ML20234C827

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Affidavit of Kw Dow.* Discusses Chlorine Minimization While Maintaining Circulating Water Sys Free from Fouling. Statement of Prof Qualification Encl
ML20234C827
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 12/21/1987
From: Dow K
YANKEE ATOMIC ELECTRIC CO.
To:
Shared Package
ML20234C672 List:
References
OL-1, NUDOCS 8801060337
Download: ML20234C827 (4)
v • d • e


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i UNITED STATES OF AMERICA UNITED STATES NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of ) l

) l PUBLIC SERVICE COMPANY ) Docket Nos. 50-443 OL-1 NEW HAMPSHIRE, et al. ) 50-444 OL-1

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(Seabrook Station, Units 1 ) (On-site Emergency i and 2) ) Planning Issues) j

) , 1 AFFIDAVIT OF KENNETH W. DOW I, Kenneth W. Dow, being on oath, depose and say as follows- i

1. I am an environmental scientist at Yankee Atomic Electric Company (YAEC) in Framingham, Massachusetts. YAEC provides engineering, scientific, and technical services to Seabrook Station. A statement of my profea;ional qualifications is attached and marked as "A".
2. Seabrook Station hes, tince its conception, been designed to provide for the control of fouling organism accumulation within the Circulating Water and Service Water Systems.

Originally to control the settlement of fouling organisms, a design application of chlorine of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per day, per unit, with each unit main condenser neing performed one unit at a time, and each unit's service water nystem beirg treated separately, was proposad. In addition, heat treatment, for the Circulating Water System was designed and fabricated to thermally kill any accumulated organisms. This information was presented within the Construction Phase Environmental Report, and reviewed within the Final Environmental Statement issued by the U.S. Atomic Energy Commission in December 1974 (Sections 3.4.5, 3.6, 5.5.2.2, 5.5.2.3).

3. Subsequent to this, the company determined through evaluation of activities at other coastal generating facilities, that in order to control effectively the settlement and potential growth of marine fouling organisms, continuous chlorination of both the Circulating Water and Service Water Systems was required. This strategy was 8801060337 880104 PDR G

ADOCK 05000443 PDR

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i prusented in detail with the operational License Phase l Environmental Report and within the NRC Final Environmental l

Statement of December 1982. This is also presented within l the Final Safety Analysis Report (FSAR) for Seabrook Station (Sections 9.2.1.2 and 10.4.5.2). Following an extensive review by the Environmental Protection Agency, the New Hampshire Water Supply and Pollution Control Division, and the New Hampshire Fish and Game Department of the Station National Pollutant Discharge and Elimination System permit (NPDES), a permit was issued which allowed for the control of fouling organisms within the systems through the continuous application of low level chlorine.

4. Environmental data collected since 1969 has identified the major macrofouling organisms to be the blue mussel (Mytilus edulis) and barnacles (Balanus spp.). The asiatic clam (Corbicula sp.) is a fresh water organism not observed within the region through monitoring programs. The blue mussel spawns when water temperature ranges from 10'C to 20*C, roughly May through October. Larvae remain planktonic for 2 to 3 weeks, but this may last as long as several months depending upon the environmental conditions. Settlement onto filamentous algae generally occurs when shell lengths reach 0.01 inches and into adult colonies when shell lengths of 0.03 - 0.06 inches are obtained. Growth following settlement is highly dependent on the environmental conditions of salinity, light, the degree of submergence, water temperature and food supply. Under optimum conditions it could be expected that an annual mussel growth be between 1-2 inches.

Barnacle settlement occurs during tne spring, with peak settlement found during April. Barnacle growth under favorable environmental conditiens is rapid and full size (approximately 0.25 - 0.5 inches) is achieved within a few months.

5. To determine the toxicity of chlorine, these as well as numerous other plant and animal species were evaluated through available literatura. Data presented within the 1974 Construction Phase Final Environmental Statement, identified that Mytilus edulis after a 35 day exposure to 1.0 mg/ liter of chlorine, experience 100% mortality. Data on barnacles for the same exposure and duration, revealed that a large number of mortalities are also experienced. The original design application of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per day at discharge concentrations of 0.2 mg/ liter to 0.5 mg/ liter would require the use of thermal backflushing of the Circulating Water System to achieve biofouling control. It was determined through the evaluation, that the continuous application of chlorine and the maintenance of residual of 0.2 mg/ liter would provide sufficient biocide presence to provide an environment hostile to larval attachment. This would ensure that the cooling water systems would be maintained free from

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i fouling while protecting the balance indigenous populations within the receiving waters.

6. The NPDES permit jointly issued by the EPA and State of New Hampshire, also requires that a Chlorine Minimization program be conducted. This program is designed to evaluate the least amount of chlorine application (and subsequent discharge to the environment), while maintaining the cooling water systems free from fouling. This program therefore j mandates the periodic evaluation and inspection of cooling water system components to evaluate fouling control. These inspections provide periodic review and assurances that critical systems are not impacted by fouling organisms.

While the' Chlorine Minimization program is still being conducted at a test facility, the on-site application of chlorine and subsequent inspections of cooling water system components have revealed no accumulation of fouling organisms.

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[shrieth W. Dow '

STATE OF NEW HAMPSHIRE t '

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I[M /Lt. ,e /Ut m ss. DecemberdI,1987 The above-subscribed Kenne'.h W. Dow appeared before me and made oath that he had read the feregoing affidavit and that the statements set forth therein are true to the best of his. knowledge.

Before me,

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' ' b J. . i t9 MLt o aN Not3ry Public 0 0r.:s a , , . . ,

My Commission Expires: My cen.a.x,,g; , i ", ~;;- ;/f'.y Peie

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I STATEMENT OF PROFESSIONAL QUALIFICATION

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KENNETH W. DOW I received a Bachelor of Science degree in Wildlife Management from the University of New Hampshire in 1976 and a Master of Science degree in Environmental Studies from the t

University of Lowell in 1984. I have ten years of experience .

as a scient'ist having primary focus in the areas of i, environmental impact assessment, biological sampling, and ,/

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permitting. I have been employed at Yankee Atomic since early 1977 and have been involved during this time with various industry groups on issues of environmental analysis,' >

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, yt permitting, and study. 1%r current position involves the oversight of environmental activities for sponsor companies of Yankee Atomic. For Sesbr5'ok Station, I currently manage (

l biologicalstudiesandcansul{.antsasmandatedbythe National Pollutant Disch4gge and Elimination System (NPDES) permit jointly issued Kp,the Environmental Protection Agenby is (EPA) and the New Hampsfdb(Water Supply and Follution { \ \,

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Control Division. My'axp bience with the use of chlorine \'!<

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(sodium hypochlorite) Isss'the b desired means for prnventing biological growth and 'subsdquent fouling of the Seabrook S.

Station Circulating Water and Service Water systems began in 1981, through the preparation of an analysis of the potential effects of continuous chlorination during station operation.

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