ML20082N457

Answer Opposing Applicant 831121 Motion to Strike Fr Romano Testimony on Contention V-4.Certificate of Svc Encl. Related Correspondence

ML20082N457
Person / Time
Site:	Limerick
Issue date:	11/27/1983
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8312070182
Download: ML20082N457 (4)

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W Pollution Patrol D?le BROAD AXE, PA. Nov. 27, 1983 b-U. S. Nuclear Regulatory Commission Washington, D.C. 20555

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C 4//ffg Before The Safety and Licensino Board ~C j); .(G '

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In The Matter Of PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 (Limerick Generating Station. and 50-353 Units 1 and 2)

AWPP' S (Romano) Answer To Applicant's Motion To Strike Frank R. Romano's Testimony re Contention V-4 On November 21, 1983 Applicant entered a Motion To Strike Testi-many in above contention.

Applicant stated it based its strike on (1) " grounds that it (AWPP Tcstimony) is not competent"; (2) that "it is not material"; (3) that "it is not relevant evidence"; and (4) "that AWPP has failed to demon-strate that Mr. Romano is qualified to be an expert witness such that hn may give expert testimony".

Relitive to (1) above AWPP answers that the testimony given by Romano is just as competent as the authors of the many references (some clso used by Applicant) I have quoted, as identified in the Romano tes-timony.

As it relates to point (2). the testimony Romano detailed- (with references to tests and opinions of other experts) is material in that it shows Romano's understanding of the principle that with the right conditions of air moisture and temperature, carburetor ice can and will form over wide temperature ranges. Romano's testimony was directly related to the specific factors involved in the carburetor icing phen-onmena and the problems involved in the insufficiency of the crude car-buretor heat arrangement to guard against carburetor icing many times resulting in engine failure and dire consequences. The mere indication of a drop in RPM or manifold pressure is not, as the Applicant alleges, the easy assureance of protection from carburetor ice engine failure.

No better proof of the ambigious nature of the carburetor icing hazzard is evident as per " Light Aircraft Piston Engine Carburetor Ice Detector / Warning Device Sensitivity Effectiveness" (Reprint of June 1982 8312070182 831127 PDR ADOCK 05000352 G PDR

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(2)

AWPP's Antwer To Applicant's Motion to Strike Romano Testimony re V-4 continued:

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supplied in Krug Testimony in, Support of Applicant) identified as DOT /

FAA/CT-8244 at page 10.

As it relates to the difficulty of recognizing carburetor ice and inadequacy of pilot training re carburetor ice prevention and cure (which has jist of part of Romano's testimony) records on page 10 of above reference show that in the 1978-79-80 period there were.8 accidents caused by Carburetor. ice.in aircraft flown by Certified Flight Instructors.

As it relates to point (3), testimony given by Romano (in which many references used by the Applicant were referred to) must be.consi-dered relevant if the Applicant used the same references (see AWPP's Statement of Material Facts). Certainly Romano's testimony that thirty five million gallons of water as vapor increases the localized moisture, to increase the potential for carubretor icing, is relevant...in.partic-ular under already quasi-saturated natural moisture conditions.

Certainly Romano's testimony that Applicant's own supporting refer-ence (Discoveryll, item 2D) showing graphics from tests at John E. Amos plant with plumes 5,000' feet and more from the plant are relevant.

Certainly Romano's testimony supported by the Applicant's own references which questioned validity of results when there are airport traffic '

patterns nearby (as exists at Limerick) is relevant. It is relevant bncause the New York Sectional Aviation Map, as well as LGS FSAR at 2.2.

2.5 shows 5 public use and 10 private airports within 10 miles. Actually Butter Valley airport, just 10 miles away,is not listed, and no doubt there are more.

There are four airports whose traffic patterns would practically intercept even short plumes as Mr. Romano knows from personal experience as detailed in his testimony of hundreds of hours flying in the Montgom-cry County areas. The relevancy and experience of Mr. Romano is eviden-ced in showing that Applicant's witness Mr. Geier unlike Mr. Romano, has

AIR and WATER

.W Pollution Patrol BROAD AXE, PA.

(3)

AWPP's Answer to Applicant's Motion To Strike Romano Testimony re V-4 continued:

not flown in the Limerick area but depends on hear-say of "inspec-tors from the Philadelphia Aviation District Office who flew the pattern "recently" and "were not near the cooling towers". Such testimony relates to proximity to towers, unrelated to carburetor ice. Further, as it relates to point (4) AWPP states it is in Frank Romano's self-interest and safety to keep abreast of the lit-erature and incidents of accidents and the need to know factors involved in air safety. Thus Romano's membership in Airplane Own-ers and Pilots Association for the past five years is to take part in their main activity of insuring pilot safety through continued

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contact with latest information and updated courses of study re weather, flying tips and safe operation.

As a pilot flying two or three times per week and understand-ing the greatest factor in safety, namely, respect for weather

! characteristics such as visibility, sky conditions, temperature, dew point, pressure, air density, and proper aircraft maintanence, l Romano is familiar with the principles and consequences of car-buretor icing far in excess of -meterologist who specializes,for example, in factors involved in different types of cloud formations, l cr factors involved in weather forcasting', or weather studies at flight levels over normal use, etc. The main point is that a reg-ularly flying small plane pilot (even as against an airline pilot who mostly flys above the weather, and has no carburetor to develop ice) becomes very knowldgeable about things that could cause engine fsilure. Carburetor ice is paramont as to cause for engine failure because it can occur fast, and when you least expect it. In spite of this understanding any localized condition conducive to carbur-etor icing can suddenly overcome attentiveness as Mr. Romano per-sonally experienced without warning. The diagnosis of carburetor

AIR and WATER W Pollution Patrol l BROAD AXE, PA.

(4) l l

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i AWPP's Answer To Applicant's Motion To Strike Romano Testimony  !

i re V-4 continued: j icing experienced by Mr. Romano was not hear-say as stated by Appli- j l

cant, but statement of a mechanic at the Cape May field who, be-l cause of familarity with high moisture in the Cape May area, and low temperatures of the October day, stated a suredly it was engine j failure due to carburetor ice. ,

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Respectfully, AIR & WATER POLLUTION PATROL l

Frank R. Romano, Chairman 61 Forest Ave.

FRR/jch Ambler, Pa. 19002 l

l I certify the Service List has been served.

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