ML20205E567

Requests NRC Review of Plant Impact on Schuylkill River & River & Valley Life Per 860305 Petition & 860619 Response. Util in Violation of Terms of App B & License Must Be Suspended Until Review Complete

ML20205E567
Person / Time
Site:	Limerick
Issue date:	07/07/1986
From:	Anthony R ANTHONY, R.L.
To:	Bernero R Office of Nuclear Reactor Regulation
References
CON-#386-943 2.206, NUDOCS 8608180426
Download: ML20205E567 (2)

Text

[. y/14 fpf rW 000KETED 3 USNRC Mr. Robert M. Bernero,Dir. BWR Lic. ox 186 Moylan,Pa.19065 U.S. Nuclear D.

Washington, Rep.latory 20555Commiss.

86 JL 10 P3:04 Res Phila.Elec. Limerick, Unit 1. Docket: 50-352

Dear Mr.Berrero,

0FFICE OF SEG@PVICI.

00CKETggE July 7,1986 f.M b We received a copy of your letter of 6/l7/86 to Mr.E.G.Bauer,PECO, and a copy of a letter from Mr.Y.S.Boyer ,FECe s to you, 6/24/86, relative to'our petition of 3/5/86 for an immediate suspension of Lic. NPF-39 for cause,under 10 CFR 50.100. we call your attention to our response to Mr.Eisenhut's letter of 5/27/86 cluded to our further petition,to evidence NRR of the ' 6/19 viokation/86, We in-s ettfor thelicense suspension.

liosase by PECo in its maa-ipulation of Schuylkill River withdrawals through a DRBC agreement. We isolude here our rebuttal of Mr.Boyer's letter sud his enclosure which fails to meet ,

the requiremesis of an environmental impact study and license amendmentzequired for changes in the EFF, license App.B,such as those in DRBC D-69-210,Rev.5 & 6.

We acte that Mr.Eoyer referred to a letter fromT.B.Commer to D.O.Eisenhut, 6/13/86, which we have not seen since we were not provided a copy. We ask that you defer consideration of "his le~tter until we have been served a oopy as required by the NRC,and we have had a ehr.noe to respond to the points cov- i ered. i l ENVIRONMENTAL IMPACTS NOT EVALUATED We ask you to review-the impacts on the Schuylkill River and the river and valley life as set forth in our 3/5/86 petition and ciar response of 6/1%6 to the Comminion and Mr.Eisenhut. We be-lieve that you and the Commission will agree that Py.co has for the most part ignored the impacts caused by its changed withdrawals and that the changes l from the original DRBC agreement must be recinded. We assert that PEco's i

conclusions of no adverse impact,no significant change, ao matters not pre-viously reviewed,and no prior NRC approval required are all . erroneous as we have previously proves and further reinforce wif,h the facts belowfBoyer 6/24,p.6.)

CHANGES IN WITHDRAWAL. All the conclusions regarding coolin erick inFES-OL,4/84, were based on the assumption (FES p.4-3)gthat" water for Lim-virtually all of the water supplied to Limerick to replace consumptive losses...during the period June through October of an average year will come from the Del-aware River /Perkiomen Creek system...".(See the estimated sanounts in Table 4.1. )

1. The effect of effluents from Limerick were evaluated in FES on the basis of Delaware River water being used exclusively from June to October,which FES states (p.4-14) "...will result in the discharge of water of different coup-l osition from that either withdrawn from the Schuylkill River.or ...from the j Point Pleasant Diversion."The effect of exclusive Schuylkill use changes the I

conditions below Limerick and calls for new study of impacts.

2. With the use of Tamaqua water there is no study to seppe.t'.thate the conclusion,Boyer 6/24/86 (Enol. p.4) "...the effects of the L merick i discharge will be essentially the same as evaluated in....the FES (Section 5 3 2 3)"is j in any way aoourate. '

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3. The impact of chlorine levels from Limerick evaporization on the Schu-ylkill was only studied by Penna DER in 1982 (FES p.5-9)and this study was predicated ou use of Delaware water from June to October,presumeabily. There has to be a new ba in act study covering the exclusive use of Schwylkill water.

4. The FES3 cono usions on the values of" major' water quality constituents in the Limerick discharge" and " variations.in source. water quality...and om applicable DRBC constraints" on source water withdrawal."These conclusione, 8608180426 860707 PDR P

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l obviously,are based on a 59 F temperature limit and not DO content,as well 0

I as mixing with Delaware water. With the addition of Tamaqua water a new con- '

dition with respect to water constituents is added and this has to be the subject of a new study because of changed conditions. (See FES ,p.5-lO) l l

5.There has to be a new study to determine whether the constituents and the parameters are similar oidifferent from those in Table 5 3 (FES). With-out a study of the Tamaqua constituents the PEco conclusion " essentially then same" (para.f2,above) is without foundation.

on IMPACT ON FISH AND BIOLOGIC LIFEl.1here has been no study of the effecta gish and aquatio life from elimination of the 59* temperature limit and injection of large quantities of Tamaqua water.

6. Tables 4,4 and 4 5 FES are no longer relevant to the Schuylkill,with the addition of Tamaqua water , 1 . new study must be made and impacts eval-usted.

7. The possibility of endangered aquatio species in the Schuylkill be-.

twass Tamaqua and Limerick must be considered and impact evaluated.

8.The effect on stream life of sudden ~1arge volumes of water coursing" down the upper Schuylkill must be evaluated,at times of low flow conditions.

Additional pollutants may be dislodged.

9. Additional entrainment will occur at the Limerick intake because of-fish and larvae swept downstream by the Tamaqua and Titus water.

10. Not only is a new study of additional entrainment reggired, but the conditions controling numbers,.Boyer: 6/24(Enol.p.5),arenolongerapplicable ,

"(4) the peak larval abundunce soeurs during June end July,q priod when 70% ,

of the Limerick water needs will he sunplied from diversion water from the Delaware River and Perkiomen Creek".."(Emp.added) Delaware is not isow'uned.

11. The peak load of drif t organisms is shown in Boyer 6/24 (Esol. Tab.5-1-5) to moeur in the 1975 study,24 June and 5 Aug.; for 1976,1 June and 15 June.

Anthony 6/19/86(Attach #2)(Table times under DRBC1)(shows Rev.5.) asadded days of Schuylkill withdrawal 12 days,6/15-6/30:

during 7/31 s 5these days peak.~/13.

8/1-8 This,therefore, indicates 27 additional days in twolo day months of peak impingement never evaluated under the former DREC agreement,ard FES.

12. DRBC (Rev.6. p.6) showelO2 potential days of ee'rainments with 'the addition of Tamaqua and Cromby-Titus water,with intake from the Schuylkill rather thaa Delaware BLyer, water which was the basis for FES. These heretofore unevaluated impacts must be covered inr a new impact study required by Lio.NPF-39.

l 13. The findings in FES 5 3 2.2'on thermal impacts no longer a[ ply under I DHBC Rev.5 and Rev.6. These findings are based on the use of Delaware water l

i and a restriction of 59 on Schuylkill water. With exclusive Schuylkill use,

• water will be withdrawn at river temperatures from June through August fha 67 to 84* (Att.# 2, Anthony 6/19) and in the worst case Boyer 6/24 enol.p.6) 37 ofs can be withdrawn which is 14% of the river . low flow. ghis means that river biota under worst conditione can be subject to a 5*F increase from blow-down on top of river temperature of 84*,a total of 897 below Limerick. These same temperature extremos could existifffamaqua and Crhaby-Titus water were used.

(See FES p.5-3 )The effects of such extreme temperatures have not been studied.

CONCLUSION. We believe that you will find on the basis of the evidesee we have submitted and from your own study that PEco is in violation of the terms of

. Appendix B,Lio.NPF-39 and that the license must be suspended until the unre-viewed impacts; are reviewed and the illegal EPP changes offered is amendment.

Copies to:NRC Gen. Counsel,Dookoting, Staff Counsel

' ectfull'

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