ML20077J534
| ML20077J534 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/12/1983 |
| From: | Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | AIR AND WATER POLLUTION PATROL |
| References | |
| NUDOCS 8308160496 | |
| Download: ML20077J534 (45) | |
Text
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4 6 REIATED COlttu31*ON'IHW('F g ,
00CKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'83 AUG 15 Af0 :47 i In the Matter of ) CFFl?E OF SECPED -
CCCXiIUi'i& SEg, Philadelphia Electric Company DocketNos.50-35$
) 50-353 (Limerick Generating Station )
Units 1 and 2) )
APPLICANT'S ANSWERS TO INTERVENOR AWPP'S (ROMANO) FIRST SET OF INTERROGATORIES ON CARBURETOR ICING CONTEh"IION DISCOVERY 11 AUGUST 12, 1983 M
B308160496 B30812 PDR ADOCK 05000352 G PDR
- Interrogatorv No. 1 y .
- State whether you intend to present any expert witnesses on the subject matter at issue in Contention V-4. If so, identify each such expert witness and further state (a) his professional qualifications; (b) the subject matter on which the expert is expected to testify; (c) the substance of the facts and opinions to which the expert is expected to testify; (d) the grounds for each ooinion. Identify by court, agency, or other body, each proceeding in which such individual rendered testimony on this (these) subject (s) .
Answer The following five individuals may testify on the subject metter of the contention:
A. Vincent S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 (a) Professional qualifications are described in the Attachment.
(b) Mr. Boyer will testify on the design and operation of the Limerick Generating Station power plant and cooling towers.
(c) Mr. Boyer will testify as to the design data used in j calculating the heat dissipation through the Limerick cooling towers.
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(d) Mr. Boyer's opinion is an expert's determination of data
". and results based on professional training and extensive experience in the field. Mr. Boyer superviced the preparation of the Limerick Final Safety Analysis Report (FS AR ) , and the Limerick Environmental Report Operating License Stage (EROL).
(e) Mr. Boyer presented testimony on the design and operation of the Limerick Generating Station during the Limerick Construction Permit Hearings. (Transcript p.
4243, December 12, 1973). .
B. Mavnard E. Smith, President and Principal Consultant Meteorological Evaluation Services, Inc.
134 Broadway Amityville, NY 11701 Patrick T. Brennan, Consultant Meteorologist Meteorological Evaluation Services, Inc.
134 Broadway Amityville, NY 11701 Dr. Charles L. Hosler, Dean of the College of Earth and Mineral Sciences - .
Pennsylvania State University i 3 1
A
, 116 Deike Building University Park,.PA 16802 David E. Seymour, Consultant Meteorologist and Pilot Meteoroloaical Evaluation Services, Inc.
134 Broadway Amityville, NY 11701 (a) The orofessional cualifications of these individuals are attached.
f (b) The witnesses will testify on the operaticn of the Limerick cooling towers and the resultant physica'l phenomenon which may lead to carburetor icing.
(c) The witnesses 'will testify that the operation of the Limerick Generating Station cooling towers do not significantly increase the risk to pilots.
(d ) The ooinions of the witnesses are based on professional training ~and extensive experience in the field.
(e) Messrs. Smith, Brennan, and-Seymour have not appeared as a witness on the subject matter of this contention.
Dr. Hosler presented testimony on the design and j operation of the Limerick Cooling Towers as part of the L
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,s Limerick Construction Permit Hearings. (Transcript p.
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( 4157, December 12, 1973.)
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Particinants in Precaration of Answer Yincent S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Phil'adelphia,' PA 19101 Maynaid 'E. Smith President'and Principal Consultant Meteorological Evaluation Services, Inc.
134 B' roadway Amityville, NY 11701 Patrick T,._Brennan ,
Consultant MGteorolo? 7t i
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Meteorological E' iluation Services, Inc.
134 Broadway _ . s .
Amityville, NY 11701 Dr. Charles'L. Hosler Dean of the College of Earth and Mineral Sciences Pennsvivania State University +
116 Dhike Building University Park, PA 16802 David E. Seymour ,
Consultant Meteorologist and Pilot Meteorological Evaluation Services, Inc. -
134 Broadway '
Amityville, NY 11701
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- Interrocatory No. 2 Identify by title, author, publisher and date of issuance or publication, all documents that you rely upon~as a basis for your contention or that you intend to use (by way of reference or evidentiary proffer) in presenting your direct case on Contention V-4 and all documents to which you intend to refer in conducting cross-examination of other witnesses who may testify in connection with any such contention (s) .
Answer Gardner L. and G. Moon, Aircraf t Carburetor Icing Studies, Mechanical Engineering Report LR-536, National Research Council of Canada, July (1970). (Designated Discovery 11, Item 2A).
Johns Hopkins Univerci ty, Applied Physics Lab: Salt Loading, Modeling and Aircraf t Hazard Studies, Chalk Point Cooling Tower Project, JHU/ APL. FY1977, Final Repor t, PPSP-CPCTP-16, Volume 1, August (1977). (Designa ted Discovery 11, Item 2B, previously provided as Discovery 2, Items D and L)
Kramer M. L. and D. E. Seymour, John E. Amos Cooling Tower Flight Program Data, December 1974 - March 1975, (1975).
(Designated Discovery 11, Item 2C).
Kramer M. L. and D. E. Seymour, John E. Amos Cooling Tower Flight Program Data, December 1975 - March 1976, (1976).
(Designated Discovery ll, Item 2D).
Speiser A. S., Kramer M. L., Calby R. H., and P. A. Dal Porto, Empirical Relationships Between Meteorological 6
0, Variables and Visible Plumes from Large Natural-Draft i
! Cooling Towers, in Proceedings of Fourth Symposium on Turbulence, Diffusion, and Air Pollution, American Meteorological Society, Boston, Mass., (1979).
1 e (Designated Discovery 11, Item 2E).
l Thomson, D. W., R. G. de Pena, and J. A. Pena, Environmental j Measurements of Power Plant Cooling Tower and Stack
- Plumes, Dept. of Meteorology, Pennsylvania State
- ~
j University, (1981). (Designated Discovery 11, Item 2F) . ,
! Pilot's Handbook of Aeronautical Knowledge, Advisory Circular 61-23B, U.S. Department of Transportation, Federal
! Aviation Administration, 1980. U.S. Government Printing Office. (Designated ' Discovery 11, Item 2G) .
, Federal Aviation Administration, Eastern Region;
" Determination of No Hazard to Air Navigation", Case No.
l 70-EA-510-0E; Issued in Jamaica, New York on June 15, 1971. -(Designated Discovery 11, Item 2H).
I.
New York Sectional Aeronautical Chart, 27th Edition, June 9, c
1983, U.S. Department of Defense / Federal Aviation f
Administration / Department of Commerce. National Oceanic 4
and Atmospheric Administration (NOAA) , U.S . Dept. of Commerce. (Designated Discovery 11, Item 2I).
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U.S. No. 24 Low Altitute Enroute Chart, Effcctivo August 4, 6,
1983. Jeopesen Co., Denver CO. (DOcignated Discovery
. 11, Item 2J).
Philadelphia VFR Terminal Area Chart, 17th Edition, March 17, 1983, U.S. Department of Defense / Federal Aviation Administration / Department of Commerce. National Oceanic and Atmospheric Administration (NOAA) , U.S. Dept. of Commerce. (Designated Discovery 11, Item 2K).
1981 Cessna Model 172-P Information Manual, May 30, 1980, ,
Cessna Aircraft Co., pp. 3-16 to 4-24, incl.,
(Designated Discovery 11, Item 2L).
Kersher, W. K., Student Pilot's Flight Manual, Iowa State University Press, 1979 Edition, Chapters 3, 4, 7, 8, 9, 25 (pp 216-221), (Designated Discovery 11, Item 2M).
Federal Aviation Regulations: Part 61 (61.87cli, ii, vii);
Part 61 (61.105); Part 71 (71.5bl) , Part 71 (71.5cl);
Part 91 (91.79); Part 91 (91.105); Part 91 (91.119).
(Designated Discovery 11, Item 2N) .
Johns Hopkins University, Applied Physics Lab and Chesapeake Bay Institutes Power Plant Site Evaluation, Douglas Point. Site, JHU-PPSE 4-2, Final Report, January 1976:
Volume 1, Part 2, Chapter 8, (Potential Impact of Cooling Tower Air Emissions), Section entitled " Cooling 8
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O Tower Plume - Induced Flight Safety". (Designated o
. Discovery 11, Item 20).
Participants in Preparation of Answer Vincent S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Maynard E. Smith President and Principal Consultant Meteorological Evaluation Services, Inc.
134 Broadway Amityville, NY 11701 ,
David E. Seymour Consultant Meteorologist and Pilot Meteorological Evaluation Services, Inc.
134 Broadway Amityville, IW 11701 e
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'A Interrocatorv No. (a)
Did Applicant determine how many single engine aircraft use the twelve airports within 10 miles of Limerick per year?
Answer The Applicant has made a determination of the estimated number of annual aircraft movements at the Pottstown Municipal, the New Hanover , the Pottstown-Limerick and the Perkiomen Airports. The Applicant has also made a determination of the estimated number of single-engine aircraft that are based at the Pottstown-Limerick Airport. This information is described in Section 2.2.2.5 of the Limerick FSAR (hereaf ter "FSAR Section 2.2.2.5," and designated Discovery ll, Item a)
Particioants in Preoaration of Answer Vincent S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 l
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Interrogatory No. (b)
Did Applicant calculate how many single engine aircraft use the radio-guide VOR 116.5 approximately 1 mile from the reactor?
Answer No.
Particicants in Preparation of Answer Vincent S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 .
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4 Interrogatory No. (c)
Did Applicant determine how many student pilots; how many first year pilots; how many pilots that fly less than one hour per week; less than average of 1/2 hour per week; less than average of 1/4 hour per week on a year's basis at the twelve airports within 10 miles of Limerick?
Answer No.
Particioants in Preparation of Answer Vincent S. Boyer Senior Vice President - Nuclear Power .
Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 12
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- Interrogatory No. (d)
At what throttle RPM is Carburetor ice (and throttle ice) most likely to occur when dew point and air temperature are within 5 F between 32 F and 65"F with 1/2 saturated and near saturated air?
Answer There is no single answer to this question. Carburetor icing is dependent on type of aircraf t, type of carburetor and type of ducting.
Aircraft Carburetor Icing Probability Curves are in Figure 5-C-1 of the Johns Ilopkins University / Applied Physics Laboratory Chalk Point Cooling Tower Project Study, (designated as Discovery 11, Item 2B, previously provided as Discovery 2, items D & L).
Participants in Preparation of Answer David E. Seymour, Consultant Meteorologist and Pilot Meteorological Evaluation Services, Inc.
134 Broadway Amityville, NY 11701 Maynard E. Smith President and Principal Consultant Meteorological Evaluation Services, Inc.
134 Broadway Amityville, NY 11701 -
Vincent S. Boyer Senior Vice President - Nuclear Power l Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 13
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Interrocatory No. (e)
Has Aoplicant obtained data relating to the instrumentation or indicators available to the pilots referred to in (a),.(b), l and (c) above? l Answer All planes that are certified by the Federal Aviation Administration (FAA) must be equipped with an engine rpm gauge.
In addition variable-pitch-propeller aircraft are required to be
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eculpped with a manifold pressure gauge.
Participants in Preparation of Answer David E. Seymour, Consultant Meteorologist and Pilot Meteorological Evaluation Services, Inc.
134 Broadway Amityville, NY 11701 Vincent S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 l
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Interrogatory No. (f)
Has Applicant determined what % of single engine airplanes that fly in the Limerick area or otherwise have instrumentation or indicators available to the pilot?
Answer, i
No.
_ Participants in Preparation of Answer Vincent S. Boyer i Senior Vice President - Nuclear Power 'i Philadelphia Electric Ccmpany 2301 Market Street Philadelphia, PA 19101 2
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Interrogatory No. (g)
What plume studies has the applicant made including width, length, grams of water per cubic meter, and obstruction of view within the plume at different lengths, widths, and water vapor per cubic meter?
Answer The applicant has performed a computer study of the Limerick cooling tower plumes using the Electric Power Research Institute (EPRI) Seasonal / Annual Prediction of Cooling Tower Plumes Model (SACT-I) . The model provides information on plume behavior based on ambient meteorological conditions. Cooling tower de. sign characteristics used in the model are described in Section 5.1.4 of the Limerick EROL (hereaf ter "EROL Section 5.1.4", and designated as Discovery 11, Item gl), and in EROL Section 3.4.3, (designated as Discovery 11, Item g2) . Meteorological data for the model was obtained from the "Micrometeorological Data and Analyses for the Limerick Generating Station Environmental Report
- Operating License Stage, and Final Safety Analysis Report Submittals, Section 2.3.2 - Data Period January 1972 - December 1976", Vols. I, II, III, IV. (Designated Discovery 11, Item g3, previously provided as Discovery 2, Items A, B,.C, E, F, and G).
The computer output f rom the .modeling study is entitled
" Limerick Generating Station SACT-I Cooling Tower Modeling, 1972-1976, Meteorological Data, Books 1 and 2, (Designated as Discovery 11, Item g4).
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I Participants in Preparation of Answer l
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I Maynard E. Smith President and Principal Consultant Meteorological Evaluation Services, Inc.
134 Broadway '
Amityville, NY 11701 Vincent S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101
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Interrocatory No. (h)
The applicant has used the Johns Hopkins University Applied Physics Laboratory (JHU/APL) studies as indicated by " Cooling Tower Plume - Indicated Flight Hazards". These studies as stated in Chapter V, P.5-1 show results are invalid near traffic patterns (as exist at Limerick) . On what basis, then, does Applicant overcome the use of a study that states it cannot apply to Limerick?
2 Answer l The applicant has only used Appendix 5-C cf the donns Hopkins University, Apolied Physics Laboratory Chalt Point Study (Discovery 11, Item 2B). This part of the report, entitled
" Reciprocating Engine Carburetor Icing", was used in the analysis of the carburetor icing phenomenon. Other plume-induced hazards noted in the report are Chalk Point site-specific and were not used by the Applicant in his analysis.
Participants in Preparation of Answer Maynard E. Smith President and Principal Consultant Meteorological Evaluation Services, Inc.
134 Broadway Amityville, NY 11701 Vincent S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 l
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s Interrogatorv No. (i)
In JHU/APL report " worst condition" air moisture concentration is stated to be 1 gram of moisture per cubic meter of air. How many cubic meters of air will develop " worst condition" concentration as a result of release of 35 million gallons of water, as vapor, from the Limerick tower per day?
Answer The " worst condition" air moisture concentration noted on pace 5-4 of the JHU/APL report (Discovery 11, Item 2B) refers to "aircraf t structural icing" and not aircraf t carburetor icing.
The phenomenon of aircraf t structural icing is not relevant to the Carburetor Icing Contention.
Particioants in Preparation of Answer Maynard E. Smith President and Principal Consultant Meteorological Evaluation Services, Inc.
134 Broadway Amityville, NY 11701 Vincent S. Boyer Senior Vice President - Nuclear Power Philadelphia. Electric Company 2301 Market Street Philadelphia, PA 19101 19
. Interrocatory No. (i)
Did applicant study when air is at 0.9 grams of moisture per cubic meter, how many cubic meters of air will attain " worst condition" status by addition of 35 million gallons of water as vapor per 1 day; per 2 days; per 3 days?
Answer No. Refer to response to Interrogatory (i) .
Participants in Preparation of Answer Maynard E. Smith President and Principal Consultant Meteorolooical Evaluation Services, Inc.
134 Broadway Amityville, NY 11701 Vincent S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphic, PA 19101 I
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Interrogatory No. (k)
What staff questions were asked of the applicant relative to carburetor ice potential in aircraf t passing through or near the Limerick cooling tower plume in marginal VFR conditions? What were the . answers the applicant .gave in each case? !
Answer None.
Participants in Preparation of Answer Vincent S. Boyer '
- Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street ~
Philadelphia, PA 19101 L
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, Interrogatory No. (1) l i
Did applicant (P.E.) or its representatives perform quantative analyses on effect of saturated air (visible and invisible) on carburetor ice potential in the 1 mile, 2 mile, 3 mile, 4 mile, 5 mile area su rounding the Limerick reactor as affected by the addition of 35 million gallons of water, per day, as vapor? Did applicant study potential re above question for carburetor ice in naturally saturated VFR conditions, with stagnant no-wind condition and compounding of 35 million gallons of 0 water per day for three or four days with temperatures between 32 F and 650F?
Answer The applicant has performed a computer study using the EPRI SACT-I model. Refer to Response to Interrogatory (g) .
Participants in Preparation of Anawer i Maynard E. Smith President and Principal Consultant Meteorological Evaluation Services, Inc.
134 Broadway Amityville, NY 11701 .
Vincent S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 0
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. Interrogatory No. (m)
Further since carburetor ice potential is proportional to degree of saturation of the atmosphere at temperatures between 32 P and 65 F or more, did P.E. do studies re number of days in the past ten (10) years during which the dew point was 50F lower than the air temperature?
Answer The applicant has made available "Micrometeorological Data and Analyses for the Limerick Generating Station Environmental Repor t - Operating License Stage, and Final Safety Analysis Report Submittais, Section 2.3.2- Data' Period Jan. 1972 - Dec.
1 9 7 6 " , V o.l. s . I, II, III, IV, (Designated Discovery 11 Item g3, previously provided as Discovery 2, Items A, B, C, E, F, and G).
For the 1977-1981 period, hourly temperature and relative
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humidity data for Limerick can be found in " Limerick Generating Station, Weather Station No. 1, Hourly Data Listings, January 1977-June 1979 (Book 1); July 1979-December 1981 (Book 2) " ,
(Designated Discovery 11, Item m).
Dew point temperature can be calculated from the temperature and relative humidity data.
Participants in Prenaration of Answer Maynard E. Smith President and Principal Consultant Meteorological Evaluation Services, Inc.
134 Broadway Amityville, NY 11701 .
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. Vincent S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company !
- 2301 Market Street
, Philadelphia, PA 19101 a
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6 Interrogatory No. (n)
Did P.E. calculate the number of ' days in the past ten years in the Pottstown-Limerick area when cloud ceiling was 1,000 feet, 1,200 feet, 1,500 feet, and visibility was 4 miles, 3 1/2 miles, and 3 miles?
Answer No.
Participants in Preparation of Answer Vincent S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 l
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Interrogatory No. 03)
Did P.E. do cuantitative studies which indicated there would be no potential for carburetor ice 0or other adverse effect re flying hazard) from accumulation of 35 million gallons as water per day of moisture from the Limerick towers under no-wind naturally saturated conditions present 2, 3, 4, days or more in a row from February through April and from September through November?
Answer See Resoonse to Interrogatory 0g ) .
Particioants in Preoaration of Answer Maynard E. Smith President and Principal Consultant Meteorolcgical Evaluation Services, Inc.
134 Broadway Amityville, NY 11701 Vincent S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 26
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. Interrogatorv No. (g)
Has P.E. contacted the operators of the twelve airports--in particular Pottstown-Limerick, Pottstown Municipal and Perkiomen Valley airports relative to the potential for carburetor ice and shear as a result of both visible (on marginal VFR days) and invisible plume, in particular on full VFR days?
Answer No, as to carburetor icing.
Participants in Preparation of Answer e
Vincent S. Boyer Senior Vide President - Nuclear Power Philadelphia Electric Company -
- 2301 Market Street Philadelphia, PA 19101 s
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O Interrogatory No. (r)
Did P.E. study how many days during 1980, 81, or 82 that the dew point conditions were reached within 1, 3, 5, 7, 10 miles from Limerick?
Answer No.
Particioants in Preoaration of Answer Vincent S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 28
4 Interrogatory No. (s)
Did P.E. study how many days during 1980, 81, or 82 the dew point was within 1, 3, 5, 7 degrees F of the air temperature in the Limerick area?
l Answer Refer to Response to Interrogatory (m).
Particioants in Preparation of Answer i Maynard E. Smith l President and Principal Censultant i Meteorological Evaluatica Services, Inc. )
- 134 Broadway .i j
Amityville, NY 11701 l 4 vincent S. Boyer r
Senior Vice President - Nuclear Power
, Philadelpnia Electric Company j 2301 Market Street Philadelphia, PA 19101 4
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Ihtorrcanterv No. (t)
Re (r) and (s) above, did P.E. quantitate the grams of moisture per cubic meter of air on days when dew point was within 1, 3 , 5 degrees F of air temperature and on days when air is stagnant and saturated, how much moisture is added per liter in a volume of air 1,000 feet high and 1 mile square with tower water vapor releases accumulating 1, 2, 3, 4, 5, and 6 days?
Answer No.
4 Participants in Precaration of Answer Vincent S. Boyer 2 Senior Vice President - Nuclear Power '
Philadelphia Electric Company 2301 Market Street PhiladelDhia, PA 19101 30
, Ihtorrogetory No. (v)
Did P.E. purchase the Pottstown-Limerick airport in order to control movement of aircraft in the immediate airspacei for hazard considerations, or otherwise?
Answer The Pottstown-Limerick airport was purchased by the Applicant for potential use as an industrial park and for transmission line right-of-way. This information is contained in letters from M.G.
, Eas tman to W.H . Jones , da ted 1/15/ 68, and f rom M . G . Eas tman to J. L. Everett, dated 2/27/68, (Designated Discovery 11, Item v;
. previously provided as Discovery 2, Iten K). -
Particicants in Preparation of Answer Vincent S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 31 4 _a,, _ .-p .-, v--, --- '
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Interrogatory No. (w)
Does P.E. intend to change or limit access to the Pottstown-Limerick airport by pilots and aircraft as compared to previous owners? !
l Answer l No.
Particicants in Precaration of Answer Vincent S. Boyer Senior Vice President - Nuclear Power Philadelphia Electric Company 2301 Market Street .
Philadelphia, PA 19101 5
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VINCENT S. BOYER
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., _ Employer: Philadelphia Electric Company Pokition: Senior Vice President - Nuclear Power
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Born: Philadelphia, April 5, 1918 i
, Education: "
B.S.'itt Mechanical Engineering - Swarthmore College - 1939 N - -
M.S. in Mechanical Engineering - University
'lif Pennsylvania ~- 1944 -
Hucled- Energy Courses - Universi~ty of Pennsylvainia and Drexel Universit)!- 1960-1962
-Experience: Philadelphia Electric Company - 1939 to date ,
g 1939 - 1951 - Engineering positions in power pia t .
1951 - 1953 -- Engineering Department 1953 - 1960 - Cromby Generating Station.- ~
Assistant and Station Superintendent 3
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1960 - 1963 - Superintendent, Peach Bottom Atomic
, Power Station ' N l
1963 - 1968 - Mankgei,' Nuclear Power and Electric .
Operations
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s 3 1968-1[80- Vice President, Engideering & Research
', Department
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J , 4 198_0" '- Praseat - Senior Vice Frhaiddt, Nuclear Power I g s' 9 Professional Organizations: s s -s American Nuclean Society *
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American Society oftMechanical Engineers ' ' 'N-Society of American Military Engineers National Sdelety of frofessional Engineers ,
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, l Honors: N -
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. Honorary. Loctorate of Engineering Technology - Spring Garden College
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. Engineer of the Year - Delaware Valley - 1979 e/- s
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Nctional Academy of Engineering - 196G $
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~' . .s L' ASME James M.-Landis Medal - 1981 s' .
George Washington Medal of Engineers Club of Philadelphia - 1982 -
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MAYNARD E. SMITH 1
Ed ucation:
. University of Chicago, Additional work on general circula-i tion,. single-station analysis, 1942 New York University, MS, Meteorology, 1942 i
Princeton University, BA, Economics, 1941
{ Ex perience :
I Meteorological Evaluation Services, Inc., Amityville, New
- York, 1 9 6 tl to Present, President, Principal Consultant i
l Mr. Smith has provided consulting assistance to a number of industrial and governmental organizations since the early
, 1950's. In 1968, Smith-Singer Meteorologists, Inc. was
! founded and Mr. Smith became President. The Company's name j was changed to Meteorological Evaluation Services, Inc., in 1977.
1 The . Company provides advice and assistance in meteorological l '
and air pollution problems, including atmospheric diffusion l studies, design and evaluation of stacks and abatement facil -
. ities, processing and analysis of meteorological and air
- pollution survey data, evaluation of wind loads on structures
- and the preparation of environmental reports. It also con-i ducts a variety of applied research projects, such as field
- evaluations of cooling tower plumes and building downwash, 1 and the analysis of large-scale pollution patterns.
i
! Brookhaven National Laboratory, Upton, New York, 1948-1972, Leader, Meteorology Group l The original objectives . of the Meteorology staff cent ered' on .
i understanding and. forecasting the dispersion conditions af-
- fecting the reactor cooling air. Following solution of these i problems in.1952, the activities were redirected toward basic research in . low-level diffusion and deposition. Prominent j aspects of, this program have been detailed investigations of i diffusion from elevated sources, studies of the low-level l wind speed structure, and the development of specialized meteorological and sampling equipment. The study of particu-late deposition over grids, of samplers in the.open terrain and in forests was also important.
I Significant by-products of these studies have included in-struments, techniques and procedures.for applying the results-to practical problems in air pollution, not only- in the atomic energy field but for industry'in general.
l ueTaonotooecAL avauAnON SERVICES. INC. l
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Page 2 MAYNARD E. SMITH l
American Airlines New York, 1945-1948, Supervisor of Mete- i
, orological Staff, New York Region
. Staff provided terminal and route weather forecasts for oper-ations in the Northeastern United States. Icinq phenomena were important aspects of commercial aviation at this time, since the aircraft were carburetor-equipped and could not operate above 14,000 ft MSL.
United States Air Force, 1941-1945, Major Research in upper atmospheric analysis and forecasting.
Member of forecast team involved in the ferrying of aircraf t across the North Atlantic via Greenland and Iceland.
Assisted in the analysis of all USAF accidents within the continental U.S. in which meteorology was involved. De-veloped a new weather service for the 12th Army Group in Europe to provide meteorological data and forecasts for a variety of ground-force activities.
Professional Organizations and Committees:~ -
4 American Meteorological Society Air Pollution Control Association American Meteorological Society / Environmental Protection Agency Steering Committee on Atmospheric Diffusion Modeling, 1981 to present.
Invited Participant & Panel Chairman, AMS-EPA Workshop on
" Quantifying and Communicating Uncertainty in Regulatory ' Air Quality Modeling," Woods. Hole, MA, Sept., 1982.
Invited Participant & Panel Chairman, EPA Workshop on "On-Site Meteorological Instrumentation Requirements to Charac-i terize Diffusion From Foint So ur ces ," Raleigh, NC , ' Jan . , -
i- 1980. '
Invited Participant & Panel Chairman, EPA Workshop in Rough Terrain Modeling , Raleigh , NC, July, - 1979..
Invited Participant, EPA - Conference. on Modeling Guideline, Argonne National Laboratory, February, 1977.
l METEOROLOGICAL EVALUATION SERVtCES. INC.
e Page 3 MAYNARD E. SMITH
. Steering Committee, Large Power Plant Effluent Study, Air Pollution Control Organization, Eavironmental Protection Agency, 1969-1973.
Chairman, Task Group, Dispersion of Airborne Effluents, American Society of Mechanical Engineers, 1966-1968.
Publications:
Mr. Smith has published approximately 100 articles in vari-ous journals, particularly the American Meteorological Society, the Air Pollution Control Association, and Atmos-pheric Environment. The most important are:
Recommended Guide for the Prediction of Dispersion of Air-borne Effluents, Amer. Soc. Mech. Engineers (Chairman of Task Group preparing document), June, 1968.
- The Influence of Atmospheric Dispersion on the Exposure of Plant to Airborne Pollutants, Phytopathological Soc. 58, -
(8), 10-85-88, 1968.
An Improved Method of Estimating Concentrations and Related Phenomena f rom a Point-Source Emission, J. Appl. Met., Oct.
1966.
The Variation of Effluent Concentration from an Elevated Point Source, AMA Archives of Indus. Health 14, pp. 56-68, July 1956.
Relation of Gustiness to Other Meteorological Parameters, Jour. of Met., V. 10, No. 2, 121-126, 1953.
Atmospheric Dispersion at Brookhaven National Laboratory, Int. Jour. Air and Water Poll. 10 (2), 125-135, Feb., 1966.
Snowfall Observations from Natural-Draft Cooling Tower Plumes, Science, V. 193, 1239-1241, 1976.
Improvement of Ambient SO2 Concentrations by Conversion from Low to High Stacks, Jour. APCA, V. 25, No. 6, 1975.
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. Transport and Diffusion Modeling, 1980. Position paper prepared at the request of the American Meteorological Society.
Atmospheric Modeling for Emergencies, Plant Operations Progress, American Institute of Chemical Engineers, Vol. 2, No. 1, 1983.
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s PATRICK T. BRENNAN Education:
State University of New York at Stony Brook, MS, Atmospheric Science, 1978 State University of New York at Oswego, BA, Meteorology, 1974 Experience:
Meteorological Evaluation Services, Inc., Amityville, New York, 1974 to Present, Meteorologist Since joining Meteorological Evaluation Services, Mr. Brennan has been involved in the meteorological aspects of nuclear power plant operation and licensing, including preparation of '
Safety Analysis (FSAR) and Environmental Reports (ER). Most recently this has involved _ development and application of Class A and Class B dispersion models to meet NRC requirements for nuclear accident preparedness, and interpretation and application of other post-Three Mile Island requirements.
Other experience includes application and modification of EPA UNAMAP series dispersion models, particularly for multiple-source applications, coal conversion studies, and preparation of testimony for State Implementati~on Plans (SIP) hearings for fossil-fuel power plants and smelters. He has also partici-pated in an extensive research program to study the effects of local meteorology on the behavior of large natural-draft 4
cooling tower plumes.
Graduate research involved the application of boundary layer similarity concepts in regulatory modeling. Author of publi-cations on cooling tower plume behavior and dispersion mete-orology.
Lake Ontario Environmental Laboratory (LOTEL), O'wego, s New York, 1972-1974, Meteorological-Technician Operation of weather radar equipment as part of the Inter-national and Field Year for the Great Lakes (IFYGL). Reduction analyses of meteorological data for - power plant envi-ronmental impact statements. -
- Professional Organizations
1- American Meteorological S'ociety l- American Nuclear Society Certification: -
Named by the American Meteorological - Society in 1982 as a Certified Consulting Meteorologist (CCM).
METWOROLOQlCAL EVALUATION SERVCES. INC.
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Page 2 PATRICK T. BRENNAN Publications:
The Observed Rise of Visible Plumes from Hyperbolic Natural-Draft Cooling Towers, Atmospheric Environment, V. 10, 425-431, June, 1976.
~ Behavior of Visible Plumes from Hyperbolic Cooling Towers, Proceedings of the American Power Conference, V. 38, 732-739, 1976.
Comparative Measurements on Two Adjacent Meteorological Towers, Proceedings of the Joint Conference on Applications of Air Pollution Meteorology, Salt Lake City, Utah, 154-159, November, 1977.
The Regulatory Implications of Using Airport Meteorological Data Instead of Onsite Data in Air Quality Modeling, lith NATO-CCMS International Technical Meeting on Air Pollution Modeling and Its Applications, Amsterdam, The Netherlands, pp. 483-494, 1980.
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CHARLES L. HOSLER l ,
Short Biographical Sketch
! Born in Honey Brook, Pennsylvania - 1924 l
l Studied at The Pennsylvania State University, Bucknell University and Massachusetts Institute of Technology. Received B.S. 1947; M.S. 1948;
. Ph.D. 1951 in Meteorology from The Pennsylvania State University.
Served in the United States Navy 1943-1946 on small craft and as aerologist and observer in typhoon reconnaissance in Pacific Asiatic Theatre.
Since 1948 has been employed at Penn State as Instructor, Assistant Professor, Associate Professor, Professor of Meteorology and Head of the Department of Meteorology and is currently Dean of the College of Earth and Mineral Sciences. The College of Fr-th and Mineral Sciencen carried out a broad program of instruction anc research aimed at the application and extension of our knowledge of the earth and its environment. The College has a total budget of $20,000,000, 2,000 undergraduate and 500 graduate students.
Has served as consultant to the President of the United States, United States Senate Committees, The White House Office of Science and Technology Policy, The Secretary to the Interior, and various federal agencies and committees, and as an industrial consultant on prediction of fall-out, air pollution, design of satellite experiments, weather modification, and environmental effects of power plant cooling towers and pollution, etc., and aa an expert witness in a number of -
court cases hinging upon weather phenomena. Has published over 80 scientific papers.
For the past 15 years Dr. Hosler supervised and participated in research on the nature and behavior of cooling tower plumes and their environmental impact. Most of this work was done at the Keystone Station in Pennsylvania but also included studies in Tennessee, Alabama, Georgia, Virginia, New York and at Three-Mile Island in Pa.
He also visited installations in Switzerland and Oreat Britain in connection with this work. Dr. Hosler also contributed to the design of drift collectors and cooling tower conficurations to obtain ,
maximum plume rise.
He serves on numerous committees and panels for the Environmental Protection Agency, National Oceanic and Atmospheric Administration, The National Academy of Sciences. He is Chairman of the Board and Acting President of the University Corporation for Atmospheric Research of Boulder, Colorado which employs 850 people and engages in a wide range of atmospheric research with a budget of $70,000,000..
He was elected president of the American Meteorological Society in 1976 and was elected to the National Academy of Engineering in 1978.
Member of: American Meteorological Society (Fellow)
American Geophysical Union American Association of University Professors American Association for the Advancement of Science Sigma Xi Tau Beta Pi Alpha Phi Omega 8/8/83
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s :' .. - 1 COMMONWEALTH OF PENNSYLVANIA :
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COUNTY OF PHILADELPHIA :
J. S. Kemper, being first sworn, deposes and states:
That he is Vice President of Philadelphia Electric Company, the Applicant herein; that he has read the foregoing Applicant's Answers to Intervenor Frank Romano's First Set Of Interrogatories On Carburetor Icing Contention and knows -
the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
G.L S LL .
/Vice President Subscribed and sworn to before me this //N day of August, 1983.
. M Notary Public PATRICIA D. SCHOLE Isotary Putsc, Philadelphia, Phdadelphia Co.
bly Comaussion Empires February 10, 1988
e DAVID E. SEYMOUR Ed ucation: ,
Rutgers University, 1972-1976, MS, Meteorology l Purdue University, 1964-1969, BS, AAS, Professional Pilot Technology Ex perience:
f-Meteorological Evaluation Services, Inc., Amityville, N.Y.,
(formerly Smith-Singer Meteorologists, Inc.) 1973-Present, Consultant Meteorologist - Pilot. ,
Mr. Seymour has provided consulting assistance to MES Inc. on a number of airborne field evaluations. These have included atmospheric diffusion studies, evaluation of stacks, cooling tower plume behavior, and sea-breeze research.
He has conducted extensive airborne cooling tower plume re-j search, and was responsible for the training and checking of the twelve other commercial pilots involved -in the MES/AEP cooling tower research program. He has also been responsible for all airborne photography, wind aloft calculations, and aircraft procurement and maintenance for the numerous aircraft .
involved in MES studies and proposals since 1973.
United Airlines, Denver, Colorado, 1969-Present, Flight Officer Pilot on Caravelle and Boeing 727, 737 Aircraf t. Presently Flight Officer on Boeing 727.
Glider Pilot's Ground School, Rochester, New York, 1975-Present, Director.
The ground school provides the necessary education for pilots as required by Federal Air Regulations. Mr. Seymour formed the company in 1975 and now serves as a Director.
Purdue University, West Lafayette, Indiana 1968-1969 l
l Flight Operations Instructor for DC-6, Dept. of Aviation l Technology 1
Flight Officer on DC-3, DC-6 Aircraft i Chief Flight Instructor - Purdue Glider Club METEOROLOGICAL EVALUA110N SERVICES,INC.
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,s t 0 Page 2 DAVID E. SEYMOUR Pilot' Qualifications:
Commercial Pilot: Airplane Single & Multi-engine land , Glid-er, Instrument, Douglas DC-3 Flight Engineer: Turbojet Powered Flight Instructor: Glider, Advanced & Instrument Ground In-structor Federation Aeronautique Internationale Gold Soaring Badge (USA #300) with two diamonds, 8 state soaring records Total Flight Time: 5000+ hours (1983)
Professional Organizations:
Airline Pilots Association Soaring Society of America American Meteorological Society Publications:
John E. Amos Cooling Tower Flight Program Data, December 1974
- March 1975, Available from American Electric Power Service Corporation (1975).
John E. Amos Cooling Tower Flight Program Data, December 1975
- March 1976, Available from American Electric Power Service Corporation (1976).
Cooling Towers and the Environment, Jour. APCA, Vol. 26, pp.
582-584 (1976).
The Observed Rise of Visible Plumes From Hyperbolic Natural-Draft Cooling Towers, Atmospheric Environment, Vol. 10, pp.
425-431 (1976).
l l Snowfall Observations From Natural Draft Cooling Tower Plumes, Science, Vol. 193, pp. 1239-1241.
l Glider Pilots Ground School (1977).
l METEOROLOGICAL EVALUATION SERVICES,INC.
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DOCKETED USNRC' UNITED STATES OF AMER A
. NUCLEAR REGULATORY COMMISSION' 0FFICE OF SECRETA."u-00CKETinG & SERVl BRANCH In the Matter of )
)
Philadelphia Electric Company ) Docket Nos. 50-352
) 50-353 (Limerick Generating Station, )
Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Answers to Intervenor AWPP's (Romano) First Set of Interrogatories on Carburetor Icing Contentions" dated August 12, 1983, in the captioned matter have been served upon the following by
> deposit in the United States mail this 12th day of August, 1983:
Judge Lawrence.Brenner (2) Docketing and Service ~Section Atomic Safety and Licensing Office of the Secretary
. Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555
- i Ann P. Hodgdon, Esq.
Judge Richard F. Cole Elaine I. Chan, Esq.
Atomic Safety and Licensing Counsel for NRC Staff Board Office of the Executive U.S. Nuclear Regulatory Legal Director Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Judge Peter A. Morris Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission
.. Washington, D.C. 20555 Washington, D.C. 20555 Atomic Safety and Licensing Philadelphia Electric Company _
Appeal Panel ATTN: Edward G..Bauer, Jr.
U.S.. Nuclear Regulatory -
Vice President &
Commission General Counsel Washington, D.C. 20555 2301 Market Street' Philadelphia, PA 19101
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Mr. Frank R. Romano David Wersan, Esq. Consumer 61 Forest Avenue Assistant Advocate Ambler, Pennsylvania 19002 Office of Consumer Advocate 1425 Strawberry Square Mr. Robert L. Anthony Harrisburg, PA 17120 Friends of the Earth of the Delaware Valley Steven P. Hershey, Esq.
P. O. Box 186 Community Legal 103 Vernon Lane Services, Inc.
Moylan, Pennsylvania 19065 Law Center North Central Beury Bldg.
Mr. Marvin I. Lewis 3701 North Broad Street 6504 Bradford Terrace Philadelphia, PA 19140 Philadelphia, PA 19149 Angus Love, Esq.
Judith A. Dorsey, Esq. 101 East Main Street 1315 Walnut Street Norristown, PA 19401 Suite 1632 Philadelphia, PA 19107 Mr. Joseph H. White, III 8 North Warner Avenue Charles W. Elliott, Esq. Bryn Mawr, PA 19010 Brose and Postwistilo 1101 Building Robert J. Sugarman, Esq.
lith & Northampton Streets Sugarman & Denworth Suite Easton, PA 18042 510 North American Building I 121 South Broad Street Jacqueline I. Ruttenberg Philadelphia, PA 19107 Keysteon Alliance 3700 Chestnut Street Director, Pennsylvania Philadelphia, PA 19104 Emergency Management Agency Basement, Transportation Thomas Y. Au, Esq. and Safety Building Assistant Counsel Harrisburg, PA 17120 Commonwealth of Pennsylvania DER Martha W. Bush, Esq.
505 Executive House P.O. Box Kathryn S. Lewis, Esq.
2357 Harrisburg, PA 17120 City of Philadelphia Municipal Services Bldg.
Thomas Gerusky, Director 15th and JFK Blvd.
Bureau of Radiation Philadelphia, PA 19107 Protection Department of Environmental Spence W. Perry, Esq.
Resources Associate General Counsel 5th Floor, Fulton Bank Bldg. Federal Emergency Third and Locust Streets Management Agency Harrisburg, PA 17120 500 C Street, S.W., Rm. 840 Washington, DC 20472 Mdik J. Wetterhahn
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