ML20072E567

Answer to First Set of Interrogatories.Related Correspondence

ML20072E567
Person / Time
Site:	Limerick
Issue date:	06/20/1983
From:	Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH
To:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 8306270038
Download: ML20072E567 (2)

Text

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" U.S.M Nuclsar Regulatory Commi$iIn "*"

g sd 2 V Rn Phile Elco. Co.

Limerick Generating Sta. Docket Nos. 50-3 & M3

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• F6E and R.L. AnthonyJ s Answer to Applicant's ?irst Set of Interrogat . .s sw.

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Interrog.1.. We intend to present expert witnesses under Contentions V-3a and T-3b. We intend to call pipe line operators and supervisors who oill testify on the frequency of ruptures,the record of valve operation and ,

the extent of syphoning under conditions of rivercrossings and geography equiv 4 clent to that at Limerick. We will callexperts on diesel and petroleum tank fires with figures on heat generation, metal stress, explosions, conduction,and radiation.

Int. 2. The gathering of documents is in process and these will be made available to the Applicant when the process is completed, be Int. 3 Our answers are and willgbased on all the published or unpublish-sd material. that is available and we irill specify the items from each docu-cent. It appears that we will have to do research which evidently was skipped over by PEco when the selection of the Limerick site was made a n d the risks involved ffom pipelines in the vicinity were overlooked. Our research will have to be continued. One of the items we have covered at this point is the extent of remote control valves on the pipelines and the use of manually operated valves at the river crossings.'Some operating experience has been offered to us by a retired supervisor whom we expect to use as an expert witness.

Int. 4 Our research is still in progress. ~ The titles, studies, details, s,nd persons involved will be provided. This research is all directed to cover the subjects specified in Int. # 1.

Int. 5 These personal consultations are still being carried out and vill be specified as soon as they have been completed.

Int. 6. We were informed during informal discovery that the applicant had nothing on file connected with syphoningphich lef t us to conclude that PEco had no basis for coniuding thatsyphoning would not occur. We are not aware of any NRC regulations or criteria that cover pipeline rupture and siph-ontng.

Int. 7 The Limerick F3AR has no consideration of siphoning in case of a pipeline rupture because the Applicant made the unsupported assumption that siphoning could not occur. The Applicant,therefore, fail.ed to provide protect-ion for the plant and its safe operation in the event of a pipeline rupture,

g explosion, and fire fed by siphoning, and failed tococply with NRC safety reg-g ulations thereby.

l M Int. 8. Siphoning is simply the vacuu= effect of a difference of height g in a pipe filled with liquid. In this inste.nce the vakkey where the 1imerick t plant is located is the low point in the pipeline north and south. A rupture n at the low point next the plant would cause a flow from both directions pulling i uHD liquid over high points from lower,as long as the rupture is at a lower elevation.  !

g Int. 9. The Applicant will be notified when the details of the " worst case Pipeline accident" have been completed. It appears to us that the assumptions

$$ and estimates in FSAR seriously underplay the hazards. Our studies up to this point indicate overpressure and heat generation of at least twice the propor-tions assumed in FSAR.

We assume the detonation wod1d occur at the corner of the 500 KY switchyard.

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F0E and R.L. Anthony's Answer to Applicant (cont.) ,

2.

Int. 10. Our stcdy in41 cates no significant aspect of the terrain in-volved that would inhibit the major impacts of heat and explosion on the Plant sita and the structures exposed.

Int. 11. We do not think that it is the function of a citizen intervenor to site all the regulations and design criteria. We simply 4 tate that the FSAR co6 sideration of the hazards to the plant from deflagration and radiant heat'from a pipeline rupture is inadequate and seriously underestimates the risk.

We shall present figures to substantiate this.

Int. 12. As ie have stated above,the FSAR does not include an adequate evaluation or estimate of. the hazards and ,therefore,does not satisfy the regulatory requirements. We expect that our evaluation when it is completed will demonstrate in detail these deficiencies.

Int. 13 Onr. present estimate is that the heat load on the diesel gene- .

rator areaof the plant from the worst case accident to the ARCO pipeline would be at least sevetilatimes the intensity estimated in FSAR. When we have com-pleted our resear6h with experts in this field (see Int. 1.), we will make available the figures which show the inadequacies of the FSAR.

INT. 14 Similarly, when we have completed our contacte with experts in diesel fuel storage and diesel operation we will be in a position to share with the Applicant more adequate detail on heat loading on structures and diesel operation than the superficial findings recorded inFSAR.

Int. 15 This is covered in Int. 14 Analyses and computations will be supplied where indicated. As stated in Int.10 (shove), we see no significant diminishing impa ct from terrais en the hazard to exposed plant structures, equip-ment and processes.

June,20, 1983 Copies to: Judges L.Brenner,Dr.R.F Cole,Dr.P.A. Morris, Ann P.Hodgdon.T.B.

Conar.E.G.Bauer, A.S.&L Board Panel,NRC Docketting, T.Y. AU ,M.W. Bush,M Lewis ,

J. I. Ruttenberg, F . Romano , J .H. Whit e , R. Su garman .

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