View source for RBG-26545, Forwards Proposed Changes to Asiatic Clam Control Program for Review.Approval Prior to 871115 Startup Following First Refueling Outage Requested

{{Adams
| number = ML20238C352
| issue date = 08/31/1987
| title = Forwards Proposed Changes to Asiatic Clam Control Program for Review.Approval Prior to 871115 Startup Following First Refueling Outage Requested
| author name = Booker J
| author affiliation = GULF STATES UTILITIES CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION &amp; RESOURCES MANAGEMENT (ARM)
| docket = 05000458
| license number = 
| contact person = 
| document report number = RBG-26545, NUDOCS 8709100054
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 13
}}

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Augt:s t 31, 1987 RBG-26545                             .a
                   ''                                                                                                    File No. G9.5, C10.2.7.
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n                                                 U.'S.' Nuclear Regul'atory Commission
                                                 . Document Control Desk-Washington.;D. C. ;20555 Gentlemen s,
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                                                                                    ' River Bend Station.- Unit 1 Docket <No. 50-458 i.
Enclosed for your -review oa're proposed changes to Gulf. States Utilities Company's (GSU)' Asiatic ; Clam Control Program. In' accordance with. Technical Specification 6.8.4.d, the proposed
                                                 . changes are-submitted for NRC Region IV and NRR approval prior to
                                                 -implementation of these' changes. Therefore, GSU requests your approval prior to startup following the. first refueling outage currently scheduled for November 15, 1987.
If     ;you              have-   sny       questions, : contact Mr. ' James Cook at
                                                 ,(504)381-4151.                                                                                                  i
      ~ .
J Sincerely,                                         l M                                                                                                                  .
   ; [jJ                                                                                                      'J. E. Booker                                        j Nanager-River Bend Oversight Itiver Bend'. Nuclear Group                        l 1
JEB/ ERG /               /ch Attachment 1 - ACCP Changes Attachment 2 -- Proposed ADM-0053, Rev. 2 cc:     U..S. Nuclear Regulatcry Commission Region IV                                                                                                .
611 Ryan Plaza Drive, Suite 1000                                                                         '
Arlington, TX 76011                                                                                     ;
NRC Resident Inspector P. O. Box 1051
                                                        'St. Francisv111e, I.A 70775 3709V1054B7g li g j-              PDs                .  , 00CK O             pg L            _P

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ATTACHMENT 1 9
ASIATIC CLAM CONTROL PROGRAM (ACCP) CHANGES y-REQUIREMENT
                                       ' River l Bend Station's.(RBS) Technical Specification 6.8.4.d          Biofouling Prevention and Detection requires:
i                      "A   program, approved by the.NRC Staff prior to introduction of
                                             . river water to the, systems, which will include the procedures to prevent 'biofouling           of    safety-related equipment, to assure     ;
detection.of Corbicula in-the intake embayment and the Mississippi          l River at the River Bend Station site, and to monitor and survey safety-related equipment to detect biofouling.           Changes to this program 'will be submitted to and approved by the NRC (both the Region and'NRR) prior to implementation."
HISTORY                                                                          4
                                       ~The RBS;ACCP was, submitted for review on June 21, 1985 and approved on           !
                                       -September 27, 1985. The program was implemented prior to introduction             I of river' water to plant systems and has been effective to date in preventing          biofouling of safety-related equipment.         The changes proposed herein are based on program experience and are expected to enhance the effectiveness of the ACCP.
1 DISCUSSION OF PROPOSED CHANGES                                                    j
                                                                                                                          ]
Many-   of         the. changes requested in this proposed revision are administrative or editorial in nature and were determined to not warrant further discussion.          A' discussion of the significant technical changes is provided herein as proposed revisions to Administrative Procedure (ADM)-0053, Revision 2 " Asiatic Clam Control Program."
6.2 Biological Monitoring for Asiatic Clams The requirement for monitoring to detect the presence or relative abundance of Corbicula in the Mississippi River channel has been deleted. As indicated in GSU's {{letter dated|date=August 21, 1984|text=August 21, 1984 letter}} in respanse to I&E Bulletin 81-03, several years of historical data exist for Corbicula in the river near the site for both substrate-associated          juveniles    and   adults   and     drifting   l larval / juveniles. The intent of this monitoring was to determine if there was a meaningful relationship between the method of sampling ambient densities of young clams in the source water and the method of sampling the clarifier influent.          The temporal and l                                              quantitative relationship of these two methods and sampling l
1 locations has been documented since the implementation of the ACCP.         Suspension of river sampling will not decrease the l
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effectiveness of the program, but in fact, will enhance the effectiveness by focussing resources on other phases of the         i program. Monitoring for adult /large juvenile clams will continue in the embayment where circulating water makeup is withdrawn.
The requirement for increasing the sampling frequency of the clarifier effluent for larval / smaller juvenile clams in the event i that normal service water chlorination is interrupted longer than 48 hours has also been deleted. When the program was planned, it was expected that the clarifiers would remove most, if not all, of these planktonic clams. Increasing the sampling frequency during chlorination lapses was supposed to contribute evidence that the lack of biocide was inconsequential. We now know that, although substantial removal is accomplished by the clarification process, some young clams are introduced into the Circulating Water system from the clarifiers.         Therefore, the purpose of increasing the sampling frequency of the clarifier effluent is moot and serves no purpose.
6.3 Sampling and Visual Inspections The requirement for visually inspecting the eleven Aux 111ary Building unit coolers yearly, one cooler per month, has been deleted. The unit cooler welded design prevents direct access for visual inspection of their internal coils. To physically cut into     these   heat exchangers would be expensive, man-power intensive, and would require the equipment to be Inoperative for a substantial period of time. The only method that can be used to positively determine the presence of adult clams is to collect the liquid and sediment from the lower coil drain and analyze it for evidence of clams. If significant quantities of fouling-size clams or shells were present, it is highly probable that they would be found in such samples.
The combination of this sampling and the conthly performance monitoring and trending required in Section 6.1 provides the redundant assurance that the Auxillary Building unit coolers will not abruptly / unexpectedly fail to serve their safety-related loads due to blockage by Corbicula.
6.4 CHLORINATION The provision that the chlorine concentration in the Normal Service Water system can be reduced during the months of December through March has been changed and the upper control limit of 0.8 ppm total residual chlorine (TRC) has been deleted.        When the ACCP was originally conceived, GSU was concerned that its wastewater discharge permit limitations on the discharge of chlorine in cooling tower blowdown could not be met if a TRC concentration of 0.6 to 0.8 ppm was used during winter months when evaporative dissipation in the cooling towers was reduced.
The reduction was also justified in that the spawning season for Corbicula in the source water occurs only during the months of

varmer river water temperature. However, we now know that young Corbicula are sometimes suspended in the source water during at least part of'the winter.
GSU has installed a system for injecting a dechlorinating chemica] Into the blowdown line so that the discharge permit limitations can be met regardless of the chlorine dosage used.
Blocide will now be applied year round to the Normal Service Water. system at a concentration of at least 0.6 ppm TRC to prevent survival of larvae spawned within the Circulating Water j                                     system or entrained in the clarifier effluent. The addition of E
this requirement will further assure that clams will not survive and grow to fouling size in the Normal Service Water system.

0 ATTACINENT 2 ASIATIC CLAM CONTROL PROGRAM                  j
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TABLE OF CONTENTS 1
SECTION                                                   PAGE NO.
4 1.0   PURPOSE / APPLICABILITY                               2

==2.0    REFERENCES==
2 3.0    DEFINITIONS                                           3     l 4.0    RESPONSIBILITIES                                      3 5.0    ADMINISTRATIVE CONTROLS                               4 6.0    GENERAL REQUIREMENTS                                  5 6.1 Monitoring and Trending of Safety Related         5 Equipment Using Service Water 6.2 Biological Monitoring for Asiatic Clams           5 6.3 Sampling & Visual Inspections                     6 6.4 Chlorination                                      7 6.5 Reporting                                '
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ADM-0053       REV - 2   PAGE 1 0F 8

1.0 PURPOSE APPLICABILITY 1.1   This procedure establishes the Asiatic Clam Control Pr'ogram (ACCP) to prevent and/or detect fouling of safety related equipment by Asiatic Clams.. The program includes.
1.1.1 -  Monitoring and trending of.the performance of safety related equipment which is supplied by Normal Service Water (NSW).
1.1.2    Biological monitoring for Asiatic Clams in the source of makeup water and in certain plant systems.
1.1.3    Inspection and/or sampling of selected heat exchangers.
1.1.4 - Chlorination of NSW.
1.1.5    Preparing and submitting required reports.
1.2   This program shall apply to all Station'0perating Personnel, Environmental Services Personnel, and Licensing Personnel responsible for the monitoring, detection, preventative maintenance, and reporting as required by this procedure.
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==2.0 REFERENCES==

2.1   RBS Technical Specifications 6.8.4.d and 6.9.2.b 2.2   IE Bulletin 81-03 Flow Blockage of Cooling Water to Safety System Components by Corbicula sp. (Asiatic Clams) and Mytilus sp. (Mussel) 2.3   ESP-8-049 Biological Monitoring for Asiatic Clams 1
2.4   PEP-0025 Biofouling Detection of Safety Related Equipment 2.5   PMP-8047 Preventative Maintenance Inspections and Sampling for Biofouling 2.6   SOP-0094 Hypochlorination and Chemical Feed i
2.7   RBG-18715 Lecter Booker-(GSU) to Seyfrit (NRC) dated August 21, 1984 2.8   Joint Interveners and State of Louisiana's motion to withdraw contention 1 related to the ASIATIC clam. Dated October 10, 1984 2.9   ADM-0019 " Initiation and Processing Condition Report" 2.10 RBNP-4, " Reporting Requirements" 2.11 CSP-0101, " Chemical / Radiochemical Non-Technical Specification I                           Surveillance" 2.12 CSP-0122, " Chemistry Surveillance of the Chemical Process
  .'                        Instruments" I
l ADM-0053          REV - 2       PAGE 2 0F 8

l              3.0 DEFINITIONS' l
3.1   Infestation - An accumulation of large juvenile and/or adult Asiatic Clams (or shells) which causes, or could cause, flow blockage in a safety related heat exchanger. Assessment of the potential for flow blockage shall consider the number and sizes of clams / shells in relation to the smallest critical orifices in the heat exchanger being inspected.
3.2   Large juvenile / adult clams - Specimens of Asiatic Clams with shell lenghts greater than or equal to 0.5 millimeters.
3.3   Larval / smaller juvenile clams - Specimens of Asiatic Clans with shell lengths less than 0.5 millimeters.
3.4   TRC - Total residual chlorine as defined by the latest revision of Standard Methods for the Examination of Water and Waste Water.
4.0 RESPONSIBILITIES 4.1  The Plant Manager has overall responsibility to ensure this program is implemented in accordance with commitments to the NRC and              '
Technical Specification requirements.
4.2  The Assistant Plant Manager - Operations and Radwaste (APM-0) is assigned the responsibility for implementation of this procedure.
The APM-0 assures the coordination of the activities between the supporting groups for implementation of the program, reviews the program results for acceptability and assures reporting requirements are satisfied.
4.3  The Supervisor Environmental Services, or designee, is responsible for ensuring that biological monitoring is conducted in accordance with Reference 2.3 and Section 5.2 of this procedure; for providing support to equipment inspections / sampling per Refe t cce 2.5; and for compiling internal reports in support of Section f.5 of this procedure.
4.4  The Mechanical Maintenance Supervisor, or desir.iee, is responsible for coordination of the inspection and sampling of safety related equipment in accordance with Reference 2.5 and Section 5.3 of this procedure, and providing a monthly summary report in accordance with Section 5.5.
4.5  Process Systems Supervisor, or designee, is responsible for ensuring     l that performance monitoring and trend analysis are carried out in          j accordance with Reference 2.4 and Section 5.1 of this procedure, and       1 providing a monthly summary report in accordance with Section 5.5.
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t ADM-0053      REV - 2          PAGE 3 0F 8             i

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4.6   The Chemistry Supervisor, or designee, is responsible for determining the chlorination level of the Normal Service Water, and providing direction,to the SS/COF for adjusting hypochlorite pump operation.
The Chemistry l Supervisor is responsible for compiling chemistry 1 results and providing a monthly summary report in accordance with Section 5.5. If a temporary chlorination system must be.used to satisfy Section 5.4 of this procedure, the Chemistry Section shall be responsible for operating the temporary system.
4.7   The Operation Supervisor, or designee, is responsible for operating the hypochlorite system in accordance with Reference 2.6.
4.8  The Director-Nuclear Licensing, or designee, is responsible for preparing fermal reports for offsite submission in accordance with Section 5.5 of this procedure.
                  - 5.0 ADMINISTRATIVE CONTROLS
                         .5.1  Review 5.1.1     Review of the ACCP and its results for adequacy shall be conducted after each twelfth quarterly report (once every three years). This review will be conducted by the Supervise r Environmental Services and APM-0. A review for    I adequacy shall also follow any Licensee Event Report attributable to the ACCP.
5.2  Record Retention 5.2.1     Records _ relative to the ACCP shall be retained for five years and shall include the following:
: 1. ACCP Reviews
: 2. Licensee Event Reports attributable to ACCP
: 3. Request for changes                                         I j
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: 4. Quarterly reports
: 5. Underlying data for quarterly reports                     l  )
5.3  Changes to the ACCP
                                                                                                            )
i 5.3.1    Requests for changes to the ACCP must be submitted to the NRC and should include an assessment of the proposed changes and supporting justification. Written approval of the proposed changes shall be received from the NRC prior to their implementation.
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ADM-0053       REV - 2           PAGE 4 0F 8         I J

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y 6.0 GENERAL REQUIREMENTS 6.1 Monitoring and trending of safety related. equipment using Normal p                                                       Service Water.
1                                                                                                                               i fl                                                      6.1.1   The Process System Supervisor, or designee, is responsible    {
i, for' monitoring and trending the performance of the safety related equipment in accordance with Reference 2.4.
Performance results are evaluated and reported in accordance with section 5.5 of this procedure.
I                                                               1. Performance Monitoring will be conducted monthly on
[                                                                      the following equipment:
: a. Control building water chiller condensers
: b. Anxiliary building unit coolers
: c. Emergency diesel generator coolers
: d. Residual heat removal heat exchangers
: e. Penetration leakage control compressor after coolers.
l                                                               2. Trending.will be accomplished in accordance with l                                                                      Reference 2.4. Any heat exchanger not meeting j                                                                      performance acceptance criteria shall be removed from service as soon as possible, inspected and corrective action taken.
6.2  Biological Monitoring for Asiatic Clams 6.2.1   Biological monitoring for Asiatic Clams will be accomplished by the Environmental Services Section in-accordance with Reference 2.3. Sampling / analysis will be performed to detect the presence and relative abundance of Corbicula as follows:
: 1. Large juvenile and adult clams
: a. Sediments of River Bend Station intake embayment-monthly,
: b. Sediments of normal cooling tower basins-monthly (one basin each month).
: 2. Larval and smaller juvenile clams
: a. Clarifier Influent - semimonthly April through November; monthly December through March.           !
: b. Clarifier Effluent - weekly April through November; monthly December through March.
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t 6.3- Sampling and Visual Inspections 6.3.1  Visual inspection and sampling will be performed by the Mechanical Maintenance Section and the Environmental Service Section in accordance with Reference 2.5. The following equipment'will be inspected at the prescribed intervals. Environmental Services personnel shall take samples of sediment, as appropriate; in each component to
                                                 'be analyzed for the presence of Asiatic clams.
: 1. Contro1' Building Water Chiller Condensers (4) - One per quarter
: 2. Emergency Diesel Generator Coolers (3) - each cooler
                                                        'every Refueling Outage
: 3. Penetration Leakage Control. Compressor After Coolers (2) - One cooler each 6 months 4     RHR Heat Exchangers (4) - each heat exchanger every     ,
Refueling Outage.                                       1 6.3.2  Due to the welded design of the Auxiliary Building unit coolers, th'e only method that can be used to determine the presence of adult clams is to obtain a liquid sample and analyze it for the presence of clams. These coolers (11) shall be sampled yearly, one cooler per month.
6.3.3  In the event service water is cross connected with the Fire   !
Protection or RPCCW System, the Shift Supervisor / Control Operating Foreman shall notify the Mechanical Maintenance Supervisor,'and the Process System Supervisor. Cross connection will require inspection and sampling at            {
j appropriate points in accordance with the applicable section of Reference 2.5. The affected system will then be flushed with demineralized water to remove chemical contaminates and return chemical parameters to the acceptable range. The Shift Supervisor shall request            !
increased monitoring of these systems by Chemistry             i personnel until chemistry limits are satisfied. This notification should be made using a Condition Report.
6.3.4  If sny inspections / sampling reveal an infestation of      l Asiatic Clams in any heat exchanger listed in Step 5.3.1 and 5.3.2 above, performance testing per Reference 2.4 of all other safety-related components monitored will be conducted within seven (7) days. A Condition Report will be generated in accordance with Reference 2.9 which identifies the. quantity of clams / shells relative to the size of the heat exchanger (s), systems affected, and i                                                 corrective actions taken to prevent further spread of l                                                 clams.

6.4 Chlorination-6.4.1   Chlorination of NSW will normally be accomplished in accordance with Reference 2.6. The chlorination system will be operated continuously to maintain a TRC concentration of at least 0.6 ppm in the Normal Service Water return header as determined by sampling and analysis and/or as read on recorder 1-WTH-AR144 (Blue pen) or locally at 1WTH-AE158. If the hypochlorite system becomes inoperable, alternate methods of chlorination may be used, including batch addition, or a temporary system until the hypochlorite system is returned to service. If the recorder becomes inoperable, Chemistry shall sample (grab) the NSW return header once per 12 hour shift. In the event the chlorination is not maintained greater than 0.6 ppm TRC for a continous period of 48 hours, a Condition Report                     I shall be initiated in accordance with Reference 2.9.
I 6.4.2   The Chemistry Supervisor, or designee shall sample and analyze NSW for TRC in accordance with Reference 2.11 and 2.12 and provide results on a monthly basis to the APM-0 rnd Supervisor Environmental Services.
6.5 Reporting 6.5.1   Reports will be submitted on a quarterly basis to the Joint Interveners and the State of Louisiana within 60 days after the end of each calendar quarter. The reports will contain a summary of the ACCP activities at River Bend Station and copies of the Louisiana Water Discharge Permit (#WP0409) monitoring reports of chlorine discharges to the Mississippi River for the quarter. These quarterly reports                   I shall be prepared by Nuclear Licensing on the basis of informa+1on compiled by the Supervisor-Environmental                          .
Services.                                                                    !
6.5.2   Monthly status reports of ACCP activities shall be submitted by the Chemistry, Process Systems, and Mechanical                  I Maintenance Supervisors to the APM-0 and                                     I Supervisor-Environmental Services. The status reports from the individual areas shall include; as a minimum;
: 1. Monthly chemistry sample results; number of hours the                   l NSW chlorine was out of specification; reasons (s) for                  I out of specification condition (s).
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: 2. Performance monitoring, results including the l                        identification of adverse trends; identification of l
l                        corrective action (s).                                                  l
: 3. Results of heat exchanger inspections; any missed                       j inspections and causes; corrective actions initiated resulting from inspection.                                              I l
ADM-0053       REV - 2         PAGE 7 0F 8 l
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6.5.3 Upon identification of infestation of any clams in a safety                l related system of a magnitude which causes or may cause flow blockage, a report will be submitted to the NRC in accordance with Reference 2.1 within 30 days describing the level of infestation, affected system, and measures taken to prevent further infestation.                                           !
                                                                                   "END"                                                i c3                   l z=                   ;
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