ML20082A761

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Testimony of Jd Walsh on Contentions V-3a & V-3b Re FSAR Analysis of Arco Pipeline
ML20082A761
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 11/14/1983
From: J Walsh
BECHTEL GROUP, INC., PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20082A708 List:
References
NUDOCS 8311180243
Download: ML20082A761 (30)


Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

TESTIMONY OF JOHN D. WALSH l RELATING TO CONTENTIONS V-3a and V-3b

1. My name is John D. Walsh. I am a Science Specialist with Bechtel Group, Inc. In that position I was responsible for the preparation of the portions of Final Safety Analysis Report (FSAR) which deal with, among other things, the analysis of postulated transportation accidents, including the possible effect of accidents related to various pipelines that pass near the Limerick Generating Station (FSAR Sections 2.2.3.1.1 and 2.2.3.1.2). I have been requested by Philadelphia Electric Company to respond to the two contentions, Contentions V-3a and V-3b, related to postulated pipeline failure set forth below.
2. I have an undergraduate degree in meteorology from New York University and have taken a number of graduate courses in l

l the sciences. I have recently completed the requirements for an M.S. degree in Environmental Management. I have been employed l ^

l as a meteorologist and have performed numerouc accident analyses for nuclear power stations during my employment with Bechtel.

I 3. In preparing the FSAR section on accident analyses and in responding to these two contentions, I have visited the Limerick site and viewed portions of the pipelines in question, l

l l 8311130243 831114 PDR ADOCK 05000352 PDR 1

examined topographic maps, researched the literature, and con-tacted the companies operating the pipelines. My response to these two contentions also utilizer, information contained in Table 2.2-2, Figure 2.2-4 and Section 9.5.4.3 (page 9.5-34) of the FSAR. I have also reviewed the testimony of Walter Payne of Philadelphia Electric Company, LeRoy Christman of ARCO Pipe-line Company, and Jack G. Brown of Columbia Gas Transmission Corporation related to these contentions.

The analyses described below, which I performed, were conducted in accordance with NRC Regulatory Guides 1.70 (Rev. 3), 1.91 (Rev. 0), 1.91 (Rev. 1). The analyses are extremely conservative and overestimate the effects of pipeline ruptures on the Limerick Generating Station. These conservatisms are discussed, along with the analyses which respond to the contentions.

Contention V-3a In developing its analysis of the worst case rup-ture of the ARCO pipeline, the Applicant provided no basis for excluding consideration of siphoning.

Thus, the consequences from the worst case pipeline accident are understated.

4. The Atlantic Richfield Company (ARCO) refined petroleum products pipeline passes within about 1600 feet of the Unit 2 reactor enclosure, which is the nearest it approaches safety related structures. The pipeline is also approximately 1675 feet from the Unit 2 diesel generator building at its closest point of approach. These distances were scaled from the full sized drawing used to make Figure 2.2-4 and are consistent with the plan provided as an attachment to the Testimony of Walter Payne.

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The pipeline runs generally north-south in the vicinity of the plant with product being pumped in a northward direction. The routing of the pipeline and its relationship to the facility is shown on the figure attached to the testimony of Walter Payne.

While the location of the ARCO pipeline to the North of the

. Station is slightly different than depicted in FSAR Figure 2.2-4, this area is farther from the facility than the critical location and thus there is no effect of this difference on my analysis.

5. From information provided to me by ARCO Pipeline Corp-oration, the pipeline is nominally 8 inches in diameter, operates at 1200 psig pumping pressure and is 28 years old. This pipeline is buried a minimum of three feet below grade, and is a carrier for refined petroleum products. Gasoline is carried in this pipe, as are diesel and home heating oil. Propane and butane are not, and have never been carried in this pipeline. According to ARCO they could not be carried without major modifications to the pipeline. Philadelphia Electric Company has obtained an agreement from ARCO that it will not transport propane through this pipeline.
6. According to ARCO, the pumping stations for this ARCO pipeline are equipped with pressure sensors to detect a sudden rise or fall in pressure which could indicate a leak or break in the lines. The pumps would automatically be shut off in this event. Operators monitoring the pipeline and pump stations would also note a speedup of the pumps and could terminate pumping.

Even small leaks would be detected through routine inventory 3 -

{

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procedures in a relatively short time. For purposes of analysis, it was assumed that a rupture occurs while gasoline is being car-ried s',nce gasoline is the most volatile substance carried and has the highest energy content.1 I did not assume that aviation gasoline was being transported because of its lower volatility and lower heat content compared to automotive gasoline.2 7 The analysis of the effect of this pipeline failure postulated its complete rupture at a location which would cause the greatest effect on the Station. This point is located where the pipeline crosses Possum Hollow Run. If such a rupture should occur other than at where the pipeline crosses the stream bed, the rupture point would be at a higher elevation. Gasoline from above tne rupture point to the adjacent high points would be released, but the gasoline below the rupture point would re-main in the pipeline. The maximum amount would be released only if the rupture were to occur at the pipelines lowest elevation.

Ruptures of the pipeline at other locations in the vicinity of the Limerick Plant would either release less gasoline, because of the relative elevation as determined from the plan attached to the Payne testimony or would drain into other, less proximate drainage systems, and thus cause lesser effects. For example a rupture in the pipeline south of the adjacent high point would cause gasoline to be released into the Brooks Evans Creek drain-age where it would drain past the closest safety related struc-tures at a distance of approximately 2550 feet. Therefore, the rupture of the pipeline was assumed to occur at the point at which it crosses Possum Hollow Run, which is the lowest point 4

\ . .

betweOn tha cdjecant high pointo of the terrain. As discussed above, it was further assumed that pumping would stop due to detection of the sudden pressure drop in the broken line.

8. Following a postulated pipeline rupture at Possum Hollow Run, it was assumed that the entire calculated gasoline content of the pipeline (4962 gallons) between the two adjacent high points of land, 1400 feet north and 600 feet south, immediately flowed into the stream bed, and was distributed over the bed between the pipeline and the first downstream bridge in a pool 610 meters by one meter wide by approximately three centimeters deep. From personal observation, the pooling capacity of the creek bed, i.e., the water remaining in the creek bed if flow were to stop, is very small. No loss of gasoline ~is assumed from the stream bed. No credit is taken for outflow into the Schuylkill River, or for absorption of gasoline into the soil.

The entire available volume of flammable vapor was assumed to be at the location of detonation. Thus, even should the amount of gasoline be significantly larger than postulated above,for example, as the result of gravity flow depending on the size and location of the break, the additional gasoline in excess of the conservative pool capacity utilized in this analysis would drain downstream away from the plant. Thus, even for large releases, the impact on the plant would not significantly change.

9. No siphoning effect would occur from beyond the high points. Air would enter the lines at the point of rupture and travel through the upper portions of the pipe above the surface of the draining fluid until it reached the adjacent high points where it would accumulate and prevent further drainage by gravity 5

l * .

flow. Liquid in the pipe beyond the adjacent high points would not siphon because a siphon requires the presence of atmospheric pressure at both ends. Thus, to drain more gasoline than con-tained between the two adjacent high points would require that air at atmospheric pressure enter the line at a point which is higher than the postulated break at a location beyond the ad-jacent high points. Two separate openings of the pipe must be postulated to permit siphoning to occur.

10. Once distributed in the Possum Hollow Run stream bed, the gasoline was assumed to evaporate, forming a gradient of gasoline vapor at decreasing concentrations above the stream, ,

and confined horizontally within the valley walls. In the case of a liquid such as gasoline, which has a high vapor pressure (the tendency for rapid loss of molecules at a normal temper-atures), the loss of molecules from the liquid surface exceeds the. return of molecules at the air-liquid interface. In the situation postulated for the rupture of the ARCO pipeline while transporting gasoline, the loss of gasoline molecules from the liquid surface exceeds the return of molecules to the surface of the gasoline. Because the molecules of gasoline tend to remain near the surface of the liquid gasoline due to their greater density compared to air, the escaping molecules force molecules which had previously been released from the liquid surface to a greater elevation above the liquid surface. These molecules then form a gradient of gasoline molecules above the liquid surface which varies from essentially 100% gasoline 6

vapor immediately above the liquid surface to near 0% at some elevation above the liquid surface. Since it has been assumed that there is no wind, the only means by which gasoline vapors are forced away from the liquid surface is by means of this molecular diffusion above the liquid surface. If winds were not calm, greater dilution of the gasoline would occur, resulting in less gasoline vapor within flammmable limits near the facility.

Because of mixing, this would be true even if the wind were in the direction of the Station.

11. In accordance with accepted values the explosive limits of gasoline vapor were assumed to be 1.3 to 6.0 percer.t by volume in air.3 The amount of gasoline vapor within explosive limits was calculated, assuming that all of the butane component of the gasoline evaporated during the first hour and that one centimeter of the remaining components of the gasoline evaporated during the period (see Attachment 1.) The total amount evaporated in the first hour was 1920 gallons of gasoline. It was conservatively assumed that the distribution of gasoline vapor concentrations was linear, rather than exponential in order to increase the amount of gasoline vapor within flammable limits. Thus, it was calculated that 4.7% or 90 1 25 gallons of the evaporated gasoline vapor was within explosive limits. The TNT-equivalent energy of this gasoline vapor was determined by comparing the energy content of the gasoline vapor to that of TNT.
12. Detonation was assumed to occur, with the centroid of the explosion being approximately 800 feet from the Unit 2 re-actor enclosure. This location was chosen based upon examination 7

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of the area topographic map. It represents a wide spot in the valley where direct exposure to safety related structures exists.

No credit was taken for intervening terrain at this location. The resulting peak reflected overpressure, as defined in Regulatory Guide 1.91, and using Regulatory Guide 1.91 methodology, (Figure 1 at Page 1.91-3) was calculated to be 1.9 pounds per square inch. Even were the location of the centroid of the explosion selected as the closest approach of Possum Hollow Run to the Station, i.e., approximately 550 feet, the calculated peak over-pressure at the critical station location would be approximately 3 psi, and would not affect these structures. No credit was taken fod the shielding effects of the Possum Hollow Run valley walls. The potentially affected safety related structures have been evaluated and shosn capable of withstanding a reflected

, average overpressure of 12 psi.

13. Alternatively, the entire 5,000 gallons of the spilled gasoline was assumed to deflagrate in a 15-minute period. The 15 minute period was conservatively utilized to maximize the heat generation rate. Using American Petroleum Institute me-thods, it was then calculated that the heat from the resulting fire would produce a radiant heat load of 85 Btu per square foot per hour at the Unit 2 reactor enclosure (see Attachment 2).

This level would not have any effect on the reactor enclosure other than a slight warming of the concrete surface, even for an extended period of deflagration. By comparison, a flat sur-face in the sun would receive solar radiation at approximately s

180 Btu per square foot per hour in the vicinity of the Limerick hsneratingStationaveragedoveranentireday.

, 14. Neither the peak overpressure of 1.9 psi by detonation nor the radiant heat at 85 Btu per square foot per hour by defla-gration of spilled gasoline vapors would affect safety related structures. ,

t

15. While I do not believe that the following scenario is credible, I have utilized it' to demonstrate that the overpressure from even a spill of four times the magnitude which was assumed for purposes of my conservative analysis is below that for which the affected plant structures were evaluate'd. I assumed that 21,000 gallons were spilled over an area which was four times the assumed pool area originally utilized. No credit for run-off or absorption was taken. Four times'the vapor in explosive limits would be present. Again using Regulatory Guide 1.91 methods the peak reflected overpressure at the nearest safety related structures is 3.5 psi if the centroid were 800 ft away.

Even if the closest point of approach were utilized, i.e., ,

approximately 550 feet, the peak reflected overpressure would i  ;

be approximately 6.0 psi. If deflagration of the salae 21,000 1 ,

gallons of gasoline over a fiteen minute period were assumed, the radiant heat at the reactor enclosure would still be only 350 btu /ft2 hr. The human threshold of pain is about 500

'N '

btu /ft2 hr.4 .

e 9

+

Contention V-3b In discussing deflagration of gas and petroleum due to pipeline rupture, no specific consideration has been given to the effect of radiant heat upon the diesel generators and associated diesel fuel storage facilities.

16 The two Columbia Gas Transmission Company pipelines (Nos. 1278 and 10110) carry only natural gas and pass within 3500 feet of the Unit 2 reactor anclosure at their closest approach. Both pipelines share the same right of way and run south-southwest to north-northeast. The routing of these gas pipelines and their relationship to the facility is shown on the plan attached to the Payne testimony. Based upon infor-mation from Columbia Gas, pipeline No. 1278 is 14 inches in diameter, operates at a maximum pumping pressure of 1000 psig, is 34 years old, and is buried a minimum of 3 feet below grado.

Pipeline No. 11010 is 20 inches in diameter, operates at a max-imum pumping pressure of 1200 psig, is 17 years old, and is also buried a minimum of 3 feet below grade.

17 In the case of the natural gas pipelines, it was con-servatively assumed that the larger of the two lines (#10110) ruptures at the point at which the pipeline passes closest to Unit 2 reactor containment (approximately 3500 feet). It was further assumed to be a double-ended rupture (complete separation of the pipe at the point of rupture), and the two pipe ends thereafter are forced into a vertical orientation from pressure and whip. This assumption ignores the fact that the lines are buried, which would mitigate the whip effect. If the pipes 10

ends were not in a vertical orientation as was assumed in the calculation, the two opposed streams of gas would es- e rapid mixing and dilution, and would cause the gas emitted to be a ground level source, resulting in a fire further from the plant than used in the conservative analysis.

18 It is possible that the entire contents ot the pipe-line between adjacent compressor stations at Eagle, 7.5 miles south, and at Easton, 37.6 miles north, would be released at sonic velocity (about 1100 feet per second) in a single combined vertical jet. However, the calculations are dependent upon the rate rather than being affected by the total amount available for release. There is a finite rate of gas which can be re-leased from the Columbia Gas transmission line; the release rate is a function'of the diameter of the release point which acts as a limiting orifice, and the sonJO velocity of the released gas.

In determining the amount of natural gas within flammable limits, a very conservative atmospheric condition was used to minimize dispersion of the gas cloud in its travel toward the LGS. This allowed the cloud to travel as closely as possible towardtheLGSbeforedeflagationfwasassumed. It should be also noted that the dispersion of the natural gas cloud in the atmosphere is a continuous function which occurs over a period of time, with gas which is too rich entering the zone in which dispersion brings the gas into the flammable range, then continues and brings the gas to below flammable limits. Since the quantity of gas released is physically limited by release parameters 11

f t

1 over time, as described above, the amount of gas within flam-mable limits is rate dependent on the atmospheric dispersion parameters selected.

19. It was conservatively assumed that the escaping gas rises in a column to about 500 feet above plant grade, where the momentum energy decays, and that the gas then travels hori-zontally, directly toward Unit 2 reactor enclosure. The miti-gating effect of the height above plant grade was not used in the analysis for overpressure.
20. It was further assumed that the natural gas began dispersing downwind toward the Limerick plant from directly above the rupture point, at a low dispersion rate using Pasquill "F" stability with one meter per second wind speed (approximately the 95th percentile meteorology). These conser-vative assumptions allow the plume to travel nearest the plant prior to reaching flammable concentrations. The flammable limits of natural gas are between 6 and 14 parcent by volume in air.6 Using standard meteorological dispersion methodology, the amount of the gas within flammable limits was calculated (see Attach-ment 3). If the wind were blowing in any other direction than directly towards the plant, the effects of a gas deflagration on the facility would be less. Similarly, if the wind speed were higher, greater dilution would occur and the zone of flammability would be closer to the point of release and further from the Station. Using American Petroleum Institute methods, the radiant heat load at the Unit 2 reactor enclosure was calculated to be 250 Btu per square foot per hour (see Attachment 2). My affidavit 12

s ,

which was dated on October 6, 1983 stated that the heat load was 70 Btu per square foot per hour. In checking my calculations, I determined that an error had been made. This correction does not change my conclusien that the radiant load would significantly affect the Station. As I previously discussed, the threshold of human pain is about 500 Btu per square foot per hour and the calctilated value is half that value.

21. Morover, the analysis made the very conservative as-sumption that the cloud continues to burn at the original point of ignition. In actuality, the flame front would probably move back and have negligible effect on the plant. Should ignition of the natural gas cloud occur at some location between the point of release and the LGS, the heat of combustion would alter the stability of the atmosphere in the vicinity of the fire, making the air more unstable, and accordingly increasing local dispersion. This, in turn, would move the zone of flam-mability closer to the source of the gas cloud and further from the LGS. Ultimately, this effect would cause the flame f2ont to e

reach the source of the gas cloud, the point of pipeline ruture, l igniting the gas as it escapes from the pipe. The analysis actually performed does not consider this phenomenon, but as-sumes that the fire of the natural gas cloud continues at the point where reaches flammable limits. Were this phenomenon of a retreating flame from to be considered, the ultimate location of the burning gas would be at the pipeline rupture, at a con-siderably greater distance from the LGS than was used in this 13

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analysis. Since radiant heat decreases with distance, the effects on the LGS would be measurably lessened.

22. The radiant heat would only cause slight warming of the outer layer of concrete, and would not cause noticeable or lasting effect, even for an extended period of deflagration.

It should be recognized that the diesel fuel storage tanks and associated piping are buried and would therefore not be affected '

by deflagration (or detonation) of the natural gas postulated in these analyses. See FSAR s.5.4.3, page 9.5-34.

23. While not part of this contention, for completeness, I would note that I performed an alternative analysis whereby the natural gas within explosive limits was assumed to detonate.

The meteorological assumptions were the same as for the flam-mability analysis. Using Bureau of Mines methodology, the peak overpressure at the Unit 2 reactor enclosure is calculated to be 10 psi, which is less than the overpressure for which the critical safety related structures have been analyzed (see Attachment 3). It should also be noted that natural gas clouds seldom detonate in the open air.7 Further, it would be difficult to hypothesize an ignition source to trigger a detonation in the elevated cloud.

24. Thus, if deflagation of na.tural gas released from either of the two Columbia Gas Transmission lines were lost-ulated to occur, no adverse effects on safety related structures or equipment would result.

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FOOTNOTES

1) Petroleum Procesing Handbook, Bland & Davidson McGraw-Hill Publishing Company (1967) at page 11-44 and Figure 11-8.

The Conde7 sed Chemical Dictionary, 7th Edition, Reinhold Publishing Co.) at page 1013.

Chemical Process Principles, Part 1, Hougen, Watson, Ragatz, 2nd Edition, John Wiley & Sons, Inc. Figure 74.

2) Petroleum Processing Handbook at pp. 11-24-25. Bland

& Davidson, McGraw-Hill Publishing Company (1967).

3) Flammability Characteristics of Combustible Gases and Vapors, M.G. Zabbtakis, Bulletin 627 - Bureau of Mines, US Department of Interior, 1965.
4) Guide for Pressure Relief and Depressuring Systems, API RP 521, First Edition, September, 1969.
5) National Atlas, US Dept. of Interior, pg. 93.
6) Dangerous Properties of Industrial Materials, Fifth Edition Van Nostrad Reinhold Company at page 846.
7) Hazards to Nuclear Power Plant from Nearby Accidents Involving Hazardous Materials, NUREG/CR-1748, Sand 80-2334, D.E. Bennett and N.C. Finley, April, 1981.

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4 Attachment 1 EXPIDSION OF GASOLINE Assume rupture of ARCO petroleum products pipeline, while carrying gasoline, where it crosses Possum Hollow Run. Pipeline is 8 inches diameter, and 1900 feet between points A and B, where gravity could cause gasoline to flow ont of pipe and into stream bed. Full rupture of pipe is assumed. Then, Vol. = Pi r2 1

= Pi x (0.333)2 x 1900

= Pi x 0.1111 x 1900

= 663.2 ft3 ofgasoline

= 663.2 ft3 x m /35.31 f t3 = 18.78 m3 Gasoline is a mix of C4 through C11 Assumed typical average molecular weight is 113.42, and the distribution of components:

Cn 7 Cn MDL WT  % x MW C4 8 58.12 464.96 (Butane)

C5 12 72.13 865.56 (Pentane)

C6 12 86.17 1,034.04 (Hexane)

C7 14 100.20 1,402.80 (Heptane)

C8 14 114.23 1,599.22 (Octane)

C9 14 128.25 1,795.50 (Nonane)

C10 14 142.28 1,991.92 (Decane)

C 11 14 156.30 2,188.20 (Undecane) 102 SUM = 11,342.20 =113.42 Avg. Mol. Wt.

100 l

l l Assuming the release of 18.78 m3 of gasoline, the liquid flows into the bed of Possum Hollow Run and flows downhill past the reactor complex. It is also assumed that the gasoline forms a surf ace layer in the creek bed from point R to the road bridge (point Bk), a distance of approximately 2000 feet, or 609.6 meters. If it is further assumed that the width of the gasoline flow is one meter wide in the stream bed, then the depth of the gasoline flow would be:

18.78 m3 /609.6 m2 = 3.081 cm 1

According to Dr. D. MacKay at the University of Toronto (personal communication, 8-2-77), the evaporation rate of gasoline is apprcxLaately one cm per hour, with all the butane coming off in the first hour at a uniform rate, due to the low boiling point of the butane (gaseous at atmospheric pressure, standard temp) .

C = 0.6000 g/l = 5.003 lb/ gal 4

C = 0.6260 g/l = 5.219 lb/ gal 5

C = 0.6603 g/l = 5.506 lb/ gal 6

C = 0.6840 g/l = 5.702 lb/ gal 7

C8 - 0.7036 g/l - 5.867 lb/ gal C a 0.7177 g/l = 5.984 lb/ gal 9

C = 0.7301 g/l = 6.087 lb/ gal 10 C yg = 0.7410 g/l = 6.178 lb/ gal 18.78 m 3 x 264.2 gal = 4962 gals spilled m3 Assume all C4 evaporated in first hour:

4962 gal x 0.08 C4 = 397 Eal C4 4962 - 397 = 4565 gals remaining At an evap. rate of I cm./hr = 1522 gal /hr Then, in the first hour, 1522 (C5 through C 11) + 397 (C4 ) = 1922 gals evap.

1922 gal /(1st br) x 5.9 lb x 454 g x hr = 1430 g/sec gal x lb x 3600 sec Q is 1430 g/sec From the topography of the stream bed and close-in area of Possum Ecllow Run, the gasoline vapors would be reasonably well contained within the valley under low wind speede. The spilled gasoline would act as a continuous line source with little dispersion crosswind due to the valley walls, or vertically due to the density of the gasoline vapor above that of air.

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If it is assumed that 1922 gallons of gasoline has evaporated during the first hour after the rupture and spill, then the explosive limits of gasoline vapor are 1.3 to 6.0% by volume, and 6.0 - 1.3 = 4.7% of the vapor is available for detonation if layering and gradual upward expansion of the vapors in the valley are assumed, as follows:

1922 gals x 0.047 = 90.33 gals. gasoline in explosive limits. I gasoline = 5.75 lb/ gal 90.25 gaf. x 5.75 lb = 519 lbs gasoline

. gal Heat value of gasoline = 20,000 Btu /lb. Total heat value of explos.

mixture is: 519 lb x 20,000 Btu /lb = 1.038 x 107 Btu 1.038 x 107 Btu x 0.2530 = 2.626 x 106 kg -cal 20,000 Btu x 0.2530 = kg - cal 5060 lb lb TNI = 500 k-cal /lb Then, 519 lbs gasoline x 5060 k-cal = 2.626 x 106 lb 519 lbs nas x 5060 = 5.252 x 103 lbs TNT equiv.

500 5252 lbs TNT equiv. x ton = 2.626 tons TNT equiv.

2000 lbs Assume centroid of explosion along stream bed is about 800 feet, or 250 mete rs , from unit 2 reactor.

Calculate overpressure:

From NRC Reg guide 1.91:

Zg = Rg/W I/3 where Zg = A scaled ground distance, f t/lbl/3 '

Rg = Radial distance from detonation, ft W = TNI-equiv. of charge, lbs.

Zg = 800/(5252)l/3 = 46.03 f t/lbl/3 From Figure 1, RG 1.91, PR (peak overpressure) is approximately 1.9 psi

! What is peak reflected overpressure from gasoline vapor explosion at closest point of approach of Possum Hollow Run to LGS 7 3

m,wy- - -. , - . , - - - - - - -,,y- , '

,-,w+,vy,- y,-g,w---,+-w,,v,.yw-*-g ww---g-e.-w, e,,e,v----,---,,y-,,-c *% c p--,--w-ey,y=,u-,-r+-m,,--eyee e --,--ev v.,, s w wmv n i- ya-w w w g- *5

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Closest point of approach is 550 feet.

From Gasoline Explosion Calculation, Zo = Rg/W1/3 (from NRC RG 1.91, 1975)

Zc = 550/(5252)l/3 Zo = 550/17.38 = 31.64 From RG 1.91, p. 1.91-3.

@ Zo = 31.64, PR = 3 psi 4

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l Attachment 2 RADIANT HEAT LOAD CALCULATION COLUMBIA GAS PIPELINE From API RP 521, " Guide for Pressure Relief and Depressuring Systems",

API, Wasington, D.C., Sept. 1969. according to Hajek and Ludwig (p. 35, ref. 25),

D = (FQ/(4 x 3.14 x K))1/2 Where: D = dist. from flame midpt. to receptor, f t.

F = fraction of heat radicted Q = heat release, Btu /hr K = radiation, Btu /ft 2 hr Then:

D2 , FQ 12.57 K and K. FQ _

12.57 D' (from API RP 521)

F = 0.25 for3CH4 Q = 4800 f t /sec x 1050 Btu /f t3 = 5.04 x 106 Beu/sec D=365m=Ig00ft.

Q = 5.04 x 10 Btu /see x 3600 sec/hr =

1.814 x 1010 Btu /hr Then:

10 K= 0.25 x 1.814 x 10 . 4.54 x 109 .

12.57 x (1200)' 1.81 x 107

=

250 Btu /ft2 hr ARCO PIPELINE For Gasoline:

K= FQ 12.57D2 F= 0.30 (based on API Butane values)

Q= 5.706_x 10 8 Btu x 4 (1/4 hrs) 2.28 x 109 Btu /hr 1/4 hour hr D= 800 f t, D2 = 6.40 x 105 ft2 5

Above assumes pooled gasoline burns off as vapor in 15 minutes. Total gasoline is 4962 gals spilled.

Then:

4962 gals x 5.75 lb x .,9;000 2 Btu . 5.706 x 108 Btu in 15 min.

gal Ib 5.706 x 108 x 4 = 2.28 x 109 Btu /hr K. 0.30 x 2.28 x 109 = 85 Btu /ft2hr 12.57 x 6.40 x105 O

e 6

Attachment 3 CALCULATION OF NATURAL GAS DETONATION COLUMBIA GAS PIPELINE The concentrations of natural gas downwind and cresswind may be calculated. Assume "F" stability, 1 mps wind speed.

Use:

[I = Q/2Pi(Sigma y) (Sigma z) u] exp [-1/2 (y/ Sigma y)2]

[exp -1/2 (z-H/ Sigma z)2] + exp [-1/2 (z+H/ Sigma z)2]

Distances to be considered:

100, 200, 300, 400, 500, 600, 700, 800, 900, 1000 m Initial conditions:

o Plume becomes horizontal at 500' (150 m) and contains 66.7%

natural gas, 33.3% air in a column 1 meter across.

o Q = 4800 f t3 /see x 0.02832 = 136 m3/see o Explosive and flammable limits of mechane are approximately 6% 'o 14% in air o The plume is cold (due to gas expansion) and any buoyancy effect is offset by cold gas density.

o Atmosphere is "F" stability,1 aps.

o Gas density = 0.04481h/ft3 o Air density = 0.0808 lb/ft3 d mir e 00 C = 0.0808 lb/ft3 d gas e 00 c = 0.0448 lb/ft3 00 C temp is consistent with "F", 1 mps. Use these values.

air: 0.0806 lbs x 454 gm x 35.31 ft3 .1295.3 g/m3 ftJ lb m3 gas: 0.0448 lbs x 454 mm x 35.31 f t3 . 718.2 g/m3 ft3 lb m'

q . 136 m 3 x 716.2 a . 9.777 x 10 g4 gas /sec 100% see m?

Calculate gas concentrations at explosive limits of 6 and 14%:

100% gas = 0.0448 lbs/ft 3

= 0.0448 lb x 454 g, 35.31_ f t3 ft> lb m3

= 718.2 g/m3 14% gas = 718.2 x 0.14 = 1.01 x 10 2 g/,3 6i gas = 718.2 x 0.06 = 4.31 x 103 g/m3 At 66.7% gas at 500' at the point source:

718.2 x 0.66666 = 478.8 g/m 3 Thus:

Q = 4.788 x 102 gf ,3 = 4.788 x 108 ug/m3 Explosive limits:

Upper X = 1.01 x 10 2 g/m3 = 1.01 x 108 ug/m3 Lower X = 4.31 x 101 g/m3 = 4.31 x 107 ug/m3 i

Source height is approximately 500 f t, 152 m Q = 9.77 x 10 4g/sec (see above) @ 100%

X = [Q/2 Pi (Sigma y) (Sigma z) u] exp [-1/2 (y/ Sigma y)2]

[exp -1/2 (z-H/ Sigma z)2] + ext [-1/2 (z+H/ Sigma z)2]

Let B = 152 m.

"F" Stability Q = 9.77 x 104 g/sec = 9.77 x 1010 ug/sec u = 1 mps.

H = 152 m.

2

Resulting Gas Centerline Concentration v. L4 stance (ug/m3 )

Disc. Sigma y Sigma z X [X = Q/2 Pi (Sigma y) (Sigma z) u]

(m) 100 4.0 0.7 5.55 x 109 200 8.0 3.0 6.48 x 108 300 12.0 4.8 2.70 x 108 400 16.0 6.3 1.54 x 108 500 19.4 7.8 1.03 x 108 600 23.2 9.0 7.45 x 107 Within 700 27.0 10.2 5.65 x 107 Explosive 800 29.4 11.5 4.45 x 107 Limits 900 33.7 12.7 3.63 x 10 7 1000 37.0 14.0 3.00 x 107 Explosive Limits 1.01 x 108; 4.31 x 107 C asswind Gas Concentrations (ug/m3 )

I Let y = 10,20,30,40,50, etc.

(m) y=10- y=20 y=30 y=40 y=50 ,

100 2.44 x 108 2.07 x 104 ___ ___

200 2.97 x 108 2.85 x 107 5.73 x 105 ___

300 1.91 x 108 6.73 x 107 1.19 x 107 --- ---

3

400 1.27 x 108 7.05 x 107 2.66 x 107 ---

500 9.02 x 107 6.05 x 107 3.12 x 107 1.23 x 107 ---

600 6.79 x 107 5.14 x 107 3.23 x 107 1.69 x 107 --

~ 700 5.28 x 107 4.29 x 107 3.05 x 107 1.89 x 107 ___

800 4.22 x 10 7 3.58 x 107 --- -- --

Vertical Gas Concentration (ug/m3)

Expl. Limits: 1.01 x 10 8, 4.31 x 107 H = 152 m Dist Xc1 Z = 10 Z = 20 Z = 30 Z = 40 S_igma z 100 5.55 x 109 ---- - - - - ----

0.7 200 6.48 x 108 2.51 x 107 - - ---

3.0

300 2.70 x 108 3.08 x 107 - -

4.8 400 1.54 x 108 4.37 x 107 9.98 x 10 5 --- --

6.3 500 1.03 x 108 4.53 x 107 3.85 x 106 --- --

7.8 600 7.45 x 107 4.02 x 107 - - - - --- ---

9.0 700 5.65 x 107 3.49 x 107 --- --

10.2 800 4.45 x 107 3.05 x 107 ---- -

11.5 4

4

- --r-, , ,v-- wy , .-w ,,,,-v -,,---,,,,..,e,--,--e,<, , <- r ,,-w,,.,yw - - , . - - - -,,-,,,,--,--,y---, , - - . - , , - - , - , -,, %,,- ,,,,

l l

Average concentration within explos. limits

= (14% + 6%)/2 = 10%

Volume of ellipsoid: V = 4 Pi abc/3 (where a, b, e are lengths of semi axes) ,

Thus:

V = 4 Pi (420 x 25 x 12.5 - 240 x 17.5 x 10).)

= 3.739 x 105 ,3

= 373,900 m3 natural gas @ 10% avg conc. (between 6 and 14%)

Therefore, 373,900 m3 x 0.10 = 37,390 m3 total nat. gas in detonable range.

37,390 m 3 x 35.31 ft3 x 0.0448 lb = 5.915 x 104 lbs natural gas at mJ ft3 explosive mixture levels 3 4 3 Then: W = (1050 Btu /ft ) (5.915 x 10 lbs) x ft~~

(2000 Beu/lb TNT) x 0.0448 lb W = 6.932 x 105 lb TNT equivalent W = 693,164 lb TNT equivalent W = 347 Tons TNT equivalent The centroid of the explosion is assumed to occur at approximately 700 meters dowawind of the source, or 1065-700 = 365 meters from the Unit 2 containment.

This distance is also utilized in the calculation of radiant heat impinging on the station structures if the natural gas burns. A highmenergy ignition source is assumed (lighting stroke, or something similar).

From NRC Reg. guide 1.91:

zG = RG/W where Zo = scaled ground distance, f t/lb 1/3 Rg = radial distance from explosion, ft.

W = charge weight, lbs Zg = 1183/(6.94 x 105 )1/3

= 1183/88.54

= 13.36 Then, from NRC RG 1.91, fig. 1. PR (Peak overpressure) = 10 psi 5

. ln PROFESSIONAL QUALIFICATIONS JOHN D. WALSH SCIENCE SPECIALIST BECHTEL GROUP INC.

My name is John'D. Walsh. My business address is 50 Beale St.

San Francisco, California 94109. I am a professional meteor-l ologist. I am a science specialist.In that position, I provide staff-support in meteorology and air quality matters. I am responsible for the hazards analyses associated with nearby military, industrial and transportation f acilities for a number of nuclear power plants, including the Limerick Generating Station.

I received training as an aerographer with the U.S. Navy during the Korean war. Following that, I attended New York University from 1956 through 1959, and received an A.B. in meteorclogy.

I later joined the U.S. Naval Reserve and was designated as meteorological officer, a designation I still hold with the rank of Commander.

Following receipt of my undergraduate degree, I pursued part-time graduate studies in meteorology, physics, mathematics, and a number of institutions, including Hofstra psychology at College, State University of New York, University of Maryland and University of California-Berkeley. I recently completed requirements for an M.S. degree in Environmental Management at the University of San Francisco.

Following my graduation from undergraduate school, I was employed by Brookhaven National Laboratory as a Research Meteorologist.

The work was primarily in the field of atmospheric dispersion research.

From 1961 through 1966, I was employed by the New York State Department of Health as a Senior Meteorologist in the Bureau of Air Pollution Control. During this time, I assisted in the establishment of a state-wide air pollution control program, and organized methods for evaluating the impacts of industrial and utility facilities on air quality.

From 1966 through 1968, I was employed by NUS Corporation as a Senior Scientist, where I was primarily assigned in preparation i of PSAR/FSAR meteorological and climatological chapters, in-cluding accident analyses.

From 1968 through 1974, I was employed by several consulting companies as Chief, Air Quality Section, and as Manager of Envi-romental Services. My assignments were in atmospheric dispersion studies, in resource development, and in chemical / biological war-fare defense systems.

I have been employed by Bechtel Group Inc. since September, 1974. My present title is Science Specialist, and I work as a staff consultant to a number of Bechtel projects. Among my assignments, I have performed numerous accident analyses for over one dozen nuclear power plants. These analyses have included the effects on the operation of these stations of nearby industrial, military and transportation facilities.

2

I l

1 . ,

PROFESSIONAL QUALIFICATIONS JOHN D. WALSH SCIENCE SPECIALIST BECHTEL GROUP INC.

My name is John D. Walsh. My business address is 50 Beale St.

San Francisco, California 94109. I am a professional meteor-ologist. I am a science specialist.In that position, I provide staff support in meteorology and air quality matters. I am responsible for the hazards analyses associated with nearby military, industrial and transportation f acilities for a number of nuclear power plants, including the Limerick Generating Station.

I received training as an aerographer with the U.S. Navy during the Korean war. Following that, I attended New York University from 1956 through 1959, and received an A.B. in meteorology.

' later joined the U.S. Naval Reserve and was designated as meteorological officer, a designation I still hold with the rank l

of Commander.

Following receipt of my undergraduate degree, I pursued part-time l

physics, mathematics, and graduate-studies in meteorology, a number of institutiens, including Hofstra psychology at College, State University of New York, University of Maryland and University of California-Berkeley. I recently completed requirements for an M.S. degree in Environmental Management at the University of San Francisco.

Following my graduation from undergraduate school, I was employed by Brookhaven National Laboratory as a Research Meteorologist.

1

~

The work was primarily in the field of atmospheric dispersion research.

From 1961 through 1966, I was employed by the New York State Department of Health as a Senior Meteorologist in the Bureau of Air Pollution Control. During this time, I assisted in the establishment of a state-wide air pollution control program, and organized methods for evaluating the impacts of industrial and utility facilities on air quality.

From 1966 through 1968, I was employed by NUS Corporation as a Senior Scientist, where I was primarily assigned in preparation of PSAR/FSAR meteorological and climatological chapters, in-cluding accident analyses.

From 1968 through 1974, I was employed by several consulting companies as Chief, Air Quality Section, and as Manager of Envi-romental Services. My assignments were in atmospheric dispersion studies, in resource development, and in chemical / biological war-fare defense systems.

l l

I have been employed by Bechtel Group Inc. since September, 1974. My present title is Science Specialist, and I work as a staff consultant to a number of Bechtel projects. Among my acsignments, I have performed numerous accident analyses for over one dozen nuclaar power plants. These analyses have included the effects on the operation of these stations of ,

4 nearby industrial, military and transportation facilities.

3 2

c g o

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In'the Matter of ) .

)

Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station,. '

)

Units 1 and 2) )

o AFFIDAVIT OF MAYNARD E. SMITH AND DAVID SEYMOUR IN SUPPORT OF A MOTION FOR

SUMMARY

DISPOSITION REGARDING CONTENTION V-4 Messrs. Smith and Seymour being duly sworn according tv law come forth and say: ,

1. My name is Maynard E. Smith. I am President and Principal Consultant for Meteorological Evaluation Services, Inc.

("MES") located in Amityville, New York. I obtained a Master of Science in meteorology in 1942 and have been engaged in the practice of professional meteorology since that time. A copy of my professional qualifications is attached hereto and incorporated by reference herein. MES, under my direction, has provided meteorological consulting services for the Limerick Genera ~cing Station since 1970.

2. MES services have included advice on site selection, the location and choice of meteorological instruments and 9

e s

f acilities, processing and analysis of the data and the preparation of the meteorological portions of the studies and documents necessary for the licensing of the Limerick Generating Station.

MES, under my supervision, prepared the following portions of the Limerick Generating Station FSAR and EROL:

FSAR EROL

~

Sections 2.3.1 Sections 5.1.4 2.3.2 5.2.2 2.3.3 2.3.1 2.3.4 2.3.2 2.3.5 In addition, as more fully described below, MES, under my direction, has conducted extensive studies related to the effects of the operation of cooling towers. In those studies we-used carburetor-equipped aircraft extensively to obtain data on cooling tower plume behavior.

3. My name is David E. Seymour. I am presently a Consultant Meteorologist to MES, Inc. I obtained a Bachelor of Sci-ence degree from Purdue University in Professional Pilot Technology and obtained a Master of Science degree in mete-orology from Rutgers University in 1976. I have provided consulting services to MES, Inc. on a number of airborne field evaluations. These have included atmospheric diffu-sion studies and evaluation of stack and cooling tower plume behavior. I have conducted extensive airborne cooling tower plume research, and was responsible for the training of 12 other commercial pilots involved in MES

cooling tower research programs. I have also been respon-sible for airborne photography and aircraft procurement and maintenance for numerous aircraft involved _in MES studies.

I am presently a commercial airline flight officer. I am also a director of a glider pilot ground school in Rochester, New York. I am qualified as a commercial pilot in single and multi-engine land, glider and instrument aircraft. I am also a flight instructor Lor glider, advanced and instrument ground training. A copy of my professional qualifications is attached hereto and incorpo-rated by reference herein.

4. We have been asked by the Philadelphia Electric Company to ,

despond to the contention V-4 which was submitted by the Air and Water Pollution Patrol ("AWPP"). This contention reads as follows:

"Neither Applicant nor Staff have considered the potential for and import of carburetor icing of aircraf t flying into the Limerick cooling tower plume (s)."

We have prepared, reviewed and concur 4.a all sections of this affidavit; however, certain sections were either prepared primarily by one individual, or one of us is more knowledgeable about the details. Such sections are shown in Table 1. In addition to the sections of the EROL and FSAR listed in paragraph 2 above, we have utilized section 3.4.3 of the EROL as input to our analysis.

5. We have carefully examined and analyzed the contention of the Air and Water Pollution Patrol. Our consideration of the contention utilizes our extensive experience with

regard to meteorology, cooling tower technology and aircraft operations, and has included examination of the literature and documents on the subject, review of the experience and field data developed in research studies of such plumes, and a computer modeling study of the expected behavior and persistence of the Limerick plumes.

6. Our conclusion is that these plumes will not add to the frequency or the severity of carburetor icing potential.

The most important reason for our conclusion is that the temperature and moisture conditions in cooling tower plumes are only slightly different from those in the ambient air, despite the impressive appearance of the plumes on certain occasions. We also find that it would be extremely dif-ficult for an aircraft to remain in the plume from the Limerick cooling towers for a sufficient time to develop significant carburetor icing, even if the equipment built into the aircraft for dealing with icing were not used.

The dimensions of the plumes would seldom allow more than a few minutes of flight time in the plumes, and even when they are more extensive, staying in a plume long enough to provide a chance for enhan:ed icing would be a difficult deliberate maneuver on the part of the pilot.

PERTINENT STUDIES AND RESEARCH ON COOLING TOWER PLUMES

7. One of the most important factors in assessing the AWPP contention is to determine how the temperature and moisture conditions in cooling tower plumes differ from those in the ambient air. Both from the impressive appearance of the plumes and a casual consideration of the large amounts of water vapor released, one would anticipate that the condi-tions in such plumes would be quite different from the

surrounding atmosphere. This is not the case, however, because the very rapid mixing that occurs with the ambient atmosphere dilutes the excess heat and moisture within a short distance. In responding to discovery requests, AWPP has emphasized that 35 million gallons of water vapor per day would be released from the Limetick trwers. Compared with the amount of water vapor naturally present in the air with which the tower release mixes, this is not a signif-icant amount. Typically, in an hour the cooling tower water vapor would mix into 10,000 million cubic meters of air (a section 10 Km long, 1 Km deep and 1 Km wide). Typ-ically also, this air would contain about 2 1/2 thousandths of a gallon of water vapor in each cubic meter. Therefore, the 1.3 million gallons per hour re'1 eased from the tower would be mixed with 25 million gallons of natural water

  • iapor, hardly a major addition.

Jennsylvania State. University Study

8. Tle most informative study available on the temperature, humidity and turbulent scructure of cooling tower plumes is especially appropriate since it was conducted in Pennsyl-vania on hyperbolic cooling towers. The Pennsylvania State University (Thomson et al., 1981) made a large number of aircraf t flights through the cooling tower plumes from the Keystone power plant in western Pennsylvania for the ex-press purpose of determining what in-plume conditions were like, and how they dif fered from those in the ambient air.

The Pennsylvania State research team found that very close to the towers (i.e. with the aircraft traversing the plume within a quarter of a mile) both temperature and numidity conditions varied sharply as the aircraft traversed the

Y . . . . .

,,#d>gp@ IMAGE EVALUATION

////

.d'#4

/ TEST TARGET (MT-3) ,

k//

1.0 l# 8a UE

'd S HE

=

l,l [!-Ese l.8

]

1.25 1.4 1.6 i

4 150mm >

6" >

  • &g

,, /+s;gge '/b

$f77 oh// *k#'

~

4$ \if / d'#

k IMAGE EVALUATION ((/

f/ TEST TARGET (MT-3) 4% 4 ggy>,7;e@gi f  %,4y/+4

+ s l.0 lf 82 En u'

tflef i mDE

'I _l.8_

I.25 1.4 1.6 4

4 150mm >

6" >

4

  1. % ,, / 4 47*/, Azzzzz <g+yf4

plumes, with both quantities exceeding ambient levels sig-nificantly for very short periods. The variability was attributed to the fact that the plumes, although often appearing to be quite dense and solid, actually consist of puffs of excess moisture and temperature. Beyond a quarter of a mile, it became difficult to distinguish the tempera-ture in the plume from that of the outside air, as shown in Figure 1, and the humidity difference dropped to 0.25 gm/kg or less as shown in Figure 2. This is a very small excess; the natural atmosphere, when saturated, contains about 3.5 gm/kg at 30*F and this figure increases to 22 gm/kg at 80*F. Thus, even though a plume may remain visible for a considerable distance, the conditions within it become essentially those of the surrounding air after a very short distance.

9. This Pennsylvania State study is directly comparable to the Limerick Generating Station situation since the experiments were done under nearly identical climatic conditions.

American. Electric Power Study

10. During the 1970's the American Electric Power Service Corporation supported an extensive study of cooling tower plumes, conducted by MES. The objectives of this program were to determine whether such plumes had any significant environmental effects, and how they behaved with respect to their height above ground and persistence downwind. These tests involved the use of light aircraft of the same type that is of concern to the AWPP. In all, over 340 experi-ments were completed, as shown in Figure 3. The total water vapor emissions from the Amos and Gavin Plants are in the same range as the total that will come from the two towers at Limerick.

l l

- , - - - - - ---, g,-,w-,,-*w y ~+-s-w'- --- -- m~- , *w-n=+=? ------c-- --=----------',-e-------,----o ----'=-w-'w w - - ~' ~-

11. The key point is that, of these 340 individual tests, visible plumes ten miles and longer were observed only six times, and of these six cases, three were at temperatures well below 20*F, which is, as discussed below, too cold to have created any serious carburetor icing hazard. Thus c as l

we will show later, the pilots found plumes with the ade-quate length and temperature criteria for potential carbu-retor icing less than it of the time, in a program designed to document long plumes.

12. No icing problems were ever reported during all of this flying even though light, carburetor-equipped aircraft flown by local pilots employing normal procedures were used extensively.

COMPUTER MODELING STUDY

13. We have conducted a computerized modeling study of the behavior of the Limerick cooling tower plumes, using the Electric Power Research Institute's SACTI program. This computer code uses the plant thermal output and the cooling tower water vapor and air volume releases at maximum power as inout data, treating the two towers simultaneously. It combines this information with data from the Limerick me-teorological tower f acility and with data on above-ground l meteorology to develop a series of seasonal and annual distributions of pertinent information about the plume behavior and effects.

i l

l 14. The SACTI computer code is a " state-of-the-art" program in that it predicts the behavior of plumes such as those of

[

the Limerick Generating Station as faithfully as is l

\

I possible at the present time. We can say from our direct experience with the American Electric Power field studies that the heights and frequencies of lengthy plumes calcu-lated for Limerick are in accord with our expectations.

15. The modeling_ study shows that the length of the plumes would be expecred to reach or exceed ten miles in less than 4% of the cases, and the maximum frequency of these long plumes would be toward the west (0.6%). The code predicts that the Limerick plumes will always reach a height of at least 1,000 feet above ground before leveling off, if they have not dissipated before reaching that altitude.

CARBURETOR ICING PHENOMENA

16. The conditions responsible for carburetor ice formation are well understood and have been extensively documented. In carburetor-equipped aircraft, the fuel enters the airstream at the throttle valve. The vaporization of the fuel, com- ,

eined with the rapid expanison of air as it passes through the carburetor, causes a cooling of the mixture. The water vapor content of the intake air may condense, and if the temperature in the carburetor reaches 32*F or below, the moisture will be deposited in the fuel intake system as l

frost or ice. This ice may reduce or block the passage of the fuel / air mixture to the engine and cause engine fail-ure. Due to the venturi effect of a partially closed throttle valve, this occurs most of ten when the throttle is partially or fully closed and the temperature of air pass-ing downstream of the throttle valve may drop as much as 60*F.

17. On very dry days, or when the temperature is well below freezing, the moisture content of the atmosphere is a l l

1 generally too small to cause icing. But if the temperature is between 20*F and 90*F, and moderate humidity or visible moisture is present, there is a potential for carburetor ice. A full discussion of the conditions under which car-buretor ice develops is given in a Johns Hopkins University publication from the Chalk Point Cooling Tower Projact (JHU 1977). Figure 4, reproduced from the Johns Hopkins report, is a chart showing'the meteorological conditions during which carburetor icing is possible. This chart shows that serious icing may occur with temperatures ranging from 20 to 90*F even at moderate humidities. However, it does not occur at temperatures below 20*F.

18. It is also important to recognize that this icing is not an instantaneous process. Figure 5 is reproduced from a study by Gardner and Moon (1970) which documented ice buildup as a function of time during conditions favorable for car-buretor icing. Based upon the plots presented in this figure, Gardner and Moon concluded that approximately 8 minutes of flying time under adverse conditions without carburetor heat would be required to create medium to heavy carburetor ice (i.e. ice that would represent a significant hazard to aircraft).

PLUME TRAVERSE TIME VERSUS ICE BUILDUP

19. For the purpose of developing an extremely conservative analysis, we have assumed: 1) that the pilot inadvertently flies through the plume without carburetor heat, 2) that his air speed is 100 mph, and that he is descending with a partially closed throttle (see following table), 3) that the visible cooling tower plume actually does present an icing hazard significantly different from the ambient air,

and 4) that it would take at least 8 minutes for a signif-icant icing problem to develop.

Flight Speeds and Related Parameters of Typical Single-Engine Light Aircraft Time to Travel Distance Traveled Flight Speeds One Mile in Eight Minutes (mph) (ft/sec) (sec) (miles)

Climb 70 102 52 9.3 80 117 45 10.7 Cruise or 100 147 36 13.3 Descent 130 191 28 17.0

20. If the pilot were to fly across the visible plume at any-angle, it is doubtful he would remain in the plume long l

enough to accumulate any (.etectable icing. Figure 6 is an

! illustration showing two possible flight paths through the visible plume, one flying directly perpendicular across the plume, and the other in a flight path coincident with the plume trajectory, providing the maximum possible in-plume exposure. Cooling tower plumes are almost never more than one mile wide, and even flying at an oblique angle at a i

typical speed, an aircraft traversing the visible plume would only be in the plume on the order of two minutes.

I

21. In the second example, we have assumed that the pilot would be flying along the plume axis, descending with a nearly closed throttle at a rate which matched the slope of the plume. He would have to stay in the plume for more than 10 l

1 l

miles for serious icing to be encountered. Furthermore, he would be approaching the tower structure itself while in the cloud during the latter part of his' approach, an un-likely maneuver in itself.

22. It is also possible that 'the pilot might follow a similar path in the opposite direction during climb, when he would be moving more slowly. However, under these conditions the aircraf t throttle would be open, and the risk of icing would be much smaller.

PROBABILITY OF PLUMES EXTENDING TEN MILES OR MORE

23. The chances are very small that a pilot could encounter a plume having the right temperature and moisture conditions for icing, and of sufficient length so that he could in-l advertently fly in the core of the plume for eight minutes or more. We have already discussed the computer mcdeling study that showed less than 4% of the plumes reaching or exceeding ten miles in length. Furthermore, the American Electric Power program, in which we were seeking long plumes, showed only six plumes out of 340 tests extending

' to ten miles or more, and of these , three were too cold to have presented an icing problem.

24. The AWPP contention has also stressed the possibility of icing in the invisible plume extending downwind af ter the liquid droplets evaporate. However, this cannot be ac-cepted as a significant increment to icing problems because the Pennsylvania State program has shown that conditions more than 1/4 mile downwind of a tower are virtually iden-tical to those in the ambient air, whether inside or out-side of the visible plume.

i 4

PILOT TRAINING i

25. The fact that we do not see any significant increase in the potential for carburetor icing as a result of the cooling l

tower operation does not mean, of course, that carburetor ice will not occur in the Limerick area. However, carburetor ice is a routine phenomenon that all pilots are trained to' deal with.

2. 6 . Pilots are taught about the risk of carburetor ice in ground school and are trained from their first flights to use carburetor heat, an anti-icing device that preheats the air before it enters the carburetor. This preheating is used to melt any ice or snow entet._g the intake, to melt any ice that may have formed in the carburetor passages l (provided the accumulation is not too great), and to keep the fuel / air mixture above the freezing point to prevent formation of ice. A pilot's first indication of carburetor ice is a drop in engine RPM for aircraft with fixed pitch propellers, and a drop in manifold pressure for aircraft equippe' with variable pitch propellers. Aircraft with fuel injection or turbine engines do not experience

! carburetor ice.

27. The vast majority of small airplanes flying at relatively low altitude (below 10,000 feet) are carburetor-equipped and have carburetor heat controls. Pilots are trained to check these controls during the preflight check, and to

! apply heat at the first indication of carburetor ice and during operations when the thrortle is closed or nearly closed. Carburetor heat is not used in normal flight as it tends to reduce the output of the engine.

l l l l

r

28. Pilots who are not instrument rated, equipped, and on an instrument flight plan must avoid flying in or near the visible cooling tower plume because it appears as a cumulus-looking cloud. VFR (Visual Flight Rule) pilots are to avoid clouds by at least 2,000 feet horizontally and they'must also remain at least 1,000 feet above and 500 feet below clouds in the Limerick area. While on a few occasions during the year the operation of the Limerick cooling towers may cause slight deviations in approach, departure or flight paths for VFR pilots, this situation is no different than that which would be encountered by s"ch pilots having to avoid natural cloud formations. IFR (Instrument Flight Rule) aircraft could enter the plume, either purposefully or inadvertently, but as previously discussed, their residence time in the plume would be brief. Also, their aircraft must have carburetor heat con-trols to be instrument-equipped.

MISCONCEPTIONS

29. Several misconceptions about cooling tower plumes and car-buretor icing continue to appear in the AWPP contention, l requests for and responses to discovery. Three of these

(

L are important enough to discuss in detail.

l Large Water Vapor Emissions Do Not Cause Moisture Buildup Over a Period of Days

30. It is very easy for someone who has not had direct experi-ence with large, hyperbolic cooling towers to visualize a situation in which the winds are calm, the air almost i

i completely stagnant, and the moisture released from the l

l

. l towers constantly adds to the atmospheric humidity. This sort of thing can actually happen if moisture is released without buoyancy very close to the ground surface. The fact that the plumes from the large towers are visually impressive under certain conditions makes it even easier to 4

conjure up a scenario of this type.

31. However, there is no question that plumes from the large hyptsbolic towers do not cause any such buildup of local moisture. First of all they originate far above the ground, at altitudes where completely calm winds are almost-never found. The moisture is therefore transported away from the source; sometimes slowly, but there is transport.

Secondly, when stagnant conditions exist close to the ground and the winds are very light, the great buoyancy of the cooling tower plumes carries the moisture far above the top of the tower, usually to several thousand feet above the terrain. Thus, the cooling tower plumes are completely divorced from the 1cw-level conditions, rising high above

' the local stagnation and drifting off at the speed of the winds alofr (Figure 7).

j The Roxborough Incinerator is Not Comparable to the Limerick Generating Station Cooling Towers i

I

32. We have investigated the Roxborough incinerator, mentioned in the AWPP contention ,as having been observed causing a condensed water vapor cloud along the Schuylkill Express-way. This plant is a smq11 incinerator in which a water spray is used to reduce the effluent temperature to levels commensurate with the design of the electrostatic precip-itator. It is in no way comparable to the Limerick cooling i

towers.

l l . _ _ _ _ _ . . _ _ _ _ . - _ . - . . _ _ . . _ . _ . _ _ ~ _ - . - , ,__

33. Furthermore, we have obtained the meteorological data from the National Weather Service for April 9, 1982, the day on which AWPP alleged that the incinerator produced local fog.

These data clearly indicate that snow and f.cg were observed most of the day at the Philadelphia International Airport, ~

and it is very likely that the fog along the Schuylkill River was entirely natural.

Wind Shear, Turbulence and Generation of Thunderstorms

34. AWPP has raised the question of whether the operation of the Limerick cooling towers could initiate thunderstorms which could be a hazard to aircraft. This phenomenon has never been observed in any field study of cooling tower plumes, and a comprehensive study of this question by Hanna l

and Gifford (1975) shows that 10 or 15 plants of the size of the Limerick Generating Station would have to be clus-tered in a small geographical area for such an effect to be possible. AWPP has also implied that the rising plume from the towers could create turbulence and wind shear. Studies reported by Hosler (1974) of Pennsylvania State University demonstrate that, based upon numerous traverses of cooling tower plumes, nothing more than light turbulence and slight updrafts were encountered. This is confirmed by MES expe-rience during the American Electric Power s*:udies, CONCLUSIONS REGARDING CARBURETOR ICING f

35. Experimental measurements, modeling studies, practical considerations and extensive pilot experience prove con-clusively that cooling tower plumes, visible or invisible, present no special carburetor icing hazard to aircraft.

Conditions in the plume at distances of a quarter mile or more.from the towers are insignificantly different from those in the ambient air as f ar as temperature and humidity are concerned.

36. This is not to say that some determined aviator, f ailing to turn on carburetor heat and deliberately flying back and forth in the core of a tower plume, might not encounter carburetor ice. It is to say, however, that anyone per-forming such a maneuver would encounter virtually the same carburetor icing if he were flying near the plume rather than within it.

L b 'lQ'),3 .(

5d,077,m 4 e4 .

/ w e f/ f- -

/lm/M.g.W y' \

'~

MA:.*N E. SMITH

~~

7./ " - MARTIN E. LEONARD Notary Public. State of New York

,,No. 30 7495025, _

N @ M M W1m DAVID E. SEYMOUR NOTARY Mr. Seymour has concurred in the A fully affidavit copy executed but was will unavailable to sign it.

be substituted when available.

TABLE 1 RESPONSIBILITY FOR AFFIDAVIT PARAGRAPHS Smith & Seymour Smith Seymour 4 1 3 5 2 16 6 7 17 12 8 18 19 9 25 20 10 26 21 11 27 22 13 28 34 14 35 15 36 , 23 24 29 30 31 1

32 j 33 i

1 I

l

s FIGURE 1 .

DELTA T AS A FCN OF TOTAL HANGE SS-

  • STM80L FLIGHT NUM8f R SO -

A AEC 3

. aEC s C AEC 4 0 AEC S E AEC 0 F 1904 e nn. - e.

-i 40 35 -

I so . . .. ,

z.S a,'

l G zo 'E .

o - '

, y .

- 5.5 -

e- t '

3 s.o j *

. w ,=p .

a -

05 . .

- eks ,

3 ' *: ^ -  : -

4000 45'00 3000 3500 a 2500 00 2000 500* e Iq

= .

-a5 - .

TO TAL RANGE ( MCit.RW (Figure 5.1 of the Penn. State study. DELTA T is the difference between the temperature in the plume and that in the ambient air. Range refers j

l to the overall distance from the tower to the point of measurement.)

FIGURE 2 .

M E FI N D E L. T F1 GL. V 5 f9 FIN G E 2.K --

5YMBOL FL1GHT NUMBER l R DGE 4-11 2U "

f5 DOE 4-19 C DGE 4-20 D DGE 4-22 -

r E DOE 4-30 .

F DDE 4-31 d

G G ll DDE 4-32 j LO l .g --

m ~

C 1

d O 0 g .O --

Wx C

cf 0 1 EE D.E - -

Q F R R E DF p E p D dh gF E D pBBE F B gg C

r EY C E n.a  :  :  :

700

, . n 100 2 G1 0 300 '40 0 ECO E00 i

R FI N G E EM3 j (Figure 5.29 of Penn. State study. DELTA Q is the difference

between the specific humidity in the plume and that of the
ambient air. Range refers to the overall distance from the towers to the point of measurement.)

l l

FIGURE 3 COMPARISON OF NATURAL DRAFT COOLING TOWER EMISSIONS FROM THE LIMERICK GENERATING STATION AND THE AEP PLANTS AND

SUMMARY

OF FLIGHT TESTS Average Water No. of Flight Plant Vapor Releases Tests ,

(gpm)

Amos 19,000 147 Big Sandy 6,300 3 Gavin 20,800 7 Mitchell 8,600 86 Muskingum 3,800 100 Limerick 22,350 (total for -

both units) 4

  • Number of flights made withlight aircraft in the AEP studies, 1974-1978.

I

, , , - , - - - - , , , - - - _ - , - , - - - - - , - - - + --y,- -,- ,--,a,--rne -, -,e,w n---,,.-,,- --y,--

I/1 9 M sU c 20 30 o 40 50 60 70 80 90' 100' 110' 0 10" Relative humidity Ambient temperature 'F

^ 89 80 70 70 0

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  • 50

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. / M8W/

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/ ,# vi n .E. 0*

Oo 40' 50* 60 70 80 '50 100' 110' O' 10 20 30 icing probability curves showing conditions which are known to be favorable in the formation of induction system icing in typical light aircraf t installations. Icing cenditions within the limits of the " visible icing" curves may become " serious" af ter 15 minutes continuous operation in such conditions.

Aircraf t Carburetor icing Probability Curves, Canadian Department of Transportation (D.O.T.)

l 1

e

a t-'"

Figure 5 16 I I 1 I

/ Mean icing curve j

. 14 .

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= 13 -

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Tracel Light l MediumHeavy I l l 1 I l

30 40 50 o 10 20 Time (minutes)

Mean Baseline Carburetor icing Curve Fitted with Straight Line Segments Representing the Various icing Phases

  • e

'S 1

~ - . . - . - - . - , , , ,--,-,-,n.--.-._-,.r..-.- , . . - - - - - . - . - - , - . , , - - - - , - , , , ,

FIGURE 6 AIRCRAFT FLYING THROUGil COOLING TOWER PLUME 4% .M i ~

Aircraf t flying exactly along the axis of plume p' A

could stay in it for its entire length. Ilowever,

^\ % ,

plume would have to be .,

more than 10 miles long M e p gg 7 4 I Aircraft flying across the plume would seldom be in plume structure more than a minute or so.

C 1

)

i s

\-

Field tests have repeatedly shown that temperature and humidity conditions within the plume are almost identical to those outside it. .

Also, plumes of 10 or more miles in length, having temperature and humidity conditions conducive to icing occur less than 1% of the time.

FIGURE 7

~'

-. ..-t ,

A v . .' ._

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.a. .=.

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. w wpp gJY.c::. ..

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= ...; R,yq. . - c ' wM pg,yp-n.y .g 4;gJ,pt.

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%-n .. 1.

1 1

Plume Rise Above Natural Fog 7:55 a.m.

January 17, 1975 l

This photograph, taken during the AEP cooling tower flight study (AEP, 1975) shows the typical behavior of plumes from large hyperbolic towers during stagnant, foggy surface weather conditions.

\

l l

1

~

References Gardner L. and Moon G., Aircraft Carburetor Icing Studies, i

Mechanical Engineering Report LR-536, National Research Council of Canada, July (1970).

Johns Hopkins Univ., Applied Physics Lab: Salt Loading, Model-ing and Aircraf t Hazard Studies, Chalk Point Cooling Tower p

Project, JHU/APL FY1977, Final Report, PPSP-CPCTP-16, Vol.

- 1, August (1977).

I Johns Hopkins Univ. , Applied Physics Lab: Power Plant Evalua-tion, Final Report, Douglas Point Site, PPSE.4-2, Vol. 1, Part 2, January (1976).

Kramer M.L. and Seymour D.E., John E. Amos Cooling Tower Flight Program Data, December 1974 - March 1975, available Ameri-can Electric Power Service Corp., (1975).

Kramer M.L. and Seynour D.E., John E. Amos Cooling Tower Flight Program Data, December 1975 - March 1976, available Ameri-can Electric Power Service Corp., (1976).

A.S., Kramer M.L., Calby R.H., and Dal Porto P.A.,

Speiser Empirical Relationships . Between Meteorological Variables and Visible Plumes from Large Natural-Draf t Cooling Tow-ers, in Proceedings of Fourth Symposium on Turbulence, Diffusion, and Air Pollution, American Meteorological Society, Boston, Mass., (1979).

Thomson, D.W., de Pena R.G., and' Pena J. A. , Environmental Meas-urements of Power Plant Cooling Tower and Stack Plumes, Dept. of Meteorology, Penn. State Univ., (1981).

American Electric Power Service Corporation, Cooling Towers and the Environment, AEPSC, 1974.

danna S.R. and Gifford F.A.: Meteorological Effects of Energy Dissipation at Large Power Parks, Bulletin, AMS, V56, No. 10, Oct., 1975, pp. 1069-1076.

Hosler C.L.: Cooling Tower Plume and Air Navigation Pepco Douglas Point, Appendix A, Appl. Answers to the U.S.

Marine Corps' Interrogatories dated Oct. 30, 1974, Docket Nos. 50-448 and 50-449, Atomic Safety & Licensing Board, 12/20/74.

w, ..--.-,-, .- e. - , - - . , - , , - . , . - ---,-----w n,,-,n-.,_,---n,-,..,,,e--,-w -,.,n, . , - - - , - - , , , , , , , - n-- ---m,,--.-, ,w ,.,w, , e--n,,n ,,,,

F' MAYNARD E. SMITH Education:

University of Chicago, Additional work on general circula-tion, single-station analysis, 1942 New York University, MS, Meteorology, 1942 Princeton University, BA, Economics, 1941 f Experience:

Meteorological Evaluation Services, Inc., Amityville, New York, 1968 to Present, President, Principal Consultant Mr. Smith has provided consulting assistance to a number of ino:irtrial and governmental organizations since the early 1950's. In 1968, Smith-Singer Meteorologists, Inc. was founded and Mr. Smith became President. The Company's name was changed to Meteorological Evaluation Services, Inc., in 1977.

I The Company provides advice and assistance in meteorological and air pollution problems, including atmospheric diffusion studies, design and evaluation of stacks and abatement facil-ities, processing and analysis of meteorological and air pollution survey data, evaluation of wind loads onItstructures -

and the preparation o:! environmental reports. also con-I ducts a variety of applied research projects, such as field i

evaluations of cooling tower plumes and building downwash, and the' analysis of large-scale pollution patterns.

Brookhaven National Laboratory, Upton, New York, 1948-1972, Leader, Meteorology Group The original objectives of the Meteorology staff centered on understanding and forecasting the dispersion conditions af-fecting the reactor cooling air. Following solution of these l

problems in 1952, the activities were redirected toward basic Prominent research in low-level diffus!.on and deposition.

l aspects of this program have been detailed investigations of i

diffusion from elevated sources, studies of the low-level wind speed structure, and the development of specialized meteorological and sampling equipment. The study of particu- 1 late deposition over grids of samplers in the open terrain and in forests was also important.

Significant by-products of these studies have included in-struments, techniques and procedures for applying the results to practical problems in air pollution, not only in the atomic energy field but for industry in general.

METEOROLOGICAL EVALUAT:oN SERVICES,INo.

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Page 2 MAYNARD E. SMITH American Airlines New York, 1945-1948, Supervisor of Mete-orological Staff, New York Region Staff-provided terminal and route weather forecasts for oper-ations in the Northeastern United States.

United States Air Force, 1941-1945, Major atmospheric analysis and forecastihg.

Research in upper Deve'lopment of new weather service for the 12th Army Group in Europe to provide meteorological data and forecasts for a variety of ground-force activities.

Professi6nal Organizations and Committees:

American Meteorological Society Air Pollution Control Association American Meteorological Society / Environmental Protection Agency Steering Committee on Atmospheric Dif fusion Modeling, 1981- .

s Invited Participant & Panel Chairman, AMS-EPA Workshop on

" Quantifying and Communicating Uncertainty in Regulatory Air Quality Modeling " Woods Hole, MA, Sept., 1982.

Invited Participant & Panel Chairman, EPA Workshop on "On-Site Meteorological Instrumentatloa Requirements toNC,Charac- Jan.,

terize Diffusion From Point So trees ,"

Raleigh, 1980.

Invited Participant & Panel Chairman, EPA Workshop in Rough Terrain Modeling, Raleigh, NC, July, 1979.

Invited Participant, EPA Conference on Modeling Guideline, Argonne National Laboratory, February, 1977.

Steering Committee, Large Power Plant Effluent Study, Air Pollution Control Organization, Environmental Protection Agency, 1969-1973.

Dispersion of Airborne Effluents, Chairman, Task Group, American Society of Mechanical Engineers, 1966-1968.

METEOROLOO6 CAL EVALUATION SERVICES,INC.

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Page 3 MAYNARD E. SMITH Publications:

Mr. Smith has published approximately 100 articles.in Meteorological vari-ous journals, particularly the American Society, the Air Pollution Control Association, and Atmos-pheric Environment. The most important are:

Recommended Guide for the Prediction of Dispersion of Air-borne Effluents, Amer. Soc. Mech. Engineers (Chairman of Task Group preparing document), June, 1968.

The Influence of Atmospheric Dispersion on the Exposure58, of Plant to Airborne Pollutants, Phytopathological Soc.

(8), 10-85-88, 1968 An Improved Method of Estimating Concentrations and Related Phenomena from a Point-Source Emission, J. Appl. Met., Oct.

1966.

The Variation of Effluent Concentration from an Elevated Point Source, AMA Archives of Indus. Health 14, pp. 56-68, July 1956.

Relation of Gustiness to Other Meteorological Parameters, Jour. of Met., V. 10, No. 2, 121-126, 1953.

Atmospheric Dispersion at Brookhaven National (2),

Laboratory, 125-135, Feb.,

Jour. Air and Water Poll. 10 Int.

1966.

Snowfall Observations from Natural-Draft Cooling Tower Plumes, Science, V. 193, 1239-1241, 1976.

Improvement of Ambient SO2 Concentrations 25, by Conversion No. 6, 1975.

from Low to High Stacks, Jour. APCA, V.

1980. Position paper

' Transport and Diffusion Modeling, the American Meteorological prepared at the request of Society.

Emergencies, Plant Operations Atmospheric Modeling for Vol. 2, Progress, American Institute of Chemical Engineers, No. I, 1983.

METEOROLOGICAL TVALUATION SERVICES. INC.

-- ~ ...--._ .. _ --_ ._ _ _ _ _ _ _ _ - - . - . . , _ - - _ _ , . . . . . _ _ . - - . _ . , _ . _ , . _ . - _ . - _ , _ . _ . _ - . _ _ _ _

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DAVID E. SEYMOUR Ed ucation:

Rutgers University, 1972-1976, MS, Meteorology Purdue University, 1964-1969, BS, AAS, Professional Pilot Technology Experience:

. Meteorological Evaluation Services, Inc., Amityville, N .1* . ,

~

Meteorologists, Inc.) 1973-Present, (formerly Smith-Singer Consultant Meteorologist - Pilot. l Mr. Seymour has provided consulting assistance to MES Inc. on a number of airborne field evaluations . These have included atmospheric diffusion studies, evaluation' of stacks, cooling tower plume behavior, and sea-breeze research.

He has conducted extensive airborne cooling tower plume re-search, and was responsible for.the training and checking of the twelve other commercial pilots invcived in the MES/AEP He has also been responsible cooling tower research program.

for all airborne photography, wind aloft calculations, and af.rcraf t procurement and maintenance for the numerous aircraf t involved in MES studies and proposals since 1973.

United Airlines, Denver, Colorado, 1969-Present, Flight Officer Pilot on Caravelle and Boeing 727, 737 Aircraft. Presently Flight Officer on Boeing 727.

School, Rochester, New York, 1975-Glider Pilot's Ground Present, Director.

The ground school provides the necessary education for pilots as required by Federal Air Regulations. Mr. Seymour formed

! the company in 1975 and now serves as a Director.

' Purdue University, West Laf ayette, Indiana 1968-1969 DC-6, Dept. of Aviation

. Flight Operations Instructor for i Technology Flight Officer on DC-3, DC-6 Aircraft i

Chief Flight Instructor - Purdue Glider Club i -.

METEOMOLOQlCAL EVALUATION SERVICES. INC.

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- Page 2 DAVID E. SEYMOUR Pilot Qualifications:

Commercial Pilot: Airplane Single & Multi-engine land, Glid-er, Instrument, Douglas DC-3 Flight Engineer: Turbojet Powered Flight Instructor: Glider, Advanced & Instrument Ground In-structor

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Federation Aeronautique Internationale Gold Soaring Badge (USA #300) with two diamonds, 8 state soaring records Total Flight Time: 5000+ hours (1983)

Professional Organizations:

Airline Pilots Association Soaring Society.of America American Meteorological Society Publications:

John E. Amos Cooling Tower Flight Progran Data, December 1974

- March 1975, Available from American Electric Power Service Corporation (1975).

John E. Amos Cooling Tower Flight Program Data, December 1975

- March 1976, Available from American Electric Power Service Corporation (1976).

Cooling Towers and the Environment, Jour. APCA, Vol. 26, pp.

582-584 (1976).

The Observed Rise of Visible Plumes From Hyperbolic Natural-Draft Cooling Towers, Atmospheric Environment, Vol. 10, pp.

425-431 (1976).

l Snowfall Observations From Natural Draft Cooling Tower Plumes, Science, Vol. 193, pp. 1239-1241.

Glider Pilots Ground School (1977).

+e METEOROLOOeCAL EVALUATION SERVICES, INo.

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