ML20117D004
| ML20117D004 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/08/1985 |
| From: | Conner T CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Cole R, Harbour J, Hoyt H Atomic Safety and Licensing Board Panel |
| References | |
| CON-#285-912 NUDOCS 8505100001 | |
| Download: ML20117D004 (38) | |
Text
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L AW OFFICES -
CONNER & WETTERHAHN. P.C.
17 4 7 P E N N S Y LVA N I A AV E N U E. N. W.
Tnor a. CowNER.Ja.
WASHINGTON,D.C.20000 MARE J. wETTEERAMN ROBERT M. RADER DOUOf.A3 E. OLSON
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N N CH L8 ROBERT H. PUEL (2021833-3500 BERNNAED O. BECH HOEFER a-h CABLE ADDRESS. ATOMLAw OC Tt E
Helen F. Hoyt, Esq.
Dr. Richard F. Cole Chairperson Ato- : Safety and Licensing Atomic Safety and Licensing Buard Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Jerry Harbour Atomic Safety and Licensing Board U.S. Nucle'ar 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
Dear Board Members:
On May 7,
1985, the Delaware River Basin Commission
("DRBC") conducted its legislative hearing on Philadelphia Electric Company's application for certain changes in its authority from that Commission to obtain temporary supplies of additional water.
The Application, dated March 15, 1985, and the amendment dated April 23, 1985, have already been transmitted for your information.
Enclosed for the further information of the Board are i
the following items relating to our DRBC application and hearing:
1.
DRBC "PUBLIC NOTICE -- Project Review Applications Received" dated April 3, 1985.
2.
DRBC " NOTICE OF COMMISSION MEETINGS AND PUBLIC HEARINGS," dated April 16, 1985, pages 1 and 3.
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l Atomic Safety and Licensing Board May 8, 1985 Pago 2 i
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1 3.
DRBC draft partial preliminary " docket."
4.
" Applicant's Testimony" by Vincent S. Boyer dated May 7, 1985.
Sincerely, J
Troy B. Conner, Jr.
TBC/ac Enclosures cc:
Service List e
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'85 MM -9 A11 :46 PUBLIC NOTICE OFFICE OF SECRtiAs -
Project Review Application @ mecu ent SERVICf tmAN.;H The Commission has recently received applications from the sponsors of the following projects for approval pursuant to Section 3.8, Article 11, and/or i
Article 10.3 of the Delaware River Basin Compact.
These projects are presently under review by the Commission staff in collaboration with other public agencies.
Individuals or organizations having a special interest in these projects,- or information relating to their impact on water and related land resources of the Delaware River Basin, are invited to comment in writing to the Commission's Executive Director, Gerald M.
Hansler.
When writing about a project, please refer to its docket number as listed' below.
Such pub'lic hearings as may.be. required for. these projects will be announced at,a later date in accordance with the Commission's Rules of Practice and Procedure.
1.
Philadelphia Electric Company D-69-210 CP (Pinal) Revised.
An application by the Philadelphia Electric Company.(PECO) to temporarily, during 1985, revise portions of the Limerick Electric Generating Project as included in the Comprehensive Plan and to approve the temporary changes under Section 3.8 of the Compact.
The proposed revisions consist of (1) a sutr-1 i
stitution of dissolved oxygen controls (average 5.0 mg/l and instantaneous of 4.0 mg/1) in lieu of the existing 59 F temperature limitation to determine i
the availability of Schuylkill River water and (2) the release of varying amounts of water from Blue Marsh Reservoir and/or other water supply storage whenever the proposed dissolved oxygen limits or the existing flow limitation of 530 cubic feet per second (cfs) in the Schuylkill River at Pottstown would otherwise prohibit the consumptive use of water from the Schuylkill River.
The quantity of water withdrawn will vary during the power ascension testing and start-up period.
PECO estimates that Unit No. I will not operate at full power before September 1985. At full power water consumption will average 27 cfs (17.3 million gallons per day (agd)) with a peak demand of 32.5 cfs (21 agd).
The Limerick Electric Generating Project'is located in Limerick Township, Montgomery County, Pennsylvania.
I 2.
Mount Laurel Municipal Utilities Authority D-84-36 CP.
A revised
)
I application for a sewage treatment project to serve Mount Laurel Township in l
Burlington County, New Jersey.
The existing Hartford Road STP will be modified to eliminate. odor problems and to remove. 90 percent 50D and TSS 5
l from an average waste flow of 2.4 -agd.
Treated effluent will discharge to the Rancocas Creek in Mount Laurel Township, Burlington County.'
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Borough of Elmer D-85-24 CP.
An application for approval of two existing wells (Nos. 6 and 8) supplying the Borough of Elmer, Salem County, New Jersey with a-totd1 of 4.8 mg/30 days for domestic use. This is the sole
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water supply for Elmer.
The wells, which draw from the Wencah-Mount Laurel geologic formation, are located off Broad Street in the Boroegh of Elmer.
4.
Blue Ridge Real Estate / Big Boulder Corporation D-85-25.
A sewage treatment project to serve the " Big Boulder Lake ** resort area in Kidder Township, Carbon County, Pennsylvania.
The treatment plant will be designed to remove 93 percent BOD, 88 percent TSS and nutrients from an average waste 5
flow of 0.225 agd.
Treated effluent will discharge to an unnamed tributary of Tunkhannock Creek in Kidder Township.
5.
Borough of Ambler D-85-26 CP.
A ground water withdrawal application to continue approvals for the applicant's Well Nos. 12 and 14 Dockets D-77-92 CP and D-77-16 CP granted interim approvals in 1978 and 1977 for Well Nos. 12 and 14, respectively, subject to review when the applicant submitted an acceptable ground water monitoring program and a report on the. findings and analysis of the effacts of Ambler ~ withdrawals on the: water resosrces of 'the In 1984 the applicant supplied an average of 1.89 agd from nine wells area.
to meet system demands. Well No. 12 is located 800 feet east of Houston Road l
in Lower Gwynedd Township, Montgomery County, Pennsylvania and is expected to 1
yield up to 0.22 agd.
Well No. 14 is located adjacent to Butler Pike in Upper Dublin Township, Montgomery County and is expected to yield up to 0.547 agd.
4 Susan M. Weisman, Secretary April 3, 1985 i
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DOLKETENcaocuAarcas tocArion GrRALD M.MANSLrR USNRC as srArc pouct onivt cxecutive osaacrom wcs? rRcNrON.N4 NOTICE OF COIStISSION MEETING
'85 MAY -9 All :46 AND PUBLIC HEARINGS j
0FFICE Or SECRt.W
- Notice is hereby given that the Delaware River Basin CMf7af Q 1 N old a public hearing on Wednesday, May 1, 1985, beginning at 1:30 p.m. i CH4 Newcastle Room of the Radisson Wilmington Hotel, Wilmington, Delaware.
The hearing will be a part of l-the Commission's regular business meeting which is open to the public.
An informal pre-seeting conference among the Comissioners and. staff will be open for public observation at about 11:00 a.m. at the same location.
j Applications for Approval of the Following Projects Pursuant to Article 10.3 Article 11 and/or Section 3.8 of the Compact:
4 1.
Kudra. Rudra and Frawley D-84-40.
A sewage treatment project to serve tho' Heritage Hilla residential' development sin Upper Makefield Township' Bucks Cogaty,
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Pennsylvania'.. The treatment plant will be designed to remove 92 percent (sammer) l BOD and TSS from an average waste flow of 0.10 million gallons per day (agd).
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Tretted effluent will discharge to the Delaware River in Upper Makefield Township.
2.
Comonwealth of Pennsylvania. Department of General Services D-84-41 CF.
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sewage treatment project to serve Graterford Correctional Institution in Shippsch Township, Montgomery County, Pennsylvania. The project will be designed for storage and subsequent spray irrigation of an annual average of 1.0 agd of secondary treated i
effluent.
Spray volume will vary from 0.76 agd during winter months to 1.3 agd during the sumer.
The spray area will consist of 25 acres of woodland and 369 acres of pasture and : rop land.
Feed crops will be harvested and used for the prison's farm operation.
l 3.
Scott Paper Company D-84-53.
Discharge of industrial waste waters from the applicant's new cogeneration process at its paper manufacturing facililty in the City of Chester, Delaware County, Pennsylvania.
Up to 0.725 agd of treated coal pile runoff and 'O.461 agd of cooling tower blowdown will be discharged through I
separate outfalls to Zone 4 of the Delaware River. Coal pile runoff will be treated for oil, sediment removal and pH control prior to discharge.
l 4.
H. Bassan D-84-54.
A sewage treatment project to serve the applicant's
" Orchard" subdivision in Montgomery Township, Montgomery County, Pennsylvania.
The plant is designed to remove 96 percent B005 (suomer) and 90 percent TSS from an average waste flow of 0.15 agd.
Treated effluent will discharge to the Little Neshaminy Creek in Montgomery Township, Montgomery County, Pennsylvania.
5.
Texaco USA D-85-1.
An application for ground water withdrawal to supply the applicant's oil refining facility in West Deptford Township, Gloucester County, New Jersey.
Replacement Well Nos. 4A and 64, both located in West Deptford Township, were previously placed in service and repisce Well Nos. 4 and 6 which have been sealed.
Each well supplies up to 40.176 million gallons (ag)/30 days for cooling and process use. Total withdrawals from all system wells average 118.7 ag/30 days.
.)
l =.
Documents relating to these items may be examined at the Commission's offices.
j Preliminary deckets are available in single copies upon request.
Please contact David B.
Everett.
Persons wishing to testify at this hearing are requested to register with the Secretary prior to the hearings.
eeeeee The Commission will hold a public hearing on Tuesday, May 7.1985. fe 10:00 a.a. and 1:30 p.m. in the Goddagd.Cesference move or rne commission's offices at 25 State Police Drive, West Trenton, New Jersey to consider the following application:
l l
Philadelphia Electric Company D-69-210 CP (Final) Revised.
An application by the l
Philadelphia Electric Company (PECO) to temporarily, during 1985, revise portions of the Limerick Electric Generating Project as included in the Comprehensive Plan and to approve the temporary changes under Section 3.8 of the Compact.
The proposed p
revisions consist of (1) a substitution of dissolved oxygen controgs (average 5.0 J
ag/l and instantaneous of 4.0 mg/1) in lieu of the existing 59 P temperature limitation to determine the availability of Scheylkill River water and (2) the release of varfing amounts of water from Blue Marsh Reservoir and/or other water supply storage whenever the proposed dissolved oxygen limits or the existing flew I
limitation of 530 cubic feet per second (cfs) in the Schuylkill River at Pottstown would otherwise prohibit the consumptive use of. water from the Schuylkill Riv.er'.
l Th'e quantity of water withdrawn will vary during the power ascension. testing 'and start-up period.
PECO estimat' s that Unit No. I will not operate at fall power e
before September 1985.
At full power water consumption will average 27 cfs (17.3 agd with a peak demand of 32.5 cfs (21 agd).
The Limerick Electric Generating Project is located in Limerick Township, Montgomery County, Pennsylvania.
Documents relating to this iten may be examined at the Commission's offices.
Persons wishing to testify at this hearing are requested to register with the Secretary prior to the hearing.
PUBLIC INFORMATION BRIEPINGS ON WATER SUPPLY CHARGES l
The Commission is currently considering new revenue arrangements to meet its 4
prospective obligations for financing the proposed enlargement of two existing reservoirs in the Basin. Under its current progren, anticipated revenues from water charges will fall far short of meeting future contract or bond repayment requirements if revenues are not increased by greatly raising present rates or by expanding the number of paying users.
Based upon Delaware River Basin Compact i
Section 15.1(b), only surface water users who commenced or increased r. heir water use af ter Compact enactment in 1961 are presently subject to user fer; As of 1984, j
those surface water users subject to DEBC charges included ten public water supply l
systems, seven electric power plants, and 11 industrial facilities.
Presently, the vast majority of Basin water users are grandfathered and exempt from such r.harges.
In assessing potential arrangements for financing future water projects, the i
Commission believes that consideration must be given to possible modification of Federal Reservation Section 15.1(b) and potential extension of water charges, in some fore, to pre-Compact water users.
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Befora tha Dalawara Rivar Basin Comnission.
i in the Matter of
)
Appilcation for Teimorary
)
Modification of Limitations Philadelphia Electric Ccreany
)
on Use of Schuylkill River
)
Water 0-69-210 CP (Final)
)
Revised ETED APPLICANT'S TESTIMONY Introduction M *46 F
1.
My name is Vincent S. Boyer.
I am SergCVI'ceSPresl#ent, ETinG & sggy;cy Nuclear Power, Philadelphia Electric Correany ("PECO")
ch is omer and operator of the Lirnerick Generating Station (" LGS").
2.
PECO is seeking a temporary supply of water for 1985 in order to irrplement the ascent to power progran of LGS leading to comnercial operation.
3.
PECO. recognizes.that the water it Is seeking' frcm sources of 2
water supply storage, suchas' the Blue Marsh Reservoir, must serve the needs of all basin users.
Assuning Blue March as the probable source of a temporary water supply, PECO is seeking to use only a portion of that water now earmarked for future use by Western Berks Township C
, or water from other storage as determined by ORBC under the pooled water concept, for the remainder of 1985.
4 Under DRBC docket Ilmitations, in an average year, LGS can be operated on withdrawals from the Schuylkill River and Perkicmen Creek for approximately 200 days per year.
Accordingly, to pennit operation for a full year, particularly for the drought of 1985, water from supply storage such as Blue Marsh is essential.
5.
At the present time, Blue Marsh has 8,000 acre-feet of water designated for dcmstream water supply needs which Is eculvalent to a firm yleid of 55 cfs.
At present, Western Berks Water Authority has an allocation for only 9 cfs.
Accordingly, the remaining 46 cfs is more l
l i
than cnough to provide the 22 cfs needed on the average for LGS duri ng late 1985.
6.
Addltlonally, PECO proposes a temporary substitution of dissolved oxygen monitoring for the 59 F temperature Ilmitation for withdrawals under the present docket conditions.
7 It is uncertain,
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particularly in a drought year, how many additional days of water i
I withdrawal frcrn the Schuylkill would be made available by a temorary elimination of this restriction in 1985.
Nevertheless, Ilfting the t
tenperature Ilmitation for 1985 and substituting a dissolved oxygen monitoring program should be approved because it appears likely that a least a few days of additional withdrawals would be gained in 1985 with the corresponding reduction in the need for water fecrn water supply storage.
7.'
' Examination of the environmental Impact of temorarily Ilfting the temperature limitation for withdrawals demonstrates th t a
this will not have any adverse l@ act.
The temerature limits were estabitshed primarily to maintain State water quality standards for dissolved oxygen in order to ensure dissolved oxygen to meet th e
biological oxygen demands of wasteload discharges and to provide a
minimtsn dissolved oxygen level normally assocInted with a cold water fishery.
The dissolved oxygen monitoring program proposed by PECO for 1985 will assure protection of water quality by the maintenance of adequate dissolved oxygen levels.
8 PECO's request is made solely because Point Pleasant
, for reasons beyond PECO's control, will not be available in 1985 for the provision of supplemental cooling water.
This testimony strnnarizes the material contained in PECO's appilcations and suppor' o er 5,1975).
- 39. On Apell 23, 1985, the application was amended to reauest a change in the Comprehensive Plan corresponding to the terms of the proposal in the appilcation and to include an analysis of increased water withdrawals from natural river flow which would result frcyn substituting the proposed dissolved oxygen monitoring in 11eu of the existing temperature ilmitation.
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III. D7scription of Request A.-
Purpose 40.
PECo's request for temporary modification of the 59 F temperature constraint on the withdrawal of Schuylkill Ri ver water for constsnptive use during 19851s intended solely as an Interim meas
(
o enable LGS to ccrnplete the power ascension phase of operation I
u delay and to operate at full capacity in order to provide reli bl a e and econcmic electric power for southeastern Pennsylvania.
41.
Release of varying arounts of water, not exceeding 32 5 i
- cfs, frcm water supply storage during 1985 is also intended sol ely as an interim measure that will be requested only when Instream monitoring reveals low dissolved oxygen levels or when river flows fall b l e ow 530 cfs in the Schuylkill.or 180 cfs in the Perkicmen, which would otherwise preclude further 'wlthdrawals from the Schuylkill River frcrn Perklamen Creek.
B.
Proposed Plan of Operation 42.
The continuation of the start-up program and approach t o full power for LGS Unit I will begin following NRC authorizati on.
A gradual ascension to full power is planned with tests being conducted at several discrete power levels.
The test progran is estimated to require approximately six trenths, which provides time for r eview and approval of test results and for some adjustment and tuning of control systems.
43.
Based on the availability of consumtive water, the following program is envisioned.
For the first two months of the start-up program, Unit I will be operated at power levels up to 50%
of full power and the average consumttve water requirements will b e about 10 cfs.
In the third month, testing will occur at power levels up t o 75%
of full power with tha consumtive water recuirements averagin out 17 cfs._
Thereafter through Noverter, 1985, it is planned to conduct tests up to full power output with consunptive water need s averaging about 22 cfs.
When operating centinuously at full power, the average consumtive use will be about 27 cfs.
This can increase to 32.5 cfs under adverse meteorological conditions.
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44 During the test program, PECo will use withdrawals from th e
Schuylkill River and Perklomen Creek as authorized by the DRBC d ocket decisions.
When river water termeratures approach 59, PECo will conduct instream monitoring of dissolved oxygen levels in the Schuylkill River at predesignated locations.
In fact, we have already begun preliminary monitoring.
45.
When further withdrawals fecrn.the Schuylkill River 'and Perkimen Creek are precluded by ORBC flow constraint s or by low dissolved oxygen levels, PECo will request, during 1985
, release of water fra existing water storage facilities.
The water released will ficw into the Schuylkill River to be withdrawn at the S h c uylkill River intake for LGS.
Under the terTns of Docket No.69-210 CP (Final)
(Noverter 5,1975), the withdrawal constraints imposed b y that docket decision would be inappilcable to any such releases C.
Differences Between PECo's Application and Bucks
_ County / Del-Aware's Proposal
- 46. The termorary, Interim measures proposed by PEco are far more limited than those previously proposed by Bucks County and D l A e - ware Unlimited, Inc., which DRBC rejected in Resolution No
. 84-20 (August 15, 1984).
The Interim relief sought by PECo is requested solely in order to enable operation of Limerick during ccropletion of the Poi t n
ta -
Pleasant project, which will be the perranent supply of suopi enental cooling water for LGS.
47.
Unlike the Bucks County / Del-Aware proposal, which sought to reopen and overturn the previous docket decisions of DRBC in gran final Section 3.8 approval to the Point Pleasant diversion proj
- ect, PECo's application will protect, rather than defeat, the rights and interests of the parties to the Point Pleasant project do k c et decisions.
48.
Unlike the Bucks County / Del-Mare proposal, which sought an allocation from the water supply and water quality storage in Blue Marsh Reservoir throughout the entire operating life of LGS
, PECo is reauesting only an interim use during 1985 of a portion of the 8 000 acre-feet of the water supply storage in Blue Marsh. PsCo is not reques' ting any releases fran the 6,600 acre-feet of water c uality storage in Blue Marsh. Accordingly, the tenporary use requested b PECo so water supply storage in Blue Marsh would not int erfere with either DRBC allocations and increased withdrawals fro y
other users throughout the Schuylkill watershed, or DRBC's use of er cuality storage to protect and enhance water quality in the Basin 49.
Similarly, unilke the Bucks County / Del-Aware proposal
, PECo is not requesting a pennanent change in the 59 F terceratu re constraint on Schuylkill River withdrawals.
PECo is werely recuesting an interim substitution of monitoring for dissolved oxygen levels to prevent stresses on strean water cuality related to consumptive use of wate r at Limerick.
The PECo appitcation, as distinguished from the Bucks County / Del-Aare proposal, demonstrates the proposal's benefit to LGS in terns of additional days of withdrawals from the S h c uylk!)1 River
which would be gained by a temporary substitution of dissolved oxyg monitoring requirements for the 59 F temperature constraint.
50.
PECo's appilcation does not contain other features or alternatives which DRBC found unacceptable in the Bucks County / Del-Aware proposal, namely:
l (1) adverse impacts upon the capability to serve the public water supply needs in Bucks and I
Montgomery Countles; (2) Impairment of DRBC's capability to respond o
water Quality and water supply needs in drought emergencies; (3) substitution of releases from Merrill Creek Reservoir for storage in Blue Marsh Reservoir; (4) reduction of salinity control; (5) utilization of Schuylkill River desilting basins; (6) reallocation of 2,000 acre-feet in the Green Lane Reservoir for LGS; (7) reduction of the Schuylkill River trigger flow for LGS' Unit I from 530'cfs t o 400 cfs; (8) development of Red Creek Reservoir and/or construction of other puro storage facilities in Chester and Montgcrnery Counties 51.
PECo's appilcation does not contain the objectionable features which precluded DRBC's evaluation of the Bucks County / Del-Aware proposal.
Because Bucks County and Del-Aware proposed to eliminate the Point Pleasant project, their proposal recui red evaluation of specific water supply alternatives for Bucks and Montgcmery Counties, including engineering, economic and environmental o
impacts, which were not provided.
In contrast, PEco's application does not require such evaluations Inasmuch as its proposal will not Interfere with the avallebility of pubile water supplies frcm the Poi t n
Pleasant project as approved by ORBC.
- 52. Finally, in contrast to the Bucks County / Del-Aware proposal PECo's appilcation contains a rea11stic estimate of cooling water needs for LGS for the brief, Interim period requested.
DRBC previously found
th;t Bucks County and Del-Aware has substantially under estimated cons mptive water makeup demands for LGS.
Further, the constrnptive water makeup needs for 1985 during the ascension to power progr am are far less than the permanent, sustained operating power needs appilcable to the Bucks County / Del-Aware proposal.
IV.
Consideration of Potential Environmental irnoacts A.
Need for Power 53.
As to the specific need for the electrical power to b e
generated by LGS, DRBC has relled upon the findings of the N cl A
u ear Regulatory Conmission (previously the Atcmic Energ I
y Ccrmission) in its environmental statements for LGS.In issulng construction pernits for LGS, the AEC determined that there is a need for the elect 'i r, cal power to.be generated by LGS.
At the operating Itcense stage, the NRC similarly found a substantial benefit to the ervironment to be d erived frcm the operation of LGS in the annual production of approximately 10 billion kWh of base load electric energy.
1 54.
The Pennsylvania Public Utility Ccrmission ("PUC") st t d ae in an order entered August 27, 1982 that the pubile Interest rec tu res timely ccrpletion of LGS Unit 1.
The PUC encouraged PECo to ccrrelete LGS Unit 1 as rapidly as possible consistent with pubilc
. safety.
Pennsylvania PUC, Opinion and Order, Docket No 1982).
. 1-80100341 (August 27, 55.
Delays in the full power operation of LGS Unit 1 may adversely affect the restart of Unit 2 construction. The Pennsylvania PUC is presently holding hearings on whether constructi on of Unit 2 should reccmnence.
In ccnollance with a prior PUC order, construction
of Unit 2 h s been suspended until Unit 1 is placed in commercial operatlon.
B.
Alternatives 56.
Inasmuch as PECo has reauested interim relief for only the remainder of 1985, an alternative is not realistic and need not b e
considered unless capable of being prerrotly implemented.Thus, an alternative which would require construction or major modification of existing facilities would be too time constining to be practicable 57.
PECo considered various alternatives for a temporary sup l py of supplemental cooling water for LGS for the period of 1985 when docket decision constraints preclude withdrawals from th e Schuylkill River and Perkicren Creek.
58.
He Action Due to flow and temperature con'straln'ts im pos'ed by DRBC on withdrawals of' water fecri the Schuylkill River for consurotive use, the Schuylkill River will be largely unavailable f or such withdraaals during the period June to October 1985.
Because the permanent supplemental water supply frcrn the Point Pleasant di version project will be unavailable for this period, LGS cannotcontinue with ascension to full power without an Interim source.
59.
Delays in proceeding to full power will result in a delay in the ccmnercial operation of Unit 1.
Such delays will increase the cost of Unit 1 by $3t+ million per month.
This cost figure is comprised of
$24 mil 11on ner month Allowance for Funds Used During Constru on
("AFUDC") and $10 million per month operational
, security, and maintenance costs.
In addition, the fuel costs of PECo's customers will be increased by $15 nillion a month for each month of del ay.
Thus, the cost of not operating LGS for lack of water duri ng that period is estimated to be $r+9 million per month.
a
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60.
Ontelaunee Reservoir - Obtaining water supplies from this
\\
reservoir was considered as an alternative to the relief re here.
The reservoir is located on Maiden Creek, a tributary to the Schuylkill River upstream of LGS, and is owned by the City of R eading for use as a water supply source.
Ontelaunee Reservoir is reported to have 11,640 acre-feet of total. storage, although silting may hav I
e substantially reduced this storage.
The City of Reading was granted an allocation of 35 ngd by the predecessor agency to the Pennsylvania on May 14, 1968.
61.
The water supply system served by Ontelaunee is presently reported to use an average of 20 ngd with a nexinum usage of about 25 mgd.
In general, this withdrawal is for nonconsunptive use.
62.
PECo nade a presentation to the City' Counct) of Reading.and Inquired into the City's interest in providing water from its unused allocation to PECo.
The city has indicated no interest.
63.
Green Lane Reservoir _ - Obtaining water supplies fran this reservoir was also considered as an alternative to the relief requested.
The Green Lane Reservoir is located on the Perkion It is owned by the Philadelphia Suburban Water Campany ("PSW")
and is used in conbination with other reservoirs and wells for wate pply.
Total storage in the reservoir is 13,340 acre-feet PSW has advised OER by letter dated June 4,1984 that any use of water from Gre en Lane Reservoir by PEco would be "Irmossible" without " crippling" PSW' s water supply.
C.
Description of Phyrical impacts
- 64. Beneficial Impacts to the environment - The availability of cooling water during 1985 for LGS will enable LGS to complete its po ascension progran without delay and to operate at full capacity in l
l l
l
ord2r to provide re11able and econcmic electric power for scutheaster l
i 65.
DRBC has previously determined that the supoly of cooling water for LGS provides a benefit to the environment.
This conclusion can be found in both the DRBC Final Envirorynental Assessment for the Neshaminy Water Supply System, Part III, p. 2-53 (August 1980) a d i n
n the Section 3.8 approval to the Point Pleasant diversion project in Docket No. D-79-52 CP at p. 5 (February 18, 1981).
66.
No adverse impact from temporary suspension of 59CF
.termerature constraint _ - DRBC Docket No. D-69-210 CP (March 29, 1973) precludes Schuylkill River withdrawals for consurotive use by LGS whenever river water temperatures below LGS exceed 590F
, except during i
Aprli, May, and June when flows measured at. the Pottstown gage exceed 1,791 cfs'.
DRBC's' decision to limit Schuylkill River withdrawals when temperatures are above 590F is Intended to reduce stresses o n stream water quality caused by consumtive losses at LGS when water cualit y is significantly affected by organic waste assimilation.
e When termeratures in the river exceed 59 F, the biological oxygen d
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emand accelerates and the dissolved oxygen necessary for waste assimilation beccmes rmre critical.
67.
PECO proposes to monitor the river for dissolved oxygen at several predesignated locations below LGS and to substitute State standards for dissolved oxygen for the existing 59CF temperature constraint as the Ilmit on withdrawals from the natural river ficw This substitution of dissolved oxygen monitoring for the tem perature constraint is proposed only for the remainder of 1985.
PECO will routinely transmit the dissolved oxygen Information to DRBC
68.
The Pennsylvania water cuality standard for dissolved oxygen In the Schuylkill River is 5.0 mg/l minimum daily average and 4.0 mg/l minimun instantaneous value. PECO proposes that these two values be estabilshed as the critical values which Ilmit withdrawals frcrn natura river flow and also trigger releases of water frcm water supply e
storage.
t 69.
The monitoring program proposed to measure dissolved oxygen levels during 1985 will include water sanpling at least six times per day at regular time intervals at six different locations between LGS (R.M 48.0) and the Fairmount Dam (R.M. 8.5) in Philadelphia, 70.
The monitoring and transmittal of data will be accomplished with autcmatic equipment where practical and possible.
When autcmatic eculpment is unavailable, manual means will be uttilzed.: -Regardless'of the means of nonttoring, data will be transmitted to DRBC at least daily ard DRBC also will have ready access to all data during any intervening tirne interval.
71.
Depressed dissolved oxygen levels usually occur in the pools J
4 behind the dams across the Schuylkill R1ver, it is therefore proposed to establish a sangling station behind each of the following six dams:
Falrmount Dam (R.M. 8.5), Flat Rock Dam (R.M. 15.6), Plymouth Dam (R.M.
20.7), Norristcm Dam (R.M. 23.9), Black Rock Dam (R.M. 36.6), and 1
Vincent Dam (R.M. 44.7).
A sangling station at LGS (R.M. 48.0) was estabi tsbed about ten years ago and sanpling will continue at this location as before.
72.
At each of these stations, a single probe will be installed The specific location will be determined based on access, availability of electricity, telephone lines and protection from vandalism.
The
zu probe will be positioned vertically in the water colum bel ow the mid-point so that it will not be subject to surface effects 73.
This rronitoring program, when substituted for a single termerature measurement, will provide satisfactory water c uality protection because of the relationship between dissolved oxy l
gen and
(
organic waste assimilation and because the entire down river stretch wi l l be tron t tored.
74.
_No adverse Impact from releases from existino water storace in 1985 - In addition to the existing 59 F termerature constraint on Schuylkill River withdrawals for LGS, there is a minima t-n flow constraint of 530 cfs for one unit. This constraint operat es independently of the 590F temperature constraint Frecuently, the flow
, constraint will preclude withdrawals fran the Schuylkill River, regardless of the temperature constraint.
75.
During the drought of 1965, the flow constraint of 530 cf s
would have prohibited Schuylkill River withdrawals 167 days
, while the termerature constraint would have prohibited i
withdrawals for only an additional 29 days, a total of 196 days.
The historic record for the Schuylkill River, over 57 years, shows that en average
, withdrawals for one unit at LGS would have been prohibited by flow 52 days per y ear.
It can be seen therefore that for this period, the flow const raint would have been the limiting factor for rany days each year 76.
Suspension of the 59"F temperature constraint alone w'**
not provide a long-term source of makeup water for LG9. Availabi show, however, that a termorary suspension of that constraint w 1 permit Schuylklll River withdrawals for sane nurber of additi onal days.
PECO's analysis of available temperature and dissolved oxygen data shows that the proposed substitution will probably not provide
l significont benefits by yleiding a great nuter of additional da ys of Schuylkill water availability in drought periods, such as 1985 to date
~
and as anticipated for the remainder of the year.
77.
Accordingly, a correlation was conducted to detennine benefits in tenns of additional days of water availability f or years of Interest.
In 1968, a year in which ficw in the Schuylkill River dropped below 530 cfs on 55 days Can average year)
, terroerature and dissolved oxygen data were available 276 days.Considering this data, water could have been withdrawn 177 days or 64% of the tim e under the present flow and temperature constraints.
Substituting dissolved oxygen monitoring for the temperature would have perTnitted water withdrawals on 41 more days or 218 days total, 79% of the ye i
ar.
- 78. Dissolved oxygen data were unavailable for 19'65
~
, the drought year of. record, but 1966 had almost as many low ficw d ays and was therefore a good representative of severe drought conditions.
In 1966, data were available 326 days for a correlation Water could have been withdrawn 122 days or 37% of the time under present fi cw and temperature constraints.
Substituting dissolved oxygen monitoring would have perriltted withdrawals on 50 more days or a tot l a of 172 days, 53% of the year.
Only 20 of these days, however, would be in the months of June through Decerrter.
79.
Review of the recent drought years of 1980 and 1981 I di n cates that substituting dissolved oxygen rionitoring for t emperature constraints may not significantly increase the nunter of days w t a er could be withdrawn from toe Schuylkill River.
In 1980, data were available for a correlation on 296 days.
Of these, water could be
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withdrawn based on flow and temperature constraints on 153 d ays or 52%
of the time. Substituting DO monitoring would have Increased
a wtthdrawals by only four d;ys or 53% of the year.
Those four days were In the_nonths dune through Decenter.
80.
In 1981, data were available 287 days for a correlation Of these, water could be withdrawn based on flow and tenv erature constraints on 187 days or 65% of the time. Substituting 00 monit oring would have increased withdrawals by six days or 67% of the year. Five of those days were in the months June through Decenter 81.
Cooling water needs for Limerick during 1985 for the continuation of startup will reach an average of 22 cfs during th e
months of Septecter, October and Noverter.
By substitution DO monitoring for the temperature !!mitation, a reduction or savi
.l ng of about 44 acre-feet in the amount of water PECO would need from
' ~
supply storage would result for each additional day that Wate r can be withdrawn frcm 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 frcm storage.
82.
Recognizing that stream flow and dissolved oxygen t
constraints will prevent withdrawals at certain times, particularly i n a drought scenario for 1985, another source of makevo water will be ne j
cessary for the Interim period remaining in 1985.
During that short Interim period, releases will be reauested from existing wat er storage supplies.
83.
In view of the inventory of water supply storage faciliti es under DRBC control, the Blue Marsh Reservoir appears to be th e most probable source of such releases.
In authorizing construction of the Blue Marsh Reservoir, Congress designated 8 000 acre f for water supply needs.
- eet of storage 84
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The release of water supplies form the reservoir has undergone environmental review in two environmental statements pre by the U. S. Army Corps of Engineers ("COE").
In neither docunent did COE determine that there would be an adverse environmental impact frors the release of water from the water supply storage for the ben fit e
of water supply users.
To the contrary, COE found that the release of those waters would have a beneficial Irmact upon overall water cuality in that stretch of the Schuylkill River.
85.
PECO acknowledges that the long-term use of Blue Marsh for LGS would conflict with anticipated needs c.f pubile water suppli ers along the Schuylkill River.
Mcwever, PECO is merely recuesting releases from water supply storage on a temporary basis for 1985 Moreover, PECO is not reauesting releases form wate'r cuality
- storage, but only frcrn water supply storage.
86.
PECO recognizes that Blue Marsh Reservoir must be availabl i
e to assist in meeting the needs of dcwnstream users in a drought and that DRBC has authority to use the water supply storage of Blue M arsh 8
Reservoir to meet downstream wate cuality objectives Nonetheless, the termorary short-tenn use of Blue Marsh Reservoir should n t b o
e precluded, as two water suppliers have argued, sirmly because d rought conditions might require released frcm the water supply storage Under the " pooled water" concept, drought hardships must be shared on an equitable basis arnong all Basin users.
Ecultable demands upon other 1rmoundments (e.c., Beltzville) would be made to meet flow augment t a on needs for water supply and water cuality in a droucht.
87.
The COE Blue Marsh Lake Water control Manual (Final
(
at p. 7-13 that the 8,000 acre-feet of water supply storage in Blue l
Marsh Reservoir is equivalent to a continuous yleid of 55 cf s.
Of this
-s-t amount, 9 cfs is currently under contract with the Western Berks W r
Authority and an additional quantity is released pursuant t o the ORBC's authorization for the use of other existing downstream users The remaining arrount is therefore available to meet other " current wate r
supply needs" as determined by ORBC.
88.
Accordingly, the release of a maxirrun monthly average of 22 cfs for LGS for the short interim period requested by PECO will ha adverse effect upon other users or potential users along the Schuy River below Blue Marsh Reservoir.
Further, inastruch as PECO proposes merely to receive releases of water from an existing reservoir via facilities, structures, and mechanisms already In use, there will be no adverse impact to the environment.
89.
No adverse effect on recreational use of Blue Marsh'
- The release of water frcm Blue Marsh Reservoir in amounts required b y PECO would not adversely affect recreational use of the Reservoir The COE Blue Marsh Lake Water Control Manual (Final) states tha eservoir should be maintained at elevation 290 feet throughout the strrmer
~'
n s for the benefit of recreational use. The Manual states at p. 8-3 that the recreational facilities are usable form the top of the strrmer pool (elevation 290 feet) to a drawn down elevation of 283 fe t e.
90.
PECO analyzed several critical years to determine the possible effects of the drawdown resulting from PECO's request d e
releases.
In its analysis, PECO assmed one unit at full load operation at an average constrrotive use of 27 cfs throughout the peri o
of water unavailability from natural flows of the Schuylkill River until Septerriser 30, the end of the recreation season, and included th e
9 cfs under contract to the Western Berks Water Authority
, the full conservation release of 41 cfs, and 5 cfs as evaporation.
o-91.
For 1955, an average year for flow in the Schuylkill River PECO found that during the strrmer rmnths, the pool elevation would b e
drawn dcwn less than one foot.
92.
PECO analyzed the situation for 1980 because that year Schuylkill flows were 20 percent below average.
It was determined that drawdown frcrn the requested releases would have been about two feet j
PECO also simulated withdrawals for 1965 because 1965 represent s the worst year of record for Icw ficws in the Tulpehocken Creek and therefore the year of lowest supplies to the Reservoir PECO determined that its requested releases would ha/e resulted in a dra w
down at the end of the recreational season of approximately 4 5 fe t e.
93.
Thus, the requested releases of water for PECO and the
, resulting drawdown of,the Reservoir, under. worst case cond' it.lons, 'wo result in the Blue Marsh Reservoir water level 2.5 feet higher than the design drawn down elevation of 283 feet.
This margin of drawdown would remain available for other concurrent users of Blue Marsh w would have not detrimental effect on recreation.
V.
_ Conclusion 94.
In stm, grant of the requested temporary substitution of instream monitoring of dissolved oxygen levels for the 59 F temper t a ure constraint on withdrawals from the Schuylkill River and, as needed release of water frcm the Blue Marsh Reservoir or other Bas r
supply storage will permit scheduled operation of LGS.
There will be no adverse Irpacts from either the temporary suspension of the 59 F temperature constraint or the release of water from Basin sto rage.
Maintenance of water quality in the Schuylkill River below LGS will be
]
ensured by instream monitoring of dissolved oxygen levels and ceasingi
)
withdrawals of Schuylkill natural ficws when dissolved oxygen levels fall below acceptable levels.
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RECEIVED m E er seca m -
00CdEimG & SE6V!CI BRANCH MAY 31985 E, J. BRAD.L.EY Application by the Philadelphia Electric Company to temporarily revise Docket No. D-69-210 CP (Final) -
Limerick Generating Station Interested Parties Attached is a portion of the preliminary docket which summarizes the application by the Philadelphia Electric Company currently pending before the Delaware River Basin Commission (DRBC). This partial docket was prepared for the convenience of interested parties.
The complete application is available at DRBC's office and will be available at the public hearing on May 7, 1985.
An amended application was received on April 24, 1985, which requested that the application be considered for revision of the Comprehensive Plan as well as approval under Section 3.8 of the Delaware River Basin Compact and the amended application evaluated the benefits of the proposed substitution of the dissolved oxygen limitation for the temperature constraint for various drought years and an average year.
The draft docket dcms not include complete staff findings, nor does it propose any decision by the Commission. Additional information will be considered from the public record on this application.
Upon consideration of the testimony received at the public hearing on May 7 and written comments received by May 14, the Commission will make a decision on this application by the Philadelphia Electric Company.
Gerald M. Hansler
e Prelimintry Subject to Ravision 5/2/85 <
ib DOCKET NO. D-69-210 CP (FINAL)(REVISED)
DELAWARE RIVER BASIN COMMISSION Philadelphia Electric Company Limerick Electric Generating Station Limerick Township, Montgomery County, Pennsylvania PROCEEDINGS The Philadelphia Electric Company (PECO) applied, on March 21, 1985, for a temporary modification of Docket D-69-210 CP (Final). The application was amended with a submission o'f s'upplemental information on April 24, 1985.
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The application is being reviewed for temporary revision of the project in the Comprehensive Plan and approval of these temporary changes under Section 3.8 of the Delaware River Basin Compact. The Montgomery County Planning Commission has been notified of pending action on this docket. A public hearing on this application by PECO will be held by the DRBC on May 7, 1985.
DESCRIPTION l
Purpose.-- The purpose of this project is to obtain temporary relief, through December 31, 1985, from two existing docket limitations and thereby increase the frequency that water may be withdrawn from the Schuylkill River for evaporation at Limerick Unit No. 1.
The two existing limitations are:
(1) PECO may not withdraw water from the Schuylkill River for evaporative use at their Limerick Station when the temperature rises above 59 F and (2) water for evaporative use may r,t be withdrawn from the Schuylkill River when the flow at the Pottstown gage falls below 530 cfs (one Limerick unit in
4 D-69-210 CP (FINAL)(REVISED) 2 operation).- The applicant also has requested, as necessary, release of varying amounts of water not exceeding 32.5 cfs, from water supply storage; and that the flow constraint contained in said docket to be unapplicable to any such releases.
t Location.-- The only change in location of any project facilities is the proposed location of six dissolved oxygen monitors in lieu of the previously proposed temperature monitor at Pottstown.
The six dissolved oxygen monitors will be located in the pool area behind each of the six dans between the Limerick project site and Fairmount Dam.
The six dans and the location of each are as follows:
Fairmount Dam 92.47 - 8.49 Flat Rock Dam 92.47 - 15.6 Plymouth Dam 92.47 - 20.7 Norristown Dam 92.47 - 23.95 Black Rock Dam 92.47 - 36.6 Vincent Dam 92.47 - 44.7 A seventh dissolved oxygen monitoring station presently exists at the Limerick site and PECO will continue to sample at this location.
)
No changes are proposed in the location of any of the intake or dis-charge facilities as described in Docket.D-69-210 CP (Final).
Physical features.
a.
Design criteria.-- The proposed substitution of dissolved oxygen limitations of an average of 5.0 mg/l and 4.0 mg/l instantaneous in lieu of the current temperature limitation (59 F) is requested so as to reduce the-number of days that PECO would be required to replace their evaporative losses from other sources.
=
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.r-
1 D-69-210 CP (FINAL)(REUISED) 3
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The applicant has estimated that the number of days it would be permitted to evaporate Schuylkill River water by substituting the dissolved oxygen limitations for the temperature criteria could increase by 20 days during a drought year like 1966 or 41 days during an average year like 1968.
However, review of the recent drought years of 1980 and 1981 indicates that the substi:ution of dissolved oxygen monitoring for temperature constraints would have added only four days between June and December in 1980 and five days between June and December in 1981 when the Schuylkill River could have been used.
The request for the Delaware River Basin Commission (DRBC) to release water from storage, whenever the proposed dissolved oxygen limita-tions or current flow limitations would require PECO to replace all evapora-tive losses, is designed to allow PECO to start and complete the testing of the Limerick I f acility prior to having. a. permanent' alternative water supply -
available. The applicant has requested that the releases be made from the Blue Marsh Reservoir, or other basin water supply storages.
The proposed dissolved oxygen monitoring will include water sampl-ing at least six times per day at regular intervals. The location of the dissolved oxygen monitors will be in the pool area upstream of each dam where the minimum level of dissolved oxygen should occur and the specific location of each monitor will be based on accessibility, availability of power and protection from vandalism. The probe will be positioned below the midpoint of the water column to avoid surface effects.
The quantity of water that may be needed, if permitted to operate in accordance with this application will vary with the testing schedule to gradually ascend to full power. During the first two months, the unit would operate at increasing levels up to 50 percent of power.
During the third month, it would increase to 75 percent of full power and then during the next two months, it should increase to full power with the overall test program of about six months.
D-69-210 CP (FINAL)(REVISED) 4 b.
Facilities.-- All existing facilities of the Limerick Electric Generating Project remain as approved by Docket D-69-210 CP (Final) and the only new facilities required by this application for revision is the addition of the dissolved oxygen monitors.
The requested release of water from existing storage could include existing storage and release facilities, and would not involve any new construction.
Cost.-- The overall cost of the proposed dissolved oxygen monitors is estimated to be $95,000.
Relationship to the Comprehensive Plan.-- The applicant is requesting revision of the Limerick Generating Station Project as included in the Com-prehensive Plan by Docket D-69-210 CP (Final).
The ap'plicant has also requested that water be. released from storage regulated by the Commission whenever docket constraints would otherwise pro-hibit the evaporative use at the Limerick Generating Station. The only storage presently owned and regulated by DRBC in the Schuylkill Basin is storage in Blue Marsh Reservoir. The DRBC Comprehensive Plan provisions governing the use of Blue Marsh Reservoir are included in DRBC Resolution No.
84-7, adopted on April 25, 1984, and also included in Article 2 of the Com-mission's Water Code of the Delaware River Basin; Section 2.5.5. Coordinated Operation of Lower Basin and Hydroelectric Reservoirs During a Basinwide Drought.
n
D-69-210 CP (FINAL)(REVISED) 5 i
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FINDINGS The Limerick Generating Station was included in the Comprehensive Plan by Docket decision D-69-210 CP (Final) on November 5,1975, which also incor-porated the project description and docket decision D-69-210 CP dated March 29, 1973.
Docket D-69-210 CP (5/29/73) includes a section headed
" FINDINGS" subheading " Source of Water Supply
- 1. Schuylkill River" which reads as follows:
"Schuylkill River water at the plant site may be used for noncon-sumptive use whenever the effluent discharged back to the river meets all applicable water quality standards.
"Schuylkill River water at the plant may be used for consumptive use when flow (not including future augmentations of flow from Commission-sponsore'd'pr'ojects) as measured at the Pot'ts' own gage t
is in' excess of 530 cfs (342 mgd) with one unit in operation and 560 cfs (362 mgd) with two units in operation with the'following exceptions:
"(a) There shall be no withdrawals when river water tempera-tures below the Limerick station are above 15 C except during April, May and June when the flow as measured at the Pottstown gage is in excess of 1791 cfs (1158 mgd).
"(b) Use of the Schuylkill River will be limited to a with-drawal that will result in an effluent that meets all applicable water quality standards.
_ - - = _ _ _.
D-69-210 CP (FINAL)(REVISED) 6 "The constraints on nonconsumptive use of Schuylkill River water are necessary to prevent violation of total dissolved solids, strema quality objectives and effluent quality requirements of the Commission's water quality regulations. The constraint on consumptive use of Schuylkill River water is to protect water quantity and water quality below the Limerick Station. Both sets of constraints would be suspended in the event of any operational emergency requiring a shutdown of the plant."
Pertinent provisions of DRBC Resolution No. 84-7 are as follows:
"During ' drought" conditions as defined by Figure 1 in Section 2.5.3A, the Francis E. Walter, Prompton, Beltzville, Blue Marsh, a
Nockamixon, Lake Wallenpaupack and Mongaup hydroelectric reser-will be utilized to complement the drought management operations of. the New York City reservoirs.
"While it is clearly understood that the water supply storage at Beltzville and Blue Marsh reservoirs is to be used for water supply and to control salinity intrusion into the Delaware 1
estuary during low flow periods, it is also recognized that extensive recreational development is established on these lakes, which should be protected to the extent possible. Accordingly, I
the operation plans for both of these reservoirs, as well as Nockamixon, in drought emergencies have recognized these multiple uses,:with water supply having precedence."
Additional findings will be considered by the Commission after con-sideration of the record compiled at the Public Hearing of May 7,1985.
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