ML20099G458

Rebuttal of Applicant 840518 Reply on Contentions V-3a & V-3b Re safety-related Structures.Six Remedies Listed in Finding Should Be Mitigated Re Hazards to safety-related Structures Set Forth in Record of Hearings on Contentions

ML20099G458
Person / Time
Site:	Limerick
Issue date:	06/06/1984
From:	Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH
To:
Shared Package
ML20099G457	List: ML20099G455 ML20099G458
References
OL, NUDOCS 8411270303
Download: ML20099G458 (4)

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p.3. NUCLEAR REGULATORY CCMMISSION . . ... . ATOMIC SAFSTY AND LICENSING BOARD RE: Philo Electrio Co. LinOrick Gcn.Sta. Unita 1 & 2 D:okot # 50- 352,353 R.L. ANTHONY /F0E REBUTTAL OF APPLICANT'S REPLY FINDINGS. 5/18/84 m _ON CONTENTIONS 1-la AND V - 3b. h t

,1984 PECo's and Staff's findings.

We are not responding indiv'S4u g g o e NRC Staff's findings as they appear to be practically identical to PBCo's. e believe thatourresponsestoPECo's" insertions"detailedbelokn.31sf agp y equally to the Staff's findings.

• BRANcy 's Response to PEco insertion 8A. No evidence was presented to show that Mr.Benkert's

" considerable experience with nuclear power plants" over was directly connected cith the design of Limerick safety related structures. de flatly denied selecting the drawings to demonstrate the design to withstand outside explo sions or making cny calculations. 8395-19 & 23.,8397-10,11.

Even had Mr.Benkert certified the designs,he was not permitted to say whether he had any knowledge that the safety relate 4 structures had been build according to these plans or that any had been completed. We raise again the question as to whether the Board can evaluate the structures' ability to withstand explosions, Iceking assurance that these structures are built to the designs,and completed.

8396-11.

Insertion 9A. The Staff witnesses were handicapped because they had never been ct the site',by lack of knowing the orientation of Possum Hollow Run and the rail-rcad' to the plant. The vulnerability og the reactor building louvre had to be pointed out to thes,for example. And Dr.Campe acknowledgeiall the ARCO fuel in the"Run"could be daemed for three hours without any escape to the Sdhuylkill,7524-7558. He could have estimated,without our questioning,the additional capacity of the flood plain in the "Run" as ample to contain more than three hours fuel flow,since he came up with a figure of 500,000 cu.f t. 7541-8t had he seen the site.

_-9B . Dr.Kuo and Mr. Homney were not able to testify as to the margins to resist blast overpressures without knowing that the structures had been completed as chown in the pla ns. Without a first hand view they could not testify even whether the structures had been started,much less completed in a way to be able to withstand.

- 11 A .

C.Ferrell in his testimony on the pipelines feferred to the "CP stage"

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MO 7 roport and the lack of any consideration of pipelines. If this safety issue had l go b:en considered,the plant construction might have waited for its resolution.

n f Page 9, Par.17 Contrary to this insertion Mr.Christman did testify that the ARCO n< pumps could fail to shut down automatically in case of a break that was not a complete one. 5175-15 to 5175-4. The coard's concern for a requirements for E o safety grade equipment" in connection with an accident is stated in 5085-10 to 16.

- 28 A. The railroad emba nkment is abutted by a PEco roadway across the"Run" which MH l E l T~ A

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to not choun on the cito map. If Mr.Compo had vioitod the sito ho oculd havo observed this.It is another examplo of the diceropsney botascn dracinga cod "co built" conditions by PECo,but this did not get into the record .

It is not true that evaporation area would not be increased by a blockage.

Dr.Campe stated that a three-hour dammihg would raise the level in the "Run" "a fraction of a foot".' 7536-16. He also estimated this area could contain 500,000 cu.ft.of fuel. 7541-8. Thus 500,000 sq.ft. x 1 f t. means a surf ace for evaporation of at least the 500,000 sq.ft. since he estimated a depth of "a fraction of a foot" for a three-hour damming. See M 9A above.

41.A . The overpressure of 24 psi was based on a conversion factor of 10, the figure used by Mr.Walsh in his testimony and used by PEco witnes!", TABLE II, columns 3 and 4 in the structural testimony. Had PECo used thig conversion rate along oith a hillside evaporation area,plus the additional 500,000 sq.ft. in the dam-ced "Run" it could have come closer to a realistic " worst case" ARCO break. It could have come out with 24 poi or more and would then have accurately assessed the potential, hazard to the safety related structures, ins tead og the figures in TABLE II.

In thw metter of evaporation rate, Mf. Walsh never varied from the rate he

' crrived at, 1 ca./ hour, and there is no testimony to prove that this rate is i

not as valid as the one chosen by the Staff. The 24 psi overpressure was not crrived at by " combining every conservatism" but only to make a comparison of PE cnd Staff methods and this comparison was backed up by the Board,7506- 14 to 23 60.A. Mr.Walsh's testimony on the momentum of the jet of gas released from a Columbia break is contradiotory if the assumption is made that the two severed cado point toward the plant.He says at 5460- 15 that there would be no penetra-tion of a heavy inversion. He admits that the mixture would travel from pressure and the wind toward the plant and impingement on the excavation would not stop the stream, 5473-1 to 20. He says,however, that the mixture could resch the' plant, 5469-2,but that he does not believe it would be within flammable limits,5473-e.

On the other hand he said that the Hasbrouck scenario of g break at Possum Hollow Run with the pipe ends pointed down the Run for a " fire hose" effect could create the" possibility" of a flammable mass travelling down the Run. 5476- 10 to 19 i

There is no evidence in the testimony to show that the flammable mixture would no longer be flammable af ter an arbritary 360 meters. It is equally justified to assume that flammable masses could arrive within 800 feet of the plant or closer, because of pulses in the jet strena and variations in the wind force. Mr.Hasbrouck'

. concept of successive layers of vapor adding to the front of the mass,either in the Run, or from the PECo break location down the slope from Longview Road was not refuted. i The arbitrary " closest" detonation distance of 1,200 f t from the plant was l

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cpparcatly cccoptcd cithcut cn indspondent cnclyois by the otaff, 9147-3,21, 9149-

20. Thore is no substantiation,therefore,for this distance, leaving open the pos-cibilities for closer detonations and higher overpressures.

78. A . It was not possible for us to"show deficiencies in construction" since no evidence of construction was permitted by the Board except one aerial photo-graph,at our request. However,one deficiency was brought out when Judge Brenner recalled,in the hearing on our new fuel contentions, that the license application cpecified storing new fuel inthe "new fuel storage vaulta",7826-23 to 7827-5.He was told that there were no vaults,they had been eliminated from the design.

Had the Board allowed inquiry into "as built" conditions,as we believe it should have, other deficiencies in construction performance could have come to light, providing the only comelusive basis.from the present form of the structures, whether they afforded the structural integrity to withstand explosions,and, equally important, whether there were" margins inherent".

Page 40, Par.79.

PEco and the Staff did not use " worst case" ARCO and Columbia cxplosions as set forth in their alternate calculations which they both provided in the record. See 41 A and 60 A above.

05. A. The fallacy of PECo's calculations cf overpressures on walls and roofa in Tables I and II becomes apparent from the maximum railroad blast pressure of ggf3-1 18.2 which is not shown at all in the tables. The figuring of maximum pressure on the " critical element" makes the results symbolic and inaccurate. In an actual ranroad explosion the south wall of the reactor building,for example,would be bubject to overpresrure at every spot on its whole surface,resulting in a cumula-tive total stress,not just the overpressure at the " critical element". The PEco eniculations are,therefore, inaccurate,and,in addition,without "as built" evidence there is no way to detdraine the strong or weak spots and other irregularities in construction. -

93. A. There is no proof in the testimony that 800 tons differential in weight on the bedrock between a loaded #.1 reactor and an empty # 2 "is obviously so insignificant compared to the weight of the entire facility" that it could not initiates faults or other unstablising activity in the bedrock. There is no~

I Poeight of the entire facility" indicated. And in addition to the weight differ-i ential is the process load and the stress of extreme impacts from start up. change of loads, and shut down.

94 . A. The witneaese did not provide adequate consideration of the transfer of shocks from the suppression pool processes to the reactor structure and thence to the foundations of the plant and the bedrock support. These movements and '

chocks are transmitted via the bedrock and foundations to the wall foundations cf the reactor building. Should the forces of an external explosion be added, 8{*! I

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the intogrity of tho rosator building could bo threatoned. Thic could happen no o recult of the cparating prooscs withcut the eddition cfo "LOCA".

113. A. In the testimony the release of sulphuric acid was accepted and the effect on ground water evaluated. Since the acid and the chlorine structures are me.tching structures next to the two cooling tc.wers,the destruction of both cas assumed in a blast that would collapse both towers.

Ms.Ferkin for the Commonwealth questioned the integrity of the contreL room air cource against smoke and fumes, 5526-12. Her question is still not answered uith respect to a chlorine gas release in the vicinity of the control building from damage to the chlorine storage building which is not built to safety related j otandards. Such a release poses a threat to control building habitability and consequently, the safety of the whole plant.

113. B. There is no doubt that the circulating water pumphouse should be classi- '

fied as safety related since ithouses the fire pumps. The damage from cooling tower collapses with sca+ Aaring of reinforced concrete slabs is not at all compar-able with that from a tua year frequency natural phenomenon. The pumphouse Seismic Class 2 construction will not prevent its destruction titnder collapsing cooling towe rs . 'i'b e two fire pumps could be damaged by building destruction and further disabled by flooding from the tower pool releases. The building is in the direct downhill flow path. Survivab'ility of safety related =tructures is endangered by the prospect of simultaneous disabling of all fire pumps. 8945-2 113. C. It is ironic that our concern for protection from a railroad explosion should be termed " Improper" by PECo. The record shows that an explosion against the south wall of the reactor stucture could blow in the louvre and open the con-tainment structure to the outdoors. A greater threat to the reactor building,however,would come from overpressures from pipeline explosions (see 41.A be and 60.A a.bove). These pressures could twice as great as from railroad explosions, 24 psi and more from ARCO and in a similar range from tbs Columbia Cas line. 5508-Ue repeat our call for relocation of both pipelines which was included in the 1 to 1@

" remedies " included in our 5/2/84 findings. With respect to the railroad explo-oion threat,we suggested the erection of a barrier as a sedond choice since we did not consider the relocation of the railroad a possibility.

The above rebuttal of PEco's reply findings are added to our findings of 5/2/84 We repeat again our request for the six remedies (page 8) listed in our l findings to mitigate the hazards to safety related structures set forth in the

record of hearings on Contentions V-3a and V-3b.

Cc: Judges Brenner, Cole and Morris (Opec. Del.) Respectfully submitted, t

NRC Staff, M.J.Wetterbahn, T Others on Serv. List [

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Bat 18 Moylan, a.19065

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