ML20107F507

Testimony of B Aptowicz,C Zitomer & R Weiss Discussing Addl Considerations That Need to Be Developed in Greater Detail as Part of Implementable Water Supply Emergency Plan.W/ Certificate of Svc.Related Correspondence

ML20107F507
Person / Time
Site:	Limerick
Issue date:	11/02/1984
From:	Aptowicz B, Weiss R, Zitomer C PHILADELPHIA, PA
To:
Shared Package
ML20107F481	List: ML20107F477 ML20107F487 ML20107F507
References
OL, NUDOCS 8411060542
Download: ML20107F507 (36)

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' City Statement 3 '

Novenbar 2,1984 00CMETED USNRC UNITED STATES OF AMERICA MJCLEAR REGUIATORY CDMISSION .. .

, . . _ _ _ . , '84 mV-5 / tit n IEFORE '1HE MtMIC SAPTFY AIO LICENSING BOARD: '

, Helen F. Hoyt, Chairman '

'. Richard F. Cole, Administrative Law Judge . <

Dr. Jerry Harbour, Adninistrat,1ve Law Judge In the Matter of  :

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Philadelphia Electric Ccapany  : Docket Nos. 50-352 (Limerick Generating Station, 50-353 Units 1 and 2)  :

TESTIMDNY & BRUCE APICWICZ CHARLES ZI'KMER Alt RICHARD MISS DISCUSSING SEVERAL. ADDITIONAL C)NSIDERATIONS g

'IHAT MED 'IO M DEVEIDPED IN GtEATI!'R DETAIL ','

AS PART OF AN IMPLl!MENFATABLE NNFER SUPPLY SIERGENCY P[AN FOR '!HE CITY OF PHILADELPHIA Q.l. Please state your names, addresses, positions with the City of Philadelphia and the purpose of your testimony.

A.l. My name is Bruce Aptowicz, Manager of Operations, Water Department, ,

City of Philadelphia. My business address is One Reading Center, Third Floor, Philadelphia, Pennsylvania, 19102. '

My name is Charles Zitoner, Chief of Load Control, Water Department, City of Philadelphia. My business address is One Reading Center, Third Floor, Philadelphia, Pennsylvania, 19102.

0411060542 841102 PDR ADOCK 05000352 ,

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My name^is Richard miss, Project. ' =y of Planning and Research, _

Mater Department, City of Pblindelphia. My business address is One Readinir Center, Second Floor, Philadelphia, Pennsylvania, 19102 *

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The purpose $ this[testimoriy is to discuss 'sewral additional con ; ') ,

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siderations"that need:to be developed ih greater detail as part of any J .

y  : '~ . isplementable hy ' .. water emergency plan for the City of Philadelphia.

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Q.2.

In general, what additional information is needed before a water supply emergency plan can be developed for the City of' Philadelphia? '

! A.2. t More information is needed on the types of accidents for which planning sunt be done. Specificaliy, in order to develop an a argency plan,#4.he I level, kind and nature of contandnants, the time frames involved, l j

meteorological Impacts and the expected impact on potability must first I i be estimated. Knowle&pe of the associated probabilities of the various  :

i accident types also would be useful for planning. Further information

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j must be developed on the feasibility and effectiveness of trekting each '

type of contmainants at our treatment plants in order to be N

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able use 5 i the treated uter as a potable supply, As indicated '

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by Mr.

1 Rulossa, we have two raw wter supply sources - the Delaware and the Schuylkill Rivers. ' mis information Old therefore need to be i

developed for both sources, Q.3.  !

Why is this level of detailed information necessary to develop an amargency plan for the water supply?

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As we' understand it, there are many. potential types of accidents with varying quantities and quall't'les of released contaminants. These types

.of accidents have projected frequencies of occurrence.- Also, the impact of weather conditions, wind direction, and ' precipitation wil1'

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. need1to be taken into account in developing a plan. .

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' All of tt:ese variables would affect the precise nature of the energency

.<j, . , : plan that would needsto be devel W .

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Could you elaborate further on why this information is necessary?

A.4.

The actions that muld need to be undertaken by the Water Department for different time perlo's d of contamination will vary. Similarly, b level of contamination will determine what types of mitigation tech-niques will need to be employed. The degree of water contamination will determine whether or not either supply source will be available and, if available, at what capacity. The availability and extent of supply is the primary factor in determining what conservation measures and supply strategies will be'necessary to provide every Philadelphia -

Water Department custaner with potable water. Similarly,'if the Schuylkill River raw water treatment plants'. capacities or the Delaware River treat:nent plant's capacity h?n to 53 fully or partially subjected to repeat precipitation, the plans muld vary. The developnent of each ccuponent of the plan will depend on supply constraints imposed bv pua-page capcities and the configuration of the water distribution system.

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l Q.5. Have you reviewed any-information that ' addresses energency planning for the water supply of Philadelphia? l g~.. y.

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A.S. We have briefly reviewed the quantitative graphs presented by- the MC ,

i , '. staff and the Philadelphia Electric Ccnipany developed for the environ- \

mental impact stataeant ("EIS") with regard to the levels, types and the time perieds of,v:

centamination

. associated with various accident

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types. 'the Cannonwealth of Pennsylvania also provided the City with a booklet. The City has had several meetings with the Cannonwaalth and PECO with regard to these probims.

Q.6.

Mas that information sufficient to prepare a water supply energency plan for the City of Philadelphia? ,# &

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A.6. No.

'Ihe EIS material seemed to focus on the broader, long-term measurenents. For planning purposes one needs to know much more detailed infonnation, e.g., short-term contaminants, the entire spectrum of contaminants, the time periods of.various ' contamination lovels, p'robabilities, the impacts on both rivers, etc. Tfie material ..

provided by the Ccenonwealth was also insufficient in addressing these issues.

j Q.7. Please exclain in more detail tho water systs constraints that are relevant for those purposes. '

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In designing any'e. ster supply system there are.two major o'onstraints

. that naast he ' eval'ueted. The first is the demand for potable e ter '

supplies by all classes of custamars (residential, caonarcial, industrial, institutional, wholesale). 'these demands should be eye- -

c, luated both on a' peak and average day basis.

Distribution syntes dunands for hydrant use and it;+ sust also be evaluated. '

The secon.d constraint that . . must.oe, evaluated is the a availabi.lity o.fi

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potable water supplies. Factors that must be considered include raw s

water and finished u ter pumping capacities at each plant and in the service districts, available treatment processes and their effec-

, tiveness in treating water supplies at various levels of contamination, available raw and finishal water storage basin capac'i ties, transudssion main capacities at average and peak daily dunands and the ability o4, the systen to supply all sections of the City fran more than one supply rource. 'the last factor, h , the inte - ra tlon of supply sourc s . .

e, la of particular concern to the City of Philadelphia since there are '

several sections of the City that can be supplied by only one of the two rivers, r

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Q.8. Why naast pak day usage be considered in the development of an energency plan?

A.8.

The design of any water or seer facility must be bened on peak day l usage in order to assure that .whquate service 1.1 provided to all uti-l lity customrs.

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~ ^ 3 Qh90.. ' In the caseof a~ water ' suppl'y emergency, wha't' strategies ~nust be .

, employed to manage the situation?

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)Td develop energency planning ' strategy one' must know the angnitude of' 2

i the problen.J Once' lih'is .is known'a number;of measures, if properly '

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deval W , can be applied to: minimize'any potential health or. safety imr**s.. . It is assumed that the enonnous _ media coverage of, such an s-

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Jevent'will h 1p the Ccmnonwealth~ and the City of Philadelphia gain public cooperation. Although a m=4=r of measures should be ingle- '

mented city-wide for all classes of custcmcrs to minimize exposure and reduce demand, there may be a number of emergencies which are so severe that the water supply constraints of Philadelphia's system would pre-ventcertaindistrictsof_theserviceareatobesuppliedwithpotape water. Under these conditions, special measures would have to be I

inplemented for those custaners that reside in these severely inpacted districts.

Q.10.

Previously a number of types of accidents have been mentioned. If one A: -

possible water supply emergency is an event such that the Schuylkill .

River cannot be used u a source of water supply, describe what would be entailed in utilizing only the Delaware River as the sole source of water supoly for the City and its suburban custczners, i

A.10.

This muld represent an emergency condition of a magnitude that has not been previously encountered by the City. In order to maintain water l

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service for the City during such an event, 'three different cperational

• nust be addressed. Chronologically these phases would coincide with 1) a notification period, during'which the details of the energency are mde known to the City and a raw water intake termination time has been established, 2) the period of four to eight. days after shutacwn of the Schuylkill River raw water intakes during'which certain

. areas of the City are supplied solely fran storage reserves (of

, SchuylkilL origin),fwhiler the majority of.the City relies on the Delaware River as a supply source, and 3) that period after the deple- ,

tion of storage reserves for the Roxborough/Manayunk sections, certain areas in Germantown, and the area known as the "Belmont High Service District," during which Delaware River water would be required to be utilized to the conveyance capacity limits of the systen.

s 41 Q.ll. Please elaborate on each of the three phasea described above.

A.ll . PHASE I:

The planning and implementation of the procedures necessary to cope with this type of energency are highly dependant on the availa-bility of accurate notification of: the nature'and extent of the event. '

The possibility of the loss of a' raw water source for periods of time

. longer than several hours necessitates inplementation of a number of operational. procedures that ootentially could assure City-wide supply for at least several days. Imolementation of these operations would be needed to replenish storage facilities and isolate treatment and con-veyance routes to serve primarily areas that could not be ultimately supplied frcm the Delaware River. Any facilities that are cut-of-e e

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. seivice'for repair

,. cc maintenance would also.need to be reactivated,'if possible, during this time. Because.these~ actions require mobilization ' ,

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of crews and sufficient raw and filtered water punping time to refill storage structures, adequate., advance notification.is crucial. Adequate' j advance notification nost.' allow'approximately.12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.to fill;al1~

storage facilities

, tlipotabiewaterbefore'.theintakesare' closed. A"

. water' conservation'progr a nust be inplemented within 1.5 daysJ of the

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.j- gintakes being.' closed. Gince ceitain;areasf6f theicity'aust i a . .5 upon am-lated storage, the lifespan of their remaining supplies is .

directly proportional to their existing storage levels, consumption levels and the time of energency readiness prior to the termination of Schuylkill River punping. -

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In sunmary, inherent in developnent of required emergency measures are assunptions that define conditions prevelent at the outset of such an emergency as well as adequate advance warning. -In addition, the following conditions must exist:

no loss of electrical power during the emergency and average day consunption demands even during peak periods.

(We present later an analysis of. how energency conservation

, measures may reduce consunption.) .

PHASE II:

Upon closure of the Schuylkill River raw water intakes, the Belmont High Service District ("BHSD") and the Roxborough, Manayunk, and Germard.own areas could be serviced by water frczn the storage reser-ves accumulated in Phase I, assuming average day consumption levels.

Under the above stated assunptions, it is estimated that thess reserves

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will last.approximately 8.0 days..for these sections in Northwest Philadelphia and 4.0 days in the Belmont High Service District. Since storage in . addition' to that.'available in the 'Belmont ~High. Servihe Clear .

Well eEists at the 7klmnot Treatment Plant, portable'punps :could1tiei - 4

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used to-suppienent IMSD storage fra lowerkbasins. -This(additional l' ,

g storage could meet tlie IESD aamands for roughly.3 more days.. '.

Therefore, the longest possible self-sustaided supply period.for,the

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.a m TElmnrit High-Service' District;would be'7.0-days.; 1N1Isotherf areals7of N N

the City could be adeqaately supplied fr a the Delaware River source if .

Delaware River Nater can be utilized, all cricital cm ponents of the

> . water systen are @erational, and a conservative plan can be imple-mented.

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PHASE III: E Upco depletion of the storage reserves as mentioned above, additional operations can be taken to attempt to distribute more Delaware River water to the western reaches of the City, iki.iever, due to various systen constraints, certain areas of the City cannot be delivered Delaware River water and will renain out of service. These

.- , areasip;udetheBelmop$rt.High 8- Service District and Roxborough,.as well.- -

as sections of Manayunk, Germantown, Mt. Airy and Chestnut Hill' .

It should be noted that other sections of the last group would experience greatly reduced pressures and flcw rates. Specific areas of cutage and reduced level of service could be located only after addi-tional detailed study; however, those areas which exist at high eleva-tion or are serviced by older, smaller distribution mains (Germantown),

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,, - . i will suffer the'greatestiloss. These effects will be ' felt 'innediately "

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upon.thedepl'etion[afavailablsstoragereserves. In general,'the only L

sections of Northwest Philadelphia that~will continue to experience y n .. existing levels'of water service'will be'the northernmost area bounded

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- +If a conservative plan can be developed now and implenented'as needed,

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fN/,if no' britibai outages aff5:t a 3crtion of~ the Cit'y's abili$y; t'o' be serviced, all other sections of the City could, frcan a distribution '

point of view, receive water supplies conveyed fran the Delaware River source.

In sumnary, any type of emergency condition which would render the L Schuylkill River useless as a source of potable water supply would impose a great hardship upon the City's water supply systen.

Q.12.

Have you evaluated a number of measures that might be effective in t

reducing consunption on a peak day in the event that the Schuylkill River could not.be.used as a source'of water' supply?- ^

A.12. Yes.

Q.13.

What measures did you review that might be implemented city-wide in the event that such an accident occurred?

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. . A.13.: I reviewed the'use of'ritioning, non-essential water'.use bans,.the

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' distribution of.: flow restrictors and the i v ition of water use

'fh." l surcharges ' for!all~ Phl%p la;iW*i Water

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Q.14. . lNhycis itJinportant"to, evaluate th"e appropriateness of these various

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A anhar'of techniques nust be implemented to reduce consunption quickly and for an extended length of time if the Schuylkill River is eliminated as source of supply for more than seven to eight days.

Censumption nust drop immediately to ensure that the Baxter plant will

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be able to supply as nuch of the Water Department service area as

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possible.

Theobjectiveofthesetechniquesshouldbetoenablethf Water N partment to stretch its\ reservoir supplies of potable water as

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long as possible 'Asq:1 to supply as My people as possible with water fran the Baxter plant in the more likely situation that the Schuylkill River would be contaminated to a relatively more severe degree than the Delaware River.

.Q 15. Which hf the city-wide mitigation techiques that you evaluated were 1

y deemed appropriate? !  !

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A.15. Rationing, the use of non-essential dater use bans and the distribution of flow restrictors were all deemed appropriate,

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' Q.16 e Which':of;tlie city-wide mit1gation techniques,that you evaluated were' '

~ deemed non-appropriate ~ and !why?-' .

A.16. .

The use of water use surcharges is not workable for the short -tem.

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The effehtiveness of this measure % nds'.on'the use of_ quarterly .

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g billing to 3=maa'high usage' charges on custcmers-that do not 'cmply._

4 with any mandated. rationing provisions. Given the innediate nature of '

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• 'the.u,emergency,. this;. option would notfreduceiconsunption fi-adiately.

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[.c y In the case that the energency was prolonged for more than one year, this measure might be effective since most custmers' meters m21d be read in this time frame. Any custmers not abiding by the other con-servation mamires would be assessed high surplus usage charges. ' Itis W d help to reduce consunption.

'h Q.17.

Have you made sme praliminary estimates of the level of rad"M con-sunption that might occur during a peak use day if the measures you daamad aopropriate were implemented?

'A.17.- Yes. - -

Q.18. How were these estimations prepared?

A.18.

The peak day usage of 480 H;D in Fiscal Year 1984 was used as a base-line.

Reductions in consumption frm this baseline were estimated for the non-essential water use ban, rationing and distribution of flow restrictor provisions.

! In order to make assunctions about the level of l

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- conservation or reduced enne =ption that could be expected for each measure, a number of sources of infonnation were consulted. . 'the two major soerces of reduced water consunption that were assumed are the

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of fire hydrant controls and the reduction in custoner eter

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s usage. These are discussed in greater detail below. .

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Fire Hydrant Controls

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One type of non-essential water use' provision that.would have a major inpact on consumption during an energency is a ban on the use of water '

fr a a fire hydrant for any purpose except for firefighting or health protection purposes specifically approved by the city's health offi-cials. ~

An estimate of the anount of illegal recreational hydrant usage thatcouldfeasiblybereducedonapeakusagedaywaspreparedusig historical data. An assunption that seventy-five percent or 85 M3D of a possible 113, MID of recreational hydrant usage would be reduced was made based cm the success of the hydrant use control program during the 1981 drought.

It was assumed that hydrant use reduction would be even greater in this case as a result of the intense publicity this event would cmmand. In addition, greater public resources such as-police enforcement activities, around the clock shutoff of hydrants, and the installation of hydrant locks will of necces.sity be concentrated on reducing hydrant abuse to ensure sufficient water for firefighting pur-poses.

In addition to illegal hydrant usage, a number of legal hydrant uses 1

would be banned during this emergency such as the use of hydrants for water main flushing, construction and ccamercial use and for cleaning l

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and'di5infectingnewwater' mains'. We estimates for each use were-based on previous studies ~en hydrant use in the' Philadelphia Mater

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Department'Fr80 Unaccounted-For-Water Report (1981). A total' savings 1-of approximately 5.0 ICD for these uses would be feasible.

g 4 Custmer Water Use '

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The imposition of non-essential water. use bans and~ rationing will aff.ect each class of custmers in Philadelphia and Bucks-County dif 1 e '-

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'ferently. Five classes of custmers were analyzed for feasible water use reductions: . residential, ccanercial, industrial, p1blic properties and Backs County, Since any set of water use restrictions will impet each class of custaners differently, any emergency plan inplemented as part of the city-wide consunption reduction strategy must address each class of cust mer differently.

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The table below presents average day and estimated peak day constmp-tions for each custm er class. Average day consunption numbers were based on recent custmer billing records. It is difficult to estimate the degree to which usage for each custmer class will increase above this average on a peak day.1 The major reasons"that each class' increases. usage during: peak periods are greatcr outdoor water use, greater use of air conditioning, use of swinming pools, and greater frequency of bathing. We peak day occurs on a very hot sunmer day.

During the sunmer in general industries may switch part of their supplies to groundwater sources for cooling water purposes. It is expected that Bucks County, since it has a suburban water population, will have a higher per capita water use due to greater outdoor water

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A ballnck estimate is that.all custmer classes will. increase consunption"by ten percent' on the peak day except for Bucks County (an assumed twenty percent increase).' ~ >

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' Residential 1043 114 Caumercial ' 41 45 Industrial 50 55

,c ~ .-Public Properties, - 310 . ;c , -:^.

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Bucks County ~ 13 16 ~

Residential - Per capita residential usage was assumed to be able to be reduced by approximately 25 percent frcm 68 gallons per capita day

("gped") to 50 gped. This would represent a 30.2 MGD savings. ' It is

.assumedthatthesesavingscouldoccurthroughthedistributionofgow restrictions (9.2 gped reduction), prohibition of outdoor water uses' .

such as car washing, ... lawn watering, outdoor plant watering with fresh water and the use of swinning pools (5.0 gped reduction) and =Mitional conservation efforts for dishwashing and laundry use, the elimination of many household leaks and the installation of toilet tank inserts by sane households (3.8 gped reduction). An effective public relations 'Q programs as well as a network that can rapidly distribute the flow restrictors will be necessary for this goal to be realistic.

Commercial - Ccmnercial usage includes water use by office buildings, institutions (school, hospitals, etc.) and corrmercial establishments (stores, engineering and other non-manufacturing businesses in the ser-vice sector).

Conservation is more limited for ccanercial uses because 4

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- 'many health and 'saf ty codes requira .the use of air conditioning'during' the sunner 'in' buildings which~ do-nct have windows that.cpen. Itlis

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4 also more difficult to. reduce consuuption since many camercial buildings'haveinstAlledblowout, fixtures [(toiletsandurinals)[which 3

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'. c' .. ...e '. . w use: considerably more. water per flush and-cannot.be: easily modifled. A .,

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five' percent or. 2.25 DGD reduction was assumed for-~ outdoor water usie

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'(irdigation, ornamental water use and vehicle washing) during'the maxi -

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Another;five percegt6reductiert was. assumed ~ forginstalla . 67,:

tion' of flow'restrictors, the reduction of timing of flush values, a s

water conservation employee education effort and the elimination of leaks.

Industrial - A goal of 25% redu tion in industrial use would be t

established during such an emergency. 'Ibe inpact on industry would vary according '.

to the type of operation and the ability of the firm to reduce water usage without shutting down. Scme firms may be more flexible in switching to alternative supply sources (e.g.,

groundwater).

Others may be able to reduce production without shutting down cm pletely._ Since this level of industrial conservation has_never-been attained .in thE Philadelph'ia region, it is difficult to'say for, ,

certain what the econcmic impact of this reduction would be. As part of the energency planning effort there should be a study in cooperation with the Chamber of Ccmnerce and the Philadelphia Industrial Developnent Corporation ("PIDC") to assess this. Since certain industrial groups are better able to reduce consumption without affecting production or enploymnt, a Canmercial and Industrial Water l

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dse rmmittee could' be' established .through the'ch=har of cr=narce to ; ' .. .

detarmine the-best way for all industrial users'to' attain this goal.

Perhaps certain industrial groups could save more than 25%, thus off-V[y setting those with less than 25% without shutting down any firm's u q.1 7

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' operations. A 25 perc'ent reduction would reduce Philadelphia. .

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industrial water usage by 13.8 M3D.

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f JP"ublihProperEfes-Publ'icpr8 pert $s'aredefineEiadbuildings'and parks owned by the City of Philadelphia. Public property accounts .

include public schools, public libraries and nuseums, city buildings, recreational centers, park facilities, etc. Prohibiting the use of public swinning pools, reducing the use of other public buildings '

(schocols,nuseune, libraries) and implementing various conservation k

measures mentioned in the mrmarcial use section should result in a ten g percent reduction (1.1 MGD). It was assumed that public property accounts and careercial accounts have similar usage patterns and there-fore similar potential savings.

Bucks County - Bucks County Water ard Sewer Authority customers will be .,

, 1 * *

• impacted since the Authority is a wholesale custcmer of the Water Department. c It is unclear to what extent 'onservation will succeed here since the City of Philadelphia does not have direct regulatory control over the custcmers. During the 1981 drought, consunption increased in Bucks County by 3.3 percent during February-May and then >

reduced 11.3 percent during June-August. Overall, the level o~f conser-

) vation was less than in the City of Philadelphia.

.. . For this reason a 15 6

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9 percent' reduction.was ascumed for n' 2.4 MIi savings.

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What sources of information were. consulted in the preparation of these

)

i estimates?

.. - m A.19.

A mnnhar- of analyses prepared following' the:1981 drought iS ' '

PhilMalphia were reviewed to determine what -levels of. hydrant.use:

reduction

,., and custane.r

. ...- conservation arezfeasible.

,c . Aeveral

-.c articles ..

> . f+ v -

were also reviewed which analyzed the effectiveness of various measures s

taken in northern California in 1977 and in northern New Jersey in 1981 during the severe droughts in those states. Metered consunption history records were obtained fran the Revenue Department's Water Revenue Bureau. Water distribution records were ob6inad fran the operations Division of the Water Department. The 1981 City of e.

t Philadelphia Drought Water Bnergency Plan was reviewed to detennine which non-essential water uses might be banned during the energency.

Many of the draught measures would need to be made more stringent as part of an inglenentable water energency plan for Limerick. A number of estimates were prepared based on procedures referenced in the Water Department's FY80 Unaccounted-For-Water Report. A panphlet entitled S Water Conservation and Wasteflow Reduction in the Ikme (Special' Circular 184) fran Pennsylvania State University provided this infor-mation in per capita use and residential conservation measures.

Q.20. What are the results of this preliminary analysis?

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.Ai20. If'successfully impleme'nt'ed, the'various conservation' measures pr~e .

~ , viously.: described would.1'ikely reduce the peak day consunption fra 480 MGD to'338 1CD. This' represents'a thirty percent reduction in

r -

'conbmptlon.;Abreakdown"ofthisreductionisasfollows:

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' Peak useage of 480 BGD (85.0) illegal hydrant _use

- ./ . .:(5.'0) other-hydrant use

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6 - _-

(30.2) resldential (4.5) ammercial (13.8) industrial -

(1.1) public properties (2.4) Backs Counties 338.0 !GD This projected reduction could lower consunption fr m the peak day usage to approximately the average day usage (342 BGD). If one

. I, subtracts out the 12.1 LED average day demand of the Belmont High Service District (which currently cannot be supplied by Baxter without permanent punping and piping improvements), the remaining 325.9 MGD represents the demand the Baxter plant would have to satisfy to supply the rest of the service area. This is below the 350 3GD peak day capa-city of the Baxter plant.

Q.21.

Are there any caveats that should be mentioned regarding the assunp-tions that were used in the preparation of these estiimates?

A.21. First and foremost the applicability of each conservation measure will depend on the type and degree of accident assumed. The neasures that e

19 '

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s wers chosen and tne conservation-estimates'that were made may change '

radically for a different accident with .different impacts.. For i

exanple,.an accident which is less severe may enable the 'Watir '

~ {

Department to use at least part of the capacities of. the Belmont and Queen Lane' treatment plants assuming additional . treatment remedial measures are undertaken.

e.

Samvi}yc the:assunptions thakwere usedrand the. estimates that were prepared are not hard numbers - they rely on a good deal of guesswork .

since we do not have a previous accident history upon which to base our judgment.

For exanple, any estimate of raanead residential consunption will be inexact in the case of a nuclear accident. It. is difficult to l

( approximate how the Philadelphia population will respond to such an energency.

Sme people may decide to board water once an emergency',is declared, especially in districts which are severely inpacted. This would reduce thb amount of conservation that is feasible. On the other hand, a number of people may decide to leave the area during any w rgency.

This would tend to increase the anount of conservation that

{

is feasible. A third possibility may be the evacuation of number of

~

people frcm one section of the' city to shelters in another section.

This may redistribute the consunption demands for potable water, thereby-increasing or decreasing the feasibilty of various supply alternatives.

It is also difficult to estimate peak usage by rustcmer class. There have not been any studies to date in the Philadelphia service area on

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.the daily variatica in demand .for each . type of.custcmer throughout the '

year. The ten and. twenty percentage increases chosen were based.on ~

literature values reported for other er-mmities, not on actual con- . .;

sunption data -for Philadelphia. %e peak' usage es'timates for>

s. .

, industrial consunption are espedially difficult' to determine ~since .

industrial'use tends toibe.less hoogeneous'in nature.:

G.22.

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.^

^ j' ,r During~Mr. Rulesza's' testimony it was mentioned that lime-soda ash sof-tening might be used to remove SR-90 during the sadimantation process '

at the Baxter Treatment Plant. If the water treated at the plant was softened twice, what possible inpacts would this have on the ability of Baxter to meet the City's average daily demand?

L 1

A.22. The use of lime-soda ash softening to remove SR-90 at the Baxter Treatment Plant may reduce the through-put by as must as one-half at the plant if the water is softened twice. If approximately 170 M3D is recycled then only 170 M3D would be available for distribution, which clearly is inadequate to satisfy demand.

Q. 23.

Beyond-the imposition of city-wide' rationing and non-essential use ban -

measures, are there any additional measures that might be necessary?

A.23.

Yes, dditional neasures must be undertaken for a long-term accident in certain high pressure districts in the Philadelphia Service area to ensure that these custcmers do not run out of potable water. These people would,be impacted most severely by such an accident.

4-

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specifically,.the Belmont High Service dictrict and approximately thirty percent of the service area ~of the Roxborough High Service -West J

~ Oak Lane district would be impacted if the Schuylkill Ri~ver was una- -

~

,* bailable n as~a-supply source for a long period of_ time. These measures w

, would 'stil1~ be ' required- even .iI the city--wide measures were success- .

. - . fully inplemented to the ==v4== extent possible. -

<: + Q'.24?

'n Ple'ase sunma ihe any'ihformatio yodhave dn t. hen' umber'of people' that

, ,  :. .v-a.

muld be affected and the anount of consuuption in these two districts. -

A.24. The following table sunmarizes the consunption in the two districts that would affected by such -an energency. Consunption values 'for the affected areas of the Roxborough High Service - West Oak Lane District 4.

can not be aadelated fran known consunption values for the entire' district due to the non-hanogeneity of this service area.

- In order to fully evaluate various mitigation techniques for this district, con-sunption and population numbers will have to be prepared as part of the energency planning process.

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(IED) ' (M3D) ' (bGD)

Average Day Max. Day ~ Max. Rate Pooulation Belmont High Service 12.1 14.9 l 22.3 65,500 Roxborough High Service 16.9 24.6 46 .4 111,138 W. Oak Lane (total service)

Roxborough High Service N/A N/A N/A N/A W. Oak Lane (affected portion only) 0.25. What neasures did you review that might be necessary for these two districts?

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Four poss'ible ' techniques wars proposed to' supply the two di:tricts with potable water. The proposed' techniques-include 1) the use of~ tanker trucks or tmporary storage tanks, 2) the installation of energency I

. .~

, pipes;and; pumps to provide additional capacity,_3) Use permanent nodi-s

. fication and improvenant of 'the distribution systs to enable residents , .

in' these two districts to. be ccanpletely supplied by the -Baxter plant

,and 4) the creation of permanent interecruw:ction(s) with neighboring ,

t. m.. J._ water ., supply purveyors who. have . excess. capacity.7. Ibe . first two ' tech -

niques represent temporary or step-gap measures while the latter two techniques are more permanent in nature.

Q.26. What criteria were chosen to evaluate.the appropriateness of these various measures?

r A.26.

Each measure must be evaluated in terms of the accident event that wts presupposed. In the particular case we mentioned, they must be con-sistent with a situation in which the Schuylkill is unavailable as a supply source beyond the seven to eight days of available storage and

-the ident has. occurred during:a period of peak usage. ~

To properly evaluate these four techniques one must first assess the impact of' this emergency on the distribution' system in the two high service district affected areas. As potable water supplies are depleted in these districts, three possible impacts could occur.

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L The first possibility;is ~ that' afdecision';is made'not to'punp any water N s ,

.into those mains. This decision ,could be disastrous for the integrity

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-l Gf l i of the systen. Asairgets;entrdined the innins tit nere and more difficult to resMl' the y systemylthout 2

causihg pipe collapses

' dueJto vacuum'or water W r.,gTo prevent such damage, the resupply

'.would take a m=*=r of days, retarding the reestablishment of service.

.In addition, the. lack ofiwater in. these mains .is mtable fran a

-ipublic' safety. standpointE due to the unavnflahilityhof'. water for(fire '

fighting purposes. %Is situation is especially acute in the case of the b1mnnt High Service District which would run out of water (assuming temporary r M ial measures have already been taken)-in approximately seven days if no Schuylkill, River water or alternative water supplies were punged into the system. S e situation for the affected areas in the Roxborough High Service - West Oak Lane District I is less straight forward.I Although sane water would probably remain in I

\ \ -

many of the amins in these a'reas (especially% lower elevation areas),

it would be inadequate to meet water consunption demands. It is unclear, without a very detailed analysis, to what extent these mains would have water and in what quantity. It is assumed, especially at i

.thethigher' elevations,lthat.the available supply will be inadequate

, fran a pressure sEandpoint for filefighting.

I

. r, The second possibility is that contaminated Schuylkill River water is punped thrcugh these mains to prevent the loss of supply. The problem with this w tion is that there is a potential that a number of people may ingest this contaminated water despite an intensive door to door l

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education efforti. ~.In'aJrecent Pittsburgh area conta'minated water case, a family' ingested contaminated water in spite of such an education and-media campaign.

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It is difficult to. imagine a.100%' effective campaign t .. .

... . . , s. -

.in reaching

= ' every; person affected in the tiwo~ districts. Given these, drawbacks and the availability of alternatives;, this option is:not,

' viable.'

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The' third and"enly viable possibility available to the City'of Philadelphia is the provision through the distribution system of alter- '

native sources of potable water to these Districts.

i Q.27. On the basis of these criteria, which measures that you evaluated for the two districts were M non-appropriate and why? k A.27.

The first two"pbssibilities presented in the previous response avoid the use of alternative water supplies, through the distribution syst s ,

for potable water uses. Both possibilities rely on the use of tanker trucks, tm porary storage tanks, or bottled water to supply potable

, ~

> waterifor drinking, cooking 'and.possibly bathing. purposes. Addit [onal water would be needed for sanitary purposes (toilets and. bathing) if the no punping first option was chosen. V.S. Boyer of PECO has indi-cated in his letter under date of August 1984 to Ccmnissioner Marrazzo (City Exhibit "B") that the use of tanker trucks is a feasible cotion.

Given the discussion in the previous response, the use of tanker trucks is not a viable cocion since there are ways to obtain potable water through the distribution system, which is the preferred alternative "-

6

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, ' all{ water supply needs could be5 satidfied[and health and safety hazards 1 are minimized. This is especially true in the case of the Ninmt High service District which will run ccznpletely out of water in approxima- ,

{

1 tely seven days. One underlying reason behind the determination that O ,

- . tankertrucksare[non-appropriateinthiscaseisthe_opinionthat mitigation techniques implementable ~in the case of a severe' drought are not necessarily appropriate in the case of a nuclear' accident. A

' ~

e nuclear. accident ..is much more likely to have health impact con-

~

's. ', ,

siderations as well as supply considerations. During a severe drought, for example, water could still be punped frczn the Schuylkill to these districts without the fear of people ingesting this water. This unfor-tunately is not the case with a nuclear accident.

The letter by Mr. Boyer also refers to the use of temporary pumps and piping to supply the blmnnt High Service District frczn existing covered reservoirs supplied by the Baxter plant. Specifically, he refers to the supply of the Behnont High Service District Clear Well using a tenporary punping and piping scheme frcan the covered Monument Road Reservoir. The Monument Road Reservoir, which normally is used to-supply the Belmont Gravity District, could be supplied frczn a transmission main that connects to the East Park Reservoir. The East

. Park Reservoir, in turn, could be supplied by the Delaware River. In order to sup,oly the average daily consumption (12.1 m to this district, sufficient tenporary puncing and piping capacity connecting the Monument Road Reservoir and the Clear Well would be required to satisfy demand. Mr. Dick Lamison of PW A has indicated that pipes and L

26 '

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pumps' ara availablo fr a that agency on an emergency. . basis. ~Mr.

1 Boyer's transmittal does attempt to define the total punping capacity and the discharge piping size.that would be required.

s The.use of- tanporary punps and piping 'is cons'istent:with the al'ter- ~

native potable water; supply criteria presented earlier. Fr a this standpoint'the measure is a viable alternative. This alternative may

~ '

inot be viable, however, for some degrees of accident. The accident .

that was assumed here was a cont aination of the Schuylkill River for '

more than seven to eight days such that available potable water storage supplies would no longer be available to supply the impacted high ser-vice districts. Mr. Boyer's letter fails to address'the fact that i:tsufficient hydraulic capacity currently exists in the 48 inch I L 1

transmission main that curi:ct.s the East Park Reservoir and the '

Mountain Road Reservior to supply both the Belmont High Service and Mmnnt Gravity District on a peak usage day even if the conservation measures previously discussed were fully implemented. The tenporary punping and piping scheme will succeed in the extending potable water

. service to the Belmm High Service District frczn a four day supply to '

a seven day supply but this measure does not represent a long-tem

~

feasible response. .

Q.28. The remaining measures that you mentioned earlier are 1) the installa-tion of punping capacity and piping to permanently modify Philadelphia's distribution system and 2) the construction of intercon-nections with adjoining water supply purveyors who might have an excess '

I j

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'empscity 'of' non-c'on'taminated 'wa tee : supplies .

. Have yoh studied.either

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e of'these measures in more detai1I and,'if_so, were~any possiole-su'pply u options identified?' * *

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A.23.- p Thedfi~rst sup' ply measure 'available !t o the Water Department. ,would ,,

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. require .'several? permanent :mo'dification$i of Philidelphia 's -distribution ', ,i 3

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_- 1 s'ystemfin order to supply the two high -service districts. In the = case

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of an emergency. thisi measure represents the quickest. and most. effective (Q~%~

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response'by' the' Water Department. _ This, measure voc!d require ' the installation.of some combination of additional pumps and piping-capa-

• city. It should be mentioned that each design alternative identified I

L for this measure would require additional studies to' size the piping and determine the additional pumping capacity that will be required.

Engineering cost estimates must be developed as part of this process.

e t

( The modification of the system in terms of this meas'ure shocid be

^

evaulated'f' rom two standpoints: 1.) increased transmission capacity

+

from the Delaware River to the Baxter Treatment Plant and 2.) increased transmission capacity from the Baxter Treatment Plan to the two impacted high service districts.

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3

' Increased transmission capacity from the-Delaware River to the Baxter Treatment Plant would have at least three possible benefits for the l Water Department. The first benefit would be an increase in peak capa-1 city at the Baxter Plant which currently is 350 MG3 due to raw water pumping constraints. If these constraints could be eliminated, actual I

{ peak capacity could increase to 423 MGD. This would improve the safety I

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margin 'for' the Water. Department 'on a. peak'~ day _ assuming the Schuy1 kill River is-unavailable'as a'supp1'y source.

Earlier (it was'pcojected'that 4

r u ld be ' reduced from 480 MGD to .338 MGD through the peak.. demand co'

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- various u

^ conservation meas _ res., < This only leves .a slight 12 MGD safety."

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margin. :If~:w } the araw water transmission capacity was increased,and if . <

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. th's other~ intra-system transmiss' ion'capacitf modifications'were imple-- ",

mented, the. Water Department could safely supply its ' entire service ~

jarea und'er tb corisiitions assume)t.S c /b5- N Y ^ $s iJ fb

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• The second possible benefit this would present for the Water Department '

would be an increased flexibility in water supplies for the region.

For example,? assuming interconnection (s) were available in Northeast

' Ph'iladelphia with the Philadelphia Suburban Water Company (PSWC); the Ph::adelphia Water Department could supply eastern sections of PSWC's e

capacity. PSWC's freed capeity could then be used at two other inter-f connection's,near the Belmont High Service and Roxborough High Service-West Oak Lane Districts to suply these two areas. The increased capacity of the Baxter Plant would therefore enable the City to " tradeoff" its water supplies with neighboring water purveyors.

This supply option would eliminate .the need for the previously men- -

tioned intrasystem modifications. This jaw water supply enhancement could also be scaled back to allow for PSWC or another water purveyor to supply one High Service District which would mean that the Water Department could lower its raw water transmission capacity increase requirements. The Department would, however, have to provide addi-

. tional transmission capacity,to the other High Service District.

29

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aJ Tha? third lb:nsfit' w:t$1d be ito -increase potable water's'uplies available -

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at the Baxter Plant 'in an' event: of partial' contaminationfof the

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Delaware River, requiring the use of lime-sode ash,spf tening;t for d/c. on-

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, tamination.'.-Since.this'treataent' process;mayrequiretheDelaware[

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~ River water"to be sof tened twice, n - ,thereby reducing the_ throughput of . ,

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z the plant'g b'y' as muci as: one-halI, any increase in peak .capacith will be~.

highly beneficial in. helping. the Water Department 1 attain;ics objectives

.; . u

, ofguphlyi~ng 'as[many,[ people as pos' sib'le' Oith! potaple'. vater.durinE Ean : ', ..l emergency.

s 7ncreasing the. transmission capacity from the Baxter Treatment Plant to the two high cervice districts can potentially be accomplished in a number of wa'ys. Several modifications may be necessa'ry given the '

current distribution network arrangement to effectively supply the two t.

districts without the use of interconnections. The purpose of these T

modifications would be to supply the BHSD and section\s of Germantown, -

N Roxborough, Manayunk and Chestnut Hill with sufficient additional capa-city to ensure adequate pressure for firefighting and potable water use in all areas, including the higher elevations.

Thelother.sup' ply, measure'- a' vailable - to 'the . Water [ Department that' should .

~

be further. eval,uated is the possibility of- Yonstructing interconnec-1 -

tions with adjoining with supply purveyors such as the Ptpladelphia Suburban Water Company or the Chester Water Authority. 'his option was discussed in the previous paragraph for the situation where' the raw water peak capacity of the Baxter plant is increased and supply tes-l 1

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danffs ~thr ugh intsrc nnse'tiens areLimplemented. - Andther possibility

. tha't may.be feasibie is . for one ~ or 'aore suburban water supply purveyors 1 ,

to supply the two highiservice districts without any ' water s'upply trade-r  ; _

j. .

offs. /Diis would( oblivate 'the need .for any permanent' Water Department

~

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distribution system modifications.. Only one'wate'r~ supply interconnec- . ..

f ti~on ; currently exis t between purveyors (with Bucks ' County Water lind , '

Sewer Authority.). It may: be ~ feasible: to construct ,one .or more addi-

?; _

' l tional a Lintercon'nedtions iw'ichi.s'dburban; areis J if' the tpuriveyors imig$t havel excess uncontaminated supplies under these emergency conditions. This would be the case for purveyors which rely on ground water sources, adjoining supply basins or stretches of the Delaware River not con-taminated. It is assumed in the case of a. regional.. water supply emergency enforced by the Commonwealth that neighbordng water supply purveyors would be requested to implement water conservation and ',

rationing measures even if their supplies were not directly impacted by the acciden't. Under these conditions there are any other utilities with sufficient excess capacity to supply either or both of the high service districts. This must be researched immediately. If excess capacity is available, further design studies will be required to determine the .sizec and ' connection ' pol'nts 'of ' the" transmission m'ains and - '

the capacities of the pumps that will be needed as part of each inter-connection. Simulation studies should be performed under a variety of emergency conditions and system demands prior to the selection of any design alternatives.

To evaluate the potential for regional interconnections , the emergency plan must include an analysis on a regional basis of various sources of

. 1 -

31

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citerar,tiva. water supplics that. water' purveyors' might have' available . in excess supply in the. event that.the Schuylkill River was eliminated as

'a tsource of L potable water for various time frames. Emergency planning

>j. .

?should ~ proceed wi'th'the objective of developing strategies in all i

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, . af fected

- e water servide- arean go thst' thr ics:t.,ausbA: of people will

( , -so,t'have'.an.available.non-contaminated water supply source. 'The emergency plan 'for Philadelphia should therefore be part of a regional

.. ;- 4

' emergency. plane.that could, b~e implemented. following .an accident -at Limerick.

Q.29. Have you evaluated the feasibility of these water supply options at this time?

A.29. No. Each water supply option will require estensions or modifications to the existing distribution system network. Some of these optid%s may require significant capital expenditures to accomplish. Further research an' d detailed design work will be necessary to evaluate these alternative adequately.

Q.30.

In summary, what needs to be done to have an implementable water supply emergency plan? -

.t r A.30.

In order to have an implementable water supply emergency plan for the City of Philadelphia a number of steps need to be undertaken jointly by the City, suburban water purveyors, the Commonwealth and PECO.

Firstly, PEco must develop various accident probabilities, risks and impacts as an input into the planning process. Secondly, each party 32 U

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/ anat review: this information. Appropriate conservation and water supply measures for. each level of accident must' be developed. i Institutional-or 'organisational' barriers-to the implementation of.these

-l

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measures aust'be litentified. For example, the City does not. currently n, -

'have t rationing plea 'for its customers. The. legal framework for .

), .

I

. instituting such a plan.must be developed. Organisational procedures 1

i.o institute the .distrib'ution 'of flow restrictors city-wide and the-

- ~

rapidreduction'iniillegal'.'hy'drant' usage'may;also'needcobeaddressedI , s Thirdly, a detailed study of feasible potable water supply options for each severely impacted district that would be affected by one or more levels of accidents must be prepared. Detailed design, construction

- and cost information for each feasible alternatives must be prepared.

This study should provide the basis for the development of a regional water supply emergenc[ plant to fully explore the possibility of k creating interconnections. This study should be funded jointly by all o

parties inv'lved (regional water purveyors, the City, the Commonwealth and PECO). Finally, the plan must be adopted by all parties involved.

Necessary water supply enhancements recommended in the third step must be funded and constructed. Institutional and organisational constraints to the implementation'of variousIconservation measuies mus~t be overcome. The plan should be subject to a public hearing process

- prior to adoption.

Q.31. Does this conclude your testit.ony?

A.31. Yes it does.

33 4

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!6 '- - . m q UNITED STATES ^OF AMERICA p

' NUCLEAR REGULATORY COMMISSION'O.[nn.r-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD oq j z,

.g w. -v I

Helen F. Hoyt, Chairman Richard F. Cole, Adminis trative Law Judge ~ ,

Dr. Jerry Harbour, Administrative L'aw Judgd "

IN THE. MATTER OF:  :

Philadelphia Electric Company  : Docket Nos. 50-352 (Limerick Generating Station- 50-353

. Units l' and ,2) . ~

.~ _  :~ -- -

CERTIFICATE OF SERVICE

• I hereby certify that a true and correct copy of the City of Philadelphia's Testimony in the above-captioned proceeding have been served on the following persons named on the following Service List,,by Federal Express Mail, or '

i by causing the same to be deposited in envelopes addressed to said persons , first class , postage prepaid, and deposited with the United States Postal Service at Philadelphia, Pennsylvania 19107.

Respectfully submitted,

~~

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,,h6{k(h b

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MARTHA W. B USH ,

Deputy City Solicitor f

DATED: bA '

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'~  ;

Paul B. Cotter, Jr. -

Maureen Mulliga'n, Esquire Chief Administrative Law ' Judge Limerick Ecology Action-l Atomic Safety, & Licensing Board

,~

'U.S. Nuclear ~. Regulatory Commission; . Post Offi.ce Box 761_., . . .

~Potts town', , Penna. .19 46f Washington,:D.C.-2.0555 7 -

s - "

Jerry Harbour, Dr. Zori G. Ferkin (FE)

Administrative Law Judge Assistant Counsel Atomic Safety & Licensing Board .

Governor's Energy Council '

1625 N. Front Street U.S. Nuclear Regulatory Commission P.O. Box 8010 Washington, D.C. 20555 Harrisburg, Pennsylvania 17125 Helen F. Hoyt, Chairman Mr. Frank ~R. Romano

~

Administrative Law Judge 61 Fores t Avehue Atomic Safety & Licensing Board Ambler, Pennsylvania 19002 U.S. Nuclear Regulatory Commis5 ion Washington , D.C. 20555 ,*, 'y Mr. Gregory Minor '

Honorable Richard F. Cole MHB Technical Associates Administrative Law Judge 1723 Hamilton Avenue Atomic Safety & Licensing Board San Jose, California 95125 U.S. Nuclear Regulatory Commission Eugene J. Bradley Washington, D.C. 20555 Philadelphia Electric Company Docketing & Service Section Associate General Counsel Office of the Secretary 2301 Market Street '

U.S. Nuclear Regulatory Commission Philadelphia, Penna. 19101 Washington, D.C. 20555 <

~

Edward'G. Bauer, Jr; Vice-President & General Counsel Benjamin H. Vogler, Esciuire .(FE) 0.E.L.D. Philad'elphia Electric Company U.S. Nuclear -Regulatory Conmtission 2301 Market Street Washington, D.C. 20555 Philadelphia, Penna. 19101 Mark Wetterhahn, Esquire (FE) Mr. Vincent Boyer Troy B. Conner, Jr., Esquire Senior Vice President Nuclear Operations Conner & Wecterhahn 1747 Pennsylvania Avenue, N.W. Philadelphia Electric Company Washington, D.C. 20006 2 301 Market Street Philadelphia, Pa. 19101 Robert L. An thony 10 3 Vernon Lan'e .

Moyland, Pennsylvania 19065 '

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Mr. NE .TL Robb , N2-l'-

Philadelphiai Electric Company Robert'L. Sugarman, Esquire

.2301 Market Street. ~ Sugarman,.lDenworth & Hellegers Philadelphia,J.Pa. 19101 16th ~Floorf Center Plaza ~ -

101 NorthiBroa5d St/eet '

(Honorable Lawrence Coughlin

. ;Philadhl'phia, Pennh. 1910 7 House iof Repres~entatives. . .

Charles We Elliott, Esquire'

, Congress of, the . Uni.ted . S tates 110liBuilding. .I '-

Washington ,:-D. Ci 20515 .

Easton,1 Penna., ;1804.2 -

Frank Hippart, Director ~' .

Pennsylvania Emergency *

. Spence W.: Perry, Esquire Associate General Counsel Management Agency; B .151 1

- { J Transporthtion & Safety.' Building 1 Room 18'40" 'Fe.deral ~" Emergency

' ' ' ' '^-Management..

Harrisburg, Pennsylvania 17120 500 C. Street, N.W.

Washington, D.C. 20472 Roger B. Reynold, Jr., Esquire .

324 Swede Street U.S.N.R.C. Region I Norristown, Pennsylvania 19401 631 Park Avenue

. Phyllis Zitzer King of Prussia, Penna. 19406 Limerick Ecology Action Thomas Gerusky,- Director P.O. Box 761 Potts town , P a. 19 464 Bureau of Radiation Protection Department of Environmental For FE: 762 Queen St. # -

Resources *t Potts town, Pa. 19464 5th Floor, Fulton Bank Buil' ding Third & \Locust Streets Timothy R. S. Campbell Harrisburg, Penna. 17120 -

Department of Eme~r gency Services 'N 14 East Biddle Street Atomic Safety & Licensing Wester Chester, Penna. 19380 Appeal Panel U.S. Nuclear Regulatory Commission Mr. Marvin I. Lewis Washington, D.C. 20555 6504 Bradford Terrace Philadelphia, Penna. 19149

' Frederi'c ' M~. Wenhz - ',

I County Solicitor .

County of Montgomery .

Courthouse '

Norris town, Penna. 19404 J

Angus Love, Esquire 101 East Main S treet -

Norris town , Penna. 19401

, Mr. Joseph E. White, III

! 8 North Warner Avenue B ryn Mawr , Penna. 19010 t

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