ML20116D657
| ML20116D657 | |
| Person / Time | |
|---|---|
| Site: | Limerick |
| Issue date: | 04/24/1985 |
| From: | Bauer E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Weisman S DELAWARE RIVER BASIN COMMISSION |
| References | |
| CON-#285-742 OL, NUDOCS 8504290505 | |
| Download: ML20116D657 (8) | |
Text
7, %
PHILADELPHIA ELECTRIC COMPANY D
Y 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 DOCKETED Obbbb Eow Amo e. sAUER.JR.
gym gg,
'85 APR 29 All:08 EUGEME J. SN AoLEY oON Abo SLAMMEN RUoOLPH A. CHILLEMI 0FFICE OF SECRETARY E.C.x1RuMALL 00CKETING & SERviu T. M. M AMER CORMELL BRANCH PAUL AUERSACH Eow Amo J. CULLEn. J R.
April 24, 1985 THOM AS M. MILLER, JR.
PR00. & UTIL FAC.,.gd. "k -M8db 00CKET !!Uf.'UER i R E a = ^ " ".s ". a^
.. -.w Ms. Susan Weisman, Secretary Delaware River Basin Commission P. O. Box 7360 West Trenton, New Jersey 08628 Re: Application for Temporary Modification of Limitations on Use of Schuylkill River Water D-69-210 CP (Final) Revised
Dear Ms. Weisman:
Transmitted herewith for filing with the Commission are an original and six copies of Amendment No. 1 to Philadelphia Electric Company's Application in the above referenced matter dated April 23, 1985. This Amendment No. 1 consists of a revised application form and Attachment 1-A thereto and revises the Company's March 15, 1985 Application in response to Mr. David B. Everett's letter of April 2, 1985.
Very truly yours, e
g dward G. Bauer, Jr.
EGB,JR:pkc Enclosures l
l l
l l
8504290505 850424 D
gDR ADOCK 0500 2
L
Amentrent No.1 DELAWARE RIVER BASIN COMMISSION Type of Application: (Check one or more - see reverse side)
. (o) Addition to the Comprehen'sive Plan........................ ( )
(b) Change in o Comprehensive Plan Project.................... (x)
(c) Approval under.Section 3.8 of the Compact................. {c )
(d) Inclusion in "A-List" of the Water Resources Program......... ( ) -
.s Pursuont to the Delowere River Basin Compact and the Rules of Practice and Procedure of the For Use of' Commission De'lowore River Basin Commission, cpplication Docket No.
is hereby made for review of the project des-Date Received Action by Commission cribed below:
(A)
Application From:
Nome-Philadalchim Flac+-ric canpany Mailing Address 2301 Marka* Re aa+,
Philadelphia, PA 19101 Telephone _ (215) 841-annn.
Nome of Counsel Edward G. Manar..Tr.
and' Eugene J. Bradlev Nome of Engineer v. S. Bover (B)
Type of Project: (Check)
(I) Impoundment..'.............. ( )
(4) Stream Encroachment....... ( )
(2) Withdrawal of Water......... (x)
(5) We l l..................... ( )
(3). Disposal of Westess..........(.)
(6) O th e r.................... ( )
(C)
Description of Project:
For 1985, withdrawal of water frcrn tha Schov1 kill Rivar fnr mnemr+4ua n=a at Limerick Generating Station Unit No.1 hv teTicorarv substitution of in-stream monitoring of dissolved oxygen levels in place of 59 F t-Aehsre constras.nt 2.ncorporated in Docket Ib.69-210 CP (Final) (Novettber 5,1975);
and as necessary, release of varvira aneunts of mFar mt avraadim W 9 e fe, Fha F1'u mnew-m i n4-mn4-m i n=A in_
frcm water supolv storace as atzmnria+-a.
e
= aid docket to be inapplicable to any such releases.
Signolure of Authorized Person, Nome. v. S. nnvar V
Title Sr. v.P.,'Naclaar Perer DoIe-April 23. 1985
ATTACENENT 1-A Amendment No. 1 April 23, 1985 App 1Ication of Philadelphia Electric Company For Temporary Suspension of 59o Temperature Constraint and Blue Marsh or Other Releases as Back-up Supply Analysis of substitutino Dissolved Oxyaen Criteria. The water allocation by DRBC for the Limerick Generating Station, as approved by Comnission's Docket No. D-69-210 CP (Final) (Noventer 5,1975),
contains constraints on the withdrawal of water for consurptive use from the Schuylkill River. Water may not be used for the operation of one unit when the flow (not including future augmentations by Conmission) as measured at the Pottstown gage is less than 530 cfs (342 mgd) or when the river water terrperatures below Limerick are above 15 'C'(59 F) except durliig April, May, and Jule when the flow is in excess of 1791 cfs (1158 mgd).
The flow and temperature constraints were reviewed separately to determine their effect on water availability for various years. Based on flow records for the Schuylkill River as collected by the USGS at Pottstown for the period frcrn 1927 through 1983, 57 years, the nurber j
of days of water unavailability because of the flow constraints were determined for an average year, the drought of record year and the drought years of 1980 and 1981.
In an average year, the nurber of days experiencing a flow below 530 cfs is 52 days. The drought of record year 1965 experienced 167 days of flow shortage, followed closely by 1966 with 161 days of shortage. The recent drought years of 1980 and 1981 had low flows for 141 days and 105 days, respectively.
See DER " Assessment of Bucks County Proposals For Alternatives to the Point Pleasant Water Supply project" at p. 21 (June 1984).
..._,.--n-,-,
- 2.-
l 1
1 1
Water termerature records are not as cmplete as flow records.
The Pennsylvania DER obtained daily te:Teratures in the Schuylkill River from October 1944 to Septenber 1949 at Pottstown.
It was fomd that temperatures vary seasonally and are approximately the same every year. See DER "59 F Restriction on the Schuylkill River Water Withdrawal, Limerick Nuclear Power Plant" at p. 3 (Septenter 1983)."
Nonnally, temperatures begin exceeding 150C about May 1 and remain above 15 C until the end of Septenter or into October. The DRBC docket provision lifts the termerature restriction during high river flows in April, May, and June.
In an average year, this reduces the unavailability of water due to high termeratures to about 120 days.
Therefore, the temperature requirement would preclude Schuylkill.Rtver
~
withdrawals for Limerick'during the stsrmer and early fall of a normal year for approximately four months. Review of the USGS Surface Water Records for Philadelphia shows that water would have been unavailable based on the temperature criterla alone In 1965 for 181 days and in 1966 for 171 days. Sarmling at Limerick In 1980 and 1981 showed that temperature alone would have prohibited withdrawals 150 and 138 days respectively. These years were reviewed because they are drought years as discussed earlier, and restricted days would exceed those in a normal year.
The operation of Limerick is dependent upon the availability of water.
In the absence of the Point Pleasant facilities and water from the Delaware River during 1985, a more detailed review of the constraints was made; and possible modifications to the criteria were considered.
j l
"Since this doctsnent uses calendar years, all references herein are i
also to calendar years.
1
,*-e---ve
,e
-,-,--,,-,--a--.
.---w--
,--w,-,,
a...--r,-,-m~~--
w,e--n.~,,----.--n---,-----,----~~--.,,--,en..,e
,,-.e,a, The substitution of dissolved oxygen (DO) levels in the water for the temperature criteria has been proposed because the temperature constraint is based upon decreased DO levels above 59. For the reasons discussed below, however, the proposed substitution will probably not provide significant benefits by yielding a great nurber of additional days of Schuylkill water availability in drought periods as 1985 to date and as anticipated for the remainder of the year.
Under a drought scenario for 1985, interim availability of water supply storage will still be necessary for the continuation of the Limerick ascent to full power.
The purpose for which the temperature limits were established primarily relates to the dissolved oxygen levels in the water.
Monitoring DO levels at six stations conservatively located behind six dams rather than tenverature at one location would provide, therefore, protection to water cuality for the year 1985. See DER " Assessment of Bucks County Proposals For Alternatives to the Point Pleasant Water Supply Project" at p. 18 to p. 20 (June 1984). Under the tenporary, substituted criteria proposed by PECO, Schuylkill withdrawals could be made when DO levels as measured at the various locations exceed the Pennsylvania water quality standard for the Schuylkill River, 5.0 mg/l mininun dally average and 4.0 mg/l minimun instantaneous value.
Available data substituting a DO constraint for the tenperature constraint were reviewed for the years of interest. Accordingly, a correlation was conducted to determine benefits in additional days of water availability for those years.
a:
4-The year 1968 was selected as an average year to study because flow dropped below 530 cfs, the critical value for operation of one Limerick unit, on 55 days.
In the calendar year 1968, criteria data to make a correlation were available 276 days. DO data were missing truch of the year, and values that are available were take'n at Philadelphia. Considering the 276 days of data, water could have been withdrawn 177 days or 64% of the time under the present constraints of flow and temperature. Substituting 00 monitoring for the terrcerature criteria would have permitted water withdrawals 41 more days or 218 days, 79% of the year.
It was planned to study the drought year of record, 1965; but because DO data were lacking, the year 1966 was analyzed. As,noted earlier,1966 had alrSost as many low flow days as 1965 and consequently was a good representative of the record drought year.
In the calendar year 1966, data were available 326 days for a correlation. Water could have been withdrawn only 122 days or 37% of the time under present constraints of flow and temperature.
Substituting DO monitoring would have permitted withdrawals 50 more days or a total of 172 days, 53% of the year. However, or.ly 20 of these days would be in the months of June through Decerrber.
Review of the recent drought years of 1980 and 1981 Indicates that the substitution of 00 monitoring for temperature constraints may not significantly increase the ntrrber of days water could be withdrawn.
In 1980, data was available 296 days; and of these water could be withdrawn based on flow and temperature constraints 153 days or 52% of the time. Substituting DO monitoring would have increased the withdrawat days by only four days to 53% of the year. Those four
i.
da/s were in the months June through Decent >er.
In 1981, data was available 287 days; and of these water could be withdrawn based on flow Jm.m and temperature constraints 187 days or 65% of the time. Substituting DO monitoring would have increased the withdrawal days by six days to 67% of the year.
Five of those days were in the months June through Decent >er.
The 1980 and 1981 data reflect DO readings from water sangling at Limerick.
Two other aspects associated with DO monitoring should be noted.
The first is diurnal swings of DO levels. The DO data used in the correlation for 1980 and 1981 taken at Limerick were Instantaneous or j
grab samples and not 24-hour averages. Hourly values of DO for 24-hour periods were made in the Limerick area in the early 1970's, one day a month from March through December.
It was found that the lowest values of DO nonna11y occurred in the early morning, 4 a.m. to 8 a.m.
The sangling was conducted generally in the 8 a.m. to 10 a.m.
period so values obtained are conservative when considering daily average criteria and near the mininun value because the upswing was just beginning. The DO data obtained at Philadelphia included minimum, maximum, and average values. This pennitted correlation of the data to both the mininun daily average and mininun instantaneous DO criteria.
The second item has to do with the sangling locations. D0 sanples were obtained at Philadelphia (R.M.10.1) and Limerick (R.M.
48).
In a study made under an agreement with the DER for the purpose of developing a Ccrnprehensive Water Quality Management Plan, a centerline profile of DO values was presented for more than 120 miles of the Schuylkill River. See Water Resources Engineers, Inc. " Water 1
1
).
Quality Modeling...." at p. VI-30 (Decertber 1977). This study shows low DO areas in the river at Limerick and above Fairmount Dam in Philadelphia at (R.M. 12). Because D0 sampilng data used in the above correlation were obtained in or close to the Indicated low 00 level areas, DO monitoring at the six sites behind the low head dams downriver fran Limerick will adequately protect the envirorvnent.
As Indicated by the review, DO monitoring increases the nuTber of days that water can be withdrawn In a year.
In drought years, the nutber of days may be few because low flow becomes the dominant constraint. In such periods, the total days of flow restriction extends almost over the entire period of high water temperatures when the DO monitoring program would have permitted withdrawals.
The water needs for Limerick during 1985 for the continuation of startup (see Exhibit 5) will reach an average of 22 cfs during the months of August, Septerrber, and October. By substituting 00 monitoring for the temperature criterla, a reduction or saving in the amount of water PECO would need from a water supply storage reservoir
.a of about 44 acre-feet would result for each additional day that water can be withdrawn from the Schuylkill River. Modeled against the drought year 1966, 20 days would be saved for the balance of 1985 or a net reduction of 880 acre-feet from storage.
In conclusion, the effect of the removal of the temperature restriction is uncertain at best, particularly in a drought year; and it is clear that supplemental water from storage is essential.
Nevertheless, the temperature Ilmitation should be lifted for 1985 and the DO monitoring approach adopted because It appears likely that at least a few days would be " saved" In 1985 with the corresponding reduction in need for water from storage.
--r-y,-.
r-._
-. -, - - - - - -, -, - + -..
.-.v---.....,,_.-m...
. -. _ _. - ~ _ _ _
,-__._y...
-