ML20095C025

New Info Contention Re Health Hazard Via Polyvinyl Chloride Fill Used in Reactor Cooling Towers.W/Svc List

ML20095C025
Person / Time
Site:	Limerick
Issue date:	08/16/1984
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	Atomic Safety and Licensing Board Panel
References
OL, NUDOCS 8408220354
Download: ML20095C025 (4)

Text

\%% ' .

I i.

AIR and WATER Pollution Patrol BROAD AXE, PA. Aug. 16, 1984 U.S. Nuclear Regulatory Commission gg ,7. . .

Washington, D.C. 20555 esf.;f .

E4 AG020 m; BEFORE THE ATOMIC SAFETY AND LICENSING BOARD  ?' r.-

5 C;.Y. . ',, - : . . : .

' ~ ;~.' J a :k 5'. ..

.1.' ' ] g In The Matter Of PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 0,

(Limerick Generating Station and 50-353 U L'-

Units 1 and 2)

Attached please find" AIR AND WATER POLLUTION PATROL (ROMANO)

ENTERS NEW INFORMATION CONTENTION RE HEALTH HAZZARD VIA POLY-VINYL CHLORIDE " FILL" USED IN THE LIMERICK REACTOR COOLING TOWERS".

VERY,TRULY YOURS, AIR & WATER POLLUTION PATROL

/.A v ,e . e Frank R. Romano, Chairman I certify the above hai been served by first class mail on the latest Service List as follows:

Lawrence Brenner. Esq., Chairman; Dr. Richard Cole; Dr. Peter Morris; Troy B. Conner, Jr. Esq; Atomic Safety and Licensing Board; Docketing and Service Section; Ann P. Hodgdon, Esq; and Atomic Safety and Licensing Appeal Board Panel. Without attachemnts:

Limerick Ecology Action; Edward G. Buaer, Jr.; Marvin Lewis; Joseph H; White III; Martha N. Bush, Esq.; Thomas Gerusky; Director PEMA; Robert L. Anthony; Anejus R. Love, Esq.; Charles W. Elliott:

David Wersan; Jay GutierrcC; Steven P. Hershey, Esq.; Zori Ferkin, Esq.; Spence W. Perry, Esq.; Robert J. Sugarman, Esq.; Jame.s Wiggins; Gregory Minor; and Timothy R.D. Campbell.

8408220354 840816 PDR ADOCK 05000352 gh G /

PDR

..e

. AIR and WATER Pollution Patrol BROAD AXE, PA. ^ 9' '

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Of l 7,.,

n:,q s BEFORE THE ATOMIC SAFETY AND LICENSING BGBRD In The Matter Of 20 L_

PHILADELPHIA ELECTRIC COMPANY DocketQ, os., 50-35 Ig (Limerick Generating Station " and.~50-353 Units 1 and 2) )[jf'y'~le ,

. . !b .7 AIR AND WATER POLLUTION PATROL (ROMANO)

ENTERS NEW INFORMATION CONTENTION RE EEALTH HAZZARD VIA POLYVINYL CHLORIDE " FILL" USED IN THE LIMERICK REACTOR COOLING TOWERS On February 15, 1984 a new information contention was filed in which Air and Water Pollution Patrol (Romano) contended that asbestos cement splash bars to be used inside the Limerick cool-ing towers would,due to heat and violent action of hot air and water,cause the splash bars to shed and discharge asbestos fib-ers into the air for miles, and into the Schuylkill River used for drinking in Montgomery County and Philadelphia.

Applicant and Staff objected to the admission of AWPP's contention mainly, first, on the basis that asbestos splash bars were replaced by polyvinyl chloride as per FSAR, page 9.5-17, and page 3.4-3 of EROL. And, secondly, that EPA had no regula-tion on asbestos in dri-nking water. EPA does have regulations on asbestos fibers in air as can come from asbestos cement drift eliminators in the cooling towers. However, AWPP's filing relat-ing to discharge of asbestos fibers into the air has thus far been ignored.

I move at this time that the Board responds to the air-borne asbestos aspect.

Now AWPP contends that neither the Staff nor Applicant con-sidered the health effect of the contamination of air and water via fragmenting and volatilization of p61yvinyl chloride and its plasticizers and stabilizers that will emanate from the polyvinyl fill now in the Limerick Cooling Towers.

Re timeliness criterion, this contention is late filed due

4 AIR and WATER Pollution Patrol BROAD AXE, PA.

(2)

AWPP New Information Contention re Polyvinyl Chlcride contd:

to the fact'that I recently read of adverse health effects caused by p61yvinly chloride and its plasticizers and stabil-izers. Therefore, the substitution of tons and tons of polyvinyl chloride plastic fill for hazzardous asbestos splash bars require immediate attention.

Polyvinyl chloride and its plasticizers (phthalic anhydride) and stabilizers (organotins) readily enter the air and aqueous solutions, and have been known to cause " shock' lung". This con-dition sometimes causing death was found to be caused by trans-fusion of blood stored in polyvinyl containers substituted for glass. Further, studies on chick embryoes and rats show death caused by plasticizer and stabilizer leached from polyvinyl con-tainers and polyvinyl hoses, into the culture medium. Phthalic anhydride and derivations used as plasticizers in polyvinyl chlo-ride have been shown by test to cause congenital malformations through work done at Baylor University in Texas.

Further, I plan to contact as a prospective witness, Mr.

Robert De,Haan. who as early as 1970 recognized health problems associated with plasticizers used in polyvinyl chloride plastics.

Another prospective witness would be Dr. R. J. Rubin of Johns Hop-kins Hospital who found metabolic breakdown products of PVC in I

blood, urine and tissues of patients receiving blood that had been stored in PVC bags.

It is obvious ,therefore, that polyvinyl chloride (PVC) will readily leach into aqueous solutions and air. The tons of PVC

! " fill" in the cooling towers, (aided by hot water and hot air action) will release large amounts of breakdown products of PVC, plasticizers, and its stabilizers into the air over Montgomery County, and into the Schuylkill River.

Re second criterion, I, as a Biochemist, see no other means l

l l

. AIR and WATER Pollution Patrol BROAD AXE, PA.

s . (3)

AWPP New Information Contention re Polyvinyl Chloride continued:

or party protecting AWPP's interest, since the Air and Water Pollution Patrol involves itself specifically with chemical, and biochemical environmental interests to which we now are alerted as described herein.

Re third criterion, AWPP's participation will assist in de-veloping a sound record by injecting this issue of significant health effects not heretofor adequately considered by Applicant or Staff. Therefore, this contention must be considered now with the idea of preventing health effects caused by the enviro-mentally and health affecting polyvinyl chloride present in the reactor towers. 4th: no one to any extent represents AWPP's interest.

Respectfully submitted, AIR & WATER ,P,OLLUTION PATROL hFrank A .4(L.

R. Romano, Chairman 61 Forest Ave.

Ambler, Pa. 19002 FRR/jch l

l 1

1 r