ML20040F785
| ML20040F785 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/05/1982 |
| From: | Lewis S NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Brenner L, Cole R, Morris P Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8202100305 | |
| Download: ML20040F785 (2) | |
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g February
, 1982 Lawrence Brenner, Esq., Chairman Dr. Richard F. Cole Administrative Judge Administrative Judge U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Peter A. Morris
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Administrative Judge pV U.S. Nuclear Regulatory Comission q
Washington, D.C.
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In the Matter of 9,9 go)F 4 N )Wh,, 8
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PHILADELPHIA ELECTRIC COMPANY 0
(Limerick Generating Station, Units 1 and 2)
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6 Docket Nos. 50-352 and 50-353 vg,g[O g
Dear Administrative Judges:
By letter dated January 26, 1982, to the Chairman of the Atomic Safety and Licensing Board, petitioner Air and Water Pollution Patrol (AWPP), through its Chairman, Mr. Romano, has made certain arguments regarding the relevance of the recent aircraft accidents in Washington, D.C. and Boston, Massachusetts to the issue of the potential impacts on aviation of the cooling tower plumes from the Limerick Generating Station. AWPP notes that one of its proposed contentions (V-4) raises this issue and the NRC Staff understands the letter to be in the nature of further provision of basis for that contention. The Board did not call for a further statement of the basis for proposed contention V-4, but the Staff offers the following response to AWPP's letter in the event that the Board chooses to consider that letter in reaching its determination on the admissibility of the proposed contention.
The information provided by AWPP does not address the ground for Staff's opposition to the admission of the contention, namely, that the Environmental Report (ER0L) on its face demonstated that AWPP was incorrect in asserting that the neteorological input to the Applicant's analysis of the effects of the Linerick cooling tower plume on air traffic was based on average tenperatures.
"NRC Staff Answer to Supplemental Petition of Coordinated Intervenors" (December 7,1981) at 18. To the contrary, ER0L
$ 5.1.4.1.2, cited in the Staff's Answer, states that 237 different plumes were predicted based upon that number of individual soundings of upper air taken at Philadelphia International Airport over a one-year period. Nothing in the letter obviates this ground for objection to the admission of proposed contention V-4.
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At the close of its letter, AWPP also " request [s] whatever information the NRC and the Applicant has, as it relates to its authority to modify the natural atmosphere, in particular as it relates to the above points." This appears to be a discovery request, which is premature at this time since neither AWPP, nor its proposed contention V-4, has yet been admitted into the proceeding.
Sincerely, Stephen H. Lewis Counsel for NRC Staff cc:
Mr. Frank R. Pomano Judith A. Dorsey, Esq.
DISTRIBUTION:
Mr. Edward G. Bauer, Jr.
NRC Docket Troy B. Conner, Jr., Esq.
LPDR Mark J. Wetterhahn, Esq.
PDR Mr. Marvin I. Lewis FF (2)
James M. Neill, Esq.
Cunningham/Engelhardt Joseph H. White III Christenbury/Scinto Dr. Judith H. Johnsrud Rutberg Thomas Gerusky Olmstead PA. Emergency Management Agency Chandler John Shniper Vogler Robert L. Anthony Lewis Alan J. Nogee Hodguon W. Wilson Goode Chan William A. Lochstet Chron.
Charles W. Elliott, Esq.
Walter W. Cohen Robert W. Adler m.
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