ML20136A817
| ML20136A817 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/23/1985 |
| From: | Conner T CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| CON-#485-583 OL, NUDOCS 8511200033 | |
| Download: ML20136A817 (72) | |
Text
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N D Pos t..sw orrices Coxxea & WETTEHH AIIN, P.C.
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THOY B. CONN EH, J H.
WAsil:NOTON. D. h).bbb7)OG MAHK J. WETTENuASIN ROB E RT M. RA D E R DOUGI.AS M. OLSON
'85 SEP 24 All :26 o E..TsA. uv Tv
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'S September 23, 1985 EU","[A,"[o?"scunOerzu
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SRANCH Mr.-Samuel J. Chilk Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 In the Matter of Philadelphia Electric Company (Limerick Generating Station, Unit 1)
Docket No. 50-352e L
Dear Mr. Chilk:
As a follow-up to my June 3, 1985 letter to you, I am enclosing copies of (1) an application filed with the Delaware River Basin Commission under Section 3.8 of the Compact for approval of the withdrawal of water from the Schuylkill River for consumptive use at Limerick Unit 1, for the balance of 1985, when the flow at Pottstown gage is in excess of 415 cfs; (2) a revision to the application which would permit permit release of water from the Beechwood Pit, for the balance of 1985, at a maximum rate of 10 cfs for withdrawal and consumptive use at. Limerick Unit 1.
Item 1 was delivered to the NRC Staff on September 23, 1985.
Sincerely,.
Trol onner, Jr.
Counsel for Philadelphia Electric Company TBC/dlf Enclosure cc:
Service List h1200033850923 p
ADOCM 05000352 PDR
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PHILADELPHIA ELECTRIC COMPANY s
2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 JOHN S. KEMPER vacs engssogNr -
snesnssatase ano massaacn September 20, 1985 4
Ms. Susan Weisman Secretary Delaware River Basin Commission P. O. Box 7360 West Trenton, NJ 08628 i
Dear Ms. Weisman:
In an Application filed July 3, 1985. Philadelphia Electric Company and Reading Anthracite Company (" Applicants") sought approval under Section 3.8 of the Compact of the withdrawal of water, during 1985, from the Schuylkill River for consumptive use at Limerick Generating Station Unit No. 1, when existing dissolved oxygen or flow constraints would otherwise prevent such withdrawal, in amounts not exceeding existing docket limits and not exceeding amounts released into the West Branch of the Schuylkill River from the Beechwood Pit.
Applicants requested authorization to release water from the Beechwood Pit in amounts up to 32.5 cfs.
Applicants hereby revise the July 3, 1985 Application by reducing the maximum releases from the Beechwood Pit for which approval is
/
requested to 10 cfs, subject to the maintenance of levels of total dissolved solids in the Schuylkill River at both the Pottstown Water Treatment Plant and Citizens Home Water Company at levels below 500 mg/1.
A release of no more than 10 cfs from the Beechwood. Pit having the highest expected total dissolved solids (TDS) concentration, mixing with the Schuylkill River with a median TDS concentration at a design low flow (Q7-10) will result in a mix of water within the DRBC TDS water quality standard of 500 mg/l at the first two downstream municipal water users, Pottstown Borough and Citizens Home Water Company. Figure 1 is a graph of TDS vs Schuylkill River Flow presented by the DRBC staff at the September 13, 1985, Public Meeting held in Philadelphia. This graph is a composite of the TDS data for the sampling periods 1944-1951, 1965, 1966 and TDS data supplied to the DRBC by Philadelphia Electric Company (PECo) for the sampling period 1974-1984. The data supplied by PECo was taken at the Limerick intake and includes the effects of the Pottstown Sewage Treatment Plant on TDS levels, unlike the original data which did not include the effects of the sewage plant. Drawn on the graph is the original envelope curve, which encompasses all values of Schuylkill River
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s Background TDS used by the DRBC In preparation of Docket D-69-210 CP l
(Final). To reflect the improving quality of the river, the graph includes a new temporary envelope curve for low Schuylkill River flows. PEco has added to the graph a median IIne for the DRBC new tenporary envelope curve. The median IIne is considered representative of the range of TDS levels for the sanple period, i
although it is recognized that there will be periods when the TDS f
levels are above the median value. The monitoring program described in the Septenber 3,1985 letter from V. S. Boyer to S. Weisman will 1
provide indication when high TDS levels are present during lower river flows. When high TDS levels are Indicated, operation of Limerick and/or Beechwood will be modified so as to keep the TDS levels in the Schuylkill River at the downstream users' location within the 500 mg/l water quality standard. Table 1 shows the effects of purping 10 cfs from Beechwood Pit with a TDS level of 1700 mg/1, the highest expected s
TDS level In the top 30 feet of the Beechwood water and the subsequent mixing of this water with the Schuylkill River at various flows and a median background TDS concentration.
It is shown that the DRBC TDS water quality standard of 500 mg/l can be met during a Q7-10 flow, at l
both the Pottstown Water Treatment Plant and Citizens Home Water Ccripany.
j The effects of a 10 cfs release from Beechwood on aquatic Ilfe and water quality are minimal. A 10 cfs puipage from Beechwood Pit results In a mixed intake total dissolved solids (TDS) concentration of 448 mg/l at the Limerick Intake at a flow of 250 cfs at the i
Pottstow1 USGS gage.
It is expected that under these conditions the maximtm allowable withdrawal at Limerick would be' 18 cfs for evaporative cooling and 10 cfs for cooling tower blowdow1.
It is calculated that the above mixed intake TDS concentration would result In a fully mixed downstream TDS concentration of about 479 mg/1. This fully mlxed TDS value Is below the Pennsy1vania Department of Environmental Resources Chapter 93 Water Quality Standard for TDS and will not be harmful to the aquatic life In the River below Limerick.
I Additional evaluations of Beechwood Pit water releases to the i
Schuylkill River are contained In: "Blological and Water Quality s.
Evaluation of Proposed Beechwood Pit Discharge to the West Branch and Mainstem Schuylkill River" by P. L. Hannon and R. W. Blye, RMC-Envircrvnental Services (dated Septenter 3,1985) and " Analysis of I
the Schuylkill River Water Quality due to the Beechwood Pit Discharge" by J. E. Edinger, J. E. Edinger Associates, Inc. (dated August 21, 1985), both reports submitted to the DRBC by Co1pany letter of September 3, 1985.
On August 8,1985, the U. S. Nuclear Regulatory Conmission issued a full power license for Limerick Unit No. I and since that time PECo has been proceeding with the power ascension program. At the present time the unit is unable to proceed beyond approximately 25% of full power because of water use restrictions. Essentially all testing up to this power level has been carpleted and the unit would now be operating at higher levels except for the existing water use restrictions.
Permitting the requested maxinun release of 10 cfs from Beechwood Pit and use of water in ilke amounts at Limerick would l ~
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3 pennit tirnely substantial progress in cormletion of the power ascension program and ccnmercial operation of the unit.
Accordingly, it is hereby requested that the Ccmnission take inmediate action on the Application, as revised herein, pursuant to Section 2-3.9(d) of the Ccmnission's Rules of Practice and Procedure to protect the public Interest and to avoid substantial and irreparable injury to the public and to Philadelphia Electric Canpany.
We have been authorized by the Reading Anthracite Cormany to state that it joins in this revision to the duly 3, 1985 Application and request for Irnnediate emergency action.
Sincerely, f$$vf 9
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TABLE 1 3
-TDS CONCENTRATIONS IN (ag/1) AT SELECT LOCATIONS IN THE SCHUYLKILL RIVER WITH A BEECHWOOD DISCHARGE TDS AT FLOW BACKGROUND BACKGROUND POTTS RIVER TDS TDS 9 POTTS NIXED RIVER MIXED RIVER CITIZENS GAGE e LGS WATER PLANT AT POTTSTOWN AT LGS HOME WATER (cfa) (measured)
(calc.)
WATER PLANT INTAKE COMPANY 250 400 390 440 448 479 275 395 386 432 439 467 300 390 381 424 431 456 350 378 370 407 413 435 400 367 360 392 399 416 450 354 347 377 382 398 500 342 336 362 368 381 Acaumptions:
- 1. Background TDS from Figure 1 at median range.
10
- 2. Beechwood maximum pumping rate (cfa)
=
=
1700
- 3. Beechwood TDS concentration (ag/1) 18
- 4. LGS consumptive water use rate (cfa)
=
- 5. Measured TDS at LGS intake includes the effect of the Pottatown sewage treatment plant (estimated to be 12.4 cia 9 600 mg/1) f l
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'I PHILADELPHIA ELECTRIC COMPANY l
23OI MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 sow ARO e. SAUsm. Ja-(2158841 4000
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~ EUGENS J. GR AOLEY a.
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6 OONALD SLANMSM RUDOLPM A. CMILLEMG
. S. C. M8 AM MAbb T. M. M AMER CONNEbb PAUL AUERSACM
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September 20, 1985
""** '.','tt*": '":
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...A Ms. Susan Weisman, Secretary Delaware River Basin Commission P.O. Box 7360
~ West Trenton, New Jersey 08628
Dear Ms. Weisman:
Transmitted herewith for filing with the Commission is Philadelphia Electric Catpany's Application under Section 3.8 of the Compact for approval, during 1985, of the withdrawal of water from the Schuylkill River for consunptive use at Limerick Generating Station Unit No. 1, when the flow as measured at the Pottstown gage is in excess of 415 cfs (268 mgd) and the dissolved oxygen levels in the Schuylkill' River at or below Limerick exceed the values incorporated in Docket No. D-69-210CP (Final) (Revised) of May 29, 1985. This is a reduction in the existing flow restgaint of 530 cfs.
This filing consists of six copies of the following documents: a) coupleted DRBC Application Form, including Attachments 1 and 2 and Exhibits 1 through 8 thereto; b) conpleted DRBC Environmental Form; and c) conpleted Applicant's Statement - Project Review Fee Form.
Enclosed is Philadelphia Electric Conpany's check in the amount of $100 to cover the Project Review Fee.
l l
As indicated in the affidavit of J. S. Kenper, Vice President, Philadelphia Electric Conpany, which is part of Attachment 2 of the Application, Limerick Unit 1 is prevented from operating at power levels in excess of approximately 254 because of restrictions on water use and, j
consequently, is unable to proceed with the power ascension program. Delays l
l l
l
[-
1 in coupletion of this program and the came will have substantial adverse consequences.rcial operation of Limerick Unit 1 pursuant to section 2-3.9(d) of the consission's Rules Procedure to protect the public interest and to avoid substantial and irreparable injury to the public and to the Conpany as described mor Mr. Kenper's affidavit.
u y in Connunications regarding this Application should be directed to the undersigned.
Very truly yours, Lf Edwar G. Bauer, Jr. /
EGB,JR:pkc Enclosures 0077q
$e
Dellwcre Rivcr Basin C:mmissian No.
4515 APPLICANT'S STATEMENT - PROJECT REVIEW FEE (See Reverse side For AdditionalInformation)
- 1. % and h d W Philadelphia Electric Co.apany 2301 Market Street, Philadelphia, PA 19101
- 2. Norsed d W bI"" rick Generating Station 3
. i..
Interim Consumptive Water Supply Docket #
- 3. Type of Project Check Applicable item (s)
(a) impoundments (b) diversions of water into or out of the Delowore River Sorin.
(c) industriol water use and waste treatment focilities (d) electric ;:n...; and transmission facilities (e) p.:s *-
pr' duct pipelines (f) stroom encroockments: and (g) withdrawol of ground water
- 4. Project Cost Foctors (d'.;'1 oil lines using Zero where opplicable)
Item Estimated. Cost
- o. Design 0
- b. Supervision of Conseruction 0
ce Legal Services O
- d. Contract Adminiseration 0
- e. Land 0
- f. Motenals g g gr.:.C. u....
., - u o,. w ms v.o :os m., : -.>.-
s....i i....cn e m TOTAL ESTIMATED PROJECT. COST.-
0
" *.J p.,no,,,jg
,g, Non-structural - temporary reduction'of.- 530 cfs flow res'tirain' t
.to 415 cfm at _P tt3.tO!ML_SAER_.f9I Clle Jtema.inier qt._1RSS.
O
- 5. Filing Fee Schedule (Check applicolle item (s))
(The filing fee is the greater of (a) or (b))
Connputation:
_A._(o) minimum fee: $100, for any project; or (a)$
100.
_(b) alternative fee I
E (b)
_(1) 1/10 of 1% of estimated proje:t cost up to $1,000,000.
(1)$
(2) 1/50 of 1% of remaining cost above $1,000,000; but not (2)$
to exceed a rnoximum fee of $50,000 as to any one project, exclusive of odded environmental fees.
Total $ 100.00
- 6. Filing Fee Requ. red with Application
- Pfeone enclose check in this amount with application. Check shovid be mode payoble to Delowore River sosin Commission.
NOTE: Shovid this project require on Environm.ntalimpact Statement or on En..w
.O Assessment, you will be notified at a later date and on Applicant's Statement.Environmensel Review Fee will be forwarded for completion and payment of o; ": "_ fee.
(2/ f"'M signeur.#.rtifying'om 4 Do,. -
70 35
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Vice President. En=heerina & Research Dept.
3 s.
7 3
ACKNOWLEDGMENT SY DRSC OF FEE PAYMENT...,,
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1 del. AWARE RIVER BASIN COMMIS510N Type of Application: (Check one or more - see reverse side) 4 (a) Addition to the.Comprehen'siv s P lan........................( )-
~.
(b) Change in a CoInprehensive Plan Pro ject....................(X) l -
(c) Approval under Section 3.8 of the Compact................. (x)
(d) Inclusion in "A-l.ist" of the Water Resources Progresa......... ( )
l Pursuant to the Delowere River Basin Compact and the Rules of Practice and Procedure of the For Use of Commission Delaware River Bosin Commission, cpplication Docket No.
is hereby anode for review of the project des-Date Received -
Action by Commission cribed below:
a g..
(A)
Application From:..
Nome-Philadelphia Electric Co.-
Mailing Address 2301 Market Street, l
Philadelphia, PA 19101 Telephone (215) 841-4000 Nome of Counsel Edward C. Bauer, Jr.
I and Eugene J. Bradley Nome of Engineer v. s. Boyer (8)
Type of Project: (Check)
(I) Impoundment................( )
(4) Stream Encroachment.......( )
l (2) Withdrawal of Water......... (X)
(5) We ll..................... ( )
(3). Dispmol of Westes...........(.)
@) Oth er.................... ( )
(C)
Description of Project:
For the balance of 1985. withdrawal of unear fenm rh,Schuylkill River for consumptive use at Limerick Generating Station Unit No. I when the' flow at Pottstown gage is in excess of 415 cfs (268 agd) and dissolved oxygen levels exceed values incorporated in Docket No. D-69-210CP (Final)
(Revised) of May 29, 1985.
1 I
Signcture of Authorized Person, $SWL Name John S. Yamne'r Titic Vice President, Eng.6Res.
Date Sentamhor ?n fonc f
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Deloween River Basin Commission ENVIRONMENTAL FORM SEP 201985 Applicant Philadelphia Electric Company Date Title of Project Interim consumptive Water supply Location Limerick Generating Station DRBC Docket No.
l.
List any significant environmental impacts, beneficial and adverse, caused by the proposed action.
The beneficial impact of the requested change to Schuylkill River withdrawal limitations from 530 cfs to 415 cfs for the balance or 19u3 will oe to penau.
scheduled operation of 1.imerick, already evaluated by the DRBC.
See, DRBC FEA for Neshaminy Water Supply System (August, 1980); DRBC Level B Study; and AEC/NRC FES for Limerick (November 1973 and April 1984). There will be no significant adverse impacts. See Attachment,1.
2 What mitigati,ng measums will be imod to reduce or elleviate the adverse environmental imposts ?
There will be no adverse impacts from the channe.
Thus. no mitinatine measures need be undertaken.
See Attachment 1.
3.
Summarize the alternatives considered.
The alternatives considered were (1) no action, (2) release of water from the l
Ontelaunee Reservoir, (3) release of water from Green Lane Reservoir, (4) release of water from Blue Marsh Reservoir and (5) release of water from Beechwood Pit
(
(see Attachment 2).
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4 List any known objectors to the proposed action.
None.
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ATTAOfENT 1 Application of Philadelphia Electric Covpany For fenporary Withdrasal of Water When Flow at Pottstown Gage is in Excess of 8*15 cfs Beneficial Incacts to the environment. The availability of cooling water during the remainder of 1985 for Limerick wl11 enable the Linarick Generating Station to couplete 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 determined that the supply of cooling water for Limerick provides a benefit to the envirarment. As DRBC stated in its most recent envirorurental review of the supply of supplemental cooling water for Limerick, "doctrnents prepared after DRBC's Final EIS on the Point Pleasant Diversion Plan, issued in 1973, support the conclusion that the proposed project would be a feasible and beneficial i
use of water resources." DRBC Final Envircrvnental Assessment for the l
- r. ?
Neshaminy Water Supply System, Part III, p. 2-53 (Adgust 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 l
l 18, 1981). Accordingly, DRBC has recognized that the use of Basin water resources to provide cooling water for Linarick constitutes a beneficial use.
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l L
i
2-Q 4
As to the specific need for the electrical power to be generated by the Limerick Generatir4; Station, DRBC has rolled upon the findings of the Nuclear Regulatory Comnission (previously the Atanic Energy Comnission) in its own environmental statements for Limerick. See Docket No. D-69-210 CP (Final) at pp.1, 6-8 (Novenber 5,1975).
In Issuing construction pennits for Limerick, the AEC detennined that there is a need for the electrical power to be generated by Limerick.
See AEC Final Envircranental Statement Related to the Proposed Limerick Generating Station, Units 1 and 2, Docket Nos. 50-352 and 50-353, Ch.
9 (Novenber 1973). At the operating IIcense stage, the MtC similarly foted a stbstantial benefit to the environnent to be dortved from the 4
operation of the Limerick Station in the annual production of approxinately 10 billion kWh of base load electrical energy. See MtC Final Environmental Statement Related to the Operation of Limerick Generisting Station, Units 1 and 2, Docket Nos. 50-352 and 50-353, Section 6.4.2 (April 1984). The NRC issued the full power operating IIcense on August 8, 1985.
j' Further, in an order entered August 27,1982, 'the Pemsylvania PUC expressly stated that "(t)he pubile Interest requires...
(t)lme1Y completion of Limerick Unit 1" and further stated "we encourage the Comany to comlete this unit as rapidly as possible consistent with the pthile safety.",Pemsylvania PUC, Opinion and Order, Docket No. I-80100341 (August -27,1982) (emphasis added) (pp.
23-25). Accordingly,~there exists a stbstantial benefit to the.
envircrvnent and the ptblic In the ccmnencement of comnercial operations at Limerick as soon as possible.
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- 0 No adverse Incact by terrporary reduction of 530 cfs flow constraint to 415 cfs. DRSC Dncket No. D-69-210 CP (March 29, 1973) precludes Schuylkill RI er withdrawals for consurptive use for one unit at Limerick whenever river water flows measured at Pottstow1 are below 530 cfs and below 560 cfs for two smits. DRBC's decision to 11mit Schuylkill River withdrasals weien flows are below 560 cfs for two tailts Is intended to maintain stroem water quality, prImarily total dissolved solids levels, within suitable Ilmits. DRBC reviewed the dissolved solids content of Schuylkill River water prior to issuing Docket No. D-69-210 CP (Final) on Noveniser 5,1975, and concluded that-the concentration would be expected to average about 480 mg/1 Just belcw the Limerick blowdows disdsarge pipe (See Docket Sheet 4, item 2.b.).
This value of 480 mg/l represents an increase of 50 mg/l above the original upper envelope curve value of 430 mg/l for natural river f
backgromd, as determined by DRBC, based on data gathered during 1944 1
to 1951 and 1965 and 1966 at a flow of 500 cfs (See Figure 1).
This value represented the effect on the river of two un{ts at full load operation at Limerick. When one unit is operating f.he dissolved solids will only increase by 25 mg/l above the plant intake level at the average consuretive withdrawal rate of 27 cfs.
Company proposes, during the remainder of 1985, to operate only one tritt and to Ilmit withdrmels to river flows above 415 cfs flows.
Under these conditions the dissolved so11ds will not exceed 455 mg/1.
Table 1 has been prepared using the new teper envelope of TDS data frcrn Figure 1 and shows the expected levels of dissolved sollds at several locations in the river at two withdrawal rates. The flow rates vary from the requested value of 415 cfs up to 550 cfs. The background river TDS at Limerick (measured) are values taken from
4-i Figure 1 vditch were determined by field sanplIng in front of the plant.
The backgromd TDS at Pottstown water treatment plant was calculated by reducing the measured value at Limerick by the effects of the Pottstom treament plant. This water was passed through the Limerick plant, the TDS was concentrated in the plant as water was evaporated in the 4
cooling tower, the blowdown was discharged back to the river and mixed with the Instrean flow to determine the TDS levels at the Citizens Home Water Conpany. The rate of 32.5 cfs is shapet t-me that is the maxlaun withdramm1 for one unit during the most severe meteorological conditions. The 27 cfs rate represents the average consusptive use for the full year. It is calculated that 26 cfs is the maxinun consuiptive rate to be experienced during the last three months of 1985. At 26 cfs the dissolved solids value below Limerick will not exceed 455 mg/1. These withdrawal rates are consistent with the values shown in the' Environmental Report - Operating License on Table 3.3-1 as i
submitted to the NRC. Said table lists quantitles for two units which have been reduced by 50% to reflect one unit operatf.
It is sham in Table 1 that withdrawal of 27 cfs at flows dovei to 415 cfs will not result in TDS levels above 455 mg/1, the value considered as acceptable during the evaluation made prior to issuance of the Docket No. D-69-210 CP (Fina O in 1975.
Conpany has had an evaluation of the proposed reduction of the flow constraint from 530 cfs to 415 cfs. At a river flow of 415 cfs it is expected that a reasonable maxinun withdrawal for full power
- operation would be 27 cfs for evaporative cooling and 10 cfs for.
cooling tower blowdom. These withdrmvels and discharge of 10 cfs i
blowdown would leave 388 cfs as the fim downstream of the discharge.
4
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Any loss of fish due to inpingement will be Insignificant because of the small volune and percentage of River flow to be withdrawn for one unit operation. An acceptable level of Invect was expected by the MtC (FES) due to two.uilt operation at 560 cfs (74 cfs - 13.2%
withdrawal from River); the present situation is an 8.9% withdrawal (37 cfs) at 415 cfs. Critical maximun Intake velocities will remain below the level at elch fish become trapped and Inpinged on the screens. Other design features of the intake, e.g., flush alignnent with the strean bank and the open construction of the structure, will also serve to minimize impinrement at the new flow limit, as has been the case at the higher limit flows.
Discharge considerations include teroperature and chemical effects. Thermal effects on the blota will be minor and acceptable as previously evaluated.
Evaluation of water quality effects due to blowdown discharge.
. under the new flow conditions was based on March 1979_- Decent >er 1984, September-Novent>er quarter, maxinun and median values for selected t
conservative parameters considered of Interest and is found in the FES (Section 5.3.2.3) (copy attached). The maxinun concentrations observed in the fall quarter were multiplied by a concentration factor of 1.0696 which represents a 6.96% increase in constituent concentration due to a River flow reduction from 415 to 388 cfs; the 27 cfs being lost due to evaporatlon. (Table 2)
Only Iron and chromIun in the fully mixed domstream waters were predicted to exceed the nunerical criteria in PA DER Chapter 93 Water e
Quality Standards. UtIIIzation of the seascoal maxinun iron concentration is a conservative approach because Iron concentration
s does not show a negative correlation with flow and therefore maxinun concentrations are not expected at low flows. Both the extrame source water intake concentration and the fully mixed domstream concentration presented in Table 2 are much lower than the values previously evaluated and are found in Section 5.3.2.3 (copy attached) of the FES.
The domstream maxinun fully mixed chromlun concentration is found to exceed the state standard for the autum quarter fram the maxinun source water concentration also exceeds the standard. Such high source water concentrations are infrequent and not directly related to low flows. The FES (Section 5.3.2.3) (copy attached) recopized that occasional exceedances of applicable standards would occur due to infrequent source water exceedances that were tmrelated to plant operation. The autum quarter median concentration is 0.009 mg/l and reflects the more' prevalent range of values in the Schuylkill. At median values there would be no exceedance of the water quality standard.
Both zinc and copper have nonnunerical bloassap criteria.
The autum, maxinun fully mixed dcwnstream concentrations for zinc and copper exceed the values considered safe for long tenn exposure of fish based on available bloassay data. However, this situation was previously analyzed and is found in the EROL (Section 5.3) and the FES (Section 5.3.2.3) (copies attached).
This analysis would be unchanged as a result of lowering the flow Ilmit. As fomd previously, high fully mixed concentrations are a direct result of the high seasonal maxinun source water concentrations.
The relationship between anblent zinc and copper concentration and flow is such that the negnitude of these parameters in the source veter is not expected to be any higher l
at the lower limit flow than at the previously evaluated higher limit l
flow.
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4 TABLE 1 l
TDS CONCENTRATIONS IN (ag/1) AT SELECT LOCATIONS IN THE SCHUYLKILL RIVER AFTER LOWERIlfG THE TRIGGER FLOW TO 415 cfm TDS AT TDS AT FLOW AT BACKGROUND BACKGROUND CITIZENS CITIZENS POTTS.
RIVER TDS TDS S POTTS.
HOME WATER HOME WATER GAGE S LGS WATER PLANT COMPANY COMPANY (cfa)
(measured)
(calc.)
(assumption 3 ) (samumption 4 )
415 425 420 455 460 430 420 415 447 453 460 413 408 438 444 490 407 402 430 435 500 405 400 428 432 520 400 395 421 426 550 392,
387 412 416 Ammumptions:
- 2. Measured TDS at LGS intake includes the effect of the Pottatown aewage treatment plant (estimated to be 12.4 cfm 8 600 mg/1) 3.
LGS consumptive water use rate (cfs) 27
=
4.
LGS consumptive water use rate (cfs) 32.5
=
t
-,.,..-v__e
1 TAB 1.E 2 1
March 1979 - December 1984 4th quarter constituent concentrations at Sc huyl k i ll Station S77660 (intake 3 and full y mixed concentrations under conditions of 415 cfs River flow and 27 cf s consumptive withdrawal.
S77660 Conc.
Fully 4th'Ouarter Factor:
Mixed Parameter max. Value x
1 0696 Conc.
~
Criterion TOS 425 1.0696 455 500 Fe. '~
0 028 1.0696 0.030
'.- 0.05
-15 1 42 1.0696 1.51 =
Pb Mn 0.29 1 0696
'O.31 1.0 Sulfate 141 9
'1.0696 151.7 ISO Zn 0 62 1.0696 0 66 Bioassay Cu 0.03 1.0696 0.03 Bioassay Cr 0 104 1 0696
. 0.111
. 0.05 e
8 t
5 4
b e
LIMERICK GENERATING STATION FINAL ENVIRCNiENTAL STATENNT SECTIONS 5.3.2.2 Ato 5.3.2.3 t
e
- - --- -----~
I 1*
Water quality impacts in the vicinity of Bradshaw Reservoir, in the East Branch of Perkiomen Creek, in the Main Stem of Perkiomen Creek, and in the Schuylkill River may result from the creation of the Bradshaw Reservoir, the introduction of Delaware River waters into the Perkionsg Creek watershed, or the discharge of physical and chemical pollutants to the Schuylkill River during Limerick operation.
The potential #for impacts to receidng water quality was assessed during the construction permit review (FES-CP Sei:tions 5.2 and 5.4 and the NRC ASLB Initial Decision of June 14,1974). There have been changes in the volumes and concentrations of waste in the station effluents as a result of finalization of plant design and updated environmental data (see Sections 4.2.3, 4.2.6, and 4.3.2).
The resulting changes in potential water quality impacts are discussed below.
5.3.2.2 Thermal Impacts of 81owdown Discharge on the Schuylkill River The applicant has made several modifications to the design of the blowdown discharge system since the issuance of the FES-CP. These changes and.the cor-responding design parameters.that were evaluated in the FES-CP are given in Section 4.2.4.
Because the blowdown diiHi: hah system has been redesigned, the applic nt has re-evaluated the thermal plume predictions to ensure that the system will result in downstream river temperatures that are in compliance with the thermal limita-tions set by the DRBC in its Water Use Approval 0-69-210CP (final).
The applicant has provided a. thermal analysis revised from that presented at the CP stage.
The revised analysis considers the final design of the Limerick blowdown diffuser, its location at the tip of Limerick Island, revised blowdown estimates, and updated Schuylkill River flow / temperature data.
The analysis in I
l the FES-CP considered anticipated winter and summer discharge conditions and assumed mixing of the blowdown with one-half of the available Schuylkill River i
I flow at the site.
The revised analysis presented by the applicant used'the predictive technique of Jirka and Halemean (1973), which does not account hr surface heat loss or l
interfacial mixing (conductive heat loss across plume boundaries) in its pre-dictions, but is based on heat loss through dilution with ambient river water.
The analysis considered annual average, monthly average, and extreme combina-tions of Schuylkill River flow rate, Limerick blowdown (i.e., diffuser) flow rate, and river / blowdown temperature difference.
The extreme condition con-sidered the 7Q10 river flow rate and October Limerick blowdown and river tem-Peratures.
Using blowdown temperatures expected to be exceeded 505, 55, and 1%
of the time, the applicant's model simulated the expectr.i temperature rise 15.2 m (50 feet) downstream of the diffuser after the L 'merick blowdown had 1
mixed with one-third of the river flow at the site.
The results of the simula-tions are given in ER-OL Table 5.1-1.
For the blowdown temperatures expected to be exceeded IX of the time,'the largest increase in temperature expected 15.2 m (50 feet) downstream ~of the diffuser is predicted to be less than that predicted in the FES-CP, assuming mixing with only one-third of the river.
e These predictions are summarized in Table 5.1.
The extreme case analysis using the 7Q10 and October 1% exceedence blowdown temperature indicates an in-river temperature rise 15.2 m (50 feet) downstream of the diffuser of 2.9'C (5.3*F).
This value is comparable to the result of the NRC staff's worst case analysh given in the FES-CP (2.8*C, 5'F).
Limerick FES 5-3 l
1 J.
Table 5.1 Thermal analysis summary Schuylkill River flow rate at Temperature difference, Downstreas temperature Condition diffuser e as*
blowdown vs. river, *C rise. *C c
FES-CP Winter 6.16 13.7 1.17 Summer 3.22 2.8 0.556 ER-OL**
i Winter 20.94 19.46 0.8 Summer 10.8 13.34 0.89 j
Average 17.8 17.8 0.72 1
- FES-CP values represent one-half of river flow at the site passing over the diffuser; ER-0L valuy represent one-third of river flow at the site passing 4
over the diffuser.-
S
- Values shown for temperature differences are bas'ed on Limerick blowdown temperatures expected to be exceeded 1% of the tree.
t The results of the revised analysis indicate that, based on dilution with the i
assumed one-third of the river flow passing over the diffuser, complete mixing is accomplished within a short distance of the diffuser. The river is relative-ly shallow at and immediately below the' discharge so that rapid mixing would be expected.
The predicted temperature rise values are well below the DR8C-speci-fied allowable surface temperature excess (2.8'C, 5*F) for all but the severe The Limerick discharge is expected to be in compliance with the applic-case.
i able limitations because (1) the river channel widens downstream of the dis-charge, the additional flow from the river channel' on the other. side of Limerick Island is available for mixing immediately downstread of~the discharge, and (2) the allowable excess surface temperature zone (46 m by 1067. e, or 150 feet p
by 3500 feet) is large compared to the area predicted to be needed for reduction i
of the excess surface temperature to below the'2.8*C (5*F)-allowable maximum.
5.3.2.3 ~ Nonthemal Water Quality Impacts Point Pleasant Diversion: ~ Delaware River and Bradshaw Reservoi:-
The potential for. adverse impact to the quality of surface water aad ground-water in the Delaware River and in the vicinity of the proposed Bradshaw Reservoir has been assessed by the Commonwealth of Pennsylvania (Penna, 1982).
This assessment considered impacts resulting from withdrawal of water from the 4
i river at Point Pleasant and the possible introduction of toxic substances into the proposed Bradshaw Reservoir and subsequently inb the Perklosen Creek water-shed.
The assessment concluded generally that the withdrawal will not result in L
adverse japacts to the water quality of the Delaware River downstream of Point Pleasant.
Specifically, the assessment found (1) the operation of the Diversion will not compound existing water quality problems in the Delaware.and Raritan 2.
Limerick FES 5-4
E-Canal (which withdraws water from the river at a point about 1600 m (1 mile) downstream of the Point Pleasant Diversion); (2) there will be no,ignificant effect on concentrations of dissolved oxygen, trace organic substances, and
==
suspended solids in the upper estuary, even during low flow and summertime flow conditions; (3) there will be no significant adverse effect on the assimilative x-capacity of the river and estuary; and (4) there will be no alteration to the concentration of trihalomethanes in the river as a result of the operation of r
the diversion (these concentrations have been reported to be below the level of detection in the City of Trenton's raw water supply).
m 5
The DRBC assessment (DR8C 1980) notes,that although the operation of the diver-
~~
sion will result in less flow below Point Pleasant being available to dilute substances introduced to the river below the diversion, the concentration of r
organic substances delivered to Point Pleasant-from upstream drainage will not be affected by the diversion, because they would be removed proportionately with flow.
Additionally, the assessment states that changes in water quality Z-downstream of the diversion are not expected to be measurable as a result of its operation.
c Based on a review of the Pennsylvania and DRSC assessments and on a review of the DR8C Level 8 Study of the Delaware River, the NRC staff concurs with the y
above assessments of the likely impacts to Delaware River water quality as a
{
result of operation of the Point Pleasant Diversion. -
With regard to the proposed Bradshaw Reservoir, the DRSC examined the potential
?
i for eutrophication in the reservoir (DR8C,1980).
The DRBC stndy concluded that j
although a eutrophication potential could be demonstrated, the short retention g
time of 3 days or less and the small reservoir size would not indicate a strong potential.
The assessment concluded that these same factors would preclude,the
_E buildup of concentrations of algae and that the reservoir may in fact operate as a phosphorus sink, because of settling of particulates during retention. The g
Pennsylvania assessment of the water quality aspects of Bradshaw Reservoir g-concurs with the DRBC assessment (Penna,1980).
a=*
, 9, The NRC staff has examined the quality of the water fo be delivered to Bradshaw t
Eir Reservoir via' the Point Pleasant Diversion.
Summaries of the available data on gii Delaware River water quality are in Section 4.3.2.
With regard to the applic-able general criteria of the DRBC and Pennsylvania and based on a review of the pm tY data collected by the applicant and others, the NRC staff concludes that the water quality of the Delaware River in the vicinity of the Point Pleasant Diver-sion is good and that the observed concentrations of toxics and detrimental substances are very low. The NRC staff concurs with the water quality character-izations of this reach of the river as presented by the DR8C and the Pennsylvania DER in their impact assessments of the Point Pleasant Diversion. The NRC staff
=.
notes that this water, which will be delivered to Bradshaw Reservoir, has been characterized by the Pennsylvania DER as being of satisfactory quality to be w
used for water supply, m
The NRC staff has considered the potential for groundwater contamination that
=
may result from seepage of water and toxics from Bradshaw Reservoir. Under the E
requirements of the Safe Drinking Water Act, the EPA has established National Interim Primary Drinking Water Regulations (40 CFR 141) and National Secondary
=
Drinking Water Regulations (40 CFR 143).
Although these regulations apply Limerick FES 5-5 g
+
y-Nm K
\\
1 g
e specifically to waters that have been processed in &nd delivered to a customer i
i from a public water system and not raw, untreated waters like those to be trans-ported to the proposed Bradshaw Restrvoir, they do contain maximum contaminant 1evels (MCLs) far several impurities of concern la potable water supplies. The staff is aware that there are several individual drinking water wells in the vicinity of the proposed Bradshaw Reservoir locaties (response to staff question E240.24).
Even though there is no statutory mquirement for water in these wells to meet the criteria established under the Safe Drinking Water Act, in order to take a conservative approach, the staff compared the quality of the Delaware River water to the MCLs established under the Act.
j AreviewofthedatawithrespecttotheMCLsehtablishedpursuanttotheSafe i
Drinking Water Act indicates that six different constituents have been measured at least once at concentrations in excess of the McLs. These are pH, cadmium, chromium, iron, manganese, and coliform bacteria.
The EL for pH, cadmium, and
. chromium have been exceeded infrequently.
For example, records for 1975-1982 j
show that cadmium MCLs were exceeded only in 1976, and only one chromium value i
1 in excess of the MCL was recorded.
The average values for these constituents have not been found to be in excess of the corresponding MCL. For the remain-ing constituents, the average values at both the proposed intake location and i
{
the sampling location immediately upstream in the Delaware River have been found to exceed the corresponding MCL as shown in Table 5.2 below.
These measurements do not represent violations, because the provisions of the Act do not apply to' i
the waters of the Delaware River that would be withdrawn at Point Pleasant nor to the Bradshaw Reservoir waters, both of which are untreated supply waters.
Iron and manganese at concentrations typically encountered in surface waters are not harmful to human health. Control of the concentrations of these minerals j
in domestic and potable waters is desirabl.e because they have such adverse aesthetic effects as coloring the water, staining laundry, and imparting objec-1 j
tionable tastes to beverages.
i Table 5.2 Average values of water constituents in the Delaware River, ag/l j
j Range of mean values Range of max val'ues MCL Intake Upstream Intake Upstream Total Iron 0.36 0.41-0.48 2.06 2.97-3.00 0.30 l
Manganese 0.07-0.08 0.06-0.09 0.37-0.40 0.48 0.05 Califors j
bacteria **
ND 6771 W
154,000 1
i l
- Each sample for fron and manganese consists of three replicates.
- Values shown are number of bacteria per 100 al.
NO = No Data 4
i i
i a
l Limerick FES 5-6
l.
Iron and manganese can be readily controlled to acceptable levels for domestic and potable water use during normal treatment of surface water supplies (1) through such processes as water softening, aeration, filtration, pH adjust-ment, and sedimentation, and (2) as a byproduct of normally applied disinfectants (e.g., chlorine).
In groundwater supplies, these impurities can be controlled to acceptable levels thrudgh the use of water softening treatment systems that are available for individual supply systems (treatment systems for individual dwellings).
The proposed Bradshaw Reservoir will have an impervious liner installed that is designed to greatly reduce any water and waterborne contaminant seepage through the reservoir bottom (response to NRC staff request for information E291.24).
The form of the iron and manganese (i.e., particulate or dissolved) in the reservoir water will also influence the amount of these constituents that may leave the reservoir with any seepage, because particulate forms could reasonably be expected to be upheld within the reservoir by the liner.
Bacteria levels are periodically very high when compared to the MCL of the Safe Drinking Water Act and the Pennsylvania DER and DRBC limitations.
The movement of waterborne bacteria through the reservoir bottom will be hindered by the either on the reservoir bottom or within the soil. presence of the impervious Other factors--such as soil and rock character, bacteria levels in the reservoir waters, growth media en-countered in the soil, and the rate of groundwater movement--would affect the Bradshaw Reservoir. extent of any travel of bacterial contaminants in the vicinity of the In any event, the applicant's data (response to staff request for additional information E240.24) indicate that seepage is expected to flow to the northeast of the reservoir, where there are no existing wells (existing. wells are located south of the reservoir) or recharge areas for existing wells.
Based on the above, the NRC staff concludes that the presence of iron, manganese, and coliform bacteria in Bradshaw Reservoir at concentirations similar to thos measured in the Delaware River in the vicinity of Point Pleasant does not pose a significant threat to nearby existing groundwater wells.
The limited data on several pesticides controlled (in finished water) by the Safe Drinking Water Act are summarized in Section 4.3.2.2.
The limit of detec-tion of the measurements was below the MCLs for all of the parameters except endrin.
All of the measurements indicated concentrations below the level of detection.
Concern over increasing contamination of groundwater by trichlorethylene (TCE) in the area near Point Pleasant has been noted in the DRBC and Pennsylvania DERl assessments.
Data on concentrations of TCE are summarized in Section 4.3.2.2.
TCE appears on the EPA list of priority pollutants, but is not specifically controlled by the Safe Drinking Water Act.
Under the Clean Water Act, the human health criterion for maximum protection from potential carcinogenic effects from organisms is recommended to.be zero. exposure to TCE through ingestion of con EPA has estimated incremental cancer risk increases of 10.s and 10 7 for consumption concentrations over a human lifetime of 27 pg/l and 2.7 pg/1, respectively (45 FR 231, November 28, 1980).
Limerick FES 5-7
Although no MCL has been established for TCE under the Safe Drinking Water Ac the EPA Office of Drinking Water has provided guidance to the Pennsylvania DER These on levels of TCE for toxic effects excluding cancer (Schra effects that is estimated to result in negligible risks to the general human population and is based.on 1005 exposure to TCE from drinking water.
The 1-day suggested-no-adverse-response level (SNARL) is 2000 pg/1, and theT chronic or long-tern level is 75 pg/l (ibid.).
tion of TCE in Delaware River water collected in the vicinity o detection frequency data and the above mentioned toxicity criteria, the NRC was 4 pg/1.
staff believes that the introduction of Delaware River water into Brads Reservoir will not result in a significant threat of contamination of nearby drinking water wells with these substances.
Perkiomen Creek Watershed Assessments of the likely impacts on existing water qu The DRBC both the DR8C (DRBC, 1980) and the Pennsylvania DER (Penna, 1982).
assessment notes a similarity in the quality of the Dela of Perkiomen Creek. The analysis of 1975-1978 water quality data indicates that there are somewhat higher ammonia concentrations in the diversion (i.e.,
Delaware River) water, but that any additional oxygen consumption associated with subsequent nitrification in the East Branch is not likely to cause problems (i.e., depressed dissolved oxygen) because of the low concentrations of pho The assessment concludes that in addition to increasing the median will improve degraded water quality conditions in the m involved.
J of the stream.
)
Phosphorus loadings of the East Branch from the diversion may increase in t headwaters, depending on the amount of settling of particulate phosphates in The assessment concludes, however, that even if no such reduction occurs, the water delivered by the diversion will act to reduce, by Bradshaw Reservoir.
dilution, the phosphorus concentrations of the downstream E diverted water with that of the East Branch of Perkiomen Creek Perkiomen Creek.
the waters are essentially equivalent in quality'and that As indicated in the previous section, because
. result, improving water quality.
of the lack 9f evidence of significant levels of these substances in the Delaware River waters to be diverted, the Pennslyvania DER assessment that the diversion will not result in the transfer of the toxic subst the Perkiomen watershed.
The NRC staff has reviewed the water quality data collected by the applica A com-the Delaware River and the East Branch and Main Stem of Perkio parison was made of selected Delaware River and E Calculated which the diversion it, most likely to be operating) through 1978.
5-8 Limerick FES
i 95% confidence intervals of sample mean data show overlapping intervals for only two of eight parameters tested (biochemical oxygen demand and total dis-solved solids) indicating comparability.
Tis estimates of the interval bound-artes encompassing the mean values indicated that the Delaware River waters were higher in concentration of ammonia and nitrate nitrogen, orthophosphate x
phosphorus, and total fion.
The pH value of the river was also indicated to j
be higher than the creek headwaters.
The calculations indicated that the East j
Branch headwaters were higher in sulfate concentration.
These data are incon-sistent with the DR8C and Pennsylvania DER assessments with regard to nitrate nitrogen, probably because of the different bases of comparison (the June to l
November period used by the NRC staff versus the entire year used by DR8C).
]
The maximum recorded nitrate nitrogen values of the creek headwaters for all quarters and the median values for the December-February and March-May quarters are higher than the corresponding river values.
h Ignoring any removal of nutrients n Bradshaw Reservoir, the comparison of water quality data through 1978 (the latest available from the East Branch of Perkfomen Creek) indicates that during the expected period of operation of the diversion, ammonia and nitrate nitrogen and orthophosphate levels in the-East Branch h'ead-waters are likely to increase.
However, the downstream areas of the East Branch (represented by sampling locations E22880 and E2800) and the area of the Main i
i Stem of Perkiomen Creek near the Limerick Graterford intake show higher median I
and maximum concentrations of these constituents, especially during the Septem-i ber-November quarters. Thus, the diversion could benefit these downstream areas i
by the addition of waters less heavily nutrient laden during the low flow periods of the year.
l The indicated difference in pH between the diverted water and that of the East Branch headwaters during the low flow periods of the year do not exceed one unit i
and would not cause a violation of water quality standards for the creek.
The indicated higher total iron concentration of the river water for the time period examined is not expected to be a problem in the East Branch because (1) the concentrations are within established water quality limits for the designated i
stream uses; (2) the river concentrations are, based on the calculated confidence l
limits, only about 25 to 30% higher than the headwatier values; and (3) available data on the' East Branch show a decrease in total fron concentrations in the down-l stream direction, indicating an existing removal mechanism or dilution effect.
Based on the NRC staff's review of the available water qualicy data of the i
applicant, the effects of the operation of the proposed Point Pleasant Oiversion on the water quality of the East Branch and Main Stem of Perkiomen Creek is expected to be largely beneficial, as indicated in ne DRBC and Pennsylvania DER environmental assessments.
Schuylkill River j
Assessments of the likely impact of the operation of Limerick on the water 4
quality of the Schuylkill River by the DR8C and the Pennsylvania DER since the 1
issuance of the FES-CP have been limited to consideration of the concentration j
effect of the station's evaporative cooling system on chloride levels in the river.
DER (Penna. 1982) concluded in its assessment that the low concentra-
)
tion factor of the closed cycle cooling system would not cause any violations of water quality standards, even during critical (f.e., Iow) flow conditions in
]
Limerick FES 5-9 6
I
I' the river.
The applicant estimates that the maximum seasonal chloride concen-l trations in the station blowdown will exceed the DER maximum of 150 mg/l only during the June-July-August quarter. However, when this blowdown concentration of 151.2 mg/l is mixed with one-third of the Schuylkill Rivar flow at the site, it would be reduced to about 40 ag/1, only slightly above the ambient river concentration.
The app 11 tant calculates that this would take place less than-91 m (300 feet) downstream of the station diffuser.
l The applicant has estimated the seasonal range and median values of the major water quality constituents in the Limerick discharge on the basis of a simula-tion of station operation, on variations in source water quality over the j
simulation period, and on applicable DR8C constraints on source water withdrawal.
The results of the simulation are in Table 4.3.
The applicant compared the Limerick constituent discharge concentrations after they were mixed with one-i third of the river flow and the corresponding constituent concentrations at the i
Schuylkill River discharge location for the seasonal range and median values (ER-OL Tables 5.3-1 through 5.3.1-4).
The constituent extrema resulting from this comparison were compared with applicable Pennsylvania water quality cri-teria.
The results of the comparison indicate that, for those constituents with numerical limitations, the. Limerick blowdown concentrations would at some time exceed the criteria for 10' constituents (see Table 5.3).
The results did not l
predict that the extrema and criteria would be exceeded simultaneously for all 1
of these constituents.
Of the 10 constituents, 5 extrema are predicted to exceed the criteria even after they six with one-third of the river flow downstream of the diffuser.
For these five (ammonia nitrogen, cadmium, iron, manganese, and i
mercury), all but one of the discharge extrema that exceed the criteria (i.e.,
all but manganese) correspond to the mixed intake extrema that exceed their i
respective criterion, indicating that the constituent concentrations of the source waters exceeded the criteria as well.
For all of these constituents, the corresponding extrema concentrations in the Schuylkill River equal or exceed their respective criterion. With the exception of ammonia nitrogen, the con-stituent maxima predicted to exceed water quality criteria after mixing are those noted by the applicant to be conservative.
That is, they are affected only by the concentrating effect of the Limerick evaporative cooling system and not by direct addition of chemicals during station water use or treatment.
Ammonia nitrogen concentrations are affected as a result of the operation of the station cooling system (e.g., water temperature. change, chemical oxidation) and water treatment (e.g., chlorination) and not by direct treatment with ammonia-containing chemicals.
It is predicted that these constituent maxima will exceed the applicable criteria not only because of station operation, but also because of ambient water quality conditions both in the Limerick source waters and in the receiving water.
Nonnumerical water quality criteria are set for copper, nickel, and zinc.
Com-parisons of the extreme mixed discharge concentrations of these constituents with.the limited median tolerance level bioassay data for species present at the site indicate that the concentrations would exceed those estimated to be j
safe (ER-OL Table 5.3-7), based on long-term exposure.
{
Comparing seasonal median mixed intake, Limerick b:ow3own, mixed discharge, and
{
Schuylkill River webient concentrations of major discharge constitutents, the i
number of constituents exceeding the applicable criteria is greatly reduced, as
]
shown in Table 5.3.
Of the four constituents whose predicted median discharge concentrations exceed the applicable Pennsylvania or U.S. EPA numerical criteria, Limerick FES 5-10
,-----,--,---,-.-----,--------,..-,,-----+~~.---,--,--,--e---
---.,w
, m e-m e w-m.
-,-w,*-
e i,
Table 5.3 Comparison of discharge, mixed river concentrations, and quality criteria for maximum discharge concentrations in excess of criteria 4
Concentration, og/l Schuylkill Mixed Mixed Parameter 810wdown River 1 intake rivera Criterion Total dissolved solids 1136 546 334 460 750 Sulfate 616.7 211.9 163.1 216.1 250 Ammonia nitrogen 9.52 1.60 1.89 1.89 0.02 Nitrite and nitrate 10.99 5.88 3.82 4.05 10.0 nitrogen Cadmium 0.41 0.005 0.012 0.013 0.012 Chromium 0.05*
0.036 0.016 0.043 0.10 Iron 46.1 9.313 13.56 14.761
Mercurys 1.8 2.1 0.5
- 1. 2 0.05 15tation S77140.
28ased on one-third of Schuylkill River flow at the site.
8 Values given are pg/1.
i Source:
ER-OL Table 5.3-6 4
only those for ammonia nitrogen are expected to be above consistently the app 11-cable standard (for every yearly quarter).
Ambient median Schuylkill River values for ammonia nitrogen are also consistently ab6ve the criterion (as are 4
the seasonal median mixed intake water concentrations), yielding mixed river concentrations downstream of the diffuser that are above the criterion as well.
The mixed river concentrations (i.e., median blowdown concentration mixed with one-third of the median river flow rate for the season of interest) for the i
remaining constituents--total dissolved solids, sulfate, and manganese--are calculated to be below their respective water quality criterion limits.
For copper, nickel, and zinc, the seasonal median mixed river concentrations are essentially equal to ambient Schuylkill River concentrations. The calculated median copper and zinc concentrations are below the median tolerance limit after accounting for the appropriate application factor for some resident biota at the site and'above it for others.
The median calculated discharge concentration of nickel. 0.00 mg/1, is below the limit of detection and is therefore believed to be in compliance with the criteria.
4 The predicted mixed discharge constituent concentrations for the Schuylkill River 7-day 19 year low flow (7.1 m /s (250 fts/s)) and for the lowest observed a
river flow during the preoperational sampling program (12.2 m /s (435 ft8/s))
3 4
Limerick FES 5-11 i
6 e
indicate concentrations below those given in Table 5.4.
Only ammonia nitrogen and mercury concentrations are predicted to be above their respective quality criteria.
The ambient Schuylkill River concentrations for these two constituents at low flow conditions were also predicted to be above the criterion values.
A comparison of the predictions for low flow concentration with the predictions based on maximum discharge concentrations taken from the simulation of actual
. Limerick operation and intake and receiving water quality indicates that con-stituent maxima occur at other than low flow conditions in the Schuylkill River.
Table 5.4 Comparison of discharga, mixed river concentrations, and quality criteria for median discharge concentrations in excess of criteria Concentration, mg/l Schuylkill Mixed Mixed Parameter Blowdown 1 Riverz intake 3 river
- Criterion 5 Total dissolved 752 270 221 299 750 solids f58 272 723 296 750 Sulfate 281.5 66.8 66.8 75 250 Ammonia nitrogen 2.78 0.48 0.47 0.56 0.02 2.14 0.25 0.22 0.30 0.02 1.38 0.C3 0.02 0.16 0.02 1.63 0.19 0.07 0.26 0.02 Manganese 1.153 0.326 0.339 0.36 1.0 1From ER-OL Table 3.6-3.
Multiple values represent different seasonal medians above the applicable water quality criterion.
2From ER-OL Table 2.4-12, Station S77660.
3From ER-OL Table 3.6-2.
48ased on mixing with one-third of applicable seasonal median flow, from ER-OL Table 2.4-12; diffuser flow, from ER-OL Table 5.1-1.
8From ER-OL Table 5.3-6.
L The use of chlorine for biofouling control at Limerick will result in the dis-charge of chlorine-containing compounds in the cooling tower blowdown (see Sec-l tion 4.2.6.2).
The appifcant plans to control the addition of chlorine to the cooling systems or alter the blowdown from the unit being chlorinated so that t
the total residual chlorine (TRC) (the sum of the free available chlorine and the combined available chlorine) concentration in the blowdown will not exceed 0.22 mg/l for two-unit operation.
One-unit operation is expected to produce a TRC in the discharge of up to 0.43 mg/l during chlorination (response to NRC staff request for information E291.11). Assuming mjxing with one-third of the Schuylkill River flow at the site and based on complete mixing within 91 m (300 feet) of the diffuser, as indicated for the thermal performance of the dif-fuser, this concentration would be expected to be reduced to less than 0.02 mg/l (a dilution factor of 15) by the time the effluent waters reach the downstream Limerick FES 5-12 J
edge of the thermal mixing zone.
The Water Quality Management Permit No. 4671202 issued by the Commonwealth of Pennsylvania (response to staff request for infor-mation E291.12) currently limits only the concentration of free available chlo-rine in the cooling tower blowdown of each unit, as measured in the station discharge.
The stated limit of 0.25 mg/l allows levels of residual chlorine in the blowdown higher than.;those expected by the applicant during two unit opera-t tion, but lower than those expected during one-unit operation.
The applicant's planned two-unit maximum concentration is about the same as that reviewed by the NRC staff in the FES-CP, which was judged to be sufficiently low to avoid adverse impacts on the quality of the receiving water. Available data from operating power plants indicate that residual chlorine in cooling tower blowdown is comprised nearly exclusively of combined available chlorine.
The staff believes that the Industrial Waste Pemit concentration level will be met during two-unit operation and that concentrations of free available chlorine are likely to be below detectable limits in the blowdown from the unit being chlorinated for the following reasons:
(1) Chlorine biocide addition at Limerick will be controlled by measurement of residual concentration in the cooling tower blowdown, with free available chlorine monitored at the condenser outlet waterbox.
(2) The chlorinated cooling water will be exposed to air, sunlight, and bio-logical growths in the cooling towers.
(3) The chlorinated water will be sampled in the cooling tower basin before discharge (with provisions to terminate blowdown from the cooling tower being chlorinated until the residual chlurine concentration falls within the permitted limit).
The U.S.' EPA New Source Performance Standards for Generating Units (40 CFR 423.15) prohibit the discharge of detectable residual chlorine from either Limerick unit for more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in any 1 day, unless the applicant demon-strates that the units cannot operate within the restriction.
The applicant's current plans call for chlorinating the condenser circ' ulating cooling water system via intermittent 20-minute chlorine biocide additions for a total of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per day per unit.
The releases from this system (blowdown and drift) are much less than the circulating water flow rate, and the system volume is large compared to the blowdown volume during the application period.
A finite time beyond the termination of the addition of chlorine biocide is required for the contents of the system to change completely.
Thus, assuming that a substance added to the system completely mixes with the contents of the system, this sub-stance could be expected to be present--at a reduced concentration--in the blowdown and drift for periods beyond the time it is added to the system.
The applicant's analysis is based on projected Limerick cooling water chemistry, biocide applications of 20-minute duration, and field studies on TRC concentra-tion in an operating power plant.
This analysis indicates that TRC concentra-tion in the station discharge will be greater than 0.1 mg/l (the practicable field detection limit far residual chlorine) for 50 minutes during two-unit operation (one unit chlorinated) and for T/ minutes for one-unit operation (response to NRC staff request for infomation E291.11).
1 Limerick FES 5-13
r The applicant currently plans to chlorinate the condenser circulating waters of only one unit at a time.
This operating scheme is consistent with the current restrictions in the recently promulgated U.S. EPA Final Effluent Limitations Guidelines, Pretreatment Standards and New Source Performance Standards for the Steam Electric Power G_enerating' Point Source Category (U.S. EPA,1982).
Employ-ment of the nonsimultaneous chlorination scheme provides for residual chlorine reduction in comon discharges by dilution with the unchlorinated discharge water and by reaction with chlorine-demanding substances in the unchlorinated waters.
Because residual chlorine is toxic to freshwater life and therefore is controlled by Pennsylvania under the Warm Water Fishes and Migratory Fishes Standards (Penna,1979), these reduction mechanisms are important in attaining l
water quality sufficient to meet applicable standards within the mixing zone and in minimizing the volume of water in the vicinity of the discharge that
.could contain residual chlorine concentrations deleterious to aquatic life.
t The regulations of the DR8C and the PDER permit the designation of mixing areas in receiving waters for pollutants other than heat.
The determination of such l
areas, if any, is done on a case-by-case basis.
For Limerick Generating Station, this determination will be made during development of the NPDES permit. Outside i
of this area, the cooling tower blowdown discharge shall not cause a violation of the water quality standards.
According to these standards (ibid.), substances attributable to waste discharges are not to be present in amounts inimical or 1
harmful to protected water uses or to human, animal, plant, or aquatic life.
A i
water quality standard for TRC for the protection of freshwater organisms, other than salmonid fish, has been established by EPA (U.S. EPA, 1976) under the pro-visions of the Clean Water Act at 0.01 mg/1.
This level was established on the basis of a review of toxicity studies conducted by EPA and others, and is appli-cable to a continuous exposure to residual chlorine.
Other continuous-exposure, safe concentrations or chronic toxicity thresholds have been set by Brungs i
(1973) and Mattice and Zittel (1976) for freshwater organisms. The limitation recommended by both these studies is 0.003 mg/1.
Exposure to residual chlorine at or below this level would not be expected to kill aquatic organisms.
How-l ever, these criteria considered cold water organisms (i.e., salmonid) as well as warm water organisms, and may be unduly restrictive for the organisms in the Schuylkill River.
For comparison, the EPA limitation for salmonid fish is O.002 mg/1.
Other studies by Dickson et al. (1974) and Brooks and Seegert (1978) examined the effects of intermittent exposures of warm water fishes to I.
residual chlorine.
These studies enneluded that exposures to TRC not greater than 0.2 mg/l intermittently for a total of up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per day wou'd "proba-bly be adequate to protect more resistant warm water fish such as the oluegill" (Dickson et al.,1974) and that intermittent exposures to combined available i
chlorine totaling 160 minutes would not kill the most sensitive of 10 warm water fishes tested at concentrations at or below 0.21 mg/1.
The most sensitive species in the latter study was the emerald shiner.
The other species tested were the common shiner, spotfin shiner, bluegill, carp, white sucker, channel catfish, white bass, sauger, and freshwater drum.
The most restrictive chlorine water quality criterion for a fresh warm wat'er j
fishery is that in the EPA " Red Book (U.S. EPA, 1976), 0.01 mg/1. As stated above, the applicant estimates that the proposed operation of Limerick will result in degradation of residual chlorine concentration to less than 0.02 mg/l i
during two-unit operation and about twice that during one-unit operation in an l
area well within the mixing zone established by the DRBC.
These dilution,
Limerick FES 5-14 i
i
..-~....._, - _.,.__._ - _ -. - _.- _ _ _ - -,.,.-.
__.-_-..,_-,,_,_,_.,m._,-.---,__
s 4
4 estimates do not account for reaction of residual chlorine with reducing sub-stances in the receiving water and account for mixing with only one-third of the available flow over the diffuser.
beyond the initial mixing area will reduce residual chlorine levels to thoseC commensurate with the levels identified in the " Red 8ook."
The applicant estimates that the need to chlorinate the station cooling towers will arise infrequently (about four times per year per tower).
The concentration of biocide in the cooling tower basin and in the discharge is estimated to be much higher at these times than during the normal condenser biofouling control applications.
The applicant has stated that blowdown from the cooling towers would be suspended for the period during and after cooling tower blocide treat-ment when the free available chlorine concentration is greater than 0.5 mg/1.
When monitoring indicates that the free available chlorine (FAC) concentration has fallen below this threshold, blowdown would be resumed.
FAC concentrations of 0.25 mg/l (the maximum FAC concentration in the station discharge assuming treatment of one cooling tower and full diluting flow from the remaining un-treated cooling tower) to 0.5 mg/l (the maximum FAC concentration that would exist in the undiluted blowdown) are known to be toxic to aquatic biota.
1' The chlorinated discharge from a treated tower would also contain an at-present undeterminable amount of combined available chlorine, which also is toxic to aquatic biota, in addition to the FAC.
The relatively large volume of water affected by these treatments and relatively long time that the waters containing l
high residual chlorine would be discharged following a cooling tower blocide I
treatment episode would combine, resulting in station discharges that could be toxic to or produce behavioral changes (e.g... avoidance reactions) in biota in the Schuylkill River in the vicinity of the station discharge.
DER, as the NPDES permit issuing agency, has the authority to limit the maximumThe i
allowable concentration of residual chlorine in the station discharge during cooling tower chlorination.
Actions to mitigate these potential impacts are available such as suspending cooling towner blowdown until. residual chlorine concentration degrades to an acceptable level, monitoring TRC in the treated cooling tower basin, rather than FAC concentration alone, as a criterion govern-ing discharge of these waters, and dechlorination, if necessary, to reduce residual blocide concentrations in the discharge be16w harmful levels (although this would increase the total dissolved solids in the discharge).
Chlorination of the plant cooling waters is likely to produce chlorinated com-pounds in the cooling tower blowdown in addition to the active chlorine residual,,
as discussed above.
The 1974 EPA National Organic Reconnaissance Survey (NORS) showed that chlorination of natural surface waters supplying drinking water for 80 cities around the country resulted in the fonnation of chlorinated organic compounds, primarily trihalomethanes (THM). Of these, the predominant compound was chloroform, but bromodichloromethane, dibromochloromethane, and brosoform were included.
In contrast, studies of 14 different water utilities and their i raw water supplies by Arguello et al.- (1970) indicate that TM are found at only low concentrations (0 to 15 pg/1), if at all, in nonchlorinated natural 4
surface waters. The NORS indicates that total organic carbon in the raw water at the time of chlorination and the chlorine dosage are significant parameters governing THM formation.
affects chloroform formation in chlorinated natural waters.A study by Stevens et The results indicate that the rate of format' n of chloroform.(the predominant THM found) increases j
with increasing pH.
a Lirarick FES 5-15
t i
8 A study by Young and Singer (1979) of raw watec chlorination by a water utility and the effects of chlorination and THM formatien in the finished water indicated i
that the presence of free chlorine residuals in concentrations greater than O.4 mg/l appeared to enhance the THM formation.
NRC staff experience indicates that typical target free available chlorine concentrations for biofouling con-trol in power plant heat exchangers are 0.5 to 1.0 mg/l for the duration of t'he appilcation period.
The applicant's target for Limerick is 1.0 mg/1.
Thus, the results of the Young and Singer study would tend to indicate that the proposal to chlorinate to 1.0 mg/l will be conducive to THM formation in the cooling water.
The estimated total organic carbon concentrations in the Limerick intake waters indicate a range of from 0.0 mg/l to 24.1 mg/1, which encoml, asses the i
range of total organic carbon values in the water utility studies. Characteristics of the power plant system not present in the water utility systems that may serve to reduce the THM-forming potential of the cooling water are the short chlorine contact time and the possible THM removal by air stripping (i.e., volatilization loss of chloroform) during passage through the plant cooling tower, as observed by Jolley (1978).
For chloroform, the loss was about 84% in that study.
Additional preliminary information is available from an NRC-sponsored study (Bean et al.,1981; Bean,1982; 8ean 1983) in the form of measures of THM con-centrations in intake and chlorinated discharge samples collected from operating nuclear power plants.
The plants sampled have closed cycle cooling systems, including both natural draft cooling towers and mechanical draft cooling towers.
The cooling water systems of the plants were chlorinated to total residual chlorine levels of 1 to 5 mg/1.
Dechlorination was practiced at one of the plants, and blowdown was held up in one mechanical draft cooling tower equipped plant until the residual chlorine concentration fell below 0.05 mg/1.
The results are shown in Table 5.5.
The ctilorinated discharge samples show chloro-form concentrations typically below 1 pg/1, although one plant had a concentra-tion of 2.4 mg/1.
The chlorinated discharge samples had total THM concentrations as high as 3.64 mg/1, but half the samples measured were below 1 pg/1.
Where i
measured, intake total organic carbon concentration was 12 to 15 mg/1, which is within the range of values predicted for the Limerick intake waters.
The U.S. EPA has published water quality criteria (U.S. EPA,1980a, b, c) for chloroform and halomethanes that will. "when not exceeded, reasonably protect human health and aquatic life" (U.S. EPA, 1980a).
The chloroform concentration at.which only 50% of the test organisms survived for the exposure period, generally 96 days, for Daphnia maana is 28,900 pg/1, while that for Lepomis machrochirus (Bluegill) is 100,000 pg/1.
For halomethanes, the LC50 for blue-gill is stated to be 11,000 pg/1, based on brominated compounds. A no-adverse-effect threshold test was conducted for Daphnia magna, and the corresponding chloroform concentrations were found to be between 1,800 pg/l and 3,600 pg/1.
With regard to human health effects, based only on consumption of contaminated aquatic organisms, the concentration that has been identified to result in not more than a 10.s risk of incremental cancer over a lifetime is 15.7 pg/l chloro-form or other trihalomethane; the corresponding concentration based on consump-tion of contaminated water as well as contaminated organisms is 0.19 pg/1.
l.
Under the Safe Drinking Water Act National Primary Orinking Water Regulations, i
a maximum contaminant level (MCL) has been established for total THMs.This I
MCL is 100 pg/l and is applicable to the delivered water to customers of public water systems that serve 10,000 or more individuals and that add a disinfectant (oxidant) to their water during treatment.
Limerick FES 5-16
Table 5.5 Triholomethane concentrations in unchlorinated intake and in chlorinated discharge cooling water at operating nuclear power plants (preifminary information), pg/l Parameter Intake Discharge Chloroform NO-0.40 0.24-2.4 Bromodichloromethane NO-0.03 NO-0.78 Oibromochloromethane NO-0.04 NO-0.80 Brosoform ND NO-0.30 Total triholomethane NO-0.40 0.25-3.64 Sources:
Bean et al., 1981; Bean 1982 and 1983.
ND - Not Detected The exact THM concentrations in the Limerick discharge cannot be predicted at this time.
The results to date of the NRC research program on THM concentra-tions in the discharges of operating closed cycle nuclear power plants indicate concentrations well below those identified as having adverse effects on aquatic biota and well below the MCL for total THMs (note, however, that the MCL is not applicable to the Limerick discharge or to.the concentrations in the Schuylkill River that may come to exist therein as a result of Limerick operation).
The intermittent chlorination of Limerick cooling waters and the treatment of Schuylkill River water by water utilities prior to consumption serve to mitigate consumer exposure to THMs from Limerick operation and the presently estimated adverse human health risks therefrom.
5.3.2.4 Sanitary Waste Impacts l
The Limerick operational phase sanitary waste system will utilize a readily-available, conventional, secondary level of treatment employing extended aeration.
The system has sufficient capacity when it is operating in the extended aeration mode to treat the wastes (at 107.5 1/ cap / day (28.5 gal / cap /
l day)) of about 350 persons.
During refueling, the system will be operated in a l
contact stabilization mode to treat the wastes of about 1100 persons.
Effluent Ifmitations for this treatment plant are in Pennsylvania DER Bureau of Water l
Quality Management Sewage Permit No. 4672437 and U.S. EPA NPDES Permit No. PA i
0024414, and are given in ER-OL Section 5.4.
The effluent limitations set by l
the permits are readily attainable by this treatment technology, if the system is properly controlled by a qualified operator.
Small sewage treatment plants operated in the extended aeration mode often suffer periodic upsets because of hydraulic overloading and sudden increases in influent organic loading.
These upsets would lead to degraded effluent quality.
Even for periods of less than l
design treatment performance, detectable adverse impacts on receiving water quality are not likely because treated wastes from this system are directed to l
Limerick FES 17 l
t
I LIMERICK GENERATING STATION EROL SECTIONS 5.1.3 AND 5.3
.o LGS EROL of the total discharge.
Therefore cooling tower blowdown is the only heat source considered in the following analysis of thermal e ffects.
Discharge through the diffuser will cause a rapid dilution of the effluent in the schuylkill River.
For typical river flows it is estimated that the effluent will become fully mixed in that portion of the Schuylkill River which passes over the diffuser.
This estimate is based on the results of MIT laboratory model studies on the performance of submerged diffusers in shallow water - (Ref 5.1-2 ).
The initial mixing zone is the region in which nozzle velocities are dissipated and the effluent is fully mixed with the river flow passing over the diffuser.
The estimates of downstream extent of the mixing zones given above are based on methods presented in Reference 5.1-75.
For average conditions (river flow rate of 1910 cfs, diffuser flow rate of 26.8 cfs), the initial mixing zone will be about 150 feet wide and 30 feet long (Figure 5.1-1).
For a high river flow rate of 9800 cfs (1%
exceedance value), the resulting dilution of the effluent would be much greater and the mixing zone would extend about 150 feet downstream.
The areas of these initial mixing zones for average and high river flow conditions are approximately 0.1 and 0.5 acre, respectively.
The mixing zone area for river flows lower
[
than average will be-less than 0.1 acre.
At river current velocity of 1 foot per second (which is less than the mean velocity for average flow), an organism would pass through the initial mixing zone in about 0.5 and 2.5 minutes for average and high river flow rate conditions, respectively.
Table 5.1-1 gives effluent flow rates, dilution factors, and temperature rises for the discharge plume for monthly ' cooling tower blowdown temperatures with 50, 5 and 1% probabilities of exceedance.
Under average stream flow conditions and all blowdown temperature conditions, even a sudden commencement or cessation of discharge flow would not cause the river temperature outside the small area of initial dilution to be changed by more than 2*F during any one-hour period.
Under extreme low flow conditions, a 3-hour gradual commencement or cessation of discharge would not cause the river temperature to be changed by more than 2*F during any one-hour period.
The only set of conditions for which the temperature rise limitation of 5'F is exceeded is for the 1% exceedance blowdown temperature for October and for the 7-day, 10-year low river flow.
Even under this unlikely combination of extreme conditions, the computer temperature rise (5.3*F) is only slightly above the limit.
It is apparent that the likelihood of effluent temperatures being a constraint on plant operation is very small.
The dilution factors presented in Table 5.1-1 also apply to the dilution of chemical constituents in the effluent (Section 5.3).
5.1-3 Rev. 2, 12/81
LGS EROL In'the Environmental Report-Construction Permit Stage (Ref p
5.1-3 ) and the Final Environmental Impact Statement (Ref. 5.1-4),
a constant blowdown of 20 cfs was assumed to mix with one-half the river flow.
Since that time, the system design has been finalized.
Minor changes have been made to the nozzle design, system controls, and the diffuser location.
The blowdown flow rate has.been determined to -vary between 30 and 32 cfs.
One-half to one-third of the river flow will pass over the diffuser.
It has been conservatively assumed that the effluent will have become diluted in one-third of the river flow.
5.1.3.
BIOLOGICAL EFFECTS The following discussion of the biological effects of the heat dissipation system is based primarily on information gathered by the Applicant's ecological consultant in the Schuylkill River, Perkiomen Creek, and East Branch Perkiomen Creek (Sections 6.1 and 2.2), as well as design and operational parameters presented in the ERCP (PEco, Ref 5.1-3 ) and FES (USAEC, Ref 5.1-4), and simulated real time plant operating conditions.
Chemical effects are discussed in Section 5.3.
General:
No rare, threatened, or commercially valuable species were found in 9 years of collecting (1970-1978).
Although all three potentially affected streams suffer from past or present anthropogenic activities (Section 2.2.2), all are biologically productive and diverse.
Schuylkill River:
Only minor impact is expected on all biotic components (Section 2.2) as a result of intake operation and thermal discharge, due to the low proportion of total flow withdrawn and the small localized increase in temperature, respectively.
At present-the area near LGS is lightly utilized for sport fishing.
However, the river was recently designated Pennsylvania's first scenic river, which probably increases its potential for recreational development.
Water quality has been improving and is expected to continue to improve.
An American shad restoration program has been initiated by the Pennsylvania Fish commission.
The river near LGS is not of unique importance i
for the life-sustaining activities of resident aquatic organisms, i
and the discharge will under no conditions block fish movement past LGS.
Perkiomen Creek:
Diversion, by increasing flow and wetted area, should slightly benefit creek biota between the East Branch confluence and intake, especially in low flow years.
A relatively large percentage of total flow will be withdrawn by the Graterford intake, but intake design (wedge wire screen) is expected to minimize impingement, and entrainment is expected to have little or no impact on phytoplankton, zooplankton, or macrobenthos.
Fish entrainment will be reduced by use and location of the wedge wire screens.
The creek near Graterford is not of unique importance for the life-sustaining activities of Rev. 2, 12/81 5.1-4
LCS EROL resident aquatic organisms.
Water level fluctuations downstream of the intake will affect, through alternating inundation and exposure, a small area of stream bottom and associated resident biota.
There is presently an active sport fishery on Perkiomen Creek.
East Branch.Perkiomen Creek:
Changes in abundance and distribution are expected here for some biota in response to diversion.
Changes related to flow augmentation (principally through elimination of intermittent flow in the headwaters and improved water quality in the middle and lower reaches) will generally be beneficial to the creek ecosystem through enhancement of community productivity and diversity.
The recreational fishery is expected to improve.
Diversion may introduce species here and on Perkiomen Creek that have not yet
.been recorded from these creeks.
5.1.3.1 Schuylkill River 5.1.3.1.1 Intake Operation of the LGS cooling water intake will affect some aquatic biota through impingement and entrainment.
Some organisms too large to pass through the 6-mm mesh traveling screens will become impinged and disposed of with the trash.
It
(
is assumed that smaller organisms that pass through the intake screens will suffer 100% mortality as a result of extended exposure to temperature differentials and physical and chemical stresses within the cooling system.
For purposes of impact evaluation it is assumed that at the annual average withdrawal rate, approximately 2.6% of river flow will be'used at mean flow'(50.2 m /s), 9.3% at 7-day, 10-year low flow (7.0 m /s), and 27.2% at lowest recorded flow (2.4 m /s).
Information derived from 316(b) studies conducted at Cromby (CGS, 13 km downstream of LGS, PECo (Ref 5.1-5), Barbadoes (BGS, 40 km downstream, PECo (Ref 5.1-6 ),
and Schuylkill (SGS, 67 km downstream, PECo (Ref 5.1-7) Generating Stations is presented where applicable, a.
Impingement Large invertebrates and juvenile and adult fish will be impinged.- The number of organisms impinged is largely a function of intake location (as related to the variety and distribution of nearby fauna) and design.
An intake not located in an area of high macroinvertebrate and fish density, and withdrawing a relatively small volume of water at low velocity, generally has a low potential for deleterious impingement impact (USEPA:p. 19 Ref 5.1-8).
Based on these criteria the Schuylkill intake is not likely to impinge large numbers of macroinvertebrates or fish.
5.1-5 Rev.
2, 12/81
LGS EROL Macroinvertebrates:
Several important macroinvertebrates I
(crayfishes, Cambarus bartoni and Orconectes spp.; snails, Goniobasis virginica; and leeches, Erpobdella punctata) are large enough ( 6 mm) to be impinged.
However these are benthic dwelling organisms which were never collected in drift samples near LGS (Section 2.2.2.1.6).
Thus it is highly unlikely that a significant number of these organisms will be impinged.
Crayfish were impinged at CGS, BGS, and SGS, but only one at each station.
Fish:
The intake location-is not an area of concentrated abundance for any important fishes (Section 2.2.2.1.7), and rare, endangered, or commercially valuable species do not presently inhabit this reach of the Schuylkill.
American shad may be restored to the river during the life of the plant (Section 2.2.2.1.7).
Striped bass and other migratory species could also be re-established, or in the case of the American eel become more abundant, when fish passages are constructed at downstream dams.
Fish passage facilities have been installed at Fairmount Dam.
Spawning, localized migration, and feeding of resident fishes
~
take place in the general intake location, but the area is not of unique importance for these activities.
In addition the area is only lightly utilized for sport fishing (Harmon, Ref 5.1-9).
The following operational and design features will help minimize entrapment and impingement of fishes: (1) the volume of water withdrawn (Section 3.3) will be small relative to total river flow, (2) at average (0.56 m /s) and maximum (0.70 m /s) blowdown, design approach velocities to the screens will be 0.13 and 0.16 m/s, respectively, under low flow (7-day,10-year) clean screen conditions, (3) the face of the traveling screens will be set nearly flush with the river bank and preceded only by trash racks, so that lateral passage and stream flow may assist fish to escape, and (4) no curtain or skimmer wall (commonly a significant contributor to impingement) will be used.
The differences in elevation of the river bottom, front foot wall, and interior structure floor will create a pool about 1.7 m deep immediately in front of the traveling screens (Figure 3.4-9 ).
This pool may attract and concentrate fish which increases the potential for impingement.
Impinged fish that are carried up on the screens will be deposited in a trash receptacle.
Rates of impingement will vary among species.
Fishes that migrate or undertake frequent localized movements are generally more susceptible to impingement than sedentary species.
The catadromous American eel and anadromous American shad (if restored to the river) are both likely to migrate upriver and downriver past LGS.
However, studies at power plants on the nontidal portion of the Delaware River (Lofton, Ref 5.1-10) have indicated that neither juvenile nor adult shad nor eels are frequently impinged from free-flowing waters, and the 316(b)
)
studies at CGS and BGS on the Schuylkill River indicated few eels Rev.
2, 12/81 5.1-6
..~
LGS EROL were impinged. -The majority of fish impinged at CGS were brown 4
bullheads and white suckers.
s probably as 'a result of localized spawning movements.Most were collected in s It is probable that a.similar situation will occur at LGS.
- Goldfish, brown bullheads, and pumpkinseeds exhibited considerable movement near LGS.
The redbreast sunfish does not move frequently or far enough to cause serious movement related impingement, but due to i
its high abundance is likely to be regularly impinged.
At CGS and BGS swallowtail shiners and spotfin shiners were infrequently found in impingement collections; banded killifish and tessellated darters were not collected.
However it is difficult to determine whether these' species actually avoid impingement, or, due to their small size, are entrained.
Fish impingement at LGS is expected to be below that recorded at CGS (11,199 fish impinged per year) and BGS (3319) because of the improved intake design at LGS.
LGS intake capacity is only 15%
i and 41% of that at CGS and BGS, respectively.
LGS design intake 1
average velocity is approximately one-third that at CGS and BGS.
b.
Entrainment a'
Drifting phytoplankton, zooplankton, benthic macroinvertebrates, and fish eggs and larvae will be 1
entrained by the LGS intake.
Weekly withdrawal projections summarized in Table 5.1-2 were used to 4
estimate entrainment.
biota, except fish eggs and larvae,It is assumed that all drifting are uniformly
. distributed in the Schuylkill, and that entrainment loss will be proportional to water withdrawn.
Fish eggs and larvae were not uniformly distributed in the river near LGS (Section 2.2.2.1.7); and therefore loss of these organisms was estimated from densities within the portion of water withdrawn.
Phytoplankton and Zooplankton:
The effects of entrainment on phytoplankton and zooplankton near LGS are expected to be minimal because (1) the proportion of river flow withdrawn will be low, i
(2) population densities near LGS are known (phytoplankton) or presumed (zooplankton) to be low (Sections 2.2.2.1.2 and 2.2.2.1.5),
periphyton which continually enters the water column due to(3) most ph scouring action, and (4) both components typically have high reproductive rates.
Macroinvertebrates:
Most important macroinvertebrate species rarely drift (Section 2.2.2.1.6).
For those that do, only a small proportion of the benthic population drift at any one time (Table 2.2.2.1-14).
Furthermore, withdrawal of river flow and subsequent loss of drifting macroinvertebrates will be low (Table 5.1-3).
Therefore entrainment of drifting macroinvertebrates is expected to have little impact on either local macroinvertebrate populations or fish which feed on macroinvertebrate drift.
5.1-7 Rev.
2, 12/81
- =
LGS EROL less significant than that assumed in the LPGS study due to the lack of commercial fishing in the Schuylkill River.
REFERENCES E240.21-1.
NUREG-0440, Licuid Pathway Generic Study, USNRC, Washington, D.C.,
February 1978.
E240.21-2.
Reactor Safety Study, WASH-1400, An Assessment of Accident Risks in U.S. Commercial Nuclear Power Plants, USNRC, October 1975.
i so.
O i
a
' 4M
)
E240.21-3 Rev.
2, 12/81
P LGS EROL in constant contact with the discharge.
With the exception of a small area immediately downriver of the discharge, no measureable
change in community structure or productivity is expected because of the small temperature difference.
Fish:
Effects of thermal discharge on fish populations are expected to be minor and generally limited to a small area in the vicinity of the diffuser.
Under no condition will the discharge pose a block to migrating anadromous fishes.
Drifting larvae and downstrean moving adults which pass through the discharge area will be sub ject to temperature change, but because of the rapid transit ti m and small temperature difference, no mortality is expected.
"emperatures near the diffuser will occasionally exceed upper avoidance levels for important species (Tables 5.1-5 and 6).
Some displacement of -fish from the immediate area may occur.
During most of the year temperatures near the diffuser will be attractive to some species (Table 5.1-7).
Fish attracted to the discharge will also have increased contact time with other blowdown constituents (section 5.3).
The impact of individual reactions to the altered thermal regime will be minor at the.
population level because of the small area involved.
In the event of rapid plant shutdown, fish near the diffuser may be subject to a drop in temperature of up to 11.l*C (20*F) (see Table 5.1-1).
The effect of temperature change depends on the i
rate and magnitude of the temperature decline.
The small discharge volume and the small delta T values (Tables 3.3-1 and 5.1-1) outside of the 0.4-ha mixing area indicate the potential for significant impact due to cold shock is small.
5.1.3.2 Perkiomen Creek 5.1.3.2.1 Diversion Low flow in summer and fall may be a problem in Perkiomen Creek, especially in. dry years.
Low flow stresses biota by reducing wetted area, velocity, depth, and often cover (Johnson Ref 5.1-13).
Flow augmentation, especially during the low flow period of dry years, should improve aquatic habitat in Perkiomen Creek between the East Branch confluence and the Graterford intake (3.9 km), and thereby result in a slight increase in productivity of periphyton and benthos if newly wetted areas are submerged long enough for colonization.
A reduction in densities of drifting biota may occur initially and throughout diversion if production is not proportional to flow augmentation.
Flow augmentation is not expected to cause changes in species composition.
Flow augmentation plus natural flow will fall within the natural range of flow variation presently experienced.
The unlikely event of a complete interruption of diversion flow (i.e., accidental pump shutdown) would cause a temporary reduction in abundance of some biotic components in low flow i
years.
Populations will recover following resumption of 5.1-9 Rev.
2, 12/81
LGS EROL augmentation, the rate depending on the population affected, the time of year, and the duration of interruption.
The redundancy of the power supply to the pumping station, pumping capacity, and the provision of emergency storage at Bradshaw Reservoir should essentially preclude a complete interruption.
The introduction of new species via flow augmentation is possible and is discussed in Section 5.1.3.3.
4-
,,k h bd d8 5.1.3.2.2 Intake a.
A general discussion of intake effects \\on aquatic biota is-given in Section 5.1.3.1.1.
Due to constraints placed on the use of water from Perkiomen Creek (Section 2.4.1), operation of the Graterford intake and subsequent impacts to biota will be limited generally to the period April through November.
Specific operating times will vary among years, depending on water flow.
At average withdrawal (1.5 m /s) a relatively large portion of g
water will be withdrawn; 16.0% of average flow (7.9 m /s, April-y November) plus-diversion, 75.0% of 7-day,10-year low flow (0.5 m /s) plus diversion, and 93.8% of lowest recorded flow (0.1 m /s) plus diversion.
In addition, occasions will arise infrequently when water can be withdrawn from Perkiomen Creek without augmentation; at average withdrawal under these conditions, a maximum of 26% of flow would be withdrawn.
The intake represents latest technology and will consist of a cylindrical wedge-wire screening system (Johnson screen, Section a
3.4).
The intake screens will be located in the center of the creek parallel with flow and will remain submerged even at extreme low flow.
At maximum withdrawal (1.84 m /s) average velocity through the 2-mm screen slots will be 0.13 m/s; the maximum velocity will be 0.14 m/s.
a.
Impingement Few macroinvertebrates and juvenile and adult fishes are expected to be impinged.
\\ l'.
' Macroinvertebr' ates :
Intake operation is expected to affect only subsurface drift.
Chironomidae, Hydropsyche, Cheumatopsyche, Baetis, and Naididae (Oligochaeta) were most abundant in drift (Section 2.2.2.2.6) and therefore are subject to greatest impact.
Losses due to impingement and entrainment are difficult to separate because many aquatic macroinvertebrates exceed 2 mm in length or width.
Based on worst case conditions (100% mortality of'all entrained and impinged organisms), and using the average predicted withdrawal rate of 1.5 m /s, daily impingement plus entrainment loss was estimated for each of the 24-hour drift studies conducted in the immediate vicinity of the proposed Rev.
2, 12/81 5.1-10 l
l
LGS EROL
(
intake.
(The impact of Johnson screens on macrobenthos has only begun to be evaluated, but actual losses will probably be considerably less than with conventional screens (Hanson et al, Ref 5.1-14).
Estimates for all taxa combined ranged from 4.19 x 10* to 1.52 x 106 (mean 5.44 x 10s) organisms, and 5.6 to 182.9 (mean 29.5) g dry weight.
The average numerical and biomass losses were equivalent to the standing crop of invertebrates on roughly 41 m2 of stream bottom (or a 1.3-m reach; the channel width near the intake is approximately 64 m) and 7.6 ma (0.2-m reach), respectively.
These equivalencies were based on estimates of mean benthic standing crop /m a (13,283 organisms, 3.9 g dry wt) for the same 13-month period at Rahns (P13600) located 0.8 km downstream of the drift sampling site.
~
The percentage of bottom fauna drifting at any given time is generally considered to be very low; no more than 0.5%, and usually less than 0.01% (Waters, Ref 5.1-16, based on the formula of Elliott (Ref 5.1-15): P=xD*100 divided by X - xD where x is the_ number of drifters per m3, X is the benthic density per m,
a and D is average stream depth in m).
Estimates for Perkiomen Creek in 1973 ranged from 0.002 to 0.132% (Rutter and Poe, Ref 5.1-17).
In addition the potential for rapid spatial recovery of drift in streams has been demonstrated (McLay, Ref 5.1-18; Townsend and Hildrew, Ref 5.1-19).
(
For these reasons impingement plus entrainment of drifting macroinvertebrates is expected to have little impact on local macroinvertebrate populations or fish which feed on drift.
Fish:
The Graterford intake location is not an area of concentrated abundance for any of the important fishes selected in Section 2.2.2.2.7.
Although spawning, localized movement, and feeding occur in the intake vicinity, the area is not of unique importance for these activities.
No rare, endangered, or commercially valuable species presently inhabit this reach of the creek.
The Perkiomen Creek near Graterford supports an active j
sport fishery (bass and sunfish), and it is possible that j
American shad may gain access to the creek if shad restoration efforts on the Schuylkill are successful (see Section 5.1.3.1.1).
I Although a large portion of augmented source water will be i
withdrawn, potential for fish contact with the screen is low because of the screen's orientation parallel to creek flow (Cook, Ref 5.1-20).
Fish which contact the screen should easily escape because intake velocity decreases rapidly with distance from the screen.
The screen's cylindrical configuration and placement in the water column preclude entrapment.
This screen will virtually eliminate impingement as a source of impact on the important species discussed in Section 2.2.2.2.7.
i 5.1-11
LGS EROL l
b.
Entrainment-Drifting phytoplankton, zooplankton, benthic macroinvertebrates, and fish eggs and larvae will be entrained by the Graterford intake.
Withdrawal projections summarized in Table 5.1-8 were used to estimate entrainment.
It is assumed that all drifting biota, except fish eggs and larvae, are uniformly distributed in the water column, and that entrainment loss will be proportional to water withdrawn.
Fish eggs and larvae were not uniformly distributed in the creek near the intake site.
Therefore losses of these organisms were estimated from densities within the portion of water withdrawn.
Phytoplankton and Zooplankton:
Water withdrawal is expected to lower-numbers of phytoplankton and zooplankton for a short distance downstream of the intake.
Numbers of drifting organisms will be reduced, but the density will not change, assuming uniform distribution.
The impact of these reductions is expected to be minor because (1) phytoplankton is known and zooplankton is presumed to be naturally very low in abundance in Perkiomen Creek (Sections 2.2.2.2.2 and 2.2.2.2.5), and probably play a minor role in the aquatic community, (2) most phytoplankton in i
Perkiomen Creek is dislodged periphyton that continually enters y/
the drift, and (3) zooplankton generally reproduces in backwater areas and therefore losses should be compensated a short distance downstream.
Macroinvertebrates:
Invertebrate entrainment was discussed previously with tmpingement.
Fish:
Important species (Section 2.2.2.2.7) which reproduce in Perkiomen Creek near Graterford either construct nests or broadcast adhesive eggs.
As a result few eggs enter the water column and only a small percentage of the total number spawned are expected to be withdrawn.
1 The importance of larval drift and the effects of entrainment on fish populations were discussed in Section 5.1.3.1.1.
Because water withdrawal will occur during the spawning season (Section 2.4.1), and because a large proportion of the source water body will be removed, the potential impact of entrainment on fish populations in Perkiomen Creek can be regarded as high (based on EPA criteria, USEPA: p.
19, Ref 5.1-8).
However the Johnson screen at:d its midstream location (larvae in Perkiomen Creek generally drift in higher densities along either shore, Section 2.2.2.2.7) should reduce entrainment impact (Heuer and Tomljanovich, Ref 5.1-21; Hanson et al, Ref 5.1-14).
)
5.1-12
P 6
LGS EROL Estimates of larval entrainment loss based on 1975 and 1976 data are presented in. Table 5.1-9.
Percentage of total drift entrained was influenced by horizontal larval drift distribution and' proportion of total flow withdrawn.
Fish that hypothetically would have suffered the greatest losses drifted in highest density within the influence of the intake (midstream).
Estimates of seasonal loss are not possible based on four sample dates; however, entrainment impact will be mitigated by the design midstream location of the wedge wire screen.
As described in Section 2.4.1, the high flows in 1975_would have allowed consumptive use of the Schuylkill River through June.
In more typical flow years withdrawal from Perkiomen Creek will commence in late April or early May.
Under these conditions losses of early spawning minnows, white suckers, tesse11ated darters, and shield darters would occur, as well as additional losses of carp and goldfish (Section 2.2.2.2.7).
- Also, withdrawal in average years, when creek flow is less than that which occurred in 1975, will probably result in greater loss (both numbers and percent of total drift entrained) of each taxon than estimated because a greater portion of stream flow and larval drift will be removed.
[
c.
Downstream Water Fluctuations Flows will fluctuate downstream of the intake due to variable water withdrawal.
When both LGS units are operating, water will be withdrawn by two pumps.
Variation in withdrawal rates and downstream flow may range up to 0.9 ml/s.
Effects of such variation will be most pronounced during extreme low flows.
Phytoplankton, Periphyton, Macrophytes, Zooplankton, Macrotnvertebrates: Flow fluctuations will most affect attached and sedentary organisms (periphyton, macrophytes, benthic macroinvertebrates).
Alternate wetting and drying will probably reduce their numbers and production.
However, ecosystem impact is expected to be minor because presumably only a small percentage of stream width will be involved.
Only minor changes are expected in phytoplankton or zooplankton numbers.
Fish:
Fish populations downstream of the intake may be indirectly affected by changes in food production, and directly affected by alteration of near-shore nursery habitat.
However since fish populations of Perkiomen Creek have evolved in a fluctuating flow regime, these stresses should not alter fish community structure, t
5.1-13
LGS EROL
)
5.1.3.3 East Branch Perkiomen Creek:
Diversion Diversion of Delaware River water through East Branch Perkiomen Creek will markedly alter flow characteristics of the creek, particularly in the headwaters.
Augmentation of 1.5 m3/s (average, 0.8-1.8 m3/s range) is projected to begin in spring or early summer and continue through the low flow season into fall.
Augmentation may be temporarily discontinued during high-flow periods.
Flow will be contained within the present channel; the only channel modifications will be at the outside banks of bends to prevent erosion.
Delaware River water quality is compatible with that of the East Branch, and no appreciable temperature differences are expected.
Results of augmentation will be most evident in the headwaters, where present flows are frequently <0.03 m3/s during the year, and current velocities are virtually zero during summer.
Immediately after initiation of diversion, scouring of the streambed, increased siltation, channel modification, and bank flooding will occur.
These effects will be temporary and will end when the channel becomes stablized to the new flows.
Based on comparison of present low and high flows, stream width will double, depth triple, and velocity will exceed 0.9 m/s in riffle areas of the headwaters.
The stabilized channel will contain new run and riffle habitats, pool areas may be eliminated in the headwaters, and substrates could change to coarser materials.
Termination of intermittent summer conditions (see Section 2.2.2.3.1) will occur.
Downstream areas will be less affected by diversion, but changes in stream hydrology can also be expected.
The magnitude of change will depend on the configuration of the streambed.
The most important result of augmentation downstream will be an improvement in water quality through dilution of the Sellersville Municipal Treatment Plant effluent, the polluted Indian Creek discharge, and farmland runoff (See Section 2.2.2.3.1).
Flow augmentation will introduce biota from the Delaware River and Bradshaw Reservoir.
Viability of introduced species will depend in part on survival through the transit system.
After passing the intake pumps at Point Pleasant, entrained organisms will pass through 4.3 km of 1.5-m pressure pipe to Bradshaw Reservoir, a 274 x 274 x 4.6 meter deep man made storage impoundment.
From Bradshaw, biota will pass through more intake pumps, 9.3 km of 1.1-m pressure pipe, and 1.5 km of 91-cm gravity-flow culvert to an energy dissipator in the East Branch headwaters.
Transit time through the pipeline will be approximately three hours, and residence time in Bradshaw is estimated as 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />.
5.1-14
LGS EROL Phytoplankton:
Phytoplankton is typically low in density and of periphytic origin in shallow, temperate headwater streams.
Augmentation could cause increased periphyton scouring resulting in increased phytoplankton numbers.
The density however will remain low due to increased flow.
Little impact is expected.
Periphyton:
Diversion is expected to affect periphyton through changes in density and biomass.
Increased water velocity may cause greater scouring and therefore decreased densities.
However, increased wetted area will provide more substrate for attachment, potentially resulting in an overall increase in biomass.
Greatest changes are expected in the upper reaches where intermittent flow presently exists in summer.
Effects will be somewhat attenuated in middle and downstream reaches because of naturally higher flows.
Diversion could alter community composition.
Dilution of point source discharges should not have an affect on periphyton growth because sufficient nutrients would still be present.
Macrophytes:
Macrophytes are not common.
Scouring may affect existing plants, particularly in the headwaters, but increased wetted area will provide additional macrophyte habitat.
Zooplankton:
Zooplankton is typically low in density in small,
(
temperate streams.
Diversion will not significantly alter the stream conditions necessary for zooplankton growth.
Minimal impact is anticipated.
Macroinvertebrates:
Diversion is expected to be generally beneficial to creek macrobenthos.
Perturbations which presently operate on the East Branch to reduce invertebrate standing crop (intermittency) and taxonomic richness (degraded water quality) will be ameliorated as a result of flow augmentation.
It is expected that East Branch benthic fauna will show a gradational spatial response to diversion.
The proposed maintenance of a 0.8-m3/s minimum flow until the end of the low flow period (November) would prevent intermittent conditions in the headwaters, thus increasing benthic production.
Ward (Ref 5.1-22) in his review of effects of stream flow regulation concluded that extended periods of uniform flow were generally beneficial to benthos.
Newly inundated substrate throughout the affected area will eventually become permanently colonized through drift from upstream sections, and from multidirectional movements of benthic organisms over and within the substrate.
Full colonization typically occurs within 30 to 60 days (Mason, Ref 5.1-23, Poole and Stewart, Ref 5.1-24, Sheldon, Ref 5.1-25).
The absence of existing intermittent conditions due to the diversion will also be accompanied by a change in benthic community structure.
For example at Elephant Station (E36725) the important (dominant) species Allocapnia vivipara, Perlesta 5.1-15 i
LGS EROL' placida, and Corixidae (Sicara modesta, Trichocorixa calva) will i
undoubtedly be reduced in c ensity, whereas other taxa (e.g.,
THydropsychidae) will' increase.
In addition, annual creek diversity will probably decrease since there will no longer be a prolonged seasonal habitat change (i.e.,
riffle to pool, see
.Section 2.2.2.2.6) in the headwaters.
A benthic response (i.e., change in community structure) to improved water quality is also expected to occur, particularly in the middle reaches, which are presently stressed by stormdrain runoff and the Sellersville Sewage Treatment Plant effluent (Section 2.2.2.3.1).
The benthos stations most severely stressed are Sellersville (E26700) and Cathill (E23000) (Section 2.2.2.2.6).
Important taxa that will be most affected by a change in. water quality are Oligochaeta, Physa acuta,.and Sphaerium at Sellersville, and Oligochaeta and Physa acuta at Cathill.
Diversity at Cathill should increase significantly.
Based on flow-regime, substrate composition, faunal assemblage, and magnitude of stress, it is expected that changes in benthic community structure associated with elimination of intermittent conditions and improved water quality will result in benthic faunas more like that presently found at Moyer (E12500) station.
Such a shift would be beneficial, since benthic standing crops (and presumably productivity) here were higher than at any other
)
upstream station, and diversity was relatively high (Section
' s-2.2.2.2.6).
Fluctuations in discharge volume and velocity during augmentation are not expected to influence the changes discussed above.
Spates are a common occurrence on East Branch Perkiomen Creek, and existing communities are adapted to, and recover rapidly (1-3 weeks) from, this stress.
Diversion interruption (an unlikely event, see Section 5.1.3.2.1) for.a prolonged period after newly inundated substrate has been colonized would cause differential mortality of stranded benthos (Ward, Ref 5.1-22).
When an area is exposed the primary producers are destroyed, and until algae and higher plants are re-established in an area that has been denuded,' invertebrates will not return in their former numbers (Waters, Ref 5.1-26).
The effect of flow augmentation on invertebrate drift is i
difficult to predict or assess.
Walton et al (Ref 5.1-27), in their literature review, found that most studies on the effect of current velocity on drift have been descriptive in natural streams, and concluded that the general role of velocity in drift remains obscure.
In general, drift rates (number of organisms passing a given point per unit time) have been found to increase with increasing velocity, but inverse (Hynes, Ref 5.1-28), direct 1
(Brooker and Hemsworth, Ref 5.1-29), and nondetectable (Elliott, s,I Ref 5.1-15, Anderson and Lehmkuhl, Ref 5.1-30, Ciborowski et al, 5.1-16 l
LGS EROL Ref 5.1-31) effects on drift density snumber per unit volume) have been reported.
On the East Branch, drift rates will undoubtedly increase initially with augmentation due to increased velocity and an anticipated accompanying catastrophic drift response (Waters, Ref 5.1-16), but assuming incoming water is essentially devoid of drifters, the discharge, like a spate, will subsequently dilute existing drift densities throughout the affected area.
Unlike a spate however, discharge dilution will continue proportional to the volume pumped.
Dilution would be greatest in the headwaters, where incoming water will represent the largest percentage of total water, and least near the confluence.
Drift densities will increase somewhat as newly inundated substrate is colonized, but the areal extent of this compensation is unknown.
Qualitative investigations near the proposed Delaware River intake indicated the presence of macroinvertebrates not recorded from East Branch Perkiomen Creek.
It is assumed that all entrained aquatic invertebrate species are capable of surviving transport to the East Branch either as egg, immature, or adult.
Newly introduced species may (1) never gain a foothold, (2) compete with other species and eventually displace or replace them, or (3) occupy a previously unexploited niche.
For example,
(
Gammarus appeared to be abundant at Point Pleasant.
With exception of the isolated occurrence of Hyallela azteca in the headwaters, essentially no other amphipods were found in East Branch Perkiomen Creek.
It is possible therefore that once introduced, this omnivore may become established in the East Branch and provide a stable food base readily utilized by fish.
High incidence of the parasitic copepod Arculus sp. was observed during sampling near Gilbert Generating Station, 22.5 km upriver of Point Pleasant.
This copepod has not been reported from East Branch Perkiomen Creek.
Arculus sp. is commonly found on the body, fins (Hoffman p.
11, Ref 5.1-32), and gills (Davis p.
197, Ref 5.1-33) of many freshwater fishes.
Fish:
Initiation of augmentation will have a temporary adverse aTTect on the fish community, cepecially in the headwaters.
Initiation of diversion in April, prior to most spawning, and resultant alteration of substrate, may decrease availability of suitable spawning habitat for some species.
If diversion is initiated in May or June there may be destruction of nests, increased egg mortality due to siltation and scouring, increased larval mortalities from physical abrasion, and downstream flushing of larvae, young, and some adults.
While the channel is stabilizing tc the new flows, a temporary redistribution of adults will occur, and growth of species may be interrupted due l
to siltation and disturbance of the food supply.
Downstream l
effects of augmentation initiation will be less serious, but some i
disruption of spawning may occur.
l 5.1-17 w
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LGS EROL I-The -long term response of the fish community to. hydrology changes will be a redistribution of species.
Discharge, stream width,
-depth, and_ velocity all control fish distribution in streams (Hynes:-p. 326-336, Ref 5.1-34; Fraser; Ref 5.1-35).
Species adapted to swifter velocities, deeper water, and coarser substrates will find more suitable breeding areas in the headwaters, while those adapted'to present low-flow habitat will find less. ;In downstream reaches augmentation will provide additional spawning and adult habitat which will be beneficial to species already present.
Improvement of water quality, particularly below Sellersville, will enable pollution-intolerant species to prosper.
Pollution-tolerant species may decrease in abundance because their competitive advantage will be reduced.
Important species in the East Branch (Section 2.2.2.3.7) are distributed according to the range in habitats available.
Mont species have narrow preferences for current velocity and depth, and have adapted spawning activities to existing breeding habitat.
Timing of spawning is often affected by stream flow.
particularly in migratory species.
Water-quality also affects species throughout their life cycle.
Therefore each species in the creek will respond differently to the increased flow caused by diversion.
Redfin pickerel, present in the East Branch headwaters and tributaries, will probably be the most affected species because its preferred habitat of sluggish, heavily-vegetated (macrophytes or periphyton) water will be much reduced after augmentation.
This species is apparently dependent upon the pool conditions that occur in summer.
Although it may be eliminated from some diversion-affected areas, it will not be eliminated from the creek since suitable habitat is available upstream of'the point of discharge and in tributaries.
Although redfin pickerel is considered a game species in some drainages, there will be little effect on the recreational fishery here.
Angling ~for redfin pickerel on upper East Branch Perktomen Creek is virtually nonexistant due to small adult size and scarcity of suitable fishing areas'.
Satinfin shiner, common shiner, and spotfin shiner are common in most of the East Branch, but relatively uncommon in the headwaters.
Intermittent conditions durinq the summer may presently limit production of these species.
The common shiner requires gravel substrates above riffles for spawning, and this habitat is expected to increase after diversion.
Satinfin and spotfin shiners prefer slower-moving water, so success of these species will depend on presence of quiet shallow areas near shore.
Eggs of all three species are deposited in crevices or among rocks.
During augmentation adults will find headwater habitat more similar to present conditions downstream where they are more abundant.
The common shiner will also benefit from
.)
improved water quality below Sellersville.
5.1-18
~. -
LGS EROL i
k The white sucker, abundant in most areas of the creek, migrates upstream in spring to spawn.
Increased discharge at Elephant Road may affect tha location of breeding habitat.
Although white suckers may utilize many habitats and substrates for reproduction, gravel and flowing water are usually a necessity.
Both will radically increase in the headwaters during diversion, and because of the sudden flow decrease above the discharge point, a-concentration of spawning activity may occur near Elephant Road.
More run area will provide more habitat for adults throughout the creek.
The yellow bullhead reproduces under stream banks in relatively deep (0.5-1.2 m) water, a habitat uncommon in the headwaters in June and July.
Increases in depth and current velocity will
- probably cause more undercutting of banks and increase the spawning habitat.
Success of young and adults, however, may depend on the development of slow-moving run habitat with aquatic vegetation.
Redbreast sunfish, pumpkinseed, and green sunfish exhibit distributional patterns related to present stream hydrology, morphology, and water quality.
Following diversion, changes in distribution are expected.
The redbreast sunfish is low in i
abundance in the headwaters, possibly because of lack of flow,
(,'
and low in abundance below Sellersville because of poor water quality.
Both situations will change, and consequently this species will benefit from diversion.
The pumpkinseed requires i
habitat similar to the redfin pickerel, and increased flow will be detrimental to its success in the headwaters.
The green sunfish is most abundant below Sellersville, indicating tolerance to degraded water quality.
Elsewhere in the creek this species is relatively common, but it appears to be less successful than redbreast sunfish where they co-exist.
Improved water quality therefore may be detrimental to the green sunfish by enabling redbreast sunfish to prosper.
t l
Smallmouth bass may be the species most benefited by diversion.
Presently the species is abundant only in the downstream reach.
Lack of habitat in the headwaters and pollution in midstream j
areas severely inhibit production elsewhere on the creek.
Diversion will enhance survival of this species throughout the East Branch.
Although most collected specimens were young, legal-size bass were collected from three of five sample sites in 1975.
Increased food supply will also improve growth, provided l
turbidity does not increase concurrent with higher discharges.
Termination of intermittent summer conditions and the improvement of smallmouth habitat may provide an improved recreational fichery for this species.
lI
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The tessellated darter is abundant in upstream areas, less so l
below Sellersville.
This species appears to adapt to many j
habitats; adults can be found in quiet water and riffles.
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LGS EROL Because spawning occurs in moderate currents, flow augmentation may have little effect on reproduction.
Abundance may increase below Sellersville because of improved water quality.
Reduced abundance of hybrid sunfish (Section 2.2.2.3.7) in the headwaters may be caused by increased discharge.
Intermittent conditions have been suggested as a major cause of high numbers of hybrids, and diversion will preclude these conditions.
Increased spawning area will cause a reduction in hybridization due to reduced crowding during spawning.
The pumpkinseed appears to hybridize more frequently than other species, and its anticipated decrease in abundance may also cause a corresponding decrease in hybrid sunfish.
Eleven fish species not present in the East Branch have been collected from the middle Delaware River.
Adults, juveniles, and larvae of sea lamprey, blueback herring, alewife, quillback f
carpsucker, and walleye; adults of iarown trout, channel catfish, white perch, and black crappie; and eggs of American shad were collected in electrofishing, seine, and ichthyoplankton samples near Gilbert Generating Station, approximately 22.5 km upriver of Point Pleasant.
Six of these species, and silvery minnow, were captured by seine and trap and fyke nets near the Point Pleasant intake location.
Qui 11back comprised 35% of all larval fish taken, and American shad 28S. of all eggs taken at Gilbert.
One
)
sea lamprey and nine quillback were collected in entrainment id samples.
Bkuebackherringandwhitepercheggsandlarvaewillprobably not be entrained at Point Pleasant.
Both species spawn nearer the tidal reaches of the Delaware River.
Larvae of the remaining nine Delaware River species and eggs of American shad, silvery minnow, and quillback carpsucker may be entrained at Point Pleasant.
Fishes transported from the Delaware River to the East Branch will be exposed to several stresses.
Eggs and larvae will i
experience sudden pressure fluctuations, velocity shear forces, and physical abrasion in the pumps at Point Pleasant and Bradshaw Reservoir and throughout the pipeline.
Mortality will vary depending on system design, species, life-history stage, and length (Marcy: pp. 135-138, Ref 5.1-36).
It is probable that many entrained organisms will survive transit.
Their success in the East Branch will depend on the presence of suitable habitat and the results of interactions with other biota.
Larvae of the anadromous sea lamprey prefer eddies or poolr with areas of sandy silt and mud into which they burrow.
Although little of this habitat will exist in the headwaters during diversion, suitable areas may exist downstream, particularly in g
the impoundments.
Concentrations of larvae are documented from
,,)
only two Delaware tributaries (Hihursky, Ref 5.1-37).
5.1-20
i 9
LGS EROL
'(
Establishment of migratory populations of alewife and American shad is unlikely because of the small size of the East Branch.
'While land-locked alewives have been noted, they appear to prefer
-inland lakes.
No land-locked American shad populations have been recorded.
High summer water temperatures will not allow survival of brown trout in the East Branch.
The silvery minnow, once found only in the tidal reaches of the Delaware River, now inhabits lower reaches of-tributary streams (Mihursky, Ref 5.1-37).
This minnow prefers lakes and large wide rivers in this region, and therefore may not be successful in the creek.
Abundance of. adult guillback carpsucker is low in the Delaware River, and none have been found in tributary streams.
Drifting eggs and larvae are numerous however, and may reach the East Branch.
Quillback prefers deep sluggish water in large rivern, and establishment of an adult population in the creek is unlikely.
Because of spawning habits and low adult abundance very few if any channel catfish larvae will be entrained at Point Pleasant.
Even if introduced, channel catfish would probably not become established in the East Branch because this species prefers moderate to large rivers.
Lentic habitat is preferred by black crappie, a rare species in Perkiomen Creek, and absent from
(
the East Branch.
Lack of deep water will also preclude successful establishment of walleye.
In the unlikely event of a total pump shutdown, diversion interruption could have an adverse impact on the East Branch fish community, particularly in the headwaters.
A sudden decrease in discharge will leave most of the streambed dry, and in summer the creek would revert to a series of pools.
Sustained interruption during spawninc will expose eggs and larvae and strand individuals in small isolated pools.
i 5.1.4 EFFECTS OF HEAT DISSIPATION FACILITIES Waste heat from '.he Limerick Generating Station will be i
dissipated by two crossflow, natural-draft, cooling towers.
Each tower will be 507 feet tall, and located directly north of the turbine-reactor enclosure complex, as shown in Figure 5.1-2.
The performance specifications for the cooling towers are given in Section 3.4.
l No significant environmental effects on the local agriculture, housing, highways, recreational facilities, or airports are expected from operation of the cooling system.
5.1-21
~
LGS EROL
)
5.1.4.1 Predicted Climatoloov of Visible Plume Geometry
-Several. computer models have been. developed to predict the rise and persistence of visible plumes from natural draft cooling towers.
Policastro et al (Ref 5.1-38) have recently compared the
- predictions from all of the available models with plume measurements made in the field.
Their results indicate that while some progress is being made toward realistically modeling the plume behavior from a single tower, none of the currently available models are adequate to predict the plume geometry from multiple cooling tower installations such as Limerick.
It is expected that to the degree the plumes interact, the plume rise will be increased.
An alternative method for providing climatological estimates of visible plume rise and persistence has been described by Brennan et al (Ref 5.1-39).
This method is based upon empirical relationships derived from aircraft measurements of natural draft cooling tower plumes at the John E. Amos plant in West Virginia (Refs 5.1-40 and 41).
Amos is a 2900 MW fossil plant with waste heat roughly equivalent to that generated by a 2200 MW nuclear plant such as Limerick.
Plume rise and persistence are determined using inversion height and saturation deficit criteria obtained from upper air temperature and humidity soundings.
The Amos measurements showed that ground-level meteorology had little influence on the elevated plume behavior.
This latter method has been selected for the Limerick evaluation, using Philadelphia NWS upper air sounding data (Ref 5.1-42) as input.
5.1.4.1.1 Criteria Used in the Plume Analysis The methodology described by Brennan et al (Ref 5.1-39) is based upon the relationship between the final rise of the visible plume and the capping inversion height, and upon saturation deficit as described by Kramer et al (Refs 5.1-41 and -43).
The algorithm used to analyze each NWS upper air sounding is described in the following sections.
5.1.4.1.1.1 Plume Rise Criteria Each sounding was first scanned for the presence of an
' upper-level capping inversion.
Inversions below the 950 millibar level (approximately 1800 feet MSL) were-discounted, since field observations have indicated that-low-level inversions have no appreciable effect on the final plume rise.
The base of the upper-level inversion was then designated as the height of the final plume rise.
In cases where no inversion was present, the climatological mixing height obtained from Holzworth (Ref 5.1-44) was used as an approximation of the final plume rise.
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.. J 5.1-22
y
-n ATTACI-NENT 2 Appilcation of Philadelphia Electric Cenpany For Tenporary Withdrawal of Water
-When Flow at Pottstown Gage is in Excess of 415 cfs Alternatives Considered PECo has considered various alternatives for a tenporary supply of supplemental cooling water to Linvelck for the period of 1985 when docket decision constraints preclude withdrawals from the Schuylkill and Perklanen. An alternative is not reallatic and need not be considered unless capable of being promptly Inglemented. 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 flew and tenverature constraints imposed by ORBC on withdrawals of water from the Schuylkill River for consunctive use, the Schuylkill will be largely unavailable for such withdrawals during the period June to late in 1985. Because the pennanent supplanental water supply from the Point Pleasant project will be unavailable for this period, Limerick cannot continue with start-up testing, and ascend to full power without an interim 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 John S. Kenper, Vice President, i
Engineering and Research (Septerter 20, 1985) (attached).
I
n (2) Ontelaunee Reservoir - This reservoir is located on Maiden Creek, a tributary to the Schuylkill River upstream of the Limerick plant, and is cwned by the City 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 mgd with a traximtm usage of about 25 mgd. The City of Reading and the nunicipalltles served by the water system are served by comrehensive s stems of sewerage collection which discharge to cormlete 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 from their allocation to PEco. /v1 application 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 Perklcmen Creek.
It is cwied by the Philadelphia Suburban Water Cormany ("PSW Co.") and is used in cort >lnation with other reservoirs and wells for water supply. Total storage
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ls 13,430 acre-feet. Green Lane Is not large enough to meet the contpined needs of PSW Co. and Limerick.
(Letter to
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Nicholas DeBenedictis, DER Secretary from Robert A. Luksa, Executive Vice President, Philadelphia Suburban Water Company, June 4, 1984).
(4) Blue Marsh Reservoir - This reservoir is located en the Tulpehocken Creek, a tributary to the Schuylkill River upstream of the Limerick plant. On March 15, 1985, PEco filed with the DRBC an appilcation under Section 3.8 of the Corrpact for releases from Blue Marsh or other DRBC water supply storage during 1985 for use at Limerick Generating Station Unit No. 1.
This request was rejected by the DRSC on May 29, 1985 In Docket No. D-69-210 CP (Final) (Revised).
(5) Beechwoed Pit - This is an abandoned stripmlne adjacent to the West Branch Schuylkill River near Pottsville, Pennsylvania. On July 3, 1985, PEco and Reading Anthracite Ccurpany, owners of the pit, filed with the DRBC a joint application under Section 3.8 of the Ccrnpact for release of the water frcm the pit and for a variance frcm DRBC water quality standards for total dissolved sollds. Concurrently, a revision to the Appilcation is being filed requesting approval of Beechwood Pit releases at a maxinun rate of 10 cfs Instead of 32.5 cfs as requested in the original Application.
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C0bt40NWEALTH OF PE!WSYLVANIA ss.
COUNTY OF PHILADELPHIA L
JOHN S. KEMPER, being first duly sworn, states as follows:
1.
My name is John S. Kemper, I am Vice President of the Engineering and Research Department of Philadelphia Electric Correany
("the Company"), owner and operator of the Limerick Generating Station.
2.
On August 8, 1985, the NRC issued a full power operating IIcense for Limerick Generating Station Unit 1.
3.
The partially constructed Point Pleasant diversion will not be corrpleted in time to supply Unit l's supplemental cooling water needs for 1985, and the Delaware River Basin Corrmission, on August 9, 1985, approved the temporary transfer of consuretive water allocations from Titus and Crcrrby Generating Stations for use at Limerick.
4.
The power ascension and testing program at Limerick was begun Irrmediately, but power levels are limited by the cuantity of water available from the transfer of allocations (approximately 25%
power).
5.
Consequently, an additional Interim supply of supplemental cooling water is reculred for the remainder of 1985 to operate Unit 1 at power levels in excess of those attalnable by the transfer of water allocations frcm Titus and Crcrrby Stations.
6.
Delays in proceeding with the power ascension program above 25% wl11 delay the corrmercial operation of the init. Such a delay will increase the costs of Limerick Unit 1 by $34 million per month.
This cost figure is mde up of $24 million per tronth Allowance for
. 0 Funds Used During Construction (AFUDC) and $10 million per month operational, security and maintenance costs.
In addition, the fuel costs of the Cmpany's c,ustomers will be Increased by $10 million a month for each rrenth of delay.
7.
Delays in the full power operation of Unit 1 may also irreact on the restart of construction of Unit 2.
The Pennsylvania Pubile Utility Conmission is presently reviewing whether construction at Unit 2 should be continued, but in conp11ance with a prior order issued by the PUC, construction of Unit 2 has been suspended until Unit 1 Is placed in conmercial operation.
0? T/r*A
,' dchn S. Kemper Subscribed and sworn to befremethisf0hday of M, 1985.
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T Exhibit 1 Application of Philadelphia Electric Corrpany For Terrporary Withdrawal of Water When Flow at Pottstown Gage is in Excess of 415 cfs 1
Abstract of Proceedings Authorizing Project DRBC Docket No. 0-69-210 CP (Final) (Novenber 5,1975) approved the Limerick Generating Station Project pursuant to Section 3.8 of the Compact.
Incorporated in this Docket were Schuylkill River flow and temperature restrictions which would largely prohlblt consumtive water withdrawals during the period June to October, 1985. The temperature restraints were temporarily suspended and a dissolved
^
oxygen monitoring program irmosed in lieu thereof in Docket No.
D-69-210 CP (Final) (Revised) (May 29, 1985).
l
Exhibit 2 Appilcation of Philadelphia Electric Cormany For Temporary Withdrawal of Water When Flow at Pottstown Gage Is in Excess of 8+15 cfs Standard or PoIIcy Under Consideration The primary purpose of the DRBC in establishing Ilmits for consumtive use of water is to minimize the adverse envircrrnental effects of withdrawals for consunptive use during periods of low natural stream flow and low dissolved oxygen levels. The proposal set forth in this Appilcation is consistent with this purpose in that the level of consumttve use presently authorized for the units in question will not be increased with the operation of Limerick Unit 1 as proposed herein.
1 I
o Exhibit 3 Appilcation of Philadelphia Electric Coreany For Terrporary Withdrawal of Water When Flow at Pottstown Gage is in Excess of 415 cfs Section of the United States Geological Survey Topographic Map Showing the Territory and Watershed Affected The map attached detalling the location of Limerick Station was prepared from the United States Geological Survey Phoenixville Quadrangle, e
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i Exhibit 4 Application of Philadelphia Electric Comany For Temporary Withdrawal of Water When Flow at Pottstown Gage is in Excess of 415 cfs Description of Specific Effects of Non-Structural Projects The specific effects of the non-structural projects are discussed in Section 1 of Envircrvnental Form and Attacivnent I hereto.
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Exhibit 5 Application of Philadelphia Electric Correany For -Terrporary Withdrawal of Water When Flow at Pottstown Gage is in Excess of 415 cfs Report of the Applicant's Engineer Showing the Proposed Plan of Operation of the Project The resuretion of the startup program and approach to full power for the Lirnerick Generating Station Unit No.1 began following issuance
. of a full power license by the Nuclear Regulatory Carmission on August 8, 1985. A gradual ascension to full power is mderway with tests being conducted at several discrete power levels. The total test program from the date of issuance of the full power IIcense, August 8, 1985, is estimated to require a period of approximately six months, including time for review and approval of test results and for sTe adjustment and tuning of control systems.
t If Lirnerick is available for coeration but its operation would otherwise be prohibited because of existing flow and DO consunptive use restrictions, Limerick would be permitted to operate to the extent that its consurotive uses would be ccrroensated for by equal reductions in the consunptive uses of the Crcrmy and/or Titus units in accordance with Docket No. D-69-210 CP (Final) (Revision No. 2). Whenever the resultant power generation at Limerick is less than the power which would have been supplied fran the Titus and/or Crorby units, the difference in power generation will not be produced by units utilizing consunptive water from the Delaware River Basin.
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If the water utilized from Cronby and/or Titus is insufficient to enable Limerick to operate at the desired power level, it is proposed that the additional wat r required will be obtained from the Schuylkill River provided that the natural river flow as measured at Pottstown is above 415 cfs and dissolved oxygen limits set forth in Docket No. D-69-210 CP (Final) (Revised) are met. This plan of operation is further discussed in Attactynent 1 of this application.
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Exhibit 6 i
Appilcation of Philadelphia Electric Comany For Termorary Withdrawal of Water -
When Flow at Pottstown Gage is in Excess of '+15 cfs Map of Any Lands to be Acoutred or Occupied This is a non-structural proposal. There are no lands to be acquired.
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ly Exhibit 7
- Application of Philadelphia Electric Cormany For Temporary Withdrawal of Water When Flow at Pottstown Gage is in Excess of 415 cfs Estimate of Cost of CormletIng the Proposed Project This is a non-structural proposal which involves no expenditures for its completion, e
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s Exhibit 8 Appilcation of Philadelphia Electric Ccrnpany For Termorary Withdrawal of Water When Flow at Pottstom Gage is in Excess of !+15 cfs Description of Construction Procedures
.This is a non-strucctural proposal which involves no construction activity.
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