ML20133F410
| ML20133F410 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/01/1985 |
| From: | Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| CON-#485-732 OL, NUDOCS 8510110017 | |
| Download: ML20133F410 (2) | |
Text
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,L U.S. NUCLEAR REGULATORY CO!! MISSION.
RE: PHILA.ELEC.CO. Ltusrick Gan.Sta. Units 1 & 2.
Docket No.
50-352,353 1
- 0. W PETITION TO REQUIRE PSCo TO COMPLY WITH THE REQUIREMENTS OF ENSE NPP-39, APPENDIX 3, PARA.
3 1 and 5 3 AND TO TITHDRAW PLICATIO TO DRBC TO LOWER SCHUYLKILL FLOW RESTRAINT AND TO PERMIT R ES FROM BEECHWOOD PIT.
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~0ctober 1, 1985 sbn e uire PECo to a.L. Anthony /FOR hereby petition the tJ o
withdraw applications to DRBC to change the ggiong'7pf: thef the compact with DR3C as specified in a letter of 9/23/851ftf.ghr tjo S.J.Chilk,Sec.,
forwarding copies of two letters of 9/20/85 to DRBC-applyinfr for a reduction of Schuylkill flow restra. int from 530 cfs to 415 cfs at the'Pottstown gage l
and also approval of maximum releases from the Beechwood Pit into the river of 100fs.
Te asse:-t that these applicatior)s by PEco,1f granted, have the potential to-degrade the iaters of the Schuylkill and to <*amage the life of the river i
and the safety of drinking water supplies at Pottsdown and downstream from
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the plant They wouli change the conditions specified as conditions of op-er ting the plant under EROL g g 3? hey invoke the requirements in License-a JPF-39 under Para. 3 1 and 5 3 3 The former specifies an environmental evalu-stion of ' operational activities _which may significantly affect the environment".
PEco's application to change the DREC conpact has.the above a:"fect and also
" involves an unreviewed environmental question" thereby requiring that " the licenses shall provide a written evaluation of such actiiity and obtsin prior
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.TRC approval".
PEco has provided no environmental evalugtion and h.s not ask-ed for " prior NRC approval."
PECo's application to change the DR3C compact involves changes in the
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Environnental Protection Plan.
Appendir 3 ? ara. 5 3 also requires an assess-ment of impact gud" supporting justification" and specifies "su:h chan'ges in the H?? ahall not co=ence prior to NHC approval... in the f2 2 of a license amendment incorporating the appropriate revisions to the EPP.' ?Eco is seek-ing D130 compact changes without a lice'nse amendment.
Petition for a Stay.Ne petition the Commission to stay ?3Co h applications to DR3C above and to re<1uire the withdrawal of these until PEco fulfills the requirements of Appendir 3.
Ye are enclosing (Attachment 1.) a copy of our letter to the Delaware River 3nsin Commist'sion,10/1/35 in opposition to PECO's applications,sud re-questing that action be deferred pending action on this petition to' 320.
cc NRC 13, Docketing,Jir.Licebsing,PSCo,DR30, 2espectfully submitted, LEA,Cthers on Serv.Iist.
8510110017 851001 PDR ADOCK 05000352
- or l?o, Y ay h n,.,cs 13 Co,p.
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Bor 186. Moylan,Pa.19065 Ms. Susan Weisman, Secretary Oc tober -1,1985 Delaware River Basin: Commission.
West Trenton,N.J. 08628
Dear Ms. Weisman,
7e are in receipt of copies of PECo's applic tions of 9/20/35 to DR3C a
to reduce the existing flow restraint in the Schuylkill River from 530 cfs to 415 cfs (Pottstown gage) and approve releases to the river from the Beech-wood Pit of up to 10 cfs.
RobertL. Anthony /F0E, intervenors in the ERC Limerick licensing proceed-ings are opposed to the granting of PSCo's applications on the grounds that they would degrade the river,thereby threatening the biological life of the river and its adjacent environment. as well as drinking water supplies.
We
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oppose any degrading of the standards set in the DREC compact and we call for DRBC to uphold the River Follower principle upon which the origin l permission a
to PZCo to build the plant at Limerick was established.
We cdl attention to the provisions of Xppendir 3, Environmental Protect-ion Plan,which is written into Operating License 7P7-39 granted to PICo by NRC,9/0/35 This requires an environmental assessment and prior YHC approval
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for any such changes as the above.
We are enclosing a copy of our petition to NRC to enforce these provisions of the license and to stay PECa's applica-ti:n to 313C.
Je ask DR3C to d3fer any action on FSCo's applications until the requirenents under the license have been fulfilled.
?urthermore, in studying F5Co's applications ts :R3C we find the follow-ine discrepancies and figws :
1.
Je find no baqk-up or rational for the =arkings ou Figure 1.
- 2. Why has 323C used PECo figures on 733 instead of its own sampling, especially in revlings below 350 cf3 flow,which seen to be altogether miss-ing, thereby calling inta question the projection of the envelope curve and nedian line on the lower flow sile of the chart.
3.There is no atte=pt to identify canditions of flow in which 3eechwood levels of 1700 mg/l would tend to strat.fy and flow at a separat+ rate i
without co:plete miring. That affect would there be at Pottstown water plant?
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- 4. Ther? are no restrictions on
- ntinuous pumping frcs 3eechwood nor calculation as to when the level iculi be reduced by 30 feet and higher condentrations of dissalled s311ds ;;;;e1 to the river. There is na esti= ate of inflow and how that wa2Li stir the Sc:to: and raias 23S above 1700 =g/l 5
Table 1. attached to the revised application for 3eechwood water, records Background River TDS G L;34st Pottstown gage 4 500 cfs)aa 342 and 336 at Pottstown Flant,with a 3eechi:31 pumping rate 100fs.
In contrast to this, Table 1., Attachment 1.,re: ris higher levels at 500 cfs flow for the two locations, 405 and 420 res;e::ively.
How can there be lower read-ings "with a 3eechwood diacharge' thsn "aftvr lowering the trigger flow to 3J 415 cfs? This appears to discredit both tables.
- 6. Revised application Tsble 1. cen'tains readings for flow levels from 250 cfs to 5c0 cfs with assu=pticus s nari :a 3ee:hiosa rate of 10 cfs and 103 consumptiva r te 19efs. This table implies that Li=erick will be draw-a ing out water fres the Schuyliill at flows ici: to 250 cf3 as long as 3eechwood is pu= ping in,up to 10cfs.
7e are enclosing a copy of our petitian ta T30 of 10/1/35 with the request that D12C defer action on 220a's a;;11:ations until 72C has acted.
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