ML20081C814
| ML20081C814 | |
| 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 8310310353 | |
| Download: ML20081C814 (5) | |
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AIR and WATER oouerto USNRC Pollution Patrol October 21, 1983 55 06127 P12IO8 BROAD AXE, PA.
U. S. Nuclear Regulatory Commission Washington, D.C. 20555 0FFICE OF SECMIN 00CKETING & SEiWIC'-
1 3 RANCH Before The Atomic Safety And Licensine Board In The Matter Of s
PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 (Limerick GeneratingStation, 50-353 Units 1 and 2)
AWPP STATEMENT OF MATERIAL FACTS AS TO WHICH IT IS CONTENDED THAT THERE EXISTS A GENUINE ISSUE TO BE HEARD (1)
Temperature and moisture conditions in cooling tower plumes are often significantly different from the ambient air beyond one quarter (1/4) mile. (See AWPF Answers To Applicant's 1-0)
(2)
Visible Cooling iower plumes are generally surrounded by an invisible layer (which increases the ef fective size of the plume) whose temper-ature and moisture conditions are similar to those of visible plumes.
(See under Discovery 13, item U) (also reference at (3) below).
(3)
Some cooling tower plumes are totally invisible. (See Fig. 3.10 of 3.3.4 (Also see " Cooling Towers And Environment" Smith, of ES LGS Nov. 1973).
'Seymourier al, Oct. 1974, fi'g.10).
(4)
The natural climate r. ear Lir.; rick, as a resuh ot' the terrain and gca-eral proximity of the facility to the Schuylkill River and other water bodies, is one of relatively high moisture conditions.
From the air-a sort of mini-separate atmosphere. exists enveloped in haze and mois-ture around communities such as Pottstown and other river communities.
l (5)
Operation of the Limerick cooling towers will add sufficient moisture to the air in the vicinity of the plant to increase the number of times per year that devpoint or near dewpoint conditions exist. (See test 06 and 06 of Amos Cooling Tower Studies-Dec. 1974 -March 1975)
(6)
When ambient air conditions are near the dewcoint a pilot who flies in-to a visible or invisible plume can experience very rapid carburetor icing. (See " Carburetor Ice Still A Threat" AOPA Pilot, p. 110, Aoril 1980) 8310310353 831021 PDR ADOCK 05000352 C
AIR and WATER Pollution Patrol BROAD AXE, PA.
(2)
(7)
The traffic patterns for the three airports are roughly 1,000 feet above ground.
(8)
When tower moisture has augmented moisture conditions to approach the dewpoint, or such indications already exist, the tower plume cannot rise above the traffic pattern. (See Amos Cooling Tower Studies-graphics -05;06 Dec. 1974 - March.1975)
(9)
Such a low level plume, not able to significantly move upward, dispen-ses laterally and ipereases the moisture in that localized area.(See
- 8 reference)
(10) The three airports in the immediate vicinity of Limerick require pilots landing at the airports to conform to a left-hand traffic pattern.
(11) A pilot attempting to land at any one of the three nearby airports may unknowingly be forced to remain in the localized airspace that now has a higher potential for causing carburetor ic'ing, due to the need to con-form to the left-hand pattern at a specific altitude.
(12)
Depending on the direction from which a pilot sopraoches the arca, he may be required to circle the airfield more than once, remaining in the carburetor icing conditions for over 10 miles. This situation may also occur due to another airplane trying to land at the same time or, inter- -
ference by the ground traffic at the airport threshold.(SeeAWPP Answers to Applicant's #9 Material Facts)
(13) Carburetor heat would not be used during this tice because maximum power is needed on a "go around" and application of carburetor haat can cause a 15% power loss. (See Discovery 1, 2A)
(14) A VOR (Omni) (116.5 mh) is stationed within one mila of the Literick facility. This Omni is uced for radio guidance by pilots coming to or passing through the area and, therefore, causes more traffic in the Limerick tower plume-affected area than otherwise.
AIR and WATER Pollution Patrol BROAD AXE, PA.
~
(3)
(15) There are therefore an abnormally large number of pilots coming to, passing thourgh the plume-affected area, who will unknowing be expos-ed to increased risk of carburetor icing.
(16) Recently soloed pilots and pilots with low time flying experience, be-cause planes used do not have sensing equipment, are not sufficiently trained or capable of recognizing incipient carburetor icing, or until too late to respond,. (See Discovery 1, 2A )
(17) Carburetor ice isnot a condition easily recognized, especially by new or inexperienced pilots. RPM or manifold pressure reduction may be caused by carburetor icing but may also be caused by water or dirt in the fuel, fuel with improper octane rating, vapor lock, fouled spark plugs, slip-ping tlirottle or turbulent pitching.
(18) 98 - 99% of the planes using the three airports in the immediate vicin-
'ity of Limerick do not have carburetor ice sensing equipment. -
. r i,
,~w_-a.
(19) 1FR aircraft, even if they are insturment-equipped, are not required to have such sensing equipment. (Fed.-AviationtRegs, Part 5 of 91.33).
(20) Carburetor ice cannot be controlled in a precise manner.
Use of car-buretor heat when it is not needed (such as when RPM reduction is due to unrelated factors), may lead to loss of power at critical times or aggravate the condition responsible for RPM reduction. (See Discovery s
11, 2A )
(21)
"Ultralight" airplanes are regularly; permitted to use airports in the vicinity of Limerick. These planes have no carburetor heat and the pilots flying these craft do not have to be licensed or trained in any I
8**
way. The sunset Airstrip g geeg rated field.
is to benes *w"ctggh,t lt eo Air and Water Pollution Patrol
//
A MW Fra'ni R. Romano, Chairman 61 Forest Ave.
Enc: Appendix '4 y f~4 Ambler, Pa. 19002 I certify that copies of the foregoing have been served by first class mail on the service list.
AIR and WATER Pollution Patrol
. BROAD AXE, PA.
October 21, 1983 APPENDIX TO STATEMENT OF MATERIAL FACTS RE CONTENTION V-4 Two significant facts invalidate the statements in AFFIDAVIT OF MAYNARD E. SMITH AND DAVID SEYMOUR IN SUPPORT OF A MOTION FOR
SUMMARY
DISPOSITION RE-
~
CARDING CONTENTION V-4, dated Sept. 22, 1983.
First, the statements in the affidavit were made in response to content-ion V-4 as worded previous to AWPP's changed wording of contention V-4, accepted by the Atomic Safety and Licensing Board at the prehearing on October 17, 1983.
Whereas Smith and Seymour's statements related to " carburetor icing of aircraft flvine into the Limerick cooline tower nlume(s)", the accepted re-wording re-quires statements regarding " carburetor icing of aircraft fivinz into the air-space affected by the Limerick cooling tower plume (s)".
Secondly, Ultralights are not under the jurisdiction of the Federal Avi-ation Authority or its regulations, and do not even require a license. Ultra-lights have no carburetor heat as it relates to potential for carburetor ice.
Ultralights fly as slow as thirty miles per hour which very significantly in-creases their time in a plume or plume effect, and their very light weight (as low as 250 lbs.) makes them extremely vulnerable to turning over into a fatal spin with turbulence that would not so affect a regular airplane. Sunset Land-ing Strip, concentrated Ultralight airport is only five miles from Limerick.
Frank R. Romano AWFP
AIR and WATER Pollution Patrol
. BROAD AXE, PA.
Oct. 21, 1983 APPENDIX B CONCLUSION BY AWPP(ROMANO) RE CARBURETOR ICE CONTENTION V-4 First, Applicant seeks to dispose of ANPP's contention that the release of 35milliongallonsofwaterperdayasvaporYiatheLimerickreactorplumewill not increase the potential for carburetor ice and hazzards to pilots flying in the air space affected by the plume (s), visible or invisible. The Applicant's studies were all done via experiments wherein the test planes gathered data re-garding tine, temperature, and moisture conditions while fiving into the visible plume (s). The test method was not set up to fly the test planes so asto show conditions in the airspace affected by the clume(s), both visible and invisible 4 By improperly setting up the test, the effect of the invisible portion of the visible plume, and the effect of the totally invisible plumes were not shown as it should have been. @ New contention wording accepted by ASLB Oct.17,1983.
Second, the Applicant assumed that beyond one-quarter mile the temperature and moisture conditions in the plume were not significantly different than the ambient air. AVPP's response to Applicant's statment of Material Facts details numerous references which together with AWPP's statements of Material facts shows conclusively that Applicant wa.s incorrect in that there exists sufficient difference in the airspace affected by the Limerick plume (s)(both visible and invisible, to increase the potential for carburetor ice both in regular airplanes flown in the Limerick area, but more particularly with"Ultralights", which have no carburetor heater.
Third, Applicant's statements were based on limits of time during which an airplane could be flyine into the alume(s), whereas such time intervals exooses a carburetor to icing for shorter periods than fivine into the airsnace affected by the olume(s).
Fourth, the Applicant incorrectly regards the carburetor heat lever as an instant response to reduced RPM or manifold pressure as the cause for carburetor ice; regards the lever as an instrument so controllable as to solve all problems of carburetor ice by experienced or inexperience pilots as to all cause:; of RPM reduction.
Using RPM drop as absolute notice of carburetor can aggravate conditions when RPM drop is due to many other possibilities. The above indicates V-4 has genuine issues to be heard.
& M
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AWPP, Frank R. Romano