ML20237E850

NRC Staff Supplemental Response to New England Coalition on Nuclear Pollution First Set of Interrogatories & Request for Production of Documents.* Affidavit of Mb Fairtile & Certificate of Svc Encl.Related Correspondence

ML20237E850
Person / Time
Site:	Seabrook
Issue date:	12/11/1987
From:	Berry G NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	NEW ENGLAND COALITION ON NUCLEAR POLLUTION
References
CON-#487-5141 ALAB-875, OL-1, NUDOCS 8712290223
Download: ML20237E850 (10)

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• 00CKETED USNRC UNITED STATES OF AMERICA g/ g g pj @g NUCLEAR REGULATORY COMMISSION OFricE DF SLCF a rs <

BEFORE THE ATOMIC SAFETY AND LICENSING BOAEEN yj[ic in the Matter of )

) Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF ) 50-444 OL-01 NEW HAMPSHIRE, et al. ) On-site Emergency Planning

) and Safety issues (Seabrook Station, Units 1 and 2) )

NRC STAFF SUPPLEMENTAL RESPONSE TO NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE NRC STAFF ON NECNP CONTENTIONS 1.V. AND IV

l. INTRODUCTION On November 20, 1987, the New England Coalition on Nuclear Pollution (NECNP) served upon the NRC Staff its first set of interrogatories in which it propounded thirteen interrogatories (several of which contain multiple parts) and requests for the production of documents relating to the two contentions remanded for forther litigation by the Appeal Board in A LA B-875. The Staff responded to Interrogatories 1,2,3,4,5,6, and 7 on December 7, 1987. Herein, the Staff responds to interrogatories 8 through 13.

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11. RESPONSES Interrogatory 8 What is the Sta ff's position with respect to the adequacy of Applicants' program for prevention of biofouling of cooling systems in the

_. Seabrook nuclear power plant?

Answer >

The Staff has reviewed the design of the systems in the Seabrook Nuclear Plant intended to prevent biofouling of cooling systems which use continuous low-level chlorination and through thermal back flushing. The Staff finds that these systems, as designed, will perform in the manner proposed by Applicants.

At Seabrook, the station service water system (PSID Figure 9.2-1) and the circulating water system (PSID Figure 10.4-3) are the only open-cycle water systems susceptible to damage by biofouling as a result of direct intrusion of marine species. The Seabrook system injects chlorine, in the form of sodium hypochlorite (NaOCl), at a suitable concentration into the intake tunnel and intake transition structure of the station service water and circulating water systems in order to destroy any marine species which may be introduced into the plant to cause i

biofouling. The NaOCl is pumped into the plant intake tunnel through six two-inch risers in each tunnel shaft and through spray nozzles into the intake transition structure by an intake tunnel chlorination and distribution system (PSID Figure 10.4-3a).

In addition to this method , Applicants propose, if necessary, to align the main circulating water system so that hot condenser discharge

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water is fed to the intake tunnel while water is being supplied from the disci.arge tunnel. This would serve as a hot backflush for the inlet tunnel. ,

The design of the chlorination system provides for introduction of NaOCl while the reversed flow in the circulating water system provides a backup to the chlorination process if deemed to be necessary.

(Norman Wagner)

Interrogatory 9 Please identify and produce all documents on which you rely or intend to rely during this proceeding to support your position on NECNP contention IV (biofouling of coolant systems). This includes but is not limited to all documents used in answers to these interrogatories, summary disposition motions, testimony, and cross-examination of witnesses during hearings. l l

Answer The NRC Staff currently intends to rely upon the following documents to support of its position with respect to NECNP Contention IV:

a. IE Bulletin No. 81-03: Flow Blockage of Cooling Water to Safety System Components by Corbicula sp. (Asiatic Clam) and Mytilus sp. (Mussel). April 10,1981.

b. Seabrook Final Environmental Statement, NUREG-0895, December 1982, Pages 4-23, 4-24, 5-2, 5-3, 5-4, 5-11, 5-12 and 5-13.

c. Seabrook Units 1 and 2 Final Safety Analysis Report, Pages 9.2-2 and 9.2-3.

d. Abnormal Occurrence; Blockage of Coolant Flow to Safety-Related Systems and Components, 47 FR 21653 dated May 19,1982.

e. NUREG/CR 4626, Vol . 1, improving The Reliability OF Open-Cycle Water Systems.

The above documents are available in the Public Document Room.

(Morton Fairtile)

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.. i interrogatory 10 Please identify all persons on whose factual knowledge opinions, or technical expertise you rely or intend to rely for your position on contention IV. ,

Answer The NRC Staff currently intends to rely upon Norman Wagner of the.

Plant Systems Branch of the Office of Nuclear Reactor- Regulation, an expert in the area of plant systems review and upon the expertise of a marine biologist (yet to be selected) regarding the biological aspects of the review. The parties will be notified of the identities of this witness seasonably.

Interrogatory 11 l Please identify all persons you may call as witnesses on contention IV. Please' describe the substance of their testimony; and identify and describe any documents and the portions thereof that they may rely on for their testimony.

Answer See NRC Staff response to Interrogatory 10. The substance of the testimony of the Staff's witnesses is expected to be that the preventative  ;

actions planned by the appilcant are sufficiant to prevent biofouling from interfering with the safety functions of the coolant flow systems that j I

would otherwise be subject to such degradation. The documentation is '

the same as listed in the Staff's response to interrogatory 9. Copies of statements of professional qualifications of the Staff's witnesses on NECNP Contention IV will be furnished to NECNP.

Interrogatory 12 Please identify and provide access to all studies, evaluations, ,

reports, or other documents which describe and/or evaluate actual or potential biofouling conditions at Seabrook.

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s Answer See NRC Staff. response to interrogatory 9, especially items a, b, c, and e. ,

(Morton Fairtile) '

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interrogatory 13 l

l Please identify and provide access to documentation of all inspections of safety and non-safety related cooling systems that are affected by or are potentially affected by biofouling.

Answer The Staff objects to answering this interrogatory since the identity of cooling systems which are or may be affected by biofouling is reasonably obtainable from another source, namely the Applicants. l Moreover, to the extent that the interrogatory seeks documentation of I

inspections of cooling systems at facilities other than Seabrook, the f l l interrogatory is objectionable because it calls for information not necessary to a proper decision in the proceeding. Without waiving these objections, the Staff responds to Interrogatory 13 as follows:

The cooling water systems that could be exposed to biofouling were the subject of eight NRC Inspection Reports:  :

a. 85-20

b. 85-31

c. 86-47

d. 86-52

e. 87-13

f. 87-16

g. 87-18 l

h. 87-23 These reports were flied under the 50-443 docket of Seabrook Unit No.1, but are applicable to both plant units. Inspection Reports 85-20 and 85-31 specifically relate to Applicants' response to IE Bulletin B1-03 (see item a in response to question 9). The inspection Reports indicate that r

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.l Applicants responded properly to the Bulletin. Inspection Report 86-52 describes a detailed inspection of liner surfaces conducted by NRC inspectors. No evidence of either biofouling nor microbifogical organisms was observed during this inspection.

(Morton Fairtile) s bectfully su m ted,

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Gregory an

'An0)w-Ary 4 Counsel rN C Staff Dated at Bethesda, Maryland this 11th day of December 1987 I l

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

) Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF ) 50-444 OL-01 NEW HAMPSHIRE, et a_I. I ) On-site Emergency Planning

) and Safety issues (Seabrook Station, Units 1 and 2) )

AFFIDAVIT OF MORTON B. FAIRTILE I

I, Morton B. Fairtile, being first duly sworn do hereby depose as follows:

. 1. That I am employed by the Nuclear Regulatory Commission as a Project Manager.

2. That i participated in the preparation of the NRC Staff's responses to Interrogatories 9 through 13 of NECNP's First Set of Interrogatories And Request For The Production of Documents To The NRC Staff on NECNP contentions I.V.

and IV.

3. That such responses are correct to the best of my knowledge and belief.

'Ah b'YL Morton B. Fairtile Sworn to and subscribed before me this /v? day of December 1987:

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j My Commision Expires: July 1,1990  !

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DOCKE TEf-USNHC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION *87 KC 16 P4 :09 l BEFORE THE ATOMIC SAFETY AND LICENSING BO{%Qg?g BRANCH in the Matter of )

l ) Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF ) 50-444 OL-01 NEri HAMPSHIRE, et al. ) On-site Emergency Planning

) and F,afety issues (Seabrook Station, Units 1 and 2) )

1 i CERTIFICATE OF SERVICE I bereby certify that copies of "NRC STAFF SUPPLEMENTAL RESPONSE TO NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S FIRST SET OF INTERROGATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE NRC STAFF ON NECNP CONTENTIONS 1.V. AND IV" in the above-captioned procecding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mall system, this 11th day of December 1987.

l Sheldon J. Wolfe, Esq. , Chairman

• Dr. Emmeth A. Luebke Administrative Judge Administrative Judge Atomic Safety and Licensing Appeal 5500 Friendship Boulevard Board Apartment 1923N U.S. Nuclear Regulatory Commission Chevy Chase, Maryland 20815 Washington, DC 20555 Ms. Carol Sneider, Esq.

Dr. Jerry Harbour

• Assistant Attorney General Administrative Judge Office of the Attorney General Atcmic Safety and Licensing Appeal One Ashburton Place, 19th Floor Board Boston, MA 02108 U.S. Nuclear Regulatory Commission Washington, DC 20555 Richard A. Hampe, Esq.

New Hampshire Civil Defense Agency Beverly Hollingworth 107 Pl(asant Street 209 Winnacunnet Road Concord, NH 03301 ,

Hampton, NH 03842 Sandra Cavutis, Chairman Calvin A. Canney, City Manager Board of Selectmen City Hall RFD 1 Box 1154 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801 Stephen E. Merrill Paul McEachern, Esq.

Attorney General Matthew T. Brock, Esq.

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. Stephen E. Merrill Paul McEachern, Esq.

Attorney General . Matthew T. Brock, Esq.

George Dana Bisbee Shatnes & McEachern Assistant Attorney General 25 Maplewood Avenue Office of the Attorney General P.O. Box 360 25 Capitol Street Portsmouth, NH 03801

• Concord, NH 03301 Roberta C. Pevear Angle Machiros, Chairman State Representative Board of Selectmen Town of Hampton Falls 25 High Road Drinkwater Road .

Newbury, MA 09150 Hampton . Falls, NH 03844 Allen Lampert Mr. Robert J. Harrison Civil Defense Director President and Chief Executive Officer Town of Brentwood Public Service Co. of New Hampshire 20 Franklin Street P.O. Box 330 Exeter, NH 03833 Manchester, NH 03105 Charles P. Graham, Esq. Robert A. Backus, Esq.

McKay, Murphy and Graham Backus, Meyer & Solomon.

100 Main Street 116 Lowell Street Amesbury, MA 01913 Manchester, NH 03106 Diane Curran, Esq. Philip Ahren, Esq.

Harmon & Weiss Assistant Attorney General 2001 S Street, NW Office of the Attorney General Suite 430 State House Station #6 Washington, DC 20009 Augusta, ME 04333 Edward A. Thomas Thomas G. Dignan Jr., Esq.

Federal Emergency Management Agency Ropes & Gray 442 J.W. McCormack (POCH) 225 Franklin Street Boston, MA 02109 Boston, MA 02110 H.J. Flynn, Esq. William Armstrong Assistant General Counsel Civil Defense Director Federal Emergency Manao9 ment Agency Town of Exeter 500 C Street, SW 10 Front Street Washington, DC 20472 Exeter, NH 03833 Atomic Safety and Licensing- Atomic Safety and Licensing Appeal Panel

• Board

• U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555

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, Jane Doughty Docketing and Service Section* /

Seacoast Anti-Pollution League Office of the Secretary 5 Market Street U.S. Nuclear Regulatory Commission Portsmouth, NH 03801 Washington, DC 20555 Maynard L. Young, Chairman William S. Lord -

Board of Selectmen Board of Selectmen 10 Central Road Town Hall - Friend Street South Hampton, NH 03287 Amesbury, MA 01913

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I Michael Santosuosso, Chairman Peter J. Matthews, Mayor Board of Selectmen City Hall South Hampton, NH 03287 Newburyport, MN 09150 Mr. Robert Carrigg, Chairman Judith H. Mizner, Esq.

Board of Selectmen Silvergiate, Gertner, Baker Town Office Fine and Good Atlantic Avenue 88 Broad Street North Hampton, NH 03862 Boston, MA 02110 R. K. Gad 111, Esq. Mrs. Anne E. Goodman, Chairman Ropes & Gray Board of Selectmen 225 Franklin Stree't 13-15 Newmarket Road Boston, MN 02110 Durham, NH 03824 Gary W. Holmes, Esq.

Holmes & Ellis 47 Winnacunnet Road Hampton, NH 03842 f

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' Gregory A f iri B el 'r y Counsel fo'; NRCl Staff

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