ML20212F798

Submits Testimony Opposing Granting Extension of Revs 5 & 6 to Docket D-69-210 CP for Facility.Author Unable to Attend 870225 Public Hearing

ML20212F798
Person / Time
Site:	Limerick
Issue date:	02/19/1987
From:	Anthony R ANTHONY, R.L.
To:	Weisman S NEW JERSEY, STATE OF
References
CON-#187-2658 2.206, NUDOCS 8703050160
Download: ML20212F798 (3)

Text

2 W 6G. M S. c. . f. &WWS Rf_ l 3W CIP.0T~ S*T ' 3 N 9 i M LSu nn Coicasa,Srcratary Dox 186 M2ylan,Pa.19065 dei =cro River Bacin Cc niccion

• West Trenton, N. J. 08628 g. February 19,1987 TO THE CCBGIISSION: M' # * '

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to This is testimony Docket D-69-210against CP forthe granting,bnubTsh PECo's Limerie reactor.gf g egteg i,q Weof will Revisions not be5 and 6 able to attend the public hearing on February 25th but we urgently charge the l Commission to heed the points below and to deny the extention to PECo.

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SUMMARY

. We remind DRBC of the vital issEes at stake as set forth in our state-ment written to DRBC on 4/16/86 and our letter of 1/26/87 At this point we find that our testimony against the increased use of Schuylkill water for PECO's consumption is reinforced by the addition of river D.O., flow,and temperature records for the low flow periods during 1986. We thank you for sending us daily readings from the river monitors and the PECo record on water transfers. We are I also aware of a new threat to drinking water supplies from the Limerick blowdown. 1 The NRC Final Rnvironmental Statement (FES), Limerick (p.5-16,1.7) warns against l concentrations of triholomethanes from Limerick discharge of chlorine to the ziver and implies that these could exceed the maximum levels under the National SaIe Drinking Water Act. It is the responsibility of DRBC and PECo to conduct a com-plete Environmental Impact Study,te also. assess creation of THM, before further threats to drinking water supplies are licensed by the DRBC. As a warning we have been informed of a random water tap sample g m a Schuylkill consumer down-stream from Limer ok which had a THE content for onE sample,in excess of the total of the four year State requirement.

We remind DRBC that we have found PECo in violation of the operating license from NRC for Limerick and that we have appealed to the 3rd Circuit U.S. Court .

This case is coming to a hearing soon; our brief is due on 3/4/87 If we re-ceive a favorable decision we expect the Court to grant compensatory and puna-tive damages as we have petitioned . If it should turn out that there is proof of carcinogens in drinking water because of Limerick's operation, it would seem that DRBC would have to share the cost of damage suits if DRBC has not evalu-ated the environmental impacts on the river from granting changes to the PECo docket which result in degrading the Schuylkill River. We again ask DRBC to respect the U.S. Court process and to defer any action toward an extention of Revisions 5 and 6 to PECo.

l OTHER NEGATIVE IMPACTS.. The substitution of D.O. limit for temperature, sub-l stitution of Schuylkill water for Delaware River water during low flow, the de-priving of the reach below Limerick of the Cromby flow,disrerard of blowdown temperature and water quality criteria violations in the reach,due to deprived Schuylkill flow and diminished source quality,all pose negative impacts that have not been properly evaluated by PECo,DRBC and NRC. In addition the D.0.

records show precarious conditions in bass spawning areas below Limerick which l can only be made worse by removing the temperature limit of 59 0F. we set forth j

here the environmental threats we believe DRBC must facefand refuse Rev. 5 & 6.

I ru 1. Appendix B of the NRC operating license for Limerick, ff.NPF-39 which is o$$ the Environmental Protection Plan for operation, cites hazards which we assert gga. will be exascerbated by Rev. 5 &6 changes,i.e. " 2.1 Aquatic Issues. (1) oo During operation,the station blowdown temperature will exceed the maximum per-

$$ missible temperatures set by the applicable water quality standards....(2) The o:c water quality of the station discharge,after initial mixing with the Schuylkill 4u River, is predicted to,at times, exceed the applicable quality criteria for some 00 constituents, based on source water maximum constituent concentrations. "

Q< 2. The NRC Environmental Report on Limerick (EROL) points out the improve-l n ment in the mixed water source quality with the addition of the proposed " Del-i SE aware diversion" in the low Schuylkill flow periods (p.5 3-3) in these words:

1 EM 0 "Thus, LGS (Limerick) cooling water is of better quality during the third and fourth quarters,when the Delaware diversion is in operation,than during the first and second quarters, when the Schuylkill is the sole cooling water source."

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, 3. We proved in our letter of 4/16/86 to DREC that hi kill does not equate with safe levels of D.O. since on 8/gh flow in the lO/85,two daysSchuyl-after the NRC license for Limerick was issued the flow at Pottstown was about 1,000 ofs while D.O. was only 3.6 ag/1,well below the 4 2 mg/l minimum inst. value.

This makes clear the need for the temperature constraint of 59 to control safe conditions for biota,in addition to flow and D.O. limits.

4. This was even more apparent in the 1986 record of the Schuylkill River.

Na have recorded days that should have required a temperature cut off of river withdrawals . Tnis was removed in 1986 and PECo proposes to out it out in 1987, thereby creating a serious threat to river biota and spring fish spawning.

We have used D.O. readings from the daily logs for the Plymouth,Norristown, and Black Rock monitors. Tinse are the locations cited by Pa. Fish Commiss.(Rev.5 p.5) where the limit of 7 0 mg/l applies from 3/1 to 6/15 to protect spawning,and as well the additional monitors at the head end of these pools where PFC requires average 7 0 mg/l D.C. and minimum 6.0 mg/l .

Egrpph n inst. low Ave.D.0 low Mont Clarg Inst. Ave. Pottstown 1986 BlacR RoEfcybekdh*6.5'**#below70"*** 9HM HrleD0 "'

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5/21 # readings 12 39 18 54 0 0 73 4 1075 5/30 8 4.1 18 51 53 0 78.8 910 5/31 10 41 14 4.8 0 0 80.6 864 2

6/12 11 2.1 9 4.2 5 4,6.0 . 77 6 758 6.0 6/13 14 1.4 18 2.0 6.

.6 73 1 N/A i

. . . . . . . . . . . . . . . . 6. . .

All 6 monitors 7/11 Readings 4C 2.0-2 7 6C 3 2-4 5 80.6 489 7/12 5 e 1 5-3 7 10 6 2.6-5 1 77 9 441 7/13 10 e 2.2-4 2 18 G 2 7-5 1 76.1 447 7/14 6 C 3 2-4 2 12 @ 3 4-4 9 79 7 523

5. To establish the full significance of the readings in the days 5/21 to 7/14,above, one must know that the NRC issued the operating license to'PECo on the basis of these annual sources: Schuylkill-50%,Ferkio=en- 4%,and Delaware River- 464 (FES para. 4.2 3 2). FES states ," virtually all the water supplied to Limerick to replace consumptive losses..during the period June through Oct-ober of an' average year will come from the Delaware River /Perkiomen Creek system.."

In 1986 1004 of the water for Limerick came from the Schuylkill,instead of five low flow months water from Perkiomen/ Delaware. In 1987 PECo requests the same program. We assert that these 1004 increases in Schuylkill withdrawals have brought short term and long term damage to the Schuylkill and will continue to do so. We believe that DRBC is obligated to prevent any further damage by main-taining the criteria and limits originally established through reasoned judg-ment, 59 F. limit and 530 cfs flow limit. To these limits must now also be added the D.O. restrictions of 4.2 mg/l and 5 1 me/1. No withdrawals beyond these limits should be permitted by DRBC.

6. We realize that PEco shut down the Limerick reactor from 5/3 to 6/18/86 for no reason connected with water,but the sampling of days in the spawning season (above),5/21 to6/13 shows the dangerously low D.O. levels,1.e. 55 readings in 5 days below the minimum inst.6 mg/1 to a low of 1.4, and 77 readings below the minimum average of 7 0 mg/1,to a low of 2.0. In the same period there were 4 inst. values below the minimum and 7 average values below minimum at the 3 monitors at the head of the spawning pools.These. precarious conditions for spawning currently existing show that Schuylkill withdrawals could tip the bal-ance against successful spawning. The addition of Tamaqua water will not change this situation because this water will be consumed at Limerick. In addition the allocation of Cromby water will rob flow in the spawning area.

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7 PEco'o ocucumptiva catcr uno roports choo that tha reactor did not d -

mand cooling water on two of the days in the table (above) 7/11 to 7/14/86 but the D.O. readings below the limits for" instantaneous" and"24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> average"in-dioate the pervasive and dangerous conditions that threaten the biologic life of the river &aring low flow periods, 71 readings below the D.O. minima in 4 days. It should also be noted that minkmm river flows ranged from 441 cfs to 523, while the cut off point is 530 efs. The temperature constraint of 59 should have preventedsey withdrawals during these days because temperatures ranged from 76.1 to 80.6 , and the flow limit would have been a restriction,too.

Again this reinforces the need to keep the 59 temperature limit. For these 4 days the D.O. readings are shockingly low, down to levels which virtually in-

,dicate the disappearance of oxygen in the water, as minimal as 1 5 and 2.0 mg/1.

This kind of oxygen deprivation highlights conditions of stagnation and inability to assimilate wastes. It also hints at the dangerous setting which stimulates the reaction of Limerick chlorine releases with organic products in the river to produce triholomethanes . It is obvious that no Schuylkill withdrawals of water at Limerick should be permitted in these conditions,norshould any chlorine discharges occur. The wording of Rev. 5 ,p.4 speaks appropriately to such precarious D.O. levels in the river, " The constraint on consumptive use of Schuylkill water is to protect water quantity and quality below the Limerick Station...Regardless of the cause of low D.O. at anjc one of the monitoring sites, depletion of streamflow by consumptive use at Limerick could ae revate the D.O.

problem." Ignoring this caution PECo withdrew 14 34 MGD on 6/27 86 with D.0 level 4 9 to 5 1 and minimum natural flow 526 7 similar July violat on days followed.s

8. It is obvious from the statistics above that DRBC-KRC bade planning which l *"9 ruled out the use of Schuylkill water from June through October of the average year (FES para.4.2 3 2) was based on accurate professional appraisal of the capacity of the river and the stress under which the biologic life suffered even in the best of conditism, hum high heat and low flow during the summer months.

The addition of Tamaqua water does nothing to alleviate the stress, and blowdown temperatures add e further grave strain with possible added temperatures of 5 F to river readings which were recorded in 1986 up to 85 1 9 PECo's Consumptive Water Use reports also provide evidence of further stress on the river. We have mentioned the robbing of the reach from Limerick to Cromby of the latter's water. '2he surges of Tamaqua releases and sudden cut-offs createistrains both above and below Limerick. Furthermore the tieing of water transfers to D.O. monitor readings is fundamentally unworkable because of PECn' drive to operate the reactor for maximum use regardlesssof the damage to the environment, tis in combination with DRBC's apparent difficulty in supervising PECo's use of cooling water. There is direct evidence of this in the record for 6 days when the reactor was operating in the summer of 1996 : 6/27 ,7/3, 7/4 , 25, 30, and 31. On each of these days PECo recorded" Water wit'drawal was not restricted by flow or dissolved oxyren constraints'7n en River Monitor-Log,however, each one of these days has readings at or below tne allowable minimum D.O. levels. Some of thesc days have 6 and 8 readings below minima. The use of consumptive water for these days ranges from 12.1 to 17 7 MGD while water avail-able ranges 2 76 to 5 20 MGD. The defecits came to a total of 66 79 MGD or an average 11.13 MGD for these 6 days. In these days temperatures reached 82.2 0 and flows were down to 526 7 cfs. These withdrawals constituted a dancerous threat to the life of the river and the safety of drinking water downstream in a low flow period of maximum stress. The original 590 restraint would have hand-led this. The safety of the Schuylkill and that of the communities below Limerick require that DRBC continue this restraint.

10. It is significant that the Borough of Phoenixville has become aware of the repercussions from Lherick's Schuylkill withdrawals,on its water supply. A letter from the Borough Manager of 11/20/86 (DRHC Minutes 11/25/86) opposed PECo's application, citing temperature and pH fluctuations due to Limerick's op-eration.

We believe the Commission will give weight to the points se have raised and will exercise its responsibility to the community refusing Revisions 5 & 6 cc 3rd Cir.Ct.,NRC,U.S.Just. Dept.PEco. ~ yy 2, AiKg