ML20087M473

Request for Reconsideration of Air & Water Pollution Patrol Asbestos Contention

ML20087M473
Person / Time
Site:	Limerick
Issue date:	03/19/1984
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8403290378
Download: ML20087M473 (2)

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DENIED AIR and WATER- For the Lu%mg Scard t - -

W .l Pollution Pga,tra,n.,2

- . BROAD AXE,' .PA. M, !t[jp)gf gg Atomic Safety and licensing. Board W . 0~. u ,t E 27 E U.S. Nuclear Regulatory-Commission 2 Washington, D.C. 10555 ~h' [3[' "

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

Judge Lawrence Brenner -Chairmant.Dr.' Pet er Morris & Dr. Richard Cola REQUEST FOR RE-CONSIDERATION OF AWPP'S ASBESTOS CONTENTION As a. result: of tNe 'Marcht 15,.1984 hearing before the Board in which the AWPP (Romano) contention relating to asbestos was dis-cussed, and'af. decision made without. sufficient information attes-ted to, AWPP moves that the. Board re-consider. AWPP moves that this be done orr the basis that while the EPA has not, as yet, call-ed asbestos. fibers in drinking water hazardous,- as per American Water Works Associatiorr. Mainstream ~r Vol 27, No 11, November 1983:.

"The U.S Environemtal Protection Agency will propose a bart on..the manufacture of asbestos-cement pipe, according to Edward A. Klein, art 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 tima public input will be sought. on. theoscientific_ basis for. the rula and ort the -

. regulatory procedures irt the rule. The next step irr US EPA'ss development of a regulation is consideration of the comments and publicatiort of a final. rule "

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

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Further, at'the March 15 meeting, the Applicant was not re-quired to.provf6 information on. the ammount of asbestos-cement used in the Drit. . Eliminators. incits 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 8403290378 840319 gDRADOCK 05000352 .g3 PDR u_

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

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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 inter the air, which the EPA does designate as hazardous.140-CFR.20=to .25 discusses asbestos relating to removal.to avoid.contacte&.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.

IR Q WATER OLLUTION PATROL rank R. R$mano, Chairman 61 Forest Ave.

FRR/fch Ambler e Pa. 19002.

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