ML20137S486

Forwards Util 850603 Application Under Section 3.8 of Delaware River Basin Compact for Use of Water from Beechwood Pit.Related Correspondence

ML20137S486
Person / Time
Site:	Limerick
Issue date:	07/17/1985
From:	Conner T CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
CON-#385-899 OL, NUDOCS 8509300397
Download: ML20137S486 (32)

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I Mr. Samuel J. Chilk N

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Secretary U.S. Nuclear Regulatory l

Commission E

i Washington, D.C.

20555 l

1 In the Matter of Philadelphia Electric Company i

(Limerick Generating Station, Unit 1)

Docket No. 50-352 0

Dear Mr. Chilk q

As a follow-up to my June 3, 1985 letter to you, I am i

enclosing copies of Philadelphia Electric Company's July 3, i

1985 application under Saction 3.8 of the Delaware River Basin Compt.ct for the use of water from the Beechwood Pit at i

j Limerick Generating Station, Unit 1.

1 Sincerely, l

Troy D. Conner, Jr.

j Counsel for the Applicant i

TBC/dif

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DELAWARE RIVER BASIN COMMISSION Type of Application: (Check one or more - see reverse side)

(o) Addition to the Comprehensive Plan...................... ( I (b) Change in a Comprehensive Plan Project.................. ()

(c) Approval under Section 3.8 of the Compact................. (/.)

(d) Inclusion in "A-l.ist" of the Water Resources Program......... ( )

Pursuant to the Delowore River Basin Compact and the Rules of Practice and Procedure of the For Use of Commission Delowere River Basin Commission, cpplication Docket No.

is hereby made for review of the project des-Date Received cribed below:

Action by Commission (A)

Application from:

Nome rniladeirnia r ectric cm,rany m l "arket Gt.,

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Nome of Counsel Aard 3. Laar,

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omes J. aar:Ln, Jr.

~ c wn q 1 Nome of Engineer V. 3. Boyer (PEco)

(8)

Type of Project: (Check)

(I) Impoundment...........'..... ( )

(4) Stream Eneroochment '......( )

(2) Withdrawal of Water.........(x)

(5) We l l..................... ( )

(3). Disposal of Westes......, _....(.)

(6) Other...V.n.r.iPPrr.......... (X )

(C)

Description of Project:

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F6v 1985, withdraval of water from the Schuylkill River for consumptive use at Limerick Generating Station Unit flo.1, when existing dissolved oxygen or flow constraints vould otharvine prevent such withdrawal, in amounts not exceeding exinting docket limits and not exceeding amounts released into the Want Branch of the Ucnuyikill River from the Beechwood Pit, under a coordinated plan of release fran Beechwood and withdrawal at Limerick _ with existire dissolved oxygen Md flow constr tints to be ime-i f enbla tn "nch wi thmm.

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[M'sc/fr$ h J. N rran I~-'1 Reading Anthracite Company 1

phia Electric Cc:rany g j

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ENVIRONMENTAL FORM M

l Applicant Philadelphia Electric Co./ Reading Anthracite Co.

Date Title of Project Interim consumptive water Supply - Beechwood Pit location Limerick Generating Station DRBC Docket No.

1.

List any significant environmental impacts, beneficial and adverse, caused by the proposed action.

The beneficial impact of the requested temporary withdrawal of water released under a variance from tne beecnwood Pit vill ue to permit.ccheduled operation of j

Limerick, already evaluated by the D?BC.

See DMBC FEA for Jocntu1ir.y water Supply Systems (Aurust 1980); ERBC Level 3 Study; and AEC/NEC FES for Limerick l

iIiovember 1973 and Aoril 10% ).

The roiense ef water vill i ne rne n the etran-flow from tne beecnwood Pit to tne'Eimerice intake. kere will be mininal adverse i

j ampacts from this release whicu will be in ac:ctdance with ?ipDEC termit recuirenent[

ana applicable water quality standards, cr any aperopriate variance trierefrom.

l (dee Paragraph 2, belows See Attaennents 1 ar.d 3.

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2 What mitigating moosures will be used to reduce or alleviate the adverse environmental impocis ?

Unier liPDES requirements and the var;nr.ce ner'.ied for,nr4in (Saa -tta g <e.t ti the use of f.he consumptive water mmia avaiinPle rur-uant to eMc e mli%tten

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have minimum adverne impacts. While total dissolved solids in the Eeechwood Pit j

are somewnat, n16ner than DhbG limits tne effects in the main stem of the Senuylkill due to the introduction of the Beechwood Pit water vill be minimized cue to mixing. ine effect of the Beecnvood water on the Schuylkill after its i

casenarge at Limerica yill also be minimal. As soon as seasonal conditions permit continuous use of natural stream flow, pumping from Beechwood will be

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stopped.

.I 3.

Summarize the alternatives considered.

The alternatives considered vore (1) *io action (9) rn1nnnn nr un+ne ern-na Ontelaunce Reservoir (3) release of water from Green T,ane Rosarvoir f M ra' anne of of water from the Blue March Reservoir or other basin water sunniv storves.

See Attachment 2.

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4 List any known objectors to the proposed action.

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s ciswcra River B: sin Ccmmissi N9 4514 APPLICANT'S STATEMENT 2-PRO' JECT REVIEW FEE (Sce Reverse Side For Additional Information)

Philadelphia Electric Co. - 2301 hrket Jt., Phiin.,19101 PA

1. Nome and Address of Applican' Reading,Anthrncite._Co..... 200 S.ahantongo. St.,- Potteville, PA 17901-

2. Nome of Project.. Interim Consu=ptive. Water. Supply..- Beechwood Pit.

._ Limerick Generating Station.

Dodet #.

3. Type of Project Check Applicable item (s) l

_-...(o) impoundments

_._.(b) diversions of water into or out of the Delaware River Basin l

._. (c) industriot water use and waste treatment facilities

.1 (d) electric generating and transmission facilities (e) petroleum product pipelines (f) stream encroachments; and

. (g) withdrawal of ground water 4.

Project Cost Factors (Complete oil lines using Zero where opplicable) ltem Estimated Cost L

o. Design

$ 5,000

b. Supervision of Construction

$.5,000

c. Legal Services

$ 5,000

d. Contract Administration

e. Land

f. MaterioIs

g. Construction and Fabrication

$ 10,000.

25,000 TOTAL ESTIMATED PROJECT COST Footnotes / emarks R

5. Filing Fee Schedule (Check opplicable item (s))

(The filing fee is the greater of (a) or (b))

Com

[,[. ; puf,ofion:;(o)$

100.

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. X-(o) minimum fee: $100. for any ' project; or~.,..

(b) offernative fee:

(b) u.9[),_1/10 of,19a 'of estimatedjroject cost, u"p',.to $1,000,000.

(1) $..

.,.3.

if50 of.1% of, remaining. cost above,$1,000,000;.p.but not l

(2) $ _

.(2 to ex'ceed o'*moximus fee 'ol'$50,000 os~to any one t.,xclusive. o.f odded.e.nvironm.e,nto.! fe,'e's.i.,', ' 'wT '..' [ect, ro e

100.00 3-

....s

' Teal $

6. Fifing"F'ee"liehiredNitli kpplication **' ' ' ' ' ' " " " ' ' ' "

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..u.. Pfeo enclose.cigck in t ' omounLwith, application.. Check,should be mode payable to Defoware S

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O Should t s roi require on vironmental Impact Statement or on Environmento! Assessment, you w' e no ied at a lot ote and on Applicant's Statement Environmental Review Fee

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will-f ded for c'

. tion and payment-f applicable' fee.

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Sig atire of Qertifying Official gnature of Certifying O!!icial h

Vice President e 1 G'O g,.y__ g_.f*

Senior Vice President, Nuclear Power Do d

Title ACKNOWLEDGMENT BY DRBC OF FEE PAYMENT Received Check No.

, dated.

, Bank No.

In amount of.. _.

COMES: (t) Antmin!.trative Dhl4 n C. py vi hile

$;gnoture til APPLICANT - Retain This Cary - s ink (s) Applicent.- DR3C Receipted Copy - yellow til Praject Review Ccpy - Flue

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ATTACit'ENT 1 Appilcation of Philadelphia Electric Company and Reading Anthracite Comany for Temporary Source of Make-up Water (Beechwood Variance and PECo Withdrawal)

In view of the fact that there will be times when stream flow or dissolved oxygen (DO) constraints as described in DRBC Docket D-69-210 l

CP (Final) (Revised) (May 29, 1985) will prevent withdrawals from the i

Schuylkill River. for consumtive use at Limerick Unit No.1, another source of make-up water will be necessary for the remainder of 1985.

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Philadelphia Electric Comany (PECo) has filed with the DRBC an application, dated May 30, 1985, under Section 3.8 of.the Camact for ccordinated use of the water allocation of Metropolitan Edison's Titus Station Units No. 1, 2, & 3, and FECo's CroTby Station. Unit No. 2 for consunptive use at Limerick Generating Station Unit No.1.

This proposal will allow Limerick to resune its start-up and testing l

program, but will not provide enough water for the cormletion of the testing. Under those circunstances, Reading Anthracite Comany (Reading) proposes to pum water from its Beechvood Pit into the West Branch of-the Schuylkill River near Duncott, PA, under a National Pollutant Discharge Elimination System Pennit for which appilcation was trade by Reading to the Pennsylvania Department of Environmental Resources (DER) on June 7,1985 and under a variance from DRBC water r

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O quality regulations for total dissolved solids (TDS), application for i

which is made herein (See Attachment 3).

This water would then be conveyed via open channel flow to the Limerick intake, 82 miles dcwnstream.

The Beechwood Pit is a former strip mine controlled by Reading.

The pit, whose maxinun dimensions are approximately 2500 feet long, 1000 feet wide, and 300 feet deep, is presently unused and has filled r

with approximately 2.2 billion gallons of water, a sufficient quantity j

of water to meet Lirnerick's constsiptive needs for the remainder of the 1985 period when the Schuylkill River is-otherwise unavailable. PECo has made arrangements with Reading for use of this water and its conveyance to the river.

It is' proposed that water will be ptsnped from the pit and withdrawn. for Linerick I when the DRBC Dockets would otherwise preclude using the Schuylkill River for constmotive purposes.

Asstraing all water for Lirerick ccmes fran the Beechwood Pit, the ptrping rate at Beechwood will be equal to the conststptive use at Lirrerick, with a maxinun ptsrping rate of 32.5 cfs (21.0 mod) and an average rate of 12.8 cfs (8.3 mgd) during the 2f+ week startup and testing period. The stated ptinping rates would be reduced by the i

requested authorization to use water allocated to the Titus and Cranby No. 2 units l

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Beneficial Impacts to the environment. The availability of f

cooling water during 1985 for Limerick will enable the Limerick Generating Station to ccnplete its start-up testing program without delay and to operate at full capacity in order to help meet electric pcwer generation needs for southeastern Pennsylvania.

DRBC has previously determined -that the supply of cooling water for Limerick provides a benefit to the environment. As DRBC stated in its most recent environmental review of the supply of supplemental i

cooling water for Limerick, "docunents 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 use of water resources." See DRBC Final Environmental Assessment for the Neshaminy Water Supply System, Part III, p. 2-53 (August 1980). DRBC reached the same conclusion in grenting final Section 3.8 approval to the Point Picasant project in Docket No.

D-79-52 CP at p. 5 (February 18, 1981). Accordingly, DRBC has recognized that the use of Basin water resources to provide cooling water for Limerick constitutes a beneficial use.

4

' As to the specific need for the electrical power to be generated by the Lirrerick Generating Station, DRBC has relied upon the findings of the Nuclear Regulatory Ccnmission (previously the Atonic Energy I

Co mission) In its cwn environrrental statements for Limerick. See l

Docket No. D-69-210 CP (Final) at pp. 1, 6-8 (November 5, 1975).

In issuing construciton permits for Limerick, the AEC determiried that there is a need for the electrical power to be generated by Limerick.

See AEC Final Envirortrental Statement Related to the Proposed Lirrerick

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Generating Station, Units 1 and 2, Docket Nos. 50-352 and 50-353, Ch.

9 (Noventer 1973). At the operating IIcense stage, the NRC simliarly found a substantial benefit to the environment to be derived from the operation of the Limerick Station in the annual production of approximately 10 billion KWh of base load electrical energy. See NRC 4

Final Environmental Statement Related to the Operation of Limerick Generating Station, Units 1 and 2, Docket Nos. 50-352 and 50-353, a

Section 6.4.2 (April 1984).

i Further, in an order entered August. 27, 1982, the Pennsylvania

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PUC expressly stated that "(t)he pubile interest requires... (t)Imely coupletion of Limerick Unit 1" and further stated "we encourage the Comany to ccmplete this unit as rapidly as possible consistent with the public safety." Pennsylvania PUC, Opinion and Order, Cocket No.

1-80100341 (August 27, 1982) (emphasis added) (pp. 23-25).

Accordingly, there exists a substantial benefit to the environment and

^ the pubile in the comencement of conmercial operations at Limerick as soon as possible.

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The natural-flow in the Schuylkill River will be enhanced by the release of the Beechwood Pit water from Pottsville to the Limerick intake.

Minimal adverse impact to the environment - Water analyses, perfonred fran 1974 to 1984, Indicated that the background Total Dissolved Solid, (TDS) In the Schuylkill River at Limerick averages 375 ppm at a flow of 360 cfs. The 360 cfs ficw is the lowest flow for which sufficient data is available to analyze. For a flow of 360 cfs j

-5 and an average TDS background concentration of 375 ppm at Limerick, the release of 27.0 cfs of Beechwood water, with a TDS of 1670 ppm, will Increase the TDS to approximately 465 ppm at Limerick. When this water is used at Limerick a portion will be reconcentrated in the cooling tower, and the discharge of the blowdown water will increase the.TDS concentration in the Schuylkill inmediately below Limerick to approximately 496 ppm.

This final river TDS concentration meets the i

DRBC stream water quality objective since it is less than 133% of the river background TDS and less than.500 ppm.

1 The TDS are of concern in water quality due to imparting objection-able mineral tastes to drinking water and due to increasing the potential for corrosion. Both effects are related to specific lons that make up the TDS rather than the level of TDS itself. Most taste and corrosion problems are associated with the sodlun and chloride ion rather than the calclun, magneslun, and sulfate ions that dominate the Beechwood water.

In order to minimize the effects of increased TDS on 4

users below Limerick, the TDS level at the Limerick intake will be runitored semi-weekly and the concentration after passing through the plant will be calculated, if the TDS level after concentration exceeds

- the DRBC objective of 500 ppm, plant operations would be reduced as required so that the 500 ppm objective is met.

i The drawdown of the Beechwood Pit will have minimal impact on local groundwater levels. The strip mine was operational and dry until approximately 1966, and there were no noticeable changes in local ground water elevation. Recharge of the pit was estimated to be 200-500 gpm.

This recharge rate is small ccrnpared to the proposed punping rate and was not included in calculations of the useable t

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I quantity of water in the pit. Nearby mines will not be affected by this ptanping, as the other mines are geologically isolated by solid rock forTnations.

It is a practice to cease mining in the direction of nearby i

mines before flow paths are created. The presence of the solid separation is evidenced by the fact that adjacent mines are presently ptrnped even lower l

than the Beechwood Pit and water is not flowing out of Beechvood.

Conversely when Beechwood was working and the water was absent, water did not flow into the Beechwood pit at the ground water levels experienced at nearby mines, j

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ATTACtf4ENT 2 Application of Philadelphia Electric Ccrnpany and Reading Anthracite Ccmpany for Ternporary Source of f4ake-up Water (Beechwood Variance and PECo Withdrawal) i Alternatives Considered PECo has considered various alternatives for a temporary supply of supplemental cooling water to Limerick for the period of 1985 when

' docket decision constraints preclude withdrawals from the Schuylkill 3.

and Perklamen. -An alternative is not' realistic and need not be considered unless capable of being promptly implemented. Thus, an alternative cannot require construction or major modification of existing facilities.

The alternatives considered and a brief discussion of each follow:

(1) No action - Due to flow and DO constraints imposed by DRBC on withdrawals of water from the Schuylkill. River for constsnptive use, the'Schuylkill will be largely unavailable for such withdrawals during the period June to October, 1985. Because the permanent supplemental water i

supply from the Point Pleasant project will be unavailable for this period, Limerick cannot continue with ' start-up and ascent to full pcuer testing without.an Interim source.

The cost of not operating Lirnerick for lack of water during that period is estirrated to be $49 million per month.

See Affidavit of Vincent S. Boyer, Senior Vice President, Nuclear Power July 3,1985 (attached).

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Exhibit 1 Application of Philadelphia Electric Conpany and Reading Anthracite Ccunpany for Tenporary Source of Make-up Water (Beechwood Variance and PECo Withdrawal)

Abstract of Proceedings Authorizing Project DRBC Docket No. D-69-210 CP (Final) (Noventer 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 prohibit constinptive water withdrawals, absent Point Pleasant, during the period Jtne to October, 1985. The temperature restraints were temporarily suspended through December 31, 1985, and a dissolved oxygen monitoring program Inposed in lieu thereof in Docket No. D-69-210 CP (Final) (Revised) (May 29, 1985). PECo has flied with the DRBC an appilcation, dated May 30, l

1985, under Section 3.8 of the Ccrnpact' for temporary use of operational 1

generating stations' water allocations.

This application, if approved, I

will allow Limerick to restrne its startup and testing program, but will not provide enough water for the completion of the testing.

It is for

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this reason that this appilcation is submitted for use of the Beechvxxxi Pit water.

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Exhibit 2 l

Appilcation of Philadelphia Electric Conpany l

and Reading Anthracite Company for Temporary Source of Make-up Water (Beechwood Variance and PECo Withdrawal)

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Standard or PoIIcy Under Consideration

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The primary purpose of the DRBC in establishing Ilmits for constmptive use of water is to minimize the adverse environmental i

effects of withdrawals for consunptive use during periods of low i:=

natural stream flow and low dissolved oxygen levels. The proposal set I

forth in this Appilcation is consistent with this purpose in that a supplemental source of water will be used to provide water to be used i

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consunptively at Limerick Unit No. 1.

No additional consunptive' l

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stress will be placed on the Schuylkill River, j

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s Exhibit 3 3

Application of Philadelphia Electric Company and Reading Anthracite Company for Tenporary i

Source of Make-up Water (Beechwood Variance and PECo Withdrawal)

Section of the United States Geological 1

Survey Topographic Map Showing the i

Territory and Watershed Affected i

The maps attached detalling the location of the Beechwood Pit and 4

Limerick Unit No. I were prepared from the. United States Geological i

Survey Pottsville and Phoenixville Quadrangles, respectively.

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Exhibit 4 Application of Philadelphia Electric Company and Reading Anthracite Comany for Tenporary Source of Make-up Water (Beechwood Variance and PECo WIthdraval)

Description of Specific Effects of Non-Structural Project See Section 1 of Environmental Form and Attachment I hereto.

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(2) Ontelaunee Reservoir - This reservoir is located on Maiden Creek, a tributary to the Schuylkill River upstream of the Limerick plant, and is owned by the City of Reading for use as a water supply source. Ontelaunee has 11, 640 acre-feet

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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 maximtm usage of about 25 mgd. The City of Reading and the municipalities served by the water system are served by conprehensive systems of sewerage collection which discharge to complete 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.

An appilcation for approval of such usage would have to be made by the City to the DRBC. To date, the City has not Indicated an interest in making any water available to PECo for 1985, or any other period of time.

(3) Green Lane Reservoir - This reservoir is located on the Perklomen Creek.

It is owned by the Philadelphia Suburban Water Company ("PSW Co.") and is used in carbination with other reservoirs and wells for water supply. Total storage is.13,430 acre-feet. Green Lane is not large enough to reet the combined needs of' PSW Co. and Limerick.

(Letter to

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- Nicholas DeBenedictis, DER Secretary frcm Rcbert A Luksa, Executive Vice President, Philadelphia Suburban Water Ccrnpany, June 4,1984).

I (4) Blue Marsh Reservoir - This reservoir is located on

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l the Tulpehocken Creek, a tributary to the Schuylkill River upstream of the Limerick plant. On March 15, 1985, PECo flied with the DRBC an appilcation under Section 3.8 of the i

Compact for releases from Blue Marsh or other DRBC water supply storage during 1985 for use at. Limerick Generating i

Station Unit No. 1.

This request was rejected by the DRBC on May 29, 1985 In Docket No. D-69-210 CP (Final) (Revised).

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COMMONWEALTH OF PENNSYLVANIA ss.

COUNTY OF PHILADELPHIA VINCENT S. BOYER, being first duly sworn, states as follovs:

1.

My name is Vincent S. Boyer, I m Senior Vice President, Nuclear Power of Philadelphia Electric Co,pany ("the Ccnpany"), owner t

and operator of the Limerick Generating Station.

2.

On October 26, 198t+, the U. S. Nuclear Regulatory Ccmnission issued a license authorizing fuel loading and a low pcwer testing program for Limerick Unit No.1, these have been completed.

The schedule for the pcuer ascension phase of operation is such that the Plant is ncw ready to proceed tc power levels greater than allowed under car existing license.

Ir. view o' the current status of the NRC licensing proceedings, issuance of a full power license can be anticipated by the third quarter, 1985.

3.

_ in order to proceed with the power ascension program for -

Unit I after the issuance of a full power operating IIcense by NRC, it is nece.!ssary to have in place a supplemental cooling water supply.

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The partially constructed Point Pleasant diversion will not be corpleted in time to supply Unit l's supplemental coo 1Ing water needs In the third quarter of 1985 when it is anticipated that the i

j NRC WIll authorize the Carpany to proceed to full power operation.

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Consequently, an Interim supply of supplemental cooling water will be required to operate Unit 1 at sustained high power Icvels untti the Point Pleasant Project is carpleted.

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2-6.

Delays in proceeding to full power will result in a delay in

.the conmercial operation of the unit.

Such delays will increase the costs of Limerick Unit 1 by $34 million per month. This cost figure is made up of $24 million per month Allowance for runds Used During Construction UEUDC) and $10 million per month operational, security and cuintenance costs.

In addition, the fuel costs of the Company's customers will be increased by $15 million a month for each month of

delay, i

7.

Delays in the full power operation of Unit 1 may also impact on the restart of construction of Unit 2.

The Pennsylvania Public Utility Ccomission has concluded hearings on whether construction at Unit 2 should be centinued,.but in ccrollance with a prior order issued by the PUC, construction of Unit 2 unit has been suspended until Unit 1 is placed in conmercial operation, a

N T Vincent S. Boyer i

i Subscribed and sworn to before me this 3 M y of 985.

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ATTActf4ENT 3 i

Appilcation of Philadelphia Electric Company and Reading Anthracite Ccmpany for Tenporary i

Source of Make-up Water (Beechwood Variance and PECo Withdrawal)

Variance From DRBC Water Ouality Regulations j

Water analyses indicate that the environmental irnpact of discharging L

j the Beechwood Pit water into the West Branch Schuylkill River near Duncott, PA at a point about ) mile downstream frcm the Pit wIll be a general Irrorovement of the quality of the river downstream of the discharge. Reading Anthracite Co. has flied a National Pollutant i

Discharge Elimination System Permit application with the PA DER for i

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this discharge of water. The DER has advised that it would impose the following total dissolved solids (TDS) limits on the discharge of j

Beechwood water at the point noted above which is near an existing outfall on the western side of the West Branch Schuylkill River. The lim!*,s would be based upon DRBC Stream Water quality criteria:

580 mg/l - 30 day average 1160 mg/l - maxinun daily average 7

a l'+50 mg/l - Instantaneous rraximtm In addition DRBC effluent quality requirements, Section 3.10.f+

of " Basin Regulations-Water Quality", state that total dissolved solids shall not exceed 1000 mg/1, or a concentration established by the Cccmission which is compatible with designated. water uses and stream quality objectives, and recognizes the need for reserve capacity to serve future dischargers.

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i Water quality analyses indicate that the Beechwood water vould t

exceed these discharge limits somewhat. Six individual measurements of l

the TDS in the Beechwood water ranged frcm 1050 mg/l to 1670 mg/1.

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However, the PA DER has Indicated that if a variance is granted by the i

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DRBC, the DER would impose limits on TDS in accordance with the variance.

The _ DER has its own criteria, but will. impose DRBC criteria as they are i

more restrictive. The DER imposes water quality objectives for the i

same reasons as the DRBC, to preserve and improve the purity of the waters of the Conmonwealth of Penns91vania. The DER effluent limit for the TDS in the Beechwood Pit would be a 30 day average value of i

i 2300 mg/1. The Beechwood Pit water does meet the DER criteria. We request a variance to discharge water containing TDS in the anount up i

f to the concentration that would be allowed by the PA DER using their criteria. The Ilmited water analyses indicated that the actual TDS in l

i the Beechwood water will be significantly lower than levels allowed by l

the DER criteria.

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TDS are of concern in water quality due to imparting objectionable mineral tastes to drinking water and due to increasing j

l the potential for corrosion. Both effects are related to specific i

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ions that make up the TDS rather than the level of TDS Itself. Most i

taste and corrosion problems are associated with the soditm and chloride ion rather than the calcitm, magneslun, and sulfate ions that j

dominate the Beechwood water.

t When the Beechwood maximtm discharge reaches the main stem j

_ Schuylkill, about 10 miles downstream, a yearly average flow would j

i dilute this discharge by about 10 to 1.

The discharge will therefore be diluted before reaching any municipal water intakes and will not i

contribute to taste or corrosion problems.

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Water analyses, performed fran 1974 to 1984, Indicate that the background TDS at Limerick averages 375 mg/l at a flow of 360 cfs.

The 360 cfs flow is the lowest flow that sufficient data is available to analyze. For a flow of 360 cfs and an average TDS background

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concentration of 375 mg/l at Limerick, a release of 27 cfs of Beechwood I

water, with a TDS of 1670 mg/1, would Increase the TDS to approximately 465 mg/l at Limerick. The nearest downstream rrunicipal water Intake fran the Beechwood Pit is the Pottstown Water Authority's treatment plant,'which is approximately 8 miles. upstream from Limerick. The i

release of the Beechwood water at a Schuylkill River flow of 360 cfs j

will cause the TDS of the water at the first downstream municipal water i

1 user to be within the DRBC stream water quality objectives of 133% of

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river background TDS or 500 mg/1. At higher river flows, the effect will~be less, and it is concluded that the introduction of water form the Beechwood Pit will not adversely affect the quality of water in the 1

Schuylkill River, j

No aquatic Ilfe exists at the discharge location and therefore i

acuatic life would not be affected by the TDS level in the West Branch I

Schuylkill River. Aquatic ilfe is present in the main stem Schuylkill 1

River, but the increase in TDS due to the Beechvood release will have only a minimal effect on the aquatic ilfe pres (nt.

i All species of fish and other aquatic life must be tolerant of a 3

range of dissnived sollds in order to survive under natural conditions. Studies in Saskatchewan Indicate that several ccnmon freshwater species survived 10,000 mg/l dissolved sollds, whitefish and pikeperch survived 15,000 mg/1, and stick 1cback survived 20,000 I

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mg/l dissolved solids. The Increase in TDS of the Schuylkill River, due to the release from Beechwood is expected to be gradual and should not cause a shock to Schuylkill River fishes. When soditsn chloride Is the major constituent of TDS, levels in excess of 15,000 mg/l (soditsn chloride) can cause mortality due to osmotic 1

Inbal ance.

In the Beechwood Pit, magnesitsn sulfate is the major

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constituent of TDS; thus there soould be no mortality through osmotic i

imbalance.

Since PECo requires this water in the near future, an alternative 1

I to a variance is not reallstic and need not be considered unless capable of being promptly Inglenented. Thus, an alternative cannot require construction or major modification of existing facilities.

Treatment of the Beechwood water would require construction of i

facilities and is therefore not a realistic alternative. The only i

realistic alternative to obtaining the DRBC variance is to not use the water from the Beechwood Pit. The beneficial impact of using the water for use at Limerick Generating Station Unit No. 1 is fully described in Attactynent 1.

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Exhibit 5 1

Application of Philadelphia Electric Ccmpany and Reading Anthracite Ccmpany for Tenporary Source of Make-up Water 1

(Beechwood Variance and PEco WIthdraval)

Report of the Appilcant's Engineer Showing the Proposed Plan of Operation of the Project 4

The restmption of the startup program and approach to full pover i

i*

for the Limerick Generating Station Unit No.1 is expected to begin following issuance of a full power license by the Nuclear Regulatory j

Co: mission. A gradual ascension to full power is planned with tests being conducted at several discrete pover levels. The total test program is estimated to require a period of approximately six months, i

including time for review and approval of test results and for scme adjustment and tuning of control systems.

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Based on the availability of consunptive water requirements, the fo11oving program is envisioned.

For the first two months of the startup program, the unit will be operated at power levels progressively

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I increasing to 50% of full power and the average constmptive water l

requirements will be about 10 cfs. During month three, testing will occur at power levels up to 75% of full pover with the constmptive water requirements averaging about 17 cfs. During months four through j

six, it is planned to conduct tests at full power output with consumtive j

water needs averaging about 22 cfs. Thereafter, when operating at full i

j power, the average constmptive usage amounts to 27 cfs, which figure i

might increase to 32.5 cfs under extreme meteorological conditions.

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During the test prc< gram, PECo will utilize withdrawals frcm the Schuylkill River and Perkicren Creek as authorized by DRBC, When withdrawals from the Schuylkill River and Perkicmen Creek are precluded by the DRBC docket decision flow or DO constraints, PECo would use the constsmtive water made available pursuant to its Titus - Crcnby application to DRBC.

In addition, PECo would use the constsnptive water from the Beechwood Pit for the same purpose.

In order to minimize the quantity of water ptsnped frcm the Beechwood Pit, the amount of Beechwood water punped will equal Limerick's scheduled consunptive use minus the i

water available from Titus and Crcnby 2.

The flow and DO constraints imposed in Docket No. D-69-210 CP (Final) (Revised) (May 29, 1985) would be inappilcable to this plan of operation.

Based on the projected operating schedule, the estimated consumtive water requirements for Limerick will be calculated two weeks in advance, and a running schedule of estimated consunptive water needs will be maintained. The expected sources of this water will then be Identified and the estimated daily ptsnping requirenents from the Beechwood Pit will be calculated. Taking into consideration the river flow time between Beechwood and Limerick, a daily pumage schedule will be forTnulated and initiated with ptsnpage rates normally adjusted on a daily basis. Based upon USGS studies, the travel time from Beechwood to Limerick at a 520 cfs Schuylkill River flow is approximately 8 days; at 340 cfs, the travel time increases to 10 days. The quantity of water being added to the West Branch of the Schuylkl11 River will be measured by a standard scientific method.

1

OS 4

i To insure that the water added to the stream actually meets the i

requirements and constsmttve useage of Limerick, a second set of calculations will be made. Each day the actual constsnptive usage of water for the previous day will be calculated based on unit output, t

cooling tower rnakeup and blowdown quantitles, and cooling tower basin level changes. Based on the sources of water available to us by docket decisions, the quantity of water required from the Beechwood Pit will i

j be calculated. This will be compared to the actual anount planped from -

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the Beechwood Pool some days earlier, allowing for travel time in the i

c river between the point of addition and the Limerick Station. A running seven-day total of the actual ptsnping requirements and the j

amount ptsnped will then be made. The target value for the difference i

l in these values will be that the amount punped shall be 3% greater than r

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i the requirements. Any diversion from this figure will be corrected by t

l an adjustment.to the ptsnping rate for the current day. A procedure detalling the calculational steps will be prepared and records of the

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calculation will be retained'and available for inspection.

In somnary, the constanptive water usage at Limerick, as

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furnished frcxn the Beechwood Pit, will be projected and the Beechvood ptinping will be adjusted to be in concert with the actual requirements.

1 On a retrospective basis, ptamed quantitles will be 3% over actual

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usage.

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_4-O Dissolved oxygen content of the Schuylkill River will be continuously monitored as required by DRBC Docket No. D-69-210 CP (Final) (Revised), dated May 29, 1985, and experience will be gained regarding the correlation of D.O., temperature, and flow. During the time periods that the DO levels permit withdrawal fran the river and Beechwood Pit water is not required, future DO levels will be predicted 10 days in advance.

If predicted river flows or other conditions lead us to believe that the DO levels will drop below permissible withdrawal limits, punping will be initiated at Beechwood i

so that the water will reach Limerick when needed.

In fact, sone base level pu ping may be maintained (such as the level of 25% of full pcwer needs) as insurance against a forced plant shutdown or power reduction. When the DO level drops below the pennit levels, the consunptive water usage of Limerick and the power output which results In this usage will be adjusted so that on a daily basis the consumtive usage will not exceed permit requirements.

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s Exhibit 6 1

1 i

l Appilcation of Philadelphia Electric Company

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and Reading Anthracite Conpany for Temporary i

Source of Make-up Water (Beechwood Variance and PECo Withdrawa O e

1 i

Map of Any Lands to be Acoutred or Occupied The consunptive water withdrawal at Limerick is a non-structural proposal with no lands to be acquired.

The pipeline which will carry i

the water purped form the Beechwood Pit to the West Branch Schuylkill 1

i River will be over lands oried or contro11e'd by Reading.

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6-i Exhibit 7 Appilcation of Philadelphia Electric Comany and Reading. Anthracite-Comany for Tenporary Source of Make-up Water (Beech 6w>od Variance and PECo Withdrawal)

. Estimate of Cost of Camleting the Prorased Project i

The consumtive. water withdrawal is a non-structural proposal i

'he release of which involves no expenditures for'Its completion.

T water from the Beechwood Pit will reautre installation of pums in the l

Beechwood Pit and release lines from the Pit to the West Branch j

Schuylkill River at an estimated cost of $25,000.00, plus monthly operational and rental costs.

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s-Exhibit 8 r

Application of Philadelphia Electric Comany and Reading Anthracite Cormany for Temporary l

Source of Make-up Water l

(Beechwood Variance and PECo Withdrawal)

Description of Construction Procedures The consunptive water withdrawal is a non-structural proposal j

which involves'no construction activity.

The Installation of pums in the Beechwood Pit and release lines from the Pit to the West Branch Schuylkill River will be in accordance with standard procedures for such Installations. The pums and discharge lines will be rented.

The nurber of pums will depend-on the capacities of the pums available at the time of rental. The discharge line will be 24 inches in diameter, approximately 3300 feet in length and laid on the surface along the bank of the West Branch Schuylkill River.

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