ML20080S607

Response Supporting Motions to Reword Contention V-4. Applicant Objections to Rewording Deal W/Semantics Only. Effect of Steam Release Not Limited to Visible Plume Only. Certificate of Svc Encl

ML20080S607
Person / Time
Site:	Limerick
Issue date:	10/08/1983
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	Brenner L, Cole R, Morris P Atomic Safety and Licensing Board Panel
References
NUDOCS 8310180419
Download: ML20080S607 (1)

Text

y. W %5D..3.R?Eb AIR and WATER h' Pollut. ion Patrol 00UETET

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BROAD AXE, PA.

'83 OCT 17 P3:06 kFFM OF 5M w t0Cxtist,G & SERvm Oct. 8,19k$

Atomic Ssfety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.

Judge Laurents Brenner; Peter A. Morris ; Richard F. Cole In The Matter Of PHILADELPHIA ELECTRIC COMPANY (Limerick Cenerating Station Units 1 and 2)

Re Applicant's Answer to Motions To Reuord Contentions I-62 and V-4, and Applicant's opposition to re-wording of Contention V-4, intervenor AWPP (Romano) states chat in reading the Discove'ry material supplied by Applicant it was obvious tha t there was an effort to limit the effect of 35 million gallons of water in the air outside approximately 1/4 mile, and to interpre. my e contention as invol-ving only the visible plume. ,

I have stated in support of Contention V-4 that my concern is to insure safety for pilots not only within the limits of P.E.'s 1/4 mile visible plume, but the effect of the moisture from the towers visible and invisible as it aff-ects potential for carburetor ice and danger to pilots.

To dismiss the moisture from the towers because it is invisible, and to endevor to dismiss the effect ef the moisture because it is not in the shape of a plume, is to play games with words instead of fact. I move that the Board permits the changed wording of Contention V-4, in that it definitely is an im-portant part of the issue which the Applicant seeks to dismiss with no other justification than to blame the Board for the previous wording.

Respectfully submitted, Fran R.

b-

~ano, Chaiman AIR & WATER POLLUTION PATROL 61 Forest Ave.'

FRR/j eh Ambler, Pa. 19002 I certify that the above has been served by first calso mail upon the latest service list.

8310180419 831008 PDR ADOCK 05000352 O PDR Q