ML20206J838
| ML20206J838 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/19/1986 |
| From: | Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| CON-#286-705 2.206, NUDOCS 8606270287 | |
| Download: ML20206J838 (6) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION.. 0FF. NUC LEAR REACTOR-RE6UYTION RE: PHILA.ELEC.CO. Limerick Cen.Sta. Units 1 & 2 Dod et No. 50- 52 53 0 k-ARTHONY/F0E RESPONSE TO: COMMISSION'S REFERRAL OF 11' { 'TITION OF 3/5/86 5
TE SUSPENSION _0P LIC.
TO NRd, AND TO D.G.EISENHUT'S LETTER OF 5/27/86 HE.
k M e 19,1986 L
on 3/5/86 we submitted a petition to the CoS(sigy,qing that it act to immediately suspend License NPF-39 issued to PECo,under 10 CFR 50.100 because of violations of Appendix B,in PECe's manipulation of water withdraw-als for Limerick cooling from the Schuylkill River via an application and agreemeninwith DRBC, dated 4/29/86.
In a letter,5/27/86, we were informed by Mr.Darrell Eisenhut that our petition had been referred to him and that he would take action on it under 10 CFR 2.206.
We are not satisfied with this referral.
We petitioned the Commission for a decision and further heist we did not apply under Sec. 2.206 but under Sec. 50.100.
We disugree that this petition does not need immediate action and we ask the Director to institute action for an immediate suspension of license NPF-39 since PECo is endangering the Schuylkill diver and is violatiing the specific requirements of the license, App. B,thereby operating the Limerick reactor in a way to jeopardize the environment and safety of the community. #e have al-ready cpecified the violations and we add here further threats to the biologi-cal life of the river and the unfavorable environmental impacts which contra-securing a dict the EPP and demand a complete study and license amendment before these withdrawals from the river can be implemented.
- 1. We testified at a DRBC hearing on 4/15/86 on the dangers to the river.
We asked D5tBC not to remove the 59 F temperature restriction but to include this along with the DO and flow restrictions. It is obvious from the records of the summer of 1985 that all these limits are ne &d to protect the river life e
from harm and to protect downstream users, including the Philadelphia water supply.
'2. We include as attachment 1 a chart of river flow and D0 submitted to DRBG on 3/4/86 by PEco (V.Boyer). This chart shows 8 days in July and Augu t s
1985 when DO was below the 4.2 ppm constraint despite flow above 680 cfs at the Pottstown gauge,thus iudicating the need for minimum flow requirements although D0 limits must control,along with temperature. The chart shows more than twice as many days of low DO with flows at 530 cfs or more ror these-two g
months. Temperature is the key factor for oxygen demand and river biota health.
PECo's amendment to the DRBC contract was submitted without a study of the effects on river health resulting from the removal of the temperature limit.
from the start
-assible
- 3. NRC and DRBC never considered the Schuylkill as a[yearround cooling water source. It was understood tha t the flow of the river would be ton low 8606270287 860619 O
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2 to assure water use from May to October each summer. PECo is now trying to squeeze the limits of water from the river in direct contradiction to its acceptance of the " river follower" system whicE*Ike original basis for agree-ments with NRC and DRBC.
Up to now both of these agencies have shunned their responsibilities to hold PECo to its agreements,and to protect the river.
- 4. We include as attachment 2
" Table 1"from Mr Boyer's testimony to DRBC,l/22/86.
This table shows clearly the way 'RBCo's manipulatAou of Schuylkill withdrawals will threaten the biolosio life of the river.
It shows 27 days from 6/15/85 to 8/13/85 when "Orygen and Flow Hequirements Met" This means that under similar low flow conditions in the middle of the summer of this year it is possible for the Schuylkill to supply Limerick with cooling wator for approximately half the days without supplemental water,without re-gard to temperature limits.
In 1985 the chart shows temperature rangee at Pottstown of June 67-760F, July 70-82,and August 73-81. To take water from t
the river at these temperatures without any study of the effects on the river life represente an assault on the environment,and a direct violation of the EPP and the operating lic nse.
It is pcssible that river temperatures below e
Limerick af ter the reactor cooling water is withdrawn could reach 15-200 above those recorded at Pottstown. The destructive results must be assessed and prevented by the reinstatement of the 59 temperature limit.
- 5. Disruption of fish hatching may already have happened as a result of PECo's request and DRBC 's granting of an" emergency" removal of the 59 F limit on 4/1/86.
NRC failed to enforce the terms of the license in allowing this.
- 6. DRBC's Revision No.5 provides for diverting Titus and Cromby wator al-lotments to Limerick. Limerick use of Cromby water robs the river of that amount of flow between Limerick and Cromby thereby raising the temperature levels even higher with increased threat of harm to river biology.
- 7. Revision No.6 authorizes diversions for Limerick from Beechwood Pool and two Tamaqua Borough reservoirs.
In violation of Lic. App. B there has been no evaluation of the effects of the releases on river biology and the changes in temperature or D0 levels.
Furthe rmore the scheduling of water arrivals at Limerick cannot be exact enough to prevent exaggerations of low flow periods already existing.This will add further destructive impact which violato the EPP and the conditions of Lic.NPP-39
- 8. Further threats to the river and violations of the license are speci-fied in our letter of 4/16/86 which is included here as_s_ttachment 3.
I certify copies to: NRC-Gun Counsel,DocketingSespectfully submitted, NRR, Staff Counsel; b is f ;/.
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Table 1 i
Summary of 1985 River Conditions Temperature Number of Days Number of Days Oxygen in Relation Range at Oxygen and Flow Time Period In Period River Flow to Limits Vincent Das Requirements Het 6/15 - 6/30 16 3>530 cfs 15 days, Okay 12 of 15 days, 67 - 76*F 12 of 16 ac530 cfs I day flow okay 7/l - 7/31 31 2*530 cfs 16 Okay 10 of 16 70 - 82*F 10 of 31 days, <C 530 cfs days, flow okey 15 days Od 8/l - 8/13 13 JmS30"cfs 9' Okay 5 of 9 days, 73 - 81*F 5 of 13 li days, < 530 cfs flow okay.
4 days 8/14 - 8/31 18 25530 cfs 3 days, Okay 2 of 3 days, 70 - 84*F 2 of 18
<C530 cfs 15 days flow okay 9/1 - 9/26 26 Unaugmented flows Okay 0 days, flow 66 - 81*F 0 of 26 2*530 cfs I day, Okay
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9/27 - Yr. End 96 2*530 cfs 91 Okay entire period 32 - 66*F 96 of 96 days.
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Dalavaro River Baoin 5aciacico Box l@6 Moylas,Pa )1tp@@3 Ue t Trontos,N,.~. 08628 Ap ril 16,1986 Bor 7360.
s Re:
No. D-69 -210 CP (Tinal)
Decr Ladios and Gen tl emen, PECe f.p pli c a t i o n - Use 1966 Ae a fellow-up to my testimony before the Commiseton en 4/15/66 I ask pertission to have the following nupplemental testimony included in the recerd.
It womes under the category of CONCLUSIONS AND RECOMMENDATIOQS.
- 1. The Coerission should refuse the transfer of Titus and Croeiy water
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for Limerick use because there is a finsucial lore to PECo custecurs se stated by Boy e ),3/4/S6,T-5:
.. releasing Titue and Crosby units for service and eliminating the cost penalty incurred through these spprcrimate $1,million/mo' nth feel inits not operating.
(Raphasis added)
In adda '.lon takini Cromby water degrsdes and depr.ves the river reach from Limerick to C:wety ( 9 milee and water coepsnies drawing there) with <tra s tic shown belos,(#11)2 pps DO en 8/19/S6.PE 11g.1.
effects on DO and temperature se
- 2. Require both DO limits and 59.terperature limit at all tise: eince thc3 are both essential to maintaining the river sefety,( See 8 days " Low D3 and Flow Greater than 680 ofe, PE Fig. 1, -
8 days, June te September 1986,)
- 3. Never exempt the DO limits at sty time, including flose when augmer.t sd by Titus quota, Cromby quota or any otbst upstream sources.
- 4. Maintain 530 cfs flow minimum at all times. Do not lower to 415 cre.
5.. Refuse to allow pumping from Beechuced Pit at any time.
- 6. Require an Environmental Report before any action is ta. ken en diverting water from the Tamaqua reseveira since this is a 8 95,000 project which cemee also under the requirements of DRBC Admin. Manual Part II (c) 1. and 2.
7 Since DRHC is dependent en PECo for the readings from the river scultor -
ing stations, DRBC as well as USGS have no immediate, independent means for j
checking the operation of,and readings on the river monitors. Hence DRBC and l
USGS are at a disadvantage in carrying out their responsibility to supervise PECO and the river conditions.
DRBC must require that it and USGS be equip-ped with the means of contacting the monitoring stations directly with the ability to record directly at their offices.
DRBC
- 8. We believe that may have exceeded the authority provided in the compu t 3
when it became the financial agent for PECo in dealing with USGS to install and supervise the monitors.
In any case we ask for an accounting of the S ;3,100 in the origfal 8/85 contract and any additional fun &,to the public we ask that we be provided a copy.
- 9. we register our objection to the action of DRBC on 4/1/86, granting an Emergency gy-tificate to PECo to operate under its apnroval to PECo of 5 /29fe5 D
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 niver outweighe 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 Pp'Ce 7ptepayers would be relieved of the 27% rate increase requested by PECo to par. # It its argument, such as in Table 4, Boyer 3/4/86, PECo is misleading DRBC and the public utih 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 l
Limerick. The public intereet would be served beet by no rate hike and nc Limerick operation.There le no penalty to tha public only benefi t without it.
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The DC cositoring should include the loo reading from tb total 6 cen-itors,not 5 out of 6 as PECo requests.
Consis tently low readings at one or two stations should not be discounted but used as a warning. As an example we include hers D3 levels for the controlling minimums f rom a period in July 1985, tak*n from PECo's weekly reporte.The 6 stations are indicated by the first letter of their names.
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-8 It is important to note that the Vincent Pool has the greateet number of low readings.
Yhese figures were* recorded before the operation of the L merick rne.otor.
It is obricus that the readings at Vincent,which in the i
closest monitor to the plant,however, could not be exspected to improve with plant e,peration,and it is,therefore, e ss ential that Vincent readings imot be dis-mounted by PECo's stratagom to include only the 5 higher stations in the determination of DO.
11.
To demonstrate PECo's disregard for the condition of the river we l
present who stssistics below which show that PECo did not interrupt its op-aration during the depth of the drought despite dangerously low DO content fran early August until Hurrican Gloria en Se)t. 27; and the highes t tempera-0 tnre sater levels of the summer, 840 F in August and 81 F in September.
The cf s and _DO, figures were read from the graphs of Figure 1, Boy.)r 3/4/86.
The electric production figures are from the PECo Limerick monthly operating reports.
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 8'frlYS~
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- 12. We remind DRBC of its obl4.gation to respect the regulations of U.S agencies;1a this case the NRC. We filed a pe tition with NRC, 3/5/86, for in-mediate suspension of the operating license for Lin.erick under 10 CFR 50.100, based on PECo's violation of terms of the license, Appendix 3.
- NRC has not ruled on our petition.
We believe DREC is obligated to defer action on PEco's application until NBC rules en revoking the license. If it is revoked,there will be so basis for PECo's application or for DRBC to act on it.
cc V.S.Beyer,v.p. PECo,NEC, Conner &Eetterbahn Respec tfully cubmitted,
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