ML20081F580

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Advises of Author Intent to Testify in Place of Expert Witness Unable to Testify Re Summary Disposition of Contention V-4.Related Correspondence
ML20081F580
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 10/28/1983
From: Romano F
AIR AND WATER POLLUTION PATROL
To:
Atomic Safety and Licensing Board Panel
References
NUDOCS 8311030135
Download: ML20081F580 (1)


Text

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l AIR and WATER L_. C:x - . . . . _Z. _ ,f Pollution Patrol Oct. 28, 1983 BROAD AXE, PA. 5

'83 OCT 31 Pl2:15 U. S. Nuclear Regulatory Comnission Atomic Safety and Licensing Board 11ashington, D. C. 20555 h .g ORi NCH In the !!atter of Pll1LADELPHIA ELECTRIC CD'IPANY Docket Nos. 50'352 (Linerich Generating Station 50-353 Units 1 and 2)

An expert uhn was to testify found yet unknown scheduling difficult and as a result cannot testify in AUPP's behalf as previously thougljt possible.

I, therefore, uill be a factual uitness and ny qualifications are as indicated in " Qualifications of Frank R. Ronano Relating to Sunnary Disposi-tion of Contention V-4" notarized October 24, 1083 and received by ALSB on October 25, 1983 as required.

I will testify on facts that vill shou non-validity of nany statments and conclusions, re reports on tests referenced by Applicant and Staff relating points in Sunnary Disposition of Contention V-4 I will testify to facts that shou that Applicant's referenced tests and Affiant's statements in support of Sunnary Disposition did not take into consideration "Plune Affect" outside the visible plune, nor studies in the invisible plume. I will testify that Appli-cant's referenced testing used improper equipnent, (planes, etc.); did not test effect on planes (ultra lights)that do not have carburetor heat, and did not consider effect on airspace of the localized Limerich plume rel. ease under near saturated, saturated, cold, stagnant conditions over 1, 2, 3 day on traffic pattern conditions re increased potential for carubretor icing. I uill test-L ify that Ultra-lights are so unregulated as to not even require pilot train-inn or experience or license and ultralights can get carburetor ice urthout flying into or through clouds as apparantly seems to be the Applicant's-impression.

Resp'ectfully, ,J-8311030135 831028 ~,s s# <*^ W ,2 '. _.)

, PDR ADOCK 05000352 -

Frank R. Romano G PDR "~

AWPP ,