ML20206P612
| ML20206P612 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/24/1986 |
| From: | Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Bernero R Office of Nuclear Reactor Regulation |
| References | |
| CON-#386-820 2.206, NUDOCS 8607020169 | |
| Download: ML20206P612 (13) | |
Text
.s PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 (215)841-4500 V. S. BO Y ER SR. VICE PRESIDENT NUCLE AR POWER June 24, 1986 Mr. Robert M. Bernero Director Division of BWR Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Re: Limerick Generating Station, Unit 1, Docket No. 50-352
Dear Mr. Bernero:
)
This responds to your letter dated June 17, 1986 concerning the petition by Mr. Robert L. Anthony, dated March 5,1986, which requested action pursuant to 10 C.F.R. Section 2.206. As noted in your letter, the relief sought by Mr.
Anthony is based upon alleged violations by the Licensee of certain requirements of the operating license for the Limerick Generating Station, Unit 1, as contained in the Environmental Protection Plan.
In your letter, you note your ongoing review of the docket decision of the Delaware River Basin Commission ("DRBC") recently furnished to the NRC by Licensee's counsel. You request the Licensee to submit a response to the issues raised in Mr. Anthony's petition which "should consider all of the issues required to be considered by the EPP, including but not limited to impingement and entrainment impacts."
We believe that your questions regarding Mr. Anthony's Section 2.206 petition have been answered by the letter dated June 13, 1986 from Troy B.
Conner, Jr., Licensee's counsel, to Darrell G. Eisenhut, Acting Director, NRR, which presumably crossed in the mail with your letter. The extensive comments provided therein explain why there is no merit to any of the factual or legal allegations contained in Mr. Anthony's petition and are incorporated herein by reference.
Also, on June 13, 1986, Licensee prepared its internal evaluation of potential environmental impacts associated with the DRBC docket decision to which you refer in your letter of June 17, 1986. That evaluation (copy N
$ft l2 I
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s Mr. Robert M. Bernero June 24, 1986 Page 2 enclosed) addresses the specific point of potential impingement and entrainment impacts in the Schuylkill, as requested in your letter, and is incorporated herein by reference.
Sincerely,
)1tCA1 Vincent S. Boyer VSB:pke Enclosure t
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o CO M EALTH OF PENNSYLVANIA:
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C0(NIY OF PHILADELPHIA Vincent S. Boyer, being first duly sworn, deposes and says:
That he is Senior Vice President of Philadelphia Electric Company, the Licensee herein; that he has read the foregoing letter and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.
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Senior Vice President Subscribed and sworn to 7
before me this27 day of June, 1986.
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Notary Public MEl.AN!E R. CAMPANELLA Notary Public, Philadelphis, Philade'phia Co.
My Commission bpires February 12,1990
s cc: Troy B. Conner, Jr., Esq.
(w/ enclosure)
Ann P. Hodgdon, Esq.
(w/ enclosure)
Mr. Frank R. Romano (w/ enclosure)
Mr. Robert L. Anthony (w/ enclosure)
Ms. Phyllis Zitzer (w/ enclosure)
Charles W. Elliott, Esq.
(w/ enclosure)
Barry M. Hartman, Esq.
(w/ enclosure)
Mr. Thomas Gerusky (w/ enclosure)
Director, Penna. Emergency (w/ enclosure)
Management Agency Angus Love, Esq.
(w/ enclosure)
David Wersan, Esq.
(w/ enclosure)
Robert J. Sugarman, Esq.
(w/ enclosure)
Kathryn S. Lewis, Esq.
(w/ enclosure)
Spence W. Perry, Esq.
(w/ enclosure)
Jay M. Gutierrez, Esq.
(w/ enclosure)
Atomic Safety 6 Licensing Appeal Board (w/ enclosure)
Atomic Safety 6 Licensing Board Panel (w/ enclosure)
Docket 6 Service Section (w/ enclosure - 3 copies))
E. M. Kelly (w/ enclosure)
Timothy R. S. Campbell (w/ enclosure)
_____________________________________J
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DOCTYPE 161
' LIMERICK GENERATING STATION ENVIR0fMENTAL PROTECTION PLAN ENVIRONMENTAL EVALUATION 86-2 SUBJECT Withdrawal of water from the Schuylkill River for consunptive use at Limerick Generating Station when:
1.
The consunptive use at Titus Generating Station or the
'Crcmby Generating Station has been curtailed. The consunptive use at Limerick is not to exceed the quantity saved by the curtallment of generating units at Titus and/or Crerrby Generating Stations. The maxImun quantity that can be considered saved in this process is 3.5 mgd at Titus and 1.7 mgd at Cromby.
2.
The consunptIve use has been replaced in equal volune by water released from the Still Creek and/or Owl Creek Reservoirs upstream of Limerick.
DESCRIPTION The Delaware River Basin Comniston (DRBC) on April 29, 1986 issued Revisions 5 and 6 of Docket No. D-69-210 CP (Final). These revisions are temporary and apply only for the remainder of 1986. The changes in Limerick withdrawals authorized by Revision 5 are as follows:
1.
No withdrawals for consunptive use shall be made fran the Schuylkill River or the natural flow of any of its tributaries whenever dissolved oxygen (I) is less than 7.0 mg/l daily average or 6.0 mg/l instantaneous during the period of March 1 to June 15 at any one of the nonitoring sites in riffle spawning areas located below Limerick approved by the Executive Director in consultation with the Pennsylvania Fish Comnission (PFC) or (ii) is equal to or less than 5.1 mg/l daily average or equal to or less than i.2 mg/l Instantaneous value at any of the six existing t
monitoring stations temporarily approved by DRBC Docket No.
D-69-210 CP (Final)(Revised).
2.
Water may be withdrawn for consunptive use at Limerick whenever the consunptive use at Titus Generating Station or Cromby Generating Station has been curtailed. The consunptive use at Limerick shall not exceed the volune equal to a quantity saved by the curtallment of generating units at Titus and/or Cronby gererating stations. The maximun quantity that can be considered saved in this process is 3.5 mgd at Titus and 1.7 mgd at Cronby.
_____--__-______-_-___-__-________-_-_-_____A
s Revision 5 provided essentially the same relief as the DRBC's action on April 1, 1986 which granted an Emergency Certificate approving the substitution of dissolved oxygen limits in place of the existing temperature restriction. The Emergency Certificate was based on prior approval of the same request as described in DRBC Docket D-69-210 CP (FINAL) (REVISED) which was approved on May 29, 1985. That i
approval subsequently. expired on December 31, 1985. This change was evaluated in Environmental Evaluation 86-1 which determined that no unreviewed environmental question was created.
The change in Limerick withdrawal authorized by Revision 6 of the Docket allowed water to be withdrawn during 1986 for constmptive use at Limerick regardless of existing constraints whenever that constmptive use has been replaced in equal voltme by water. released from Still Creek and/or Owl Creek Reservoirs. The Still Creek and Owl Creek Reservoirs are owned by the Borough of Tamaqua and are used for municipal water supply.
Still Creek Reservoir is located
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in Schuylkill County, 2.3 miles north of Hometown, Pa. and approximately 5000 feet above the confluence of Still Creek and the Little Schuylkill River. The two Owl Creek reservoirs are located approximately 1.5 miles southeast of the Borough of Tamaqua in I'
Schuylkill County. The attached map shows the relationship of Still and Owl Creek reservoirs to the Limerick site.
ANALYSIS OF ENVIR0bNENTAL IMPACT OF CHANGE Substitution of Dissolved Oxygen Limits The substitution of dissolved oxygen (0.0.) limits for Schuylkill River withdrawal In place of the 59o criteria was previously evaluated in 1985. This prior evaluation found that the change did not involve a significant increase in the environmental Impact previously evaluated for the 59 criteria. The finding was based on an analysis which demonstrated that D.O. monitoring above and within 200 feet of each of the six dams on the Schuylkill River located below the Limerick Intake effectively determines when Schuylkill River water quality is significantly affected by organic f
waste assimilation. Moreover, the more restrictive D.O. Ilmitations imposed by the Docket revision frcm March 1 to June 15 was found to acconmodate the special seasonal needs of aquatic IIfe. The Schuylkill River chemistry and fishery were nonitored during 1985 as part of the Limerick nonradiological monitoring program. No adverse environmental effects were observed and none are expected due to substitution of D.O.
Iimits durIng 1986.
Use of Cromby/Titus Allocations 4
Use of these allocations was approved by the DRBC for 1985.
The envirormental evaluation conducted in 1985 found that the water quality impacts of use of the Cromby/Titus consunptive water allocations are related to changes in Schuylkill River flows. The reach between Titus and Limerick (23 miles) will be enhanced in flow i
by 3.5 mgd over the amount which would occur if Titus were in operation. On the other hand, the reach downstream of Limerick to the
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Cromby Plant (9 miles) will be depleted by 1.7 ngd. Because the quantitles involved are such a sna11 fraction of the existing river flows the effect on water quality will be negligible. However, because a longer section of the river will have enhanced flows, the net effect, although irrmeasurably small, w!!1 be positive.
During the periods in 1985 when Limer!ck was operated using the Titus/Cromby allocations, no adverse environnental effects on the water quality or blota of the Schuylkill River were observed. No adverse environmental effects are expected since the 1986 allocations are the same as those evaluated for 1985.
Use of the Croaby/Titus allocations at Limerick will not significantly change the environmental effects of the Limerick Schuylkill River intake. This is evaluated later under Withdrawal Effects.
Use of Still and Owl Creek Reservoirs Two potential environmental imp 5 cts related to the use of consunctive water fran the Still and Owl Creek Reservoirs were evaluated.
1.
Reservoir water quality - The water quality of Still and Owl Creek Reservoirs is very good throughout the pools.
Chenical analyses have Indicated that the water in the reservoirs is of better quality than nonna11y found in the Schuylkill River with the Reservoirs having average total dissolved solids (TDS) of 32 ppm.
No pollutants have been detected in the Reservoir water and no significant point sources of pollutants have been Identified within the Reservoirs' watersheds.
No adverse water quality effects are expected due to the drawdown of the reservoirs. No bottom sedinent-related problems have been encountered since installation of the aeration system and alleviation of anoxic botton water conditions.
Revision 6 of the Docket Section (2)bb, states that there shall be no releases from Still Creek Reservoir for consunptive use at Limerick Unit I whenever the water level in the reservoir pool is below the operating rule curve attached to Revision 6 of the Docket which assures protection l
of Tanaqua's available water supply.
A dissolved oxygen monitoring program has been established in accordance with provisions in the Docket Decision to identify any changes which any occur during reservoir use.
Docket Revision 6 section (2)aa states that the Executive Director of the DRBC nay nodify or suspend releases if nonitoring results indicate that releases are causing dissolved oxygen problens in the receiving waters.
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2.
Impact on downstream water users - The major streamflow effect is increased flows of high quality water in 77 miles of stream. Discharge from the Still Creek Reservoir is through a pipeline which in turn exits into Still Creek utilizing an energy dissipator which will minimize potential for erosion and assure that the discharge is well oxygenated.
The amount of water to be released into Still and Owl Creeks will be within the capacity of the receiving streams.
Spill records for the Reservoirs indicate that the receiving
.I streams regularly carry nure water than the 28 cfs maximun release for Limerick. The percentage increase in flows in the Little Schuylkill and Schuylkill 'ivers will not be R
1arge enough to affect erosion.
Since releases from the Tamaqua reservoirs will actually
'I reduce the total dissolved solid (TDS) concentrations in the Little Schuylkill and Schuylkill Rivers slightly, the effects of the Linerick discharge will be essentially the same as evaluated in the EROL (Section 5.1) and the FES (Section 5.3.2.3).
Withdrawal Effects The combination of conseptive make up supply by use of Crcrrby/T1tus allocations and Still/ Owl Creek Reservoirs will not significantly change the effects of the Limerick Schuylkill River intake. These effects are evaluated below.
The Limerick Schuylkill River intake is described in EROL Section 3.4.5 and shown in EROL Figures 3.4.7-3.4.10.
The intake design implements the EPA criteria for good design features and minimizes the potential for impingement impact.
The Schuylkill River pep structure is a full-capacity intake rated at a total flow of 34,000 gpm with a maximtm physical capability of 42,000 gpm. There are three wet-pit vertical turbine ptmps (each protected by a traveling screen) rated at 11,300 gpn per ptmp. A fourth vertical traveling screen protects two wet-pit vertical turbine ptmps, each rated at 5650 gpn. Trash racks (with 3-1/2-inch clear openings between bars) are provided in front of the intake to protect the screens, and in both the upstream and downstream ends of the intake to allow free passage of fish swinming near the screen face. The trash bars are placed upstream and downstream to permit an escape route for the fishes which might temporarily swim in front of the vertical traveling screens. The trash bars extend nearly the full vertical height of the supporting structure pennitting light to enter the enclosed area. Deck gratings also were installed to pennit light to enter frcm above. A floating trash bocm in front of the trash racks diverts nest surface debris and drift organisms before they reach the trash racks. The vertical traveling screens are placed so that the offshore face of the screens is flush with the walls of the structure, and in line with the nonnal river bank. The 5 feet wide screen trays are fabricated with No. 14 gauge (0.080 inch) stainless steel mesh with h-Inch clear openings. At average river level (elevation 106-108 feet MSL). and rated ptmp flow, the average approach velocity to the screens is less than 0.5 fps.
NRC review of the Schuylkill intake determined there was minimal impingement Impact for the followlng reasons: "(1) the.
most abundant species near Limerick also a're abundant throughout the river study area; (2) habitat-fonning macrophytes are extensive in the river and are not unique to the site; (3) passage in the river for fish novements exists in the west river channel that is removed fran the sphere of influence of the intake; and (4) approach velocities will be Icwest during the higher river flows of winter and early spring" (FES, p. 5-29) and identified the intake velocity of 0.5 to 0.6 fps as a consideration in reaching that conclusion. The four conclusions are Independent of any withdrawal rates which may change during 1986. The approach velocity also remains as stated because the design of the Schuylkill intake (described above) is such that the water velocities approaching the traveling screens do not vary substantially with the rate of water withdrawal. For example, at the withdrawal rate of 21 cfs, one of the four punp bays would be in operation, resulting in an approach velocity to its traveling screen of 0.4 fps at the extreme low river level of 104 ft. (MSL)
(EROL Pg. 3.4 - 6). Under the expected withdrawal rate for 1986 (37 cfs), two punp bays would be used, resultIng in an approach velocity of 0.5 fps (screen 1) and 0.3 fps (screen 2) at this water level. Therefore, as these velocities remain at or below the values used in the FES evaluation, no significant change in impingement effects is anticipated.
Entrainment of larval fishes, primarily goldfish, carp, minnows, and sunfishes, has been previously acknowledged as acceptable impact of station operation.
In the FES it was anticipated that entrainment impacts to the river fish population would be minimal for four primary reasons: "(1) the larval species abundant near Limerick also are abundant throughout the river study area; (2) although spawning does appear to occur near Limerick, the area does not appear to be unique in this respect; (3) few fish eggs were collected near Limerick (most river fishes deposit demersal eggs that are not susceptible to entralnment); (4) the peak larval abundance occurs during June and July, a period when 70%
of the Limerick water needs will be supplied from diversion water from the Delaware River and Perkionen Creek" (FES page l
5-29).
The first three statements are unaffected by changes In plant withdrawal rates. The fourth statement is analyzed below.
I EROL Table 5.1-4 presented the predicted entrainment of fish eggs and larvae at LGS during the 1975 and 1976 spawning seasons.
Fleid data shcwed that goldfish, carp, several minnow species, and sunfishes (four species) would account for practically all larval i
fish entrained.
Included in this table was a calculated percent i
of the larval fish and egg drift entrained. This figure did not equal the percentage of river ficw entrained because of distributional differences in organism density across the river. A revision of Table 5.1-4 which shcws the pertinent infonnation in sunnary fonn was prepared and is attached to assist in this l
reevaluation of the entrainment impact. The revised percer.t drift entrained is calculated frcm a ratio of revised and previous percent #10w entrained times the previous percent drift entrained.
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4 The relative contributions of the specific taxonomic categories which appeared in the drift collections.can be seen by reference to the original. EROL table. The revised entrairment projections do not indicate a' potential for a biologically significant impact of the changed node of operation on the fish conmunity.
Even at the 7 day,10 year (Q7-10) Schuylkill River low flow (260 cfs), no significant change in species composition or abundance of important species near Limerick should occur during 1986.
In the EROL, entrainment analysis covered a wide range of river flows, including the Q7-10 where 9.3% of the river flow was assumed to be withdrawn (EROL page 5.1-5).
Under DRBC Docket Revisions 5 and 6, Limerick would be permitted to withdraw 37 cfs which would equal a withdrawal rate of 14%. Flows as low as 260 cfs have not occurred historically until late surmer when fish spawning has been concluded and few larval fish would be expected. Thus, actual withdrawal rates during the period of peak larval fish abtsidance can be expected to be much less than the 14% discussed above. The additional 5% of river flow withdrawn at Q7-10 does not represent a significant increase in either the withdrawal rate or in the corresponding entrainment of larvae fish and eggs.
CONCLUSIONS:
The use during 1986 by Limerick Generating Station of dissolved oxygen limits in lieu of the 59 F criteria, the consunptive use water allocation for Titus/Cromby and releases from the Tamaqua reservoirs 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, 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. Therefore, these changes do not involve unreviewed environmental questions.
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 must be provided in the 1986 Limerick Annual Environmental Operation Report.
2.
Since the planned activities do not involve unreviewed environmental questions, no prior NRC approval Is required.
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REFERENCES:
Letter dated, December 16, 1985 frcm V. S. Boyer to S. M.
Weisman transmitting Philadelphia Electric Canpany's application for substitution of dissolved oxygen monitoring and for use of the Titus/Crcmby allocation for 1986.
Lett'er dated March 4,1986 from V. S. Boyer to S. M. Weisman transmitting Philadelphia Electric Company's application for the use of releases frcm Tamaqua reservoirs.
Notice of Conmission Action dated April 30, 1986 issuing revisions 5 and 6 on Docket No. D-69-210 CPCFinaO Final Environmental Statement related to the operation ~of Limerick Generating Station, Units 1 and 2, U.S. Nuclear Regulatory Ccnmission, April 1984.
Environmental Report Operating License Stage, Limerick Generating Station Units 1 and 2, Philadelphia Electric Company, March 1981.
Philadelphia Electric Company's response to Conments on its Application for Dissolved Oxygen Measurements in Lieu of Temperature, Its Use of Titus-Cromby Allocations and Use of Tamaqua and Beechwood Water.
Prepared under the direction of V. S. Boyer, March 4, 1986.
Prepared by:
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REVISED REVISED Total 24-hr REVISED Withdrawal WITHDRAWAL River
% Flou X FLOW Drift X Drift
- 2 D' RIFT '
Date Rate RATE Flou Withdrawn WITHDRAWN
(# of Organisms)
Entrained ENTRAINED CFS CFS CFS 1975 20 May 74 37 2027 3.6 1.8 482,100 3.8
- 1. 9' 11 June 74 37 1829 4.1 2.0 99,810 4.4 2.2 24 June 25 37 1268 2.0 2.9 591,500 2.3 3.3 8 July 21 37 1518 1.4 2.4 315,400 1.8 3.1 5 Aug 25 37 2098 1.2 1.7 767,779 1.5
,2, 1 19 Aug 21 37 1267 1.7 2.9 115,400 2.0 3.4 2 Sep 21 37 1098 1.9 3.4 8,868 3.3 5.9 1976 4 May 21 37 2210 1.0 1.7 250,100 6.1 1' 0. 4 18 May 21 37 2669 0.8 1.4 1,852,000-8.8 15.,4 1 June 21
~37 1759 1.2 2.1 3,489,000 13.0 22.8 15 June 21 37 796 2.7 4.6 2,350,000 5.4 9.2 30 ' June 21 37 2168 1.0 1.7 881,700 2.3 3.9 13 July 21 37 1660 1.3 2.2 704,500 2,1 3 '. 6 f
27 July 21 37 720 2.9 5.1 298,500 Sc5
'9.7 12 Aug 21 37 1310 1.6 2.8 83,300 3.3 5.8 25 Aug 21 37 812 2.6 4.6 122,000 4.1 7.3 O
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