ML20081K024
| ML20081K024 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/03/1983 |
| From: | Romano F AIR AND WATER POLLUTION PATROL |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20081K012 | List: |
| References | |
| NUDOCS 8311090235 | |
| Download: ML20081K024 (5) | |
Text
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AIR and WATER DOCKETED Pollut. ion Patrol us s November 3' 1983 BROAD AXE, PA.
'83 NOV -7 A11 :15 U.
S. Nuclear Regulatory Commission ATOMIC SAFETY AND LICENSING BOARD
[g['.[{g.g '
Washington, D.
C.
20555 PrV D 1 In The Matter Of PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 (Limerick Generating Station 50-353 Units 1 and 2)
Intervenor AWPP (Romano) responds to NRC
" Staff Response In Support Of Applicant's Motion For Summary Disposition Of Contention V-4" On October 24, 1983, one day before NRC Staff received AWPP's re-sponse by Express Mail on October 25, 1983, Staff wrote that it " supports the Applicant's motion because it shows that there are no genuine issues of material fact that must be resolved in a hearing".
AWPP disagrees as follows:
" Argument" page 3 and 4, Staff states support for its position are tests done at Douglas Point.
Rotors of the helicopters used in that test are so disruptive of the plume as to invalidate the test results.
Staff further states helicopters and fixed wing planes, as per page 4, exper-ienced "no change in engine performance or vibration".
But effect of plume on engine performance and vibration were not the purpose of the test.
Further, other conditions can cause changes in " engine performance or vibration" so that improper gauging of carburetor icing potential was used.
Effect on carburetor ice was not at all mentioned by Staff.
Then on pages 3 and 4 under " Argument" Staff states: "as shown in Affidavit of Harry E. Krug, the Aircraft Owners and Pilots Association Hand Book For Pilots' indicates that carburetor ice occurs under certain meterological conditions without regard to presence or absence of cooling towers." (Emphasis by AWPP)
First, that statement does not appear in Mr.
Erug's affidavit, and secondly it does not appear in the AOPA Hand Book For Pilots.
Also Krug, at paragraph 7, page 3 states " visible plumes of cooling towers are clouds".
No where has Krug referenced where a " cloud" is defined.
Further, invisible plumes which certainly are not " clouds" B311090235 831102 PDR ADOCK 05000352 O
AIR and WATER Pollution Patrol BROAD AXE, PA.
(2) raise the potential for carburetor ice just as visible plumes which have not offically been defined as clouds dc.
Irrespective of mis-quotations, AWPP's position is that 35 mill-ion gallons of water released from the Limerick towers for one or more consecutive days of cold, saturated, stagnant, no-wind condit-ions can, many times, create those certain carburetor-icing meteoro-logical conditions which otherwise would not exist naturally in the localized area enveloping three near-by airport traffic patterns.
Further, the ultra-light Sunset Strip landing field only three miles from the Limerick site means many flights of 250 lb aircraft, flying 30 mph, and without carburetor heat will be endangered.
Staff states Mr. Krug's affidavit established (sic) that carbur-etor ice is "not an unusual phenonomen and that prevention and com-batting it are routine."
That is absolutely not so.
See AWPP answer to paragraph 39 and 41 of " Applicant's Statements Of Material Facts As To Which There Is No Genuine Issue To Be Heard", dated Sept. 17, 1983.
Also'see 16, 17, and 20, AWPP's Statement Of Material Facts dated Oct. 21, 1983.
Both Staff and Applicant, in order to give validity to certain of their statements in support of Summary Disposition Of Contention l
V-4 state that carburetor ice occurs mostly at reduced throttle.
How-ever, on page 15 of January 1, 1980 Aviation Consumer under the art-icle "Those Icy Fingers In Your Carburetor" indicates National Trans-portation Safety Board "Newman" study in 1977 showed carburetor ice-related engine failures occured at various times during flight as follows:
During Cruise--39%; During Climb--21%; During Descent--18%.
Re Staff's Affiant, Earl H. Markee's statement, (par. 5) test aircraft used in PEPCO experiments were not the majority type planes used in the Limerick area 90% of the time...and sunset Landing Strip, an " Ultra-light" field will have ultra-lights flying in the denser plume airspace, and have their field traffic pattern generally envel-oped by the prevailing wind carrying the plume over their field.
The Applicant states the field is 5 miles from the site, when in reality
AIR and WATER Pollution Patrol BROAD AXE, PA.
(3) according to latest New-York : Sectional Air Map, the field, in par-ticular the traffic pattern is as close as 3 miles from the site.
With speeds of 30 mph and no carburetor heat, the tower plume pre-sents increased potential for carburetol ice over ambient air.
Fur-ther if a plume is to be considered a cloud, (which it cannot be) landing at Sunset Strip would too often be against the cloud separ-ation rule... aircraf t very of ten could not land, creating a hazard.
Re Affiant Markee's Affidavit at paragraphs 6 and 8, see AWPP's response to paragraphs 8 and 9 to Applicant's Statement of Material Facts on Summary Disposition of V-4 dated September 17, 1983.
Further, Staff response includes an affidavit of Harry E Krug which after 9 days has not been verified by date, signature or not-arization.
And,if such is not forthcoming by November 2, 1983, so that I may respond by Nov. 3, 1983 (so as to meet Nov.
4, 1983 dead-line) I ask that statements he purportedly made be stricken.
Even so, Mr. Krug's unsigned affidavit, at paragraph 5, refers to "The Aircraft Owners and Pilots Association Handbook for Pilot's
( AOPA, HP ) statement that "at about -10 C and colder, moisture becomes ice crystals, which usually pass through the induction system harm-lessly (emphasis by AWPP)
Thus carburetor icing data from tests at Douglas Point and Keystone used by Staff and Applicant to conclude there was no potential for carburetor ice observed flying in visible plumes at temperatures between -6*C and -12*C are invalid.
That is based on Krug's reference above which states " moisture at temperatures around -10*C becomes ice and passes through the induction system harmlessly." This latter statement shows improper test conditions were used both at Douglass Point and Penn State studies at Keystone.
Krug Affidavit statements at paragraph 6,7,8, refer to experiments "in visible plume", not in plume effect; refers to experiments not done in traffic patterns as exist at Limerick site; refers to experi-ments which did not include very small planes and, inparticular " Ultra-lights" which have much higher RPM, which therefore take in more air with moisture, are susceptible to carburetor ice.
Krug, at paragraph 9, states that planes ( ultra-lights) without
AIR and WATER Pollution Patrol BROAD AXE, PA.
(4) carburetor heat would not develop carburetor ice in an invisible plume because they would not remain in plume long enough, nor would there be more moisture than in ambient air.
This is not so, as stated in AWPP's response dated October 21, 1983 to Applicant's Statement Of Facts re Summary V-4, (9/17/83).
Also an " ultra-light" at 30 mph would remain in plume 4 times longer than 120 mph test by faster planes used.
Krug affidavit again,. paragraph'ninee. states planes without car-buretor heat will not develop carburetor ice because " pilots can't fly those planes into or through clouds".
And at par.7, Mr Krug dog-maticaly states "The. visible plumes of cooling towers are clouds".
Mr.
Krug has no basis, nor official reference to plumes constituting a cloud, either by Federal Aviation Regulation or otherwise.
- Further, his statement re par. 9 and par. 7 does not hold for visible plumes and invisible plumes as it relates to their effect on the airspace and carburetor ice.
Re invisible plume Krug inadvertently supports my latter sentence when, in par.
6, top of page 3, line 3 of his affidavit, Krug states " carburetor icing depends upon humidity and temperature and clear visibility is not an indication of freedom from such icing".
Further as per Krug affidavit par.
6, page 3 it is stated carbur-etor heat is used to " detect" carburetor ice.
That is not so.
See AWPP's Statement Of Material Facts at pars. 16, 17, and 20.
l Also at par.6 of Krug Affidavit, it is stated " conditions caus-l ing carburetor ice occurs naturally".
AWPP answers that non-carbure-l tor icing conditions also occur naturally.
And when such natural non-1 icing conditions exist near Limerick, at certain times, just that mois-i ture contributed by the 35 million gallons of water vapor, in partic-l ular in cold, near saturated, no wind conditions natural conditions are 1
aggrivated to the point of increasing the potential for carburetor ice.
l Krug's affidavit at par. 11 would put the blame on pilots when-1 ever carburetor ice causes engine failure with possible fatality, on the basis that flying according to regulations prevents carburetor ice.
That is not so.
See Affidavit of Frank Romano at A-3 dated Oct. 21, 1983.
i Also see par. 16, 17, and 20, of AWPP's " Statement of Material Facts l
l
AIR and WATER Pollution Patrol BROAD AXE, PA.
(5)
As To Which It Is Contended That There Exists A Genuine Issue To Be Heard", dated Oct. 21, 1983.
At par.
9, p.
4 of Affidavit, Krug again feels visual flight rules solves problems of carburetor ice, as if carburetor ice can-not form under Visual Flight Rules. (see Krug's own statement at par.
6, top page 3, line 3).
Respectifully submitted, AIR AND WATER POLLU ION PATROL
(
Fran
- 1. Roma o, airman 61 ?orest Ave.
Ambler, Pa. 19002 l
l I certify that copies of the above have been served by first l
class mail on the latest service list.
l
.-_.