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Letter to PADEP (T. Barron) Regarding Peach Bottom Atomic Power Station Proposal for Information Collection for NPDES PA0009733
	ML19067A109
Person / Time
Site:	Peach Bottom
Issue date:	06/10/2005
From:	Scott W; Exelon Nuclear
To:	Barron T; Office of Nuclear Reactor Regulation, State of PA, Dept of Environmental Protection
	Hayes B, NRR-DMLR 415-7442
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Exelon Nuclear Peach Bottom Atomic Po~r Station Telephone 717.456.7014 www.exeloncorp.com Nuclear 1848 lay Road Delta, PA 17314-9032 June 10, 2005 Thomas Barron Pennsylvania Department of Environmental Protection Office of Water Management 400 Market Street Rachel Carson State Office Building Harrisburg, PA 17105 Re: Peach Bottom Atomic Power Station

Proposal for Information Collection for NPOES PA0009733

Dear Mr. Barron,

Enclosed 1s the Proposal for Information Collection required by the Phase II 316(b) regulations promulgated by the USEPA for Peach Bottom Atomic Power Station. It is our understanding that you will be co~rdinating the Phase II 316(b) reviews _with the other Agencies that you feel should review the required submissions. We look forward to working with t~e Department on this matter.

If you have questions on this proposal, please contact Daniel Jordan (717) 456-4551, or Tracy S1gl1n (610) 765~5904.

Sincerely, iv~J~

Wade Scott Chemistry Programs Supervisor Peach Bottom Atomic Power Station ccn 0 5-14067 Cc: H. A. Ryan Environmental Affairs, KS Regulatory Affairs

EXELON GENE~ATION COMPANY, LLC PROPOSAL FOR INFORMATION COLLECTION Clean Water Act Section 316(b) for Peach Bottom Atomic Power Station Delta, PA Technical Consultants:

Normandeau Associates, Inc.

URS Corp.

Triangle Economic Research May 26,2005

Table of Contents EXECUTIVE

SUMMARY

......................................................._,"..............................-........................_....... I

1.0 INTRODUCTION

._.;....................................................................................- ................................ 3 1.1 FACILITY LOCATION ...................................... _............................................................................. 4 1.2 COOLINO w A'll!R INTAKE SYS'll:M ............................................................................................... 4 1.3 SOURCE WA'IDBODY DESCRIFJ'10N ............................................................. _ .............................. 6 2.0 IMPLEMENTED AND PROPOSED COMPLIANCE TECHNOLOGJF.S ..............................8 2.1 PR!LHINARY EVAWATION OP IMPLEMEN1'ED TECHNOLOOIES ................................................... 9 2.2 PRELIMINARY EVALUATION OF PROPOSED TEcHNOLOGIES, OPERATIONAL MEASURES. AND RES'l'ORATJON OPTJONS TO BE Fl1R1HER EVAWA11iD IN'JHECDS............................................. 11 2.2.l Complialu:e ApproQCM8*.*.*...*...***.*..*.- ................................................................................ I 1 2.2.2 Modify ScreetU, Install Fl.sh Retum System .......................................................................... 12 2.2.3 Behavioral ~vicu..............................:................................................................................. I 2 2.2.4

Operational Controu ............................................................................................................ 12 2.2.5 Restol'ation ***************************************************************--******************************************************** JJ 3.0 LIST AND DESCIUP110N OF PREVIOUS STUDIES ........ "'""'""'....- ......- ...- -..... 14 3.1 HISTORICAL S'R.IDIBS LISTED IN APPENDIX A ............................................................................. 14 3.2 REVmw AND EVAWATION Of"J1Di .Rl!LEYANT STUDIES ............................................................. 14 3.3

SUMMARY

OP 11113 RslBVANT S'11n>IBS...................- .................................................................. l S 3.3.J *lmpingtJTMllJStudiu..............................................................................................................16 4.0 AGENCY CONSULTADONS..........._......................................................................................18 5.0 PLANS FOR ADDmONAL INFORMAnON COLLEC110N....- .........._____.... t, 5.l IMPINOEMENTSAMPLINGDBslCiN.........,_................................................................................... 19 S.2 SAMPLECOlJ.ECTION AT111ETRASH BINS ................................................................................. 19 S.3 SAMPl.E PROC'EsSll'fG **************--.. *********************************.............................................................20 5.4 FISH FOR COu.scrtON EFFlclBNCY TEsTs ..................................................................................21 s.s COUEcnoN EFFlclENCY SnJDIES .............................................................................................2) 5.6 SAMPLE HANDLING ....................................................................................................................21 5.7 QUAt.n'Y AsSURANCBANDCONntOL.........................................................................................21 5.8 DATA ANALYSIS AND RE.PoRTJNO .............................................................................................. 22 6.0 ()'rlllR INFORMATION ..........- ...................._ ......................................................................... %3 6.1 BENBFTI'S vALUATION S'ruDY ....................................................................................................23 6.2 COMPIUiHENSJVB COST EV AWATION SnJDY .......................................................- ....................24

6.3 SrrE-SPECn:tC TECHNOLOOY PLAN.............................................................................................25 6.4 srra-SPEClflC REsroRATION PLAN ............................................................................................25 7.0 R.UERENCES..- ......._._........._..................................................................................................26 APPENDIX A ............--***--***...- ..-*.........- .............................................................................................. .29 List of Figures Figure l. Map of Conowingo Reservoir showing locations of Peach Bottom Atomic Power Station and other power plants.

Figure 2. Peach Bottom Atomic Power Station's cooling water intakes and discharge.

Figure 3. Steps in the valuation process showing the economic losses from impingement '

mortality.

EXECUTIVE

SUMMARY

Exelon Generation, L.L.C. (Exelon) is submitting this Proposal for Information ColJection (PIC) to the Pennsylvania Department of Environmental Protection (PADEP) for the Peach Bottom Atomic Power Station (PBAPS) in accordance with the U.S.

Environmental Protection Agency's Clean Water Act §316(b) Phase II Rule, 40 CFR 125. As you know, the PIC is the first submission required for compli~e with the Rule, which pertai~ to existing sources of cooling water intake at electric generating stations.

PBAPS is a Phase II Existing Facility as defmed in 40 CFR 129.91.

PBAPS is a two-unit boiling water reactor facility with a capacity of 2,304 megawatts.

Units 2 and 3 entered commercial service in 1974. Unit 1 is no longer in operation. The power plant is about 5 miles north of the Pennsylvania-Maryland border on the west shore of Conowingo Reservoir. which is the lowennost impoundmeot on the Susquehamla River in southeast Pennsylvania. Conowingo Reservoir was formed in 1928 with the construction of Conowingo Hydroelectric Station.

Since the facility withdraws cooling water from a reservoir, it is required to meet only the Phase II Rule's impingement performance standard (80 to 95% reduction). This is consistent with the determination that the EPA made in Appendix A of the Phase ll Rule when it based its cost estimates on PBAPS only having to meet the impingement performance standard.

PBAPS uses a once-through cooJing system to remove waste heat from the station's condenserS. The circulating water for both units is withdrawn through an outer intake structure located on the western shoreline of Conowingo Reservoir. through two 3-acre jntake basins (one serving each unit), and th~n through the original (inner) intake structure.

Exelon conducted a preliminary assessment of existing and potential tedmological, operational, and restoration measllR!s to determine which would be most applicable and feasible at PBAPS and, thus, warrant further evaluation in the Comprehensive Demonstration Study (CDS). In addition to this assessment, Exelon conducted a preliminary evaluation of the potential benefits and costs associated with various compliance measures.

Exelon's preliminary assessment found that the original design to supply cooling water to Units 2 and 3 consisted of just the inner intake structure. When the plant was .under co~truction, it was realized that most fish entering the intake canal would become trapped near the inner intake screens due to the high water velocity approaching the screens and the absence of lateral escape routes. Therefore, the fish would be exposed to the high intake velocities for long periods, resulting in exhaustion, impingement and

death. Numerous fish swim speed tests were perfonned in order to select an appropriate intake velocity for a new intake structure that would minimize impingement.

Consequently. the improved outer intake structure was subsequently installed at the mouth of the intake canal to reduce the intake velocity by approximately 70%.

Exelon considers the inner intake structure to be the baseline intake for which the calculation baseline rate_, of impingement mortality will be computed. Current impingement mortality at the outer intake will be evaluated against the calculation baseline to estimate the magnitude of reductions already achieved by installing the new intake structure. Based on a preliminary evaluation, *we conclude that substantial reductions in fish impingement have been achieved due primarily to the much lower water intake velocity at the outer intake screens. PBAPS's seasonal reductions in circulating water volume also reduce impingement from baseline. .Exelon will evaluate the previously implemented technological and operational changes in the CDS to determine how . much progress has already been achieved toward meeting the performance standard.

Those measures that Exelon has select;e<i for further analysis include technologies to improve the survival of impinged fish, flow reduction and technologies to reduce impingement, and natural resource restoration.

Exelon anticipates that the review of compliance alternatives will include a site-specific cost benefit evaluation that compares the relative monetary value of the resource being protected to the cost of the fish protection measures being considered.

Intensive impingement sampling was conduct~ at PBAPS in November 1973 through March 1979. In most years since 1982. as part of the American shad restoration program, impingement of emigrating juvenile American shad bu been monitored at the outer intake. In addition. fish sampling in Conowingo Reservoir was performed during 1996 -

1999 in support of zero cooling tower operation. Exelon

believes that the existing impingement and fisheries data are sufficient to characterize fish species composition.

size, Wtµng, seasonal patterns, vulnerability to impingement, and facton that contribute to impinge_ment.

In general, species composition of impinged fishes, except for the migratory fishes during the fall outmigration period, is similar to that observed dwing the intensive study petiod (1973 - 1979). In short, channel catfish. white crappie. bluegill, and gizzard shad are the most frequently impinged fish currently. However, Exelon is proposing additiQl181 impingement sampling to supplement and valida~ the existing data and to support our calculation of the impingement reductions already achieved.

As mandated by the Phase II Rule, this PIC accomplishes its objective of providing the PADEP_with sufficient details on the infonnation that Exelon intends to *collect and evaluate in order to assure that the PBAPS CDS will fulfill the applicable requirements of the Phase II Rule.

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1.0 INTRODUCTION

. ~*

Section 316(b) of the. Clean Water Act requires the U.S. Environmental Protection Agency (EPA) to ensure that the location, design, construction, and capacity of industrial cooling water intake structures *reflect the best technology available (STA) for reducing adverse* environmental impacts. The Federal Ruic implementing 3 l 6(b) performance standlrds for Phase 11. existing *steam electric power stations was promulgated July 9, 2004 .and became effective September 7, 2004.

This regulation requires that facilities reduce impingement mortality by 80 to 9S% and, if applicable, entrainment by 60 to 90% from a calculation baseline. The Rule also provides a number of compliance alternatives to achieve these standards. Finally, the Rule allows site-specific detennination of BTA based on cost and benefit analyses.

~x~on's PBAPS meets EPA's dermition of a ..Phase II Existing Facility became it is:

a point source requiring a NPDES permit that commenced construction before January 17, 2002,

a generator of electric power for transmission or sale, and

~ designed to withdraw greater than or equal to 50 million gallons per day (MGD) of water, at least 25% of which is used for cooling.

Determination of the applicable pelformance standards for PBAPS is based on the source water type. Since PBAPS withdraws cooling water from a reservoir, Conowingo Reservoir. the applicable perfonnance standard is 80 to 95% reduction in impingement I mortality. This is oonsistent with the detennination that EPA made in Appendix A of the . I Phase ll Rule wh~ it based its cost estimates on PBAPS only havina to meet the I impingement perfonnance standard.

CompliaJiee with the final 116(b) regulations requires PBAPS to submit a PIC to the Director of the PADEP for review and comment. The PIC is the first submission required for 316(b) compliance.

This document _is the PIC for PBAPS and is organized as follows:

Section l describes the main requirements of the Phase D Rule and how it applies to PBAPS. It also provides infonnation on the location, design, and operation of the facility and its cooling water intake structure system;

Section 2 provides a preliminary review of technologies and operatibnal and/or restoration compliance m~sures already implemented and the measures proposed to be evaluated further in the CDS;

Section 3 *summarizes past studies o( impingement and discusses their relevance for development of PBAPS'.s CDS; 3

Section 4 summarizes relevant historical consultations with the State and Federal fish and wildlife agencies;

Section 5 describeS the sampling plan for the new field study; and

Section 6 presentS other infonnation available for PBAPS that will assist the Director in commenting on the CDS.

In preparing this PIC, we have relied on:

existing design. constnlction and operational specifications for the cooling w~ter intake systems;

available ecological impa~ assessment data col1ected at PBAPS;

information describing the ecology of Conowingo Reservoir;

available literature about fish protection alternatives;

generally accepted cost-benefit methodologies; and

specific guidance provided by EPA dming its rule making.

1.1 Facility Locadon PBAPS is a two-unit boiling water reactor with a total output of 2,304 megawatts. Unit 2 began commercial operation in July 1974 and Unit 3 entered commercial service in December 1974. Unit 1 is no longer in service. The power plant is about Smiles from .the Pennsylvania-Maryland border on the west shore of Conowingo Reservoir, a 9,000-acre impoundment on the lower Susquehanna River in southeast Pennsylvania (Figure 1).

Conowingo Reservoir was formed in 1_928 with the construction of Conowingo Hydroelectric Station Project.

1.2 Cooling Water Intake System PBAPS uses a once-through cooling system to remove waste heat from the station* s condensers. The circu~ing water for both units is withdrawn from the Reservoir through an outer intake structure located on the shoreline of Conowingo Reservoir. The withdrawn water flows through two 3-acre intake basins (one serving each unit). and then through the original, inner intak~ structure (Figure 2).

The outer intake is about 500 ft long an4 32 ft high. There are 29 trash racks on the face of the intake followed by a set of 24 vertical traveling screens. The trash racks.

consisting of 0.2.5-inch by 3-inch steel bars spaced 3.5-inches on center, are designed to prevent large debris and ice from entering the intake. They are cleaned periodically on an as needed basis.

The traveling screens are located about 44'ft downstream of the trash racks. Each screen is lO ft wide and has 3/8-inch niesh openings. The design average water velocity 4

approaching the face of the screens (approach velocity) is no more than 0.75 ft/sec at low reservoir elevation and about 0.60 ft/sec at nonnat elevation. The average water velocity passing through the screen mesh (through-screen velocity), at normal reservoir level, is about 1 ft/sec. The screens are nonnally rotated when the pressure differential between the front and back of the screen reaches a particular level. During high debris loading and periods of icing. the screens can be rotated continuously. The screens can be rotated at either 5 or 10 ft/min. Debris (including fish) is removed from the screens by a front spray-wash system and washed into a sluiceway. The debris is dewatered as it passes over a vibrating screen at each end of the sluiceway and collected in a trash bin. No fish or debris are returned to the river.

Before reaching the inner intake, the water flows through the intake basins. The initially constructed intake was the single inner structure, which is close to the plant within the embayment or intake canal, as shown in Figure 2.- When the improved outer intake was consttucted, the intake canal became the basins between the two intake structures.

Earthen dikes separate the basins from the Reservoir. *

Water enters the inner intake through eight screen bays. Two bays screen the service water flows and six filter the water going to the circulating water pumps. The original standard vertical traveling screens in the circulating water bays were replaced with 3/8-in mesh dual-flow (dual*entry singl~exit) traveling ~ in the late 1990s to alleviate carry-over of trash to the condensen. These screens differ from standard traveling screens. such as those at the outer intake, in that the screen faces are ro~ 90 degrees so that incoming water is filtered by both the ascending and descending sides of the screen.

A benefit to this type of screen is* that debris always stays on the upstream side of the screem, effectively eliminating any debris carcyover to the clean side of the ~. The..

screens have a spray-wash system on the ascending side of the. screens to clean them of

debris and fish. Fish live and grow in the basins and can enter them in several ways. e.g.,

through the screens when they are small, carried over the screens if they are not removed during the screen cleaning process,

and through the cross-tie gate from the discharge canal in winter (recirculation system). The materials removed. from these screens are deposited in a dumpster or trash bin.

Approximately 47 ft downstream from the dual flow screens. there are the six circulating .!

water pumps. three per unit. each with a capacity of about 361 MGD (250,880 gpm) for a facility total of 2,168 MGD (3,360 cubic feet per second [ds]). Generally, Exelon operates all six *pumps from April through Octobel:. From approximately November through March, Exelon operates four P-Umps to optimize plant performance. This ____. ,

operational change was initiated in 1984. I On an as-needed basis when ice or debris .restricts water flow through the outer intake structure, a cross-tie gate between the discharge basin and the intake basin is opened to re-~irculate some of the heated discharge water.

During passage through the condensers the temperature of the water is increased by_abou~ .

21°F at full load. The heated non-contact cooling water is discharged into a common s

basin and flows down a 4,700-ft long canal to the Reservoir (Figure 2). Until 1997,

approximately 58% of the cooling water was pumped -through one or two helper cooling towers (as many as five were available) when needed on a seasonal basis to moderate the discharge temperature. The remainder of the discharge water was*passed directly into the discharge canal. As a result of a 4-ycar fishery study of Conowingo Reservoir in 1996 to 1999, and with subsequent concurrence of the regulatory ageµcies, operation of the helper cooling towers was formally ended in 2001.

The entire circulating water flow ia discharged to Conowingo Reservoir via a discharge structure located at the end of the discharge canal. The discharge structure contains one rectangular fixed opening and three regulating ga.tes. The automatic operation of the three regulating gates maintains the velocity of the submerged jet discharge between S to 8 ft/s. The high velocity at the jet discharge provides relatively rapid dissipation of heat and discourages entry of large numbeni off1Sb into the discharge canal.

1.3 Source Waterbody Description Conowingo Reserv~ir, the lower most impoundment on the Susquehanna River, was fonned in 1928 by the backwater of Conowingo Hydroelectric Dam (river mile 10). The Reservoir is bounded upstream by Holtwood Dam (river mile 24) built in 1914. PBAPS, which is at river mile J7, is approximately equidistant from *the two dams (Figure 1).

Prior to the construction of these dams and two .other upstream dams (Safe Harbor at river mile 31 and York Haven at river mile SS), the natural river was wide, relatively shallow. and characterized by areas of swift current with a bottom largely of bedrock, much like which exists today downstream of Cooowingo Dam and in the free flowing areas upstream of Yodt Haven Dam.

Conowingo Reservoir has a surface area of about 9,000 acres and has a gross storage capacity of at least 310,000 acre-feet. It is 14 miles long and averages 1 mile in width.

The average depth of the Reservoir is 20 ft with a maximum depth of nearly 90 ft in the lower Reservoir behind Conowingo Dam. The elevation at nonnal full Reservoir is 108.S ft (Conowingo Datum) and the minimum for operation of Conowingo Hydroelectric Station is 98.S ft. Reservoir elevation is normally maintained at 106.S ft or higher for recreational use on weekends between Memorial Day and Labor Day and at levels no less than 104.5 ft at other times for operation of PBAPS.

Thennal stratification, typically characteristic of many temperate lakes and reservoirs, has not been observed in Conowingo Reservoir-. - However, during the summertime,

generally at water temperatures exceeding 75°F and river flows <12,000 cfs, particularly in deeper areas of the lower third of the Reservoir, limited dissolved oxygen stratification can occur. However, this stratification usually is not strong or stable and quickly breaks down during periods of heavy rain or high winds (Mathur et al. 1987). The operation of PBAPS has not had a detectable effect on this phenomenon.

The volume and flow rates of the Reservoir are variable because of the controlled outflows and inflows that can occur on a daily basis from controlled inflows of up to 6

32,000 cfs from Holtwood Hydroelectric Dam and up to 31,000 cfs (during generation) from Muddy Run Pumped Storage Station (river mile 23). Controlled outflows of up to

. S!S,000 cfs occur at' Conowingo Hydroelectric Station and of up to 27,000 cfs (during pumping) ac Muddy Run Pumped Storage Reservoir. FERC-mandated seasonally adjusted minimum flow requirements apply at Conowingo Dam while no minimum flow requirements exist at the upstream dams.

1

2.0 IMPLEMENTED AND PROPOSED COMPLIANCE TECHNOLOGIES This section provides a brief discussion of the baseline for detennining compliance with the impingement performance standard at PBAPS. It continues with a preliminary evaluation of existing implemented technologies. The primary technology already implemented to minimize impingement is the outer intake structure. In addition, seasonal flow reduction further mluces impingement. FinaUy, this section presents the results of a preliminary assessment of the technologies to be evaluated in the CDS.

As described previously, PBAPS must reduce impingement mortality by 8().95%. This reduction is measured from a "calculation baseline."

The calculation can be generalized .as having three basic steps.

Calculate the impingement mortality for the "baseline" condition,

Cakulate the impingement mortality after whatever teclmological fixes you propose to use or have already installed, and *

Demonstrate that the reduction attributed to teclmological or operational changes and/or restoration falls within the range of u:ceptable percentage reductions. (The si~specific approach is an exception.)

As described in the Phase II Rule, EPA' s '1>aseline" c0nsists of:

Once-through cooling,

Opening of the intake located at the shoreline near the surface,

Standard 3/8-inch traveling screen oriented parallel to the shoreline, and

Baseline practices, procedures, and structuraJ configuration that the facility would maintain in the absence of any structural or operational controls, including flow or velocity reduction, implemented in whole or part for the purposes of reducing impingement mortality or entrainment.

Based on a preliminary assessment, "baseline" conditions at PBAPS are:

Once-through cooling.

The design features of original inner intake structure at the original shoreline of the Reservoir. This baseline intake lacks the design improvements which were built into the present outer intalce to reduce intake velocity and to enable fish to escape from the screens, and thereby minimize impingement. *

The baseline intake is equipped . with standard 3/8-inch traveling screens (not dual-flow) and has JO screens to ftlter the circulating and service water flow.

All impinged materials are deposited into a trash receptacle resulting in 100%

impingement mortality.

8

All of the circulating water pumps are always operated at full design flow and none of the heated effluent is re-circulated in the winter. Full design flow is passed through the baseline intake at all times.

2,1 Preliminary Evaluation of Implemented Technologies In this section we describe the technologies and opeiational measures that have already been implemented at PBAPS and present a preliminary evaluation of the reduction in impingement mortality that has resulted from their implementation.

PBAPS currently operates as a once-through cooJi.r,ig facility, consistent wi.tb the baseline condition. Although the facility had helper coolina towers for part-time use, they are no longer required as a result of s~dies performed in the late 1990's which showed that the aquatic.community was not being banned by the thermal discharge.

The original design to supply cooling water for Uni~ 2 and 3 consisted of only the inner intake structure. The intake has a total of six vertical traveling screens to filter the circulating water and four to filter service water. The original intake structure was built at the original shoreline of the reservoir. However, fill placed jtJst upstream to create 18114 for station. facilities and just downstream for the cooling towers created a* canal leading to the inner intake. The total screened area for circulating Water W8S about 60 ft wide (six 10-ft wide screens) and 20 ft deep, for an estimated cross sectional area of 1,200 ft2. Given the total circulating water intake volume of 3,360 cfs, the construction engineers estimated that the original configuration would have had an* average intake approach velocity of about 2.8 feet per second (ft/s). This high velocity was deemed to.

be adverse for fish. based on high impingement rates observed at other cooling water intakes with similar high velocities. Thus, extensive studies (over S80 laboratory tests) of the swim speeds of resident and anadromous fishes were performed to determine the threshold escape velocity for the common fishes.

The results of these studies, combined with experienc~ from other power stations and i knowledge of fish behavior, provided a basis for the design. modifications needed to minimize impingement. It was realized that most fish entering the intake canal would I

become trapped near the inner intake screens due to the high water velocity approaching I the screens and the absence of lateral escape routes. *Therefore, they would be exposed to the high intake velocities for long periods, resulting in exhaustion, impingement and I death. I White crappie was found to be the weakest swimmer, generally unable to escape velocities exceeding 0.75 ft/s. Consequently, based on the swimming ability of white crappie, Exelon installed an improved outer intake structure to filter all of the water I withdrawn from the Reservoir. The new structure was lengthened to approximately .500 I ft to maintain*an -average intake approach veloclty of less than or equal to 0. 75 ftls at the I face of the screens at the lowest operating Reservoir level of 98.5 ft. The new intake was I provided with 24 vertical traveling screens (12 per unit) equipped with 3/8-in mesh to -. I filter all of the water going into the plant. Also, the new intake structure was located I

9 i

]

I

about 750 ft outward from the original inner screens site and set parallel with the new shoreline to provide fish with lateral escape routes, thus further minimizing impingement.

Because the design Reservoir elevation for the velocity detennination was conservatively set at 98.5 ft, the actual average velocity is less than 0.7S ft/s at the higher nonnal reservoir elevations. The 0.75 ft/sec design intake velocity of the outer screens represents about a 73% reduction in average intake velocity compared to the original intake configuration.

The combination of improvements built into the outer intake structure has substantially reduced the number of impinged fish. However, we lack impingement data for the original inner intake, which is the baseline, to calcuiate the percent reduction.

We note that reducing intake velocity by increasing the screened area bas the same effect as reducing intake flow (volume) while keeping the screened area the same. This conclusion is consistent with EPA's fmding that "reducing ;ntCIU by installing flow reduction technolog;es will result in similarly high reduction of impinged and entrained organisms, ..." (69 Fed. Reg. 41,612).

In addition. "EPA.believu the record contains ample evidence w support the proposition that entrainment is related to flow (see DCN 2-013L-R15 and 2-0131) while impingement is related to a combination offlow, intaU velocity and fish swim speed (see DCN 2-029). *** Swim speeds of affected species cu well as intake velocity must be talcen into account to predict rates of impingement in relation to flow in order to account for t~ ability of juvenile and adult life stages *of species to avoid impingement* (emphasis added).

Thus, it is reasonable to conclude that the reduction in numbers of fish impinged bas been substantial. Exelon will further evaluate the available da~

perform a search for comparable data from other facilities, and may propose a field investigation designed to estimate the magnitude of impingement reduction that has already occurred at PBAPS.

Exelon has made additional progress toward achieving the national impingement perfonnance standard due to intake volume reductions. The volume of cooling water withdrawn through the outer intake screens is reduced by one-thin! when four circulating water pumps instead of the full complement of six are operating, usually in November through March which correlates with the period when impingement is highest. This one-r.bird reduction in flow and, consequently, intake velocity further reduces impingement rates. Some additional volume reduction also occurs when the cross-tie gate is opened to allow temporary recirculation of a portion of the heated effluent back into the intake basins when ice or debris restricts flow through the outer intake structure. Exelon will evaluate the impingement mortality reduction that occurs due to reducing the circulating water flow.

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2.2 Preliminary Evaluation of Proposed Technologies, Operational Measures, and Restoration Options to be Further Evaluated Jn the CDS E~elon conducted a preliminary evaluation of the technologies and operational measures that have potential to enable PBAPS to comply with the perfonnance standard for impingement. Technologies were reviewed for compatibility with site-specific conditions, potential effectiveness, and cost. The technologies were screened to determine which are viable for the site and if further assessment is warranted.

Based on the preliminary evaluation, these compliance alternatives, technologies, and operational measures emerge as warranting consideration in the CDS:

Demonstrate that selected technologies, operational, and/or restoration *measures

in place of or in combination with existing technologies meet the performance standard, or

~ite-specific BTA determination based on cost-benefit, with the following options or combinations of options:

o Include progress already made toward achieving the performance standard by replacing the "baseline" intake structure with the improved outer intake structure and implementing flow reduction measures o Add a fish return system to the outer intake structure o Add fish baskets to the outer intake screens o Employ behavioral controls such as strobe lights and/or sound.

o Make other modifications to the outer screens, e.g.* incorporate smooth screening material to enhance fish survival o Replace the existing outer intake screens, e.g.. with Geiger MultiDisc rotary screeo8 incorporating fish handling technology o Obtain additional volwnelvelocity reduction through reduced (optimized) pump operation and recirculation of cooling water o Employ restoration, e.g., fish stocking or removal of dams on tributaries to the Susquehanna River that block passage of migratory fish .

o Evaluate other options that become apparent during CDS evaluation and appear justifiable.

2.2.1 . Compliance Approaches Exelon selected the two compliance approaches listed above based on the preliminary evaluation of the measures already implemented to reduce impingement mortality, fish species believed to comprise most of the impingement losses, the anticipated magnitude of current impingement, ~d preliminary assessment of the value of impingement losses at PBAPS. For the first compliance approach. Exelon will perform a more detailed evaluation of the _magnitude of impingement reduction due to design and operational measures already adopted. Additional compliance measures will then be evaluated to II

determine those that will provide the incremental reductions needed to achieve the performance standard. The site-specific alternative is being advanced because many of the technologies evaluated thus far are likely to result in "costs that are significantly greater than the benefits. To further evaluate this supposition, Exelon intends to conduct a site-specific cost and benefits evaluation in the CDS.

2.2.2 Modi/J Screens, Install Fish Retum System Modification or replacement of the existing screens is being considered because the present traveling screen system does not have any provision for returning fish back to Conowingo Reservoir. An initial step will be to evaluate means of returning impinged fish back to the Reservoir as an incremental enhancement to the present intake screens.

A further enhancement could include changes such as addition of simple fish baskets (not necessarily enhanced Ristroph baskets) to the screen panels and .a low-pressure spray-wash and fish return system incorporated with more frequent or continuous rotation of the screens. This may be a viable approach to reduce impingement mortality sufficiently to achieve the performance standard in combination with other measures. In addition, this approach is consistent with EPA' s detennination in Appendix A of the Phase II Rule which identified the addition of a fish handling and return system to the existing traveling screen system at the outer intake as the most appropriate compliance technology for addressing impingement at PBAPS.

If necessary and justifiable within the limits of the benefit valuation, Exelon may evaluate more extensive changes to the outer intake structure. For example, vertical traveling screens equipped with Ristropb/Fletcher modified baskets and a fish return system have proven to yield high impingement survival rates at other large, once-through power plants. As an additional modification, if needed, the performance (impingement survival) of Ristroph/Fletcher-modified screens may be improved by including "smooth screen

technology. i.e.. replacing the original coarse woven mesh with a smoother screening material. If screen replacement is justifiable, a relatively new technology, the Oeiger Multidisc screen, may also be considered. This screening technology is installed and operating successfuJly at the D. C. Cook Plant on Lake Michigan and is currently being evaluated for impingement and entrainment reduction in a retrofit situation at a power plant on the Potomac River.

2.2.J Behavioral Devkes Another option is to employ behavioral devices, such as sound or light systems, as an enhancement to one or_more scree11 modifications to divert fish away from the intake structure before they contact the screens. Behavioral devices have limited potential to reduce impingement but may prove, upon further evaluation, to have the potential to be effective with the species at this facility to achieve incremental impingement reductions.

2.2.4 Operational Control8 Reduction in volume of water pumped is a proven way to reduce impingement and will be evaluated. Reducing the number of circulating water pumps in operation or use of variable speed pumps when the full design circulating flow is not needed for efficient plant operation will be further evaluated. Another measure that will be evaluated is 12

recirculation of a portion of the heated effluent through the cross tie-gate between the discharge basin and the intake basins. Flow reduction can be implemented with other options, such as those previously mentioned, to achieve compliance with the perfonnance standard.

2.2.S Restoration If restoration is not eliminated as a compliance option in the Pha8e II Rule, various restoration alternatives may be applicable to PBAPS and will be considered for the CDS.

Most likely, potential restoration measures will be evaluated within the limits indicated by the benefits valuation.

13

3.0 LIST AND DESCRIPI'ION OF PREVIOUS STUDIES The second regulatory requirement of th~ PIC involves .providing a list and deScrlption of historical studies that characteri:ze impingement mortality. entrainment. and the physical and biological conditions near the cooling water intake structures. In addition, the PIC must also describe the relevance of these data to developing the CDS.

A list of the . historical studies that have been conducted for PBAPS is provided in

Appendix A of this PIC. This section includes a summary of the relevant studies.

3.1 Historical Studies Listed in Appendix A The impingemen~ fishery and entrainment studies conducted at PBAPS in the 1970s provided the basis for development of the station's 316(a) and 316(b) demonstrations which were issued in 1977. Numerous other studies in support of the demonstrations were perfonned .over many subsequent years to further evaluate . the effects of the station's thermal discharge and to evaluate the hydrothermal and biological characteristics in Conowingo Reservoir. Impingement and entrainment studies as well as other ecological, engineering and technical studies continued to be conducted through the late 1970s and early 1980s.

More recently, impingement sampling has been performed to monitor river herring and American shad takings on the intake saeens during the fall out-migration period. In addition. a fisheries study to evaluate the effects of the thermal *discharge was performed in the late 1990s to support elimination of the helper cooling towers at PBAPS.

3.2 Review and Evaluatloa of the Relevant Studies The seteetion of technologies for fish *protection at the PBAPS to *meet the 316(b) perfonnance standard is based, in part; 'on the species and life stages of the important fish subject to the effects of the intake structure, their spatial and temporal abundance, and their relative hardiness. Since the performance standard is based on reduction from a calculated baseline, some understanding of the fish communities in the source waterbody and their interaction with the intake structure is necessary to make predictions about the efficacy of potential compliance options. The studies viously performed at the PBAPS provide the information needed to achieve this understanding.

We perfonned a review of the study designs employed* in the sampling programs for impingement to assess data adequacy and relevance to current conditions. Our .review included:

Sampling gear and deployment methods,

Sampling frequency and periodicity,

Sample processing, and 14

Data analysis methods Results of this examination show that:

Sample col~ection gear and methods used for the impingement studies were state*

of*the*art at the time they were employed. In addition. essentially these same methodologies have been used in more recent impingement studies conducted at

similar facilities and would be applicable to impingement studies today.

Sample design was adequate to describe diet. seasonal, and inter*annual variability. The field studies were performed over several years .and sampling frequency was sufficient to describe diet and seasonal variability.

: Acceptable measures were employed to assure collection of quality data. In fact, several of the studi~ formed the basis of l'eer-reviewed technical publications.

We believe that the* existing impingement and fish community data are sufficiently representative to characterize species composition, relative abundance, seasonal patterns, and ~Inerability to intake impacts. -

3.3 .. Summary of the Re~evant Studiea Extensive fishery sampling of Conowingo Reservoir between 1966 and 1999 showed that the Reservoir supports a productive and divene wann water fish community*. Recent sampling. in l 996 - 1999, indicated patterns in temporal variation and spatial distribution similar to those observed in 1966 to 1980. Except for the species introduced in Conowingo Reservoir since 1966. the relative abundance of the previously designated representative important species (RIS) has nOt shown significant changes. However, the abundance of white crappie, though within the historical range. has declined since the introduction of gizzard shad, which is now the most abundant species. While the gizzard shad is numerically dominant. its population size in the Reservoir tends to fluctuate widely from year to .year.* The game fishes such as the smallmouth bass, largemouth bass, yellow perch and walleye are well represented. No designated threatened or eridangered. species are pres_ent, nor are any commercially ~ested fishes present in the Reservoir. *

The following fishes were designated 8S the RIS for the original 316(a) and 316(b) demonstrations for PBAPS: white crappie, channel catfish, bluegill, gizzard shad.

smalJmouth bass, largemouth bass, walleye, bluntnose minnow and spotfm shiner. The alewife, American shad, blueback herring and striped bass have been re-introduced during the last 30 years. Except for the American shad, large populations of the other species ~ve not developed.

No large concentrations of fish have been observed near the PBAPS intake location, even prior to operation of PBAPS. *Additionally, the themtal effluent from PBAPS-has neither acted as a thermal barrier to the upstream movement of American shad nor does it

impede the downstream winter movement of white crappie.. The location of PBAPS was IS

selected to minimize potential interference with fish spawning areas; studies had shown that major spawning areas of common fishes in Conowingo *Reservoir do not occur near the PBAPS intake.

Records of fishes passed upstream at the Conowingo East Fish Lift and Holtwood Fish Lift provide additional data on the fish fauna of Conowingo Reservoir and species that may be impinged. Except for the migratory fishes, the species composition is similar to that observed in Conowingo Reservoir prior to the construction and operation of the fish lifts. Gizzard shad is the most abundant species passed at the lifts. American shad.

blueback herring, and alewife have collectively comprised up to 35% of total fish passed dependent on prevailing hydrological conditions.

3.3.l Impingement Studiea Intensive impingement sampling was conducted at PBAPS in November 1973 through March 1979. Sampling frequency varied from two to four 12-hour periods per wee.le: in 1973 through 1976 with four 12-hour periods the nonn in July-September. *After 1976.

sampling generally was conducted weekly (one 24-hour sample per.week). Fish were identified. measured, and weighed.

More recently in most years since 1982, as part of the American shad restoration program, impingement of emigrating juvenile American shad on outer intake screens has been quantified during fall. Sampling has occurred three times weekly, generally from October through mid-December. The out-migration data provide information on siu, timing, and origin (hatchery versus wild) of juvenile American shad outmigrants.

Although the primaey focus of this program bas been for enumeration of Am~can shad impinged, information on other fishes was also obtained.

In general, species composition of impinged fishes, except for-the migratory fishes during the outmigration period, is similar to that observed in these same months during the intensive, quantitative study period (1973 - 1979). The number of taxa impinged during the outmigration period (generally September through mid-December) has ranged from 14 to 27 with gizzard shad dominating the collections (channel catfish and bluegill were the other numerous species). Although impingement rates appear to be affected by a host of hydrological-physical factors -and the year-class strength of the particular fishes, the number of alosids (American shad. blueback herring, and alewife) observed in impingement collections appears to be dependent on numbel'S of adult alosids passed by .

fish lifts and the numbers of young American shad stocked annually by the*Pennsylvania Fish and Boat Commission.

In the historic studies, channel catfish, white crappie, bluegill, and gizzard shad were most frequently impinged. Most of these fishes averaged less than 120 mm (ages 0 and I). In general, impingement rates for the most common fishes were highest from November to March. However, average rates were affected by a few episodes of high impingement coincident to exceptionally high river flows. We believe that the existing 16

4*.0 AGENCYCONSULTATIONS Exelon .submitted the initial 316(b) demonstration to the PADEP (then DER) in 1977.

Subseqilently, PADEP sent Exelon notice that they accepted the conclusions of the document which demonstrated that Best Technology Available was employed at the facility.

Exelon did not hold any further discussions specific to 316(b) at PBAPS tmtil November 19, 2004 when Exelon met with' PADEP representatives to discuss me Phase 11 316(b) implementation process in general. PADEP did not raise any specific issues or concerns with respect to impingement and entrainment at PBAPS. Subsequently. on May 2S,

.I 2005, *Exelon met with representatives of the PADEP, Pennsylvania Fish and Boat Commission. and Maryland Department of NaturaJ Resources to review the draft PIC.

No other consultations that are relevant to compliance with the §316(b) Rule have occurred with any envirorunental or fish and wildlife agency.

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5.0 PLANS FOR ADDITIONAL INFORMATION COLLECTION This section describes the fieJd study we propose to conduct at PBAPS. The objective of the sampling program is to detennine the species and numbers of fish impinged on the traveling screens at the PBAPS outer intake structure. Data collected in this sampling program will also be used to identify temporal trends in impingement abundance, to evaluate the utility of the existing impingement study da~ and to support preparation of the CDS.

Exelon also intends to collect additional data to support evaluation of impingement at PBAPS and evaluation of technologies. operational

measures, an<:iJor restoration measures. However, specific plans for these efforts will depend on additional evaluation of the measures already implemented to reduce impingement These additional data collection efforts will not affect how the proposed *study to develop a scientifically valid estimate of cw,arrent impingement is performed, but it is expected that the new data will validate and support the calculations of impingement reductions that have occurred due to Exelon's design improvements and operational measures.

5.1 Impingement SampUng Design Impingement sampling will be perfonned over one 24-hour sampling event per week at each outer screenhouse over a 1-year period. Each weekly sampling event will be

scheduled for the same day each week to assure systematic spacing of the events. fu some weeks, holidays, equipment or plant operations may interfe(e with this schedule and an adjustment of a day or two may be necessary.

Note that the screens are normally run in response to a pressure (head) differential, *but that they may run continuously when debris loads are high, usually as a result of high river flows associated with stonns. or when icing is expected. Therefore, provision will be made with the station personnel to assure the screens are operated when needed for sampling and to identify periods when the screens may be running continuously.

Coordination with PBAPS personnel would occur .to identify periods when screen or other equipment is undergoing maintenance which could interfere with impingement sampling.

The weekly sampling events will not be subdivided into predominantly day and night collection periods on a routine basis to obtain infonnation about diel variability in impingement since PBAPS consistently operates at a constant high generation level.

Variable operation of PBAPS to take advantage of diel differences in impingement is not a viable*compliance option.

5.2 Sample Collecdon at the Trash Bins Each weekly sampling event will start by running the screens for at least one revolution to clean them of previously impinged fish. The organisms from this initial cleaning run will to be disposed of as per the nonnal practice at the facility. After the cleaning run. a 19

clean net or basket, trash receptacle, or other device will be installed to capture the impinged fish from the periodi~ screen cleanings during the impingement sampling event.

Fish collected from the subsequent periodic screen cleanings (the sample collection periods) const~tute the periodic samples. Starting with a clean bin or placing a net over the bin will adequately collect the sample for each sample collection period. If a net or basket is used, it will have a mesh size smaller than the mesh size of the intake screens (3/8*inch) to help assure adequate capture of the impinged fish.

5.3 Sample Processin1 For each sample collection period (within each weekly sampling event), the fish will be separated from the debris, identified to species, categorized as to condition. and enumerated. If there ar~ two size groups (e.g. young of the year and older) then each size group will be enumerated, mea5ured ~ categorized as to condition separately. If possible, the impingeme~t sample ~chniciao will be on-hand to observe the sampling run of the screens in order to determine the condition of impinged fish as soon as they are collected.

Fish will be identified to species and at least 20 individuals of each species or size group (age class) in each sample will be measured for total length to the nearest millimeter. If excessive numbers of a particular species are collected in a sample, the total number in each length group for that species will be estimated from a sub-sample count or weight extraP<<>lation. Care will be taken that the sub-sampling technique is random to minimize size bias.

For each sample the following information will be recorded on the appropriate data sheets: *.

Date and time of the day at the start ~d end of each sample.

Fish enumerations, measurements and observations of condition.

Intake water temperature and dissolved oxygen at the start and end of each sampling period. *

Identification of the circulating and service water pumps in operation*for each unit during the sampling period. *

Identification of the SCICens in operation during the sampling period.

Note if the cross-tie gate is in open and heated water is being re-circulated, obtain any available infonnation about the use of the tie-gate during the sampling period.

Reservoir water level.

Names of the sample collectors. *

Any deviations from the sampling protocolt unusual conditions, or other pertinent observations (e.g., observations of dead/moribund gizzard shad drifting into the intake).

20

S.t mW. fir Collectloa llfider1cJ T~ts

,A.fa: taaly,is.. spcci.-iens needct far Ile next rollection efficiency study will be retained.

At least 100 fish rer ~pecies.Aerl1tf1 d ass are needed for each calendar quarter's release, of 1hose ~cies rial:iag ap a1 lus1 lOCll rf 1he quarter's total collection. The fish will be fror.en lll'til need eel, If Jq!Je!aJtii"tes of thase species making up more than 10% of a q.ta.tter's ttlll eollfaio.11. are aot naiktlle. l!ubstitutes may be selected from species of coqmd:lle s_i2c E:l1d l:xicly~:ipe, ~aui er obtained elsewhere.

!.S

CrjJ4c1b Erli:lellCJI Sllldies Tile ~ c1 ttE oollic:tia"J diciellcy testing is to detennine the percentage *of fish ph:f!d 4in:d y cm lle sc:reeas tJa ER SJbsequendy recovered in the impingement oolectiJluJ. Suii:s a rilllY (Xl'M:r phn: cooling water intakes have shown that the i~piagen.e~

Hmpli18 :maJ allda'l:stilrae the number of fish that are actually being hpiaged .~se si:ne pr*portDI af in"llilied fish may be consumed by predators, pass

~ ~pemmgs i* tic s::xeering strocruic, carry over to the clean side of the screens, de.

Ccilec1im effd.~ st-.<li.cs vii \e c:on.dl.rted when the species of interest (dominant or n*meti:H.l:y lr:Vt ~ f"&l) uc availabl i an.d nwnerous in the collections~ Studies will be corD!cEd .periaclmty, at 1(9;t 41.lHt~tly or on a modified schedule ir' needed to accoll1Il04atc tie prcsace of tic species of interest. A target

number of 100

~gsi c~a' 1isll per species a:xl lqtb cl~ (if available) are to be released as cklse ~ (XHiible t:J fEK:e r£ tic travetm, sc:aeeas at the start of a 24-hr sampling event~

Sevi:nl s::a:ea:JS er1Cllqa:iq l:mh 1.riu ~11 be evaluated. The actual number released ancl tie rurb:J i~dy Jec:overecl K1 each size class over the following 24 hr will be teeoJCiel. N* st~ &11~f1g urill be mloP\'cd on sampling dates on which collection efficie..ey :it.Kl e are am.11Cte4..

s,, Smn(lle Halldlmg Wl'B1 p10ceu:Its of l u,.ple is coqhe, we will determine the disposition of the umple (wletler to clixaad it _er s*bje(t it to QC procedures for counts and icle*tiic11icns) Aftei fish b cdlec1i.m efficiency testing and any fish needed for the rc1cii:n::c cofh:.tioa lr ~ '1eiifatioa have been removed from the sample, the

'pecinms l"Ji.) ~e ciicar4.ed* iato t\e tra!li bin. All young American shad will be pr°'4cled 10 tbc ~lvatia Fbl aid BOEt Ccmnnission so that they can detennine if the speri lllQ~ B"e of wilt cc la~ cii&il1.

5.1 Qalf3 AISlll"BllCf 8114 Cllltl'Cll A 4etaied S1En:la.xl quatillJ Procecbe and QuaHty Assurance Project Plan wiJI be i:reJH"ed to iover!l tile pedi:::l:nam:e oc tiis study prior to initiating the field collections.

full iclerii:fici.ticiu. 0011ats. llCD Jre2911e111euts will be subject to QC checks. Field in.stn.JITJ:rlt5 Mii re ealhttecl pmr '1 etd1 sample event. Data entry and processing will ah* le subject to.qtaliy cAecks. Q~ wdits ud tests wi11 b~ pert'ormed periodically to 21

verify the achievement of quality during the study and to indicate when corrective action is needed.

5.8 Data Analysis and Reporting Numbers of fish impinged for each weekly 24-hr sampling event will be used to calculate the number of fish impinged per week and these will be summed to develop the annual totals. Impingement data from the sampling periods within 24-hr sampling events will be evaluated to detennine diel variation. The periodic collection efficiency tests will indicate the correction factors that need to be applied to the data to develop the total impingement numbers.

Seasonal and annual descriptions of species composition and abundance will be provided.

The results from this new study will be compared to impingement data obtained in previous studies at PBAPS to assess annual variability and will be compared with other data sets that may be available or applicable.

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6.0 OTHER INFORMATION The final component of the PIC involves providing other infonnation that will aid the Director in reviewing and commenting on the plans for developing PBAPS's CDS. This section presents an overview of some studies and plans required for the site-specific determination of BTA.

6.1 BeneOts Valuation Study The Phase II 316(b) Rule allows for site-specific impingement and entrainment reduction

.requirements based on cost-benefit assessment. Specifically, a demonstration that the costs of technological compliance with the performance standards is significantly greater than the benefit allows for lesser reduction in impingement and entrainment or the use of restoration to achieve compliance. A Benefits Valuation Study (BVS) is required for this assessment and is based on a comprehensive methodology to value the impacts of impingement mortality and entrainment at the site and the benefits of complying with the applicable performance standards. The BVS study plan will include:

A description of the methodology(ies) used to value commercial. recreational, and ecological benefits (including any non-use benefits, if applicable).

Documentation of the basis for any assumptions and quantitative estimates.

An analysis of the effects of significant sources of uncertainty on the results of the study.

If requested by the Director, a peer review of the items submitted in the BVS. The facility operator would choose the peer reviewers in consultation with the Director who may consult with EPA and Federal, State, and Tribal fish and wildlife management agencies with responsibility for fish and wildlife potentially affected by your cooling water intake structure. Peer reviewers must have appropriate qualifications depending upon the materials to be reviewed.

A narrative description of any non-monetized benefits that would be realized at your site if the facility were to meet the applicable perfonnance standards and a qualitative assessment of their magnitude and significance.

There are a number of inputs to developing a BVS for an individual facility. The following list describes the inputs and the methods that will be used for each.

Convert impingement and entrainment sample data to annual -estimates:

The BVS will use a sample-period weighted extrapolation to convert the sample data to annual*loss estimates.

23

petermine the number of Age-1 egujyalents impinged and/or cntQincd:

The BVS will use EPA's life history parameters to detennine the number of Age-1 equivalents impinged or entrained.

Detennine the rati_o of caught to uncaught fish:

The value of impingement and entrainment reductions depends on whether or not spared organisms are harvested. This determination will be based on EPA assumptions of catch by species.

Determine commercial versus recreational breakdown:

Harvested fish are valued differently in the commercial and recreational markets. This determination will be based on EPA assumptions regarding ~ational and commercial catch.

Detennine commercial hnpacts:

This detennination will employ EPA's percent change in dockside value approach.

Determine recreational impacts:

Recreational impacts are the largest benefit category in EPA's national analysis. In this analysis, EPA employs regional random utility models (RUMs) to estimate the dollar value impacts from increases in catch rates. The BVS will use these models to develop a rigorous benefits transfer.

.Address nonuse values of uncauaht fish:

EPA requires a narrative description of non-monetized benefits and a qualitative assessment of their magnitude and significance. The BVS will provide this narrative desCription.

Include uncertainty analysis:

Analysis of uncertainty in recreational benefits estimates may include bootstrapping to address sample variance, Monte Carlo Analysis for model variance, and an interactive evaluation of variance arising from model specification.

6.2 Comprehensive Cost Evaluation Study The Comerehensive Cost Evaluation Study component of the CDS must include engineering costeStimates for implementing design and *construction technologies, operational measures, and/or restoration measures that would comply with 316(b) performance standards. The three components of the Comprehensive Cost Evaluation Study are:

Engineering cost estimates of technologies/meas~ to meet the applicable perfonnance standards, expressed as Net Present Value including energy penalties, carrying charges, as examples discussed below 24

Demonstration of cost-benefit test.

*Engineering cost estimates to document the cost of technologies/measures in the Site-Specific Technology/Restoration Plan.

6.3 Site-Specific Technology Plan If Exelon requests a site-specific detennination of BTA. this plan will be included in the CDS. This plan is required to contain: *

A nmative description of the design and operation of all existing and proposed design and construction technologies or operational measures and/or restoration measures that we have selected.

An engineering estimate of the efficacy of the proposed and/or implemented technologies and/or measures based on representative studies at exjsting facilities and, if applicable. site-specific prototype or pilot studies.

A demonstration that the proposed and/or implemented technologies and/or measures achieve an efficacy that is as close as practicable to the performance standards without resulting in costs significantly greater than the benefits of complying with the applicable performance standards.

'-4 Site-Specific Restoration Plan The final Phase n Rule states that EPA views restoration measures as part of the design'_'

of a cooling water intake structure and considers restoration measures one of sevenl technologies that may be employed to minimize adverse environmental impact. . If restoration remains an option in the Phase U Rule. Exelon will consider small restoration projects to achieve compliance.

25

i I

I

7.0 REFERENCES

Mathur, D., E.S. McClellan, and S. Haney. 1987. Effects of Variable Discharge Schemes on Dissolved Oxygen at a Hydroelectric Sta~ion. Water Resources Bull.

24{1): 159-167.

PECO. 1976. 316(a) Demonstration for PBAPS Units No. 2 & 3 on Conowingo Pond.

Supplementary Materials prepared for the Environmental Protection Agency, June 1976. Philadelphia Electric Company.

PECO. 1977. 316(b) Demonstration for PBAPS Units No. 2 & 3 on Conowingo Pond.

Materials prepared for the Environmental Protection Agency, June 1977.

Philadelphia Electric Company.

26

I I

I*

I r CIECIL Figure *1. Map of Conowingo Reservoir showing locations of Peach Bottom Atomic Power Station and other power plants.

27

Figure 2. Peach Bottom Atomic Power Station's cooling water intakes and discharge.

~-

28

APPENDIX A List of Historical Studies 316(b) and Related 316(b) Demonstntion .**

Philadelphia Electric Company. 1977. 316(b) Demonstration for PBAPS Units NQ. 2 & 3 on Conowingo Pond. Materials prepared for .the Enviro~ntal Protection

Agency, June 1977.

lchthyological Ass~iates, "Inc. 1977. Peach Bottom Atomic Power Station materials prepared for the EPA 316(b) demonstration for Peach Bottom Atomic Power Station Units No. 2 and 3 on Conowingo Pond, 103 pp.

,* ~and Post-operational. Reports that indude Impingement and Entrainment llesult8

Robbins, Timothy W., and Dilip Mathur.. 1974. Peach Bottom Atomic Power Station pre-operational report on the ecology of Conowingo Pond for Units No. 2 and 3.Ichthyological Associates, Inc., Drumore, Pa., prepared for Philadelphia Electric Company, xviii + 349 pp. * .

Robbins, Timothy W., and Dilip Mathur. 1974. Peach Bottom Atomic Power Station Post-operational Report No. 1 on the ecology of Conowingo Pond for Units No. 2 and 3. Ichthyological Associates, Inc., Drumore, Pa., prepared for Philadelphia Electric Company. xiii + 142 pp.

Robbins, Timothy W., and Dilip Mathur. 1975. Peach Bottom Atomic Power Station Post-operational Report No. 2 on the ecology of Conowingo Pond for Units No. 2 and 3. lchthyological Associates, Inc** Drumore, Pa., prepared for Philadelphia El~ic Company, xix+ 192 pp.

Robbins, Timothy W., and Dilip Mathur. 1975. Peach Bottom Atomic Power Station Post-operational Report No. 3 on the ecology of Conowingo Pond for the period of July 1974-December 1974. lchthyological Ass~ates, Inc., Drumore, Pa.,

prepared for Philadelphia Electric Company, xxiv + 338 pp.

Robbins, Timothy W., and Dilip Mathur. 1975. Peach Bottom Atomic Power Station, Post*operational Report No. 4 on the ecology of Conowingo Pond for the period January 1975..June 1975. lchthyological Associates, Inc.* Drumore, Pa., prepared for Philadelphia Electric Company, xxiii + 322 pp.

Robbins, Timothy w.. and DiJip Mathur. 1976. Peach Bottom Atomic Power Station Post-operational Report No. S on the ecology of Conowingo Pond for the period July 1975-December 1975. Ichthyological Associates, Inc., Drumore, Pa.*

prep~ for Philadelphia Electric Company, xxiii + SOI pp.

Robbins, Timothy W., and Dilip Mathur. tm. Peach Bottom Atomic Power Station Post-operational Report No. 6 on the ecology of Conowingo Pond for the period January 1976-June 1976. lchthyological Associates, Inc., Drumore. Pa.. prepared for Philadelphia Electric Company. xv+ 191 pp.

29

lchthyological Associates, . Inc. 1977. Peach Bottom Atomic Power Station Post-operational Report No. 7 on the ecology of Conowingo Pond for the period July 1976-December 1976. lchthyological Associates, Inc., Drumore, Pa., prepared for PJtiladelphia Electric Company, xxi + 313 pp.

Ichthyological Associates, Inc. 1977. Peach Bottom Atomic Power Stati~ Post-operational Report No. 8 on the ecology of Conowingo Pond for the period

)anuary 1977-June 1977. Ichthyological Associates, Inc., Drumore, Pa.. prepared

. for Philadelphia Electric Company, xi+ 186 pp.

RMC Ecological Division. 1979. Peach Bottom Atomic Power Station, Post-operational Report No. 9 on the ecology of Conowingo Pond for the period of July 1977-December 1977. Prepared for Philadelphia Electric Company. Muddy Run Ecological Laboratory. Drumore. Pa. xiv+ 245 pp.

Other Reports/Presentations/Papen Impingement Robbins, 1unothy W., Pauline L. Heisey, and Paul G. Heisey. 1975. Envirorunental deviation report for impingement of fishes at the Peach Bottom Atomic Power Station Units No. 2 and 3 on 25-27 February l 97S. lchthyological Associates.

Inc .* Drumore, Pa., March 1975, prepared for Philadelphia Electric Company, 10 pp.

Mathur, Dilip, Paul C. Heisey, ai1d Nancy C. Magnusson. 1976. Impingement of fishes at a nuclear powei: station on the lower Susquehanna River. A paper presented at the 106th Ann. Meeting Amer. Fish Soc.,

Dearborn,

Michigan.

Mathur, Dilip, Paul C. Heisey, and Nancy C. Magnusson. 1976. Impingement of fishes at a nuclear power station on the lower Susquehanna River. A paper presented at the 32nd Ann. N. E. FISb and Wddlife Conf., Hershey, Pennsylvania.

Mathur, Dilip, Paul G. Heisey, and Nancy C. Magnusson. 1977. Impingement of fishes at Peach Bottom Atomic Power Station on Conowingo Pond, Pennsylvania. Trans.

Amer. Fish. Soc. 106:258-267.

RMC Environmental Services Division. 1981. Report on impingement of gizzard shad at Peach Bottom Atomic Power Station, Units 2 *and 3, Decembe.- 1980-January 1981. Prepared for Philadelphia Electric Company..7pp.

Canberra/Radiation Management Corporation. 1984. Impingement of fishes at Peach Bottom Atomic Power Station. Units No. 2 and 3, during December 1983 and early January 1984. Prepared for Philadelphia Electric Company. ISpp.

Heisey, P. G. 1987. Peach Bottom Atomic Power Station inner screens fish impingement.

Letter report to D. Mathur, 8January1987. 2pp.

RMC Environmental Services, Inc. 1994. Analysis of potential factors affecting the white crappie population in Conowingo Pond. Prepared for PECO Energy Company.

12pp.

Nonnandeau Associates, Inc. 1996. Environmental review of proposed upgrade to intake water system at Peach Bottom Atomic Power Station. York County, Pennsylvania. Prepared for PECO Energy Company. 3pp.-

Matty, R.M. Jr., D. Mathur, P. L. Hannon. 1999. PECO Energy's 316(b) experience with

. specific reference to Peach Bottom Atomic P.ower Station, Permsylvania. In 30

Proceeding: 1998 EPRI Clean Water Act Section 316(b) Technical Workshop.

Coolfont Conference Center. EPRJ 1999 TR-112613.

Normandeau Associates. Inc. 2000. Data report on intake screen sampling at the Peach Bottom Atomic Power Station in 1999. Prepared for Peach Bottom Atomic Power .

Station; 3pp.

Normandeau Associates. Inc. 2000. Data report on intake screen sampling at the Peach Bottom Atomic Power Station in 2000. Prepared for Peach Bottom Atomic Power Station. 3pp.

Entrainment Boyer. Helen A. 1970. Eff~t of passage of zooplankton*through Peach Bottom Atomic Plant, Unit No. 1. preliminary data report. 65 pp.

Boyer, Helen A. 1971. The effect of passage of :it?<>Plankton: through Peach Bottom Atomic Plant, Unit No. 1. M. S. nesis. University of Minnesota, Minneapolis, M~. .

Anjard,. Charles A.* 1978. Entrainment of fish eggs and larvae at Peach Bottom Atomic Power Station. A paper pteseoted at the 34th Ann. Meeting N. E. Amer. Fish.

Wildlife Cont** Sulphur Springs. West Virgiqia.

Swim Speed Schuler, Victor J. 1968. Progrc:ss report of s\vim speed study conducted on fishes of Conowingo Reservoir. lch1hyolasical Associates, Holtwood, Pa., Progress Report lB. prep~ for Philadelphia Electric Company, 61 pp.

King, Laurence R. 1969. Swimming speed of the channel catfish, white crappie and other warm water fishes from Conowingo Reservoir, Susquehanna River, Pa.

. lchthyological Associates, Ithaca, NY. Bulletin No. 4, Much 1969, prepared for Philadelphia Electric Company, 74 pp.

Hocutt, Charles H. 1970. The eff~ts of temperature on the swimming.performance of the largemouth bass, spotfin shiner, and.channel catfish. lchthyological Associates, .,

Holtwood, PA, Progress Report S. February 1970, prepared *for *Philadelphia Electric Company, 6S pp.

Hocutt. Charles H. 1970. The e~fects of temperature on the swimming performance of the largemouth baas, spotfm shiner, and channel catfish. M. S. Thesis~ Southern Conn. State College, New Haven, Conn.

Kotkas, Enn. 1970. Studies of the swimming speed of some anadromous fishes found below Conowingo Dam, SusCJ!Channa River, Maryland. lchtbyologicaJ Associates, Holtwood, Pa., Progress Report 6, February 1~0.-prepared for Philadelphia Electric Company fol submission tQ the Advisory Board, 19 pp.

Hocutt, Charles H. 1973. Swimming pedormance of three wannwater fishes exposed to a rapid temperature change. Chesapeake Sci. 14:11-16.

Hannon, P. L, 0. Mathur. and R. M. Matty, Jr~ 1999. Design *of CWJS in accordance

. with fish swim speed measurements at Peach Bottom Atomic Power Station.

Presentation at the Power Generation Impacts on Aquatic Resources Conference.

April 1999. AtJanta, OA.

31

Pre- and Post*operadonal Reports (those that indude Pond limnology, fash distribution, abundance, and movement, thermal testing, biology of fishes, and/or creel surveys)

Robbins, Timothy W., and Dilip Mathur. 1974. Peach Bottom Atomic Power Station pre-operational report on the ecology .of Conowingo Pond for Units No. 2 and 3 lchthyological Associates, Inc., Drumore,. Pa., prepared for Philadelphia Electric Company, xviii + 349 pp.

Robbins, Timothy W., and Dilip Mathur. 1974. Peach Bottom Atomic Power Station Post-operational Report No. 1 on the ecology of Conowingo Pond for Units No. 2 and 3. Ichthyoiogical Associates, Inc., Drumore, Pa** prepare4 for Philadelphia Electric Company, xiii+ 142 pp. .

Robbins. Timothy W., and Dilip Mathur. 1975. Peach Bottom Atomic Power Station Post-operational Report No. 2 on the ecology of Conowingo Pond for Units No. 2 and 3. lchtbyological Associates, Inc** Drumore, Pa., prepared for Philadelphia Electric Company, xix+ 192 pp.

Robbins, Timothy W., and Dilip Mathur. 197.5. Peach Bottom Atomic Power 'Station Post-operational Report No. 3 on the ecology of Conowingo Pond for the period of July 1974-December 1974. lchthyological Associates, Inc** Drumore. Pa.,

prepared.for Philadelphia Electric Company, xxiv + 338 pp.

Robbins, Timothy W., and Dilip Mathur. 1975. Peach Bottom Atomic Power Station,

. Post-operational Report No. 4 on the ecology of Conowingo Pond for the period January 1975-June 1975. lchthyological Associates, Inc., Drumore, Pa., prepared for Philadelphia Electric Company, xxiii + 322 pp.

Robbins, Timothy W., and Dilip Mathur. 1976. Peach Bottom Atomic Power Station

Post-operational Report No. S on the ecology of Conowingo Pond for the period July 197S-December 197S. Ichthyological Associates, Inc., Drumore, Pa.,

prepafecl*for Philadelphia Electric Company, xxiii + 501 pp.

Robbins, Timothy W., and Dilip Mathur. 1977. Peach Bottom Atomic Power Station Post-operational Report No. 6 on the ecology of Conowingo Pond for the period January 1976-June 1976. lchthyological Associates, Inc., Drumore, Pa., prepared for Philadelphia Electric Company, xv+ 191 pp. *

lchthyological Associates. Inc. 1977. Peach Bottom Atomic Power Station Post-operational Report No. 7 on the ecology of Conowingo Pond for the period July 1976-December 1976. lchthyological Associates, Inc., Drumore, Pa.~ prepared for Philadelphia Electric Company, xxi + 313 pp.

I lchthyological Associates, Inc. 1977. Peach Bottom Atomic Power Station Post-operational Report No. 8 on the ecology of Conowingo Pond for the period January J'Y/7-Juoe 1977. lchthyological Associates, Inc., Drumore, Pa., prepared for Philadelphia Electric Company, xi+ 186 pp.

RMC Ecological Division. 1979. Peach Bottom Atomic Power Stati0"9 Post-operational

Report No. 9 on the ecology of Conowingo Pond for the period of July 1977-December l'Y/7. Prepared for Philadelphia Electric Company. Muddy Run Ecological Laboratory, Drumore, Pa. xiv+ 245 pp.

RMC Ecological Division. 1979. Peach Bottom Atomic Power Station Post-operational Report No. 10 on the ecology of Conowingo Pond for the. period of January 1978-June 1978. Prepared for Philadelphia Electric Company. Muddy Run Ecological Laboratory, Drumore, Pa. xv+ 210 pp.

32

RMC Ecological Division. 1979. Peach Bottom Atomic Power Station. Post-operational Report No. 11 on the ecology of Conowingo Pond for the period of July 1978-December 1978. Prepared for Philadelphia Electric Company. Muddy Run Ecological Laboratory, Drumore. Pa. xiv+ 24S pp.

RMC Ecological Division. 1979. Peach Bottom Atomic Power Station Post-operational Report No.* 12 on lhe ecology of Conowingo Pond for the period of January 1979-June 1979. Prepared for Philadelphia Electri~. Company. Muddy Run Ecological Laboratory. Drumore, Pa. xv+ 210 pp.

RMC Ecological Division. 1980. Peach Bottom Atomic Power Station Post-operational

Report No. 13 on the ecology of Conowingo Pond for the period of July 1979-December 1979. Prepared for Philadelphia ~lectric Comp~y. Muddy Run Ecological Laboratory, Dru~ore, Pa. x + 196 pp.

RMC Ecological Division. 1980. Peach Bottom Atomic Power Station Post-operational Report No. 14 on the ecology ofConowingo Pond for the period of January 1980.

April 1980. Prepared for Philadelphia Electric Company. Muddy Run Ecological LabOratory. Drumore, Pa. xi+ lS3 pp.

NPDES/~oollng Tower Reduction Studies RMC Environmental Services. Inc. 1994 (January). A report on the fish populations in Conowingo Pond relative to the NPDES pennit application for the Peach Bottom Atomic Power Station, Pennsylvania. Prepared for Philadelphia Electric

Company. 8pp:

RMC Environmentai Services. 1994. Analysis of potential factors _affeciing the white crappie population in Conowingo Pond. Prepared for PECO Energy. Company. I+

12pp. .

Nonnancleau Associates, InC. 1995 (August). Summary of thermal surveys for PBAPS.

Data report prepared for Peach Bottom Atomic Power Station, Philadelphia Electric Company. 10 pP. .

Nonnandeau As~iates, .Inc. 1996 (May). Study plan to assess fish Populations in Conowingo Pond relative to the reduction in cooling tower operation at the Peach Bottom Atomic Power Station, P~ylvania. Prepared for PECO Energy Company. 19pp. . *

Nonnandeau Associates. .Inc. 1997 (March). A report on the assessment of fish populations and thermal conditions in Conowingo Pond relative to. the variable cooling tower operation at the Peach Bottom .Atomic Power Station. Prepared for PECO Energy Company. 106~ +Appendices.

Normandeau Associates, Inc. 1997 (March). Study plan fQr fish protection in Conowingo Pond relative to zero cooling tower operation at Pe8ch. *Bottom Atomic Power Stati~ Pe.nnsylvania. Prepared for PECO Energy Company, 16pp. .

Nonnandeau Associates. Inc. 1998 (February). A.report on the thennal conditions ~

fish populations in Conowingo Pond relative to zero cooling tower operation at Peach Bottom Atomic Power Station (June-October 1997). Prepared for PECO Energy Company. 67pp: + Appendices.

Nonnandeau Associates, .Inc. 1999 (February). A report on the thermal conditions and fish populations in Conowingo Pond relative to zero cooling tower operation at Peach Bottom Atomic Power Station (June-October 1998). Prepared for PECO Energy Comp~y. 67pp. +Appendices.

33

Normandeau Associates, Inc. 2000 (February). A report on the thermal conditions and fish populations in Conowingo Pond relative to zero cooling tower operation at Peach Bottom Atomic Power Station (June-October 1999). Prepared for PECO Energy Company. 68pp. +Appendices.

Normandeau Associates, Inc. 2000 (June). Assessment of cooling tower operation at Peach Bottom Atomic Power Station on potential fish habitat. Prepared for PECO Energy Company. 7pp. + tables and figures + Appendices.

34

ML19067A109

Text

Dear Mr. Barron,

SUMMARY

1.0 INTRODUCTION

SUMMARY

SUMMARY

1.0 INTRODUCTION

7.0 REFERENCES

Dearborn,

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