ML20198N564

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Forwards Environ Evaluations Re Environ Protection Plan, Referenced in 1985 Annual Operating Rept,Per 860515 Telcon Request.Evaluation 86-01 Re 860401 Emergency Certification for Substitute of Direct Monitoring of Oxygen Also Encl
ML20198N564
Person / Time
Site: Limerick Constellation icon.png
Issue date: 06/02/1986
From: Kemper J
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Butler W
Office of Nuclear Reactor Regulation
References
CON-#286-432 2.206, OL, NUDOCS 8606060125
Download: ML20198N564 (12)


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PHILADELPHIA ELECTRIC COMPANY 23O1 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 JU N 2 - 1985 JOHN S. KEMPER V IC E-PR ESI D E NT E NGINE E setNG AND 8tESE ARCN Mr. Walter R. Butler, Director Docket No: 50-352 BWR Project Directorate #4 FOL:

NPF-39 United States Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Limerick Generating Station, Unit 1 Environmental Evaluations FILE:

GOVT l-1 (NRC)

Dear Mr. Butler:

Per a telephone request, May 15, 1986, from R. E. Martin of your staff, enclosed are copien of the environmental evaluations referenced in the 1985 Annual Operating report which were prepared in connection with the interim supplemental cooling water supply for 1985. Also enclosed is a copy of evaluation 86-1, dealing with the same subject for 1986. This evaluation applies to the April 1, 1986 emergency certification for the substitution of direct monitoring of dissolved oxygen levels for the 59'F constraint on withdrawals from the Schuylkill River. When evaluations concerning the April 30, 1986 decisions (Revision 5 of Docket D-69-210 CP, regarding use of the Cromby/Titus Allocations and Revision 6, regarding 'ise of Tamaqua Water) have been prepared, we will send you copies.

Sincerely, WSWh ACC/mb/05208602 Enclosures Copy to: See attached Service List 9606060125 860602 PDR ADOCK 05000352 R

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cc: Troy B. Conner,* dr., Esq.

(w/o' enclosure)

Ann P. Hodgdon,.Esq.

(w/o. enclosure)

Mr. Frank R. Romano (w/o enclosure)

Mr. Robert L. Anthony (w/o enclosure)

Ms. Phyllis Zitzer (w/o enclosure)

Charles W. Elliot, Esq.

(w/o enclosure)

Barry M. Partman,-Esq.

(w/o enclosure) 1 Mr. Thomas Gerusky (w/o enclosure) i Director, Penna. Emergency (w/o enclosure)

Management Agency Angus R. Love, Esq.

(w/o enclosure)

David Wersan, Esq.

(w/o enclosure)

Robert J. Sugamen, Esq.

(w/o enclosure)

Kathryn S. Lewis, Esq.

(w/o enclosure) i l

Spence W. Perry, Esq.

(w/o enclosure) day M. Gutierrez, Esq.

(w/o enclosure)

Atomic Safety & Licensing (w/o enclosure)

Appeal Board Atomic Safety & Licensing (w/o enclosure)

Board Panel i

Docket & Service Section (w/o enclosure)

Mr. E. M. Kelly (w/o enclosure) l Mr. Timothy R. S. Campbell (w/o enclosure)

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a LIMERICK GENERATING STATION EtNIROf f' ENTAL PROTECTION PLAN Et#1RCWENTAL EVALUAT!ON

SUBJECT:

Substitution for 1985 of instrean monitoring of dissolved oxygen levels In the Schuylkill River in place of the 59 F temperature criteria.

DESCRIPTION:

DRBC Docket No. D-69-210CP (March 29, 1973) precluded Schuylkill River withdrawals for consunctive use by Limerick whenever river water temperatures below Limerick exceed 15 C (59 F), except during April, May, and June when flows measured at Pottstown exceed 1,791 cfs.

DRBC's decision to Ilmlt Schuylkill River withdrawals was Intended to reduce stresses on the Schuylkill River when water quality Is signifl-cantly affected by organic waste assimilation. When temperatures In the river exceed 59 F, the biological oxygen demand accelerates and the dissolved oxygen necessary for waste assimilation becomes critical. On May 29, 1985, the DRBC revised Docket No. D-69-210CP permitting PECo to substitute a dissolved oxygen rrcoltoring program for the previous 59 F termerature Ilmit.

C Atat.YSIS OF ENVIRONMENTAL IMPACT OF CHANGE:

1.

Authorization by the DRBC of a dissolved oxygen monitoring more effectively prevents the Limerick project fran aggravating conditions !n the Schuylkill River during critical periods.

Dissolved oxygen will be ronitored at critical locations at least six times a day above and within 200 feet of each of the six drms on the Schuylkill River located boltw thu Linnrick intnkn.

'In addition, the dissolved oxygen monitors wl11 provide data, not otherwise evallable to the water resource agencles, for bottor imongenant or the !.chuylkill River.

2.

When dissolved oxygen is controlling withdrawal, the IlmIt s are ont tronant vnLively bluh. l*lH; 1%ln hni l(#0 permith no wit.hilrownin for consumtive use whenever dissolved oxygen in the river at or bel'cw Limer!ck as measured at any one or more of the (6) nonitoring st at itwin 19 199= than 1.0 nu/1 innt.nnt.nnotas=ly alurinu Mar t.h i Lee June 15 or equal to or less than 5.1 arc /l daily average or equal to or less than te.2 ng/l Instantaneously during the remainder of thn year. This two ticred nnnitorinu lirogran won not.yx>n tho reconnendation of the Pennsylvania Fish Conmission to accernrodnto the "special seasonal needs of aquatic 11fe."

3.

On the basis of the fact that total volune and percentage of river flow to be withdrawn remains small relative to total river flow, any changes in Impingement or entraInment as a result of withdrawing Schuylkill River water will be minimal.

There will be no significant environmental effect.

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CONCLUSIONS:

4 The tanporary substitution of a dissolved oxygen rnonitoring program for the 59 F ternperature criteria does not involve either: 1) a matter which may result in a significant increase in any adverse environmental

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Impact previously evaluated in the FES-OL, envirorvrental Impact

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appraisals or in any decisions of the Atomic Safety and Licensing Board; 2) a significant change in effluents or power level; or 3) a matter not previously reviewed and evaluated in the above docunents which has a significant adverse environmental Irnpact. Therefore, this change does not involve an unreviewed envirorynental question.

ACTION REQUIRED:

1.

This evaluation must be retained for convenient review and Inspection and made available to the NRC upon request.

In addition, a discussion of this evaluation will be provided in the 1985 Limerick Annual Environmental Operating Report.

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Since the planned activity does not involve an unreviewed environ-rnental question g prior NRC approval is required.

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l ATTACFNENTS:

I 1.

Letter dated March 15, 1985 from E. G. Bauer, Jr. to S. Weisman

J transmitting Philadelphia Electric Ccrmany's appilcation for temporary modification of Docket D-69-210CP.

2.

Letter dated April 24, 1985 from E. G. Bauer, Jr. to S. Weisman transmitting Anendment No.1 to PEco's appilcation for terrporary modification of Docket D-69210CP.

3.

Docket D-69-210 CP (Final) (Revised), Delaware River Basin Ccmnission, May 29, 1985.

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Distribution:

V. S. Boyer

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J. S. Kenper E. C. Kistner 4

S. J. Kowalski l

R. A. Mulford A. R. Diederich l

P. K. Pav11 des G. T. Brecht D. Marano A. R. Lewis E

G. M. Leitch 5

J. J. Clarey D. B, Fetters J. J. Millto DAC (NG-8)

W. T. Ullrich G. A. Htriger, Jr.

G. J. Madsen W. B. W'11sey W. F. McElroy R. B1';e (RMC)

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d' DOCTYPE 161 LIMERICK GENERATItG STATION ENVIROtt4 ENTAL PROTECTION PLAN EtNIRONMENTAL EVALUATION NO. 86-1

SUBJECT:

Terrporary substitution, during 1986, of in-stream monitoring of dissolved oxygen levels in place of the 59 degree F temperature constraint on withdrawals for Limerick Generating Station Unit No. 1.

BACKGROUND:

On March 31, 1986, Philadelphla Electric Cctrpany requested that the Delaware River Basin Cormission grant emergency approval to renew the terrporary substitution for 1985 of dissolved oxygen monitoring in place of the 59 degrees F temperature restriction.

This request was made due to unseasonably warm weather conditions which were anticipated to prevent withdrawal of water at Limerick within several days.

On April 1, the Cerrmission granted the PECo request by issuing an Emergency Certificate subject to alI conditlons in Docket D-69-210CP (Final)(Revised) dated May 29, 1985.

ANALYSIS OF ENVIRONMENTAL IMPACT OF CHANGE:

This change was evaluated for 1985 in the referenced Environmental Evaluation dated June 10, 1985. The envi rorynental advantages of the change detailed in this evaluation are equally appilcable to 1986.

Moreover, PECo's capability for dissolved oxygen monitoring will be enhanced for 1986 as a result of newly installed automatic D.O.

monitoring and transmitting facilities. As in 1985, data will be transmitted to the DRBC daily for their evaluation.

CONCLUSIONS:

Termorary substitution, during 1986, of Instream monitoring of dissolved oxygen does not involve:

1) a matter which may result in a significant increase in any adverse environmental Impact previously evaluated in the FES-OL, environmental Impact appraisals or in any decisions of the Atomic Safety and Licensing Board; 2) a significant change in effluents or power level; or 3) a matter not previously reviewed and evaluated in the above docunents which has a significant adverse environmental impact. Thus, this change does not involve an unreviewed envirorynental question.

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ACTION REQUIRED:

1.

This evaluation must be retained for review and Inspection and made available to the NRC upon request.

In addition, a discussion of this evaluation will be provided in the 1986 Limerick Annual Envi ronmental Operating Report.

2.

Since the planned activity does not involve an unreviewed envirorvnental question no prior NRC approval is required.

REFERENCES:

1.

Limerick Generating Station Environmental Evaluation related to dissolved oxygen substitution for 1985, dated June 10, 1985.

2.

Letter dated March 31, 1986 from V. S. Boyer to S. Weisman requesting reactivation of Docket D-69-210-CP.

3.

Letter from Gerald M. Hansler to V. S. Boyer dated April 1,1986 granting emergency certification.

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o LIMERICK GENERATING STATION ENVIRONMENTAL PROTECTION PLAN ENVIRONMENTAL EVALUATION l

SUBJECT i

Withdrawal of water from the Schuylkill River for consumtive use at Limerick Generating Station unit No. I during 1985 when the flow as measured at the Pottstow) gage is in excess of 415 cfs, the backgrou,d TDS does not exceed 425 ppm, and the dissolved oxygen levels in the

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Schuylkill River at or below Limerick exceed 5.1 mg/l mininun daily average and 4.2 mg/l minimtm Instantaneous value. This is a reduction in the existing flow restraint of 530 cfs.

DESCRIPTION On August 8,1985 Limerick Generating Station began a gradual ascension to full power with tests being conducted at several discrete power levels. The test program will extend through the balance of 1985.

This ascension to full power is being restrained by the availability of cooling' water. Existing flow and dissolved oxygen constraints are l

limiting consunptive water use except for that which can be compensated for by equal reductions in consumtive uses of the Cromby and/or Titus Generating Staticos.

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In order to allow cormletion of the test program, the DRBC on October 2,1985 granted an emergency certificate which changed the flow restraint for consunptive use of the Schuylk!11 River from 530 cfs to 415 cfs.

ANALYSIS OF ENVIRONMENTAL IMPACT OF CHANGE 1.

The 530 cfs ficw limitation on Schuylkl11 River withdrawal was Intended to maintain river water quality primarily by limiting

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total dissolved solids (TDS). The DRBC'S analysis had concluded that with this flow constraint the concentration of TDS would average about 480 mg/l Just below the LGS blowdown discharge pipe.

This value of 480 mg/l represents an increase of 50 mg/l above the upper value of 430 mg/l for natural river background as determined by the DRBC and represents the effect of 2 unit operation at Limerick Generating Station. When 1 unit is operating the TDS wi11 only increase by 25 mg/l to 455 mg/l at the average consunptive withdrawal of 27 cfs. Thus, the new flow target of 415 cfs for one unit operation will maintain total dissolved solids below the 455 mg/l previously considered acceptable by the DRBC. As insurance that this TDS value will not be exceeded, the emergency certificate requires PECo to monitor the background TDS level and to cease water withdrawal when the leyel exceeds 425

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ppm and the flow is between 415 cfs and 530 cfs.

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Any loss of fish due to inpingement will be insignificant because 4

of the small volune and percentage of river flow to be withdrawn l

for one unit operation. An acceptable level of irrpact was expected by the NRC (FES) due to two unit operation at 560 cfs (74 cfs - 13.2% withdrawal frcm River); the present situation is an 8.9% withdrawal (37cfs) at 415 cfs. Critical maximun intake velocities will remain below the level at which fish beccme trapped and impinged on the screen. Other design features of the intake, e.g.,

flush aligrment with the stream bank and the open construction of the structure, will also serve to minimize impingement at the new flow target, as has been the case at the higher target flow.

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Discharge considerations include tenperature and chemical effects.

jf Thermal effects on the blota will be minor and acceptable as c:

previously evaluated in the EROL and FES. Evaluation of water quality effects due to blowdown discharge under the new flow p

conditions was based on March 1979 - Decenber 1984, Septenber-Novenber quarter, maximun and median values for selected i

conservative parameters considered of interest by the NRC in the F

FES. The maxinun concentrations observed in the fall quarter were multiplied by a~ concentration factor of 1 0696' which ~

5 represents a 6.96% increase in constituent concentration due to a

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River flow reduction from 415 to 388 cfs; the 27 cfs being lost

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due to evaporat lon.

T a.

Only iron and chrcmlun in the fully mixed downstream waters I:

were found to exceed the nunerical criteria in PA DER Chapter 5,

93 Water Quality Standards.

Iron concentration does not show a negative correlation with flow and therefore maximum concentrations are not expected at low flows. The Septenber '

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Noverrber autum quarter tredian value for Iron is 0.17 which P

is the lowest median value for any quarter in the 1979-1984 H

period. Thus, iron concentrations may at times exceed the

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appilcable standard due to occasional high source water concentrations. This circunstance was fully evaluated in the

/l EROL and FES. The fully mixed chromtun concentration is b

found to exceed the state standard for the autum maxinun N

- the source water concentration also exceeds the standard, b

Such high source water concentrations are Infrequent and not necessarily associated with low flows. The auturn quarter f

median concentration is 0.009 mg/l and reflects the trore

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prevalent range of values in the Schuylkill.

b.

Both zinc and copper have numerical bloassay criteria. The 6

autum, maxinun fully mixed downstream concentrations for zinc and copper exceed the values considered safe for k

long term exposure of fish based on available bloassay data.

L This situation was reviewed by the NRC In,the FES. Thus, k

Icwering of the flow target level does not create a new set j^;

of circunstances not previously reviewed by the NRC. The high fully mixed concentrations are direct result of the high Y

source water concentration and flow is such that the magnitude of these parameters in the source water is not

.h expected to be any higher at the lower target ficw than at the higher target f i cw.

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_ CONCLUSIONS:

l The withdrawal of water frcrn the Schuylkill River for consunptive use i

during 1985 by L1rnerick Generating Station when the flow is in excess of 415 cfs does not Involve either:

1) a rnatter which rray result in a significant increase in any adverse environmental Irnpact previcusly

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evaluated in the FES-OL, environmental Impact appraisals or in any decisions of the Atcmic Safety and Licensing Board; 2) a significant l

change in effluents or power level; or 3) a rnatter not previously j

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reviewed and evaluated in the above doctsrents ~which has a significant i

adverse envirorvrental Impact. Therefore, this change does not involve an unreviewed envircrvnental question,

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ACTION REQUIRED:

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1.

This evaluation must be retained for review and inspection and rnade available to the NRC upon request.

In addition, a discussion of this evaluation will be provided in the 1985 L1nerick Annual Envircrvnental Operating Report.

2.

Since the planned activity does not involve an unreviewed ewIrorvnental question,no_ prior NRC' approval Is required.

REFERENCE Letter dated Septerrtaer 30 1985 frcm Edward G. Bauer, Jr. to S.

l Weisman transmitting Philadelphia Electric Ccnpany's application i

for approval of the constsrotive use during 1985, by Limerick l

Unit 1 of the Schuylkill River when flow is in excess of 415 cfs.

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Emergency certificate dated October 2,1985 frcrn Gerald M.

Hansler to Edward G. Bauer, Jr.

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LIMERICK GENERATING STATION ENVIRONMENTAL PROTECTION PLAN ENVIRONMENTAL EVALUATION

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SUBJECT:

For 1985, withdrawal of water frcm Schuylkill River for consunptive f

use at Limerick Generating Station Unit No. I when existing flow and dissolved oxygen constraints prevent withdrawal by using, at Limerick

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Unit 1, consunptive water in amounts authorized to be withdrawn, but i

not withdrawn at Titus Generating Station Units 1, 2 and 3 and Crcrrby

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Generating Station Unit 2.

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f DESCRIPTION:

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The Ccrrprehensive Plan of the Delaware River Basin Carmission (DRBC) as

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amended by Docket D-69-210 CP allows consunptive use of Schuylkill

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River water for one unit operation when the ficw is in excess of 530 t

cfs with the folicwing exception: no withdrawals are permitted when 3

the river water temperature belcw Limerick Station is above 15 C except "q

during April, May and dene when the ficw is in excess of 1791 cfs. On May 29, 1985, the DRBC revised Docket D-69-210 CP to permit PECo to substitute a dissolved oxygen (DO) monitoring program for the previous 15 C temperature limit. The DO limitations on water withdrawal are 7.0

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mg/l minimun Instantaneous value until June 15, then 5.1 mg/l minimtm daily average and !+.2 mg/l mininun instantaneous value throughout the y

remainder of 1985.

Under the existing drought conditions the limits on Schuylkill. River water withdrawal are expected to restrict the power ascension testing program planned for Unit i during 1985. Accordingly, the DRBC was requested on May 30, 1985 to permit PECo to obtain a supply of water frcm the Schuylkill not to exceed censunptive use withdrawals now authorized for the Titus and Crcriby Units. Approval for this request was granted on August 9,1985.

ANALYSIS OF EtNIRONMENTAL IMPACT OF CHANGE I

1.

Together, Crcrnby Unit 2 and Titus Units 1, 2 and 3 have been authorized to use Schuylkill water for consunptive uses equivalent r

to a maximun withdrawal of 5.2 mgd. Ccxrparison of this amount to the Schuylkill River 7 day, 10 year, icw ficw value (168 mgd),

r, Indicates the envirormental insignificance of the water quantity involved.

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2.

Of the 5.2 mgd consunptive use authorization that PECo is requesting, 3.5 mgd would be frcm the Titus units. Limerick is

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approximately 23 miles dcwnstream of Titus. Thus, the Schuylkill p

River will be enhanced for a 23 mile reach due to the delay in e

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The remaining 1.7 mgd would be obtained from the Crcnby allocation. An adverse impact on the 9 mile reach below Limerick to Crcnby Station would be expected due to the earlier constrrptive use of water.

4.

Because a longer reach of the river is benefited by a larger quantity of water, the net environmental Impact although inmeasurably small will be positive.

CONCLUSIONS:

The use during 1985 by Limerick Generating Station of the constmptive use water allocation for Titus Units 1, 2 and 3 and Crcnby Unit 2, does not involve either:

1) a matter which may result in a significant increase in any adverse environmental impact previously evaluated in the FES-OL, envirormental impact appraisals or in any decisions of the Atcmic Safety and Licensing Board; 2) a significant change in effluents or power level; or 3) a matter not previously reviewed and evaluated in the above doctments which has a significant adverse environmental impact. Therefore, this change does not involve an unreviewed envircrvnental question.

ACTION REQUIRED:

a.e 1.

This evaluation must be retained for review and inspection and made available to the NRC upon request.

In addition, a discussion of this evaluation will be provided in the 1985 Limerick Annual Environmental Operating Report.

2.

Since the planned activity does not involve an unreviewed environmental question n_o prior NRC approval is required.

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REFERENCE:

Letter dated May 30, 1985 frcm E. G. Bauer, Jr. to S. Weisman transmitting Philadelphia Electric Conpany's application for approval of the use during 1985, by Limerick Unit 1 of the constmptive use water allocations of Titus 'Jnits 1, 2 and 3 and Cromby Unit 2.

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