ML20213E259

Forwards Requests for Addl Info Sent to Applicant for Use in Controlling Numbering of Requests.Duplication Should Be Avoided

ML20213E259
Person / Time
Site:	Columbia
Issue date:	09/15/1982
From:	Kerrigan J Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
CON-WNP-0545, CON-WNP-545 NUDOCS 8210180031
Download: ML20213E259 (35)

Text

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"E?0PN100" F0l1: " ranch Chiefs (OSI, OE, DhFS) /'

FPM: Janis Verrigan, Acting Chief O Licensing Branch ilo. 3 Division of Licensing 51.'PJ ECT : MI wi" PERI.'!G FOR Ti!E '.'hP-3 (?L 9E'/IE'!

Peference: tielorandum, Miraglia to Eranch Chiefs,

Subject:

WP-3 ol accentance leview, dated July 'i,19'32 The referenced nemorant'um forwar>.'ed for your revies a cocy of cuestions c;enerated by EGhG, Inc. during their accep tance revicis of the '?.'P-3 F5.'a. .h reques ted in the '1e:.orandun, your responses desionated speci fic RAI nurners for thnse s;uestions relaten to your revieu re-snonsibilities.

Enclosed for your information and use in controlling your MI nuM)ering is a cony of the ilAls (environ'tental from h3.P, safety froa ECLG) that ware sent to the apolicant. olease ensure tnat these .'AI numers are not duplicated unen adcitional questions are develonen during your cetailed environenental and safety revicus.

The CL reviou schedule is now being developed and vill be forearced to you in the near future.

The P1 vision of Licensing coint of contact for the review is nuke '1her'lcr,

'27792.

OzIginal Signed Ppr ~

Janis Kerrigan, Acting Chief Licensino ') ranch ro. 3 Division at Licensing inclosure:

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FR0ti: Janis Kerrigan, Acting Chief Licensing Branch ilo. 3 Division of Licensing SUPJECT: RAI N WCERING FOR THE 1:NP-3 OL REVIEW

Reference:

Memorandum, itiraglia to Branch Chiefs,

Subject:

WNP-3 OL Acceptance Review, dated July 9,1982 The referenced raenorandum forwarded for you review a copy of ouestions generated by EG3G, Inc. during their acceptance review of the WP.'P-3 FSAR. As requested in the memorandum, your responses designated specific RAI numbers for those questions related to your review re- .

sponsibilities.

• Enclosed for your information and use in controlling your RAI nuntering is a copy of the RAIs (environmental from !!RR, safety from EGSG) that were sent to the applicant. Please ensure that these RAI nud ers are not duplicated when additional questions are developed during your detailed environemental and safety reviews.

The OL review schedule is now being developed and will be forwarded to you in the near future.

The Division of Licensing point of contact for the review is Duke Wheeler, X27792.

higinal Signed Pyy' Janis Kerrigan, Acting Chief Licensing Branch Ho. 3 Division of Licensing

Enclosure:

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UNITED STATES NUCLEAR REGULATORY 60MMl3SION

$: e WASHINGTON, D. C. 20555

%, ' ,/ SEP 171982 MEMORANDUM FOR: Branch Chiefs (DSI, DE, DHFS)

FROM: Janis Kerrigan, Acting Chief Licensing Branch No. 3 Division of Licensing

SUBJECT:

RAI NUMBERING FOR THE WNP-3 OL REVIEW

Reference:

Memorandum, Miraglia to Branch Chiefs,

Subject:

WN?-3 OL Acceptance Review, dated July 9,1982 The referenced memorandum forwarded for your review a copy of questions generated by EG8G, Inc. during their acceptance review of the WNP-3 FSAR. As requested in the memorandum, your responses designated specific RAI numbers for those questions related to your review re- ~

• sponsibilities. ..

Enclosed for your information and use in controlling your RAI numbering is a copy of the RAIs (environmental from NRR, safety from EG8G) that were sent to the applicant. Please ensure that these RAI numoers are not duplicated when additional questions are developed during your detailed .

environemental and safety reviews.

The OL review schedule is now being developed and will be forwarded to you in the near future.

The Division of Licensing point of contact for the review is Duke Wheeler, X27792.

()^tA&W Wi W

/Tanis Kerrigan, Acting Chief L'icensing Branch No.

(jDivisionofLicensing

Enclosure:

As stated 6

O e

ENCLOSURE

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100.1 Table 1.8-3 addresses conform'ance and exceptions to the Standard (1.8.3 and Review Plan (SRP),'NUREG-75/087. You have stated that WNP-3 will other be reviewed and evaluated relative to NUREG-0800. This review sections) ' and evaluation should conform to the following:

1. Applications for light water cooled nuclear power plant operating licenses docketed after May 17, 1982, shall include an evalua-tion of the facility against the Standard Review Plan (SRP) in' effect on May 17, 1982, or the SRP revision in effect six months prior to the docket date of the application, whichever is later.

2. The evaluation shall include an identification and description of all differences in design features, analytical techniques, and procedural measures proposed for a facility and those. correspond-ing features, techniques, and measures given in the -SRP accep-tance criteria. Where such a difference exists, the evaluation shall discuss how the alternative proposed provides an acceptable method of complying with those rules or regulations of Commission, or portions thereof, that underlie the corresponding SRP acceptance criteria.

3. The SRP was issued to establish criteria that the NRC staff intends to use in evaluating whether an applicant / licensee meets the Commission's regulations. The SRP is not a substitute for

- the regulations, and compliance is not a requirement. Appli-cants shall identify differences from the SRP acceptance criteria and evaluate how the proposed alternatives to the SRP criteria provide an acceptable method of complying with the Commission's regulations.

In addition, a schedule should be provided for completion of the review and evaluation.

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l 311.1 As per Regulatory Guide 1.70, the site area map should include the i site boundary lines and if they are the same as the plant property (2.1.1.2) lines, this should be stated, l' I

j As per Regulatory Guide 1.70, an estimate should be provided of the 311.2 l t4me required to evacuate all personnel from the exclusion area.

(2.1.2.2) L

[

As per Regulatory Guide 1.70, provide estimates of the weight of the 451.1  !

100-year return period snowpack and the weight of the 48-hour (2.3.1.2) Using Probable Maximum Winter Precipitation for the site vicinity.

these estimates, provide the weight of snow and ice on the roof of each safety-related structure.

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240.1 ' For non-safety-related water supplies, demonstrate that the supply will be adequate for a 100-year drought, or show that it is (2*4*11*1) sufficient to not cause unacceptably frequent use of the emergency systems. Include a discussion of low flow in the Chehalis River.

241.1 1 The type, location, and purpose of each instrument used for; surveillance .o f foundations for safety-related structures 'should be (2.5.4.13) presented.

Provide or reference a discussion of the testing and inspection to 410.1 be performed to verify that the groundwater drainage system capa (3.4.1.2) and reliability are met and the instrumentation and control necessary for proper operation of the system are adequate.

As per Regulatory Guide 1.70, su=narize for each safety-related 220.1 structure, system, and component that may be so affected, the desig

(3.4.2) basis static and dynamic loadings, including consideration of hydro-static loadings, equivalent hydrostatic dynamically induced loadings, coincident wind loadings, and the static and dynamic effects on i

foundation properties. Provide or reference this material.

2 I

Table 3.5.1-1 has several columns that have "under investigation" 410.2 Provide this data or a listed instead of the necessary data.

!- (3.5.1.1),

schedule for providing it.

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I 420.3 Provide or reference the following as specified in Regulatory ,

i (3.5 1 1) . Guide 1,70:

l i i  :

A tabulation showing the safety-related structures, systems, and >

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i components outside contair. ment required for safe shutdown of the 2

reactor under all ccnditiens of plant operation should be provided f l .l I

and, as.a minimum, should include the follcwing: }

i i .t i 1. Locations of the structures, systems, or ccepor.ents. -  :

2. Applicable seismic category and quality group classifications 1

i (may be referenced from Section 3.2).

I i

! 3. Sections in the SAR where descriptions of the items may be found.

i

4. Reference drawings or piping and instrumentation diagrams where '

j applicable (may be referenced from other sections of the jSAR).

l

( j I 5. Identification of missiles to be protected against, their source, i

and the bases for selection.  !

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6. Missile protection provided. t The ability of the structures, systems, and components to withstand the effects of selected internally generated missiles should be evaluated.

b i

I 410.4 Provide or reference'the following as specified in Regulatory (3.5.1.2) Guide 1.70:

)

L A tabulation shewing the safety-related structures, systems, and l

componcrits inside containment required for safe shutdown of the j

j

- reactor under all conditions of the plant operation, including operational transients and postulated accident conditions, should be provided and, as a minimum, should include the following: i l

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-- - ..-, _e -m_--,._ -,,.~.-.4--.,--,_-----.. .,_,m__-,_-,-,--,~~_-., -m.. _, -- - , -[

1. Location of the structure, system, or ccmponent.

2. Identification of missiles to be protected against, their source, and the. bases for selection. -

3. Missile protection provided.

P The ability of the structures, systems, and components to withstand the effects of selected internally generated missiles should be evaluated.

. -v

*; 250.1 If applicable for the case of turbine destructive overspeed, an

(3.5.1.3) analysis should be presented justifying the assumption of only one disc failure. Turbine overspeed acceleration characteristics, statistical distribution of destructive overspeed failure speeds, r

and related information should be considered in the evaluation'of theprobabilityofsecondwheelfailureduringthe..!ntervalof

,y physical disassembly caused by the first failure. Provide or. refer-

ence this information.

! 410.5 Table 3.5.1-3 states the information for the dry cooling tower (3.5.1.4) enclosure will be provided later. Provide this information or a

. . , schedule for furnishing it.

I j-410.6 The externally generated missile protection analyses should take

(3.5.1.4) into account the effect on ventilation openings in the various 1

facility buildings housing essential shutdown equipment. Reference

, or provide a discussion addressing this subject.

311.3 You state that your analysis for aircraft hazards is forthcoming.

l (3.5.1.6) Provide a schedule for furnishing this information.

I 410.7 This section does not provide the detail required by Regulatory

! (3.5.2) Guide 1.70 which states that it should be demonstrated that safety- '

.. related structures, systems, and components are adequately protected .

2-4 I . ,- . _ _ . -- - _ . . _ . _ . - - - - _ , _ . _ - - - _ - - . . , , - . _- . - - _ , - -

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against very low probability missile strikes by physical barriers According to the Standard Review Plan or protective structures.

(NUREG-0800) this should even include such element service water intakes, buried components, and access openings and Provide or reference this. level of penetrations in structures.

' - detail for this FSAR section.

220.2 Regulatory Guide 1.70 states that the basis for any response spe that differ from the spectra given in Regulatory Guide 1.60 should (3.7.1.1) You state that the vertical design be included in this FSAR section.

response spectra does not comply with the recommendations of Regulatory Guide 1.60 but do not provide a basis for this divergen Reference or provide this basis.

220.3 Regulatory Guide 1.70 states the applicant should indicate the to which the procedures for considering the three components of (3.7.2.6)

' earthquake motion in determining the seismic response of; structures systems, and components follow the recommendations'of Kegula Reference or provide this information.

Guide 1.92.

220.4 Provide an FSAR Section 3.7.4 on seismic instrume in the Standard Review Plan (NUREG-0800) and Regulatory G'u (3.7.4)

Provide a discussion of the extent of compliance with Subsection 210.1 of the ASME Code,Section III, Division I for the procedures used

, (3.8.2.4) in the design and analysis of the steel containment.

. These In Section 3.8.2.5.1 you refer to Tables 3.8.2-3 and' 3.8.2-3a.

220.5 tables have not been provided. Provide these tables or a schedule (3.8.2.5) for when they will be provided.

As per Regulatory Guide 1.70, Revision 3, provide a discuss 220.6 (3.8.3.3, extent of compliance in the indicated sections with the following 3.8.3.4, &

1.

ACI-349, " Code Requirements for Nuclear Safety Related Concr 3.8.3.5)

~' Structures".

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2. AISC, " Specification for Design, Fabricatien and Erection of Structural Steel for Buildings".

3. Subsection flF of the ASME Code,Section III, Division .l.

220.7 . Provide your. schedule..for..furni.shing design information for the Ultimate Heat Sink - Dry Cooling Towers.

(3.8.4.1.3) 220.8 Provide a Section 3.8.4.8 that discusses the effects of masonry (3.8.4.8) walls on other structures in' accordance with SRP 3.8.4 (fiUREG-0800 220.9 The SRP (t4UREG-0800) and Regulatory Guide 1.70 state that a descrip-tion should be provided of the relationship between adjacent.founda-

-(3.8.5.1) tions, including any separation provided and the reasons for such separation. Reference or provide this information. Also provide the dry cooling tower information identified as later or provide a schedule for its submittal. ,

210.2 Regulatory Guide 1.70 states that the description of the computer (3.9.1.2) programs used in dynamic and static analysis should include the extent of the programs application, and the design control measures employed to demonstrate the applicability and validity of each

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program. Reference or provide this information.

i 210.3 Either supply the information identified as later in Appendix 3.9.38 (Appendix or provide a schedule for submittal of this information.

3.9.38) l The SRP (ilDREG-0800) contains the following requirements:

210.4 l

l (3.9.3.4)

- All safety-related components which utilize snubbers in their support l The i

I systems should be identified and tabulated in the FSAR.'

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+ .i' tabulation should include the following information: (i) identifi-

- cation of the systems and components in those systems which utilize snuobers, (ii) the number of snubbers utilized in each system and on components in that. system, (iii) the type (s) of snubber (hydraulic

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or mechanical) and the corresponding supplier identified, (iv) l

- specify whether the snubber was constructed to the rules of ASME Code Section II.I, Subsection NF, (v) state whether the snubber is j

used as a shock, vibration, or dual purpose snubber, and (vi) for l

snubbers identified as either dual purpose or vibration arrestor type, indicate if both snubber and component were evaluated for .

fatigue strength.  ;

Provide or reference this material for snubbers utilized on all safety-related components.

Provide a schedule for submittal of the in-service testing 210.5 ,-

~(3.9.6) program. ..

Provide the missing information or a 271-.1 Table 3.10-1 is not complete.

schedule for providing it.

(3.10)

Provide the missing 270.1 Tables 3.11-1 and 3.11-2 are not complete.

information or a schedule for providing it.

(3.11.1)

Provide a 270.2 Figures 3.11-14 and 3.11-15 have not been submitted.

schedule for. submitting these figures.

(3.11.1)

"The initial fuel cycle for WNP-3 is not consis-490.1 Chapter 4.0 states:

tent with the extended fuel cycle described in Chapter 4 of CESSAR*F (4.0 and Although the fuel design parameters in CESSAR-F other through Amendment 6.

may envelope the WNP-3 specific fuel design this has not been sections)

WNP-3 specific evaluations are currently in process and confirmed.

if it is determined that Chapter 4 or portions thereof are not applicable, an amendment will be filed with WNP-3 specific info 2-7 o

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t Chapter 4.0 Provide a schedule for completion of these evaluations.

Pro-

-data is used in other chapters of the FSAR and/or CESSAR-F.

vide an evaluation of the effects of the WNP-3 fuel cycle data on the results in other chapters (e.g., accident analyses, instrumen-tation setpoints, etc.)

Provide in Table 5.2-1 or reference the code requirements (class, 210.6 edition and addenda) for the RCS pumps and RCPB valves (A/E). l (5.2.1.1)

Either supply the infor-210.7 Section 5.4.1.1.2 references Table 5.4-1.

mation identified as "later" in Table 5.4-1 or provide a schedule (5.4.1.1.2) for its submittal.

• 1 I

Is Section 5.4.2.2, Steam Generator In-Service Inspection, intended 250.3 If this is l to replace Section 5.4.2.2, Description, in CESSAR-F?

(5.4.2.2) If the case, provide a description of the WNP-3 steam generator.

Section 5.4.5 of CESSAR-F is applicable to WNP-3 this should.be inoicated or the a.propriate n information should be provided for this section.

Provide the post-LOCA design heat load for the shutdown cooling 440.1 heat exchangers. Also, Note 2 in Table 5.4.7-2 should be replaced (5.4.7.1.3) by specific information rather than a general reference to the applicant's SAR.

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For all postu. lated design basis accidents involving release of water 281.1 into the containment building, estimate the time-history of the pH

-(6.1.1.2) Identify of the aqueous phase in each drainage area of the building.

and quantify all soluble acids and bases within the containment.

Identify the locations in the containment where water may be trappe i

480.1 The quantity and prevented from returning to the containment sump.

f (6.2.1.1.2) Discuss how the static head of water involved should be specified.

for recirculation pumps may be affected.

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u. i 480.2 , Reference or provide a discussion of the administrative controls (6.2.1.1.3). and/or electrical intericcks that would prevent the inadvertent operation of the containment heat removal system or other systems that could result i.n pressures lower than the external design pressure of the containment structure. Identify the worst single

, failure that could result in the inadvertent operation of the containment heat removal system.

480.3 Provide the results of the confirmatory review of the containment (6.2.1.5) pressure analysis for emergency core cooling system capability ,

studies.

480.4 Several concerns have been identified relative to containment (6.2.2.3) sump designs and their effect on long tem cooling following a loss of coolant ac,cident (LOCA). The staff is engaged in.a ge-neric program, des.ignated as Unresolved Safety Issue (USI) A-43,

" Containment Emergency Sump Performance," to resolve these con-cerns.

Draft flUREG-0897, which is currently under staff review, summarizes key technical findings related to USI A-43, provides reco=endations for resolution of attendant safety issues, and provides guidance for the design and performance evaluation of the containment emer-gency sump. The p;roposed technical resolution includes recomended changes to Regulatory Guide 1.82, " Sumps for Emergency Core Cooling and Containment Spray Systems" and t;RC's Standard Review Plan I

(t1UREG-OS00), Section 6.2.2., " Containment Heat Removal System" and 6.3, " Emergency Co;re Cooling System." -

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480.4 Pending the completion of Unresolved Safety Issue A-43, more

'(continued) immediate actions are required to assure greater reliability of safety system operation. We therefore require the following actions to provide additional assurance that long term cooling

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of the containment and reactor core can be achieved and maintained following a postulated LOCA.

1. Establish a procedure to perform an inspection of the containment, and the containment sump area in particular, to identify any materials which have the potential for becoming debris capable of blocking the containment sump when required for recirculation of coolant water. Typically, these materials consist of:

plastic bags, step-off pads, health physics instrumentation,

' welding equipment, scaffolding, metal chips and screws, portable inspection lights, unsecured wood, construction materials, and "As tools as well as other miscellaneous loose equipment.

licensed" cleanliness should be assured prior to each .startup. -

This inspection shall be performed at the end of each shutdown before contaiqm,ent t/ solation. . .

2. Pipe breaks, drain flow and channeling of spray flow released below or impinging on the containment water surface in the area of the sump can cause a variety of prcblems; for example, air entrainment, cavitation and vortex formation.

e Describe any changes you plan to make to reduce vortical flow in the neighborhood of the sump. Ideally, ficw should approach uniformly from all directions. ..

3. Evaluate the extent to which the containmen' suinps satisfy [

each of the positions of Regulatory Guide 1.82. .The followinc additional guidence is provided for this evaluation:

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a. Provide the size of openings in the fine screens and .

- ccmpare this with the minimum dimensions in the pumps which take suction from the sump, the mini-mum dimension in any spray' nozzles and in the fuel assemblies in the reactor core or any other line in .

the recirculation flow path whose size is comparable to or smaller than the sump screen mesh size in order j

to show that no flow blockage will occur at any point past the screen.

b. Estimate the extent to which debris could block the trash rack or screens.

If a block-age problem is identified, describe the corrective ,

actions you plan to take._ '

c. For each type of thermal insulation used in the contain-ment, provide the following information: i .

-(i) type of material including composition and density, L<

(ii) manuf3 cturer and brand name, (iii) methoU of attachment, (iv) location and quantity in containment of each type, an estimate of the tendency of each type to1 form' (v) {

parti:les small .enough to pass through the fine screen in the suction lines. I

d. Estimate what the effect of these insulation particles sould be on the operability and performance of all Address effects pumps used for recirculation cooling.

on pump seals and bearings.

Provide an evaluation of your conformance to Branch Technical 480.5 Identify and justify any deviations.

(6.2.4) Position CSB t-4.

F Provide instrument lines containment penetration information in 480.6 Table 6.2.4-1 and Figure 6.2.36 which is labeled as "later".

(6.2.4) 2-11 a

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s 421.1 Table 7.3-20 is shown as "to be supplied later".

Provide either the

• (7.37 .teble or a date by which it will be supplied.

421.2 -

Section 7.6.2 contains no analyses of instrumentation installed'to (7.6.2) prevent or mitigate the consequences of cold water slug injections and overpressurization of low-pressure systems; reference or pro-

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vide these analyses or show these analyses are not applicable to

- WNP-3.

430.1 The Utility Grid Description (Section 8.1.1) and the Offsite Power (8.0) System (Section 8.2) should be revised to reflect the cancellation of WNP-5 and any consequential changes in the BPA grid structure.

410.8 Section 9.2.5 does not define the number of cells per cooling tower (9.2.5) train, nor does it contain Figures 9.2.5-2a through 9.2.5-2d.

Confirm the date by which you intend to. supply this information.

410.9 Section 9.2.6 does not contain a stroage facility failure (9.2.6) analysis. Provide this analysis or a date by which it will be supplied.

410.10 Section 9.2.8 does not contain Figure 9.2.8-1; provide this drawing (9.2.8) or a date by which it will be supplied.

281.2 Section 9.3.2 does not include requirements to minimize, to the (9.3.2) extent possible, hazards to plant personnel; provide these require-ments.or a date by which they will be supplied.

410.11 Section 9.4'does not include piping and instrumentation diagrams for i

(9.4) any of the systems discussed; provide these diagrams or a date by

[

which they will be supplied.

l 410.12 Section 9.4.7 states that the CCWS Dry Cooling Towers Electrical Equipment Room Ventilation System design is conceptual only. Con'-

(9.4.7) firm the date by which you intend to supply this information.

(

! 280.1 Table 9.5.1-2 provides a listing of unusually hazardous material.

(9.5.1.1.6) As per Regulatory Guide 1.70, Revision 3, discuss the' conditions under which these materials are to be used.

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280.2 'As per Regulatory Guide 1.70, Revision 3, include in the evaluation (9.5.1.3) .

of fire hazards in each zone, a discussion of the expected rate of fire development and maximum intensity, as these relate to fire detection response. sensitivity and automatic and manual firefighting

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activities. Also, discuss the generation of smoke and other com-

. bustion products considering both the toxic and corrosive character-istics. .'

. 280.3 As per Regulatory Guide 1.70, Revision 3, where automatic fire (9.5.1.3) suppression systems are installed, include an evaluation of the ,

effects of the postulated fire both with and without actuation of the systems.

280.4 Many items in Appendices 9.5-1 through 9.5-21, " Fire Hazard Analyses (9.5.1.3) by Fire Areas" are marked "Later". In the proposed completion of these items, they should be evaluated against the Standard Review Plan, (NUREG-0800).  ;

280.5 Discuss the extent of conformance to the guidance given in NFPA 27.

(9.5.1.5) 430.2 As per Regulatory Guide 1.70, Revision 3, specifically provide or (10.4.1) reference discussions of the following: 1) the anticipated inven-tory of radioactive contaminants in the main condensers during operation and during shutdown, 2) anticipated air leakage limits,

3) control functions that could influence operation of the primary coolant or secondary systems, 4) protection of safety-related equipment frcm flooding resulting from failure of the' condenser,

5) a procedure to repair condensate leaks and 6) the-length of time the condenser can operate with degraded conditions without affecting

- the condensate /feedwater quality for safe operation.

281.3 As per Regulatory Guide 1.70, Revision 3, include a discussion of (10.4.6) the control of chloride ions and other contaminants in the conden-sate cleanup system.

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410.13 As per Regulatory Guide 1.70, Revision 3, provide a discussion of ]

(10.4.7) ,the piping analysis, including any forcing function, or results of '

test programs performed to verify that the uncovering of the feed-water lines could not , occur or that the uncovering would not result  !

- in unacceptable damage to the system. f 281.4 Section 10.4.8.1-e discusses the blowdown demineralizer systems

( 10.'4. 8.1 )

removal of impurities from the blowdown and references Se~ction 10.4.11. Section 10.4.11 states this system has been deleted from WNP-3. If this is correct, the referencing paragraph should also l be deleted from the FSAR.

410.14 Section 10.4.9.3 discusses the design to prevent water hammer in (10.4.9.3) the pipe routing of the auxiliary feedwater, system to the steam generators. It further states that tests acceptable to the NRC will be performed to verify unacceptable water hammer will not j

occur. Describe the proposed tests, how they will be conducted and i

l when they will be conducted. .

460.1 Supply information relating to the effluent radiation monitors for (11.5.2.4.2) steam generator blowdown flash tank vent and steam seal gland steam, f condenser ventilation which the FSAR indicates as later or provide a schedule for submittal of this information. I i

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471.1 As per Regulatory Guide 1.70 indicate whether, and if so how,.the (12.3.4) guidance provided by Regulatory Guide 1.97 has been followed con-cerning area radiation and airborne radioactivity monitoring instru-mentation. . Reference or provice this information.

471.2 The SRP (NUREG-0800) calls for a description of procedures for (12. 3. 4-)

locating suspected high activity areas. Reference or provide this information.

471.3-Regulatory Guide 1.70 states that information on the auxiliary and/or emergency power supply should be provided. This information has not (12.3.4) -

beenprovidedforthegeneral'brearadiationmonitors.'Provideor

• reference this information.

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471.4 .

The Annual Whole Body Dose table is not ccmolete. Furnish this information or provide a sche.dule for furnishing it.

(12.4.3) .

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471.5 The SRP (NUREG-0800) and Regulatory Guide 1.70 state that the appli-

. cant should indicate whether, and if so how, the guidance of (12.5.1).

Regulatory Guides 8.2, 8.8, 8.10 and 1.8 has been folicwed and where applicable, describe the specific alternative approaches used.

Provice or reference a discussion of your specific conformance or non-conformance to the guidelines in these Regulatory Guides.

471.6 Regulatory Guide 1.70 and the SRP (NUREG-0800) state that the (12.5.2) description of the health physics instrumentation should include the instruments sensitivity. You provided the type of radiation the instrument detects and not the instrument sensitivity in Table 12.5-1. Provide the requested information.

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471.7 Regulatory Guide 1.70 states that it should be indicated whether, and if so how, the guidance provided by Regulatory Guides 8.3, 8.4, (12.5.2) If this 8.8, 8.9, 8.12, 8.14, 8.15, and 1.97 has been followed.

guidance has not been followed, the specific alternative methods used should be described. Provide or reference a discussion of this information. ,

471.8 The SRP (NUREG-0800) requires information describing the implemen-tation of Regulatory Guides 1.8, 8.2, 8.7, 8.8, 8.9, 8.10, 8.26, 8.27, (12.5.3) and 8.29. This information is not completely discussed. Provide this material, including a specific discussion of the' implementa-tion of Regulatory Guides 1.8, 8.9, 8.26, 8.27, and 8.29.

630.1 This section should include a chart to show the schedule of, or each The time scale should (13.2.2) part of, the reactor operator training program.

2-15 D I

be relative to expected fuel loading and shculd also display the

- preoperational test period, expected time for examinations for licensed operators prior to criticality, and expected time for This examinations for 1.i censed operators after criticality.

~

section should delineate clearly the extent to which the training

- - program has been accomplished at the approximate time of the sub-mittal of the' FSAR.

630.2 Section 13.2.5 status that Regulatory Guide 1.101 is no longer (13.2.5) active. This was withdrawn at one time but has been reinstated as Revision 2 in October of 1981 and should be addressed in the FSAR Section 13.2.5 also indicates that information regarding compliance with Regulatory Guides 8.2, 8.8 and 8.10 will be supplied later.

Either supply this information or provide a schedule for its submittal.

The Washington fluclear Project 3 Emergency Preparedness P,lan indi-810.1 ~

cates that additional information on some facilities in the design (13.3.2) phase and on county and state emergency response plans will be provided later. Provide a schedule for submittal of this informa-tion. .

State whether all tests at each given power test plateau will be 640.1 (14.2.4) performed before increasing power to the next test plateau (power level).

Clarify the description of the review process for preo~perational 640.2 (14.2.5) and startup test results. Include: (1) requirements for review and

- approval of the test data for each major test phase before beginning the next phase, and (2) a description of the requirements for review and approval of*the startup test data at each major power test plateau before raising power to the next test plateau during the power ascension phase.

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640.3 'Section 14.2.12 indicates that test descriptions for other postcore (14.2.12) . hot functional and power ascension tests will be provided later.

Provide a schedule for submittal of this information or submit the test descriptions. .

451.2 . Sections 15.6.2.5 and 15.6.3.2.5 reference Tables 15-2 and 15-3.

(15.6.2.5 & These tables.' state that for the event induced iodine spike case 15.6.3.2.5) that results will be provided later. Provide a schedule for sub-mittal of this- information or supply the information.

100.2 The WNP-3 FSAR contains numerous references to the CESSAR-FSAR but (All) does not specifically address the Safety Evaluation Report (NUREG-0852) for the CESSAR-FSAR.

This Safety Evaluation Report (SER) imposes requirements on applicants utilizing the CESSAR-FSAR and identifies open items. The applicant should provide a plan for identifying and addressing the interface between NUREG-0852 and the WNP-3 FSAR to assure that the SER requirements are addressed in the WNP-3 FSAR and are, or will be, incorporated in the" design and operation of WNP-3. Provide a schedule for implementation of this plan. Types of information to be addressed in this plan are as follows.

1. Open items identified in th'e SER. This should include both items identified for final resolution by the licensee as well as those for Combustion Engineering resolution. Although the latter items may not require specific licensee action at this time, licensee tracking is necessary to insure that any resolu-tion is incorporated into the WNP-3 design.

2. Specific license conditions and technical specifications which are imposed by NRC cn applicants referencing CESSAR.

3. Interface requirements identified by NRC which differ from, or are in addition to, those< identified in CESSAR.

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'The following are specific examples of items from the CESSAR-SER

. which sculd be addressed.

1. The SER ide'nti.fies, in Section 15.3.9, specific items which

" must be implemented by the licensee as an interim fix for anticipated transients without scram until rulemaKing and formulation of final requirements are completed. These items are not discussed in Section 15.8 of the WNP-3 FS'AR.

2. The SER requires, in Section 7.3.2, that control logic be con-figured such that an ESFAS signal will override MSIS. This is not consistent with the statement in Section 7.3.1 of the WNP-3 FSAR which states that "there are no overrides on any

' MSIS actuated devices with the exception of the atmospheric dump valves".

3. The SER requires specific plant technical specifications in ~

Section 5.2.2 which should be addressed in the WNP-5 FSAR.

100.3 Describe your system for monitoring updates to the CESSAR-FSAR and SER and incorporating these updates into the WNP-3 systems,.

(All) operations and documentation.

Provide a Section 18 discussion regarding a detailed control 620.1 room design review per NUREG-0660, NUREG-0737 and SECY 82-111.

(18) 100.4 Correct th'e following deficiencies in the General Information:

a. 10 CFR 50.33(d)(2)(ii) requires " names, addresses and (General citizenship!' of the Directors. The tendered application Information) gives the names and addresses but the citizenship is not included. '

b. 10 CFR 50.33(d)(2)(iii) requires a statement as to whether the corporation is " owned, controlled or dominated by an alien, a foreign corporation, or foreign government and if so, give details." The tendered application is silent on this requirement.

'2-18

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G SECT 10tl (HGEB) .

a your write-up of FSAR Sections 2.5.4 and 2.5.5, there are a

mber of omissions of symbols and functions used in your mathematical (

Kpressions. Please thoroughly proof read your text and correct it 3 that it can'be reviewed.

)u have indicated that, during excavation, you discovered ground

~

acks adjacent to the excavation of Reactor Auxiliary Building (RAB-3).  !

ovide plans and cross-sectional details clearly identifyino the

) cation of these cracks and the corresponding location of sets of pins Ith strain gauges that you installed to monitor the cracks. Provide te time-displacement monitoring records of the installed strain i

luges. Also, discuss in detail, using appropriate drawings, the  :

>ck joint and dip pattern in this area. Also discuss if the cracks iserved during excavation could pose any landslide or slope stability l oblems in the future during the plant operation. l l

ovide in tabular form, the as-built dimensions of various seismic itegory I structural foundations (length and width), foundation ~; ~

ttween the foundation base and fresh) sandstone, area foundationsvations, descriptio iads for static and dynamic conditions, corresponding bearing capacities, id resultant factors of safety.

om your FSAR write-up, it is not clear to the staff whether you h G currently monitoring settlement of various Category I structures '

[

'not. Modify your FSAR to identify the settlement monitoring ogram and give reasons if you are not currently monitoring Category I undation settlements. Provide location drawings of settlement Iuments along with the time vs. settlement plots that include  !

cto-date rebound and settlement data obtained for all Category I 7uctures where settlements have been monitored.

u mention that the slopes selected for stability analysis were those unded by the interpreted surface of the weathered sandstone, shown Figure 2.5-124. You have not included this figure in the FSAR. i ovide the figure or a correct reference- to its location in the FSAR. I ur bases for selecting the critical cross-sections for slope ability analyses of natural as well as man-made slopes are not adequately stified. Provide sufficient details of your reasons for the selection critical slopes for the staff's independent evaluation.

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241.7 You mention that strain dependent damping coefficients used in the (3.7.1.3) dec6nvolution analysis are shown in Figures 2.5-87 and 2.5-88. The

. figure numbers are incorrect. Provide the correct reference.

You have stated that the engineering properties of fresh and weathered 24).8 sandstone used in the deconvolution analysis are presented in Tables

(3.7A.2)

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2.5-7 and 2.5-8. These table numbers are incorrect. Provide the correct reference. .

241. 9 Provide the thickness of the various soil and rock layers, their assumed or measured mass densities, shear wave velocities, moduli, and (3.7A.3) damping values for the model used in your deconvolution analysis.

What is your basis for selecting a 570 ft depth of rock column for this model?

241.10 Describe in detail the procedure you used for calculating the subgrade

( 3. 8.~4. 4) stiffness that was used in M3C/NASTRAN for the analysis of the Category I Tank Enclosure Structure, and provide the values of the geotechnical

' parameters for staff review. Also provide the' foundation loading results and factors of safety.with respect to sliding and overturning of this structure for SSE conditions and reference results to Section 2.5.4.

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.240 HYDROLOGIC ENGINEERING SECTION (HGEB) .

'240.01 . Provide.a summary of legal restrictions relating to water use imposed (ER) by local, state, regional or federal regulations.

.(2.1.3)

'240 02. Were rainfall and runoff data obtained at the four watersheds mentioned (ER) in the Site section of the ER (p. 2.2-1 and 2.2-2)? If so, describe the data and how it was, or can be, used in evaluating the site runoff?

(2.2.1.1)

240.03 For a more complete and useful hydrologic description, the figures (ER) need to reflect all items mentioned in the text. The locations of (2. 4.1.1 ) specific river mile (RM) marks and gaging station mentioned in the description (p. 2.4-1) needstorbe marked on the. figures.

240.04 What is the exact location (please show in appropriate figures) of the (ER) place called "near the site" (pp. 2.4-1 and 2.4-2)?

(2. 4.1.1 )  ;

'240.05 For a verification of the estimated yearly flood values ("near Ehe (ER) site"), was use niade of the approximately 5 years of record now (2.4.1.1) available at the lower Chehalis River gage site to evaluate the drainage area ratios used to make the estimates? If so, please describe the evaluation and if not make such an evaluation.

240.06 The map in Figure 2.4-6 is not legible. Provide a more legible copy of (ER) this map.

(2.4.1.2) 240.07 For an evaluation of ground water flow in the vicinity of the plant site, (ER) maps and cross sections are needed of the geologic formations and acquifers.

(2.4.2.1) These should encompass the plant site and nearest (by travel time of ground water) individual and public use of the ground water. Locations of

. these users should be indicated.

Provide information on the piezametric level, hydraulic gradients, -

permeabilities, transmissivities, storage coefficients, flow times, and adsorption properties for each of the soil or geologic units in the area of interest.

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290, 291 ENVIR0flMEf!TAL ErlGIf1EERING BRANCH 290 Terrestrial Resources  ;

290.1 Sections 5.1.4.1 and 5.1.4.2 - Provide a discussion of the biological significance of the predicted fogging and icing as well as the drift deposition predicted to occur from operation of the WNP cooling towers. ,

290.2 Section 5.5 - Provide a copy of the following reference related to the BPA transmission network. "The Role of the Bonneville Power Administration in the Pacific Northwest Power Supply System. Appendix B, BPA Power Transmission". Bonneville Power Administration, Department of the Interior, July 22, 1977.

291 Aquatic Resources 291.1 In-addition to other requested information provide a summary an'j brief discussion in table form, by section, of differences between cb rently projected environmental effects (including those that would dt 3rade, and those that would enhance environmental conditions) and the effects discussed in the environmental report submitted at the constructi,on permit stage. _.

291.2 Section 6.1.1.2 - Provide a sud5ary of $he results of the angler use studies for the 16 km section of the Chehalis River between South Elma bridge and the mouth of Smith Canal. Emphasis should be_placed on activity observed nearest the site.

291.3 Section 6.1 - Provide copies of the following references listed in Section 6.1 of the OL-ER: 9; 10; 11; 12; 20; 23.

291.4 Section 2.2.2.6 - Provide Identify a discussion of the utilization any critical of this habitat for the Chehalis species River by white sturgeon.

that might occur in the vicinity of the site, Summarize this species abundance and distribu~ tion in the Chehalis River with particular emphasis in the lower river stretches.

291.5 Amend Figure 3.4-6 by providing the elevation of the intakes of each of the circulating water intake pumps located in the Ranny Well intake l cassions.

291.6 Figure 3.4-6 shows a service water pump. Figure 3.4-1 shows flow to the R3CCWHx and the service water pump drawing from the circulating water pumps located downstream of the cooling tower. Describe the use of the service water obtained from the service water pumps in the Ranny Collectors.

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291.7 Section 2.2.2.5 - Indicate if Corbicula sp. has been collected from the Chehalis' River in the vicinity of tne site. If present, provide an estimate of the number of these organisms per square meter for each year data is available. Describe procedures and measures taken or planned that will deny access to critical plant components, or control fouling by these organisms during both construction and operation of the station.

Particular, emphasis should be placed on evaluating the potential for clams in the system that entered during the construction phase.

291.8 Section 3.4.3 - Provide additional detail for the supplemental cooling system. Inoicate its location on a site map. Provide a schematic drawing of the unit. Give an estimate of its usage on an annual basis.

Provide the criteria that determine its usage. -

291.9 Section 3.4,4 - Provide the location on a map of the blowdown diffuser in relation to the Chehalis River, Ranny Collectors and the plant. Also provide an over'nead review of the section of river in which the diffuser is located. On this figure differentiate~~between the blowdown diffuser section and the supply pipeline.

291,10 Section 3.4-4 describes a 32-foot multiport diffuser. Figure 3.4-4 shows a 34-foot long length of pipe that is presumably the diffuser since section A-A shows a discharge riser. Resolve this difference and' indicate on Figure 3.4-4 that pprtion cf the pipeline that is the blowdown diffus~er.

291.11 Section 5.1.1 - Provide the anticipated frequency of less than .3 feet /sec flow in the Chehalis River. ' Estimate how often and approximate duration this will cccur on an annual basis.

291.12 Section 5.1.3.1 - Reference is made 'to the total run of the coho and chum salmon. Provide the estimates of total run for these two species that were used in this analysis. . Indicate how these estimates.were obtained.

291.13 Section 2.2.2.6 - If available, provide on an annual basis some indication of the magnitude of runs past the site for all species and runs of salmon,

- the steelhead trout, and the white sturgeon.

291.14 Section 2.7 disclases only the nearest residence. Locate other nearby noise sensitive areas, e.g. schools, hospitals.

291.15 Section 3.7.2 - Is any air quality permit or approval needed for any aspect'of the project?

291.16 Section 12.0 - Have any environmental impact appraisals ~ ceen performed by or for any other agency?

291.17 Provide references 1, 3, and 5, Section 2.4.

291.13 At the time of site visit make reference 6. Section 2.4, available for examination. 3-3 -

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. . I Acceptance Re' view Ouestions Relating to Cost-Benefit

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329.1 Provide the followino: .

A production cost analysis which shows the difference in system production

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costs associated with the availability vs. unavailability of the proposed nuclear addit. ion. Note, the resulting cost differential should be limited solely to the variable or incremental costs associated with gener,ating ,

w w electricity from the proposed nuclear addition and the sources of replace ,

ment energy. If, in your analysis, other factors influence the cost differential, e,xplain ,

-- - in detail. ,

a. The analysis should provide re'su'lts on an annual basis covering *

. the period from initial operation of the 'first unit through five t

~

full years of operation of the 1,as.t unit.

b. Where more than one utility shares ownership in the prop 3 sed nuclear addition or where the proposed facility is centrally dispatched as part 'of an, interconnected pool, the results of the analysis may be aggregated for all participating systems.

c. The' analysis should assume electrical energy, requirements grow

. at (1) the system's latest official forecasted growt'h rate, and

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(2) zero growth from the latest actual annual energy requirement.

d.- All underlying assumptions should be explicitly identified and

! explained.-

For each year (and for each growth rate scenario) the following e.

results should be clearly stated: (1) system production costs l 3-4

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with the orocosed nuclear addition avaiTable as scheduled; (2)

.s ystem production costs withcut the proposed nuclear addition available; (3) the capacity factor assumed for the nuclear addition; (4) the ' aver &ge fuel ccst and variable 0 & M for the nuclear addition and the sources of replacement energy (by fuel type) - both espressed in mills per kWh; and (5) the orocortion.

of replacement energy assumed to be provided by coal, oil, cas, ,

etc. (The base year for all costs should be identified) 320.2 Provide 30 yr levelized fuel and 0 & M costs (fixed .and variable). Provide ,

escalation,' discount rates and all other variables assumed in calculating these costs. '

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O 450, 451 ACC1 DENT EVALUATf 0N BRANCH , ,

RADI0 LOGICAL CONSEQUENCES OF ACCIDENTS 450-1 Provide more evidence, or refer to a source that gives evidence, to support the assumptions reghrding evacuation (section 7.1.9.6). The present discussion is too incomplete to serve as a basis for choosing evacuation parameters "for an independent evaluation of accident consequences.

450-2 Provide evidence that "...the actual risks associa'ted with WHP-3 would be less than the calculated values..." (section 7.1.9.8). There is no basis for evaluating this statement; there should be a discussion of how the engineered safety features of WNP-3 are an improvement, with respect to safety (or provide for at least the same level of ,

safety), over the older FWR design that was the base design in thb RSS.

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M METEOROLOGY ACCEPTANCE REVIEW 451-1 Provide a magnetic data tape of hourly meteorological data collected onsite. The tape should follow guidance in Appbndix A of SRP 2.3.3 in {!UREG-0800 for tape format. The amount of data should be provided in accordance with section 2.3.3 of Regulatory Guide 1.70 which requests as a minimum two consecutive annual cycles including the most recent one-year period. If possible, the same data, 8760 consecutive hours '

used in your CRAC 2 analysis should be identified and included on the tape.

451-2 Describe local air quality conditions and identify the type and levels of pollutants in the region and compare these to National Ambient Air Quality Standards.

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451-3 Describe any non-radioactive plant effluents that may be released during normal plant operation and their impact on local ~ air quality.

4 51-4 Identify any changes in extreme and severe weather phenomena observed since the issuance of the Environmental Report at the construction permit stage.

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Standard Review Plan Section 2.3.3 RECOMMENDED FORMAT FOR HOURLY METEOROLOGICAL DATA TO BE PLACED ON MAGNETIC TAPE

• USE: 9-track tape (7 will be acceptable)

. Standard Label which would include:

Record Length = 160 Block Size (3200 - fixed block size)

Density (1600 BPI - 800 will be accepted)

Do Not Use: Magnetic tapes with unformatted or spanned records At the beginning of each tape, use the first five (5) records (which is the equivalent of ten cards) to give a tape description. Include plant name; location (latitt,de, longitude); dates of data; information explaining data containing in the "other" fields if they are used; height of measurements; and Make sure any additional information pertinent to identification 6fFormat the tape.for the first all five records are included, even if some are blank.

five records will be 160A1. Meteorological data format is (I6, 12, 13, I4, 25F5.1, F5.2, 3F5.1) h: J p ,.se A.aosu:.ta 4. op7q a.,p 4 g All data 'should be given to the tenth of a unit except solar radiation,--which should be given to a hundredth of a unit. This does not necessarily indicate the accuracy of the data (e.g., wind direction is usually given to All thesevens nearest

' degree). All nines in any field indicate a lost record (99999).

If there are only two levels in a wind direction field indicate calm (77777). If there is only one level of data, of data, use the upper and lower levels.

use the upper level.

• ^0ata on magnetic tape are acceptable in any reasonable format, if the format is completely described (see NUREG-0158, Part 1), and if a sample tape dump is provided.

(3-8) ,

2.3.3-8 Rev. 2 - July 1981

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s. v NkM, MAGriETIC TAPE :'ETECT,C'.031IAL OtJA s'f , ,

.V I' LOCATION:

DATE OF DATA' RECORD:

I6 Identifier (can be anything)

I2 Year I 3 _'

Julian Day I4 Hour (on 24-hour clock)

ACCURACY Upper Measurements: Level = meters F 5.1 F5.1 Wind Direction (degrees)

F5.1 Wind Speed (meter /sec)

F5.1 _ Sigma Theta (degrees)

F 5.1 _ Ambient Temperature ( C)

F 5.1 Moisture:

F5.1 Other: [E Level = meters F5.1 Intermediate Measurements:

F 5.1 Wind Direction (degrees)

F5.1 _ Wind Speed (ceters/sec)

F5.1 Sigma Theta (degrees)

F5.1 Ambient Temperature ( C) .

F5.1 Moisture:

F5.1 Other:

Lower Measurer.ients: Level = meters F5.1 F 5.1 _

Wind Direction (degrees)

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F5.1 Wind Speed (meters /sec)

F5.1 Sigma Theta (degrees) ,

F5.1 Ambient Temperature ( C)

F5.1 Moisture:

F5.1 Other:

(3-9) 2.3.3-9 ' Rev. 2 - July 1981 -

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J ' Y- v. , IAGNETIC TAPE t-:ETECT.0 LOGICAL DATA (co ntir.ued) y/ .

F5.1 Temp. Dif f. (Upper-Loter) ( C/100 meters)

F5.1 Temp..Diff. (Upper-Intermediate) ( C/100 i.eters)

- F5.1 Temp. Diff. (Intermediate-Lewer) ( C/100 meters)

F5.1 Precipitation (mm)

F5. Y V Solar Radiation (cal /cm 2/ min)

F5.1 Visibility (km)

F5.1 Other: .

F5.1 Other:

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2.3.3-10 -

Rev. 2 - July 1981

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470 RdDi0LOGICALASSESSMENTBRANCH EF.-0 470.1 (Se:-irr.: :.1 ar.d 5.2):

F.e:cnfir- di;;.7c:t and direction for seccial 1:catier.: (tite boundary. .ilt : .,

Explain h:s these ca werc c:.:ained and/or cite se;r:e etc.) [See Taoie 2.1-!]

of cata used in c::..: uter run of ref erence E.2 ..

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ER-G 470.2 (Se: tier.s 2.1 and 5.2):

Reconfirm that there is no drinking water withdrawal dc.instream, ar.d that there will be r.one. Has recharge of wells via river water been considered? For those wells which may be recharged in this manner, cnd which are a source of drin :ing water (among those in Tables 2.1-12 and 2.1-13) provide transit times and dilution factors, and the basis or method of calculating these values.* [ Table 5.2-6 and Appendix B are incomplete because they do not provide these values for the various locations].

ER-Q 470.3 (Sections 2.1 and 5.2):

Why was only the population of Montesano used for popclation doses ~ via re~c reation pathways (shoreline usage, swimming, boating)?. Where do these activities take place (locations of state parks, etc.), and what are the dilution factors transit times for each? (Table 2.1-6 lists the locations and distances, but not dilution factors and transition times').

ER-Q 470.4 (Section'3.5.3.2, p. 3.5-11): .

Section 3.5.3.2, p. 3.5-11 states that WPPSS has chosen the cost benefit option for ALARA compliance. Provide the following distributional data for each of the 22 1/2-degree radial sectors centered on the 16 cardinal compass directions for radial distance of 1, 2, 3, 4, 5, 10, 20, 30, and 50 miles from the reactor (from the ER):

1

1. Present annual meat production (kg/yr),

3-11 .

, _ . - _ _.-., ,__ . _ _ . . . _ , _ - . . - _ . . , . _ . . _ _ _ _ ~ . _ _ _ . _ . . .

% g

2. Present annual milk production (liter /yr),

3. Present annual vegetable production (kg/yr).

EP.-0 470.5 (Section 2.1):

Confirm that fish harvest data includes cil fish taken within 80 km downstream of the plant radwaste discharge. (See Table 2.1-10)

ER-0 470.6 (Section 5.2):

'What is the basis for the irrigation data of Table 5.2-6 and Appendix B?

ER-0 470:7 (Section 5.2, Table 5.2-6):

How was dilution factor calculated /obtained? (It is not necessarily the same for aquatic food / shoreline / drinking water nor are dilutions for any individual necessarily the same as for population. Justify!)

ER-0 470.8 (Section 5.2.4 and Apoendix B): ,

The ER-OL assumed that all fish consumed was to be from I location i.e., Chehalis River? Why? Table 2.1-10 of Section 2.1.3 indicates higher fish catches at Grays Harbor & Ocean (off Grays Harbor) than at Chehalis River.

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