ML20100D113
| ML20100D113 | |
| 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) |
| References | |
| CON-#285-330 OL, NUDOCS 8504020309 | |
| Download: ML20100D113 (1) | |
Text
'336 AIR and WATER 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.O '
(Limerick Generating Station Units 1 and 2)
C50h354 p;.g :'
?;., y Attn:
h,r.istine 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, A
& WAT OLLUTION PATROL 8504020309 850306
/
PDR ADOCK 05000352 A
Q PDR k R. Romano, Chal'rman 61 Forest Ave.
l Ambler, Pa. 19002
/
Notice to the Board on correction in testimony referred to above was not thought to be necessary to serve the service list.
We do so now as a result of your March 22, 1985 notice.
The above has been served on the latest Service List.
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