ML20099G455

Requests Appeal of ASLB 841023 Second Partial Initial Decision LBP-84-31 on Contentions V-3a & V-3b Re Danger from Fuel & Gas Pipelines at Facilities.Aslab Should Reverse ASLB Decision & Grant Requested Relief

ML20099G455
Person / Time
Site:	Limerick
Issue date:	11/23/1984
From:	Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH
To:
Shared Package
ML20099G457	List: ML20099G455 ML20099G458
References
CON-#484-304 LBP-84-31, OL, NUDOCS 8411270301
Download: ML20099G455 (5)

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- U.S. SUCLEAR REGULATORY CO21ISSION... ATOMIC Silm & LICOSIHG APPEAL BOARD RE

PHILA.ELEC.CO. Limerick Gen. Sta. Unita 1 & 2'. Docket # 50- 352,355 O C  !

E MNTHONY/F0E.33.IEF.IN.

SECOND PARTIAL INITIAL DECISION, SUPPORT LBP-84-31, ON OF APPEAL VTO CONTENTIONS APPEAL 3a an(  %. BOAR CUTLINE OF SITUATION. NOV g LB's rulings on our contentions constitute a failure of NRC throu[A2:55 its staff efforts and the judicial process of its licensing ka'r-Qtogpr_ojegt the health and safety. of the public. . LB also demonstrated a di$cdpAEing.

of citizen, pro se, participation and expertise while favoring Applicant and Staff testimony. .

Had it not been for our efforts, the danger from fuel and gas pipelines plant at the Lime' rick3 ,ould not have been considered in the licensing process, con-trary to NRC regulations. Pipelines were never ar. issue in the construc-tion permit hearings and it was at that time that the site should have been dis-qualified.or requirements of re-location enforced. (ExhibitA I , appears that PECo Nf*N'essumtichNir obligation to protect the plant and the public from outside erplosions was complete when they estimated the results of a possible railway accident sud explosion. Because of our research and vigilance they were compelled to study possible explosions caused from ARCO and Columbia Gas pipeline accidents. In a perverse and tragic way.however, PEco and NRC used thgielin hegings tgr uforce their positions. The single positive step taken by PEco,,to losasa the risk,was the agreement negotiated with ARCO to refrain from transporting propane. This uns used,however, against the public safety as a barrier to taking the only effectice step, relocating the ARCO line'.

The only credible conclusion from LB action ou our contentions and os identical outcoces for the other contentions' cffNN*iOhe LB[ decision is that LB interprets its function as focused on; th c A4 p rt of its title.

It appears detsrmined to license at all cost { and to lubort' th's applicant no matter 'what that does for the safety and vital interdst of the public. We understand that the Appeal Board has a view 6f its function that includes a vision of protecting the public. In respect to our contentions, there was ample evidence included in 16 days of hearing *E3 toNEEvYa* r[sE*[o"the p1*auY from the pipelines. The exact scenario for an accident that would da age m the plant did not have to be selected, nor the minimum or maximum overpressures that could be created. LB's function should have been -to estabitsh that ac-cidental releases from the pipelines could cause explosions which could im-pact the plant. It was the duty of LB to eliminate this risk. It should have ordered the relocation of the pipelines. We trust that AB' will make that order. l To this end we show how the LB process was flawed,and prejaticed against the l public's interest. 8411270301 841123 PDR ADOCK 05000352 O

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. P.10'IEOTIO3 G/ PLINT AND PJ3LIC Frt0.* E71.::AL E4FLOSIO.:S.

Withcut 10thtny/F0E rossarch cod participction in the licocaics pr:ccco there would have been no consideration of the dangers from pipeline explosions.

Our filing caused PECO and the Staff to become aware of these lines. PEco's investigation was carried out by a meterologist named John Walsh. He had no credentials and tra ining to qualify him to advise PEco os pipelines. We stated this to the LB in our 11/1/03 response to PEco's motion for summary disposition.

(See r 'page.5 ) Before the hearings and during them a part of Mr.Walsh's testimony was discredited . In spite of this LB referred to his testimony as the basis for their decision in LPB-84-31 more than a dozen times. We think LB showed a slant toward his testimony and that of the the Staff which almost excluded the evidence which came out through crose xamination during the hear-ings. Mr. Walsh was poven wrong about the following:

The amount of fuel from as ARCO break.

The automatic He asserted it shut-o(((gquipment would work would sw thout any expett wCthout knowledge fail.

or having seen it.

The amoukt of fuel from au 1RCO break would be 8 to 10 times his estimate.

The pumps would keep pumping af ter a break for two or more hours.

The pipeline from Limerick north would drain out of a break at Limerick .

This means more than 7 miles of fuel draining from the ARCO pipe.

There would be syphoning .

Mr.Walsh contradicted his written testimony that he had seen both pipelines.

hearing It was our information before the and through testimony and cross examination which caused Mr.Walsh and the Staff to amend their estimates of the amount of fuel available from an ARCO break,and to accept the possibility of an explosive mixture from a Columbia break moving toward the plant and be-ing detonated. In the following sections we will ohow how PEco's and the Staff's positiono were modified by our information and how little attention LB paid to these modification in their decision,thereby compromisirg the judicial pro-cess and the safety of the public. .

ANALYSIS OF LB CONSIDERATION OF EVID3NCE ON CONTENTIONS V 3a and 3b.

LBP-84-31 Par. B-3 It should be noted that we wore able to go beyond the syphoning Ussue and radiant heat. If we had not pursued these contentions LB might not have questioned whether the safety related buildings were designed to withstand external explosions.

B-5 R.L. Anthony's study of the site and pipelinen provided reliable informa-tion used by the other witnooses and LB. He ohould have been permitted to teatify.

B-6. LB did not give consideration to " consequences of worst case accidents."

It accepted PECo and Staff figures.

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B-7 LB rulcd co tha cd quncy of tho structuroc oithcut ollecitg cry it- f 1

quiry into whether they had been built according to design. Ex.A , 8A and 78A.

We disagree with EB that our contentions "have no merit". Even if the struct-ures can withstand the worse case pipeline explosions,which we doubt, i LB has the responsibility to prevent the risk to plant and public from allowing the possibility of external explosions by requiring relocation of the lines.

To reinforce our responses we refer to portions of our " Rebuttal of Applicant's Reply Findings" dated 6/6/84, included as Exhibit

• A.

B-10 Mr.Christman testified that ARCO pumps could fail to shut dom in a line break .(Se Ex..Ar111.) .

B-11Walsh testified about ARCO pipeline operation,but was discreditied ber ause he has no expertise in pipeline operation . LB correctly does not exclude syphoning and accepts our assumption of the ARCO pumps continuing after a break.

B-19 LB accepts our scenario of break on the hillside and the possible spraying of as area up to 65,000 sq.f t. ~

B-20 The Staff accepts our hillside spray scenario and arrived at a com-bined evaporation area in stream and on hillside of 24,800 sq.ft.

B-21 LB points out the disagreement between Walsh's and Staff's TNT .

equivalent, 5,252 pounds for the former,1,856 for the latter. LB makes the assumption," Applicant initially used a conversion factor for TNT equiva-leet that was four times too great" There is nothing in the record to support this conclusion. Both conversion factors were used in the testimony and there was no conclusion that one was more right than the other. To carry out LB's worst ocee# principle the higher factor would have to be used,and,indeed,it was used in Tab. II,p.76C, columns 3 and 4 area B-22. LB ignored the worst case basis of a streambed and hillside evaporation for an ARCO break and based its conclusions on Walsh's discreditted streambed release and the Staff's dista cen of 960 feet,while PEco used 550 feet as worst case. The record shown that auth PECO using a larger evaporation area and the Staff using PEco's conversion factor both calculated higher overpressures than the 3 0 psi recorded here for PEco and 2.1 psi for the Staff.

Under cross examination Walsh calculated from the vapor of 21,000 gallons, j (Tr. 5482) instead of the 4,962 gallons which produced the 3 0 pai. LB chose to ignore this Walsh calculation which produced more than 4 x 3 0 psi. Similar-ly LB. ignored the Steff's calculations on 24,000 sq.f t.,using PEco's conversion factor, *t288. The Staff was asked to calculate on larger sprayed areas,7291, l . 7300,7264 and 7276. At 7506 the Staff calculated an.. over pressure of 24. psi.

LB takes no account of this worse case,nor does it show up in the Steff's Table I, p. 76D.

l B-23 LB ignores Hasbrouck's narimum 28. psi, calculated f rom larger spray areas

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(Hasbr:uck tcoti../ 1 pi3) l to o similar man:Or to tho St ff.

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- To fairly cycluato tho ccrat caco,LB crred 10 ign:rica thoso calculaticco b : d ca 1crg:r cprayed cr00s. Furth r evidence on the justification for larger areas comes at 6104, 6106,6119, 7158, ,

7243, and 7274 3-24 LB apparently misunderstood our concept of a greatly enlarged pooling area in Possom Hollow Run in the wide, marshy area upstream from the rail-way embankment. A PEco road parallel to the railway emba/kment could pro-vide a dam. Evaporation would be not in the Schugill valley but in the lower part of Possum Hollow Rua directly opposite , south wall of the reactor building. Dr.Campe testified that such a damming could contatu 500,000 cu.ft.,

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7541. He said that all the fuel flowing down the Run could be dammed for three hours without flowing into the Schuylkill 7524-7558. This ch*=ger completely PECo' and the Staff's concept that the capacity of Possom Hollow Run was limited to the steep, narrow section abobe the plant,and that all ex-cess# Youid l

flow immediately to the Schuylkill . ( See Ex.'., A 9-A and 281 )

This possible scenario should not have been discarded by LE since it makes possible the collecting of the flammable mass from hillside release and flow into the Run at a location in the open directly in front of the re-actor building with the possibility of a much larger flammable mass than in any other scenario.

B-25 In assessing worst case conditions, LB drred in mot evaluating the whole

, range of scenarios and values. It chose to class y 2.k pai as "concervative,"

also even disregarding PEco's, conservative 3. pai. It is apparent that LB was not really interested in establishing the worst case or it would have weighed the other possible values, including 24. psi calculated by the Staff, TR. 7506 B-31. Diffusion would 'ee impeded under inversion conditions. Ex. ". A 601 B-33. LB should have evaluated our scenario of both ends of break pointed toward the plant causing a " fire hose effect and momentum. Ex.A . 601.

B-36 Walah's 10 pai was discredited by 16. psi Tab II, submitted by PEco. In a worst case LB cannot ignore our scenario for an ignition trigger from gas confined at plant level.

B- 39 LB cannot" rive no weight" to any travel scenario for the flammable mass since all scenarios are hypothetical and LB must evaluate " worst case".

B-40 Nowhere in the record is Reg. Guide 191, Rev.1 proven to be the " correct valu e '. In fact all who testified, including PEco's attorney, admitted not being able to understand it. ThN"Ouide factor was discredited PEco's*x 10',never.

legitimatelv PEco used ,it3 1 Tafi.II columns 3 and 4,without challenge from LB.

Por a worst case LB had to consider closer approaches to the plant; for ex-ample 800 feet, offered by Hasbrouck. Ex.A 60A .

B-50 Some of PEco's c'alculated " margins" are not marries at all,as little as 3 pC, Tab.I.

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B-53 LB ign:r:0 Colsh's ARCO 3. psi O 500 fcot c:d others,up to staff'o 24.pai.

B.-54 Aisin LB sur:est meg.cuide 191 is " correct" cith ut cry juotificatica.

LB ignores columns 3 and 4 Tab. II, overpressure of 16. psi.

B-55 LB must accept the possibility of ignition sparkedby a confined mpas.(& 3-56 3-57 Not so. Scenarios for ARCO must be considered up to Staff's 24. psi.

B-58. Again LB leaves out Tab.IIcolumns 3 and 4 B-59 . No so.( See B-57 above.)

B-60. We question whether " critical element" is valid in this eatimation.

We assert the only valid test would be derived from testing the weakest points in the walls and roofs in their "as built" condition.

B-64 This is not an adequate worst case margin, 27% for midspan.

B-66.There is no record of what Staff found when they checked PEco's calculations.

B- 67 The study was not complete without evaluation of thresholds of failure.

B-67 Again LB without any justification asserts " proper TNT conversion! In Tab. I some cargins are inadequete,as little as 3 3 %, roof reactor b1dg. 2. -

B- 68 LB is in error in comparing earthquake loading with that from explosions since the latter operates through the ground the latter through the air.

B-70. There is no evidence that dead weight was calculated as additive to blant pressure on the roofs.

B- 71, 72, 73 In evaluating worst cese conditions LB should not have ignored vibratory load, temperature differentials,nad hydrostatio forces, differential settlement (B-74.)

E-75 and 76. Fromits responsibility for public safety LB must condider the failure of the louvre and roof openings since any such passage from the in-terior of the containmengging would allow radioactive contamination outdoors.

The reference to a small. increase inside the building obscures the real hazard to the public, radioactive contamination of the outside air.

B-79 to 05. LB in wrong to discios the dangers to the plant"3IhoE"Ibe overturning of cooling towers and transminnion torers and breaching of basins.

There was no conclusive evidence to rule out parts of these econorios,at the least, so they cannot be lef t out 6f consideration in worst cane conditions.

B-06 through 89 The possibility of damage to the spray pond and its equiy-ment is still open and is the subject of a special studys still unresolved.

CONCLUSION.

B-90 In finding that our scenarios for accidents and calculationo are "without merit " LB supported PECo's interests and abdicated its responsibility for the public's health r id safety and it contradicted its own ascertica in B-5 "Wo do consider the conooquences of worst cano accidents... "

On the basis of these egocific LB errors and failures we petition the Appeal BoNrd to reverne the LB decision on our contentions,and to gre.nted the requented relief.

ec. by first clano meil to: Respectfully submitted,

!"MP,n"s"MW"'

Nov. 23,1984 Swr t, h%

Box 186, Moylan,Pa. 19065 m

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