ML20126J871
| ML20126J871 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/10/1985 |
| From: | Conner T CONNER & WETTERHAHN |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| CON-#285-333 NUDOCS 8506100721 | |
| Download: ML20126J871 (15) | |
Text
i)Y CQQggs 1 law OFFICES CONNER & WETTERHAHN. P.C.
17 4 7 P E N N S Y LVA NI A AV E N U E. N. W.
TEOY B. CONNEE,Ja. WASIIINGTON. D. C. 20000 MARK J. w3TTERMAHN nomanT w. manna DoVOLAS E. OLSON drsarcA H,gavsmTV was.=3 xicnor.= June 10, 1985
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- E$55"n1="xIoYSIcnnourra 00LKETEr:
- ""*** USNRC e,,t,,,,,,,,,,,,,u, 16 JUN 10 A10:45 0FFICE 0; St.CRt v 00CKETING a SERViu Mr. Samuel J. Chilk BRANCH Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter of Philadelphia Electric Company (Limerick Generating Station, Unit 1)
Docket No. 50-3520L *
Dear Mr. Chilk:
Enclosed is another copy of a Notice of Commission Action transmitted by my letter of June 6, 1985. Some copies of the enclosure may have been incorrectly reproduced.
Sincerely
[jTroyB. Conner,Jr.
O Counsel for the Applicant TBC/dlf Enclosure cc Service List K 2 60 3
)
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g k9TEg DELAWARE RIVER BASIN COMMISSION 04ESgYO P. O. BOX 7360 e WEST TRENTON, N. J. 08628 80CKETED UStiRC Project Review
'85 JUN 10 As):j5 NOTICE OF COMMISSION ACTION 9"'""
h[6-3-85~
D'acii Docket NoD 210 CP (Final)(Revis Project Sponsor: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101
,, Project
Description:
Temporary Modification Referred by:
Action by Commission:
Included in the Commission's Comprehensive Plan for the Delaware River Basin and approved pursuant to Section 3.8 of the Delaware River Basin Compact. See attached docket for terms and conditions.
Explanatory Note:
This action has been taken by the Commission in accor-dance with its responsibilities under Sections 3.8. 11.1 and 11.2 of the Delaware River Basin Compact. The Conaission maintains a comprehensive water resources plan for the Delaware River Basin and reviews water resources projects proposed by other public and private agencies. Review of projects enables the Commission to prevent conflicts among water users and to protect the integrity of the Comprehen.tve Plan.
YM 5- l Susan M. Weisman, Secretary enc.
cc:_ R. Timothy Weston; All interested parties CP/3.8
t DOCERT NO. D-69-210 CF (FINAL)(REVISED)
DELAWARE RIVER BASIN ColetISSION Philadelphia Electric Company Limerick Electric Generating Station Liasrick 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 of supplemental information on April 24, 1985.
The application was 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. A public hearing on this applica-tien by PECO was held by the DEBC on May 7, 1985. The hearing record .
- remained open until 5.:00 p.m. May 14.1985.' ' Sixty-oes comments were received.
- and entered into'th's hearing record on'this application. ,
DESCRIPTION Purpose.- The purpose of this application 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 Schugkill River for evapgrative use at their Limerick Station when the temperature rises above 59 F and (2) water for evaporative use may not be withdrawn from the Schuylkill River when the flow at the Pottstown gage (not augasated by releases from Commission sponsored reservoir storage) falls below 530 efs for one Limerick unit in operation. They requested temporary substitution of DO monitoring in place of temperature restriction in original docket. The applicant also has requested, as necessary, release of varying amounts of water not exceeding 32.5 efs, from water supply storage; and that the con-straint contained in said docket, excluding consideration of releases from Commission-sponsored storage in counting flow at Pottstown, to be inappli-cable to any such releases.
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.
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4 1i D-69-210 CP (FINAL)(REVISED) 2 The six dissolved oxygen monitors will be located in the pool area behind each of the six dans batween the Limerick project site and Fairmount i Dam. The six dans and the location of each are as follows:
Fairmount Das 92.47 - 8.49 Flat Rock Das 92.47 - 15.6 Plymouth Den 92.47 - 20.7 Norristown Dam 92.47 - 23.95 Black Rock Das 92.47 - 36.6 Vincent Das 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 applicant, proposes substitution .of dissolved oxygen, limitations of'a' daily average of 5.0'ag l /and0 4.~0 mg/1 instantaneous in lieu of the current tem'perature limitation (59 F) in order to reduce the number of days that PECO would be required to replace evaporative losses' at l the Limerick Unit I.
i The proposed dissolved oxygen monitoring vill include water sampl-l ing at least six times per day at regular intervals. The location of the j dissolved oxygen monitors will be in the pool area upstream of each das 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 applicant has also requested to release water from storage, l
whenever the proposed dissolved oxygen limitations or current flow limita-tions would require PECO to replace all evaporative losses. Both of these assadments are proposed in order to allow PECO to start and complete the testing of the Limerick I facility prior to having a permanent alternative water supply available.
The quantity of water that will be needed to operate Limerick will vary with the testing schedule as the plant gradually ascends to full power.
l Following approval of the full power license, PECO would intend to build up to full power over a period of five months. The range of operations expected over this period is as follows:
Months 1-2 June-July 10-50% of full power 10 cfs Month 3 August 50-75% of full power 17 cfs Months 4-7 September- 75-100% of full power 22 cfs-average December 27 cfs-peak l
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D-69-210 CP (FINAL)(REVISED) 3
- b. Pac 111 ties.- All existing facilities of the Limerick Electric Generating Project remain as approved by Docket D-69-210 CP (Pinal) 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 3s estimated to be 495,000.
Reistionship to the Comprehensive Plan. - The applicant is requesting revision of the Limerick Generating Station Project as included in the Coa-prehensive Plan by Docket D-69-210 CP (Pinal).
The applicant 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,ComprehensivecFlan provisions .
governing else use of' Blue Marsh Reservoir are included in DRSC Resolution No.
84-7, s/Apted on April 25, 1984', and also included in Article 2 of the Coa -
mission's Water Code of the Delaware River Basin; Section 2.5.5. Coordinated Operation of Lower Basin and Hydroelectric Reservoirs During a Basinvide Drought.
FINDINGS The Limerick Generating Station was included in the Comprehensive Plan i by Docket decision D-69-210 CP (Pinal) 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 l reads as follows:
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"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 say be used for consumptive use when flow (not including future augmentations of flow from Commission-eponsored projects) as measured at the Pottstown gage is in excess of 530 cfs (342 agd) with one unit in operation and 560 cfs (362 agd) with two units in operation with the following exceptions:
1 D-69-210 CP (FINAL)(REVISED)
"(a) There shall be no withdrawals when river wateg 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 agd).
"(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.
"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."
DRBC Resolution No. 84-7 (Basin Water Code, Section 2.5.5) incorporates i into the Comprehensive Plan provisions governing the operation of major basin l reservoirs during periods of drought. Pertinent provisions include:~
"During ' drought" conditions as defined by Figure 1 in Section' 2.5.3A, the Francis E. Walter, Prompton, Beltsville, Blue Marsh, Nockamixon, Lake Wallenpaupack and Mongaup hydroelectric reser-voirs 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 Beltaville and Blue Marsh reservoirs is to be used for water supply and to control salinity intrusion into the Delaware 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, the operation plans for both of these reservoirs, as well as l Nockamixon, in drought emergencies have recognized these multiple uses, with water supply having precedence."
Substitution of DO monitoring for the existing temperature constraint would provide only marginal additional water availability for testing at the Limerick Unit I facility.
The applicant has estimated that the impact of substituting the proposed dissolved oxygen limitations for che temperature constraint during various hydrologic conditions would be as follows. -
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Under a repeat of the drought year 1966, water could only have been withdrawn for 122 days under present constraints of flow and ten-perature. Substituting a DO standard for temperature would have permitted withdrawals 50 more days. However, only 2C[ more of those days would have been in the months of June through December (the period of the Limerick testing program).
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- D-69-210 CP (FINAL)(REVISED) 5
- In a repeat of drought year 1940, substitution of a D0 standard would have permitted Limerick withdrawals only 4, additional days.
- In 1981, use of D0 standard in place of temperature limitation would have allowed Limerick to use Schuylkill water only ~5 more days between June and December.
- In 1968 (a normal year), water would have been available for Limerick on 177 days under present temperature and flow con-straints. Substitution of a D0 standard for temperature wou1C have allowed water withdrawals 41 more days.
The beneficial impacts to PECO of substituting DO conditions for the current temperature restriction during the proposed testing program is uncer '
tain. In its amended application, PECO states:
"In conclusion, the effect of the removal of the temperature restriction is uncertain at best, particularly during a drought year; and it is clear that supplemental water from storase. is ,
i essentia1IN7e ertheless, the 'temperettare limitation ~ shouldTe
, lif ted for 1985 and the D0 monitoring approa'ch adopted because it appears likely that at least a few days would be 'saerd" in 1985 with the corresponding reduction in need for water from storage."
(emphasis added)
On the other hand, during the course of the DRBC hearing, Vincent S.
Boyer (PECO Senior Vice President - Nuclear Power) testified that if the D0 standards were triggered, plant operations could be suspended rapidly by tripping the reac:or shutdown, but reductions "under a controlled manner" would take a matter of 8-10 hours. If DO conditions improved, it would take 10 to 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> to bring the plant back to the power levels prior to shutdown, in order to allow the continuation of the testing program.
Mr. Boyer further testified that the test program could be interrupted under certain cocditions. The test regimen does not require PECO to operate Limerick a certain number of days at a continuous level. Certain tests need to be run for a period of time to obtain power calibration data and other information, "but these are generally fairly short number of hours," and the
" test program can be interrupted or adjusted to accoanodate the water requirements."
Exhibits introduced into the hearing record by the DRBC General Copsel.
David Goldberg, (DRBC-1 and DEBC -2) addressed the rationale for the 59 C trigger regeriction. In those exhibits, it is pointed out that DESC's reason for the 59 C limitation relates to protection of an acceptable dissolved oxygen standard; and further, that higher water temperatures increase the biological demand rate which in turn reduces the dissolved oxygen concentration.
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D-69-210 CP (FINAL)(REVISED)
Several issues were raised in the DEBC hearings regarding the adequacy and accuracy of the DO monitoring program proposed by PECO.
Location and Specification of, Monitoring: PECO has proposed to install i
automatic recording monitors for D0 to sample oxygen levelt in "mid-depth" above each of the 6 dams. To date, however, PECO has not identified the precise locations of the proposed monitors, or specifications of the equip-ment. PECO initiated inquiries regarding the availability of monitors and installation requirements. The proposed monitors would utilise a radio signal to transait date to the Limerick operations center; thus, power sepply and telephone connections are not deemed critical. PECO has been asked to provide additional specifications regarding the proposed monitors, including information showing how it intends to obtain access for installation of the facilities.
Installation of the DO monitors will require some time to complete. In the interia, PECO proposes to monitor DO in the 6 pools manually six times per day. This daily monitoring regime is required to track the diurnal changes of DO in the river water.
The Pennsylvania Fish Consission has stated that it could. approve the-substitution of the DO monitoring for the temperature 'restric'tions upon" certain' conditions. Among other requirements, the Fish Commission has recommended that:
"An accurate recording D.O. meter must be installed absve and within 200 feet of each dan located below the Limerick intake on the Schuylkill River. These must be connected to the control
- center at the Limerick plant and must be properly maintained to
( insure the meters' accuracy."
Accuracy of, Monitors: PECO has proposed to use automatic telemetered DO monitors located in the pools above the Schuylkill River dans below Limerick.
Proper operation of such monitors requires careful calibration and checking.
Data recovery with automatic telemetered monitors is approximately 95 percent according to the U. S. Geolor.d cal Survey (USGS). With multiple monitors, as proposed by PECO, more reliability would be built into the monitoring system.
Company v., Independent Monitoring: PECO's application contemplates operation of the monitoring network by the Company. Witnesses at the DRBC hearing criticised this proposal as a " conflict of interest" in letting the
" fox guard the chicken coop." The monitoring program would be less subject l to criticism if undertaken by an independent agency, for example, the USGS.
USGS has broad experience with similar monitoring schemes. PECO could con-tract with USGS for such services, through a qualified public " cooperator,"
such as DEBC or PADER. The DRBC presently contracts with the USGS to perform monitoring functions elsewhere in the Delaware Basin.
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s D-69-210 CP (FINAL)(REVISED) 7 In comparison to temperature, which is relatively stable and easy to esasure, D0 in river water varies over the day by a fairly wide range. Such variability creates difficulties in setting appropriate trigger criteria, and adjusting power plant operations and water withdrawals on the basis of such changing conditions.
l PECO has formally proposed that withdrawal by Limerick for consumptive l use be allowed when Pennsylvania water quality standards for DO are not violated. The applicable standards set forth in 25 Pennsylvania Code Chapter 93 are 5.0 ag/l minimum daily average and 4.0 mg/l minimum instantaneous _
value. In testimony, however, PECO representatives stated that if the -
Company saw that DO was " trending towards" the 5 mg/l or 4 ag/l standards, it would seek a release of water from Blue Marsh. The Company "could pick a value" above the 4 or 5 mg/l levels as a trigger point to request a release, but would "need some experience" to identify such a trigger to protect the D0 standards. The lack of such specificity in the proposal askes even more troublesome the concept of allowing PECO to self-monitor DO and adjust plant.
operations as it judges appropriate.
Choice o_f,DO Standard: PECO has proposed to base Limerick operations on Pennsylvania's water quality standards for the Schuylkill. Other witnesses, however, suggested that more restrictive standards may be appropriate to
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protect fish and aquatic life in the. River. -
Philadelphia Suburban Water Company (PSWC) noted that "high temperature stress increases the sensitivity of aquatic organisms to disease and tosia pollutants, making the attainment of proper dissolved oxygen criteria par-ticularly important." PSWC recommended the trigger criteria be set according to the National Water Quality Criteria for Dissolved Oxygen. Specifically, the vara water criteria for early life stages is 6.0 mg/l seven day mean and 5.0 mg/l daily concentration. Adoption of such criteria would further reduce the number of days in which Limerick could take water from the Schuylkill without compensation; although a precise calculation of the effect of this l revised standard is not available.
Recognizing the special seasonal needs of aquatic life, the Pennsylvania Fish Commission has recommended a two-tiered D0 standard for Limerick opera-tions. The Fish Commission proposes that:
"From March 1 to June 15 no water to be withdrawn by Limerick if D.O. values fall below 7 ppa. This is the spawning period for the game species found in the Schuylkill River, and 6-8 ppa of D.O. are necessary to insure successful spawning and incubation for most game species. Flows are usually high enough during this time period so that this D.O. level can be maintained."
"For the remainder of the year the State standards of an average of 5 ppa with no value below 4 ppa would be acceptable providing the lowest readings taken at any of the dans below Limerick are used to determine if the State standards are being met."
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! D-69-210 CP (FINAL)(REVISED) 8 l
Because D0 varies over the day, and a number of hours are required to l shut down power plant operations if the DO criteria are triggered, it is necessary to establish a buffer or " margin of safety" somewhat above Pennsyl-l vania or Federal water quality standards in order to assure that DO levels l will not be violated during actual operations.
f Use o_f Blue Marsh Reservoir: To complement the D0 proposal, PECO has requested that DESC provide or authorise the release of water from upstresa storage in the Schuylkill River watershed, to compensate for Limerick use on days when either D0 or flow constraints are triggered. The only availa5&e storage operated by the DRBC in the watershed is Blue Marsh Reservoir (Berks l County). For the period of the testing program, PECO would utilise up to 32.5 cfs of releases daily for Limerick operations. The average consumptive use makeup requirements during the later part of the testing program (September-December) would average 22 cis.
Blue Marsh Reservoir located on the Tulpehocken Creek near Reading is a multi-purpose reservoir, constructed and operated by the U. S. Army Corps of Engineers. As currently authorized and operated Blue Marsh contains several storage elements, including: (1) 3000 acre-feet of inactive storage (primar-ily used for sediment storage);-(2) 8000 acre-feet'.(4035 cis-days) of. water supply st.orage; (3) 660C ac're-feet (3333 cis-days) of water'qVality/ low-
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augmentation storage; and (4) 32,400 acre-feet of flood control storage.
Within the 32,400 acre-feet of flood control storage, the Corps has adopted the operational practice of raising pool elevations on a seasonal basis by 5 feet, to elevation 290 feet a.s.1. for enhanced recreation benefits. This summer augmented pool, which is provided from April 16 to September 30, in essence borrows 5,274 acre-feet of storage from the normally empty flood control capacity.
According to analyses conducted by PADER and DRBC, Limeri;k withdrawals from the Schuylkill River during a period of drought, such as 1965, if com-pensated out of Blue Marsh, would consume more than 5000 cis-days of storage at full power operations. In a repeat of 1980-81, Limerick Unit I would have consumed 4424 cfs-days of storage in Blue Marsh.
During the testing period, the quantity of water consumed by Limerick would be somewhat below average use as the plant builds up to full power.
Under to regime proposed by PECO, Limerick would likely require the following quantities of water over the testing period (assuming commencement of opera-tions on June 1):
June-July 610 cis-days August 527 cis-days September 660 cis-days October 681 cis-days November 660 cis-days December 681 efs-days 3802 cis-days
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D-69-210 CP (FINAL)(REVISED) 9 Over this 214 day period, assuming continuing drought conditions now being experienced in the Delaware Basin, it is probable that flows on the Schuylkill River during the suaner and fall will drop below the 530 cfs trigger for a majority of the time. (In April 1985, the flow on the Schuyl-kill dropped below 530 cfs at one of the earliest times on record, and month-ly flows set all time new low records - nearly one-third below those experi-enced during the record drought of 1964-65.) Thus, consumptive use askeup !
demands upon Blue Marsh of 3000 cis-days or more might be anticipated if the PECO proposal were approved. This quantity would represent 41 percent of the combined water supply and water quality storage in Blue Marsh. -
PECO estimates of consumptive use needs for Limerick in 1985 are some- )
what lower. PECO projects a use of 1.5 billion gallons (2322 cis-days) by ;
the end of_ october. This would represent 32 percent of the water supply and water quality storage in Blue Marsh. Additional water, of course, would be required to continue operations in November and December.
Under the Basin Comprehensive Plan provisions relating to " Coordinated Operation of Iower Basin and Hydroelectric Reservoirs During Basinvide Drought," Water Code of the Delaware River Basin, Section 2.5.5 (DRBC Reso-lution No. 84-7), the combined storage of Beltsville, Blue Marsh .and Nocka .
. mixon Reservoirs is dedicated.co. pro' vision of releases to augment river fltus-
- for salinity control in tho' Delaware Estuary during periods cf basin droughti emergency. Operating models developed by DRBC indicate that during a repeat of the drought of record, all of the storage in these three lower bas?a reservoirs, as well as the New York City reservoirs, wculd be depleted to meet the requirements of the drought management plan.
In the DRBC Exhibit #4 entered into the hearing record by Mr. Goldberg, the "DRBC Staff Issues and Response Document; March-April 1984 Public Hear-ing on Proposed Amendment to DRSC Comprehensive Plan Relating to Reservoir Management During Basinvide Drought" dealt with the adverse impacts of evaporating Blue Marsh releases at Limerick:
"Use of releases from storage in the Blue Marsh Project for consumptive use at the Limerick plant would deprive the entire lower Schuylkill River from Limerick to Fairmount Dam of the water quantity and quality benefits which Blue Marsh storage was intended to provide.
"Within this reach of the Schuylkill River from the Limerick plant to Fairmount Das are eleven water supply withdrawal users, who withdrew 380 agd in 1982. In this same reach, as of 1982, 28 treated waste discharges contributed 70 agd in wastes requiring assimilation and 8,450 lbs./ day BOD5 *"
At any time, the DEBC may call on releases from Blue Marsh Reservoir to enhance poor water quality in the Schuylkill River. If a portion of such releases are evaporated off at Limerick, then their diluting effect will be lost to downstream users.
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D-69-210 CP (FINAL)(REVISED) 10 j
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on Monday, May 13, 1985, the DRBC formally declared a drought emergency for the entire Delaware River Basin. This action followed separate emergency
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declarations by the Governors of New Jersey and PennsyJvania, and the Mayor
! of New York City.
l Precipitation deficits from August 1984 to the end of April 1985 above l
Trenton have totalled over 12.9 inches below normal. Nine month precipita-tion totals over most of the Basin were the worst evidenced in over 80 years of record. Streamflows in the Delaware, Lehigh, and Schuylkill Rivers have been less than one-half of normal. Since February, river flows have been significantly under flows recorded for the same period during the record drought of 1964-65; and streamflows throughout the Basin set new records for i the month of April. Currently, combined storage in the three New York City reservoirs, which should be full, is only 61 percent of capacity. Releases from City Reservoirs to meet Montague flow requirements of 1550 cfs were triggered during the week of May 13-17, auch earlier than would be expected.
I Ground water levels in Basin monitoring wells evidence severe drought stress,
! with levels in many cases within the lowest 10-15 percentile of record. (For l example, 4 of 6 monitoring wells in Bucks County set new record lows for April.)
Pursuant to the Co' amiss' ion's drought emergency declaratiion, DRBC ptcimul'-
gat'ed a series of Conservation Orders invoking the provisions of Water Code 2.5.5 (DRBC Resolution No. 84-7), and placiag the storage in the Blue Marsh, Beltsville, Nockamixon, Wallenpaupack and Mongsup Reservoirs under Cosmission direction for coordinated operation to meet streamflow and salinity control obj ectives.
The Lower Basin Reservoirs currently have around 30.7 billion gallons of storage to meet drought needs this suaner and fall. This storage includes 13 BG in Nockamixon, 13 BG in Beltsville, and 4.7 BG in Blue Marsh. DRBC modsis indicate that under the drought operations plan (with no allocation of water to Limerick), in a repeat of the drought conditions of 1965, recreation would be sacrificed at Blue Marsh around August 9 and the reservoir would be emp-tied by approximately September 10. Evidence presented at the DEBC hearings indicates that 1985 is proceeding ahead of conditions experier id in 1965, by nearly 3 weeks. ,
The proposal presented by PECO to allocate water f rom Blue Marsh during 1985 is clearly inconsistent with the provisions of the DRBC Comprehensive Plan relating to drought operations, and would tend to further exacerbate the drought stresses and drawdowns on Blue Marsh and other Basin reservoirs.
In its application, PECO " recognizes that Blue Marsh must be available i
to assist in meeting the needs of downstream users in a drought and that DEBC has authority to utilize the water supply storage of Blue Marsh to meet downstream water quality objectives." Nevertheless, PECO argues:
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D-69-210 CP (FINAL)(REVISED) 1g i
l "[T]he temporary short-term use of Blue Marsh should not be 4
precluded simply because drought conditions might arise which j require releases from the water supply storage. Under the l ' pooled water" concept, drougat hardships must be shared equit- )
ably among all Basin users. Equitable demand upon all impound- I asats would be made en meet flow augmentation needs for water j supply and water quality in a drought period."
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I PECO's argument appears to miss the critical point. Major basin waiter atorage is being marshalled under the DRBC drought operations plan to meet
] essential water supply and salinity control needs. Experience and model i simulations show that all of this storage may well be exhausted just to meet l the requirements of the operating plan in protecting Estuary public water 4
supplies and other existing users.
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Moreover, the applicant is seeking the approval to operate under drought-conditions when existing docket conditions could preclude the operation even if the Delsware diversion into the Perkiomen Creek project was fully opera-tional and the flow of the Delaware at Trenton was less than 3000 efs.
. , PECO's propos,al .which'.would allocate substantial huantities. of wateir;
. for just one user, would place an additional draf t on already stressed i
resources, and tend to exhaust limited storage even earlier under these <
drought conditions. The result would be to place downstress water users, including those reliant on the Camden and Philadelphia water supply systems,
! at substantially increased risk.
The DRBC Comprehensive Plan policy on priorities of water use during drought emergencies give first priority to those uses which sustain human
- Life, health and safety (Water Code, Delaware River Basin, Section 2.5.2).
l l Summary The objective of the 59* temperature limitation contained in the origi-nel docket decision, was to prevent the Limerick project from aggravating dissolved oxygen conditions in the Schuylkill River during critical periods.
The temporary substitution of direct dissolved oxygen monitoring at each critical downstream location is consistent with that objective. In addition, the dissolved oxygen monitors will provide data, not otherwise available to ,
the water resource agencies, for better management of the Schuylkill River.
l The temporary use of water from Blue Marsh Reservoir for evaporation at l Limerick Generating Station conflicts with the Comprehensive Plan as cited above. Understanding the application is for the remaining portion of 1985, DRBC has considered the application presently before it and recognises the a
seriousness of the current drought emergency already declared by DRBC and j Pennsylvania in asking these decisions.
s D-69-210 CP (FIE)(REVISED) 12 DECISIONS I. The Comprehensive Plan of the DESC as amended by Docket D-69-210 CP (Final) on November 5,1975, is hereby revised as follows:
(1) For the period ending December 31, 1985, the provisions of Docket D-69-210 CP, [ attached and included as part thereof to D.-69-210 CP (Final)] headed " FINDINGS", " Sources of Water Supply", "1. Schuylkill River" paragraph "(a)" on page 5 pre temporarily suspended, and in place thereof the following provision is substituted:
"(a) No withdrawals for consumptive use shall be ande from the Schuylkill River or the natural flow of any of its tribu-taries whenever dissolved oxygen in the Schuylkill River at or below Limerick as measured at any one or more of the monitoring locations: (1) is less than 7.0 mg/l instantaneous during the period March 1 to June 15. or (ii) is equal to or less than 5.1 ag/l daily average or
. equal to or less than 4.2 ag/l instantaneous value during
-the remainder of~the year."
l (2) For the period ending December 31, 1985, the following condi-tions shall be added to the provisions of Docket D-69-210 CP (Final), "DECIS W on page 15, subheaded "II.":
"o. An accurate recording dissolved oxygen monitor shall be installed above and within 200 feet of each dan on the Schuylkill River located below the Limerick intake.
"p. Detailed plans of the location of each dissolved oxygen monitor and the equipment specifications shall be sub-mitted to and approved by the Executive Director prior to installation.
"q. The installation, calibration, maintenance and operation of all dissolved oxygen monitors and any interim manual measurements of dissolved oxygen shall be under the supervision and control of the U.S. Geological Survey.
"r. Weekly records of all dissolved oxygen monitoring shall be submitted to the Commission in writing within three working days, together with a log of power plant opera-
+ tions and consumptive water'use. Such information shall be a matter of public record.
"s. PECO shall immediately notify the Commission whenever dissolved oxygen levels at any monitoring station trigger the criteria set forth in this docket, and advise the Commission of steps taken to terminate powar plant operations."
D-69-210 CP (FINAL)(REVISED) 13 (3) The provisions set forth in paragraphs (1) and (2) above shall terminate on December 31, 1985, unless otherwise extended or directed by the Commission, and all prior provisions of Docket D-69-210 CP temporarily suspended by this docket shall become operative in full force and effect.
II. The above revisions of the Limerick Nuclear Generating Station project are approved pursuant to Section 3.8 of the Compact, subject to the conditons listed above.
III. The request that DEBC release water from storage at Blue Marsh' Reservoir or other facilities whenever dissolved oxygen limitations or flow limitations would require PECO to replace all evaporative losses at the Limerick Nuclear Generating Station is hereby denied.
BY THE CONNISSION DATED: May 29, 1985 l
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