ML20070H389

Response to ASLB 821122 Order Re Friends of the Earth Proposed Contentions on Hazards from Industrial Activities & Motion to Reconsider Admission of Contentions 1,2,6,8 & 9

ML20070H389
Person / Time
Site:	Limerick
Issue date:	12/19/1982
From:	Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8212230356
Download: ML20070H389 (3)

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,U.S. Nuclocr Ecgulstory Commission Atomic Sofoty and Liccnsing Bomrd Decembsr 19,1982 Washington, D.C. 20555 Docket # 50-352 & 353 Re: Philadelphia Electric Go. Limerick Generating Station, Units 1 & 2 COLKETEC RESPONSE OF R.L. AN'IHONY AND F.O.E. IN THE DEIAWARE VAft!EY TO THE BOARD'S ORDER OF NOV.22,1982 "CONCERNING PROPOSED F0E CONTENTIONS ON HAZARDS FROM INDUSTRIAL ACTIVITIES " and MOTION TO Hg.p0 g gRgg We acknowledge the admission by the Board of Contentions _V-Ja and V-3b and ask respectfully that the Board reconsider forladmTiklont the f ollowing contentions, numbered in accordance with F0E's subtitsion of 7/7/82:

Contention 1. According to the Board, missiles from railroad explosions cre considered "albeit briefly" in FSAR. We say the evaluation is too brief to adequately assess the dangers to plant operation. FSAR states that only safety related buildings will be hardened. There is no protection for the220 KV switchyard, only 130 feet from the railroad nor two 220 K7 lines,one crossing over the tracks the other along the R.R. right of way, -

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nor a 66 KV line parallel to the tracks,nor a 220 KV tie line between switch-yar&;nor a 500 KV line .which crosses the trachs to the substation, south of the plant. (Fig.8.2-1, Rev.10/82 ) The impact of missiles on the switch-yard and these exposed high voltage lines could drop live wires, flaming metal and firebaIk onto tank cars, setting off a succession of fires and explosions. We are convinced of severe threats to safe plant operation from the hazards of missile damage to switchyards and these high voltage lines We ask the Board to reconsider and admit this contention.

Contention 2. The Board denied this contention as to workers in the control room but left the hazards to other plant workers unresolved. FSAR -

Ne assesses no dangers from toxic' fumes produced by chemical and synthetics

$$$ fires. This is a very serious cmission as will ..be seen from the facts 4" 3d3 we cite from an article by Robert Schaeffer in F0E's "Not Man Apart",Nov.'82, i gg entitled "Where There's Smoke". We quote Schaeffer: " Until recently,most  !

o people were unaware of the danger _ posed by toxic gases.

A few like San g

o Francisco ped Fire Battalion his firemen Frank Dunphy realized the danger.." and equip- {

Chief apparatuses.

with treathing 8 "A recent fire in the computer room of a San Francisco office building de-Schaeffer qu i o composed some "of this material,and ' a nickle's worth of fire put four people dg in the hospital' . We believe that poison fumes from fire in the Limerick accontrol room computer and wiring has not been evaluated and must be. .

We think that provision must be made to protect the safe performance  !

of all the plant workers from toxic fumes produced by chemical and synthet- I ics fires from accidents at the Hooker Chemical plant and on th 9 railroad.  :

We are sure that the Board is not unmindful of the fact 2that the TMI acci- E ddnt was precipitated by a maintenance crew. We ask that this contention be admitted to Schaeffer assure safe plant operation by provisions against toxic firefumes. 5h warns, " Of the 8,000 people who die annually in U.S. fires ,80% i die from inhaling the smoke. . . . .In the MGM fire (Grand Hotel,Las Vegas),only ' 5 16 of We askthe the84Board victims burned to death.

to reconsider Thethis and admit rest..from inhaling poisonous smoke " E contention.

g Contention 6. Schaeffer's research on toxic gasses from synthetics M fires is directly applicable to the threats to Limerick from accidents at Hooker Chemical.  ?

Schaeffer cites some of the toxic gases as Hydrogen [

cynanide, hydrogen cloride, hydrogen sulfide and phosgene; " Breathing caustic 5 gases .cause(s) bloody ulcers in moist lungs... edema,where the lungs fill E with fluid,a kind of monsoon-swift pneumonia.."Tearing eyes become acid ponds, E the cornea etched like an engraver's plate. 2 FSAR, (table 2.2-6) does not list hydrogen chloride or phosgene at all 1 nor does it evaluate these and hydrogen. cyanide and hydrogen sulfide as prod- 'E ucts of fire,only as released through storage or transportation accidents.pgo3

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Tcff~c~ gases from fire on the railroad of supplies for,or products from, Hooker Chemical,next to the Limerick plant pose serious danger to all plant personnel. We ask that the Board reconsider this contention and admit it.

Contention 8. We wish to call the Board's attention again to the Omissialfrom FSAR (sect.2.2 3 1.4) of consideration of toxic fumes from chemical and synthetics fires. FSAR sums up thus (p. 2.2-8, rev 3/82):

" Potential adverse effects of such fires (burning tank car,etc.) are radi-ant heat load on plant structures and smoke generation. . . . . . . . Assuming 19,600 Btu per pound of propane and 62 tons being consumed in 20 minutes

...... smoke effects of such a fire would be negli^gible." This is not trues applied to railroad fires and at Hooker,which would include not only propane but plastic materials and products. Schaeffer, cited above, quotes Gordon Vickery former head of the U.S. Fire Admin. thus, "The science of combustion technology is only seven or eight years old." We believe, however, that what has been learned in this science must be incorporated

i in FSAR and we ask that this content' cn be admitted to offset this omission. _

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i Contention 9. We believe that the Board missed the-essential point of this contention as shown in its statement:"Further.no basis is set forth or apparent to us for believing that the effect of such quarry explosions,.

either expected or accidental,would be greater than the potential explosion of the ARCO pipeline." It is not a matter of" greater effect" or "either or".

The Quarry is north and west of the plant and an emplosion thenecould rup-ture rail cars releasing propane , petroleum, synthetics and other chemicals causing fire and explosions within 100 feet of plant buildings. Such an accident could happen independently from or simultaneously with a pipeline rupture. The effects of both must be evaluated and no value attached to  :

which accident would have a greater effect. Their effects could be cumh-lative and put strain on different parts of the plant,the railroad explosion '

on the west and north,the pipeline on the south and east. We believe that an explosion at the quarry could set off a chain reaction along the tracks and must be evaluated in addition to,ard supplementing the potentials set forth in Contention 1. We ask the Board to reconsider and admit Cont.# 9.

Respectfully submitte for R.,L.Apthony and FOE, L>/' Art"tcn-t CC. Judges Brenner, Cole, Morris NHC Sec. ,Lic. Appeal, Staff, ACHS ,T.Connbr,E.Bauer and Limerick Lic. service lisb,.

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,.' <asualty' rate ftom fire is five ti es that of , . dards, says," Synthetics haie a heat content

,  ! tuasn't a Very big fire. The revelers iit voorn .go.s of the Westchase European countries." .

., . two and three times higher than cellulme, JIL lfilton irt ilouston escaped the llarnes. Tuveh e occripants of rooms 0 nhe s, w people who aie annually in :y: cotton, wood; are gene, rally easier to ignite; US h(res,80 percent die from mhahpg the O . and produce a more compter, r j

. On the hall would also escape the flarnes, but not the sonoke.

smoLc. ne twut rash of hotel fires-n ' gases. -

m, the Stouffer*> Inn near _New Yotk City, * "Because synthetic materials burn twice w here z6 thed; htGM Grand flosel in I.as

.. as fast and twice as hot as neural mater-

." Across the hall, Ron.ikl, Cecile, Ron Jr., fireathing caustic gases is -rather like , , Vegas, where 84 thed; and the Westthase : ials," Gordon Vic kery warns. "this amount

, and Jonathan pabst huddled on the door snorting Drano. %cy cause bloody ulcers ; lidron in f louston, where t : died-alcricti . of new plastic is equal to Iwo pails of gaso-

. at the foot of the bed to get below the in moist lungs and mucous membranes.' t , many tothedangerof smoke from fires. In . ' '. hne." Afost homes now omtain 3oo to $oo 7 - smoke seeping into their room. In 4 : t, the., .. hey pnxiuee edema, where the lungs fill O the MGM fire, only s6 of the 84 vittims pounds of plastic.. ; ; . ,. . . i. .-

, i' ' , . Espanol family, five members of bree gen- ;with flmd, a kind of monsoon-swift pneu.M:'. burned to, death.He rest died from inhal-

. - Conventional rnaterials : wood and na.

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• erations, did the same. Boih famihes died ' monia. Tearing eyes become acid pondsp. ~ ing poisonous staoke.: .4 r. ". rural. fiber-also produce toxic gases.

together, their lungs ulcerated by toxic. ,- the cornea etthed hke an engraver's plate.- , A complex rnixturetoblesdly'.imoke 7 Carbon monoxide is a primary product of fumes, their eyes etthed by the hydrot bloric Ben there ate the after-effects. Phmgene was produced by decomposing plastic fur-p.V{ eombustion from,the 1 acid that formed when hydrogen chloride , ;can. remain latent for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. nishings in hotel rooms.uc average hotelf6 bon monoxide is, not caustici it'doesn't f.; - f gas mixed with their tears. ~

, damage eyes or lungs on contact Symhe-

In 4

z, Edith Anderson, 75, wedged .

tically produced gases are much more I f soaked linen in the door and tried to break -

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'%..c.s i . 't ~ toxic. liydrogen cytanide, for instance, is

! I open the windo v in her suite with the rable' lamp. She broke the lamp but not the scaled

- }{ (3kCS VCry h.t( lC pl3S(]C'm'a TOOm 10 kill. . . '

3o times more poisonous than carbon

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window. she was resened unconscious by

- firemen and survised. lier younger sister,

.mOSt ho'mescontain>3oo-Soopoundsof plastic. *

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Mrs. Drakert, was rescued from 4 5and -It,s.a gas, gas, gas b .

treated at Rosewood flospital. Here she Symptoms'of gas attack-shortness of room is furnished with products containingi r,; . m.

3 made a recovery. But three days after the breath, coughing, nausea, vomiting, head._ zo pounds of polyvinyl chloride (PVC, a ' ' Untilc,rei;ently,,most people .wcre un-fire she became ill. Two' months later she ' aches-.-can recus up to six weeks later, j standard ingredient of most synthetics)!q '"aivare of the<1 anger posed by toxic gases.

p C ' -' ' died. ~ '

? and victims,like Mrs. Drakert, can su ffer a r and other synthetic materials. Yves Alarie,i A few,like San Francisco Fire Department 5 .. ' relapse. , -;....,. professor of Public ifcalth at the Univer- ' Battalion Chief Frank Dunphy, realized

) f Escaping hotel guests might have caught' ' In all, twc!ve people died, most of them sity of Pittsburgh, warns, "It takes veryi... the danger back in t956.On December 3 ,

y .whiffsof bitter almonds, vinegar, rotten . behind closed doors. ney died from the,. . little P lastic to killin a small room." Scien- the Land Brothers factory, which manu-

.? ..;? eggs,orperhaps the scentof freshly mown  : fire. but did not perish in the flames. ne;[ trists at the,Univenity of Pittsburgh have ' factured Ping Pong balls, burned down.

f, 4 hay as they ran for the stairs. Gases from. fir + vas contained in 4o4.ne leputy fire : Wfound that five ounces of burning PVC "Over i So pcople went to the hospital as a

'. . hydrogen cynanide, hydrogen ibloride. chiu on the scene said that the firefighting , ' emits enough hydrogen cloride gas te ;11 t result of the Ping Pong ball fire," Dunphy p . ., hydrogen sulfide, and phosgene would- itself was t* fairly. straightforward." , .,k , al,1 the. people in an,ayerage size bedr ,m,.V. recalls,"After that we started using breath.

P f ' Produce these smells. lires that consume . m ten mmutes. ,, .l- ~,F s ing apparatuses." .

n w. , . : Towering Infernos,,. s..g.g ,

c.p - 3 Ilouses, like hotels, q,.a,.4 i .contam increasing f. a.But science has been sloh to k '.,Ql. G nylon famishings made of drapes, carpets, mattresses, synthetic foamplastics-

- 4.. m, flousehold IIcIls .c. . J.t quantities of plastic material., Americans ..;Most people .still assume that carbon

• c, beddings, simulated wood paneling and ,, . 6.. .. ... . W,2, ,; g.  ; are adding between io and a5 pounds of,, . monoxide is to blam.: for most fire.related fp'.. ';,. curtains, TV cabinets, and wall bathroom coverings-produce fi.xtures- and shower, ' ' .,.*' Americansd don't gise; a . damn ..ibou;L. plastic t to ,theirdeaths.This homes each' is because coroners, who rou-year Merrit; g.:'.

fire," Gordon Vickery, former hea' of the y Birken h' cad of Combustion 7tpduct Tech; M tinely examinefire fatalities, test 991 the.

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, US Fire Administration, complains. "Ourk;nologyjat thc}Tational Bureau of Stan ' , levelofcarbcinmonoxideinthebloo[Dr.

[;.tj Wthese - p .gases.

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