) ONSITE EMERGENCY

) PLANNING & TECHNICAL

) ISSUES

)

NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S THIRD SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO APPLICANTS ON NECNP CONTENTION IV INSTRUCTIONS FOR USE The following interrogatories are to be answered ln writing and under oath by an employee, representative or agent of the Applicants with personal knowledge of the facts or information requested in each interrogatory. We remind you of your obliga-tion to supplement answers to interrogatories, under 10 C.F.R. 5 2.740(e). ,

The following definitions shall apply to these inter-rogatories:

1) "pocument" shall mean any written or graphic matter or communication, however produced or reproduced, and is intended to be comprehensive and include without limitation any and all cor-respondence, letters, telegrams, agreements, notes, contracts, instructions, reports, demands, memoranda, data, schedules, a

notices, work papers, recordings, whether electronic or by other means, computer data, computer printouts, photographs, microfilm, G

JSO3 l

. l 1

-2 -

microfiche, videotapes, charts, analyses, intra-corporate or intra-office communications, notebooks, diaries, sketches, diagrams, forms, manuals, brochures, lists, publications, drafts, telephone minutes, minutes of meetings, statements, calendars, journals, orders, confirmations and all other written or graphic materials of any nature whatsoever.

2) "Identifv" with respect to any document shall mean to state the following: the document's title, its date, the author of the document, the person to whom to document was sent, all persons who received or reviewed the document, the substance and nature of the document, and the present custodian of the document and of any and all copies of the document.

3) "Identifv" with respect to any action or conduct shall mean state the following regarding any such action or conduct:

the person or persons proposing and taking such action; the date such action was proposed and/or taken; all persons with knowledge or information about such action; the purpose or proposed effect of such action; and any document recording or documenting such action.

4) "Identifv",with respect to an individual shall mean state the individual's name, address, employer, occupation, and title.

5) "Describe" with respect to any action, event or matter 7 shall mean state the following regarding such action, event or matter: the date of such action, event, or matter; the substance

. I

. l or nature of such action, event or matter; the persons participa-ting in or having knowledge of such action, event or matter; the current and past business positions and addresses of such per-sons; and the existence and location of any and all documents relating to such action or matter.

6) "Describe" with respect to any piece of equipment shall mean the type, manufacturer, equipment tag number and model num-ber of the equipment.

7) "Biofoulina" shall mean any degree of micro- or macro-biological cell deposition and subsequent biologically mediated corrosion of nuclear power plant cooling systems by aquatic debris, macro- or micro-biological Organisms, silt, and mud, or by any other organic or inorganic material.

8) "Microbioloaically induced corrosion" shall mean corro-sion or degradation that is generally caused by both aerobic or anaerobic bacteria, or any sedimentation caused by that process.

GENERAL INTERROGATORIES +

1) Please identify all persons who participated in the preparation of answers to these interrogatories, and identify the portions of your response to which each person contributed.

BIOFOULING. CORROSION AND BLOCKAGE BY MICRO- AND MACRO-BIOLOGICAL ORGANISMS

2. For each of the individuals listed in Attachment 1-1 of b your response to NECNP's Second Set of Interrogatories and Request for Production of Documents to Applicants on NECNP Con-

.-e e -me .. e . , - . . . -w

tention IV, state their area of expertise and qualification, including, but not limited to expertise in the field of micro-biology, and identify the portions of your response to each interrogatory to which each person contributed.

3) In your response to question 2(n) of NECNP's Second Set of Interrogatories and Request for Production of Documents to Applicants on NECNP Contention IV, on page 12, you stated that "The PCCW system is not chlorianted," and on page 34, you stated "For the systems mentioned, PCCW, ECCS, SCCW, RHR and FW, the water is chlorinated... prior to being put into the systems."

Please explain the apparent inconsistency between these state- <

ments.

4. In your response to questions 2(1) and 8 of NECNP's Second Set of Interrogatories and Request for Production of Docu-ments to Applicants on NECNP Contention IV, on pages 8 and 34, you stated that you performed "bulk water sempling" to monitor for bacterial contamination. For each system at Seabrook filled with circulating water, please answer the following questions:

a) Describe the parameters measured by "bulk water sampling," including but not limited to oxygen, cell count, chlorine concentration, algae.

b) Describe the exact locations at which bulk water sampling is or will be pe; formed.

6 c) Describe the number of times per week, month or year, whichever is applicable, that bulk water sampling will be performed at each location.

Applicants on NECNP Contention IV, on page 35, you stated that you per#ormed ~ "visual examination of closed-loop systems ...[and) components on a routine bases" for determining the effectiveness of the microbiologically induced corrosion prevention program.

For each such system, please answer the following questions:

a) Please specifically identify which systems you consider "closed-loop systems."

b) Please describe how many times per year such exam-inations will be performed.

c) Please identify which components of each system will be examined, and the exact location of these components.

d) Identify and produce any documents, reports, or protocols that provide information relating to this visual inspection program.

7. For each system at Seabrook filled with circulating water, either fresh water or salt water, including but not limited to the Fire Protection, PCCW, ECCS, RHR, SW, AND FW sys-tems, for which microbiologically induced corrosion is controlled through injection of biocides or biostats, including but not

! limited to chlorine, hydrazine, or boric acid, please answer the following questions:

a) Please decribe the exact location of each place of injection, the distance (in feet of piping) between injection e points, and the type of chemical injected at each place of injec-tion.

b) Please describe the equipment used to make such injections at each location, c) Please describe the precise frequency or duration of injections (i.e. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 365 days per year) and con-centration (in parts per million) at each location.

d) Please describe your plans for monitoring the effectiveness of such treatments, including but not limited to sampling of the bulk water, sampling.of pipe-liquid interfaces, .

inspection, or use of an on-line biofouling monitoring device. '

e) For each technique identified above for monitoring the effectiveness of such treatments, indicate the equipment used to perform such monitoring, indicate the exact locations at which the monitoring will be performed through the system, and the dis-tance between monitoring points or locations, and the frequency which samples are taken.

f) Please describe your criteria for residual chlorine concentration at each sampling point that you consider adequate to control microbiologically induced corrosion through-out that system.

g) Identify and produce any documents, reports, or protocols that provide information relating to your chlorination or chemical treatment program.

8. For each system at Seabrook filled with circulating e water, either fresh water or salt water, including but not limited to the Fire Protection, PCCW, ECCS, RHR, SW, AND FW sys-

\

tems, for which biofouling is controlled through injection of biocides or biostats, including but not limited to chlorine, hydrazine, or boric acid, please answer the following questions:

a) Please decribe the exact location of each place of injection, the distance (in feet of piping) between injection points, and the type of chemical injected at each place of injec-tion.

b) Please describe the equirten't Gsed to make such injections at each locatien.

c) Please describe the precise frequency or duration of injections (i.e. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, 365 days per year) and con-centration (in parts per million) at each location.

d) Please describe your plans for monitoring the effectiveness of such treatments, including but not limited to <

sampling of the bulk water, sampling of pipe-liquid interfaces, inspection, or use of an on-line biofouling monitoring device.

e) For each technique identified above for monitoring the effectiveness of such treatments, indicate the equipment used to perform such monitoring, indicate the exact locations at which the monitoring will be performed through the system, and the dis-tance between monitoring points or locations, and the frequency which samples are taken.

l f) Please describe your criteria for residual 1

o chlorine concentration at each sampling point that you consider adequate to control biofouling throughout that system.

C - - _ _ _ _ . - - _ __ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _

. , ,j s.

, . ./ .

Y d

' /

4 .a .

'! . ,g) 7.dentify and produce any documents, reports, or

~

protocols that provide information relating to your chlorination .

or chemical.treatmert program. {

9.- For each. system at Seabrook' filled with circulating

'mter, either fresh' water or salt water, including but not limited to the Fire Protection, PCCW, ECCS, RHR, SW, AND FW sys-tems, please describe your program or techniques for inspecting ,

i piping and heat exchanger surfaces, including valves, baffle l

. plates,.and other component parts of the heat exchangers, to t determine the extent the presence of slime, sediment, or micro-biological organisms. In your response, please also answer the t

following specific quetions:

a) ' Describe in detail how such inspections-are or  ;

i will be performed b) Describe the operational phase of the system when the inspections are performed.

c) Describe the frequency of such inspections, the [

exact location of the surfaces that will be inspected, and any  !

t equipment that will be utilized to perform such inspections, i 4

d) If no inspections are to be performed, explain why not. I

10. Please identify all systems filled with circulating l water, either fresh water or salt water, including but not i d limited to the Fire Protection, PCCW, ECCS, RHR, SW, AND FW sys-  ;

tems, in which no chemical biocide, or biostat is used to control i f

f

,y i ,

• a i s

, (

biofoulf.nd or microbiologically induced corrosion, and explain 1

why you do'not l'alie,ve use of sitch chemidals in necessary io_ con- s r \  % ,

trol biofouling or microbiologically ' induced '

corrosion in thbse

\ ,

systems. s

11. Please identify all syhterek filled with circulating

., 'i y' water, either fresh water or sait U ter, including but not +-

limited to the Fire Prbtection, POCW, ECCS, RHR, SW, AND FW sys-'

%i tems, which are not monitored for.the presence of, or conditions i s condusive to, biofo611ng or micro 6ioiogically induced.corrosian, For each system, ple:1 e answer the folloVing questions:

a) Please identify tha metallurgical compositicit er other material used in the piping and in each of the varjous parts component parts of the system, including bust not limited to

\

valves, baffle plates,Iand bearings. ,

b) Please. describe hov you intend.to detect the presence of, or conditions condusive to, biofouling or micro-biologically induced corrosion in those )'iping materials and s other component parts that are rot chncrete or epoxy-lined materials.

c) If" you porfora inspections of tubing and heat exchanger components that are not cement or1 epoxy lined, please describe how such inspections ure performed and the frequency of such inspections.

] 12. For each system at Sabrook tilled with circulating ' .

water, either fresh water or salt water, including but not

g* .

limited to the Fire Protection, PCCW, ECCS, RHR, SW, AND FW sys-tens,.please describe any techniques you use, or plan to use, to prevent the build-up of slime in heat exchangers and all com-ponent parts thereof.

13. For each system at Seabrook filled with circulating water, either fresh water or salt water, including but not limited to the Fire Protection, PCCW, ECCS, RHR, SW, AND FW sys-tens, please answer the following questions:

a) Describe any program you have to monitor oxygen

-level and chlorine concentration in each system.

b) Produce any data you have measuring the oxygen lavels and chlorine concentrations in each system, including the time such samples or measurements were taken, and the location of the sampling or measurement points.

14. In NRC Inspection Report No. 50-443/87-24, at page 15-17, the inspector observed several problems concerning the sor-vice water piping and deter'ined m that neither microbiologically <

induced corrosion or biofouling was involved. Please describe the exact nature of the problem for which microbiologically induced corrosion or biofouling was considered a possible cauce, and answer tne following questions regarding this problem:

a) Identify and produce any documents, inspection

<; L./ reports, work requests, station information reports or photog-a raphs that in any way discuss, investigate, or evaluate this leak, or that idchtify or describe the extent and nature of the leak.

t f

k

b) Produce the most curront version of piping and instrumentation diagrams for this system. This question may be answered by reference to the appropriate diagram in the F.S.A.R. i

\

c) Describe when, and the circumstances under which, this problem was discovered.

I d) Describe exactly where in this system, the problem l l

pccurred, including whether it occurred on a weld, through the body of a valve, through any internal part of a valve, or through a mechanical joint on or in the valve.

e) Describe the metallurgical composition or other material used for each of the various partc where this problem occurred. comprising this heat-exchanger, f) Explain how your reached the conclusion that microbiologically induced corrosion played a role in this prob-lem.

g) Describe what you have done, or intend to do, to solve this problem and prevent it from occurring in this system in the future.

15. For each system at Seabrook filled with circulating water, either fresh water or salt water, including but not limited to the Fire Protection, PCCW, ECCS, RHR, SW, AND FW sys-tems, please describe your program for preventing or controlling bivalve larvae from settling on piping and heat-exchanger sur-o faces.

16. For each system at Seabrook filled with circulating water, either fresh water or salt water, including but not Iw-nu' uuutik uuuu r ie su ue in

limited to the Fire Protection, PCCW, ECCS, RHR, SW, AND FW sys-tems, please describe your program for measuring flow velocity to estimate flow rate, and answer the following questions regarding this system:

a) Describe the equipment used to take such measure-ments, b) Identify the locations or points at which such measurements will be taken.

c) Identify the distance between measuring points or locations.

d) Describe the frequency with which such measure-ments will be taken, and the operational phase of the plant when measurements will be taken.

e) Describe your criteria for flow velocity differen-tial at each point that you consider adequate to indicate the presence and/or absence of biofouling or other blockage through-out that system.

f) Identify and produce any documents, reports, or protocols that provide information relating to your flow velocity measurement program.

17) In your response to interrogatory 24 of NECNP's First Set of Interrogatories and Request for Production of Documents to Applicants on NECNP Contention I.V and IV, on page 18, you stated

' that should Applicants' chlorination and heat treatment program "not be appropriate, there are a number of options including

mechanical cleaning, injection of higher chlorine levels...

and/or heat treatment of the transition (intake) structure and intake tunnel." Please answer the following questions regarding this statement:

a) For each system at Seabrook filled with circulat-ing water, either fresh water or salt water, including but not limited to the Fire Protection, PCCW, ECCS, RHR, SW, AND FW sys-tems, describe your current heat treatment program, including the equipment used in performing such heat treatment, the tempera-tures for such heat treatments, and the frequency such heat treatment will be performed.

b) For each system at Seabrook filled with circulat-ing water, either fresh water or salt water, including but not limited to the Fire Protection, PCCW, ECCS, RHR, SW, AND FW sys-tems, please describe the criteria or parameters you will use to determine that chlorine and heat treatment are "not appropriate,"

and the criteria or paramaters you will use to determine what alternative treatment (s) should be used.

c) For each system at Seabrook filled with circulat-ing water, either fresh water or salt water, including but not limited to the Fire Protection, PCCW, ECCS, RHR, SW, AND FW sys-tems, describe how frequently you plan to conduct conduct "mechanical cleaning" should your current program "not be

• appropriate," and describe any equipment that will be used to perform such "mechanical cleaning."

a d) For each system at Seabrook filled with circulat-ing water, either fresh water or salt water, including but not limited to the Fire Protection, PCCW, ECCS, RHR, SW, AND FW sys-tems, describe your plan to conduct "heat treatment of the transition (intake) structure and intake tunnel," including the frequency that such treatments will be made, and explain how this treatment differs from your current heat treatment program.

e) Identify and produce any documents, reports, or protocols that provide information relating to your currrent heat treatment program.

f) Identify and produce any documents, reports, or protocols that provide information relating to your program or plans for "mechanical cleaning, injection of higher chlorine levels... and/or heat treatment of the transition (intake) struc-ture and intake tunnel."

Respectfully submitted,

$ ( . $

Andrea Ferster ,

HARMON & WEISS 2001 "S" Street N.W. Suite 430 Washington, D.C. 20009 (202) 328-3500

-- - - - + + * = - - . . - - . . . - ,

DC' KC IL C' U)Nhc 1E FEB 22 P4 :17 (FFILE M SEch!Ar,v uCCMElin') & SERVICf~

BRANCH CERTIFICATE OF SERVICE I certify that on February 19, 1988, copies of the foregoing interrogatories were served by first-class mail on all parties listed on the attached service list.

^

. Z" Andrea Ferster l

1 l

l 1

f G

SEABROOK SERVICE LIST - ONSITE LICENSING BOARD 100 Main Street

'Sheldon J. Wolfe, Chairman J.P. Nadeau Town of Rye 'Greg Bery Amesbury,MA 01913 Office of General Counsel I?.S.NRC 155 Washington Road Office of General Counsel Washington, D.C. 20555 Rye, New Hampshire 03870 U.S. NRC Washington, D.C,20555 Richard E. Sullivan, Mayor

• By hand (Dr. Jerry Harbour Office of General Counsel City Hall Mr. Angie Machiros, Newburyport,MA 01950 Chairman " By Overnight Mail U.S. NRC Washington, D.C.20555 Town of Newbury Alfred V. Sargent, Chairman Town Hall,25 High Road

'Dr. Emmeth A. Luebke Board of Selectmen Newbury,MA 01951 5500 Friendship Blvd. Town of Salisbury, MA 01950 Apartment 1923N George Dana Bisbee, Esq.

Chesy Chase, MD 20815 Senator Gordon J. Humphrey Geoffrey M. Huntington, Esq.

U.S. Senate Office of the Attorney General Atomic Safety and Licensing Washington, D.C. 20510 State House Annex

' Concord, NH 03301 Board Panel (Attn. Tom Burack)

U.S. NRC Washington, D.C. 20555 Selectmen of Northampton Allen Lampert Northampton, New Hamp- Civil Defense Director Atomic Safety and Licensing shire 03826 Town of Brentowood Exeter,NH 03833 Appeal Board Panel U.S. NRC Senator Gordon J. Humphrey 1 Eagle Square, Ste 507 Richard A. Hampe, Esq.

Washington,D.C. 20555 Concord,NH 03301 Hampe and McNicholas Docketing and Senice 35 Pleasant Street Michael Santosuosso, Concord,NH 03301 U.S. NRC Washington, D.C. 20555 Chairman Board of Selectmen Gary W. Holmes, Esq.

Mrs. Anne E. Goodman Jewell Street, RFD # 2 Holmes & Ellis Board of Selectmen South Hampton, NH 03S42 47 Winnacunnent Road 1315 New Market Road Hampton,NH 03S42 Durham,NH 03842 Judith H. Mizner, Esq.

Silverglate, Gertner, et al. William Armstrong Willitm S. Lord, Selectman 88 Broad Street Cin! Defense Director Town Hall- Friend Street Boston, MA 02110 10 Front Street Exeter,NH 03833 Amesbury,MA 01913 Rep. Roberta C. Pevear Jane Doughty Drinkwater Road CaMn A.Canney SAPL Hampton, Falls, NH 03S44 City Manager City Hall 5 Market Street Portsmouth,NH 03801 Phillip Ahrens, Esq. 126 Daniel Street Assistant Attorney General Portsmouth,NH 03S01 Carol S. Sneider, Esquire State House, Station # 6 Augusta,ME 04333 Matthew T. Brock, Esq.

Assistrnt Attorney General 1 Ashburton Place,19th Floor Shaines & McEachern Boston,MA 02108 "Thomas G. Dignan, Esq. P.O. Box 360 R.K. Gad II, Esq, Maplewood Ave.

3 Ropes & Gray Portsmouth, NH 03S01 Stanley W. Knowles Board of Selectmen 225 Franklin Street Boston, MA 02110 Sandra Gavutis P.O. Box 710 North Hampton, NH 03826 RFD 1 Box 1154 Robert A. Backus, Esq. East Kensington, NH 03S27

- ~ . _ . .

_ ____... Backus, Meyer & Solomon 11112well Street Charles P. Graham, Esq.

Manchester,NH 03105 McKay, Murphy and Graham

' w a: , i