ML20099M367

Response to B Vogler Statement of Ref to 500-ft Below Clouds. Witnesses Had No Authority to Define Plume as Cloud.Testimony Applied to Clouds Cannot Be Used for Plume as Plume Relates to FAA Distance from Cloud Rules

ML20099M367
Person / Time
Site:	Limerick
Issue date:	03/06/1985
From:	Romano F AIR AND WATER POLLUTION PATROL
To:	Edles G, Gotchy R, Kohl C NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
Shared Package
ML20099M344	List: ML20099M367
References
OL, NUDOCS 8503250184
Download: ML20099M367 (1)

Text

AIR and WATER W Pollution Patrol BROAD AXE, PA. March 6, 1985 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL PANEL In The Matter Of PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 (Limerick Generating Station 50-353 Units 1 and 2)

Attn: hristine Kohl, Chairman; Garry J. Edles; Dr. Reginald L. Gotchy Gentlemen:

Re the Nuclear Regulatory Commission's Benjamin Vogler's statement of "500 Feet below clouds", I think it is important for the record to indicate two fundamental points not brought up at the Appeal Hearing but which were already on the record. I bring these two points up be-cause it is extremely important that they be reviewed.

1) Definition of a cloud:

The witnesses for the Applicant attached much of their tes-timony to rules which apply to clouds. They arbitrarily defined the plume as a cloud. They had no authority to define a plume as a cloud and, therefore, testimony that applied to clouds cannot be used for a plume as it relates to FAA distance from cloud rules.

2) Visible and invisible plumes:

The record in the Applicant's FSAR or equivalent states that invisible plumes can occur as much as 50% of the time. Mr. Vogler's reference to '500 feet below clouds" (referring to the plume as a cloud) is invalid not only because of improperly defining the plume as a cloud, but also because high moisture conditions which would affect carburetor ice could be present in an invisible plume. The invisible plume, there-by, could become a menace to unsuspecting pilots...inparticular the many student pilots in the unusually high number of airports surround-ing Limerick.

Respectfully submitted,

& WAT LUTION PATROL '

1

.sZs ((

k R. Romano, Chai'rman 61 Forest Ave. ,

8503250184 850322 PDR ADOCK 05000352 Ambler, Pa. 19002 /

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