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Affidavit of EH Markee in Support of Applicant 830927 Motion For

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Affidavit of EH Markee in Support of Applicant 830927 Motion For . - 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, 1 Units 1 and 2) ) AFFIDAVIT OF EARL H. MARKEE . ON BEHALF 0F THE NRC STAFF IN SUPPORT OF , APPLICANT'S MOTION FOR SUMMARY DISPOSITION OF CONTENTION V-4 I, Earl H. Markee, being duly sworn, depose and state: 1. I am a member of the Meteorlogy and Effluent Treatment Inte- gration, Office of Nuclear Reactor Regulation. I have been employed as a meteorologist by the U.S. Atomic Energy Commission / Nuclear Regulatory Commission since 1970. A copy of my professional qualifications is attached. 2. I have evaluated the Air and Water Pollution Patrol (AWPP) Contention V-4, which as admitted by the Licensing Board in its Special Prehearing Conference Order of June .1,1983,17 NRC 1423, reads as | follows: "Neither Applicant nor Staff has considered the potential for and impact of carburetor icing of aircraft flying into the Limerick , Cooling Tower plune(s)." 3. I have also considered AWPP's reworded contention, submitted to. the Licensing Board in a filing of September 30, 1983 and admitted by a ruling from the bench on October 17,1983 at Tr. 4560-61. O 8312060122 831024 gDRADOCK 05000352 PDR t . - _ - - - - - - . > - _ _ _ . - , _ , . - . _ _ . _ _ Y _.I _ __ .. .. _ $. -.- - - . -. - . _ _ _ . - -2- ' . As saworded the contention reads: "Neither Applicant nor Staff has considered the i potential for and impact of carburetor icing of '' l aircraft flying into the airspace that may ne affected by emissions from the Limerick cooling towers." 4 4. In evaluating AWPP's contention, I have examined, among other materials filed in this proceeding concerning that contention, the Affidavit | of Maynard E. Smith and David Seymour in Support of a Motion for Sumary Disposition Regarding Contention V-4 and the documents attached thereto. 5. I am aware of several studies which have been conducted to ! determine what if any effects emissions from cooling towers have on i aircraft. The first was performed by Pickard, Lowe and Associates, Inc. and Dr. Charles Hosler, Dean of the College of Earth and Mineral Science ! at Pennsylvania State University, for Potomac Electric Power Company (PEPCO) in connection with that utility's application to construct a nuclear power plant at Douglas Point near Quantico, Virginia. In ' response to a concern expressed by the U.S. Marine Corps that its air operations might be adversely affected by emissions from the cooling towers at the proposed Douglas Point Nuclear Generating Station, PEPC0 submitted a report based on 223 traverses by a Bell 206-B helicopter and 12 traverses by a fixed-way airplane, an Aero Comander 680E, through plumes emanating from the cooling towers of two fossil plants, one in Pennsylvania and the other in Kentucky. The report, which is ' Attachment 1 to this Affidavit, states in relevant part: t "No significant aircraft icing du'*toe water in the Douglas | Point cooling tower plumes is expected to occur. None was I t observed during helicopter and a fixed wing airplane 'j traverses of cooling tower plumes at Paradise [near Central City Kentucky] and Keystone [ located near Shelosta in Indiana County, Pennsylvania]. Five of the fixed wing and 30 of the helice,,ter traverses were made through the visible portion of such plumes when ambient air - . __ . .. - - 3- - temperature at the traverse altitude was equal to or less than O'C. These temperatures ranged ft om -6 to -12 C during the traverses. No wetting of surfaces was observed in any trtverse. No change in engine performance or vibration was observed during the traverses." Although the helicopter used in the test traverses conducted for PEPC0 has a jet engine, the fixed-wing plane, an Aero Connander 580E, : has a carburetor. In connection with the Douglas Point proceeding, the FAA reviewed the studies performed for PEPCC and concurred in their findings. (Letter form Melugin to Muller dated March 11, 1975; included in Attachment 2, wuich consists of materials relating to the FAA No Hazard Detennination for Douglas Point). 6. I am familiar with the Pennsylvania State University Study referenced in the Affidavits of Messrs. Smith and Seymour at 118 and 9 and agree with the characterizatiens of the study in those paragraphs. 7. I am also familiar with the American Electric Power Study. Paragraphs 10-12 of the Affidavit of Messrs. Smith and Seymour present an accurate characterization of the AEP study. 8 From my direct experience in evaluating cooling towers as a meteorlogist and from my reading of the literature pertaining to that subject I conclude that emissions from cooling towers under normal operation are not significantly different from conditions occurring naturally. i 1 * , | | | | | ; - -- < - -- - - . , 1_ _ _1 _ _ +. _ - . _ . _ .__ ' . m UNITED STATES OF AMERICA NUCLEAR REGULATORY COPE!ISSION 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) ) AFFIDAVIT OF EARL H. MARKEE i I, Earl H. Markee, hereby certify that the above statements are true and correct to the best of my knowledge and belief, i ffd $ $ s, Earl H. Markee ' Subscribed and sworn to before me this 21st of October 1983 s | ' I Notary Public My commission expires:7\\\b .- ,gn ,,r>= v. W ..r.. .. - -- . _ . - . - . = . - - - . - - - .- ,_ . .- ....-.; _ , - - _ _ - . _ ., . _ _ -- ._ , ' . , ' ' Earl H. Markee, Jr. Professional Qualifications ; , Meteorology and Effluent Treatment Branch Division of Systems Integration ,- My name is Earl H. Markee, Jr. I am the senior meteorologist in the Meteorology Section, Meteorology and Effluent Treatment Branch, Division of Systems Integration, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission. My duties include evaluation of meteorological . aspects of nuclear reactor siting and operation. , t I received a Bachelor of Arts degree in mathematics with a minor in physics in 1952 from Gettysburg College. I attended Massachusetts Institute of Technology for one year to obtain the academic background for qualification as a meteorologist in the U.S. Air Force. I ; I was a wing weather officer with the U.S. Air Force until 1956. After i completion of my military obligation. I accepted a position as a research meteorologist with the U.S. Weather Bureau on assignment to the U.S. Public Health Service in Cincinnati, Ohio, where I participated in urban air pollution meteorology research and provided technical assistance to state and local government agencies on air pollution. In 1962, I accepted a position as senior research meteorologist with the Environmental Science Services Administration on assignment to the U.S. Atomic Energy Commission at the national Reactor Testing Station in Idaho. My duties included the performance of research in the field of atmospheric i turbulence and diffusion and evaluation of the meteorological aspects of i reactor experiments and siting of these experimental reactors. I returned I to school for one year and received a Master of Science degree in meteorology ' from the University of Utah, Salt Lake City, in 1969. ' In August 1970, I . accepted an appointment to my present position. t . I am a professional member of the American Meteorciogical Society and the Air Pollution Control Association. I have authored eight research papers, - which were published in technical journals, and several other research reports published by the Federal government. .- [ . L.__,'..* .e' K ...*.- -..- --. X,: X: *~ ::' ' *. ,. * * ;,i L _ J __- ,1,- . ., ~.- - . - , U. -.L: . , , , . , - . _ __ - . * . ' UNITED STATES OF AMERICA NUCLEAR REGULATORY COPHISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ' In the Matter of PHILADELPHIA ELECTRIC COMPANY Docket Nos. 50-352 50-353 1 (Limerick Generating Station, ) | Units 1 and 2) ) | AFFIDAVIT OF HARRY E. P. KRUG ON BEHALF 0F THE NRC STAFF IN SUPPORT OF APPLICANT'S MOTION FOR SUMMARY DISPOSITION OF CONTENTION V-4 I, Harry E. P. Krug, being duly sworn, depose and state: 1. I am a reactor inspector, assigned at present to the Nuclear Regulatory Commission's Region Il in Atlanta, Georgia. I also hold ratings as an instrument rated commercial pilot, single engine land and sea, multi-engine. I have given expert testimony in several NRC licensing proceedings including expert testimony on aircraft operations in the proceeding conducted in connection with Pacific Gas and Electric Company's application for an operating license for the Diablo Canyon Nuclear Power Station. A copy of rqy professional qualifications is attached. 2. I have evaluated the Air and Water Pollution Patrol's Contention V-4, both as admitted by the Licensing Board in its Special Prehearing Conference Order of June 1, 1980, 15 NRC 1423, and as reworded by AWPP on September 30, 1983 and subsequently admitted by the Licensing Board at Tr. 4560-61. The two versions of Contention V-4 which I have ' considered read as follows: - "Neither Applicant nor Staff has considered the potential for and import of carburetor icing of aircraft flying into the Limerick Cooling Tower plume (s). - - - . -- .. _. -_. _ . _ . _ _ _ _ _ _ . , -2- . "Neither Applicant nor Staff has considered the potential for and impact of carburetor icing of aircraft flying into the airspace that may be .- affected by emissions from the Limerick cooling towers." 3. In evaluating AWPP's Contention V-4, I have examined the Affidavits of Maynard E. Smith and David Seymour in Support of a Motion for Sumary Disposition Regarding Contention V-4 and the documents attached thereta. 4. I have studied in detail the paragraphs of the Affidavit of Messrs. Smith and Seymour for which Mr. Seymour is responsible,11 16, 17, 18, 25, 26, 27, 28, and I agree with the statements made there.
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