ML20203C836

Provides Supplemental Testimony to 860415 Hearing Before Commission for Inclusion Under Conclusions & Recommendations Category.Related Correspondence

ML20203C836
Person / Time
Site:	Limerick
Issue date:	04/16/1986
From:	Anthony R ANTHONY, R.L.
To:	NRC COMMISSION (OCM)
References
CON-#286-830 OL, NUDOCS 8604210249
Download: ML20203C836 (2)

Text

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%' Delc;are Riv;r Basic Cennicnico DdW6r 7 Box 186 Ccylan,Pa 19065 l "q , y 9, Box 7360. Dast Treat c,N,J. 08628 /"' C L A Pril 16,1986 l

Dear Ladies and Gentlemen,

Re No. D-69-210 CP (Final)

PEco Application- Use 1986 As a fellow-up to my testimomy before th Q / /

permission to have the following supplementab $ p sien eptimony en 4 in included 15the 86 record.

I ask It eones under the category of COECLUSIONS AND RECOMMENDATIONS.

% APR 18 mt :31

1. The Commissian should refuse the transfer of Titus and Cronby water for Limeriek use because there is a fi g seial loss to PEco anatomers as stated byBoyer,3/4/86,T-5: 066nh .

.. releasing Titus and Crosby unit.5faicisidae and eliminating the approximate $1 million/ month fuel cost penalty incurred through these units act operating. (9mphasis adt.ed)

In addition takine Cromby water degrades and deprives the river reach from with drastie Limerick effects ontoDO Crosby (, 9 miles as and temperature andshown waterbelow,(fil)2 companies ppmdrawing 30 em there)/19/86,PE 8 Fig.l.

2. Require both DO limita and 59 0. temperature limit at all times since they are both essential to maintaining the river safety.( See 8 days " Low DO and Flow Greater than 680 efs, PE Fig. 1, = 8 days, June to September 1986 .) l 1

3. Never exempt the DO limite at any time, including flows when augmented I by Titus quota, Cromby quota or any other upstream sourses.

4. Maintain 530 cfs flow minimum at all times. De not lower to 415 efs.

5.. Refuse to allow pumping from Beechwood Pit at any time.

6.Hequire an Environmental Report before any action is taken om diverting water from the Tamaqua resevoirs since this is a 8 95,000 Project which eenes also under the requirements of DRBC Admin. Manual Part II (c) 1. and 2.

7 Since DREC is dependent en PECe for the readingsfrom the river motiter-ing stations, 3RBC as well as USGS have no immediate, independent means for checking the operation of,and readings on the river memiters. Hence DRBC and USGS are at a disadvantage in carrying out their responsibility to supervise PECO aug the river conditions. DRBC must require that it and USGS be equip-pod with the means of contacting the monitoring stations directly with the ability to record directly at their offices.

8.Webelievethatfahhaveexceededtheauthorityprovidedinthecompact when it beosmo the financial agent for PEco in dealing with USGS te install l and supervise the monitors. In any case we ask for an accounting of the $ 39,100 '

in the origfal 8/85 contract and any additional funch,to the public . We ask that we be provided a copy.

9. We register our objection to the aetion of DRBC on 4/1/86, granting an Emergency 3 M ificate to PECe to operate under its approval to PECo of 5/29/85 We believe 7 ailed to act under the requirement of Sect. 2-3 9 (d) "to protect the public interest" since that interest in maintaining the biological health of the Schuylkill d iver outweighs the public interest in keeping Limerick operating.

In fact it would serve the public interest to have the Limerick unit 1 shut down and never operate again if that would mean PJ'Coptopayers would be relieved of the 27% rate increase requested by PECo to pay'. #It its argument, such as in Table 4, Beyer 3/4/86, PEco is misleading DRBC and the public wtih its cate-gory " Cost Penalty to Public" because PEC was buying power before Limerick started commercial operation at less cost than the price of producing it at Limerick. The public interest would be served best by no rate hike and no Limerick operation.There is no penalty to the public only benefit inithout it.

8604210249 860416 PDR ADOCK 05000352 T PDR DSG3 _.

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10. The DO mesitoring should include the low reading from tie total 6 men-itors,not 5 out of 6 as PEco requests. Consistently low readings at one or two stations should not be discounted but used as a warning. As an example we include hers DO levels for the controlling minimums from a period im July 1985, taken from PEco's weekly reports.The 6 stations are indicated by the first letter of their names.

DME 7h_ 9 .lo 11 I L- I3 If Il n if 19 20 11 Do 3.s V.7 St '/.Y_ 3.7 V./ //./ 3.V 3,4 3E38 41 e/./

.STA . FR V V V N N r1 F A M f FR F

SUMMARY

(

22- 23 JV .16~ ,% 22 23 30 at y NXy :l

%0 37 S.1 43 Y0 36 4,3 4.Y 3.T Plymouth =1 V J _ l j _ E__ER V V V V Norristown =7

) Black Rock = 0

.Vinoemt =8 It is important to note that the V,incent Pool has the greatest 'aumber of low repdings. @hese figures were recorded before the operation of the Limerick remotor. It is obvious that the readings at Vincent,which is the closest monitor to the plant,however, oculd not be exspected to improve with plant operation,and it is,therefore, essential that Vincent readings hot'be dis-sounted by PEco's strategen to imelude only the 5 higher stations in the determination of D0.

11. To demonstrate PEco's disregard for the condition of the river we present the statistics below which show that PEco did not interrupt its ep-eratitu during the depth of the drought despite dangerously low DO content from ocaly August until Hurrican Gloria en Sept. 273 and the highest tempera-ture water levels of the summer, 840 F in August. and 81* F in September.

The ofs and ,DO figures were read from the graphs of Figure 1, Boyer 3/4/86.

The electric production figures are from the PECo Limerick monthly operating reperts. PEco received a full power operating licence 8/8/85. Water augmenta-tien from Blue Marsh took place 9/1'10 and 9/11- 19 (ltltS~ 39o ets F%ttsrowel .a.5 bo hws LimRM ust,PPegencA 5 S3o 18 3,6 0

/c /ceo 0 13 _ ._ 400 . 31- O

/[-.. 00 .

. - - . - 3, Y 100 19 310 2 O

.24 - J oe 3,8 13I 26 too 3,7 12.2-9/r . . . - . M90 .  % oF'f

12. 3s~c 3.6* O i9 95o S* 8 l14 DO levels are minimum instantaneous readings.

12. We reused DRBC of its obligation to respect the regulations of U.S agenciestia this case the NRC. We filed a petition with NRC, 3/5/86, for in-mediate suspension of the operating license for Limerick under 10 CPR 50.100, based on PEco's violation of terms of the license, Appendix B. 'NRC has not ruled on our petition. We believe DRBC is obligated to defer action on PECo's application until NRC rules en revoking the liosase. If it is revoked,there will be no basis for PEco's applicaties or for DRBC to act on it.

so: Y.S.Beyer,v.p. PECo,ERC,Conser&Wetterhahn Respectfully submitted,

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