ML20081C731
| ML20081C731 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/21/1983 |
| From: | Romano F AIR AND WATER POLLUTION PATROL |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20081C736 | List: |
| References | |
| NUDOCS 8310310336 | |
| Download: ML20081C731 (10) | |
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AIR and WATER DOCKETED Pollution Patrol October 21,1983MC BROAD AXE, PA.
U.S.' Nuclear Regulatory Commission
'83 OCT 27 P12:08 Washington D.C.20555
(?l "'.~ y " [C ? i m Before The Atomic Safety And Licensing Board
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In The Matter Of PHILADELPHIA ELECTRIC COMPANY (Limerick Generating Station, Units 1 and 2)
Docket Nos. 50-352 and 50-353 Intevenor AWPP (Romano) responds to "Apolicant's Statement of Material Facts As To Which There Is No Genuine Issues To Be Heard", dated Sept. 17, 1983 re Motion For Summary Desposition Of Contention V-4, as follows:
APPLICANT'S 1-7 Meteriological studies at Limerick were compared with studies at Philadelphia and Allentown to check their validity for tower or other effects of weather in the Limerick area. Whereas the wind direction at Allentown and Philadelphia are gener-ally SW and WSW respectively, the wind at Limerick is predominately NNW, as per. 2 3.2.1.1.4 of LGS FSAR. The choice for comparison was not the best if to be used in computer modeling.
Further comparison with studies at Peach Bottom were made and apparantly judged suitable for modeling. AWPP states Peach Bottom is too far away to give reliable comparison and valid interpolation.
APPLICANT'S S AWPP disagrees with Applicant's statement at 8 that conditions in plumes great-er than 1/4 mile are only slightly different than ambient air. AWPP says temoera-ture and moisture differences beyond 1/4 mile are often evident in well-defined vis-ible plumes seen up to and over 5,000 feet above ground as determined by elevated j
haze layers (see 2-27-75 John E. Amos 1974-75 American Electric Service Corn. in par-ticular tests numbered 48A, 10B, 12, 23) and under introductionn 2nd paragraph in Discovery 11, 2E.
Also see tests of 1/15/75 in Amos reference showing cooling tower aluces above 4,000 feet through 15 to 20 F ambient air, as also shown in 3.3.4 chapters of Envir-onmental Statement Nov. 1973 In order for those plumes to rise more than 1/4 mile plumes must be buoyant. Buo-l l
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(2) yancy is caused by differences in temperature, water vapor, and specific gravity of air. Plumes that keep rising to 5,000 and 6,000 feet can only do so because of buoyancy caused by these differences.
In those situations where conditions inside and outside a visible plume are similar (these plumes are not as buoyant and therefore do not rise as much) the potential for increased carburetor ice still exists. This is due tocthe fact that ambient air conditions already present the potential for carburetor ice, and even a small change in those condit, ions, due to localized mixing of ambient air with the plume, may trigger the carburetor icing event.
j As a plume rises, equiliburn with ambient air tends to be established by gradual evaporation which still takes place at the haze layer, many times far above 1/4 mile. That means, for evaporation to take place at 3,000 to 4,000 feet at a haze layer, there must be a sufficient saturation deficit to permit it.
This means that the moisture! content of the plume at the haze layer at the time it is evapor-ating is not the same as the ambient air, as stated by' Applicant. 'Page 11 in Appen-dex to John E. Amos Cooling Tower Flight Program Data (Dec. 1975 - March 1976) states a bent plume rises to a stabilitzed height (which most often is the haze layer which can be 4 to 5,000 feet high) and presist at that altitude until all evaporation has taken place. Also, an invisible plume surrounding the visible plume has higher air-water mixing ratios and higher temperatures than the ambient air (see Apendex B, Part 1 of " Prediction of Temperature and Moisture Distribution On Cooling Tower Plumes", Calabrese, Halitsky and Woodward (Discovery 13, item u)
APPLICANT'S 9 09 states an airplane could not remain in the plume from the Limerick towers a sufficient time to develop signigicant carburetor icing even if equipment built in the aircraft for dealing with icing was not used.
It is evident that Applicant's point #9 does not appreciate the ti=e that may be required for a pilot to remain in the pattern of an airport. Applicant apparqnt-ly feels the pilot comes straight in and lands from which ever direction he is app-roaching an airport.
Airports require "left hcnd" pattern approaches to an active one-direction run-way which is changed depending on wind direction so that pilot will land into the
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(3) wind, this many time's involves circling the field in the plume effect.
Very important, also, is the radio guide VOR, 116.5 1 mile from the Limerick facility which is used by planes coming and going in all directions like spokes of a wheel going to and out from the hub.
Consider a pilot coming in on approximately a 110 heading over the Limerick towers toward the Perkiomenville airport whose traffic pattern is as close as 6 miles from the Limerick complex. (see 2.2.2.5 of LGS FSAR). With conditions that bring the plume to and beyond the Perkiomenville landing strip the pilot would fly 6 miles to the airfield while"affected by the plume. In the required left-hand pat-tern landing procedure, he would go as much as 5 more miles during upwind, crosswind and downwind for active runway 27, That's already 10 miles. And if he could not land because of other planes in the pattern as often happens, he would have to do a "go around" requiring 6 more miles during which time he would not use carburetor heat because maximum power is needed on a "go around" and carburetor heat can entail a 15% power loss (see Aircraft Carburetor Icing Studies 1st page Discovery 1, 2a)
For reference, also see p-9 of " Cooling Towers And The Environment", Maynard Smith, David Seymour, et al, October 1974 APPLICANT'S 10 Re Applicant's point 10, re only a "few minutes" of flight time in plume. "Few minutes" is definable only with speed given.
In addition, see #9 above.
APPLICANT'S 11 I disagree with Applicant's point 11 based on studies that state that ice can form instantaneously, in 1/2 minute, in 4 minutes rather easily. Point 11 assumes danger only from medium to heavy icing (see page 8-c-8 Discovery 11, 2q) Also see figure 4, page 5 and 2nd paragraph under Base-line Carburetor Icing, page 5 of Dis-covery 11, item 2A.
Also see AWPP number 9 above.
Even at 8 minutes, according to table 8-11 of Discovery ll,2q, a "go around" would require 12 nautical miles and 7 minutes (2 X 3.59 min.) at 100 miles per hour to give double the icing at 3.59 min.
But at 80 to 90 knots in student planes it could be 10% more time and more icing. Further, as per " Carburetor Ice: Still A Threat" AOPA Pilot, p. 110, April 1980, as to the ARP probe, it is stated that " ice can form and shut down cn engine in less than 1/2 minute.
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(4)
APPLICANT'S 12 I disagree with Applicant's item 12 that "very rapid mixing" occurs under all conditions. Very rapid mixing occurs only when there is a large difference in moi-sture content between the plume and ambient air and moderate to strong wind con-ditions. When moisture differences are less, particularly at temperatures of rough-ly 30 to 65 and no wind, =oisture is not diluted...it is concentrated because of immediate condensation.
APPLICANT'S 13 I disagree with Apolicant's #13 statement. And when stagnant conditions remain for three or more days the accumulation of 100 to 120 million gallons of water from plume will have a greater effect. See 12 above.
APPLICANT'S 14 As to Applicant's #14 AWPP has no comment.
APPLICA';T'S 15 As to Applicant's #15 AWPP has no comment.
APPLICANT'S 16 AWPP disagrees with Applicant's #16 See 8 above.
APPLICANT'S 17 AUPP disagrees with Applicant's #17 For an entity to be visible against an invisible ambient air, light must be affected sufficiently by some constituent of che' entity which is not present in the ambient air.
Further, visible plumes are suf-ficiene.ly buoyant to rise to haze layers which many times are many thousands of feet above the terrain as explained in 8 above. Also see 3.3.4, Fig. 3-10, 3-11, 312 of ES LCS Nov. 1973.
APPLICANT'S 18 AVPP disagrees with Applicant's #18 because the Keystone towers are much shor-ter, they are a different type hyperbolic tower, and western Pennsylvania weather, as at Keystone does not have "nearly identical climatic conditions" as Limerick.
APPLICANT'S 19-21 AWPP questions Applicant's nos. 19, 20, and 21 statements on the basis that
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.(5) aircraft type is not given and on the basis that those flights made in 1973-74 did not have an accurate moisture measurement system.
(see p-4 of Discovery 11, item 2 d).
And the balance of the tests were done only from December to March instead of all year around. (see Amos tests of Dec. 1975 - Mardi 1975)
APPLICANT'S 22 AWPP questions SACTI's use of temperature, moisture and load as key factors.
See third and fourth paragraphs of the introduction on " Empirical Relationships Between Meterological Variables and Visible Plumes from Large Natural Draft Cooling Towers", by MES of Amityvilie*'N.Y.
APPLICANT'S 23 AWFP questions Applicant's #23 point in that the predominant wind direction which would have the longest plume is toward the East...not toward the West as stated, (see wind direction studies in LGS-FSAR).
APPLICANT'S 24 AWPP questions Applicant's #24 in that under saturated air conditions with temperatures in the vicinity of freezing, and stagnant conditions, the plume would join the low cloud deck, and not dissipate. (See Fig. 3.12 under 3.3.4 of ES LCS Nov. 1973.
APPLICANT'S 25 - 31 AWPP agrees with Applicant's #25, 26, 27, 28, 29, 30, and 31.
APPLICANT'S 32 AWPP disagrees with Applicant's point #32 that it would take approximately 8 minutes under adverse conditions without carburetor heat to cause medium to heavy carburetor ice that would represent a significant hazard to aircraft.
See 11 above that refutes such statement.
APPLICANT'S 33 I question Applicant's item #33 regarding improbability of carburetor ice for-ming while flying across Limerick tower plume because of time.
If carburetor ice had already started to build up ice and, as referenced in 11 above, which states ice can form within 1/2 minute or even instantaneously...it will form in the 1/2 minute or less going 1 mile across the plume.
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(6)
APPLICANT'S 34 I question Applicant's #34 which states plumes are never more than 1 mile wide on the basis that no mention is made of the distance from the tower, and no mention is made of the invisible plume that extends further than the visible.
APPLICANT'S 35 ARPP. states Applicant's #35 statement is possible, but does not cover the con-dition of slower air speeds, which characterize type of flying and type of plume at fields near Limerick.
APPLICANT'S 36 AWPP disagrees with Applicant's #36 that 10 minutes is necessary to form car-buretor ice under adverse conditions also see 10 & 11 APPLICANT'S 37 AWPP disagrees, as Applicant's #37 point states, that it is impossible that a pilot could inadvertently encounter a plume with proper icing conditions and length of plume and remain in it for 8 minutes or more, See item 9.
Also under such con-ditions carburetor ice could easily take less time as per item 11 APPLICANT'S 38 AWPP disagrees with Applicant's #38 statement that 1/4 mile down wind of a tower conditions inside or outside plume are always identical to those in ambient air.
See AWPP references and statements in 8 above.
APPLICANT'S 39 I disagree with the inference in Applicant's #39 point that pilots are taught about risks of carburetor ice in ground school and trained to use carburetor heat for the purpose of preventing ice formation and therefore.the problem of carburetor ice is solved. Applicant's inference is that the carburetor heat lever is a sephis-ticated accurate instrument that quickly responds and controls, and eleminates the danger of carburetor ice. That certainly is not the case. The teaching is minimal because no instructor wants to be in a plane to teach how to get rid of an already.
iced up carburetor any more than he wants to demonstrate a crash landing. As stated in " Aircraft Carburetor Icing Studies" by Gardner, Moon and Whyte (Discovery 11, 2A) carburetor icing occurs over a wide range of conditions; it is difficult to recognize;
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students, new and low-time pilotsj have insufficient experience to detect carburetor cy the >
ice because its symptoms are similar to those of engin'e problems.
g APPLICANT'S 40 Re Applicant's #40 statement, AWPP agrees on the intended purpose of the car-buretor heat lever.
APPLICANT'S 41 I disagree with Applicant's statement that a pilot's first indication of car-buretor ice is a drop in engine RPM for aircraft with fixed pitch propellers, and a drop in manifold pressure for. aircraft with variable'. pitch propellers; on-the basis that a drop in RPM or manifold pressure could result from many other caqses, such as dirt in the gasoline, vapor lock in gasoline line, water in gasoline, fouled spark plugs, gasoline of low octane, slipping throttle, and meandering pitch in turbulent air. (also see item #39). And unnecessary and confused use of carburetor heat and removal of carburetor heat can lead to worse problems, see p 110 of " Carburetor Ice; Still A Threat" AOPA - April 1980, and p 13 of "Those Icy Fingers In Your Carburetor" under Detecting Carb Ice", first paragraph.
APPLICANT'S 42 I question Applicant's #42 statement on the basis that while fuel injected or turbine engines don't have carburetors, they can get structural icing and air vent icing and fuel icing under enhanced icing conditions resulting from plumes.
APPLICANT'S 43 I question that "the vast majority of small airplanes (fly) at relatively low altitide"' involving up to "10,000 feet", quoting Applicant. The vast majority of small airplanes fly between 1,500 and 5,500 feet-that i s ', in the areas most affected by plumes.
APPLICANT'S 44 I agree pilots are taught to check (the] carburetor haat control (not " controls" as Aprlicant states, since only one rough mechanical lever is the control). As to pilots applying " heat at first indication of carburetor ice" see 41 above.
APPLICANT'S 45 As to Applicant's #45 statement, all visible plumes do not appear as a " cumulus-looking" cloud. Also there are invisible plumes and partially visible plumes.
By Applicant's reasoning, in.the Limerick area the three very close airports will not
AIR and WATER Pollution Patrol BROAD AXE, PA.
(8) be able to operate because pilots.will always be "in or near" visible plume appear-ing as a cumulus-looking cloud.
APPLICANT'S 46 AWPP disagrees with Applicant's 46 statement, in that to avoid flying 2,000 feet horizontally 1,000 feet above or 500 feet below clouds as per VFR rules would mean a student pilot or other pilots could not land at the three plume-influenced airports adjacent to Limerick tower and plumes.
Also such rule does not apply at traffic patterns of uncontrolled airports as is the case with the three ai'rports at Limerick (also see Chape. 5 of " Cooling Tower Plume Induced Flight Safety Hazard" JHU-APL, p 5-1 re Plume Study Data and Airport Traf fic Patterns).
APPLICANT'S 47 As per #46 above.
APPLICANT'S 48 Statement says "IFR (Instrument Flight Rules) a'ircraft...must have carburetor heat controls to be instrument equipoed". ANPP says carburetor heat controls are not required to be insturment equipped.
(see Federal Aviation Regulation, Part (b) of 91.33 APPLICANT'S 49 Applicant says plume from large hyperbolic towers do not cause any build up of local moisture. AWPP disagrees on basis of Dec. 1974 - March 1975 Amos Cooling Tower Studies - see test 05 where tower plumes leveled off close to tower outlet and con-densed to form rain which is an affect on local moisture. Test 14 shows dew point reached at about 1,500 feet which means rain that also affects local air and ground moisture. Also on p 7, " Cooling Towers And The Environment" Maynard Smith, David Seymour, et al, the specific question is asked: "The plume disappears quickly in most cases, but does the invisible water vapor later return to the ground to cause an increase in humidity? The answer is Yes " say the aurthors whose affidavit in.
support of the Su= mary Disposition Of The V-4 Contention.
Also see Fig. 3 of 3.3.4 of ES LCS Nov. 1973.
APPLICANT'S 50 I agree and disagree with the part of Applicant's statement that says " plume from hyperbolic towers originate far above the ground." The plumes are far above as it relates to a person thinking of jumping of f the towers.
But as it realtes to a
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(9) plane flying it is very low above the ground, as is the essance of Contention V-4 Therefore, at tower height above the ground calms do exist. Further Flight Service Stations separate wind information as " surface", "3,000" and higher. They consider tower height the same as surface as it relates to wind speed and calms.
APPLICANT's 51 AWPP agrees with Applicant and used the #51 statement of Maynard Smith in support of AWPP disagreement with Applicant's #8 statement.
On the otherhand AVPP wants to point out that the #51 statement is correct only
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because of Applicant's limitations, namely, " stagnant conditions close to the ground and the winds very light" with no mention of temperature and humidity.
But AWPP dis-agrees buoyancy would exist in stagnant, light winds plus temperature in the freezing and near freezing range and with moisture saturated air conditions, APPLICANT'S 52 AWPP. agrees with statement made.
APPLICANT'S 53 AWPP disagrees, and requests affidavit that states "the meterological data from the National Weather Service, for the afternoon of April 9, 1982, clearly indicate that snow and fog were observed most of the dav at the Philadelphia Airport". Even if that were so for Philadelphia Airport adjacent to two rivers, it d,id not exist at Roxboro which lies approximately 12 miles away and perhaps 350 feet higher.
Further I did not state the incinerator produced " local fog" as the Applicant states.
I said that the incinerator added enough moisture to reduce c'eiling in a normal low cloud deck situation.
(see my statement on Roxboro).
APPLICANT'S 54 No comment...because of lack of references.
APPLICANT'S 55 I disagree that turbulence is not produced by tower plume.
See letter of Aug-ust 15, 1983 to Mr. Darrell G. Eisenhut from Vincent Boyer te NUREG 0974, commenting on the DES.
Under Appendix D at (1) it states " Cooling Tower wake effects do not exist dur-ing low wind speed contidions ".
It infers, however, that wake occurs during high wind conditions.
Further, as per (2), " Hyperbolic cooling towers do not produce sharp down-drafts at moderate to high wind speeds causing 100% ground level releases.
Rather, enhanced turbulence results".
AIR and WATER Pollution Patrol BROAD AXE, PA.
(10)
The turbulence which Mr. Boyer refers to as " enhanced turbulence" may not severely affect standard airplanes, but would be sufficient to turn over and send an ultralight into a fatal spin. With Sunset Landing Strip, to be the new ultralight field only five miles from T.imerick, a serious hazardous cooling tower plume situation exists which Smith and Seymour studies did not at all address.
Respectively submitted, AIR & WATER POLLUTION PATROL k
M R. Ro..mano, Chairman 61 Forest Ave., Ambler, Pa. 19002 l
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I certify that copies of the forgoing have been served by first class mail on the latest service list.
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