ML20087J476

Request for Reconsideration of Asbestos Contention.Board Did Not Adequately Address Hazard to Public

ML20087J476
Person / Time
Site:	Limerick
Issue date:	03/19/1984
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	Brenner L, Cole R, Morris P Atomic Safety and Licensing Board Panel
Shared Package
ML20087J469	List: ML20087J465 ML20087J476 ML20087J486
References
NUDOCS 8403220229
Download: ML20087J476 (2)

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AIR and WATEl% gyp W Pollution Patrol l

BROAD AXE, PA'84 MR 2BaW0c519, 1984 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission M^""Nyj '-g~' I Washington, D.C. 10555 "jaaleg '

In The Matter Of PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 (Limerick Generating station and 50-353 Units 1 and 2)

Judge Lawrence Brenner, Chairman; Dr. Peter Morris & Dr. Richard Cole REQUEST FOR RE-CONSIDERATION OF AWPP'S ASBESTOS CONTENTION As a result of the March 15, 1984 hearing before the Board in which the AWPP (Romano) contention relating to asbestos was dis-cussed, and a decision made without sufficient information attes-ted to, AWPP moves that the Board re-consider. AWPP moves that this be done on the basis that while the EPA has not, as yet, call-ed asbestos fibers in drinking water hazardous, as per American Water Works Association Mainstream , Vol 27, No ll, November 1983:

"The U.S. Environemtal Protection Agency will propose a ban on the manufacture of asbestos-cement pipe, according to Edward A. Klein, an agency official in-volved in the control of toxic substances.

The ban is not imminent but could come within the next few years. The USEPA expects to publish its pro-posed rule prohibiting the use of asbestos in a number of construction projects, including asbestos-cement (A-C) pipe, next July. At that time public input will be.

sought on the scientific basis for the rule and on the regulatory procedures in the rule. The next step in US EPA's development of a regulation is consideration of

the comments and publication of a final rule."

l It's purpose is to eliminate the injestion of asbestos fib-ers "ia municipal drinking water systems using asbestos pipe.

! Further, at the March 15 meeting, the Applicant was not re-quired to provide information on the ammount of asbestos-cement used in the Drift Eliminators in its cooling towers at Limerick, even though Mr. Boyer was present, and could have been asked to supply the information.

The question of how much asbestos could be present in water discharged into the Schuylkill, therefore, could not be used in 8403220229 840319 PDR ADOCK 05000352 O PDR

l AIR and WATER l W Pollution Patrol BROAD AXE, PA.

(2)

Request for re-consideration of Asbestos contention continued:

in the Board's decision not to permit the asbestos contention.

Further, while AWPP' discussed the possible dissemination of asbestos fibers from the tower into the air, which the EPA does designate as hazardous. (40-CFR.20 to .25 discusses asbestos relating to removal to avoid contact,& as it relates to airborn asbestos see the National Emissions Standards for Hazardous Air Pollutants, under Section 112 of the Clean Air Act) . Therefore, the Board did not adequately address this known point involving a hazzard to the public.

Respectfully submitted.

AIR & WATER POLLUTION PATROL

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