ML20127C616
| ML20127C616 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/19/1985 |
| From: | Martin R Office of Nuclear Reactor Regulation |
| To: | Harold Denton, Edison G, Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20126G559 | List:
|
| References | |
| FOIA-85-103 NUDOCS 8504030421 | |
| Download: ML20127C616 (1) | |
Text
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jf[ A UNITED STATES
,y ; NUCLEAR REGULATORY COMMISSION
- 3. E j WASHINGTON, D. C. 20555
/ MAR 1 9 1985 MEMORANDUM FOR: H. Denton, NRR D. Eisenhut, NRR G. Edison, TOSB, NRR H. Thompson, DL F. Miraglia, DL T. Novak, DL W. Russell, Acting Director, DHFS J. Knight, Acting Director, DE R. Bernero, DSI
, T. Speis, DST B. Snyder, TMIPO, NRR G. Holahan, ORAB G. Lainas, DL D. Crutchfield, DL THRU: A. Schwencer, Branch Chief Licensing Branch No. 2 ,,,
Division of Licensing FROM: Robert Martin, Project Manager Licensing Branch No. 2 Division of Licensing
SUBJECT:
DAILY HIGHLIGHT l Limerick l
l On March 18, 1985 the licensee orally informed the staff that they were l
about to make an application to the Delaware River Basin Comission (DRBC) for an interim allocation of cooling water to supplement that available from the Schuylkill River for the remainder of 1985. The licensee made no estimation of when a decision of DRBC on the application would be reached.
1 ff), b 't Robert Martin, Project Manager Licensing Branch No. 2 Division of Licensing i
)
2-y-
kg UNITED STATES
- ; ) e (3 NUCLEAR REGULATORY COMMISSION ti .; h
- . y WASHINGTON, D. C. 20555
, 'f,, / MAR 1 g ,gg5 MEMORANDUM FOR: H. Denton, NRR D. Eisenhut, NRR G. Edison, TOSB, NRR ,
H. Thompson, DL '
F. Miraglia, DL T. Novak, DL t W. Russell, Acting Director, DHFS J. Knight, Acting Director, DE R. Bernero, DSI
, T. Speis, DST l 8. Snyder, TMIPO, NRR G. Holahan, ORAB G. Lainas, DL D. Crutchfield, DL THRU:
A. Schwencer, Licensing Branch No. Branch 2 Chief ((
Division of Licensing FROM: Robert Martin, Project Manager Licensing Branch No. 2 Division of Licensing
SUBJECT:
DAILY HIGHLIGHT Limerick On March 18, 1985 the licensee orally informed the staff that they were about to make an application to the Delaware River Basin Commission (DRBC) for an interim allocation of cooling water to supplement that available from the Schuylkill River for the remainder of 1985. The licensee made no estimation of when a decision of DRBC on the application would be reached.
')(L A Robe t Martin, Project Manager Licensing Branch No. 2 Division of Licensing 0
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, 1 LAW OFFICES CONNER & .WETTERHAHN. P.C.
17 47 P EN N S Y LVA N I A AV E N U E N. w.
Taoy 3. coNwsn,Ja. WASHINGTON D. C. 20006 MACE J. WETTERMAMN noOrar M.nADEs Dourr.As E.oLsoN JCOCECA W.LAVERTT NILS N. NICNOLs L3033 833 3500 R0 1 37 N.PCEL l
- o**. Y. E ' " ' * * " "'" March 19 i 1985 C ABLE ADDitE33; ATQMLaw 1 Christine H. Kohl, Esq. Gary J. Edles, Esq.
Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Reginald L. Gotchy Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter of Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2)
Docket Nos. 50-352 and 50-353
Dear Board Members:
Inasmuch as the Staff has requested a copy of Philadelphia Electric Company's March 15, 1985 Application under Section 3.8 of the Delaware River Basin Compact, copies are being sent to the Appeal Board and parties.
Sincerely,
^
Mark J. Wetterhahn Counsel for Philadelphia El'ectric Company MJW/ac Enclosu're cc: Service List 1 00 I 3 kff* .
PHILADELPHIA ELECTRIC COMPANY 8 - -
2soi M Anxsv sraccT -
P.O. BOX 8699 PHILADELPHIA. PA.19101 Iatsi e4s.4ooo NAL.ebAMMEN
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E.C.M8AM MAb&.
............a pava. ausneacu
. .. .cuusa.4=. March 15, 1985 l r .... ... u sn.4a.
I ACME A. ..MEM M A Ms. Susan Weisman, Secretary Delaware River Basin Comission l P. O. Box 7360 West Trenton, New Jersey 08628
Dear Ms. Weisman:
Transmitted herewf.th for filing with the Commission is Philadelphia Electric Company's Application under Section 3.8 of the Compact for approval of the temporary substitution, during 1985, of in-stream monitoring of -
dissolved oxygen levels in place of the 590F temperature constraint on withdrawals for Limerick Generating Station Unit No.1 incorporated in Docket Decision 69-210CP (Final) November 5, 1975, and as necessary release of varying amounts of water, not exceeding 32.5 cfs, from water supply storage during 1985.
> This filing consists of six copies of the following documents: a) completed DRBC application fom, including Attachments 1 and 2 and Exhibits 1 l through 8 thereto; b) completed DRBC Environmental Fom; and c) completed Applicant's Statement - Project Review Fee Fom.
Enclosed is Philadelphia Electric Company's check in the amount of $100 to cover the Project Review Fee.
The affidavit of Vincent S. Boyer, Senior Vice President, Nuclear Power, Philadelphia Electric Company, which is part of Attachment 2 of the application, indicates that issuance of a full power license from the Nuclear Regulatory Commission for Limerick Unit No. 1 can be anticipated about May 1, 1985; that in order to proceed with the power ascension program af ter issuance of the license it is necessary to have in place a supplemental cooling water system; that delays in proceeding to full power.will delay comercial operation of the unit, and that the cost of not operating the unit for lack of water is estimated to be $49 million per month.
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Accordingly, the Company requests imediate action on its application, pursuant to Section 2-3.9(c) of the Comission's Rules of Practice and Procedure to protect the public interest and to avoid substantial and irreparable injury to the public and to the Company.
Comunications regarding this application should be directed to the undersigned.
Very truly yours, Edward G. uer, Jr.
EGB JR:pke Enclosures
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i DELAWARE RIVER BASIN COMMISSION t
. . . _.s. .
Type of Application: (Check one or more - see reverse side) -
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) (a) Addition to t he Comprehensive Plan. . . . . . . . . . .,. . . . . . . . . . . . . ( )
(b) Change in a Comprehensive Plan Pro ject. . . . . . . . . . . . . . . . . . . . ( )
j (c) Approval under Section 3. 8 of the Compoet. . . . . . . . . . . . . . . . . ('X)
(d) inclusion in "A-Ust" of the Water Resources Program... ...... ( )
Pursuant to the Delowere River Basin Compoet and the Rules of Practice and Procedure of the For Use of. Commission Delaware River Bosin Commission, cpplicat*on Docket No.
is hereby made for review of the project des-Date Received
- cribed below: Action by Commission (A) Application From:
Nome' Philadelphia Electric '
02ncany Mailing Address 2301 Market Street, Philadelphia, PA 19101 Telephone (215) 841-4000 Nome of Counsel Edward G. Bauer, Jr.
and nagene J. Bradley Nome of Engineerv. S. Boyer
.(B) Type of Project: (Check) .
(I) Impoundment. . . . . . . . . . . . . . . . ( )
(4) Stream Encroachment. . . . . . . ( )
(2) Withdrawal of Water. . . . . . . . .(x) (5) We ll . . . . . . . . . . . . . . . . . . . . . ( )
, (3) Disposal of Wostes. . . . . . . . . . . ('.) . (6) O t h e r . . . . . . . . . . . . . . . . . . . . ( )
(C) Description of Project: - -
l For 1985, withdrawal of water frm the Schty1 kill Wav fn* cc..r.-. N. ,,e._ i l
at Limerick Generating Station Unit No.1 by teocrarv substitutinn of in- l strea:n monitoring of dissolved oxygen levels in olace of 59 0 F toweMire constras.nt incorporated in Cocket No.69-210 CP (Final) (Novechal 5,1975);
and as necessary, release of varvim annunta o* t.m&a- me =<rwim nc cfs, frcm water sucolv storace as aw% =*a. &h 71n.r ca: i
. J n* r=h i s < n .
maid docket to be inacolicable to any such releases.
mese Nome. v. S. soyer Tille Senicr Vic.e.. Preside.nt..,--
Delowere River Bosin Commission
.. . . _ _ . - '_..__ __._._. . . _ ENVIRONMENTAL FORM ..
A PPlicant Philadelphia Electric CcmpanY Title of Pro,tect Interim consunptive water Supply Date 3/ pf location Limerick Generating Station DRBC Docket No. l l
- l. List any significant environmental impacts, beneficial and adverse, caused by the proposed action.
Se beneficial impact of the requested tmporary substitution of instream renitoring of dissolved oxygen levels in place of the 59CF tamnerature constraint and the requested release of water frczn the Blue Marsh Reservoir or other basin water sucoly storages as a back-up supply will be to oermit scheduled coeration of Limerick, already evalua*ad by th DRBC. See, DRBC FEA for Neshaminv Water Sucolv Systen (Auoust 1980): DRBC Level B St22dv:
and AEC/tmC FES for Limerick (Novenhar 1973 and April 1984) . %ere will be no adverse impacts frtzn the tourwary susp=6sion of the 590F ter=rature constraint. (See Paragraph below) . Were will be no adverse imnacts fmn the relamea of warm- fiun Blue Marsh Reser See, u.m E S for Blue Marsh (Aoril 1971); the Suncla a::at to the cdR .wic for Bina Marsh _
2., daw 1973) ; and the DRBC Invel B Study (May 1981). See At+m-%. ant 1.
- 2. What mitigati. ,g measures will be used to reduce or alleviate the adverse environmental impoets ?
There will be no adverse imoacts frcm the tenoorarv eier=neian of the 059 F towat r constraint. Deoradation of water cuality of the Schuylkill River below the Ihre. rick Generatirn Station will be crecluded by instream nenitorim of dissolved exwen leve' and releases frczn unea" sucolv senrace when DO leve1= fall beinw arc.:.nrahla levels.
' There will be no adverne'irmants frm the reemt " volan=== nf sm+.* f c m, sm *.*
j sutolv storace. 'Ihim. no mitieratiner mom eiree r. =' ha urviertaken.
- 3. Summarize the alternatives considered.
me alternatives considered were (1) no action, (2) release of water fiuri the
! Ontelaunee Reservoir, and (3) release of water frtzn Green Lane Reservoir. See i Attad.ient 2.
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- 4. List any known objectors to the proposed oction. :
- None.
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.an. -mmmm -mm - y74593 :
APPLICANT'S STATEMENT - PROJECT REVIEW FEE (5cc R:v:rsa sida Fce Additlanzl Informatisn)
- 1. Name and Address of Applicant U M 2301 Market St., Philadelphia, PA 19101
- 2. Nome of Project" Umdek Generating Station Interim Censumptive Water Supply Docket #
- 3. Type of Project , .
Check Applicable Item (s) '
(o) impoundments "
., (b) diversions of water into or out of the Delowere River Bosin c) Industrial water use 'and weste treatment facilities 7((d) electric generating and transmission facilities (e) petroleum product pipelines (f) stroom encroochments and . .
(g) withdrowol of ground water
- 4. Project Cost Foctors (Complete,all lines using Zero where opplicable)I ,
Item -
Estimated Cast . .
- a. Design $ 0
- b. Supervision of Construction 3 0
, c. Legal Services -
$ 0
- d. Contract Administration 3 0
- e. Land $ 0
- f. Meterials $ 50,000- '
- g. Constructiori 'ond Fabrication , ,
$ 45,000 '
0 '
TOTAL. ESTIMATED PROJECT COST. . . $
po.,e.,espemerks non m.wi.aral - 6sary suspension of 590F t-ature const:raint and release of varyirxJ amounts not exceeding 32.5 cfs of water supply storage frcm Blue Marsh Reservoir or other hmadn water supply storage, as appropriate,in 1983 * * *
- 5. Filing Fee Schedufe (Check opplicob)e' Item (s))
(The filing fee is the grooter of (a) or (b)) .. ' Computation X (o) minimum fee: $100. for any pro [ects or l (a)$ 100.
., (b) alternative fee: , . .
, , (b)
.(1) .1/10, of,1%' of estImsted.,p'roject cost up to $1,000,000. (1)$
(2) 1/50 of .1% of remaining cost.obove $1,000,000; but not (2)$
to exceed'o moximum fee o' f $50,000 os'to any one project,
~~ ~
exclusive,of odded environmental f4es.'
Total $ 100.00
- 4. Filing Fee Re,guired with Applicotion
- Please enclwe check in this amount with application. Check shovid b4 mode payable to Delowere River Bosin Commission. .,
NOTE: Should this project require on Environmentalimpact Statement or on Environmental Assessment, you will be notified at a later dote and on Applicant's Statement. Environmental Review Fee will be forwarded for completion and payment of a ficable fee. , j l . . e -
' Signoivre of Cenifying Official l Date *
/ gT Senior Vice President; Nuclear Power e *
, Title ,
ACKNOWLEDGMENT BY DRBC OF FEE PAYMENT -
Received Check No. fdated Bonk No.
In omount of COP!ts: tt) Adminlettettre Divleien Coor - white Signature
! . (2) APPLICA)r? - Retain Thte Copy - pink
{ (3) Applicant - DRSC Reeelsted Capr - yellow l (4) Project Review Copy - blue
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. .. . t.1 NO.72-7 A RESCl.UTION requiring the payment of fees for Commission review of certain water resources projects. . -
WHEREAS, review of proposed water resources projects pursuant to Section 3.8 of the Delowere River 8asin Cornpoet has become o substantial program activity representing a mo[or public cost; m..d WHEREAS, certain categories of project review cases demand extended staff onelysis .
ond the use of expert consultants, the cost of which connot always be forecast within the Commission's budget; and WHEREAS, it is timely and iri the public interest to initiate o program of o!!ocating o ,
portion of the costs of reviewing water resources projects to the opplicant or project sponsor; now therefore ,
BE IT RE501.VED by the Delowere River Bosin Commission:
- 1. A filing fee shall be pold to the Commis: Ion, occording to th schedule herein, of the time of filing ooch application for pmject rskiew,~ described in perograph 2 hereof, ' pursuant ,
to Section 3.8 of th Delowere River Basin Compoet. Government ogencies shall be exempt from such filing fee.
- 2. Project review fees under this regulation shall be required for th following cate-gories of projects, subject to provisions of Section 2-3.5(o) of the Rules.of Proctice and Procedures (o) Impoundments; ,
(b) diversions of water into or out of the Delowere River Basin; (c) industriot water use and waste treatment facilities; (d) electric generating and transmission facilities;.- .
(e) petroleum product pipelines;- - -
(f) stroom encroochments;,and -
. . . . .., (g) withdrowel of ground water.
- 3. The proleet review filing fee is th greater of (o) and (b) ais Iollows:
~
(o)' mint'mum fee: $100 for any prolect; .
(b) oftemative fee: .
- a. r -
' (1),,1/10 of 1% of peolect cost to $1,000,000; , .
(2) 1/50 of 1%'of rernoining cost above $1,000,000 bu't not to exceed T 'o maximum fee of. $50,000 as to oriy one project, exclusive of odded ' environmental fees;'
(3) environmentalieport fee ~,51,500 for any project; and (4) environmental impoet statement fee: $30,000 for any project.
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' 4. The project cost shell l' clude n the estimated costs of design,' supervision of construe-
- tion, legal services, contract administration, land, materials, equipment; c'onstruction and fabrico-tion. .. . ..
- 5. Not more, than one project Miew filing fee shall be paid to th Coma ission a to ony one project. , Phased review by the Commission of stages in the development of a pro (ect shall
,'be considered a single filing for purposes of this regulation. Revision of protects previously approved by the Commission shall be exempt from th requirements of this regulation. -
. 6. Entirnated capitol costs of electric transmission lines, petroir. s product pipelines ond.st'ecen r encroachment shall b calculated for that portion of the project sub{ set to Commission
, review and the filing fee shall W limited in its applicotton to the cost so coleulated.
- 7. Revenues received pursuant to this regulation shall b covered into the Commission's general fund and be subject to specific oppropriation by the Commission.
ADOPTED: June 28,1972
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- Amended April,23,* 1975' (Res(75-3)'..
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ATTAC!+ENT 1 Appilcation of Philadelphia Electric Ccrrpany for Temporary Suspension of 59'F Terrperature Constraint and Blue Marsh or Other Releases as Back-up Supply i
Beneficial irremets to the envirersnent. The availability of coo 1Ing water during 1985 for Limerick will enable the Limerick l
Generating Station to corrplete its start-up testing program without delay and to operate at full capacity in order to help meet electric power generation needs for southeastern Pennsylvania.
DRBC has previously detennined that the supply of cooling water for Limerick provides a benefit to the environment. As DRBC stated in its most recent envirortnantal review of the supply of supplemental 4
cooling water for Lirnerick, "docunents prepared after DRBC's Final EIS on the Point Pleasant Diversion Plan, issued in 1973, support the conclusion that the propos e project would be a feasible and i
beneficial use of water resources." DRBC Final Environmental j
Assessment for the Neshaminy Water Supply System, Part III, p. 2-53 i (August 1980). DRBC reached the 'same conclusion in granting final ,,,
Section 3.8 approval to the Point Pleasant project In Docket No. D-79-52 CP at p. 5 (February 18, 1981). Accord:ngly, DRBC has t
recognized that the use of Basin water resources to provide cooling water for Limerick constitutes a beneficial use.
As to the specific need for the electrical power to be generated
- by the Limerick Generating Station, DRBC has relled upon the findings l
of the Nuclear Regulatory Cannission (previously the Atcrnic Energy Corrmission) In its cwn envircrrnental statements for Limerick. See Docket No. D-69-210 CP (Final) at pp.1, 6-8 (Novenber 5,1975). In l
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Issuing construction permits for Limerick, the AEC detennined that there is a need for the electrical power to be generated by Limerick.
See AEC Final Envirorvnental Statement Related to the Proposed Limerick Generating Station. Units 1 and 2, Docket Nos. 50-352 and 50-353, Ch.
9 (Novent>er 1973). At the operating Ilconse stage, the NRC slmliarly found a substantial benefit to the envirortnent to be derived frem the operation of the Limerick Station in the annual production of approximately 10 billion kWh of base load electrical energy. jee ee,NRC Final Envirorynental Statement Related to the Operation of Limerick Generating Station, Units 1 and 2, Docket Nos. 50-352 and 50-353, Section 6.4.2 (April 1984).
Further, in an order entered August 27, 1982, the Pennsylvania PVC expressly stated'that "(t)he public Interest requires . . .
(t)lmely ecznpletion of Limerick Unit 1" and further stated "we encourage the Ccrrpany to ccroplete this unit as raoldly as possible consistent with the public safety." Pennsylvania PUC, Opinion and Order, Docket No. 1-80100341 (August 27, 1982) (emphasis added) (pp.
23-25). Accordingly, there exists' a substantial benefit f.o the , , ,
environment and the publ1c in the cerrmencement of cerrmercial a
operations at Limerick as soon as possible.
No adverse Impact by temporary susoension of 59'F t-vsrature 4
constraint. DRBC Docket No. D-69-210 CP (March 29, 1973) precludes Schuylkill River withdrawals for consumttve use by Limerick whenever l river water temperatures below Limerick exceed 59'F, except during April, May, and June when ficws measured at Pottstown exceed 1,791 cfs. DRBC's decision to limit Schuylkill River withdrawals when terrperatures are above 59'F is Intended to reduce stresses on stream
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water quality caused by consurptive losses at Limerick when water quality is significantly affected by organic waste assimilatten. When 1
ternperatures in the river exceed 59'F, the biological oxygen demand l
accelerates and the dissolved oxygen necessary for waste assimilation l
becomes more critical.
PECo proposes to monitor the river for DO at several locations belew Limerick and to substitute a suitable 00 value as the ilmit on withdravals frcm the natural river flow for the present 59 F temperature limit. This substitution of 00 for termerature Is proposed only for the remaining days of calendar year 1985. PEco will regularly transmit the DO Information to the offices of the DRBC so that it can i
be evaluated by them and so that they may request releases of water l
frem storage to compensate for withdrawals at Limerick at times of Icw D0 values. With this monitoring program In effect, PECo will be permitted to continue operations at Limerick regardless of river water temperature. -
The Pennsylvania water quality standard for DO in the Schuylkill River is 5.0 mg/l mintm.m daily average and 4.0 mg/l minimun ...
Instantaneous value. PEco proposes that these two values be established as the critical values Ilmiting withdrawals from natural river flow and the values which trigger releases of water frcm water supply storage. l j The nonitoring program proposed to measure Do during 1985 will
. Include water sarmling at least six times per day at regular time i
Intervals at six different locations between Limerick (R.M. 48.0) and 3 the Fainnount Dam (R.M. 8.5) in Phl1adelphia. The monitoring and !
transmittal of data will be acccrm11shed with autcmatic equipment ;
where practical and possible.
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4-When autcmatic equipment is unavailable, manual means will be utilized. Regardless of the means of monitoring, data will be transmitted to the DRBC at least dally and DRBC also will have ready access to all data during any Intervening time Interval.
Depressed DO levels usually occur In the pools behind the dams across the Schuylkill River. It is therefore proposed to establish a sarmling station behind each of the following six dams: Fairnount Dam (R.M. 8.5), Flat Rock Dam (R.M.15.6), Plyneuth Dam (R.M. 20.7),
Norristown Dam (R.M. 23.9), Black Rock Dam (R.M 36.6), and Vincent Dam (R.M. 44.7). A sarmling station at Limerick (R.M. 48.0) was established' about 10 years ago and semilng will continue at this location as'before. At each of these stations a single probe will be Installed. The specific location to be determined based on access, availability of electric power and protection frcm vandalism. The probe will be positioned vertically In the water colum below the mid-point so that It will not be subject to surface effects.
This monitoring program, when substituted for a single temerature measurement, will provide satisfactory water quality protectio,n , ,
Wause of the relationship between DO and organic waste assimilation and also because the entire downriver stretch will be nenitored.
In addition to the present 59 F termerafure ccnstraint on withdrmals at Limerick, there is a mininun flow constraint of 530 cfs for one unit. This constraint operates Independently of the 59 F temperature constraint. Frequently, the flow constraint would preclude withdrawals frcm the Schuylkill, regardless of' the termerature constraint. For example, during the drought of 1965, the flow
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constraint of 530 cfs would have prohibited Schuylkill withdrawals 167 days, elle the temperature constraint would have prohibited withdrawals for only an additional 29 days. The historic record for the Schuylkill over the past 55 years shows that, on average,
'wlthdrawals for one unit at Limerick would have been prohibited by flow and temerature constraints 120 days per year. For 52 of the 120 days in this period, the flow constraint would have been the Ilmiting factor. See DER "59 F Restriction on the Schuylkill River Water Withdrawal, Limerick Nuclear Power Plant" at p. 4 (Septerrber 1983).
, Accordingly, suspension of the 59'F temperature constraint alone would not provide a long-tenn source of makeup water for Limerick. On the other hand, the same data show that a terrporary suspension of that .
constraint would pennit Schuylkill withdrawals for up to an additional 68 days on average.
No adverse ineact frcrn existino water storace releases in 1985.
Recognizing that there will be times when stream flow and DO constraints, as proposed above, will operate to prevent withdrawals, another source of rnakeup water will be necessary for the short interim ,,.
period until water from Point Pleasant is available. Under those circunstances, releases would be requested from existing water storage supplies. -
In view of the inventory of water supply storage facllities under DRBC control, the Blue Marsh Reservoir appears to be the most. probable source of such releases. In authorizing construction of the Blue Marsh Reservoir, Congress designated 8,000 acre-feet of storage for downstream water supply needs. See Flood Control Act of 1962, Pubile l
e , ,__ _ _.
o l t m 87-874, 877.h Congress 2nd Session. The refense of water supplies frcm the reservoir underwent environmental review In two separate enviromental statements prepared by COE. U.S. COE Environmental ,
l Statement on the Blue Marsh Lake Project (April 1971); Supplement to l U.S. COE Environmental Irmaet Statement on the Blue Marsh Lake Project (June 1973). In neither doeurent did COE determine that -there would be any adverse enviromental Impact from the release of water frcm the water supply storage for the benefit of downstream users. See COE Supplement at p. 5. To the contrary, COE fomd that the release of those waters would have a beneficial Impact upon overall water quality in that stretch of the Schuylkill River.
In June, 1984, DER undertook an assessment of Bucks County's proposal that Blue Marsh Reservoir storage be used to provide makeup water for Limerick when Schuylkill water would be unavailable. See DER's " Assessment of Bucks County Proposals for Alternatives to the Point Pleasant Water Supply Project" (June 1984). DER stated two 4
fundamental concerns regarding the ccrrmitment to Limerick of large arrounts of storage frce Blue Marsh: (1) the Irroacts upon the
- interests of other present and future water users in the Basin and (2) 1 potent!al Impacts on coordinated reservoir operations needed to l
j control salinity in the Delmare estuary (Assessment at p. 29). PECo has requested releases, however, on a far trore Ilmited basis than 1
- suggested by the Bucks Comty proposal. First, PECo is not requesting i
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releases frcm water quality storage, but.only frem water supply '
storage. Second, PECo is merely requesting releases frcm storage for .
1985. PEco acknowledges that the long-tenn use of Blue Marsh as suggested by, Bucks County "would confilet with' anticipated needs of
, pubile water suppliers" along the Schuylkill. See Del-Aware Unlimited, Inc. v. DER. EMS Docket Nos. 82-177-H and 82-219-H,
. Adjudication at 46 (June '.8, 1984).
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PECo also recognizes that Blue Marsh must be available to assist 1
In meeting the needs of downstream users in a drought and that DRBC l I
has authority to utilize the water supply storage of Blue Marsh to l meet downstream water quality objectives. Nonetheless, the terrporary short-term use of Blue Marsh should not be precluded sirrely because drought conditions might arise which require releases frcm the water supply storage. Under the " pooled water" concept, drought hardships must be shared on an equitable basis among all Basin users. Equitable demands upon other Irrpoundnents (e.o.. Beltzville) would be made to meet flow augmentation needs for water supply and water quality in a drought. See DRBC Level B Study at op. 19, 57 (May 1981).
The COE Blue Marsh Lake Water Control Manual (Final) states at p.
7-13 that the 8,000 acre-feet of water supply storage in Blue Marsh is equivalent to a continuous yleid of 55 cfs. Of this amount, 9 cfs is currently under contract with the Western Berks Water Authority and an additional quantity used under the control of the DRBC to provide for the needs of other existing downstream users. The remaining arrount is therefore available to meet other " current water supply needs" as ,,.
determined by DRBC. Accordingly, it appears that release of an average l
of 27 cfs for Limerick for the short Interim period requested by PEco would have no adverse effect upon other users or potential users along the Schuylkill River below Blue Marsh. Further, inastruch as PEco proposes merely to receive releases of water frem an existing reservoir by utilizing the same facilities, structures, and mechanisms already in use, there will be no adverse impact to the environment.
The release of water frcm the Blue Marsh Reservoir in amounts required by PEco would not adversely affect recreational use of the
~
reservoir. The COE Blue Marsh Lake Water Control Manual (Final)
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states that the Reservoir should be maintained at elevation 290 feet throughout the sunner months for the benefit of recreational use. The Manual states at p. 8-3 that the recreational facilities are usable frcm the top of the sumer pool Celevation 290 feet) to a dram down elevation of 283 feet. As explained below, releases frcm the reservoir during the recreational period will not result in a detrimental lowering of the water level.
PECo analyzed several critical years to determine the possible effects of the drawdem resulting from its requested releases. In Its analysis, PECo assuned one unit at full load operation at an average' consumtive use of 27 cfs throughout the period of water unavailability from natural flows of the Schuylkill River until Septent>er 30, the end of the recreation season, and included the 9 cfs under contract to the Western Berks Water Authority, the full conservation release of 41 cfs, and 5 cfs as evaporation. For 1955, an average year for flow in the Schuylkill River, PECo found that during the sumar months, the pool elevation would be drawn dom less than 1 feet.
PECo also analyzed the situation for 1980 because that year ,,,
Schuylkill flows were 20% below av'erage. It was detennined that drawdown fran the requested releases would have been about 2 feet.
PECo also sinulated withdrawals for 1965 because it represents the worst year of record for low flows In the Tulpehocken Creek and therefore the year of lowest supplies to the reservoir. PECo determined that its requested releases would have resulted in a dr mdown at the end of tho' recreational season of approximately 4.5 feet. Thus, the requested releases of water for PEco and the resulting drawdown of the reservoir, under worst case conditions,
9-would result in the Blue Marsh water level 2.5 feet higher than the designed drawn down elevation 283. This margin of drawdown would remain available for other concurrent users of Blue Marsh water and would have no detrirnental effect on recreation. This analysis is reflected on the attached Figure 1.
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I ATTACI-NENT 2 Appilcation of Philadelphia Egectric Ccrmany For Tempors.ry Suspension of 59 F Temperature Constraint and Blue Marsh or Other Releases as Back-up Supply Alternatives Considered PECo has considered various alternatives for a temporary supply of supplemental cooling water to Limerick for the period of 1985 when docket decision constraints preclude withdrawals from the Schuylkill 1
and Perkicmen. An alternative is not realistic and need not be considered unless capable of being prermtly implemented. Thus, an alternative cannot require construction or major modification of existing facilities. The alternatives considered and a brief discussion of each follow:
, (1) No action - Due to flow and termerature constraints limosed by DRSC on withdrawals of water frcm the Schuylkill River for consumttve use, the Schuylkill will be largely unavailable for such withdratals during the period Jme to October, 1985. Because the permanent supplemental water supply fran the Point Pleasant project will be unavailable for this period, Limerick cannot continue with start-up l
testing, and ascend to full power without an Interim i
source. The cost of not operating Limerick for lack of water during that period is estimated to be $49 million per month. See Affidavit of Vincent S. Boyer, Senior Vice President, Nuclear Power (March 15, 1985) Cattached).
i
,,e (2) Ontelaunee Reservoir - This reservoir is located on Maiden Creek, a tributary to the Schuylkill River upstream of the Limerick plant, and is owied by the Clty of Reading for use as a water supply source. Ontelaunee has 11,640 acre-feet of total storage. The City of Reading was granted an allocation of 35 million gallons per day of water by the DRBC on August 27, 1969 in Docket No. D-69-139 CP. The water supply system is presently reported to use an average of 20 med with a maxinun usage of about 25 mgd. The City of Reading and the municipalities served by the water system are served by ccmprehensive systems of sewerage collection which discharge
> to conclete treatment facilities and thence into tributary streams and the Schuylkill River.
Inquiries have been made to the City of Reading and a presentation was made to the City Council as to the city's Interest in selling unused water fran their allocation to PECo. An appilcation for approval of such usage would have to be made by the City to the DRBC. To date, the City has not Indicated an Interest in making any water available to PECo for 1985, .or any other period of time.
(3) Green Lane Reservoir - This reservoir is located on the Perklanen Creek. It is owned by the Philadelphia Suburban
. Water Ccwpany ("PSW Co.") and is used in conbination with I
i other reservoirs and wells for water supply. Total storage i
1s 13,430 acre-feet. Green Lane is not large enough to meet -
the corrbined needs of PSW Co. and Limerick. (Letter to l Nicholas DeBenedictis, DER Secretary fran Robert A. Luksa, i
Executive Vice President, Philadelphia Suburban Water Ccrnpany, June 4,1984).
~. .
CONONWEALTH OF PENNSYLVANIA :
ss.
COUNrf 0F PHILADELPHIA :
3 VINCENT S. BOYER, being first duly sworn, states as follows:
i 1. My name is Vincent S. Boyer, I am Senior Vice President, Nuclear Power of Philadelphia Electric Company ("the Company"), owner and operator of the Limerick Generating Station.
2 On October 26, 1984, the U. S. Nuclear Regulatory Commission
- issued a license authorizing fuel loading and low power testing of Limerick Unit 1. Fuel loading was completed in November,1984, and the low power testing program has been completed. The schedule for the power ascension
- phase of operation of Unit 1 of the Limerick Generating Station is such that the Plant will be ready to proceed to power levels greater than allowed trder i
our existing license by the end of March, 1985. In view of the current status -
of the EC licensing proceedings, issuance of a full power license can be anticipated about May 1, 1985.
- 3. In order to proceed with the power ascension program for Unit 1 after the issuance of a full power operating license by the NRC, it is necessary to have in place a supplemental cooling water supply. ,
- 4. The partially constructed Point Pleasant diversien will not be I completed in time to supp.ly Unit l's supplemental cooling wster needs in the second quarter of 1985 when it is anticipated that the NRC will authorize the Company to proceed to full power operation. .
- 5. Consequently, an interim supply of supplemental cooling water will be required to operate Unit 1 at sustained high power levels until the Point Pleasant Profect is completed.
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- 6. Delays in proceeding to full power will result in a delay in the commercial operation of the unit. Such delays will increase the costs of i Limerick Unit 1 by $34 million per month. This cost figure is made up of $24 million per month Allowance for Funds Used During Construction (AFUDC) and $10 million per month operational, security and maintenance costs. In addition, the fuel costs of the Company's customers will be increased by $15 million a month for each month of delay.
- 7. Delays in the full power operation of Unit 1 may also impact on the restart of construction of Unit 2. The Pennsylvania Public Utlity Commission is presently holding hearings on whether construction at Unit 2 i should be continued, but in compliance with a prior order issued by the PUC, construction of No. 2 unit has been suspended unit No. 1 is placed in commercial operation.
Vincent S. Boyeff Sybscribed And sworn to before me this / M day of March..1985. -
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Exhibit 1
- App 1lettlon of Philadalphic Electric Carcany for Torporary Suspension of 59'F Terroerature Constraint and Blue Marsh or Other Releases as Back-up Supply Abstract of ProceedIncs Authorizing Pro fect DRBC Irtposed the 59'F terrperature constraint In its docket decision regarding the withdrawal of Schuylk!11 River water for Limerick. DRBC Docket No. 0-69-210 CP at p. 5 (March 29, 1973).
While this temperature constraint has been reviewed by DRBC and DER and deemed appropriate to provide a margin of safety in maintaining desired dissolved oxygen levels, those conclusions were based upon long-term consurotive use of Schuylkill River water without alternative measures to assure that DO objectives are met and, as such, are inappilcable to the proposed short-term usage.
The Blue Marsh Lake Project was authorized by the Flood Control Act of 1962, Ptb. L. No.87-874, 76 Stat. 1173, 1182 (1962). Congress intended that Blue Marsh provide, among other things, water supply.
H.R. 13273, 87th Cong., 2d. Sess. 123 (1962). The DRBC has contracted for 8,000 acre-feet of storage from the U.S. Army Corps of Engineers
("COE") for trunicipal and Industrial water supply, as docunented in Contract No. DACW61-71-C-0145, dated May 14, 1971.
t The COE estimates that the water supply volune can continuously Yleid 55 cfs of water. U.S. Army Corps of Engineers Blue Marsh Lake Water Control Manual (Final) (March 1984) at par. 7-09(a), p. 7-13.
The Western Berks Water Authority has contracted with the DRBC to purchase 9 cfs of this water through 1989. The remaining water supply, 46 cfs, is available to meet the needs of other users.
. l l
l Exhibit 2 l l
Appilcation of Philadelphia Electric Comany '
for Termorary Suspension of 59'F Termerature Constraint and Blue Marsh or other Releases as Back-up Supply Standard Regarding Temporary Suspension of 59'F Termerature Constraint on Schuylkill Withdrawals The DRBC's objective in troposing the 59'F termerature constraint on Schuylkill withdrmals is to reduce stresses on stream water cuality caused by cons m ptive losses at Limerick when water quality is significantly affected by organic waste assimilation. So long as the stream capacity to assimilate organic waste is not impaired by Limerick withdrmals above 59'F, as assured by PECO's Instream monitoring, DRBC's objective will be achieved (see Attacinent 1).
i There is no indication in the history of DRBC's consideration of this criterion that it has any signtftcance apart from Indirectly maintaining control over desired 00 levels in the lower reaches of the 1 Schuylkill and the Delaware estuary.
Standard for Minimizing Releases N Frcm Water Supply Storage for -
Limerick Durina 1985 In authorizing construction of the Blue Marsh Reservoir, Congress ,
expressly designated 8,000 acro-feet of storage for downstream water supply needs. See Flood Control Act of 1962, Pubile Law 87-878+, 87th Congress, 2nd Session. The policy of utillzing a discrete block of storage of the Blue Marsh Reservnir to meet downstream water supply needs was restated in both envirorrnental statements prepared by COE.
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g U.S. COE Envirorsnental Statement on the Blue Marsh Lake Project at p.1 (April 1971); Supplement to U.S. COE Environmental Impact Statement on the Blue Marsh Lake Project at pp. 2, 4 (June 1973)).
See also COE Blue Marsh Lake Design Menorandun No. ISA at p. 8-2 (dtrie 1975); COE Blue Marsh Lake Water Control Manual (Final) at op. 2-1, 7-12 to 7-13, 8-4 to 8-6 (March 1984).
DRBC has inclemented the stated policy of uttilzing Blue Marsh to meet downstream water supply needs In granting Section 3.8 approval to the appilcation on behalf of Western Berks Water Authority for Blue Marsh water supplies in Docket Nos. D-69-55 CP (August 27, 1969) and D-69-55 CP (3.8) (Decarber 15, 1971).
In order to minimize water storage releases for Limerick during 1985, water would be released frcm water supply storage only when river flow i
i as measured at the Pottstem gage is less than 530 cfs and when dissolved oxygen as measured by our proposed monitoring program falls below acceptable levels; the ficw constraint incosed in Decket No.69-210 CP (Final) (Novenber 5,1975) to be Inappilcable to any such releases.
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8 Exhibit 3 -
/colication of Philadelphia Electric Ccrreany for Temporary Suspension of 59*F Terroerature Constraint and Blue Marsh or Other Releases as Back-up Supply ,
i Section of the United States Geological- i Survey Topographic Map Showing the Territory and Watershed Affected The mao attached detailing the Blue Marsh Reservoir was prepared from the enited States Geological Survey Quadrangle, Wernersville, PennsyIvanIa.
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- n' Application of Philadelohta Electric CoToany for Temocracy suspension of 59a Terroerature Constraint and Blue Marsh or Other Releases as Back-vo Supply Description of Specific Effects of Non-Structural Project The specific effects of this non-structural oroject are discussed in Section 1 of the Environrental Form and Attachment I hereto, e
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Exhibit S .-- -
Appilcation of Philadelphia Electric Comany for Temporary Suspension of 59'F Termerature Constraint and Blue Marsh or Other Releases as Back-up Supply Report of the Applicant's Engineer Showing the Proposed Plan of Operation of the Project The continuation of the startup program and approach to full power for the Lirrurick Generating Station Unit No.1 is expected to begin
'I about May 1, 1985, following authorization by the Nuclear Regulatory Cerrmission. A gradual ascension to full power is planned with tests being conducted at several discrete power levels. The total test program is estimated to require a period of approximately six months, this estimate providing time for review and approval of test results and for sans adjustment and tuning of control systems.
Based on the availability of consunctive water requirements, the following program is envisioned. For the first two months of the startup program, May and dme,1985, the unit will be operated at power levels progressively increasing to 50% of full power and the average consumtive water requirements will be about 10 cfs. During July 1985, testing will occur at power levels up to 75% of full power with the consumttve water requirements averaging about 17 cfs. Frcm August through October, it Is planned to conduct tests.at full power output with consunctive water needs averaging about 22 cfs. When operating at full pcwer, the average consumttve usage arrounts to 27 cfs, which figure can increase to 32.5 cfs under adverse -
meteorological conditions, i
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During the test program, PECo wi1Rutill-ze withdrawals frcm the -
Schuylkl11 River and Perkicmen Creek as authorized by DRBC. When river termeratures approach 59 F, PECo will conduct instream monitoring of 00 levels in the Schuylk!11 at selected locations as described in Attactrnent 1.
When further withdrawals fecm the Schuylkill River and Perkicmen Creek are precluded by the DRBC docket decision ficw constraint or by low DO levels, PEco requests, during 1985,s release of water from existing water'storsge facilities. The%ater released will flow into the Schuylkill River to be withdram at the Schuylkill River Intake for Limerick. The flew constraints imposed in Docket No.69-210 CP (Final) (Noved.*.r 5,1975) to be ina::ciicable to any such releases.
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ExHrbit 6' ' - ' '
Appilcation of Phl1adelphia Electric Coreany for Temporary Suspension of 59'F Terroerature Constraint and Blue Marsh on Other Releases as Back-up Supply fiao of Any Lands to be Accurred or Occuoted This is a non-structural proposal involving the temporary suspension of the 59'F terroerature constraint on withdrawals fra the Schuylkill River for consurotive use at Lircrick and an interim supply I
of water from water supply storage during 1985. There are no lands to .
be acquired or occuoled.
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Exhibit 7 Application of Phl1adelphia Electric CcrTeany for Terrporary Suspension of 590F Tencerature Constraint and Blue Marsh or Other Releases as Back-up Suoply Estimate of Cost of Comoleting the Proposed Project This is a non-structural proposal involving the tenporary substitution of a dissolved oxygen monitoring system for the 59 F tencerature restriction on withdrawals of water from the Schuylkill River for consufetive use at Limerick and a back-up Interim supply of water from water sucoly storage during 1985. The only physical field work Involved will be the installation of 00 monitors at six locations between Limerick and the Faintount Dam in Philadelphia.
The cost to purchase and Install the six nenitoring stations and a spare unit is estimated to be $95,000.
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Exhibit 8 - -
Application of Philadalchia Electric Cctroany for Temporary Suspension of 59 F Terroerature Constraint and Blue Marsh or other Releases as Back-up St. red y Description of Construction Procedures This is a non-structural proposal involving the tercorary si.bstitution of a dissolved oxygen tronitoring system for the 59 F temperature restriction on withdrawals of water from the Schuylkill River for consuretive use at Limerick and an Interim supply of water frcm the water supply storage during 1985. Work Involved will be the Installation of DO tronitors at six locations between Limerick and the Faintomt Dam in Philadelphia.
The monitoring equipment at each location will be similar and will consist of a small Instream probe, connecting to a mini-computer located on shore in a protective enclosure and a connection to a leased telephone line to transmit data to a central point (or points) where the data will be evaluated.
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.e SUGARM AN, DENWORTH & H ELLEGERS ATTORN EYS AT L AW e6TM FLOOR. CENTER PL AZ A ROBERTJ.SUGARMAN L2OI PENN$YLVANM AVENUC, N.W.
JOANNE R. DENWORTH 101 NORTH BROAD STREET JOHN F. HELLEGERS PHILADELPHIA. PENNSYLVANIA 19607 o ~, o (215)751 9733 ROBIN T. LOCKE ROBERT RAYMOND ELUOTT. P. C.*
COUNSEL February 11, 1 9 C .,,,,, ...
Certified Mail FREEDOM OF INFORMATON JCT REQUEST Freedom of Information Officer U.S. Nuclear Regulatory Commission FefA-II
- I 03 Washington, DC 20555 g g.Q .Q Re: Application of Philadelphia Electric Co.
(Limerick) Docket,52-352, 52-353
Dear Sirs:
At a briefing of the Commission on January 5, 1985, staf f advised that they have been informed by the applicant of the applicant's intent to seek interim supplemental cooling water for the above facility from the Delaware River Basin Commission.
Pursuant to the Freedom of Information Act, this is a formal request that we be furnished each and every document relating to such a plan by PECo, including any notification of the staff, any staff memoranda regarding such notification (whether such notification was written or oral), and each and every document constituting or relating to any consideration by the staff, whether complete or incomplete, of each and every potential source of interim supplemental cooling water or perman-ent supplemental cooling water, created or referred to since January 1, 1984.
In lieu of producing copies of documents furnished by the writer and/or Del-AWARE, Unlimited, it would be sufficient to provide a list of such documents as have been considered by the staff.
In view of the urgency of this matter, a response within the ten day statutory period is specifically requested.
You are requested to furnish these copies free of charge in view
- of the public interest in this matter, and the fact that I am i applying on behalf of a public interest group, Del-AWARE, Unlimited, Inc. However, if there is a copying charge, you are f i
}
2 Februory 11, 1985 requested to prepare the documents and furnish them together with a bill, as long as the amount does not exceed $200. I undertake that such bill will be promptly paid. If the charge exceeds
$200, you are requested to call my office in Philadelphia to establish a means for payment.
Thank you for your consideration.
I Sincerely,
' ff Robert J. Sugarman !
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