ML20070A206

Answer Supporting NRC 821112 Motion for Summary Disposition of Issue 7.Util Provided for Early Warning of Asiatic Clam Establishment in Area.Plant Monitoring Sys Will Detect Any Clam Infestation

ML20070A206
Person / Time
Site:	Perry
Issue date:	12/07/1982
From:	Silberg J CLEVELAND ELECTRIC ILLUMINATING CO.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20070A209	List: ML20070A206 ML20070A224 ML20070A242
References
NUDOCS 8212090196
Download: ML20070A206 (4)

Text

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'82 EC -8 P1 :49 December 7, 1982 c rtn 0F SECfS/F' c zitas & dt"VICE O R ANCLI UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

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THE CLEVELAND ELECTRIC ) -

ILLUMINATING COMPANY, ET AE. ) Docket Nos. 50-440

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50-441 (Perry Nuclear Power Plant, )

Units 1 and 2) )

APPLICANTS' ANSWER IN SUPPORT OF NRC STAFF MOTION FOR

SUMMARY

DISPOSITION OF ISSUE NO. 7 on November 12, 1982, the NRC Staff (" Staff") filed a Motion for Summary Disposition of Issue No. 7, which concerns the possibility of Asiatic clams, Corbicula fluminea, fouling Applicants' safety-related cooling systems. The Staff's motion and accompanying affidavit state that: there is a low prob-ability of Corbicula becoming established at or near Perry Nuclear Power Plant ("PNPP"); Applicants have provided for early warning if Corbicula were to become established in the area; Applicants' plant monitoring system will detect any Corbicula that infest PNPP; and Applicants have committed to developing a program to control Corbicula should Corbicula be detected in or near the plant.

82120901 % 821207 PDRADOCK05000g i

O 4 Applicants support the Staff's motion for summary disposi-tion of Issue No. 7. As further discussed in the Affidavit of Richard S. Nugent in Support of Staff's Motion for Summary Disposition of Issue No. 7, attached hereto, Lake Erie in the vicinity of PNPP does not provide a habitat conducive to the existence of Corbicula. The occurrence of Corbicula in the lake is presently limited to the relatively large thermal plumes from three coal-fired electric power plants in the western basin. Because Lake Erie is beyond the northern extreme of its natural habitat, Corbicula can cnly survive in such artificially heated environments. The PNPP thermal plume is unlikely to be large enough to sustain Corbicula.

Dr. Nugent also describes the comprehensive lake moni-toring program conducted by NUS for Applicants. This program will detect the presence of Corbicula in the vicinity of PNPP should populations of the clam become established. The sampling program includes Cleveland Electric's Eastlake Power Plant, which is a coal-fired plant similar to those in the western basin of Lake Erie where Corbicula have been found.

Since Eastlake would be the most likely source of any clams to become established at PNPP, Corbicula would likely be disco-vered there before they could infest PNPP.

The attached Affidavit of Richard A. Pender and Ronald L.

Scherman in Support of Staff's Motion for Summary Disposition of Issue No. 7 ("Pender/Scherman Affidavit") discusses in detail Applicants' plant monitoring program for detecting any

O 6 Corbicula that might infest PNPP's safety-related cooling systems. Applicants will conduct monthly surveillance testing of the Emergency Service Water System ("ESWS"), the only safety-related cooling system using raw water at PNPP. This surveillance testing will discover any flow reductions due to biofouling. Applicants will also inspect the ESWS for Corbicula when it is opened for maintenance. Other potential l

collection points for Corbicula will be inspected by maintenance personnel on a routine basis. Both the flow monitoring and maintenance inspection programs will insure that Corbicula will be quickly discovered should they infest PNPP.

Finally, the Pender/Scherman Affidavit discusses Applicants' commitment to develop a method of Corbicula control if the clams are discovered either at Eastlake or at PNPP itself. Although Applicants do not rule out other methods of i

Corbicula control, thermal shock is a completely effective, environmentally insignificant and relatively inexpensive means of eliminating Corbicula which can be easily implemented at PNPP. Hot water sufficient to cause 100 per cent mortality of all clams in the system would be pumped into the ESWS. The temperature would be monitored for the length of time necessary

, to kill the clams. The system would then be drained down so that all clam debris which might block the system could be removed.

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e n In conclusion, there is no genuine issue of material fact to be heard with respect to the fouling of safety-related cooling systems by Corbicula. The Staff's Motion for Summary Disposition of Issue No. 7 should be granted.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE 0

By:

J AbE

/ b Silberg, P.C T/

Couns 1 for Applicants 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Dated: December 7, 1982

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