ML20081K039
| ML20081K039 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/01/1983 |
| From: | Romano F AIR AND WATER POLLUTION PATROL |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20081K012 | List: |
| References | |
| NUDOCS 8311090239 | |
| Download: ML20081K039 (2) | |
Text
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AIR and WATER Pollution Patrol Novem H R 1983 BROAD AXE, PA.
U.
S. Nuclear Regulatory Commission Atornic Safety and Licensing Board Washington, D.C.20555 CFf;cE OF ncgt 3 00CMETmG & SERvir.:
BRANCH In The Matter Of PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 (Limerick Generating Station 50-353 Units 1 and 2)
" Applicant's Request,For Official Notice Of Federal Regulations Of Ultralight Vehicles" dated Oct. 27, 1983 was sent untimely, namely, after receipt of my answers to Appilcant's Statement Of Material Facts re Summary Disposition Of Contention V-4, timely filed Oct. 25, 1983.
AWPP (Romano) now feels it necessary to respond to avoid mis-in-ference given to ASLB by Applicant.
Applicant's statements hinge on their definition of a " cloud",
(which The Federal Aviation Authority has not permitted them to define) and the rule which applies to clouds when, and if, a visible entity can be called a cloud.
~
AWPP states that the intent of the cloud rule is to avoid mid-air collision with other planes hidden for significant distances within an entity with physical demensions capable of hiding an aircraft for a significant period of time.
An isolated small puff is called a cloud, but it could be of such a size as to make the separation-from-cloud rule non-applicable because a plane approaching would be seen and the time through the puff would be negligible.
Further the Applicant and Staff have repeatedly stated traverses of plumes are too short, because plume becomes same as ambient air after 1/4 mile.
Also, in certain thin, scattered clouds, as I often experience, another aircraft is visible, indicating the-cloud-rule would not apply even though the scattered entity could be termed a cloud.
Applicant ignores invisible plumes and " affect" of visible, and invisible plumes koj1090239831102 g
ADOCK 05000352 PDR
AIR and WATER Pollution Patrol BROAD AXE, PA.
(2)
Further, I refer to Federal Aviation Administration (14CFR Part 103)
Final Rule dated Oct.
4, 1982.
Re "Ultralight vehicles: Operating Requirements"of this rule, ultralights less than 254 pounds, which will be the type concentrated in the immediate Limerick area's Sunset Strip, quote: "The FAA has chosen not to promulgate Federal regulations regarding pilot certification, vehicle certification, and vehicle reg-istration, preferring that the ultralight community assume the initi-tive for the development of those important safety programs. (Emphasis by AWPP)
Also under Section 103.7 it is stated: Notwithstanding any other section pertaining to certification of aircraft or their parts or equip-ment, ultralight vehicles and their component parts and equipment are not required to meet the airworthiness certification standards specified for aircraft or to have certificates of airworthiness."
Further under 103.7 (b) Notwithstanding any other section pertain-ing to airman certification, ooerators of ultralicht vehicles are not required to meet any aeronautical knowledge, age, or exoerience recuire-ments to operate those vehicles or to have airman or medical certificates.
One further item:
As a result of picking up my telephone Monday, October 31, 1983 and hearing confusion as to who was to take part in an unannounced conference call (which was barely audible) I tried to state that since it seemed to not involve me, I would leave for work.
I later found it involved AWPP and I would have remained on the line.
I feel that rather than many invisible parties carrying on multi-stat-l ments at one time, as to wk-should or should not be in on the telecon, that the first statement should be the reading of names that are to be in the conference.
I am writing this because a previous incident of this type was described by the Applicant as Frank Romano refusing to take part in the conference.
Respectifully submitted,
, AIR AND WATER POpLUTION PATROL
<d &E
\\
Fram R.
Romano, Chairman 1
61 Forest Ave., Ambler, Pa. 19002 I certify that copies of this have been served on the latest service list.