ML20084H533

Proposed Findings of Fact on Contentions V-3a & V-3b Re Effects on safety-related Structures on Postulated Ruptures in Arco Petroleum & Columbia Gas Pipelines That Run Near Site.Certificate of Svc Encl

ML20084H533
Person / Time
Site:	Limerick
Issue date:	05/02/1984
From:	Ferkin Z PENNSYLVANIA, COMMONWEALTH OF
To:
References
OL, NUDOCS 8405080091
Download: ML20084H533 (13)

Text

DY -

).

UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMMISSION DE'OllE Tile ATOMIC SAFETY AND LICENSING BOAllD hfg[UI l

In the Matter of ) NAY-7 pg Docket 0 PHILADELPHIA ELECTHIC COMPANY )

) Nos.S0-393 50-352d"' =~_ 5 G.~- 1 (Limerick Generating Station, )  : .h { ' i - l Unit 1 and 2) )

COMMONWEALTH OF PENNSYLV ANIA'S Pit 0 POSED FINDINGS OF FACT ON CONTENTIONS V-3a AND V-3b In accordance with 10 C.F.R. 62 754, the Commonwealth of Pennsylvania hereby files propoced findings of fact on issues in which it participated concerning Contentions V-3a and V-3b.

Introduction Contentions V-3a and V-3b concern the effects on safety-related structures of postulated ruptures in the ARCO petroleum and Columbia Gas pipelines that run near the Limerick Generating Station site.

Contention V-3a states :

In developing its analysis of the worst case rupture of the ARCO pipeline, the Applicant provided no basis for excluding consideration s,iphoning. Thus, the consequences from the case pipeline accident'are understated.

hD b !OO o

O!o000!2 eon p 4

l

- 'E contention V-3b reads: -

l In duscussing deflagration of gas and p

petroleum due to pipeline rupture, no specific f consideration has been given to the effect of radiant heat upon the diesel generators and

.f associated diesel fuel storage facilities, Testimony was filed by the Applicant, the NRC staff and Friends of the Earth ( F0E) . Testimony concerned the structure and operation of the pipelines, the impacts upon the safety-related structures of postulated breaks in the h

pipelines, and the structural integrity of safety-related _

structures to withstand postulated overpressures from a detenation following a pipeline break.

In accordance with its status as an interested 3

governmental participant, the Commonwealth participated through cross-examination in hearings held December 12-16, j l

1983 and January 9-10, 1984. The Commonwealth did not participate in all hearings ~' held o'n"these contentions. The Commonwealth's purpose in participation has not been to advocate a position with regard to these contentions; J l

rather, its role is to aid in the development of a record. 1 i

Consequently, the Commonwealth's proposed findings are limited to matters in which it participated, and are profferred for the limited purpose of aiding the Board in evaluating the record. j i

.)

1 1

i

l I

1. The AHC0 pipeline runs approximately 49 miles from the l Boot Pumping Station to the Fullertol Terminal, traversing 1

Chester and Montgomery Counties, Pennsylvania. It was laid  :]

l in 1955 and is the only ARCO. pipeline in the vicinity of the 1 i

Limerick facility. Christman, ff. Tr. 5093, at 2; Tr. 5099, ,

t 5205 (Christman).

2. The ARCO Pipeline has a capacity of 31,700 barrels / day and operates at a maximum pumping pressure of 1,100 psig. .

I Christman, ff. Tr. 5093, at 3; Tr. 5152 (Christman). Normal J

i operating pressures for gasoline are 650 to 875 psig, and 950 to 1000 psig for diesel and furnace oil. Ibid.

J 3 The present tariffs on file with the Pennsylvania i

Public Utilities Comthission authorize ARCO to transport J gasoline, kerosene, jet engine fuel, and light and medium fuel oil. The tariffs have not been revised since 1978, and a

no new products have been carried since then. Christman, {

ff. Tr. 5093; Tr. 5120-22 (Christman).

4. ARCO Pipeline and Philadelphia Electric Company have entered into an agreement whereby ARCO has agreed not to transport propane through the line. The pumping units and terminal facilities would have to be modified in order for O

g O b

the pipeline to carry propane. Christman, ff. Tr. 5093, at 4; Tr. 5109, 5218, 5219 ( Christman); udyer, fr. Tr. 5412, Attachment.

5. The ARCO pipeline has no defined design life. The line is coated with coal tar to protect against corrosion.

Corrosion is also controlled through " impressed current cathodic protection." Hydrostatic testi'ng is not performed on the pipeline. Christman, ff. Tr. 5093, at 3; Tr. 5154, 5204-06 (Christman).

6. The Boot Pumping Station is the only pumping station on this AHC0 pipeline segment. Boot Station activities are remotely, controlled from ARCO's Point Breeze Pumping Station in Philadelphia and Control Center in Independence, Kansas.

A single sensor at the Boot Station detects changes in pressure on the pipeline. Should pressure drop below 365 psig , the sensor would automatically shut off the pumpage.

Christman, ff. Tr. 5093, at 5, 6 ; Tr . 5151, 5 234-35 (Christman).

7 There is no back-up sensor for the single sensor at Boot Station. Tr. 5196 ( Christman) .

8. Point Breeze and Independence Station, also monitor pipeline flow activity' . These stations are manned and are 1 l

independent of the sensury equipment aL Dvot. Christman, ,

. f f. Tr. 5093, at 6; Tr. 5196-99 ( Christman) . Should tho l sensor at Boot Station fail to operate, monitoring equipment at Point Breeze or Incependence would detect pressure Tr. 5198-99, 5241 (Christman).

changes. f 9 Leaks on the AllCO pipeline are detectec primarily through remote monitoring capability at Point Breeze and Independence, Kansas Stations. Another, secondary method of leak detection is weekly aerial inspections of dead vegetation, or saturation of canes, along the pipeline.

This method is not reliable when the ground is snow-covered.

Leakage may also be detected durins right-of-way maintenance activities -- e.g., brush cleaning. Brush cleaning takes place every five years, or as needed. Chris tman , f f. Tr .

5093, at 5; Tr. 5192-95, 5230 (Christman).

10. Monitoring equipment is inspected on an undefined periodic basis. Tr. 5219-5200 (Christman).

11. Upon noting a sudden radical pressure change, monitoring personnel would consider whether to shut down Boot Pumping Station. Such action would be taken on observation of a large change, e .g . , 100 psig, although equipment at Point Breeze and Independence can observe pressure changes as low as one psig. Christman, fr. Tr.

5093, at 6, 7; Tr. 5220-21 (Christman).

I

12. Isolation of known or suspected leaks is effected following pumpage shutdown by work crews dispatched from the AHC0 Montello Dist ric t Office. Isolation of the pipeline is .

effected at both the Boot and Fullerton ends of the'line.

Tr. 5241-42, S251 (Christman). There are 10 valves on the g c

Boot to Fullerton line. The nearest valve below Limerick is 3,000 feet south of the Limerick station; the nearest value downstream is 7 9 miles away, these valves are manually g E

o pe r a ted .- The valves at both Boot and Fullerton Stations E are remotely controlled; thus the segment may be isolated by j d

remote control. Christman, ff. Tr. 5093, at 7; Tr. 5202, j 2

5254 (Christman). 5 h

+

b 13 Columbia Gas Transmission Pipelines 1278 and 10110 run generally southwest to northeast through Montgomery County, E Pennsylvania. Pipeline 1278 was constructed in 1949, is 14 g inches in diameter and operates at a normal pumping pressure Il F

of 750 psig. Pipeline 10110 was constructed in 1965, is 20 g 5

inches in diameter and operates at a normal pumping pressure 5 5

of 1100 psig. The pipelines run parallel, 20-30 feet apart, 3 5

and share a common right-of-way. Brown, f f. Tr . 5 261, at 4; 5 Tr. 5321 (Brown). E b

5 5

14. The Columbia pipelines carry only methane in a gaseous $

0 state. Tr. 5318, 5325, 5327 (Brown). @

.E d

5 d

j Z

15. The Eagle and Easton Compressor-Stations are the compressors nearest the Limerick Station. The Eagle Station is 9 7 miles south or the Schulkyill niver; Easton Station )

is 44.4 miles to the north. Bro wn , ff. Tr. 5261, a't 4; Tr .

5308 (Brown). The Eagle Station is manned on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis. The Easton Stution is manned S days a week, 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> a day. Brown, ff. Tr. 5261, at 4 ; Tr. 5284 ( Brown) . Line 10110 ends at Hellertown Station, and does not extend to Easton Station. Tr . 5309 ( Brown) . Hellertown is a measuring , not a compressor station . Tr . 5308 ( Brown) .

16. The pipelines are protected against corrosion by im9ressed current cathodic protection. The pipelines do not undergo periodic pressure testing; however, there is no industry-wide standard requiring such testing. Brown, ff.

. Tr . 5261, at 4 ; Tr. 5311 ( Brown) .

17 Leakage is detected by monthly air patrols which look for dead vegetation in the right-of-way. Air patrols cannot observe the vegetation when the ground is snow-covered.

Brown, ff. Tr. 5261, at 5; Tr. 5304 ( Brown) . Annual foot patrols, semi-monthly inspections, and hydrogen. flame ionization are also employed to detect leaks. Brown, rf.

Tr. 5261, at 5.

.. l

18. The Columbia pipelines are depreciated over a 50-year period. Thus 50 years can be estimated as the pipelines'

" design life." See Tr. 5311 ( Bro wn) .

19 Pressures on these pipelines are electronically monitored by Columbia's Control Center in Bethel Park, Pennsylvania. If pressures fall below 425 psi on line 1278, or 770 psi on line 10110, alarms a're triggered at Bethel Park and at Eagle Station. Urown, ff. Tr . 5 261, at .

5.

20. The pressure sensory devices and alarm system are inspected every six months. Tr. 5306 ( Brown) .

21. Easton Station is not staffed on a continuous basis.

In periods where it is not staffed, pressure drop sensory, inflamation is transmitted to the Bethel Park Control Center via clectronic tranoducers, where pressures-are then-1 analyzed. Easton Station is capable only of sensing and transmitting information on line 1278, as line 10110 stops at Hellertown. See Tr. 5304, 5305, 5309 (Brown) .

i

22. When alarm set points activate indicating pressures on tne pipelines nave dropped below normal operating range ,

oporators either at Eagle or Easton Stations or the Bethel 4

Park Center can turn off the compressor units and close the-i A

rn'

l isolation valves, shuttting down the flow of gas in to the pipeline. Christman, fr. Tr. 5261, at 5-6; Tr. 5288, 5307-08, 5323, SJ37 ( urown) .

23 The valves at Eagle and Easton Stations can be either manually or remotely controlled. Tr . 5 308, 5 339-40 ( Brown)

Between Eagle and Easton there are six manual valves on line l

1278, and 3 manual valves on line 10110. Tr. 5339-40 (Drown). The valves closest to Limerick and those at tile i d

a compressor stations wcald be closed should a pipeline leak 1 occur near Limerick. Tr. 5330-31 (Brown). .

]

l

24. In the event of a leak resulting in a drop in pressure on eithe'r line 1278 or line'10110, Columbia Gas does not have the clearly established capability of shutting down the 1

pipeline absent operator intervention either at the compressor stations, Hellertown, or at the Bethel Park 5 Control Center. See Tr . 5288, 5301-02, 5318-19, 5320-21, d 5

(Brown). 5 0

t i

p 9-il fJ i.

il t

E ei'

25. The Applicant has not established that a breach of either the'A!!CO or Columbia Gas pipelines will not occur.

Tr . 5656 ( Board) . -

Ilespectfully submitted ,

Zori G. Ferkin 3

Assistant Counsel 4

Commonwealth of Pennsylvania Governor's Energy Council 1625 North Front Street .

t P.O. Box 8010  !

liarrisburg, PA 17105 i

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD U{f{TED In the Matter of ) 04 MY-7 P2:24

. )

PHILADELPHIA ELECTHIC COMPANY ) Docket Nos. 5.2F st 5 j 5g(g;,

5 EM (Limerick Generating Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Commonwealth of Pennsylvania's Proposed Findings of Fact on Contentions V-3a and V-3b" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class , or , as indicated by an asterisk through deposit in the Commonwealth of Pennsylvania's internal mall system, or, as indicated by a double asterisk by deposit in the United States Postal Service express mail, this 2nd day of May 1984:

0* Lawrence Brenner (2) Docketing and Service Section Administrative Judge Office of the Secretary Atumic Safety and Licensin6

~

U. S. Nuclear Hegulatory Board Commission U. S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555

1. 1. Richard F. Colo ** Mark J. Wetterhahn, Esq.

Administrative Judge Conner and Wetterhahn Atomic Safety and Licensing 17 47 Pennsylvania Avenue , N.W.

Board Washington, D.C. 20006 U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Board Panel U. S. Nuclear Hegulatory Commission Washington, D.C. 20555 OOPeter A. Morris ## Ann P. Hodgdon, Esq.

Administrative Judge Benjamin H. Vogler, Esq.

Atomic Safety and Licensing Counsel for'NRC Staff U. S. Nuclear Hegulatory Office of the Executive Ledal '

Commission Director Washington, D.C. 20555 U.S. Nuclear Hegulatory Commission Washington, D.C. 20555

l l Atomic Safety and Licensing Philadelphia Electric Company -

Appeal Panel ATTN: Edward G . Bauer , Jr .

U. S. Nuclear Regulatory Vice President &

l Commission General Counsel Washington, D.C.

20555 2301 Market Street Philadelphia, Pa. 19101 Frank H. Romano # David Wersan , Esq.

61 Forest Avenue Assistant Consumer Advocate Ambler, Pa. 19002 Office of Consumer Advocate 1425 Strawberry Square t

Harrisbur.g, Pa. 17120 Robert L. Anthony Steven P. Hershey, Esq.

Friends of the Earth of Community Legal Services, Inc.

the Delaware Valley Law Center West P. O. Box 186 5219 Chestnut. Street 103 Vernon Lane Philadelphia, Pa. 19139 Moylan, Pa. 19065 Marvin I. Lewis Angus Love, Esq.

6504 Bradfor.d Terrace 101 East Main Street Philadelphia, Pa. 19107 Norristown, Pa. 19104 Joseph H. White, III Phyllis Zitzer 15 Ardmore Avenue Limerick Ecology Action Ardmore, Pa. 19003 P. O. Box 761 Pottstown, Pa. 19464 Charles W. Elliott, Esq. Sugarman, Denworth & Hellegers Brose and Postwistilo 16th Floor Center Plaza 1101 Building 101 North Broad Street 11th & Northampton Sts. Philadelphia, Pa. 19107 Easton, Pa. 18042 Jacqueline I. Ruttenberg # Director, Pennsylvania Keystone Alliance Emergency Management Agency 3700 Chestnut Street B-151, Transportation and Philadelphia, Pa. 19104 Safety Building Harrisburg, Pa. 17120 I

i j

t l

. l

. 4

' Thomas G'erusky, Director Martha W. Bush, Esq.

Bureau of Radiation Kathryn S. Lewis, Esq.

Protection City of Philadelphia Department of Environmental Municipal Services Bldg.

Resources 15th and JFK Blvd.

5th Floor, Fulton Bank Bldg. Philadelphia, Pa. 1910'/

Third and Locust Streets Harrisburg, Pa. 17120 Spence W. Perry, Esq.

Associate General Counsel Federal Emergency Management Jay M. Gutierrez, Esq. Agency U. S. Nuclear Regulatory 500 C Street, S.W., Rm. 840 Commission Washington, D.C. 20472 Region I ,

631 Park Avenue Gregory Minor King of Prussia, Pa. 19406 MHB Technical Associates 1723 Hamilton Avenue San Jose, CA 95125 Timothy H. S. Campbell Director Department of Emergency Services 14 East Biddle Street West Chester, Pa. 19380 gW v ori G. Ferkin ssistant Counsel Governor's Energy Council Date:

( kh