ML20096B407

Answer to Applicant First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence

ML20096B407
Person / Time
Site:	Limerick
Issue date:	08/30/1984
From:	Aptowicz B PHILADELPHIA, PA
To:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
Shared Package
ML20096B389	List: ML20096B383 ML20096B407
References
OL, NUDOCS 8409040134
Download: ML20096B407 (14)

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RE:2,TED CCRRES?QtiDENCF.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD 00%

UAQED Lawrence Brenner, Chairman *84 pg Dr. . Richard F. Cole Pl2 05 Dr. Peter A.' Morris -

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In the Matter of:  :

PHILADELPHIA ELECTRIC COMPANY  : DOCKET NOS. 50-353-OL

-(Limerick Generating Station, 50-352-OL Units -1 & 2) ,

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"4 CITY OF PHILADELPHIA'S ANSWERS h TO APPLICANT'S FIRST SET OF INTERROGATORIES AND. REQUEST FOR PRODUCTION OF DOCUMENTS i

1. Ca a b) . .The specific expert witnesses to be presented  ;

by the City have not yet been determined, and may include, but is not limited to, any or all of the persons furnishing Answers to the Specific Interrogatories hereinaf ter set forth, as well as others

c. The subject matter of the testimony will include, but is not limited to, s

(1). Description of City Water Supply and Water Supply System, and Usages; (2). Capability of Treatment Facilities ;

(3). Potential Contamination Levels; -

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(4). On-Line Reservoir Capability; (5). Alternative Sources of Water Supply;  !

(6). Mitigation Treatment Techniques Available to the City; (7). Regulatory Environment Pertaining to the . City Facilities Operations; (8). Economic Responsibility to Accommodate 3 Plan for and Implement Emergency Planning Procedures ;

(9 ) . Such other testimony as is deemed appropriate.

(d & e). To be developed in the testimony.

2. (a). The specific fact witnesses to be presented-by the City have not yet been determined, and may include, but is not limited to, the persons furnishing Answers to the Specific Interrogatories hereinafter set-forth, as well as others.

(b). See 1(c) above.

(c). To be developed in the testimony.

3. The legal-bases for the City's Issues of Conce'rn have been submitted to the Board, Applicant and all other parties in documents previously filed. There may be other such publications and documents to legally and f actually support the City's Issues, but same have not yet been determined.

Inasmuch as the direct testimony of other parties has not yet been received, it is impossible, at this time, to determine cross-examination plans of other witnesses whom may testify.

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SPECIFIC INTERROGATORIES

1. a. . Belmont Clear Water Basin 4300 Ford Road Philadelphia, Pennsylvania 19131 b.- 0. 5 ; l. 8, MG

c. Belmont High Service - District #6 (See Attachment B1

d. None

e. Belmont Plant Answer by: Charles Zitomer Load Con, trol' Water Department 29th & Cambria Street Philadelphia, Pa. 19132

a. Belmont Filtered Water Basin and Clear Water Basin 4300 Ford Road Philadelphia, Pennsylvania 19131

b. 19 ; 20, MG

c. Belmont Gravity - District #5 (See Attachment B)

d. 48" main over Girard Avenue Bridge from East Park Booster Pump Station

e. Belmont Plant Answer by: Charles Zitomer Load Control Water Department 29 th & Cambria Streets Philadelphia, Pa. 19132

a. Roxborough Standpipes IIarner and Sunset Streets Philadelphia, Pennsylvania 19128

b. 3. 5 , 11. 0 , MG

c. District #9 (See Attachment B)

d. Primarily supplied from Queen Lane Plant to Roxborough High Service Pump Station. Baxter Plant water'is also interconnected through West Oak Lane Pump Station.

e. See Roxborough Answer by: Charles Zitomer, Chief Standpipes' - d above. Load Control 29th & Cambria Streets Philadelphia, Pa. 19132

2. a. Belmont Clear Water - Close 26 filter effluent valves (5 minutes).

b. Belmont Filtered Water Basin and Clear Water Basin Close 26 filter effluent valves and' electric valves (15 minutes) -

c. - Roxborough Standtanks - Manually close supply valve (45 minutes)

Answer by: Charles Zitomer, Chief-Load Control >

29 th & Cambria Streets Philadelphia, Pa. 19132

3. As of this date, the City believes that viable alternative sources of water supply in the event of contamination of the Schuylkill River include interconnections with a contiguous suburban water supply such as the Chester Water Authority or the Philadelphia Suburban Water Company,, as well as , ,

increasing present covered wa,ter reservoir owned by the Citv.

These alternatives would have to be investigated and con-sidered before they could be viewed as viable. In addition, the City believes that the .use of bottled water and tank truck water supply, although helpful under special limited conditions, would not satisfy full demand under *a contamination scenario.

Answer by: Bruce Aptowicz

. Manager Water Department .

1170 Municipal Services Bldg.

Philadelphia, Pa. 19107

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4. A meeting was held on May 14,19 84 in the Municipal Services Building at the request of Zori. Ferkin of the Governor's EnergyLCouncil. Present were Ms . Ferkin, John McParran, representatives of Chester Water Authority, Phi,ladelphia suburban Water Company and the City of Philadelphia including Bruce Aptowidz. Philadelphia expressed an interest to the .

State and other adjacent water suppliers 'in having a study conducted to evaluate the potential for system interconnections.

It is our recollection that although the State believed that' the study should be. con

• ducted and considered contractiitg a consulting engineer for this effort, they ultimately decided -

to not perform the, study, primari1[due to lack of funds. '

It was the position of the adjacent water utilities that they would be happy to cooperate in the stud'y. No further discussicn occurred on this subject matter with government

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utility or consultant personnel.

To respondent's knowledge, no efforts have been made by the City to evaluate the practicality of obtaining wate,r from

' substituted sources. The City has performed preliminary studies in the last few years to evaluate the practicality of supplying ,

f water to Philadelphia suburban Water Company. In addition,

! a study was performed pertaining to supplying water to Bucks Co.

Answer by: Bruce Aptowicz-Manager, Water Operations 1170 M.S.B.

Philadelphia, Pa. 19107

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5. See Answer to Specific Interrogatory No. 4 above.

Answer by: Bruce Aptowicz Manager, Water operations 1170 M. S . B .

Philadelphia, Pa. 19107

6. The scope -of the City's authority to take action requiring water conservation and prohibition of "non= essential" uses is set-forth in the City of Philadelphia's Drought Water ,

Emergency Plan (Attachment C) . As.of this date, the City has not investigated its legislative authority to ration water for such " essential purposes" as drinking, ' cooking, bathing and sanitation. No procedures are in place to effectuate water rationing.for " essential uses" in the event of a radiological emergency other than those in the attached Drought Water Emergency Plan for "non-essential" uses. As of this date, the City has not investigated procedures which must be taken to effectuate water rationing in the event of a radiological emergency at Limerick.

Answer by: Dennis Blair Manager Planning h Research 1270 M.S.B.

Philadelphia, Pa.1910 7

7. See Answer to Interrogatory No. 6 above. No other efforts have been made by the City.

Answer by: Dennis Blair Manager Planning & Research 1270 M.S .B .

Philadelphia, Pa. 19107 S

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8. None, as . of ' this ' date.

Answer by: . Dennis Blair Manager Planning & Research 1270 M.S .B .

, Philadelphia, Pa. '1910 7 9.' . None, as of this date.

Answer. by: Dennis Blair Manager Planning & Research

. . 1270 M.S .B.

Philadelphia, Pa. 1910 7

10. As - of this date, the City has no knowledge of such plans, :nor has thecity undertaken to investigate other

, emergency plans, nor has . it attempted to determine which r cities have a similar geographical _ relationship to a large Nuclear Plant located upwind and upriver of its water supply.

Answer by: Bruce Aptowicz Manager, Water Operations 1170 M.S .B .

Philadelphia, Pa.1910 7

11. The City has listed below various alternatives of which. it is aware, which have potential .for decontanination of dater sources. The City has not determined that this is a exhaustive list nor has it evaluated each of these specifically with regard to the unique requirements of the City's water supply and water supply systems. In addition to evaluating the existing treatment methods and procedures at the City's Water Treatment Plants for their efficiency in removing 9

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contaminants in the event of a release from Limerick, the City believes that emergency planners should evaluate processes which can remove such contamination, including but not limited to the following processes:

(a). reverse osmosis;

-(b). ion exchange; (c). post carbon contactors; (d). repetitive filtration; (e) . increased pH precipitation; (f) . alternative coagulants; (g). powdered activated carbon; 4

(h) . 'chapnical filter aids , and (1) . pclymers.

Emergency planners would have to consider each of these alternative methods individually and evaluate their effectiveness at, applicability to, and implementability for, each of Philadelphia's- Water Treatment Plants under the conditions which would exist in the event of contamination of the Schuylkill and the Delaware Rivers for an extended period of time. This evaluation should also include the effects on water quality, treatment plant operation, and maintenance, as well as consideration of costs from a Capital & Annual Operating Budget standpoints.

Answer by: Thomas Kulesza Manager, Water Treatment PlanC-29 th & Cambria Streets Philadelphia, Pa. 19 132

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1:2. See Answer to Specific Interrogatory No. 10 above Answer by: Bruce'Aptowicz Manager Water Department 1170 M.S .B .

Philadelphia, Pa. 19107

13. See Answer to Specific Interrogatory No. 4 above.

Answer by: Bruce Aptowicz Manager Water Department 1170 M.S.B.

Philadelphia, Pa. 19107

14. See Answer to Specific Interrogatory No. 4 above.

Bruce Aptowicz Answer' s- b{ Manager 1 Water Department 1170 M.S .B .

Philadelphia, Pa.19107

15. See Answer to Specific Interrogatory No. 4 above.

Answer by: Bruce Aptowicz Manager Water Department 1170 M.S .B .

Philadelphia, Pa.19107 l DOCUMENT REQUEST 1

Two documents have been attached in response to General Interrogatory No. 4 and Specific Interrogatory No. 6 (Attachments

'A and B, respectively.)

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In addition, the city may rely upon other documents in presentation of its direct case or on cross-examination or which otherwise may relate to its concerns. The city's plans for presenting its direct case and testimony have not been finalized yet, nor has the City received the testimony of others on.which it can make plans for cross-examination.

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i ~ COMMONWEALTH OF PENNSYLVANIA .!

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!. ' BRUCE APTOWICE, being. duly sworn'according to law,' deposes and _

j l_ says that'he is the Manager of Water Operations-of the Water Department of the City of' Philadelphia; that_he is authorised to

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and doe's make this Affidavit on its behalf; and that the facts set-forth'in tho'foregoin's Answers are true and correct partly upon personal knowledge and the' remainder upon information and belief.

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(L _ c ) J - u .L BRUCE APTOWICf' Y

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1 Sworn to and subscribed . I before me this4 #g ,

day * '

of August, 1984

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RCLni[6 CCI;T.'L:' ClICUICE UNITED STATES . OF AMERICA NUCLEAR REGULATORY COMMISSION

. ATOMIC SAFETY AND LICENSING BOARD BEFORE THE ADMINISTRATIVE JUDGES 00;grr"n UJ.Qc Lawrence Brenner, Chairman Dr. Richard F. Cole Dr.' Peter A. Morris *g E 31 P12:06 Vpe...c .

00MnTng-[ /,[j In the Matter-oft  : ONANC PHILADELPHIA ELECTRIC COMPANY  : Docket Nos. 50-353-OL' 50-352-OL~'

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.(Limerick Ge'nerating Station  :

~ Units 1 and 2)

CERTIFICATE OF SERVICE I hereby certify that the city of Philadelphia's Answers to Applicant's First Set of Interrogatories and Request for Production of Documents in the- above-captioned matter have been served on the following persons named on the attached

' service list by hand delivery or by causing the same to be j deposited' in envelopes addressed to said persons , first class ,

i j postage prepaid, and deposited with the United States Postal Service at Philadelphia, Pennsylvania 19107 Respectfully submitted, l

,,}- O'd TERI R. SIMON, Assistant City Solicitor Dated: August 30, 1984

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=== VEE u BT . $ n -~ -

l Honorable Laurence Brenner (PE) Mr. Frank R. Baanno I

, Administrative im Judge 61 Forese Avenus Acomic Safety & fl Board ,

Ambler, Pennsylvania 19002 U.S. Eaclear on '

Washiriston, D. . 205 5 -

Honorable Bichard F. Cole (PE) k. Gregory Minor Administrative Law Judge M5 Technical Associates Acamic Safecy & flm1= Based 1723 Henilton Avenue U.S. Maclear Lummimmian San Jose, California 95125 Washimston, D. . 205 .

Honorable Peter A. Morris (PE) & agens J. Bradley l Administrative Im Judge Philadelphia Eactric Campany 1 Acamic Safety & flW= Board Ammar4=e= General Counsel U.S. Eaclear A  :==4aa 2301 Market Screec Washirgeon, D. . 205 Philadelphia,- Pennsylvania 19101 ,

Docketing & Service Section Eduard G. Bauer, Jr. .;

Office of cbs h aary Vice-Presidant & General Comsel ,

U. S. Eaclear Regulatory Casatssion Ph11adelphia Eactric ?-- - ./ l Washington, D. C. 20555 2301 Martat Screet

' Philadelphia, Pennsylvania 19101 BenjamLn H. Vogler, r w g (yg) 0.E.L.D. W. Vincent Boyer U.S. Eaclear Regulatory Cannission "- -Senior Vice Presidene i Washington, D. C. 20555. la=taar tions

- Philadal naceric O --;- .y-Mark Wetterhahn, rf.dn (PE) 2301 Market Screet Troy B. Carmer, Jr. . . E=adM Philadelphia,. Pennsylvania 19101 NLis N. Nicholas, Esquire Conner & Weccerhehn Mr..J. T. Robb, N2-1

• 1747 Pennsylvania Avenus, N.W. Philadal Eactric C m -

Washington, D.C. 20006 2301 c Screet ,

Philadelphia, Pennsylvania 19101 i Robert L. /. d mf '

103 Vernon lans Honorable Lawrence Coughlin Moyland, 7-..eylvania 19065 House of Represencacives ~

Congress of the United Staces l Maureen telligan, Esquire Washiriscon, D.C. 20515 .

Limerick Ecology Accion -

Post Office Box 761 Frank Hipparc, Director Poccacoun, r..wf vania i 19464 Pennsylvania Energency Management Agency B-151 i Zori G. Ferkin (FE) Transportation and Safety Building l Assistanc Counsel Harrisburg, PennsylvanLa 17120 l I

Go w . s 's Energy Council . l l 1625 North Franc Screet Roger B. Reynold, Jr. , 'Esq.d.re P.O. Box 8010 324 Swede Street Harrisburg, Pemsylvania 17125 Norriscown, Pennsylvania 19401 '

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I Timothy R. S. Campbell W . Marvin I. lauis Deparement of Buergency Serives 6506 Bradford Terrace 14 Esse Eiddle Screet PM1adal FM=, Pennsylvania 19149 West Chester, Pennsylvania 19380 -

. Frederic M. Wentz Coury Soliettor .

W:- - q Norristoun, Pennsylvania 19406 Angus love, F_= d n .

101 East Main $creet i i Norriscoun, Permsylvania 19401 l

, W. Joseph H.14d. tie, III 8 North A-..r Avenue Bryn Mawr, Pennsylvania 19010

a. mare t.. Sug.ri.en, F - ,

Sugereen, Danuarch & Hellegers <

16th noce, Cancer Plaza , .4*

101 North Broad Screet 1  ;

Philadelphia, Pennsylvania 19107 l 2

7. Charles W. Elliott, F =' d n 1101 Pd w g I . . .

-Easton, T .sf vania i 18042 Spence W. Perry, F_and q

. Associate General Counsel  ;

Federal T cf Managnanc Agency i '

Ream 840 -

500 C. Screec, S. W.  !

Washington, D.C. 20472 ,

U. S. N. R. C. Region I 631 Park Avenue King of Prussia, Permsylvahia 19406 Thanns derusky, Director Bureau of Radiacion Protection

. of Environmental Resources M oor, Tulcon Bank Building Third a locuse Screets Harrisburg, Pennsylvania 17120 Acanic Safety & Licensing Appeal Panel

. U. S. Nuclear Regulatory Ccnmissien Washington, D. C. 20555 e

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