ML20078G569

Statement of Matl Facts as to Which There Is No Genuine Issue Re Contentions V-3a & V-3b

ML20078G569
Person / Time
Site:	Limerick
Issue date:	10/07/1983
From:	Wetterhahn M CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20078G568	List: ML20078G566 ML20078G569 ML20078G573 ML20078G576 ML20078G581
References
NUDOCS 8310120368
Download: ML20078G569 (10)

Text

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00CMETED USNRC UNITED STATES OF AMERICA 3 mi11 #0:25 NUCLEAR REGULATORY COMMISSION BeforetheAtomicSafetyand-LicensinghEdd;k%[

w ;.3 In the Matter of )

)

Philadelphia Electric Company ) Docket Nos. 50-362

) 50-353 (Limerick Generating Staticn, )

Units 1 and 2) )

APPLICANT'S STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD WITH REGARD TO CONTENTIONS V-3a AND V-3b

1. The Atlantic Richfield Company (" ARCO") refined petroleum products pipeline passes within about 1,600 feet of the Unit 2 reacttr enclosure, which is the nearest. it approaches safety-related structures (Affidavit of John D.

Walsh at 14).

I 2. The pipeline is approximately 1,675 feet from the

! Unit 2 diesel generator building at its closest point of I

approach (Walsh Attidavit at 14). ,

3. The pipeline runs generally north-south in the vicinity of the plant; pumpages are in a northward direction (Walsh Affidavit at 14).

4. Routing of the pipeline and its relationship to the Limerick Station is as shown on FSAR Figure 2.2-4 (Walsh Atridavit at 14; Affidavit of Vincent S. Boyer Regarding Contentions V-3a and V-3b at 112-3).

5. Tnis pipeline is buried a minimum of three feet below grade (Walsh Affidavit at 14) .

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2-4

6. The pipeline is a dedicated carrier for refined ARCO petroleum products such as gasoline and diesel and home heating oil (Walsh Affidavit at 1 4).

7. Propane is not and never has been carried by this pipeline, and could not be carried by the pipeline without major modifications (Walsh Afridavit at 14).

8. Philadelphia Electric Company has obtained an agreement from ARCO that it will not trancport propane through this. pipeline (Walsh Affidavit at 14; Boyer Affidavit at 14).

9. The pumping stations for this pipeline are equipped with pressure sensors to detect a sudden rise or fall in pressure which could indicate a leak or break in the lines (Walsh Af fidavit at 15) .

10. The pumps would automatically be shut off in this event (Walsh Af fidavit at SS) ,

11. Following a pipelina rupture, operators monitoring the pipeline and pump stations would also note a speedup of the pumps and could terminate pumping (Walsh Attidavit at 15).

12. Even small pipeline leaks would be detected through routine inventory procedures in a relatively short time (Walsh Affidavit at 15) .

13. Analyzing the potential effects upon the Limerick Station from a rupture of this pipeline, it is conservative to assume a gasoline release since gasolina is the most

volatile substance carried and has the highest energy content (Walsh Affidavit at.15).

- 14 . Possum Hollow Run is the lowest point between the adjacent high points ot the terrain in the vicinity of the Limerick Station (Walsh Affidavit at 16) .

15. Rupture of the pipeline at this location would have ,

the greatest effect on the Station (Walsh Attidavit at $6) .

16. Ruptures of the pipeline at other locations in the vicinity would either release less gasoline, because of the relative elevation, or the gasoline would drain into other, less proximate drainage systems (Walsh Affidavit at 16) .

17. Such rupturcs would have less effect (Walsh Affidavit at 16).

18. The entire calculated gasoline content of the pipeline between those two adjacent high points of land (1,400 feet north and 600 feet south) is 4,962 gallons (Walsh Affidavit at 17).

19. Assuming that 4,962 gallons of gasoline flowed into the streambed, it would be distributed over the bed between the pipeline and the first downstream bridge in a pool 610 meters by 1 meter wide by approximately 3 centimeters deep (Walsh Af fidavit at 17) .

20. The pooling capacity of the creek bed is very small (Walsh Affidavit at 17).

Even if more than the entire calculated gasoline J

21.

content of the pipeline between the two high points were

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4 released, the additional gasoline would drain downstream away from the plant (Walsh Af fidavit at 17) .

22. Accordingly, larger releases than postulated would not significantly change the predicted impact on the Station (Walsh Affidavit at 17).

23. Assuming pf.poline failure, air would enter the lines at the point of rupture and travel through the upper portions of the pipe above the surface of the draining fluid until it reached the adjacent high points, where it would accumulate and prevent further drainage by gravity flow-(Walsh Affidavit at 18).

24. No siphoning effect would occur from beyond the high points because a siphon requires the presence of atmospheric pressure at both ends (Walsh Af fidavit at 18) .

25. Gasoline from the ruptured pipeline would distribute in the Possum Hollow Run creek bed and evaporate, forming a gradient of gasoline vapor at decreasing concentrations above the stream and confined horizontally within the valley walls (Walsh Af fidavit at 19) .

26. The greatest concentration of gasoline vapor will exist if winds are calm such that the only mixing which occurs is due to the vapor pressure of the evaporating gasoline forcing vapor upward (Walsh Affidavit at 19).

27. If winds were not calm, even assuming wind in the direction of the Station, greater dilution of the gasoline vapor would exist, resulting in lesser concentrations of

l vapor within flammable limits near the Station (Walsh Affidavit at 19).

28. Using accepted values, the explosive limits of gasoline vapor is 1.3 to 6.0 percent by volume in air (Walsh Affidavit at 110).

29. Assuming detonation of the gasoline vapor approximately 800 feet from the Unit 2 reactor enclosure, a wide spot in the valley where direct exposure to safety related structure exists, and using Regulatory Guide 1.91 f

methodology, the resulting peak reflected overpressure is 1.9 pounds per square inch . (" psi") (Walsh Affidavit at 110).

30. This calculation does not credit intervening terrain at the location of the explosion centroid (Walsh Affidavit at 110).

31. If the closest approach of Possum Hollow Run (approximately 550 feet) were selected as the explosion I

l' centroid location, the calculated peak overpressure would be 1

I approximately 3 psi and would have no effect on Limerick safety'related structures (Walsh Af fidavit at 110) .

32. No credit was taken for the shielding effects of the Possum Hollow Run valley walls in this calculation (Walsh Affidavit at 110) .

33. The design reflected average overpressure of the l

affected safety related structures at Limerick is 12 psi l

. (Walsh Af fidavit at 110) .

34. An alternative assumption is that the 5,000 gallons of spilled gasoline deflagrates in a 15-minute period, which t- - - _ - , _ _ ._. _ . _ . . _ _ , - . _ _ _ _ _ _ _ _ - _ . . . _ . _ - _ . . _ . _ , . . - . . . _ . _ . _ , . . . _ ~ - - . , , _ . - - _

conservatively maximizes the heat generation rate (Walsh Affidavit at 111).

35. .The heat from such a deflagration would produce a radiant heat load of 85 Btu per square foot per hour at the Unit 2 reactor enclosure (Walsh Af fidavit at 111) .

36. A radiant heat load of 85 Btu per square foot per hour would not have any effect on the reactor enclosure other than a slight warming of the concrete surface, even for an extended period of deflagration (Walsh Affidavit at ill).

37. By comparison, a flat surface in the sun at mid-day would receive solar radiation at approximately 50 to 60 Btu per square foot per hour (Walsh Affidavit at ill) .

38. Neither the peak overpressure of 1.9 psi by detonation nor the radiant heat at 85 Btu per square foot per hour by deflagration of spilled gasoline vapors would aftect safety related structures (Walsh Affidavit at 112) .

39. Columbia Gas Transmission Company pipelines Nos.

1278 and 1010 carry only natural gas and pass within 3,500 feet of the Unit 2 reactor building at the closest approach (Walsh Attidavit at 113).

40. Both pipelines share the same right-of-way and run south-southwest to north-northeast-(Walsh Affidavit at 113).

41. The routing of these gas pipelines and their relationship to the facility are as depicted on FSAR Figure

- 2.2-4 (Walsh Af fidavit at 113; Boyer Af fidavit at 112-3) .

. _ - - _ _ _ _ , . . __ ~ . . . _ . . _ _ _ . _ __ _ . . . . _ _ _ _ . _ _ _ . - _ _ _ _ _ - _ _ _

42. Pipeline No. 1278 is 14 inches in diameter, operates at a maximum pumping pressure of 1,000 psig, is 34 years old and is buried at a minimum of 3 feet below grade (Walsh Af fidavit at 113) .

43. Pipeline No. 1010 is 20 inches in diameter, operates at a maximum pumping pressure of 1,200 psig, is 17 years old and is buried at a minimum of 3 feet below grade (Walsh Affidavit at 113).

44. In calculating potential effects or pipeline rupture, the conservative assumption is a double-ended rupture (complete separation of the pipe at the point of rupture) and vertical orientation of the two pipe ends due to pressure and whip (Walsh Affidavit at 114) .

45. This assumption takes no credit for burial of the pipelines, which would mitigate the whip effect (Walsh Affidavit at 114).

46. If the pipe ends were not in a vertical orientation, the momentum of the two opposing streams of gas l

l would cause rapid mixing and dilution and would cause the l

gas emitted to be a ground level source, resulting in an explosion centroid further from the Limerick Station than f conservatively assumed (Walsh Af fidavit at 114) .

1 l 47. The amount of gas released during a pipeline i

l rupture is inconsequential since calculations or the effect of natural gas from the pipeline are of an explosion dependent upon the rate of release rather than the total l amount available for release (Walsh Affidavit at 115).

I

.,. --_.r -, , -. . . .

48. In analyzing the postulated failure or this pipeline, it is conservative to assume that the escaping gas rises in a column to about 500 feet above plant grade, where the momentum energy decays, and that the gas then travels horizontally, directly toward the Unit 2 reactor enclosure (Walsh Affidavit-at 116).

49. The mitigating effect of the height above plant grade was not used in the calculation of overpressure (Walsh Aftidavit at 116).

50. It is conservative to assume that the natural gas begins to disperse downward toward the Limerick Station trom directly above the rupture point, at a low dispersion rate using Pasquill "F" stability with one meter per second wind speed (approximately the 95th percentile meteorology) (Walsh Affidavit at 117).

51. These conservative assumptions allow the natural gas plume to travel nearest the plant prior to reaching detonable concentrations (Walsh Affidavit at 117).

52. The explosive limits of natural gas are between 6.0 and 14.0 percent by volumo in air (Walsh Affidavit at 117) .

53. Detonation of natural gas released from the postulated pipeline failure results in a peak overpressure at the Unit 2 reactor enclosure of 10 psi, which is less than the design overpressure for critical safety related structures (Walsh Affidavit at 118).

54. If the wind were blowing in any direction other l

than directly towards the plant, the effects of a gas l

l l

l

. n.

explosion on the facility would be less (Walsh Affidavit at 118).

55. If the wind speed were higher, greater dilution would occur and the zone of explosive limits would be closer to the point of release and further from the Station (Walsh Affidavit at 118).

56. The calculations are also conservative because natural gas clouds seldom detonate in the open air (Walsh Affidavit at 118).

57. If the natural gas cloud were to deflagrate rather than detonate, the flame front would probably move back and have a negligible effect on the plant (Walsh Affidavit at 119).

58. It is conservative to assume that the cloud continues to burn at the original point of ignition (Walsh Affidavit at 119). The radiant heat load at the Unit 2 reactor enclosure resulting from the postulated detonation l would be 70 Btu per square foot per hour (Walsh Affidavit at 119).

59. This radiant heat load level would only cause slight warming of the outer layer of concrete, and would not cause noticeable or lasting ettects, even for an extended period of deflagration (Walsh Affidavit at 119).

60. Diesel fuel storage tanks and associated piping are buried and would not be affected by either the detonation or deflagration of the natural gas postulated in these analyses (Walsh Affidavit at 120; Boyer Affidavit at 12).

61. Whether-detonation or deflagration of natural gas released from either of the two Columbia Gas Transmission Company pipelines were postulated to occur, no adverse effects on safety related structures or equipment at the Limerick Generating Station would result (Walsh Affidavit at 121).

Respectfully submitted, CONNER & WETTERHAHN, P.C.

Mark J. Wetterhahn, P.C.

Counsel for the Applicant October 7, 1983 l

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