ML20099L300

Forwards 850315 Application Under Section 3.8 of Delaware River Basin Compact.Related Correspondence

ML20099L300
Person / Time
Site:	Limerick
Issue date:	03/19/1985
From:	Wetterhahn M CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Edles G, Gotchy R, Kohl C NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
CON-#185-163 OL, NUDOCS 8503200556
Download: ML20099L300 (32)

Text

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TED CORRESPONM LAW OFFICES CONNER & WETTERHAHN,' P.C. ][

17 47 PEN NSY LVANI A AV EN U E. N. W.

TROY B. CONN ER , J R.

WA S HIN O TO N, D. C. :2 0006 winx J. wETTEnxanN ROBERT w. MADER .N .Ac o* 5 # 9 PS :19 DOUOIAS X. OLSON JESSICA H. IAVERTY NILS N. NICHOLS 7 7.f.y ,,; C ~; ( ~ y Q' d ?

ROBERT N. PU" 00ChlibG f'= St r 'ifP**

"'"""*E'""*""""" March 19, 1985 bit %@,,oo,,,,:,rou,,

e'$ 7 'l Christine H. Kohl, Esq. Gary J. Edles, Esq.

Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Reginald L. Gotchy Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter of Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2)

Docket Nos. 50-352 and 50-353-d(-

Dear Board Members:

Inasmuch as the Staff has requested a copy of Philadelphia Electric Company's March 15, 1985 Application under Section 3.8 of the Delaware River Basin Compact, copies are being sent to the Appeal Board and parties.

Sincerely, t

Mark J. Wetterhahn Counsel for Philadelphia Electric Company MJW/ac Enclosure cc: Service List

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8503200556 850319 DSo]  ;" ^* * ****?R*

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< PHILADELPHIA ELECTRIC COMPANY 8 -

2301 MARKET STREET - .

P.O. BOX 8699 PHILADELPHIA. PA.19101 EOw ARO e. S AUER. JR.

weespas.ees.,

as.ees.esassewn.ab EUG EME J. SR AOLEY a..eeen,e se. sea 6eew.ses DON ALS SLAMMEM RUOOLPM A. CMGLLEMS E.C.MIRMMAbb T. M. M AMER CORNELL PAUb AUERSACM

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EOw ARO J. CuLLEN. JR. March 15, 1985 TMOM AS M. MILLER. JR.

GR EME A. MeKEMM A

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Ms. Susan Weisman, Secretary Delaware River Basin Commission P. O. Box 7360 West Trenton, New Jersey 08628

Dear Ms. Weisman:

Transmitted herewith for filing with the Commission is Philadelphia Electric Company's Application under Section 3.8 of the Compact for approval of the temporary substitution, during 1985, of in-stream monitoring of dissolved oxygen levels in place of the 590F temperature constraint on withdrawals for Limerick Generating Station Unit No.1 incorporated in Docket Decision 69-210CP (Final) November 5, 1975, and as necessary release of varying amounts of water, not exceeding 32.5 cfs, from water supply storage during 1985.

This filing consists of six copies of the following documents: a) completed DRBC application form, including Attachments 1 and 2 and Exhibits 1 through 8 thereto; b) completed DRBC Environmental Fom; and c) completed Applicant's Statement - Project Review Fee Form.

Enclosed is Philadelphia Electric Company's check in the amount of $100 i to cover the Project Review Fee.

h affidavit of Vincent S. Boyer, Senior Vice President, Nuclear Power, Philadelphia Electric Company, which is part of Attachment 2 of the application, indicates that issuance of a full power license from the Nuclear Regulatory Commission for Limerick Unit No. 1 can be anticipated about May 1, 1985; that in order to proceed with the power ascension program after issuance of the license it is necessary to have in place a supplemental cooling water system; that delays in proceeding to full power.will delay commercial operation of the unit, and that the cost of not operating the unit for lack of l water is estimated to be $49 million per month.

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. l 2-Accordingly, the Company requests immediate action on its application, f pursuant to Section 2-3.9(c) of the Commission's Rules of Practice and Procedure to protect the public interest and to avoid substantial and irreparable injury to the public and to the Company.

Communications regarding this application should be directed to the s

undersigned.

1 Very truly yours, l

?

., Edward G. uer, Jr.

EGB,JR:pke Enclosures i

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i DELAWARE RIVER BASIN COMMISSION .

'em; 1

Type of Application: (Check one or more - see reverse side) i l

(a) Addition to the Comprehensive Plan . . . . . . . . . . . . . . . . .

(b) Change in a Comprehe nsive Plon Project . . . . . . . . . . .y.

(c) Approval under Section 3.8 of the Com Pursuant to the Delowore River Bosin Coinpoet For Use of Commission and the Rules of Practice and Procedure of the Docket No.

Delowere River Bosin Commission, cpplication Date Received is hereby made for review of the project des- Action by Commission

's (A) Application From: '

Nome' Philadelphia Electric _

CLwv Mailing Address 2301 Market Street, _

Philadelphia, PA 19101 _

Telephone (215) 841-4000 Nome of Counsel Edward G. Bauer, Jr. m and Eugene J. Bradley Nome of EngineerV. S. Boyer _

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(B) Type of Project: (Check) (4) Stream Encroachment. . . . . .

(I) Impoundment . . . . . . . . . . . . . . . . ( ) (5) we l l . . . . . . . . . . . . . . . . . .

(2) witharowol of Water. . . . . . . . .(x)(6) O th e r . . . . . . . . . . . . . . . .

(3) Disposal of Wast es. . . . . . . . . . .(1)

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' Description of Project:

(C)

I For 1985, withdrawal of water fme tM Schiviki11 River fnr m ..,mn*iva .

at Ilmarick Generatirn Station Unit tb.1 bv tmuurarv stream monitoring of dissolved oxygen levels in olace of 59 F tscreramre constraint inmrporated in Docket No.69-210 CP (Final) s e fe, l

and as necessary, release of varvim arramen nf t.nwr m* av.= a frcm water sucolv nuiace as muugrimea.

==id docket to be inapplicable to any such releases. _

ste Signcture of Authorized Person g,;n Nome y .Bovar TitIc Senior Vice Presiden_L._

Do1eg/f/2.f*_ Nu,cl_ep_r_fpwer

Delowere River Basin Commission

==

n_._____._ .._ ENVIRONMENTAL FORM ,

Date 3[f/pf ,

Applicant Philadelphia Electric Conpany l Title of Project Interim consunpeive water Supply L4marick Generating Station DRBC Docket No.

Location "

l. List any significant environmental impacts, beneficial and adverse, caused by proposed action. instream nonitoring of

'Ihe beneficial impact of- the requested tour.,rary =tatitution of dissolved oxycren levels in place of the 590F taigrature constraint and the requeste release of water fran the Blue Marsh Reservoir or other basin water supply storages a back-up supolv will be to r.=enit sci-M_iled cceration of Liire.DRBC rick, Level already evalua B Study; DRBC.

See, DRBC FEA for Neshaminy Water Sucoly System (August %ere1980):will be no adverse and AEC/NBC FES for Limerick (November 1973 and C April 1984). (See Paragraph '

impacts fran the tangerary suspension of the 59 F tanperature constraint.

below) . here will be no adverse imonets fran the release of water f1un Blue See, COE E S for Blue Marsh (Aoril 1971); the Sunolisterit to the- CCE wTc for' Blue Marsh sa2=,1973) ; and the DFdic Tavel B Study (May 1981). See Atta h t 1.

What mitigati,ng measures will be used to reduce or alleviate the adverse 2.

0 There will be no adverse impacts fran the tu%rarv susc+.iision of the 59 F tanDeratur I constraint. Degradation of water cuality of the Schuv1 kill River below the Limerick Generating Station will be precluded by insi.rt:am nonitorina of dissolved oxvoen l

and releases fruin sater sucolv sL, race when DO levals fall Miew m.whable levels.

here will be no%us, adverne'imrar tm frm the ramastad ralaness of m*=v f n no mitioneino man =nram naea M uraartahn.

sucolv storace.

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3. Summarize the alternatives considered.

Se alternatives considered were (1) no action, (2) release of water frua See the Ontelaunee Reservoir, and (3) release of water fran Green Iane Reservoir.

Attachnent 2.

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4. - List any known objectors to the Proposed action.

None. . _ _

M W e .- .e _

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• D Inwsro Rivsr B: sin Ccmmissi n N? 4501 APPLICANT'S STATEMENT - PROJECT REVIEW FEE (See Reverse Side For AdditionalInformation) rwnnany

1. Nome and Address of Applicant _ __Ph41=Aalphia Elmic 2301 Market St., Philadelphia, PA 19101 __ ]

- Li r+ rick Generating Station

2. Nome of Profect Docket 15- _

, Interim Omenwtive Water Supply

3. Type 'of Fro (ect Check Applicable item (s) W

--(o) Impoundments (b) diversions of water into or out of the Delowore River Bosin (c) Industrial water use and waste treatment facilities (d) electric generating and transmission facilities

-(e) petroleum product pipelines

- (f) stroom encroachments and

_(g) withdrawal of ground water '

4. Project Cost Foctors (Complete,oll lines using Zero where opplicable)I Estimated Cost item 0

o. Des!gn 0

b. Supervision of Construction 0

c. Legal Services .O

d. Contract Administration $ 0 *

e. Land $ 50,000-

f. Materials $___

45,000 -

g. Construction' and Fabrication ,

0 TOTAL ESTlMATED PROJECT COST.

non :si.Iuctural - tm-sary suspension of 590F L=wture constraint ard release of varyim amounts not excaaiig 32.5 efs of water Footnotes / Remarks supply storage from Blue Marsh Reservoir or other basin water supply s

k opplicable it'em(s))

5F 5 Computation:

(The filing fee is the greater of (a) or (b)) .. 100.

(a)$

E (o) minimum fee: $100 for any projects or (b)

(b) ohernative fee: , , ,

-(1)$

(1) .1/10, of 1%' of estimated.,p'roject cost up to $1,000,000. (2)$__

_(2) 1/50 of .1% of remaining cost obove $1,000,000s but not ~"'

to exceed'a maximum fee of $50,000 os to any one project, exclusive ,of odded environmental fies..

Total $_100.00 1 *

6. Filing Fee Required with Applic'otion

• Please enclose check in this omount with opplication. Check should b4 mod ,

l River Sosin Commission.

NOTE: Should this project require on Environmentallmpoet Statement or on l you will be notified of a later date licable and fee. on< Applicant's Statement-En will be forwarded for completion and payment of a

• SignoIure of Certifying Official V ,

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Senie Vim President, Nuclear Power e Date _ '

/ 8[ -

Titi. ,

- kCKNOWLEDGMENT SY DRBC OF FEE PAYMENT .

Bank No. __

[deted -

Received Check No.

in amount of __

. $ignature COPIES: t!) A&olaistrative Division Copy - white (s) APPLICA30T - Retala Thle Copy - pink ist Applicans - DRec Reselsted Copy - yellow 143 Projess Review Copy - blue

, (.

NO 72-7 A RESOL.UTION requiring the payment of fees for Commission review of certain water resources projects. .

WHEREAS, review of proposed Ooter resoure'es projects pursuant to Section 3.8 of the Delowere River Basin Compact has be'come o substantial program activity representing a major public cost; and WHEREAS, certain categories of project review cases demand extended staff analysis .

and the use of expert consultants, the cost of which cannot always be forecast within the Comrnission's budget; and WHEREAS, it is timely and in the public interest to initiate o program of allocating a portion of the costs of reviewing water resources projects to the opplicant or project sponsor; now therefore .

BE IT resol.VED by the Delowere River Bonin Commission:

1. A filing fee shall be pold to the Commission, according to tiie schedule herein, at the time of filing ecc.h application for project review,' described in parograph 2 hereof, ' pursuant .

to Section 3.8 of the Delaware River Bo:In Compoet. Govemment oger.cres shall be exempt from such filing fee.

2. Project review fees under this regulation shall be required for the following cate-gories of projects, subject to provisions of Section 2-3.5(o) of the Rules of Practice and Procedure:

(a) Impoundments; ,

(b) diversions of water into or out of the Delaware River Basin; (c) Industrical water use and waste treatment facilities; (d) electric generating and transmission facilities;- t

- (e) petroleu'm product pipelines;- -

. (f) stroom encroachments;,and

, ., (g) withdrawal of ground water. .,,

3. The project review filing fee is the greater of (a) and (b) as follows:

(a)' minfmum fee: $100 for any pro]ect;

- r (b) oitemative fee:

(1).,1/10 of 1% of project cost to $1,000,000; ,

(2) 1/50 of 1% of remaining cost above $1,000,000 bu't not to excud

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o maximum fu of_ $50,000 as to oriy one project, exclusive of add'ed environmental fees; ,

(3) environmentol' report fee: ~$1,500 for any project; and (4) environmental Impact statement fee: $30,000 for any project.

4. The project cost shall include the estimated costs of design, supervision of construc-tion, legal services, contract administration, land, materials, equipment; construction and fabrico-

. tion. .-

5. Not more, than one project retow filing fee shall be paid to the Commission as to ony one project. , Phased review by the Commission of stages in the development of a project shall

. lbe considered a single filing for purposes of this regulation. Revision of projects previously opproved by the Commission shall be exempt from the requirements of this regulation. -

.. . . 6.- Estimated capitol costs of electric transmission lines, petroleuni pr.oduct pipelines end. stream encroachment shall be calculated for that portion of the project subject to Commission review and the filing fee shall be limited in its opplicotton to the cost so calculated.

7. Revenues received pursuont to this regulation shall be covered into the Comminion's general fund and be subject to specific appropriation by the Commission.

ADOPTED: June 28,1972 ,

Amended April 23,' 1975 '(Res(75-3)' . .

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ATTACit4ENT 1 Appilcation of Philadelphia Electric Cermany for Temporary suspension of 590F Termerature Constraint and Blue Marsh or Other Releases as Back-up Supply ma-The availability of Beneficial Impacts to the envircrvnent_.

cooling water during 1985 for Limerick will enable the Limerick Generating Station to cormlete its start-up testing program without delay and to operate at full capacity in order to help meet electric power generation needs for southeastern Pennsylvania.

DRBC has previously determined that the supply of cooling water As DRBC stated in I

for Limerick provides a benefit to the envirorvnent.

its most recent environmental review of the supply of supplemental EIS cooling water for Limerick, "docunents prepared after DRBC's Final on the Point Pleasant Diversion Plan, Issued in 1973, support the conclusion that the proposed project would be a feasible and DRBC Final Envirorvnental beneficial use of water resources."

Assessment for the Neshaminy Water Supply System, Part III, p. 2-53 DRBC reached the same conclusion in granting final (August 1980).

Section 3.8 approval to the Point Pleasant project in Docket No. D-79-52 CP at p. 5 (February 18,1981). Accordingly, DRBC has t

l recognized that the use of Basin water resources to provide cooling water for Limerick constitutes a beneficial use.

• As to the specific need for the electrical power to be generated by the Limerick Generating Station, DRBC has relled upon the findin of the Nuclear Regulatory Comnission (previously the Atomic Energy See.

Comnission) In its own environmental statements In for Limerick.

I Docket No. D-69-210 CP (Final) at op. 1, 6-8 (November 5, 1975).

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Issulng construction permits for Limerick, the AEC determined that f

4 there is a need for the electrical power to be generated by Limerick.

See AEC Final Enviromental Statement Related to the Proposed Limerick J

n Generating Station, Units 1 and 2, Docket Nos. 50-352 and 50-353, Ch.

9 (Novent>er 1973). At the operating IIcense stage, the NRC similarly found a substantial benefit to the environment to be derived from the operation of the Limerick Station in the annual production of See NRC approximately 10 billion kWh of base load electrical energy.

Final Environmental Statement Related to the Operation of Limerick Generating Station, Units 1 and 2, Docket Nos. 50-352 and 50-353, l

Section 6.4.'2 (April 1984).

Further, in an order entered August 27, 1982, the Pennsylvanta PUC expressly stated that "(t)he public Interest requires . . .

(t)1mely completion of Limerick Unit 1" and further stated "we encourage the Company to conplete this unit as rapidly as possible consistent with the pubile safety." Pennsylvania PUC, Opinion and Order, Docket No. I-80100341 (August 27, 1982) Cenchasis added) (pp.

23-25). Accordingly, there exists a substantial benefit to the ,,,

environment and the public In the conmencement of conmercial i operations at Limerick as soon as possible.

l No adverse Imanet by temporary suspension of 59'F temperature constraint. DRBC Docket No. D-69-210 CP (March 29, 1973) precludes Schuylkill River withdravals for consutetive use by Limerick whenever .

river water temperatures below Limerick exceed 59'F, except during April, May, and June when flers measured at Pottstown exceed 1,791 cfs. DRSC's decision to Ilmit Schuylkill River withdrawals when tenperatures are above 59'F is Intended to reduce stresses on stream u

• x e

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t Limerick when water water quality caused by consumptive losses a When nic waste assimilation.

quality is significantly affected by orgaF, the biological oxyge temperatures in the river exceed 590 l y for waste assimilation ==

accelerates and the dissolved oxygen necessar becomes more critical. l locations PECo proposes to monitor the river for DO at severa l e as the limit on below Limerick and to substitute for the present a suitable 59 F 00 va u withdrawals from the natural river flow d This substitution of 00 for temperature is propose terrperature Ilmit. PECo will regularly 1985.

only for the remaining days of calendar year f the DRBC so that it can transmit the DO Information to the offices leases o of water be evaluated by them and so that they may request re i k at times of low from storage to compensate for withdrawals at Limer ll be c

With this monitoring program In effect, PECo wi DO values. i k regardless of river water permitted to continue operations at Limer c temperature. in the Schuylkill The Pennsylvania water quality standard for DO ...

0 mg/l minimun River is 5 0 mg/l minimun daily average and 4.

PECo proposes that these two values be Instantaneous value. i hdrawals frcrn natural established as the critical values limiting w t f water frem water river flow and the values which trigger releases o supply storage. during 1985 will The monitoring program proposed to measure 00 t regular time include water sarypilng at least six times per day a ick (R.M. 48.0) and intervals at six different locations between hia. The monitoring and Limer the Fairmount Dam (R.M. 8.5) In Philadelp d with autcynatic equipment transmittal of data will be acccripilshe where practical and possible.

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4 When autmatic equipment is unavailable, manual means will be utilized. Regardless of the means of monitoring, data will be transmitted to the DRBC at least daily and DRBC also will have ready i

access to all data during any Intervening time Interval.

Depressed DO levels usually occur in the pools behind the dams across the Schuylkill River. It is therefore proposed to estabitsh a samling station behind each of the following six dams: Fairmount Dam (R.M. 8.5), Flat Rock Dam (R.M. 15.6), Plymouth Dam (R.M. 20.7),

Norristown Dam (R.M. 23.9), Black Rock Dam (R.M 36.6), and Vincent l

Dam (R.M. 44.7). A sampling station at Limerick (R.M. 48.0) was estabitshed about 10 years ago and sampilng will continue at this i

< location as before. At each of these stations a single probe will be i

installed. The specific location to be determined based on access, I

availability of electric power and protection from vandalism. The probe will be positioned vertically in the water colum below the mid-point so thet it will not be subject to surface effects.

I This monitoring program, when s4stituted for a single tagerature measurement, will provide satisfactory water quality protection , .

because of the relationship between DO and organic waste assimitation and also because the entire downriver stretch will be monitored.

In addition to the present 59 F tagerature constraint on withdr=#als at Limerick, there is a minimtsn flow constraint of 530 cfs for one unit. This constraint operates Independently of the 59 F tagerature constraint. Frequently, the flow constraint would preclude withdrawals from the Schuylkl11, regardless of the temerature constraint. For exa gle, during the dre wht of 1965, the flow e

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5 constraint of 530 cfs would have prohibited Schuylkill withdrawals 167 days, while the termerature constraint would have prohibited The historic record for withdra als for only an additional 29 days.

ma the Schuylkill over the past 55 years shows that, on average, flow withdrmals for one unit at Limerick would have been prohibited by For 52 of the 120 days and temperature constraints 120 days per year.

in this period, the fim constraint would have been the limiting Restriction on the Schuylkill River Water factor, jee DER "59 F Withdrmal, Limerick Nuclear Power Plant" at p. 4 (Septerrber 1983).

Accordingly, suspension of the 59'F termerature constraint alone would On the not provide a long-term source of makeup water for Limerick.

other hand, the same data show that a temporary suspension of that constraint would permit Schuylkill withdrawals for up to an additional 68 days on average.

' No adverse trroact from existino water storage releases in 1985.

Recognizing that there will be times when stream flow and DO constraints, as proposed above, will operate to prevent withdrawals, another source of makeup water will be necessary for the short interim l

Under those 1

period until water from Point Pleasant is available.

l circunstances, releases would be requested from existing water storage supplies.

In view of the Inventory of water supply storage facilltles under DR8C control, the Blue Marsh Reservoir appears to be the most probab ,

In authorizing construction of the Blue source of such releases.

Marsh Reservoir, Congress designated 8,000 acre-feet of storage for downstream water supply needs.

j.es e Flood Control Act of 1962, Pubile

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i .o The release of water supplies Law 87-874, 87th Congress 2nd Session.

I fra the reservoir underwent environmental review in two separate '

U.S. COE Environmental enviromental statements prepared by COE.

Statement on the Blue Marsh Lake Project (April 1971); Supplement to U.S. COE Envirorvnental Invact Statement on the Blue Marsh Lake Project EE (June 1973). In neither docunent did COE determine that there would be any adverse enviroernental impact frcm the release of water from the See COE water supply storage for the benefit of downstream users.

Supplement at p. 5. To the contrary, COE found that the release of those waters would have a beneficist impact upon overall water quality in that stretch of the Schuylktli River.

In June, 1984, DER undertook an assessment of Bucks County's proposal that Blue Marsh Reservoir storage be used to provide makeup See water for Limerick when Schuylkill water would be unavailable.

DER's " Assessment of Bucks County Proposals for Alternatives to the DER stated two Point Pleasant Water Supply Project" (June 1984).

i fundamental concerns regarding the cornnitment to Limerick of large amounts of storage from Blue Marsh: (1) the impacts upon the interests of other present and future water users in the Basin and (2) ...

l potential Impacts on coordinated reservoir operations needed to PECo control salinity in the Delaware estuary (Assessment at p. 29).

i has requested releases, however, on a far more limited basis than suggested by the Bucks County proposal. First, PECo is not requesting releases from water quality storage, but.only frcm water supply storage. Second, PECo is merely requesting releases from storage for ,

1985.

PECo ackncutedges that the long-term use of Blue Marsh as l

suggested by Bucks County "would confilet with anticipated needs of Seg,_el-Aware D

5 pslic water suppliers" along the Schuylkill.

Un11mlted, Inc. v. DER, EMB Docket Nos. 82-177-M and $2-219-H, i

Adjudication at 46 (June 18, 1984). ~

. , . . - - , , . , , . - . . , , .. . . - . - - ,,,.-...,-...,....__,__n . - ,

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PEco also recognizes that Blue Marsh must be available to assist ,

in meeting the needs of downstream users ) in a drought and that DRBC has authority to uttilze the water supply storpge of Blue Marsh to am Nonstheless, the terrporary meet downstream water quality objectives.

short-tenn use of Blue Marsh should not be pr cluded sirrrly because drought conditions might arise which require releases from the water Under the " pooled water" concept, drought hardships supply storage.

Equitable must be shared on an equitable basis among all Basin users.

demands upon other impoundments h Beltzville) would be made to meet flow augmentation needs for water supply and water quality in a drought. See,DRBC Level B Study at op. 19, 57 (May 1981).

The COE Blue Marsh Lake Water Control Manual (Final) states at p. i 7-13 that the 8,000 acre-feet of water supply storage in Blue Marsh is Of this amount, 9 cfs equivalent to a continuous yleid of 55 cfs.

Is currently under contract with the Western Berks Water Authority and an additional quantity used under the control of the DRBC to provide The remaining amount for the needs of other existing domstream users.

is therefore available to meet other " current water supply needs" as Accordingly, it appears that release of an average determined by DRBC.

of 27 cfs for Limerick for the short Interim period requested by PEco would have no adverse effect upon other users or potential users along Further, Inasmuch as PECo the Schuylkill River below Blue Marsh.

ir proposes merely to receive releases of water frt:m an existing reservo -

by utilizing the same facilities, structures, and mechanisms alread use, there will be no adverse impact to the envirorvnent.

The release of water from the Blue Marsh Reservoir In amoun required by PEco would not adversely affect recreational use of the reservoi r. The COE Blue Marsh Lake Water Co'ntrol Manual (Final i!

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states that the Reservoir should be maintained at elevation 290 feet The throughout the stmner months for the benefit of recreational use.

Manual states at p. 8-3 that the recreational facilitics are usable m

frcm the top of the stmner pool (elevation 290 feet) to a drawn down As explained belcw, releases frcm the elevation of 283 feet.

reservoir during the recreational period will not result in a detrimental lowering of the water level .

PECo analyzed several critical years to determine the possible In its effects of the drawdown resulting from its requested releases. .

analysis, PECo asstmed one unit at full load operation at an average constrnptive use of 27 cfs throughout the period of water ur. availability from natural flows of the Schuylkill River untli Septerrber 30, the end of the recreation season, and included the 9 cfs under contract to the Western Berks Water Authority, the full conservation release of 41 cfs, and 5 cfs as evaporation. For 1955, an average year for flow in the Schuylkill River, PECo found that during the strrmer nenths, the pool elevation would be drmn down less than 1 feet.

PEco also analyzed the situation for 1980 because that year Schuylkill flows were 20% below average. It was determined that drmdown frcm the requested releases would have been about 2 feet.

PECo also simulated withdrawals for 1965 because it represents the worst year of record for low flows in the Tulpehocken Creek and PEco therefore the year of lowest supplies to the reservoir.

determined that its requested releases would have resulted in a drawdown at the end of the recreational season of approximately 4.5 feet. Thus, the requested releases of water for PEco and the resulting drawdcwn of the reservoir, trider worst case conditions, e

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.. * - 9-would result in the Blue Marsh water level 2.5 feet higher than the designed drawn doei elevation 283. This margin of drawdown would remain l available for other concurrent users of Blue Marsh water and would have no detr!rnental effect on recreation. This analysis is reflected on the attached Figure 1.

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ATTACFNENT 2 -

1 Appilcation of Philadelphla Electric g Company For Temporary Suspension of 59 F Tegerature Constraint and Blue Marsh or Other Releases as Back-up Supply Alternatives Considered l

PEco has considered various alternatives for a temporary supply of supplemental cooling water to Limerick for the period of 1985 when i

docket decision constraints preclude withdrawals from the Schuylkill and Perklamen. An alternative is not realistic and need not be Thus, an considered unless capable of being promptly iglemented.

alternative cannot require construction or major modification of existing facilities. The alternatives c'onsidered and a brief discussion of each follow:

i (1) No action - Due to flow and termerature constraint.s Irmosed by DRBC on withdrawals of water frem the Schuylk7 41 River l for consumttve use, the Schuylkill will be larg,1y unavailable for such withdrawals during the r,erhd June to October, 1985. Because the pennanent supplemental water supply frczn the Point Pleasant project will be unavailable for this period, Limerick cannot continue with start-up testing, and ascend to full power without an Interim source. The cost of not operating Limerick for lack of water during that period is estimated to be $49 million per month. See Affidavit of Vincent S. Boyer, Senior Vice President, Nuclear Power (March 15, 1985) Cattached).

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- (2) Ontelaunee Reservoir - ThIs reservoir is located on Malden Creek, a tributary to the Schuylkill River u' pstream of the Limerick plant, and is opmed by the City of Reading for use as a water supply source. Ontelaunee has 11,640 acre-feet of total storage. The City of Reading was granted an allocation of 35 million gallons per day of water by the DRBC on August 27, 1969 in Docket No. D-69-139 CP. The water supply system is presently reported to use an average of 20 mgd with a maxim m usage of about 25 mgd. The City of Reading and the municipalities served by the water system are served by comprehensive systems of sewerage collection which discharge to complete treatment fac!!Ittes and thence into tributary streams and the Schuylkill River.

Inquiries have been made to the City of Reading and a presentation was made to the City Council as to the city's interest in selling unused water from their allocation to PEco. An application for approval of such usage would have to be made by the City to the DRBC. To date, the City has not Indicated an Interest in making any water available to PECo for 1985,.or any other period of time.

(3) Green Lane Reservoir - This reservoir is located on the Perki men Creek. It is owned by the Phliadelphia Suburban Water Conpany ("PSW Co.") and is used in combination with other reservoirs and wells for water supply. Total storage is 13,430 acre-feet. Green Lane is not large enough to meet the centsined needs of PSW Co. and Limerick. (Letter to Nicholas DeBenedictis, DER Secretary frem Robert A. Luksa, Executive Vice President, Philadelphia Suburban Water Ca pany, June 4, 1984).

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

CIMONWEAL'1H OF PENNSYLVANIA ss.

COUNIT OF PHILADELPHIA VINCENT S. BOYER, being first duly sworn, states as follows:

1. My name is Vincent S. Boyer, I am Senior Vice President, Nuclear Power of Philadelphia Electric Company ("the Company"), owner and operator of the Limerick Generating Station.

2 On October 26, 1984, the U. S. Nuclear Regulatory Commission issued a license authorizing fuel loading and low power testing of Limerick Unit 1. Fuel loading was completed in November,1984, and the low power testing program has been completed. The schedule for the power ascension j

phase of operation of Unit 1 of the Limerick Generating Station is such that the Plant will be ready to proceed to power levels greater than allowed under our existing license by the end of March, 1985. In view of the current status i

of the NRC licensing proceedings, issuance of a full power license can be

anticipated about May 1, 1985.

I

3. In order to proceed with the power ascension program for Unit 1 after the issuance of a full power operating license by the NRC, it is I necessary to have in place a supplemental cooling water supply. ,

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4. The partially constructed Point Pleasant diversion will not be completed in time to supply Unit D s supplemental cooling water needs in the second quarter of 1985 when it is anticipated that the NRC will authorize the i

Company to proceed to full power operation, i

5. Consequently, an interim supply of supplemental cooling water j

will be required to operate Unit 1 at sustained high power levels until the Point Pleasant Project is completed. .

1 i

6. Delays in proceeding to full power will result in a delay in the commercial operation of the unit. Such delays will increase the costs of Limerick Unit 1 by $34 million per month. 'Ihis cost figure is made up of $24 million per month Allowance for Funds Used During Construction (AFUDC) and $10 In addition, million per month operational, security and maintenance costs.

the fuel costs of the Cec:pany's customers will be increased by $15 million a month for each month of delay.

4

7. Delays in the full power operation of Unit 1 may also impact on the restart of construction of Unit 2. The Pennsylvania Public Utlity Conunission is presently holding hearings on whether construction at Unit 2 should be continued, but in compliance with a prior order issued by the PUC, construction of No. 2 unit has been suspended unit No. 1 is placed in commercial operation.

Vincent S. Boyeff

Sybscribed and sworn to before me this / P day of J4 arch,.1985.

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.,,- Notary Public

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, iismi ric..tmie'phia. Phd&ddphia Co.

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Exhibit 1

, Appilcation of Philadelphia Electric Ccrnpany for i

, Torporary Suspension of 598F Temperature Constraint and Blue Marsh or Other Releases as Back-up Supply Abstract of Proceedings Authorizino Project DRBC Imposed the 59'F terrporature constraint In its docket decision regarding the withdrawal of Schuylkill River water for Limerick. DRBC Docket No. D-69-210 CP at p. 5 (March 29, 1973).

While this terrporature constraint has been reviewed by DRBC and DER and deemed appropriate to provide a margin of safety in maintaining desired dissolved oxygen levels, those conclusions were based upon

) long-term consuretive use of Schuylkill River water wIthout alternative measures to assure that DO objectives are met and, as such, are inapplicable to the proposed short-term usage.

The Blue Marsh Lake Project was authorized by the Flood Control

Act of 1962, Pth. L. No.87-874, 76 Stat. 1173, 1182 (1962). Congress Intended that Blue Marsh provide, among other things, water supply.

H.R. 13273, 87th Cong., 2d. Sess. 123 (1962). The DRBC has contracted for 8,000 acre-feet of storage frem the U.S. Army Corps of Engineers

("COE") for municipal and Industrial water supply, as docunented in

, Contract No. DACW61-71-C-0145, dated May 14, 1971.

J The COE estimates that the water supply volune can continuously l yleid 55 cfs of water. U.S. Army Corps of Engineers Blue Marsh Lake l

Water Control Manual (Final) (March 1984) at par. 7-09(a), p. 7-13.

The Western Berks Water Authority has contracted with the DRBC to purchase 9 cfs of this water through 1989. The remaining water supply, 4

46 cfs, is available to meet the needs of other users.

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• Exhibit 2 Appilcation of Philadelphia Electric Corrpany J for Tenporary Suspension of 59 F Tenperature '

Constraint and Blue Marsh or other Releases as Back-up Supply Standard Regarding Temporary Suspension of 59'F Temperature Constraint on SchuyIki11 Withdrawals The DRBC's objective in imposing the 59*F terrverature constralnt on SchuylkIII withdrawals is to reduce stresses on stream water quality caused by consuiptive losses at Limerick when water quality is significantly <?ffected by organic waste assimliation. So long as the stream capacity to assimilate organic waste is not Impatred by Limuelck withdrawals above 590F, as assured by PECO's Instream monitoring, DRBC's objective will be achieved (see Attactinent 1).

There is no Indication in the history of DRBC's consideration of this criterion that it has any significance apart fran Indirectly maintaining control over desired DO levels in the icwer reaches of the Schuylkill and the Delaware estuary.

Standard for Minimizing Releases i Frcm Water Supply Storage for Limerick Durino 1985 1

- In authorizing construction of the Blue Marsh Reservoir, Congress expressly designated 8,000 acre-feet of storage for downstream water supply needs. See Flood Control Act of 1962, Public Law 87-874, 87th Congress, 2nd Session. The policy of utilizing a discrete block of storage of the Blue Marsh Reservoir to meet dcMnstream water supply needs was restated in both environmental statements prepared by COE.

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

See U.S. COE Environmental Statement on the Blue Marsh Lake Project at p.1 (April 1971); Supplement to U.S. COE Environmental Impact

' Statement on the Blue Marsh Lake Project at op. 2, 4 (June 1973)).

1 See.also COE Blue Marsh Lake Design Memorandun No.15A at p. 8-2 (June

. 1975); COE Stue Marsh Lake Water Control Manual (Final) at pp. 2-1, 7-12 to 7-13, 8-4 to 8-6 (March 1984).

! DRBC has luglemented the stated policy of uttilzing Blue Marsh to i

meet downstream water supply needs in granting Section 3.8 approval to e the application on behalf of Western Berks Water Authority for Blue Marsh water supplies in Docket Nos. D-69-55 CP (August 27, 1969) and j'

D-69-55 CP (3.8) (Decerter 15, 1971).

' In order to minimize water storage releases for Limerick during 1985, water would be released from water supply storage only when river flow as measured at the Pottstown gage is less than 530 cfs and when f

dissolved oxygen as measured by our proposed monitoring program falls i below acceptable levels; the flew constraint Irrposed in Docket No.69-210 CP (Final) (Noverser 5,1975) to be inappilcable to any such releases.

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.8 Exhibit 3 B

Application of Philadelphia Electric Cavany for Temporary Suspension of 59"F Tenperature Constraint and Blue Marsh or Other Releases as Back-up Supply I

Section of the United States Geological Survey Topographic Map Showing the Territory and Watershed Affected l

The map ettached detailing the Blue Marsh Reservoir was prepared from the Gnited States Geological Survey Quadrangle, Wernersville,

! Pennsylvania.

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-F!?Ibit 4 Application of Philadelphia Electric Ccrnpany for Temporary Suspension of 59a Temperature Constraint and Blue Marsh or Other Releases as Back-up Supply i Description of Specific Effects of Non-Structural Project l The specific effects of this non-structural project are discussed in Section 1 of the Envirormental Form and Attachrent I hereto.

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. 1 I

.-8 Exhibit-5 --- -

Appilcation of Philadelphia Electric Cczmany for Termorary Suspension of 59 F Tenperature Constraint and Blue Marsh or Other Releases as Back-up Supply Report of the Appilcant's Engineer Showing the Prop 3s_ed, Plan of Operation of the Project The continuation of the startup program and approach to full power for the Limerick Generating Station Unit No.1 is expected to begin

about May 1, 1985, following authorization by the Nuclear Regulatory Ccmnission. A gradual ascension to full power is piamed with tests being conducted at several discrete power levels. The total test program is estimated to require a period of approximately six months, this estimate providing time for review and approval of test results and for some adjustment and tuning of control systems.

Based on the availability of consumtive water requirements, the following program is envisioned. For the first two months of the startup program, May and June,1985, the unit will be operated at power levels progressively increasing to 50% of full power and the average consurotive water requirements will be about 10 cfs. During July 1985, testing will occur at power levels up to 75% of full power with the consu mttve water requirements averaging about 17 cfs. From August through October, it is planned to conduct tests at full power output with consumtive water needs averaging about 22 cfs. When operating at full power, the average consumttve usage atounts to 27 cfs, which figure can increase to 32.5 cfs under adverse meteorological conditions.

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2-During the test program, PECo wilit-utill-ze withdrawals fran the Schuylkill River and Perklanen Creek as authorized by DRBC. When ,

river terroeratures approach 59 F, PECo will conduct instream snonttoring of 00 levels In the Schuylkill at selected locations as described in Attacivnent 1.

When further withdrawals from the Schuylkill River and Perklcmen Creek are precluded by the DRBC docket decision flow constraint or by low DO levels, PECo requests, during 1985, release of water from i

existing water storage facilities. The%ater released will flew Into the Schuylkill River to be withdrawn at the Schuylkill River intake for Limerick. The flow constraints irrposed in Docket No.69-210 CP (Final) (Noverrber 5,1975) to be inappilcable to any such releases.

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1 ExhTbit 6' - * *

. . 8 Appilcation of Philadelphia Electric Carcany for Temporary Suspension of 59 F Tenperature Constraint and Blue Marsh on Other Releases as Back-up Supply Map of Any Lands to be Acoulred or Occuoled This is a non-structural proposal involving the temporary suspension of the 590F temperature constraint on withdravals from the Schuylkill River for consurotive use at Lirmrick and an Interim supply I

of water from water supply storage during 1985. There are no lands to be acquired or occupied.

m 9

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Exhibit 7 I

l Appilcation of Philadelphia Electric Concany j for Tepporary Suspension of 59oF Tenperature ,

Constraint and Blue Marsh or Other Releases as Back-up Supply Estimate of Cost of Concleting the Proposed Project This Is a non-structural proposal involving the temporary substitution of a dissolved oxygen monitoring system for the 59'F temperature restriction on withdrawals of water from the Schuylkill River for consunptive use at Limerick and a back-up Interim supply of water from water supply storage during 1985. The only physical field work Involved will be the installation of DO monitors at six locations between Limerick and the Fainnount Dam in Philadelphia.

The cost to purchase and Install the six monitoring stations and a spare unit is estimated to be $95,000.

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Exhibit 8 - -

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l Appilcation of Philadelphla Electric Company for Temporary suspension of 59 F Termerature Constraint and Blue Marsh or other Releases as Back-up Supply Description of Construction Procedures This is a non-structural proposal involving the temporary substitution of a dissolved oxygen nonitoring system for the 59 F termerature restriction on withdrawals of water from the Schuylkill River for consumtive use at Limerick and an Interim supply of water from the water supply storage during 1985. Work involved will be the installation of 00 nonitors at six locations between Limerick and the Fairmount Dam In Philadelphia.

The monitoring equipment at each location will be similar and will consist of a small Instream probe, connecting to a mini-ccmputer located on shore in a protective enclosure and a connection to a leased telephone line to transmit data to a central point (or points) where the data will be evaluated.

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