ML20234C720
| ML20234C720 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/04/1988 |
| From: | Dignan T PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20234C672 | List: |
| References | |
| OL-1, NUDOCS 8801060305 | |
| Download: ML20234C720 (20) | |
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5 00CKETED Dated: January 4, 198 SniC 18 JNi -5 P3 :22 UNITED STATES OF AMERICA f0M G ShIAh' y
BRANCH UNITED STATES NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
) Docket Nos. 50-443-OL-1 PUBLIC SERVICE COMPANY OF ) 50-444-OL-1 NEW HAMPSHIRE, et al. )
) (On-site Emergency Planning (Seabrook Station, Units 1 and 2) ) Issues)
)
)
APPLICANTS' MEMORANDUM IN SUPPORT OF LOW POWER OPERATION On November 25, 1987 the Commission issued a Memorandum and order granting Applicants' motion to vacate the stay of the low power license for Seabrook Station. " Memorandum and Order (Lifting the Order Staying the Director of Nuclear Reactor Regulation From Authorizing Lov Power Operations Due to the Lack of an Emergency Plan for Massachusetts)."
Therein, the Commission noted that the Appeal Board's decision in ALAB-875, reviewing the Licensing Board's partial l initial decision authorizing low power operations, remanded two issues to the Licensing Board. The Commission stated that "the Licensing Board shall expeditiously determine whether considering the issues that it is hearing on remand, 8801060305 880104 3 PDR ADOCK 05000 G
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it is appropriate to renew at this time its authorization of low power or whether low power operations must await further decisions." (p. 7)
On November 27, 1987 the Licensing Board issued a scheduling order indicating that the Applicants and parties have until January 4, 1988 to file responsive briefs.
Applicants'herein respond and assert that full resolution of the two remanded contentions need not prevent low power operation.
ARGUMENT When an operating license proceeding is remanded by the Commission or an Appeal Board, the question of whether the license must be suspended during the remanded proceeding is decided on a " balancing of the equities and a consideration of possible prejudice to further action required as a result of the reopened proceeding." Pacific Gas and Electric Co.,
(Diablo Canyon Nuclear Power Plant, Units 1 and 2), CLI-83-27 18 NRC 1146, 1149 (1983); Public Service Company of New Hampshire (Seabrook Station Units 1 and 2) CLI-77-8, 5 NRC 503, 521 (1977), affirmed, New Encland Coalition on Nuclear Pollution v. EEC, 582 F.2d 87 (1st Cir. 1978). See also, Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2) ALAB-845, 24 NRC 220, 233-234 (1986) (Remand of contention regarding emergency planning did not warrant suspension of operating license).
o A consideration of the equities in this matter establishes that the license should not be suspended. Both contentions now in front of the Licensing Board concern discrete issues that will not affect, and will not be affected by, low power operation.
- 1. NECNP Contention IV The Appeal Board in ALAB-875, determined that NECNP Contention IV should have been admitted and remanded the Contention to this Licensing Board.
NECNP Contention IV reads as follows:
The Applicant must establish a surveillance 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, 33, 34, 35, 36, 38, and 39, which require the maintenance and inspection of reactor cooling systems. The design, construction, and proposed operations of Seabrook fail to satisfy these requirements.
The Affidavits of Kenneth W. Dow and Winthrope B. Leland establish that Seabrook Station, since its inception, has had a comprehensive monitoring program for the prevention of accumulation of aquatic organisms in the plant's cooling systems. Moreover, periodic inspections of cooling system components providing seawater service has produced no indications of biofouling activity.
Specifically, the original program to control the settlement of fouling organisms involved an application of chlorine combined with heat treatment. Dow Affidavit at 1 2.
Information regarding this program was presented within the u__________-.____
a Construction Phase Environmental Report, and reviewed within the Final Environmental Statement issued in December 1974.
Id2 Seabrook Station subsequently devised a program to control the settlement of fouling organisms through the continuous application of low level chlorine. Dow Affidavit at 1 3. This program was presented in detail within the Operating License Phase Environmental Report and reviewed within the Final Environmental Statement of December 1982.
JJL._ The program mandates periodic evaluation and inspection of cooling water system components. These inspections have revealed no accumulation of fouling organisms. Id. at 1 6.
In addition, since August 1985, Seabrook Station has operated the Seabrook Circulating and Service Water Systems, including the Chlorination' System operation. Leland Affidavit at 1 2.
Various inspections of the Service Water Systems demonstrate that there has been no blockage or_biofouling in any component using seawater. Id. at 1 6. Moreover, all six of the Service Water System pumps are tested quarterly, at a minimum. Id. at 1 7. Should fouling or any other phenomena occur which would restrict system flow, it would be detected during the quarterly pump surveillance test. Id.
In addition, the Operations Department performs the following tasks to ensure that blockage or reduced flow does not occur: 1) SW pump flow capacities are measured quarterly; 2) the SW strainer immediately upstream of PCCW L- -- - - - - - - - - - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
and DGJCW heat exchangers are cleaned after reaching a 6 psi
, differential pressure; and 3) service water flow is checked by an auxiliary officer routinely during each shift, at a minimum. Id. at 1 8.
Finally, the NRC Staff investigated the generic biofouling issue in the early 1980's. In April, 1981 the Staff issued IE Bulletin 81-03 " Flow Blockage of Cooling Water to Safety System Components by Corbicula sp. (Asiatic Clam) and Mytilus sp. (Mussel)" in which it requested information regarding species abundance, species presence in fire protection and safety-related systems, and methods of preventing and detecting fouling. Seabrook Station provided an initial response in July, 1981 (SBN-168). This response indicated that a comprehensive monitoring program conducted since 1969 had identified Mytilus sp. to be present within
-the receiving water. SBN-168 at 1. Corbicula sp., a freshwater organism, was found not to be present. Id; NUREG/CR-3054 at A6. In this regard it should be noted that four other coastal units within NRC Region 1 (Pilgrim, Millstone 1-3) which had experienced a biofouling problem due to Nvtilus, have not observed the freshwater organism Corbicula. NUREG/CR-3054, Tables 1, 2 at 17, 18. In March, 1983 Seabrook Station provided an additional response (SBN-486), focusing on the materials relevant to the description L of the planned treatment, as well as information identifying l'
all safety-related systems. In June, 1984, in NUREG/CR-3054 l'
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"Close-out IE Bulletin 81-03" the Staff determined that Seabrook Station had submitted an acceptable program for detecting and preventing future flow blockage or degradation l due to clam or mussels or shell debris and had performed an acceptable program to confirm adequate flow rates for safety-related systems. NUREG/CR-3054, Table B.1 at B-7 and B-9.
In sum, Applicants have, in fact, established and implemented a surveillance and maintenance program to detect and prevent the accumulation of Mollusks and other aquatic organisms in cooling systems. To date, after more than two years of system surveillance, no biofouling accumulation has been observed. There is no reason to believe that operation at low power would change this situation. In short, low power operation may be safely authorized while the biofouling contention is litigated on remand.
- 2. NECNP Contention I.V.
NECNP Contention I.V. reads as follows:
The Applicant has not demonstrated that it meets General Design Criteria 14, 15, 31 and 32 of Appendix A to 10 CFR Part 50, as implemented by Regulatory Guide 1.83, in order adequately to reduce the probability and consequences of steam generator tube failures through periodic in-service inspection for early detection of defects and deterioration. Nor has the Applicant developed an adequate alternative program for in-service inspection of steam generator tubes.
In remanding this Contention, the Appeal Board noted that NECNP's reference to the steam generator tube rupture at Ginna provided a sufficiently specific basis for the admission of the contention. The Appeal Board also noted
that "the Ginna incident gives rise to a possible inference that adoption of the regulatory guide's surveillance program
[ Regulatory Guide 1.83] at Seabrook might not prevent a tube rupture that would breach the facility's reactor coolant pressure boundary." ALAB-875 at 17.
As demonstrated below, this contention also does not preclude 1cw power operation.
- a. There is no need to finalize the steam generator tube in-service inspection program prior to authorization of low oower coeration.
As indicated in NECNP Contention I.V. and its associated basis, NECNP's e. spoused concern is the adequacy of the periodic in-service inspection of steam generator tubes to reduce the probability and consequences of tube failure by carly detection of defects and deterioration. The essence of NECNP's concern, as well as the regulatory guidance provided in Regulatory Guide 1.83, is to identify early any defects, damage, or deterioration which coilld possibly lead to steam generator tube failure. By its very nature the periodic in-service inspection referred to occurs after the plant has been put into service or is operating.
As provided in the Technical Specifications appended to the Seabrook Station Operating License (License No. NPF-56) the first in-service inspection is to be performed after 6 l
effective full power months but within 24 months of initial criticality (Spec. 3/4.4.5, 4.4.5.3). This inspection
'l interval is consistent with that provided in Regulatory Guide
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1.83. Thus, the first periodic inspection is not required to be performed prior to low power operation being authorized and the occurrence of initial criticality.
Accordingly, there is nothing associated with low' power operation at Seabrook Station which would further complicate any subsequent inspection or preclude any augmentation of the current inspection program if deemed necessary by this Licensing Board following any litigation of the contention.
Based on the foregoing it is clear that Contention I.V. as -
put forth by RECNP involves those tube inspections performed following the placement of the unit into operation, that the first periodic inspection must be performed within 24 months following initial criticality and that low power operation does not constitute a bar to any possible inspection program augmentation which may be ordered by this Licensing Board.
- b. It is highly unlikely that a tube rupture caused by a foreign object, as occurred at Ginna, will occur during low Dower oDeration at Seabrook Station.
In the basis to its contention, NECNP questions the adequacy of the steam generator tube inspection program in view of the tube rupture incident at Ginna. The Affidavit of John N. Esposito on the Ginna Tube Rupture Event and the Design of and Experience with Model F Steam Generators (Esposito Affidavit No. 1)~ establishes that the Ginna tube rupture was caused by a foreign object. It is highly unlikely that a tube rupture caused by a foreign object will occur at Seabrook Station because, as established in the
l Affidavit of Gregory A. Kann, a comprehensive inspection of l
all four Seabrook Station steam generators was conducted following hot functional testing and these inspections revealed no foreign objects in the Seabrook Station steam generators. In addition, a loose parts monitoring system provides additional assurance that a foreign-object-related tube rupture will not occur.
On January 25, 1982 a tube ruptured in a steam generator at the Ginna Nuclear Power Station as a result of a metal object being inadvertently left in the steam generator during a field modification in 1975. Esposito Affidavit No. 1 at S
- 4. During operation, flow forces caused the foreign object to impact the peripheral tubes, damaging both plugged and operational tubes. Id. This process continued until a tube ruptured. Id. As a result of this event at Ginna, utilities now routinely perform visual searches of the steam generator tubesheet periphery to detect foreign objects. Id.
At Seabrook Station, following hot functional testing, the secondary side steam generator internals were inspected.
Kann Affidavit at 1 2. Accessible areas of the lower tubesheet were inspected by inserting a sub-miniature camera (probe) through opened hand holes in each of the four steam generators. Id. at 1 4. The separator area and related components were inspected during a " walk-through" examination of each generator. Id. at 1 7. Disposable protective clothing was worn during the walk-through examination to reduce the possibility of carrying contaminants into the internals. Id. at 1 8. In addition, material / equipment control was maintained by access control logs to preclude introduction of foreign objects into the internals. Id.
During this walk-through the downcomer annulus areas were q also viewed and no irregularities were noted. Id. at 1 9.
The slight amount of debris (approximately 3 to 4 ounces) located during these inspections was removed such that each of the four steam generators is considered to be free of any harmful materials in areas inspected. Id. at 1
- 11. Also, the areas viewed in each of the steam generators meet the requirements for Class "C" cleanliness under ANSI N.45.2.1.1073. Id. at 1 10. As such,-there is no need to re-examine the steam generators for foreign objects unless and until an entry is made into the steam generators which is not expected to occur until the first periodic inspection.
Id. at 1 13.
In addition to the visual examination performed, a loose parts monitoring system, as described in FSAR Section 4.4.6.4 is in place to detect a loose part on the steam generator tubesheet during plant operation. Id. at 1 12. This equipment is required to be operable during Modes 1 and 2 (as defined by the Technical Specifications) and if an alert level is exceeded, diagnostic steps will be taken within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to determine if a loose part is present. Id. Finally,
low power operation will not preclude performing additional inspections, if required. Id. at 1 13.
In sum, the inspections of the steam generators for foreign objects, together with the use of a loose parts monitoring system, demonstrate that a tube rupture caused by a foreign object, such as occurred at Ginna, should not occur during low power operation at Seabrook Station.
- c. It is highly unlikely that an event like the North Anna Unit 1 tube rupture incident would occur during low power operation at Seabrook Station.
During oral argument before the Appeal Board, NECNP referred to a recent tube rupture event which had occurred at North Anna Unit 1.1 The Affidavit of John N. Esposito on the North Anna Tube Rupture Event (Esposito Affidavit No. 2) establishes that the Seabrook Station Model F steam generator has a number of design features which differ from those of the North Anna steam generators. Based on these differences, a tube rupture event of the type that occurred at North Anna is not expected to occur in Model F steam generators.
On July 15, 1987, a' steam generator tube rupture event occurred at North Anna Unit 1. Esposito Affidavit No. 2 at S
- 4. The leakage location was found to be at the top tube 1 For this reason, Applicants address the North Anna incident herein. As a matter of law, however, Applicants do not believe that contention 1.V. should be read as raising any basis arising from the North Anna incident. No amended contention was ever filed. It is well established that an intervenor is bound by the literal terms of the contention and basis as filed. Texas Utilities Electric Co. (Comanche Peak Steam Electric Station), ALAB-868, 25 NRC , Slip Op.
at 37 n. 83 (June 30, 1987).
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support plate on the cold leg side and caused by high cycle fatigue. Id. and 1 5. The source of the loads was a combination of a mean stress level, produced by denting at the top tube support plate and a super-imposed alternating stress due to out-of-plane deflection of the tube above the support caused by flow induced vibration. Id. at 1 5. It is important to note that ccnting is a phenomenon which has only i occurred with carbon steel support plates. Id. at 1 6. j The differences between carbon steel support plates, as used at North Anna, and stainless steel support material, as ;
used at Seabrook Station, is described in EsDosito Affidavit No. 1 at 1 5 (c). The steam generator tube support plate material of early model steam generators was carbon steel.
Under most conditions, this material proved to be satisfactory. However, in the mid-70s corrosion of this material in the presence of chemical impurities led to a tube degradation phenomenon called denting. When carbon steel corrodes, the oxide occupies a volume that is greater than that of the original material. Under certain conditions which can occur in Pressurized Water Reactor steam generators formation of this oxide can fill the clearances between the support plates and the tubes producing forces sufficient to cause local tube deformation and producing high stresses which increase the potential for stress corrosion cracking of the tubes. The Model F tube support material is type 405 stainless steel. This material has improved corrosion I
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4 resistance and with modern water AVT chemistry control, the volume of the oxide does not exceed the material loss thus eliminating the potential for denting. Therefore a tube rupture event similar to that which occurred at North Anna is not expected to occur in Seabrook Station's Model F steam generators. See also, Escosito Affidavit No. 2 11 7-8.
The NRC staff came to the same conclusion'in "NRC Staff Response to New England Coalition on Nuclear Pollution's First Set of Interrogatories and Request for the Product of Documents to the NRC Staff on NECNP Contentions I.V. and IV" (December 7, 1987). In response to Interrogatory 6 (d), the NRC staff stated : "The Seabrook plant is not considered to be susceptible to the fluid flow induced vibration fatigue failure mechanism that caused the North Anna steam generator tube rupture, because it does not have carbon steel [ tube]
support plates with drilled holes."
In addition, the Model F steam generator incorporates a I number of design features which reduce the potential for tube rupture. Esposito Affidavit No. 1 at 15.- Those features include:
Thermal treatment of Allov 600 tube material The thermal treatment produces a microstructure that is more resistant to the various forms of stress corrosion cracking 1
and improves corrosion resistance by as much as a factor of l
- 10. EPRI has sponsored a number of programs which confirm this performance. Id.
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Full depth hydraulic exoansion tubesheet ioint The Model F tubesheet joint is formed by a full depth ;
expansion process. This process closes the crevice between the tube and the tubesheet hole (which is a region where dryout could produce chemical concentration) while at the same time producing low residual stresses. Id.
Stainless steel tube succort olate material The Model F tube support material is type 405 stainless steel. This material has improved corrosion resistance and with modern water chemistry control, the volume of the oxide does not exceed the material loss thus eliminating the potential for denting. Id.
Ouatrefoil tube succort hole ceometry The Model F tube support plate holes are broached to produce a four-lobed hole which directs the flow which passes through the tube support plate to cleanse the interface with the tube. This cleansing action limits the potential for local chemical concentration and subsequent tube corrosion. This design limits the contact between the tube and the support plate to four narrow lands, also minimizing local dryout and chemical concentration. Id.
The sufficiency of the above design features can be adjudged by evaluating the operating history of the following Model F-type steam generators using AVT chemistry operating in the United States (i.e. the equivalent to Seabrook Station). Escosito Affidavit No. 1 1 6.
A Operation Plant SG Model Loops Total Tubes Date Surry 2 51F 3 10,026 9/80 Surry 1- 51F 3 10,026 7/81 Turkey Point 3 44F 3 9,642 4/82
! Turkey Point 4 44F 3 9,642 4/83 i
Point Beach 1 44F 2 6,428 4/84 Callaway 1 F 4 22,424 10/84 l Robinson 2 44F 3 9,642 1/S5 Wolf Creek F 4 22,424 5/85-l Millstone 3 F 4 22,504 1/86 vogtle 1 F 4 22,504 3/87 These plants account for 33 Model F-type steam generators with nearly 150,000 tubes and represent a total of l 119 equivalent steam generating operating years. Id. at 1 7.
This operating experience is judged sufficient to confirm the reliable operating characteristics of the Model F steam generators. Id.
Of the nearly 150,000 Model F tubes in service in the United States, 29 tubes have been plugged. Id. at 1 8. The reasons associated with this plugging are described in Esposito Affidavit No. 1 at 18.
Therefore, due to the use of support plate material which avoids the potential for tube denting, additional 1
design features created to reduce the potential of a tube rupture, and the excellent operating history of the Model F steam generators, it is highly unlikely that a North Anna-type tube rupture event would occur at Seabrook Station during low power operation. !
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- d. The consequences of a tube rupture event during 5% power operations at Seabrook Station would not necessitate an offsite orotective action response by the public.
As provided in the Affidavits of Peter S. Littlefield, Ping Huang, and Kenneth Rubin, even if one assumed that a tube rupture occurred during low power operation, the expected doses that would be received would be less than the lower protective action guide for thyroid at the Seabrook Station exclusion area boundary and would not require any offsite protective action response by the general public.
A steam generator tube rupture (SGTR) 10 one of a number of design basis accidents that is analyzed prior to operation of a nuclear power station. Littlefield Affidavit at $2.
The analysis of this type of accident for the Seabrook Station at full power operation is found in FSAR Section 15.6. Id. The critical thermal hydraulic and radiological assumptions made in the FSAR include: (1) the total mass of
) reactor coolant transferred to the secondary side; (2) that a portion of the mass flashes to steam and; (3) that a pre-existing spike occurred raising the dose equivalent of I-131 concentration of the reactor coolant to the technical specification limit of 60 uCi/gm. Id. The only significant radiological effect of the SGTR is the thyroid dose produced by the release of radioiodine. Id. at 1 3. The FSAR analysis resulted in a thyroid dose of 66 rem at the exclusionary area boundary versus 300 rem as specified in lo
CFR 100. Id. The whole body dose reported in the FSAR accident analysis is only 120 mrem (0.12 rem). Id.
Low power operation results in substantially decreasing the potential consequences of design basis accidents. Id. at 1 5. The impact of low power operation on the FSAR SGTR assumptions is as follows:
.The mass of reactor coolant that could be transferred to the secondary side increases at low power as a result of density changes, reactor trip timing and other thermal hydraulic considerations. Id. at 1 6. A conservative analysis of this mass flow at low power has resulted in an upper bound estimate of 140,000 lbs. Affidavit of Pina Huana at 1 8. This would increase the thyroid dose by a factor of 0.4. Littlefield Affidavit at 1 6.
The reactor coolant entering the steam generator is at a 7.ower temperature during low power operation (approximately 70' F lower), and therefore the flashing fraction of this coolant in the secondary side is reduced to less than 7.5 percent. Affidavit of Pina Huana at 1 8. Littlefield Affidavit at 1 7. This reduces the potential iodine release to the environment and results in reducing the thyroid dose by approximately a factor of 2. Littlefield Affidavit at 1 7.
The greatest impact of low power operation, however, is that the potential quantity of iodine available for release 1
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to the environment is significantly less. Littlefield Affidavit at 1 8. This is due to:
- a. A reactor core iodine inventory of at least a factor of 20 less than full power operation. Id.
- b. A lower fuel gap iodine fraction available for release to the coolant due to low fuel burnup and low fuel temperature. Id.
- c. A low potential for cladding failure during early core life. Id.
A study has been completed of iodine concentration in reactor coolant during first fuel cycle operations.
Affidavit of Kenneth Rubin at 1 7. The study included 35 nuclear power stations and over 100 individual measurements. 'l The reactor coolant results, as presented in Littlefield Affidavit at 1 9, are shown below:
I-131 Concentration, uCi/gm l Normalized Corrected to l 100% Power 5% Power Maxitum 0.065 0.00325 Average 0.0043 0.00022
. Minimum 0.00006 < 0.00001 The high readings are a result of small fuel defects.
Rubin Affidavit at i 8. For the most part the operating data shows no fuel defects and the corresponding activity levels are less than 0.001 uCi/gm. Id.
l A second study of iodine spiking source terms for i accident analysis has analyzed the characteristics of 70 ,
l iodine spikes in operating reactors. Littlefield Affidavit at 110. This study reported the equilibrium concentration l prior to the start of the spike, and the peak concentration t __ _. . _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - - _ _ - _ - -
following the spike for each event. The highest reported ratio of peak-to-equilibrium concentrations was 170. Id. If this maximum ratio is multiplied by the highest equilibrium reactor coolant concentration shown above, the result would be a bounding spike reactor coolant concentration of I-131 of 0.55 uCi/gm (170 x 0.00325=0.55). Id. Accounting for the other isotopes of iodine results in a dose equivalent I-131 concentration of approximately 1.4 uCi/gm. Id. .This low pre-existing spike concentration would reduce the thyroid dose by approximately a factor of 40. Id.
The overall result of adjusting the critical assumptions discussed above for operation at 5% power is to produce an exclusion area boundary thyroid dose of approximately 1.1 rem. 'Littlefield Affidavit at 111. This should be considered a bounding value since conservative assumptions regarding mass transfer, coolant flashing, iodine concentration and spiking ratio have all been compounded.
Id. Based on rhis result, it is concluded that SGTR events, during initial low power-testing, produce an exceedingly small risk to the health and safety of the public, and require no offsite protective actions. Id.
In short, low power operation may be safely authorized while Contention I.V. is litigated on remand because: 1) the pre-operational inspection of the steam generators and a loose parts monitoring system should preclude a Ginna-type tube rupture; 2) the design of the Seabrook Station Model F steam generator makes a North Anna-type tube rupture very unlikely; and 3) in the event that a tube rupture did occur at Seabrook Station during low power operation, conservative projections indicate that doses released at the site boundary will be sufficiently low that no offsite protective action would be required.
CONCLUSION On March 25, 1987, the Licensing Board issued its partial initial decision authorizing low power operation at Seabrook Station. The Appeal Board affirmed that decision in ALAB-875, remanding only two contentions to the Licensing Board. For all of the reasons presented above, Applicants assert that the full resolution of these two contentions need not prevent low power operation. As the two remanded contentions will not affect low power operation, and as the Commission has recognized the inherent benefits in low power operation (Lona Island Lightina Company (Shoreham Nuclear Power Station) CLI-85-12, 22 NRC 1587, 1590 and n.3, (1985)),
the equities here lie in favor of the Applicants. Therefore tho Licensing Board should not further stay the low power license for Seabrook Station.
Respectfully submitted, Pm L -_- Thomas G. dignan, Jr. Deborah S. Steenland Ropes & Gray 225 Franklin Street Boston, Mass. 02110 (617) 423-6100 i t - .____ _}}