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j; UNITED STATES OF AMERICA 0 hc NilCLEAR REGULATORY COMMISSION PEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFICE Of SECRt. tan r 00CMETM A stay;cy, in the Matter of ) BRANCH | |||
) Docket Nos. 50-4h3 OL PUBLIC SERVICE COMPANY OF ) 50-4 4n . 0L-01 NEF HAMPSHIRE, et al. | |||
-~ | |||
) On-site Emergency Phanning | |||
) and Safety issues (Seabrook Station, Units 1 end 2) ) | |||
NRC STAFF RESPONSE TO NEW ENGLAND COALITION ON NUCLEAR FOLLUTION'S SECOND SET OF INTERROCATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE NRC STAFF ON NEC.?M CONTENTIONS 1.V. AND,lV. | |||
Interrogatory 1 Picasc identify all persons who participated in the preparation of answers to these interrogatories, and identify the portions of your response to which each persen contributed. | |||
Pgp_onsa See Attached affidavits of Paul C.S. Wu and Norman Wagner. | |||
_ Interrogatory 31 For each cooling system at .the Seabrook plant, please answer the following questions. | |||
(a) What is the Staff's position with respect to the adecuacy of Applicants' program for monitoring and detecting the condificns that will allow microbiologically induced corrosion to occur in these cooling systems | |||
< prior to its occurrence, including techniques for determining the extent of seclin;entation or corrosion? | |||
(b) What is the Staff's position with respect to the adequacy of Applicants' program for monitoring and detecting the presence of microbiologically induced corrosion in these systems after its occurrence, including techniques for determining the type and extent of such corrosion? | |||
0802170089 880210 PDR ADOCK 05000443 0 PDR | |||
3.- , (c) .What is the Staff's position with respect to the adequacy of | |||
, Applicants' program for treating and controlling biofouling . and microbiologically induced corrosion in these systems after it.s occurrence? | |||
(d) Identify and produce all documents prepared by the NP.C or its contractors which assess, evaluate, or discuss the Applicants' programs | |||
. for monitoring, _ detection, treating or controlling biofouling and micro-biologically Induced corresion. | |||
(e) Identify any studies, evaluations, or assessments _urderway or planned by NRC or its contractors relat!ng to the occurrence, monitoring, detection, treatment or control of microbiologically induced corrosion. | |||
( f) Describe the type and extenc of any microbiologically induced corrosion that has been identified or detected in any of these systems. | |||
===Response=== | |||
(a): The Staff does not have a position with respect to the adecuacy of Applicants' prog ram for tronitoring and detecting the conditior.s that will allow microbiologically induced corrosion to occur in these coolitig systems, because Applicants have nyt submitted such a prograrn ' for Staff review. However, bered on the statenent made by Applicants at page 11 of their January 14, 1988 response to N E CN P's second set of interrogatories on NECNP Contention IV dated January 14, 1900, the Staff consiocrs that by applying initial biocidai treatment followed by chlorination and ozonation of the well water influent to the water treatment plant, Applicants have effectively reduced the propensity for microbiologically inouced corrosion. Furthermore, the efluent of the water treatment plant was tirst filtered and dechlorinated , then domineralized and passed thrcugh a UV sterilization unit p rio,' to distribution to various plant systems. These treatments provide adequate assurance that biologically induced corrosion will net occur. | |||
l Additionally, it should be noted that microhlologically induced l | |||
corrosion is a slow degradatien process. 1.aboratory test results and field l | |||
l l | |||
l l | |||
_s _ _ . | |||
m , , _ - ._- | |||
+ 3- , | |||
~ c.xperienceL Indicate that microbiologically- Induced corrosion causes gradual | |||
- corrosion and . pitting. It docs - not cause rupture or sudden failure, . | |||
however. Therefore, the effect of microbiologically induced corrosion of the Seabrook Station steam generator tubes is not Tsignificant from a safety stardpoint. | |||
(Paul Wu) | |||
(b): Applicants have not submitted . a program for monitoring and detectino the presence of microbiologically induced corrosion for Staff review. However, Applicants indicate, at page 9 of their response to NECNP's Lsecond ' set of interrogatories on NECNP Contention IV that a program for preventien of microbiologically Induced corrosion is based on water treatment, monitoring of plant systems by visual Inspection, and . | |||
quarterly bulk water sampling for macro-organisms which are likely to ; | |||
cause degradation of metals or alloys. The, Staff considers this an adequate p rog ram to monitor and to detect microbiologically induced corrosion. | |||
(Paul Wu) | |||
(c): Appilcants have not reported any microbiologically induced corrosion in its cooling system, and the Staff has not received any App!! cant submittals for review regarding treating and controlling microbiologically induced corrosion in its cooling systems. Hewever, based on the statement made by App!! cants on pages 9-11 cf their response to the NECNP's second set of Interrogatories on NECNP Conten-tion IV, the Staff considers thc prograrr to prevent ano to detect micro-biologica!Iy induced corrosion in the cooling systems described theroin Edeq uat e . | |||
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, , , , - , , - - . - - - - - . - _ - - , ._ . ? | |||
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-4_ | |||
(Paul Wu) 1/ith respect to the adequacy of Applicants' program for treating and controlling biofouling, g A ffidavits of Dr. Michael f.iasnik and horn an Wagrer, attached to NRC Staff Response To Licensing Board Order of Noverrber 27,198f> (January 12, 1988). | |||
(d): There are no documents prepared by the NRC or. its contractors which assess, evaluate, or discuss Applicants' programs for monitoring, aetecting, treating or controlling microbiologically induced corrosion in the cooling systems. See Response to Interrogatory 31(a). | |||
(Paul hu) | |||
The fcilowinc documents are related to the subject of biofouling and are available in the Public Docurrent Roorn: | |||
: 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, NUPEG-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, 9.2-3, 10.4-12, 10.4-13, and Figure 10.4-3a. | |||
: d. NUREG/CR 4626, Vol . 1, improving the Reliability of Open-Cycle Water Systems. | |||
(Norman Wagner) | |||
(c): There currently are no studies, evaluations, or assessments | |||
. underway or planned by NPC or its contractors relating to the occurrence, rionitoring, detection, treatment or control of microbiologically induced corrosion in cooling systems. | |||
(Paul Wu) | |||
(f): The two types of organisms most frecuently involved in r11cro-biologically induced corrosion in cecling systems of nuclear power plants | |||
-S-4' are: (1) the heterotrophic iron and manganese oxidizing organisms such as the Callionella, identified in the Essential Spray Pond Piping System of the Palo Verde Unit 2, which have caused severe pitting corrosion of the stainless steel piping system in welds and heat-affected-zone; and (2) the anaerobic or sulfate reducing bacteria such as the Desulfovibrio Group, iderit'Ged in 'the Service %atu System of the Virginia Power Company's North Anna Plant, which have caused pitfirig and wasteace corrosion of the carbon steel pipino system. | |||
(Paul Wu) interrogatory 32 in NRC spection Report No. 50-403/87-07, at page 16, the inspector diset,' ..d the Applicents' disassembly, cleaning and reassembly of fire prctectico piping inside the fire pump house (part of the Fire Protection System) which contained microbiologically induced corrosion. | |||
Please answer the foliowing questions regarding this incident: | |||
(a) Identify and produce any documents, mernora nda , reports, drawings, or photographs produced by resident inspectors or other NRC staff that in any was discuss, investigate, or evaluate this incic'en t. | |||
(b) Vihat measurcs, if any, could have prevented this problem from occurrinc ? | |||
===Response=== | |||
The Staff cbjects to interrogatory 32 on the grounds that issues relating to the fire protection system are outside the scope of Conten-tion IV, which concerns the adequacy of Applicarts' surveillance and maintenance pregram at Seabrook Station to prevent the accumulation of mollusks, other aquatic organisms, and debris in cooling systems only. A fire protection systeri is not a ecofing system. Therefore, the information sought is not necessary for a proper decision in the proceeding. | |||
(Paul Wu) | |||
b Interrogatory 33 in N PsC Inspection Report No. 50-443/87-23, at page 10, the inspector observed tube degradation in the "B" train PCCW heat exchanger C C-E-17 B . Please answer the following questions regarding this incident: | |||
(a) Identify and produce any documents, reports , drawings, or photographs produced by resident inspectors or other NRC staff that in any way discuss, investigate, or evaluate this incident. | |||
(b) Describe the cause of causes of this deg radation , including whether microbiologically induced corrosion played a role in this degradation? | |||
(c) If you determined that microbiologically induced corrosion did not play a role in this incident, explain how you reached this conclusion. | |||
(d) Describe what measures, if any, could have prevented this degradation from occurring? | |||
===Response=== | |||
(a) All documents, d rawings , and other pertinent information related to the observed tube degradation in the "B" train PCCW heat exchanger C C-E-17 B are referenced in the NRC Inspection Report No. 50-443/87-07 dated November 12, 1987 (Paul Wu) | |||
(b): In their response to Interrogatory 2 of the second set of interrogatories related to NRCNP Contention IV, Applicants indicate that the cause of degradation was determined to be pin hole leaks resulting from a casting defect which degraded with service time. This was determined by considering and eliminating all other possible causes, including microbiologically induced corrosion, for the defect. No tests or examinations were conducted by the Staff or its contractors. | |||
(Paul Wu) | |||
(c): Biological growth is normally present in and around the areas where microbiologically induced corrosion occurs. Since there was no i | |||
i such deposits characteristic of microbiologically induced corrosion observed by Applicants, and, furthermore, the water in the PCCW is sterilized prior to its introduction into the system , therefore, microbiologically induced corrosion could not be the cause of the degradation. | |||
(Paul Wu) | |||
(d): As Applicants indicate, the pin hold leaks were the result of a casting defect which degraded with service time, the Staff considers that a stringent QA program for purchasing and extensive hydrotesting before starting up would prevent any defective component from being placed in service. | |||
(Paul Wu) | |||
Interrogatory 35 Describe what measures the NRC has taken, and plans to take, to assure itself that microbiologically Induced corrosion will be detected, treated and controlled at Seabrook. | |||
===Response=== | |||
The NRC has not taken, and does not plan to take, any measures at the present time to assure itself that microbiologically induced corrosion will be detected, treated and controlled at Seabrook. We consider that the program described by Applicants in its Response No. 2 to the second set of Interrogatories of NECNP Contention IV to be adequate in addressing these concerns. | |||
(Paul Wu) i l | |||
.. Interrogatory 36 Do General Design Criteria 2, 4, 5, 44, 45, and/or 46 require Applicants to monitor cooling systems for the presence of biofoullng or. | |||
microbiologically induced corrosion? If yes, Identify each cooling systems that should be so monitored and state whether it is a closed or open water system. | |||
===Response=== | |||
No, they do not require an app!! cant to monitor cooling systems specifically for the presence of biofouling or microbiologically induced corrosion. | |||
(Paul Wu, Norman Wagner) | |||
Interrogatory 37 Do General Design Criteria 2, 4, 5, 44, 45, and/or 46 require Applicants to monitor cooling systems for the conditions that allow biofouling or microbiologically induced corrosion to occur? If yes, Identify each cooling systems that should be so monitored and state whether it is a closed or open water system. | |||
===Response=== | |||
No, they do not. | |||
(Paul Wu, Norman Wagner) interrogatory 38 (n NUREC/CR-4626, Volume 2, at page 20, it is concluded that flow velocity is the most reflable indicator of conditions that allow micro-biologkally induced corrosion to occur, and that visual inspection is the most effective surveillance technique for determining the type and extent of microbiologically induced corrosion after its occurrence. Do you agree? | |||
If not, provide your reasons. | |||
Res ponse, in NUREG/CR-4626, Vol. 2, at page 20, it is stated that flow velocity is the most reliable indicator of potential biofouling, sedimentation and corrosion within the open-cycle water system. The | |||
9_ | |||
Staff agrees with this statement. In general, sedimentation and biofouling, conditions which tend to cause microbiologically induced corrosion will likely occur in conditions with flow velocities less than | |||
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3 feet per second. NUREG/CR-4626 states on 'the same page that visual observation is the most effective surveillance technique for determining the type and extent of fouling. NECNP incorrectly equates "fouling" as "microbiologically induced corrosion. " Blofouling could lead to microbiologically induced corrosion but it is not the necessary condition. | |||
Sedimentation alone could cause microbiologically induced corrosion to occur. The Staff also disagrees with the NECNP's statement that visual inspection is the most effective surveillance technique for determining the type and extent of microbiologically induced corrosion. in order to determine the type and extent of microbiologically induced corrosion, a combination of biological analysis, microst/uctur'al examination, and visual observation must be performed to provide results for final analysis. | |||
(Paul Wu) | |||
Interrogatory 39 in NUREG/CR-4626, Volume 2, at page 30, it is concluded that high-velocity flushing in combination with continuous chlorination may be an effective way of controlling microbiologically induced corrosion. Do you agree? If not, provide your reasons. | |||
Responso Yes, the Staff agrees with the conclusion that high-velocity flushing in combination with continuous chlorination may be an effective way of controlling biofouling and microbiologically induced corrosion. | |||
(Paul Wu) | |||
Interrogatory 40 Please identify what other ' treatments or combinations of treatments that you believe are as or more effective than high-veolcity flushing combined with continuous chlorination, in controlling microbiologically induced corrosion, including but not ilmited to the treatments described in NUREG/CR-4626, Volume 2, at pages 23 to 30. | |||
===Response=== | |||
As stated at page 23 of NUREG/CR-4626, Volume 2, the following measures are all effective means in controlling biofouling and MIC: | |||
o chlorination to control slime,and bivalves o | |||
the AMERTAP and MAN mechanical tube cleaning systems tube scrapers to clean heat exchanger tubes hand scrapers to remove attached bivalves from the intake structure and intake piping hydroblasting to control slime and remove attached bivalves antifoulant coatings to prevent bivalvo attachment thermal backwashing to kill bivalves o | |||
nonthermal backwashing to flush bivalves and debris from flow constrictions e | |||
oxygen scavengers to kill bivalves screens and strainers to prevent bivalves from entering the open-cycle water system contoured intake structures to eliminate low-flow areas intermediate cooling loops to isolate small heat exchangers from the open-cycle system. | |||
(Paul Wu) | |||
Interrogatory 41 Do you believe thet chlorination is effective in preventing or minimizing microbiologically induced corrosion? If yes, please answer the i following questions: | |||
.. 4 y | |||
_ 11 _ | |||
(a) Explain the condition 9 under which chlorination is most effective in preventing or minimizing microbiologically indcced corrosion, including the location that chlorine should be injected in each . cooling system, and the frequency and duration of chlorine injections, and concentration (in parts per million) of chlorine at the point of injection, in each cooling system. | |||
(b) At what level must chlorine concentration (in parts per million)- | |||
be maintained to be effective in preventing or minimizing microbiologically induced corrosion? | |||
===Response=== | |||
(a) As indicated on page 23 of NUREG/CR-4626, Volume 2, chlorination is an effective control technique for biofouling. Intermittent chlorination effectively controls slime, but it must be applied continuously at least during bivalve spawning seasons to control bivalves. Since cooling systems are not generic for all nuclear power plants, its design and construction vary from plant to plant. Therefore, the locations of chlorine injection also are not generic for all plants. The specific locations where chlorine was injected at the Seabrook Plant were described at pages 25-26 of Applicants' response to the second set of interrocatories related to the NECNP Contention IV. | |||
(Paul Wu) | |||
(b): As indicated at pages 9-10 of the applicants' responses to the second set of interrogatories related to the NECNP Contention IV, chlorine concentrations of 0.2 to 3 ppm are effective at killing the microbiologically induced corrosion related macro-organisms. | |||
(Paul Wu) | |||
Interrogatory 42 Describe the Staff's position with respect to the effectiveness of thermal backflushing in controlling microbiologically induced corrosion. | |||
===Response=== | |||
The Staff does not have a position with respect to the effectiveness of thermal backflushing in controlling microbiologically induced corrosion. | |||
Applicants have not made any requests related to this sut cet which requires Staff review. | |||
(Paul Wu) | |||
Interrogatory 43 Describe any harm or damage to cooling systems that might occur as a result of thermal backflushing at the Seabrook plant up to four times per year. | |||
===Response=== | |||
Appilcants have not submitted any request on this subject for Staff review, and the Staff has not performed an analysis on any possible harm or damage to cooling systems resulting from thermal backflushing at the Seabrcok plant up to four times per year. | |||
(Paul Wu) | |||
It should be noted, however, that at present there appears to be only one System in which Applicants propose thermal backflushing and that is in the temporary reversal of flow in the intake and discharge tunnels for the circulating water (CW) system (FSAR, page 10.4-13). In this case, Applicants state that this method "is also availdle", i.e., in addition to the injection of sodlum hypochilorite. Therefore, the rate of usage of this method is unknown but, presently, is expected to be low (once every few years) since Applicants intend to rely mainly on Injection of sodium hypochlorite for blofouling control. At any rate, flow reversal | |||
in the tunnels does not appear to affect either the CW system or the | |||
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intake and discharge tunnels, adversely. | |||
(Norman Wagner) interrogatory 44 Describe any harm or damage to cooling systems that might occur as a result of thermal backflushing at the Seabrook plant more than four times per year. | |||
Response _ | |||
As noted above, in response to interrogatory 43, the need for thermal backflushing of the intake and discharge tunnels is expected to be low and is not expected to affect, adversely either the CW system or the tunnels. | |||
(Norman Wagner) | |||
Interrogatory 45 Describe any incidents of microbiologically induced corrosion that has been identified or detected in any other nuclear power plants, including the type and extent of such corrosion or sedimentation, the systems in which the microbiologically induced corrosion occurred, and identify any documents related to these incidents. | |||
Responsc On October 2, 1984, and again on December 5, 1984, VEPCO held meetings with the NRC Staff to discuss issues concerning microbiologically induced corrosion in the North Anna service water system piping and valves. The corrosion of the SWS piping is in the form of general wall thinning and wide spread pitting. A detailed evaluation of this event was provided in the licensee's report entitled "North Anna Power Station Unit Nos. I t, 2, Mechanical Cleaning of the SWS Piping and Valve Repairs" (Serial No. 85-035), and the Staff SER dated June 11, 1985. | |||
_ 14 - | |||
A case of microbiologically induced corrosion in the SWS piping was | |||
~ | |||
reported by the Carolina Power and Light Company and is decribed in the letter . (RSEP/84-1060) from G. P. Beatty, Jr. of CPSL to J. P. O'Reilly of the NRC. | |||
(Paul Wu) | |||
Interrogatory 46 Identify and produce any studies, reports, or documents produced by NRC or its contractors that discuss potential problems associated with backflushing of the plant as a method for controlling biofouling in nuclear power plants. | |||
P P,esponso Neither the NRC nor its contractors has conducted any studies and prepared any reports or documents that discuss potential problems associated with backflushing of the plant as a method for controlling biofouling. | |||
(Paul Wu, Norman Wagner) | |||
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE,THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) | |||
) Docket Nos. 50-443 OL-01 NIBLIC SERVICE COMPANY OF ) 50-444 OL-01 NEW HAMPSHIRE, et al. | |||
~- | |||
)- On-site' Emergency Planning | |||
) and Safety issues (Seabrcok Station, Units 1 and 2) ) | |||
AFFIDA\,'lT OF NORMAN WAGNER 1, Norman Wagner, being first duly sworn, hereby affirm that the , | |||
responses to the questions set forth herein are correct to the best of my knowkdge and belief: | |||
: 1. That I am employed by the United States Nuclear Regulatory Commission. My present position is Reactor Systems Engineer in the Plant t Systems Branch of the Divisien of Engineering and Systems Technology of the Office of Nuclear Reactor Degulation. . | |||
: 2. That I participatea in the preparation of the NRC Sta ff's responser, to NECNP's secone' set of interrogatories 31(c) and (d), 36, 37, and 43, 44, and 46, | |||
: 3. That such responses are true and correct to the best of my knowledge and belief. | |||
~ | |||
A AfM b N NormanWagner{ | |||
Subscribed to and sworn before me this p25ay of February 1986 | |||
%<i.- Q /s?l{.yne, Ccemisslon expires: July 1, 1990 b | |||
r 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 al. | |||
~- | |||
) On-site Emergency Planning | |||
) and Safety issues (Seabrook Station, Units 1 and 2) ) | |||
AFFIDAVIT OF PAUL C. S. WU I, Paul C. S. Wu, being first duly sworn, hereby affirm that the responses to the questions set forth herein are correct to the best of my knowledge and belief: | |||
: 1. That I am employed by the United States Nuclear Regulatory Commission. My present position is Corrosion Specialist, _ Chemical Enginecring B ranch , Office of Nuclear Reactor Regulation. In this - | |||
capacity I am responsible for technical safety review and evaluation of materials and corrosion in the construction of nuclear power plant components. Specially, my responsibilities include the evaluation of materials application, coolant chemistry inspection and corrosion control. | |||
A statement of my professional qualifications is attached to this affidavit. | |||
: 2. That I participated in the preparation of the NRC Staff's responses to interrogatories 31, 32, 33, and 35-46. | |||
: 3. That such responses are true and correct to the best of my knowledge and belief. | |||
ki, N IA ex Pa uT' C . 5. Wu Subscribed to and sworn before me this/ day of February 1988 | |||
* h -l Y . / b i G O n j Kf Commission expires: July 1, 1910 | |||
e U.S. NUCLEAR REGULATORY COMMISSION DAUL C.S. WU PROFESSIONAL QUALIFICATIONS My present position is Corrosion Specialist, Chemical Engineering Branch, O ffice of Nuclear Rcector Regulation, in this capacity, I am respcnsible for ' technical safety reviews and evalustiens of corrosion prevention and n aterials applications used in the construction and operation of nuclear power plant component s. Specially, my responsibilities include the evaluaticn of materials application, heet t reatrrent , fabrication , inspection , corrosion and coolant chemistry ccntrol. I am a former member of the Artericen Society of Metallurgical Fngineers and a current n ember of the National Association of Corrosion Fngineers , | |||
r I hoic' a U.S. In Metallurgical Engineering ( 1 'A ~) and a Ph.D. In c | |||
fiatorials Science (1972) from the lov.a State University. I have more th6n 20 years of professional experience. I have tr. ore than 40 publications and reports in corrosion control and rr.aterial engineerinn. | |||
I have been with the Neclear Regulatory Commission since March, 1900, one year of which was as a Program Manager in the Office of . | |||
Reactor Safety Resecrch, 5 years in the Office of Nuclear Reactor - | |||
Pegulation, and 2 years as a Reactor inspector in the Office of Inspection and Enforcencnt. Prior to my assignment to Washington, I was employed by the Y'cstinghouse Electric Corporation in Pittsburgh as a Principal Engineer and Project Manager. | |||
r | |||
. 000KETED U5NRC IINITED STATES OF AMERICA 1B FEB 12 P3 50 NUCLEAR REGilLATORY COMMISSION | |||
:0FFICE OF SECREItah1 00CKEllNG A SEiiVid. | |||
BEFORE THE ATOf f!C SAFETY AND LICENSING ROARD1 RANCH c | |||
In the Matter of ) | |||
} Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF ) 50-444 OL-01 NEW HAMPSHIRE, g al. ) On-site Emergency Planning | |||
) and' Safety issues (Seabrook Station, Units 1 and 2 ) | |||
CERTIFICATE OF SERVICE I hereby certify that copies of "NP.C STAFF RESPONSE TO NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S SECOND SET OF INTERROGATORIES AND RECUEST FOP. THE PRODUCTION OF DOCtlMENTS TO THE NRC STAFF ON NECNP CONTENTIONS 1. V . AND IV." above-captioned proceeding have been served on the following by deposit in the United States trall, first class, or as Indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mall system, this 10th day of February 1988. | |||
Sheldon J. Welfe, Esq., Chairman | |||
* Atomic Safety and Licensing Administrative Judge Board | |||
* Atomic Safety and Licensing Board I).S. Nuclear Regulatory Corrmission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. Jerry Harbour | |||
* Docketing and Service Section* | |||
Administrative Judge Office of the Secretary Atorric Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Ccrrrrission Washington, DC 20555 Washington, DC 20555 Dr. Emmeth A. Luebke Thomas G. Dignan, Jr. , Esq. | |||
Adrrir.lstrative Judge Robert K. Cad, Ill, Esq. | |||
5500 Friendship Boulevard Ropes & Gray Apartrrent 1923N 225 Franklin Street Chevy Chase, Maryland 20815 Boston, MA 02110 Atomic Safety and Licensing H. J. Flynn, Esq. | |||
Appeal Panel | |||
* Assistant General Counsel U.S. Nuclear Regulatory Ccmmission Federal Errergency Managert.ent Agency Washington, DC 20555 500 C Street, SW Washington, CC 20472 | |||
/- | |||
2. | |||
'I. Phl!!p Ahren, Esq. Calvin A. Canney | |||
- Assistant Attorney General City Hell Office of the Attorney General 126 DanIe!. Street State House Station Portsmouth, NH 03801 | |||
' Augusta, ME 04333 e ' | |||
Mr. Angle Machiros, Chairman Cerol S. Sneider, Esq. Board of Sefectmen Assistant Attorne;y General - | |||
25 Hloh Road Office of tbc Attorney Cencral* ' ' | |||
Newbury, MA 09150 One Ashburton Place,19th F[oor. | |||
Boston, MA 02103 s : | |||
George Dana Bisbee, Esq. ' ' | |||
Allen Lampert Assistent Attorney General Civil Defense Director Office of the Attorney Generel - | |||
Town of Rrentwood 25 Capitol Street s 20 Franklin C. .coro , NH 03301 , JWeter, NH 03833 Ellyn R. Weiss, Esq. , Willibm Armstrong Diano Curran, Esq. e, ~, Civil Defense Director - | |||
Harmc r. 6 Weiss /. | |||
Town oF Exeter 2001 S Street, th'! 10 FFbnt Street Suite 430 Exeter, NH 03833 Washington, DC 20009 Robert A. Beckus, Esq. Gary W. Ho rnes, Esq. | |||
Backus, Veyer & Solomo. Ho!mes & Ellis . | |||
116 Lowe!'- Street 47 Winnacunnet Road Manchester, NH 03106 - | |||
Hampton, NH 03842 Paul McEachern, Esq. | |||
h.R. Nadeau 7.*atthew T . D rock , Esq . s . Board of Selectmen Shaines & McEtchern , , . - 10 Central Street 25 Maplewcod Avenue i s Rye (NH 03870 " | |||
P.O. Box 300 - > | |||
Portsrrouth, NH 03801 ' . | |||
f' Jedith H. Mizner, Eso. , | |||
Charles P. Graham, Esq. , | |||
Silvergiate, Gertner, Baker, McKay, Murphy & Grahaiac: ' | |||
' Fine & Good - | |||
100 Main Street x . | |||
88 Board Street , ,' | |||
Amtsbury, MA 01913- _ | |||
Roston, MA 02110 Sandra Gavetis, Chairman Robert Carrigg, Chairman Poard of Selectmen Board of Selectmen RFD #1, Dox 1154 - Town Office Kensington, NH 03027 . Atlantic Avenue | |||
[ North Hampton, NH 03870 E eu J | |||
s, * | |||
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*- +w- , | |||
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. I Wilflam S. Lord Peter J. Matthews, Mayor Board of Selectmen City Hall Town Hall - Friend Street Newburyport, MN 09150 Amtsbury, MA 01913 Mrs. Anne E. Goodman, Chairman Michael Santosuosso, Chairman Board of Selet.tmen Board of Selectmen 13-15 Newmarket Road South Hampton, NH 03327 Curham, NH 03024 Hon. Gordon J. Humphrey United Stctes Senate 531 Hart Senate Office Building Washington, DC 20510 C14Rnkhm%%/ | |||
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Latest revision as of 05:53, 13 November 2020
ML20196D368 | |
Person / Time | |
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Site: | Seabrook ![]() |
Issue date: | 02/10/1988 |
From: | NRC |
To: | NEW ENGLAND COALITION ON NUCLEAR POLLUTION |
Shared Package | |
ML20196D346 | List: |
References | |
OL-1, NUDOCS 8802170089 | |
Download: ML20196D368 (20) | |
Text
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j; UNITED STATES OF AMERICA 0 hc NilCLEAR REGULATORY COMMISSION PEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFICE Of SECRt. tan r 00CMETM A stay;cy, in the Matter of ) BRANCH
) Docket Nos. 50-4h3 OL PUBLIC SERVICE COMPANY OF ) 50-4 4n . 0L-01 NEF HAMPSHIRE, et al.
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) On-site Emergency Phanning
) and Safety issues (Seabrook Station, Units 1 end 2) )
NRC STAFF RESPONSE TO NEW ENGLAND COALITION ON NUCLEAR FOLLUTION'S SECOND SET OF INTERROCATORIES AND REQUEST FOR THE PRODUCTION OF DOCUMENTS TO THE NRC STAFF ON NEC.?M CONTENTIONS 1.V. AND,lV.
Interrogatory 1 Picasc identify all persons who participated in the preparation of answers to these interrogatories, and identify the portions of your response to which each persen contributed.
Pgp_onsa See Attached affidavits of Paul C.S. Wu and Norman Wagner.
_ Interrogatory 31 For each cooling system at .the Seabrook plant, please answer the following questions.
(a) What is the Staff's position with respect to the adecuacy of Applicants' program for monitoring and detecting the condificns that will allow microbiologically induced corrosion to occur in these cooling systems
< prior to its occurrence, including techniques for determining the extent of seclin;entation or corrosion?
(b) What is the Staff's position with respect to the adequacy of Applicants' program for monitoring and detecting the presence of microbiologically induced corrosion in these systems after its occurrence, including techniques for determining the type and extent of such corrosion?
0802170089 880210 PDR ADOCK 05000443 0 PDR
3.- , (c) .What is the Staff's position with respect to the adequacy of
, Applicants' program for treating and controlling biofouling . and microbiologically induced corrosion in these systems after it.s occurrence?
(d) Identify and produce all documents prepared by the NP.C or its contractors which assess, evaluate, or discuss the Applicants' programs
. for monitoring, _ detection, treating or controlling biofouling and micro-biologically Induced corresion.
(e) Identify any studies, evaluations, or assessments _urderway or planned by NRC or its contractors relat!ng to the occurrence, monitoring, detection, treatment or control of microbiologically induced corrosion.
( f) Describe the type and extenc of any microbiologically induced corrosion that has been identified or detected in any of these systems.
Response
(a): The Staff does not have a position with respect to the adecuacy of Applicants' prog ram for tronitoring and detecting the conditior.s that will allow microbiologically induced corrosion to occur in these coolitig systems, because Applicants have nyt submitted such a prograrn ' for Staff review. However, bered on the statenent made by Applicants at page 11 of their January 14, 1988 response to N E CN P's second set of interrogatories on NECNP Contention IV dated January 14, 1900, the Staff consiocrs that by applying initial biocidai treatment followed by chlorination and ozonation of the well water influent to the water treatment plant, Applicants have effectively reduced the propensity for microbiologically inouced corrosion. Furthermore, the efluent of the water treatment plant was tirst filtered and dechlorinated , then domineralized and passed thrcugh a UV sterilization unit p rio,' to distribution to various plant systems. These treatments provide adequate assurance that biologically induced corrosion will net occur.
l Additionally, it should be noted that microhlologically induced l
corrosion is a slow degradatien process. 1.aboratory test results and field l
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~ c.xperienceL Indicate that microbiologically- Induced corrosion causes gradual
- corrosion and . pitting. It docs - not cause rupture or sudden failure, .
however. Therefore, the effect of microbiologically induced corrosion of the Seabrook Station steam generator tubes is not Tsignificant from a safety stardpoint.
(Paul Wu)
(b): Applicants have not submitted . a program for monitoring and detectino the presence of microbiologically induced corrosion for Staff review. However, Applicants indicate, at page 9 of their response to NECNP's Lsecond ' set of interrogatories on NECNP Contention IV that a program for preventien of microbiologically Induced corrosion is based on water treatment, monitoring of plant systems by visual Inspection, and .
quarterly bulk water sampling for macro-organisms which are likely to ;
cause degradation of metals or alloys. The, Staff considers this an adequate p rog ram to monitor and to detect microbiologically induced corrosion.
(Paul Wu)
(c): Appilcants have not reported any microbiologically induced corrosion in its cooling system, and the Staff has not received any App!! cant submittals for review regarding treating and controlling microbiologically induced corrosion in its cooling systems. Hewever, based on the statement made by App!! cants on pages 9-11 cf their response to the NECNP's second set of Interrogatories on NECNP Conten-tion IV, the Staff considers thc prograrr to prevent ano to detect micro-biologica!Iy induced corrosion in the cooling systems described theroin Edeq uat e .
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(Paul Wu) 1/ith respect to the adequacy of Applicants' program for treating and controlling biofouling, g A ffidavits of Dr. Michael f.iasnik and horn an Wagrer, attached to NRC Staff Response To Licensing Board Order of Noverrber 27,198f> (January 12, 1988).
(d): There are no documents prepared by the NRC or. its contractors which assess, evaluate, or discuss Applicants' programs for monitoring, aetecting, treating or controlling microbiologically induced corrosion in the cooling systems. See Response to Interrogatory 31(a).
(Paul hu)
The fcilowinc documents are related to the subject of biofouling and are available in the Public Docurrent Roorn:
- 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, NUPEG-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, 9.2-3, 10.4-12, 10.4-13, and Figure 10.4-3a.
- d. NUREG/CR 4626, Vol . 1, improving the Reliability of Open-Cycle Water Systems.
(Norman Wagner)
(c): There currently are no studies, evaluations, or assessments
. underway or planned by NPC or its contractors relating to the occurrence, rionitoring, detection, treatment or control of microbiologically induced corrosion in cooling systems.
(Paul Wu)
(f): The two types of organisms most frecuently involved in r11cro-biologically induced corrosion in cecling systems of nuclear power plants
-S-4' are: (1) the heterotrophic iron and manganese oxidizing organisms such as the Callionella, identified in the Essential Spray Pond Piping System of the Palo Verde Unit 2, which have caused severe pitting corrosion of the stainless steel piping system in welds and heat-affected-zone; and (2) the anaerobic or sulfate reducing bacteria such as the Desulfovibrio Group, iderit'Ged in 'the Service %atu System of the Virginia Power Company's North Anna Plant, which have caused pitfirig and wasteace corrosion of the carbon steel pipino system.
(Paul Wu) interrogatory 32 in NRC spection Report No. 50-403/87-07, at page 16, the inspector diset,' ..d the Applicents' disassembly, cleaning and reassembly of fire prctectico piping inside the fire pump house (part of the Fire Protection System) which contained microbiologically induced corrosion.
Please answer the foliowing questions regarding this incident:
(a) Identify and produce any documents, mernora nda , reports, drawings, or photographs produced by resident inspectors or other NRC staff that in any was discuss, investigate, or evaluate this incic'en t.
(b) Vihat measurcs, if any, could have prevented this problem from occurrinc ?
Response
The Staff cbjects to interrogatory 32 on the grounds that issues relating to the fire protection system are outside the scope of Conten-tion IV, which concerns the adequacy of Applicarts' surveillance and maintenance pregram at Seabrook Station to prevent the accumulation of mollusks, other aquatic organisms, and debris in cooling systems only. A fire protection systeri is not a ecofing system. Therefore, the information sought is not necessary for a proper decision in the proceeding.
(Paul Wu)
b Interrogatory 33 in N PsC Inspection Report No. 50-443/87-23, at page 10, the inspector observed tube degradation in the "B" train PCCW heat exchanger C C-E-17 B . Please answer the following questions regarding this incident:
(a) Identify and produce any documents, reports , drawings, or photographs produced by resident inspectors or other NRC staff that in any way discuss, investigate, or evaluate this incident.
(b) Describe the cause of causes of this deg radation , including whether microbiologically induced corrosion played a role in this degradation?
(c) If you determined that microbiologically induced corrosion did not play a role in this incident, explain how you reached this conclusion.
(d) Describe what measures, if any, could have prevented this degradation from occurring?
Response
(a) All documents, d rawings , and other pertinent information related to the observed tube degradation in the "B" train PCCW heat exchanger C C-E-17 B are referenced in the NRC Inspection Report No. 50-443/87-07 dated November 12, 1987 (Paul Wu)
(b): In their response to Interrogatory 2 of the second set of interrogatories related to NRCNP Contention IV, Applicants indicate that the cause of degradation was determined to be pin hole leaks resulting from a casting defect which degraded with service time. This was determined by considering and eliminating all other possible causes, including microbiologically induced corrosion, for the defect. No tests or examinations were conducted by the Staff or its contractors.
(Paul Wu)
(c): Biological growth is normally present in and around the areas where microbiologically induced corrosion occurs. Since there was no i
i such deposits characteristic of microbiologically induced corrosion observed by Applicants, and, furthermore, the water in the PCCW is sterilized prior to its introduction into the system , therefore, microbiologically induced corrosion could not be the cause of the degradation.
(Paul Wu)
(d): As Applicants indicate, the pin hold leaks were the result of a casting defect which degraded with service time, the Staff considers that a stringent QA program for purchasing and extensive hydrotesting before starting up would prevent any defective component from being placed in service.
(Paul Wu)
Interrogatory 35 Describe what measures the NRC has taken, and plans to take, to assure itself that microbiologically Induced corrosion will be detected, treated and controlled at Seabrook.
Response
The NRC has not taken, and does not plan to take, any measures at the present time to assure itself that microbiologically induced corrosion will be detected, treated and controlled at Seabrook. We consider that the program described by Applicants in its Response No. 2 to the second set of Interrogatories of NECNP Contention IV to be adequate in addressing these concerns.
(Paul Wu) i l
.. Interrogatory 36 Do General Design Criteria 2, 4, 5, 44, 45, and/or 46 require Applicants to monitor cooling systems for the presence of biofoullng or.
microbiologically induced corrosion? If yes, Identify each cooling systems that should be so monitored and state whether it is a closed or open water system.
Response
No, they do not require an app!! cant to monitor cooling systems specifically for the presence of biofouling or microbiologically induced corrosion.
(Paul Wu, Norman Wagner)
Interrogatory 37 Do General Design Criteria 2, 4, 5, 44, 45, and/or 46 require Applicants to monitor cooling systems for the conditions that allow biofouling or microbiologically induced corrosion to occur? If yes, Identify each cooling systems that should be so monitored and state whether it is a closed or open water system.
Response
No, they do not.
(Paul Wu, Norman Wagner) interrogatory 38 (n NUREC/CR-4626, Volume 2, at page 20, it is concluded that flow velocity is the most reflable indicator of conditions that allow micro-biologkally induced corrosion to occur, and that visual inspection is the most effective surveillance technique for determining the type and extent of microbiologically induced corrosion after its occurrence. Do you agree?
If not, provide your reasons.
Res ponse, in NUREG/CR-4626, Vol. 2, at page 20, it is stated that flow velocity is the most reliable indicator of potential biofouling, sedimentation and corrosion within the open-cycle water system. The
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Staff agrees with this statement. In general, sedimentation and biofouling, conditions which tend to cause microbiologically induced corrosion will likely occur in conditions with flow velocities less than
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3 feet per second. NUREG/CR-4626 states on 'the same page that visual observation is the most effective surveillance technique for determining the type and extent of fouling. NECNP incorrectly equates "fouling" as "microbiologically induced corrosion. " Blofouling could lead to microbiologically induced corrosion but it is not the necessary condition.
Sedimentation alone could cause microbiologically induced corrosion to occur. The Staff also disagrees with the NECNP's statement that visual inspection is the most effective surveillance technique for determining the type and extent of microbiologically induced corrosion. in order to determine the type and extent of microbiologically induced corrosion, a combination of biological analysis, microst/uctur'al examination, and visual observation must be performed to provide results for final analysis.
(Paul Wu)
Interrogatory 39 in NUREG/CR-4626, Volume 2, at page 30, it is concluded that high-velocity flushing in combination with continuous chlorination may be an effective way of controlling microbiologically induced corrosion. Do you agree? If not, provide your reasons.
Responso Yes, the Staff agrees with the conclusion that high-velocity flushing in combination with continuous chlorination may be an effective way of controlling biofouling and microbiologically induced corrosion.
(Paul Wu)
Interrogatory 40 Please identify what other ' treatments or combinations of treatments that you believe are as or more effective than high-veolcity flushing combined with continuous chlorination, in controlling microbiologically induced corrosion, including but not ilmited to the treatments described in NUREG/CR-4626, Volume 2, at pages 23 to 30.
Response
As stated at page 23 of NUREG/CR-4626, Volume 2, the following measures are all effective means in controlling biofouling and MIC:
o chlorination to control slime,and bivalves o
the AMERTAP and MAN mechanical tube cleaning systems tube scrapers to clean heat exchanger tubes hand scrapers to remove attached bivalves from the intake structure and intake piping hydroblasting to control slime and remove attached bivalves antifoulant coatings to prevent bivalvo attachment thermal backwashing to kill bivalves o
nonthermal backwashing to flush bivalves and debris from flow constrictions e
oxygen scavengers to kill bivalves screens and strainers to prevent bivalves from entering the open-cycle water system contoured intake structures to eliminate low-flow areas intermediate cooling loops to isolate small heat exchangers from the open-cycle system.
(Paul Wu)
Interrogatory 41 Do you believe thet chlorination is effective in preventing or minimizing microbiologically induced corrosion? If yes, please answer the i following questions:
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(a) Explain the condition 9 under which chlorination is most effective in preventing or minimizing microbiologically indcced corrosion, including the location that chlorine should be injected in each . cooling system, and the frequency and duration of chlorine injections, and concentration (in parts per million) of chlorine at the point of injection, in each cooling system.
(b) At what level must chlorine concentration (in parts per million)-
be maintained to be effective in preventing or minimizing microbiologically induced corrosion?
Response
(a) As indicated on page 23 of NUREG/CR-4626, Volume 2, chlorination is an effective control technique for biofouling. Intermittent chlorination effectively controls slime, but it must be applied continuously at least during bivalve spawning seasons to control bivalves. Since cooling systems are not generic for all nuclear power plants, its design and construction vary from plant to plant. Therefore, the locations of chlorine injection also are not generic for all plants. The specific locations where chlorine was injected at the Seabrook Plant were described at pages 25-26 of Applicants' response to the second set of interrocatories related to the NECNP Contention IV.
(Paul Wu)
(b): As indicated at pages 9-10 of the applicants' responses to the second set of interrogatories related to the NECNP Contention IV, chlorine concentrations of 0.2 to 3 ppm are effective at killing the microbiologically induced corrosion related macro-organisms.
(Paul Wu)
Interrogatory 42 Describe the Staff's position with respect to the effectiveness of thermal backflushing in controlling microbiologically induced corrosion.
Response
The Staff does not have a position with respect to the effectiveness of thermal backflushing in controlling microbiologically induced corrosion.
Applicants have not made any requests related to this sut cet which requires Staff review.
(Paul Wu)
Interrogatory 43 Describe any harm or damage to cooling systems that might occur as a result of thermal backflushing at the Seabrook plant up to four times per year.
Response
Appilcants have not submitted any request on this subject for Staff review, and the Staff has not performed an analysis on any possible harm or damage to cooling systems resulting from thermal backflushing at the Seabrcok plant up to four times per year.
(Paul Wu)
It should be noted, however, that at present there appears to be only one System in which Applicants propose thermal backflushing and that is in the temporary reversal of flow in the intake and discharge tunnels for the circulating water (CW) system (FSAR, page 10.4-13). In this case, Applicants state that this method "is also availdle", i.e., in addition to the injection of sodlum hypochilorite. Therefore, the rate of usage of this method is unknown but, presently, is expected to be low (once every few years) since Applicants intend to rely mainly on Injection of sodium hypochlorite for blofouling control. At any rate, flow reversal
in the tunnels does not appear to affect either the CW system or the
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intake and discharge tunnels, adversely.
(Norman Wagner) interrogatory 44 Describe any harm or damage to cooling systems that might occur as a result of thermal backflushing at the Seabrook plant more than four times per year.
Response _
As noted above, in response to interrogatory 43, the need for thermal backflushing of the intake and discharge tunnels is expected to be low and is not expected to affect, adversely either the CW system or the tunnels.
(Norman Wagner)
Interrogatory 45 Describe any incidents of microbiologically induced corrosion that has been identified or detected in any other nuclear power plants, including the type and extent of such corrosion or sedimentation, the systems in which the microbiologically induced corrosion occurred, and identify any documents related to these incidents.
Responsc On October 2, 1984, and again on December 5, 1984, VEPCO held meetings with the NRC Staff to discuss issues concerning microbiologically induced corrosion in the North Anna service water system piping and valves. The corrosion of the SWS piping is in the form of general wall thinning and wide spread pitting. A detailed evaluation of this event was provided in the licensee's report entitled "North Anna Power Station Unit Nos. I t, 2, Mechanical Cleaning of the SWS Piping and Valve Repairs" (Serial No.85-035), and the Staff SER dated June 11, 1985.
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A case of microbiologically induced corrosion in the SWS piping was
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reported by the Carolina Power and Light Company and is decribed in the letter . (RSEP/84-1060) from G. P. Beatty, Jr. of CPSL to J. P. O'Reilly of the NRC.
(Paul Wu)
Interrogatory 46 Identify and produce any studies, reports, or documents produced by NRC or its contractors that discuss potential problems associated with backflushing of the plant as a method for controlling biofouling in nuclear power plants.
P P,esponso Neither the NRC nor its contractors has conducted any studies and prepared any reports or documents that discuss potential problems associated with backflushing of the plant as a method for controlling biofouling.
(Paul Wu, Norman Wagner)
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE,THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
) Docket Nos. 50-443 OL-01 NIBLIC SERVICE COMPANY OF ) 50-444 OL-01 NEW HAMPSHIRE, et al.
~-
)- On-site' Emergency Planning
) and Safety issues (Seabrcok Station, Units 1 and 2) )
AFFIDA\,'lT OF NORMAN WAGNER 1, Norman Wagner, being first duly sworn, hereby affirm that the ,
responses to the questions set forth herein are correct to the best of my knowkdge and belief:
- 1. That I am employed by the United States Nuclear Regulatory Commission. My present position is Reactor Systems Engineer in the Plant t Systems Branch of the Divisien of Engineering and Systems Technology of the Office of Nuclear Reactor Degulation. .
- 2. That I participatea in the preparation of the NRC Sta ff's responser, to NECNP's secone' set of interrogatories 31(c) and (d), 36, 37, and 43, 44, and 46,
- 3. That such responses are true and correct to the best of my knowledge and belief.
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A AfM b N NormanWagner{
Subscribed to and sworn before me this p25ay of February 1986
%<i.- Q /s?l{.yne, Ccemisslon expires: July 1, 1990 b
r 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 al.
~-
) On-site Emergency Planning
) and Safety issues (Seabrook Station, Units 1 and 2) )
AFFIDAVIT OF PAUL C. S. WU I, Paul C. S. Wu, being first duly sworn, hereby affirm that the responses to the questions set forth herein are correct to the best of my knowledge and belief:
- 1. That I am employed by the United States Nuclear Regulatory Commission. My present position is Corrosion Specialist, _ Chemical Enginecring B ranch , Office of Nuclear Reactor Regulation. In this -
capacity I am responsible for technical safety review and evaluation of materials and corrosion in the construction of nuclear power plant components. Specially, my responsibilities include the evaluation of materials application, coolant chemistry inspection and corrosion control.
A statement of my professional qualifications is attached to this affidavit.
- 2. That I participated in the preparation of the NRC Staff's responses to interrogatories 31, 32, 33, and 35-46.
- 3. That such responses are true and correct to the best of my knowledge and belief.
ki, N IA ex Pa uT' C . 5. Wu Subscribed to and sworn before me this/ day of February 1988
- h -l Y . / b i G O n j Kf Commission expires: July 1, 1910
e U.S. NUCLEAR REGULATORY COMMISSION DAUL C.S. WU PROFESSIONAL QUALIFICATIONS My present position is Corrosion Specialist, Chemical Engineering Branch, O ffice of Nuclear Rcector Regulation, in this capacity, I am respcnsible for ' technical safety reviews and evalustiens of corrosion prevention and n aterials applications used in the construction and operation of nuclear power plant component s. Specially, my responsibilities include the evaluaticn of materials application, heet t reatrrent , fabrication , inspection , corrosion and coolant chemistry ccntrol. I am a former member of the Artericen Society of Metallurgical Fngineers and a current n ember of the National Association of Corrosion Fngineers ,
r I hoic' a U.S. In Metallurgical Engineering ( 1 'A ~) and a Ph.D. In c
fiatorials Science (1972) from the lov.a State University. I have more th6n 20 years of professional experience. I have tr. ore than 40 publications and reports in corrosion control and rr.aterial engineerinn.
I have been with the Neclear Regulatory Commission since March, 1900, one year of which was as a Program Manager in the Office of .
Reactor Safety Resecrch, 5 years in the Office of Nuclear Reactor -
Pegulation, and 2 years as a Reactor inspector in the Office of Inspection and Enforcencnt. Prior to my assignment to Washington, I was employed by the Y'cstinghouse Electric Corporation in Pittsburgh as a Principal Engineer and Project Manager.
r
. 000KETED U5NRC IINITED STATES OF AMERICA 1B FEB 12 P3 50 NUCLEAR REGilLATORY COMMISSION
- 0FFICE OF SECREItah1 00CKEllNG A SEiiVid.
BEFORE THE ATOf f!C SAFETY AND LICENSING ROARD1 RANCH c
In the Matter of )
} Docket Nos. 50-443 OL-01 PUBLIC SERVICE COMPANY OF ) 50-444 OL-01 NEW HAMPSHIRE, g al. ) On-site Emergency Planning
) and' Safety issues (Seabrook Station, Units 1 and 2 )
CERTIFICATE OF SERVICE I hereby certify that copies of "NP.C STAFF RESPONSE TO NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S SECOND SET OF INTERROGATORIES AND RECUEST FOP. THE PRODUCTION OF DOCtlMENTS TO THE NRC STAFF ON NECNP CONTENTIONS 1. V . AND IV." above-captioned proceeding have been served on the following by deposit in the United States trall, first class, or as Indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mall system, this 10th day of February 1988.
Sheldon J. Welfe, Esq., Chairman
- Atomic Safety and Licensing Administrative Judge Board
- Atomic Safety and Licensing Board I).S. Nuclear Regulatory Corrmission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. Jerry Harbour
- Docketing and Service Section*
Administrative Judge Office of the Secretary Atorric Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Ccrrrrission Washington, DC 20555 Washington, DC 20555 Dr. Emmeth A. Luebke Thomas G. Dignan, Jr. , Esq.
Adrrir.lstrative Judge Robert K. Cad, Ill, Esq.
5500 Friendship Boulevard Ropes & Gray Apartrrent 1923N 225 Franklin Street Chevy Chase, Maryland 20815 Boston, MA 02110 Atomic Safety and Licensing H. J. Flynn, Esq.
Appeal Panel
- Assistant General Counsel U.S. Nuclear Regulatory Ccmmission Federal Errergency Managert.ent Agency Washington, DC 20555 500 C Street, SW Washington, CC 20472
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2.
'I. Phl!!p Ahren, Esq. Calvin A. Canney
- Assistant Attorney General City Hell Office of the Attorney General 126 DanIe!. Street State House Station Portsmouth, NH 03801
' Augusta, ME 04333 e '
Mr. Angle Machiros, Chairman Cerol S. Sneider, Esq. Board of Sefectmen Assistant Attorne;y General -
25 Hloh Road Office of tbc Attorney Cencral* ' '
Newbury, MA 09150 One Ashburton Place,19th F[oor.
Boston, MA 02103 s :
George Dana Bisbee, Esq. ' '
Allen Lampert Assistent Attorney General Civil Defense Director Office of the Attorney Generel -
Town of Rrentwood 25 Capitol Street s 20 Franklin C. .coro , NH 03301 , JWeter, NH 03833 Ellyn R. Weiss, Esq. , Willibm Armstrong Diano Curran, Esq. e, ~, Civil Defense Director -
Harmc r. 6 Weiss /.
Town oF Exeter 2001 S Street, th'! 10 FFbnt Street Suite 430 Exeter, NH 03833 Washington, DC 20009 Robert A. Beckus, Esq. Gary W. Ho rnes, Esq.
Backus, Veyer & Solomo. Ho!mes & Ellis .
116 Lowe!'- Street 47 Winnacunnet Road Manchester, NH 03106 -
Hampton, NH 03842 Paul McEachern, Esq.
h.R. Nadeau 7.*atthew T . D rock , Esq . s . Board of Selectmen Shaines & McEtchern , , . - 10 Central Street 25 Maplewcod Avenue i s Rye (NH 03870 "
P.O. Box 300 - >
Portsrrouth, NH 03801 ' .
f' Jedith H. Mizner, Eso. ,
Charles P. Graham, Esq. ,
Silvergiate, Gertner, Baker, McKay, Murphy & Grahaiac: '
' Fine & Good -
100 Main Street x .
88 Board Street , ,'
Amtsbury, MA 01913- _
Roston, MA 02110 Sandra Gavetis, Chairman Robert Carrigg, Chairman Poard of Selectmen Board of Selectmen RFD #1, Dox 1154 - Town Office Kensington, NH 03027 . Atlantic Avenue
[ North Hampton, NH 03870 E eu J
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. I Wilflam S. Lord Peter J. Matthews, Mayor Board of Selectmen City Hall Town Hall - Friend Street Newburyport, MN 09150 Amtsbury, MA 01913 Mrs. Anne E. Goodman, Chairman Michael Santosuosso, Chairman Board of Selet.tmen Board of Selectmen 13-15 Newmarket Road South Hampton, NH 03327 Curham, NH 03024 Hon. Gordon J. Humphrey United Stctes Senate 531 Hart Senate Office Building Washington, DC 20510 C14Rnkhm%%/
TirepEcry /ft ;n Be frv Counsel for l NRCdStaff L
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