ML20063K242

Supplemental Responses to Interrogatories.Certificate of Svc Encl

ML20063K242
Person / Time
Site:	Limerick
Issue date:	09/01/1982
From:	Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	DEL-AWARE UNLIMITED, INC.
Shared Package
ML20063K240	List: ML20063K238 ML20063K242
References
NUDOCS 8209030288
Download: ML20063K242 (18)

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00(,gD pp-2si51 0FFICE OF SECRETAfl ggrETJ':,G &,SEi' ~

t ,,0 UNITED STATES OF AMERICA NUCLEAR REGULATORY CCMMISSION In the Matter of )

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Philadelphia Elecrric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units.1 and 2) )

APPLICANT'S SUPPLEMENTAL RESPONSES TO 1 "INTERRCGATORIES OF DEL-AWARE UNLIMITED, INC.

! ADDRESSED TO APPLICANT PHILADELPHIA ELECTRIC COMPANY" t

i September 1, 1982 l .

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8209030298 820901 DR ADOCK 0500035g PDR

Interrogatory 1(d): Please state the anticipated nelocities in one foot, five foot, and ten foot circumferential distances, at each point (or representative points) along such circumferences surrounding the proposed intake screens. Please indicate the anticipated velocity of the water .at such points, noting the location of such points, when the flow of the Delaware River at Trenton is 2,000 CFS.

Response: To the exten Applicant has such information, it answered this interrogatory in its response filed August 20, 1982. Applicant has no further information responsive to this interrogatory and is not required'to do research to-respond to this interrogatory.

Interrocatorv 1(f) : Please state the anticipated distribution of tne water sources between Tchickon Creek and the Delaware River through the intake . at various flows in velocities, including velocities of 2,000, 2,500, 3,000, 3,200, 3,500, 4,000, 5,000, 6,000, 7,000, 8,000, 9,000, and 10,000 CFS in the Delaware River.in combination with those of 200, 500, 750, 1,000, 1,500, 2,000, 2,500, and 3,000 CFS from the Tohickon Creek.

Answer: As Applicant stated in its August 20, 1982 response, Applicant has no currently available information responsive to this interrogatory.

Interrogatory 1(g): Please state whether PECO is presently . committed to providing compensatory storage to maintain Delaware River -flow and, if so, the location at which the storage will be maintained; .the anticipated date of construction of 'such storage facility; whether an i environmental impact statement has been . prepared for such facility; whether application has been made to any agencies other than DRSC for accroval of such facility, and,. if so, the names of such agedcies, the dates of such applications, and their present status.

Answer: As PECO witnesses stated at depositions on August.5, 1982 (Tr. 88-96), PECO is a joint applicant with six other utility companies for construction of a storage reservoir on Merrill Creek, in Harmony Township, Warren County, New Jersey. The project is needed to fulfill'DRSC's requirements that utilities planning consumptive use of Delaware River. water provide compensatory flows to be released from storage when DRSC cannot maintain the flow at Trenton at more than 3,000 cfs.

The construction of the storage facility will begin promptly upon receipt of all necessary permits and l

i approvals. It is expected that the f acility will be ready for filling in 1985 and will be in full operation during 1986.

Application for project approval was filed with the DRSC on December 30, 1977. In mid-1982 the Commission issued the draft Environmental Impact Statement which is currently under review.

! MERRILL CREEK RESERVOIR PROJECT

( PERMITS OR APPROVALS

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Agency Filing Date Status Department of Army Permit for the Delaware River intake USACOE 10/23/80 Pending L

l State Agency Filing Date Status i

Permit to Construct or Repair a Dam Ingersoll Rand Dam NJDEP 4/21/80 Approved 5/27 Merrill Creek Dam NJDEP 4/22/80 Pending Water Lowering Permir Ingersoll Rand NJDEP 1/27/80 Approved 1/27/82 Soil Erosion & Sediment Control Plan NJDOA- 12/12/81 Approved WCSCD 1/27/82 County Warren County Road Crossing Permit WCRD 6/11/81 Pending Municical i

Dam Demolition Permit Harmony 5/28/80 Approved Ingersoll Rand Township 5/28/80 I

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Interrogatorv 1 (i) : Bearing in -mind that the intake will be operated by .WRA at low flow periods even if not operated for PECO's use, please state .the anticipated minimum surface water elevation and clearance ~a bove the

. intake at the proposed location, and state what measures, if any, are planned to maintain , a minimum : water elevation-sufficient to protect members of the public engaged in boating and tubing in the vicinity of the intake. Please describe in detail any such measures.

Answer: As explained at the depositions of PECO

, witnesses, on August 5, 1982 the elevation of the surface j water at the intake will be a minimum of 70 feet (Tr. 121).

The elevation of the water above ~ the intake will be a minimum of 4 feet. This is a. sufficient buffer to protect

people engaged in boating and tubing.

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Interrocatorv 3: Please state the basis of .any conclusions and describe in detail any studies -leading to the conclusion that the intake as presently proposed will not be subject to frequent or occasional outage due to debris and ice conditions in the river. Also please describe any studies relating to the potential for ice damage, and describe any plans made or other measures considered in response te such potential.

• Answer: As explained by PECO witnesses at depositions on August 5, 1982, PECO does not anticipate that ice and debris will cause any damage to the intake structure (Tr.

216-24). While there is ice in the Delaware River during the winter months, no ice jams in the Point Pleasant area at the intake site have been observed. If an ice jam were to occur, it would most likely occur upstream at the old br_idge piers or at the Lumberville Dam and would not affect the' Point Pleasant intake.

Further, the intake is 4 feet below the surface and any ice or debris would likely pass over the intake. In the unlikely event that ice or debris reaches 4 feet below the surface and causes damage, it would present a minor maintenance problem of short duration. No dredging would be required; a diver would perform any necessary repair work.

i To further assure no damage will occur, the upstream end of each screen will be fitted with a nose cone to streamline the bypass flow and to fend off any material that might impact the screens. Also, three 12 inch diameter steel j guard posts will be installed immediately upriver frcm the screens to provide added protection against ice or debris, t

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The intake will have minimal usage during the winter and early spring when floating ice, frazil ice, and debris may be present in the river. For these reasons, frazil ice is not likely to be a problem.

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Interrocatory 9: With respect to the Merrill Creek Reservoir, please indicate the extent of compensatory storage which it is expected to provide, and the potential impact of the failure to obtain approval of such reservoir or some other alternate storage facility, on the operation of Limerick (assuming both Units 1 and 2 are operated).

Answer: Applicant provided this, information at depositions August 5, 1982 (Tr. 88-96). As Applicant's witnesses explained, Merrill Creek could provide 200 cfs of flow for a period of 115 days. If the Merrill Creek project is not approved and no other water is available, no water will be taken from the Delaware other than in accordance with the conditions of the DR3C docket decisions as authorized by the DRSC.

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Interrogatory 12: Please. identify and describe the contents and conclusions of any reports, studies or other material relating to the phasing of the construction of the Point Pleasant diversion and the timing of the work in the ,

river. In other words, please provide a complete description of and identify all information made available to PECO relating to the need to undertake constructing in the Delaware River during the first winter of project construction (i.e., 1982-83).

Answer: The timing and-phasing of the construction at Point Pleasant was discussed fully at depositions on August 6, 1982 (Tr. 46-86). As explained by the NWRA witnesses, DRSC has required that NWRA undertake work in the river between November and March. It is necessary to begin during the winter months of 1982-1983 so that river work can be completed during the winter of 1983-1984. The letter of September 9, 1981 from E. H. Sourquard to the Corps of Engineers discusses phasing of construction work.

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Interrocatory 13: Please identify all documents constituting, relating to, or considering the operating plan for the Point Pleasant intake, in and of itself, and as related to the Bradshaw Reservoir and/or proposed releases to the Perkiomen Creek. Please identify any final or presently final documents relating to or constituting such operating plan.

Answer: Applicant objected to this interrogatory to the extent that it requested information relating to proposed releases to the Perkicten Creek. Except with regard to this issue, Applicant responded fully to this interrogatory in its August 20, 1982 response. One document, a letter from E. E. Sourquard to W. Haines Dickinson, dated August 10, 1982, which discusses the Point Pleasant Pumping Station and the Bradshaw Reservoir operations, is added to the list of documents contained in the August 20, 1982 response.

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Interrocatory 17a: Please describe PECO's present plans with respect to applying for a permit under Section-316(b) of the Clean Water Act, and other federal water-quality permits relating to the intake water.

Answer: No application will be filed by PECO for any intake on the Delaware River under Section 316(b) of the Clean Water Act. Applications are not filed for intake structures as such under Section 316(b). As a matter of information PECO will - apply at the appropriate time for Section 402 NPDES permits with regard to the Limerick discharge into the Schuylkill River. This application will include the description of the intake structure on the Perkiomen and the Schuylkill under which PaDER may make an evaluation as to "best available technology" as to the intake structures.

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n Interrogatorv 17b: Please describe any studies or reports relat_ng to cne compliance of the intake with EPA guidelines requiring application of .best available

, technology pursuant-to Section 316 of the Clean Water Act, and identify any documents, reports or contacts relating to the necessity for compliance with the requirements of that section.

Answer: PECO has large intake structures at all of its generating stations and thus has kept abreast of developments in design for many years. The basic study relating to this subject was the " Development Document for Best Technology Available for the Lccation, Design, Construction and Capacity of Cooling Water intake Structures for Minimizing Adverse Environmental Impact." This document contains information on the background to Section 316 (b) of the Clean Water Act. It was published by the EPA under the administration of Russell E. Train in 1976.

Other basic references concerning wedgewire screens are the " Passive Intake Screen Workshop" dated December 4-5, 1979 and " Larval Exclusion Systems for Pcwer Plant Cooling Water Intakes" from Proceedings of the Workshop Held at Shelter Island Inn, Santiago, California February 7-8, 1978.

The intake at Point Pleasant will use wedgewire screens.

i These screens are generally accepted by fishery . biologists as being state of the art to further reduce impingement and entrainment of aquatic life.

Interrocatorv 20: Please identify and describe the contents anc conclusions of any reports, .or evaluations of .

reports, submitted by intervenors or other opponents of PECO in any proceeding before an' agency, and made available to PECO of its technical consultants (including, but not limited.to, reports by GKY Associates, Ezra Golub, and Edwin Seemer) relating to hydrolics, hydrology, location of the intake and the ambient velocities, tne effects of blasting, or any other impacts. Please identify any reports relating to water quality information submitted by intervenor or any other opponent of PECO to the Pennsylvania Department of Environmental Resources, the Corps of Engineers, or any other agency, and made available to PECO or any of its technical consultants.

Answer: PECO responded fully to this interrogatory, as clarified in Intervenor's Motion to Compel Answers, in its August 20, 1982 response.

Interrogatory 21: Please describe the extent to which the data in the MIRA Environmental Report of February,1979, was . considered in preparing the July 1979 Report and identify all documents in which such data was considered.

Please describe the- coordination between the NWRA Environmental Report of February, 1979, and PECO concerning the collection, analysis, interpretation, and/or presentation of water quality data for the Delaware River.

Please identify all documents constituting, reflecting, or ,

prepared in the course of such consideration.

Answer: PECO responded to this interrogatory in its August 20, 1982 response.

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VERIFICATION COMMONWEALTH OF PENNSYLVANIA  :

ss.

-COUNTY OF PHILADELPHIA  :

VINCENT S. SOYER, being duly sworn states that he is Senior Vice President, Nuclear Power, of Philadelphia Electric Company, the Applicant herein; that.he has read the contents of " Applicant's Supplemental Responses to

' Interrogatories of Del-Aware, Unlimited, Inc., addressed to Applicant Philadelphia Electric. Company'" and that the statements and matters set.forth herein are true and correct to the best of his knowledge, information and belief.

5 VINCENT /S. BOYER SUBSCRISED AND SWORN TO before me this 1st day of September, 1982.

'Z 5/ .

l Notary Puclic I

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Supplemental Responses to ' Interrogatories of Del-Aware Unlimited, Inc. Addressed to Applican: Philadelphia Electric-Company,'" dated September 1, 1982 in the captioned matter have been served upon the following by hand delivery, as noted below, or by deposit in the United States mail this 1st day of September, 1982:

Judge Lawrence Brenner (2) Docketing and Service Section Atomic Safety and Licensing Office of the Secretary Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555

• Stephen H. Lewis, Esq.

Judge Richard F. Cole Ann P. Hodgdon, Esq.

Atomic Safety and Licensing Elaine I. Chan, Esq.

Board Counsel for NRC Staff U.S. Nuclear Regulatory Office of the Executive Commission Legal Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Judge Peter A. Morris Washington, D.C. 20555 Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555

Atomic Safety and Licensing Appeal Panel Philadelphia Electric Company U.S. Nuclear Regulatory ATTN

Edward G. Bauer, Jr.

Commission Vice President &

Washington, D.C. 20555 General Counsel 2301 Market Street Philadelphia, PA 19101

• Hand Delivery I

-O 2-Mr. Frank R. Romano Walter W. Cohen, Esq.

61 Forest Avenue Consumer Advocate Office of Ambler, Pennsylvania 19002 Attorney General 1425 Strawberry Square Mr. Robert L. Anthony Harrisburg, PA 17120 Friends of the Earth of the Delaware Valley W. Wilson Goode P. O. Box 186 Managing Director 103 Vernon Lane City of Philadelphia Moylan,' Pennsylvania 19065 Philadelphia, PA Mr. Marvin I. Lewis Steven P. Hershey, Esq.

6504 Bradford Terrace Community Legal Philadelphia, PA 19149 Services, Inc.

Law Center Judith A. Dorsey, Esq. North-Central Beury Bldg.

1315 Walnut Street 3701 North Broad Street Suite 1632 Philadelphia, PA 19140 Philadelphia, PA 19107 Donald S. Bronstein, Esq.

Charles W. Elliott, Esq. 1425 Walnut Street 123 N. 5th Street Philadelphia, PA 19102 Suite 101 .

Allentown, PA 18102 Mr. Joseph H. White, III 11 South Merion Avenue Mr. Alan J. Nogee Bryn Mawr, PA 19010 3700 Chestnut Street Philadelphia, PA 19104 Dr. Judith H. Johnsrud Co-Director, ECNP Robert W. Adler, Esq. 433 Orlando Avenue Assistant Counsel State College, PA 16801 Commonwealth of Pennsylvania DER

• Robert J. Sugarman, Esq.

505 Executive House Sugarman & Denworth Box 2357 P.O. Suite 510 Harrisburg, PA 17120 North American Building 121 South Broad Street Thomas Gerusky, Director Philadelphia, PA 19107 Bureau of Radiation Protection James M. Neill, Esq.

Department of Environmental Box 217 Resources Plumsteadville, PA 18949 Sth Floor, Fulton Bank Bldg.

Third and Locust Streets Director Pennsylvania Harrisburg, PA 17120 Emergency Management Agency Basement, Transportation and Safety Building Harrisburg, PA 17120

• Hand Delivery (

Robert M. Rader