ML20214N743

Submits Info to Be Included in Record as Testimony to Deny Util Application to Reduce Flow Requirement to 415 Cfs for Withdrawal of Schuylkill River Water for Cooling

ML20214N743
Person / Time
Site:	Limerick
Issue date:	11/28/1986
From:	Anthony R ANTHONY, R.L.
To:	Harold Denton DELAWARE RIVER BASIN COMMISSION, Office of Nuclear Reactor Regulation
References
NUDOCS 8612030734
Download: ML20214N743 (2)

Text

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Dalcuaro River Bacio Commiccion Box 186 Moylen.Pa.19065 B:x 7360 -

Wast Trcotoa,NJ. 08628 Novenbar 28,1986 Ladies and Gentlemen , W '

We received a public notice of the DRBC hearing scheduled for 11/25/86 in Philadelphia to take testimony on PECo's request to reduce the flow require-meat from 530 cfs to 415 ofs for withdrawal of Schuylkill River water for the Limerick nuclear plant cooling. As an intervenor for myself and Friends of the Earth in the Limerick proceed.' gs and as an aggrieved citizen I respectfully urge the Commission to refuse shis change. I had hoped to state our opposition in person but at the last moment was not able to attend the hearing. Will you please enter the following points in the record as our testimony and act to deny PEco's application.

1. e direct DRBC's attention to our testimony on 4/15/86 against PECo's application to use Titus ,Cromby, Tamaqua,and Beechwood Pit water which we 4 pointed out would subject the Schuylkill to extreme stress during the summer l low flow period. We demonstrated this with the DO levels and low flow readings for 1985 taken fro = DRBC and PECO records.

" Conclusions and Recommendations"which we submitted These were included to DRBC in follow-up/16/86.

in writing on 4 It appears that DRBC did not heed our evidence but proceeded to issue PECo's requested amendment. We feel that DRBC did not act in good faith because it never acknowledged our research nor did it respect our petition to honor its obligation to another U.S. agency,the NRC, te withhold its decisbs on this appli-cation until the NRC had acted on our petition to suspend the Operating License for Limerick. Our petition was based on PECo's violation of the requirements of the operating license which require a license amendment for any change in the environmen.tal impacts,specifically such a change as increasing Schuylkill withdrawals and removing temperature restraints.

DRBC granted the aqiendment on 4/29/86; NRC did not act on our petition to suspend the license becau s e of Schuylkill water violations until 10/16/86.

We enclose a copy of the cover letter from H.R.Denton to R.L. Anthony of that date. We intend to appeal this decision and again respectfully remind DRBC of the need for it to respect the NRC process and the rights of an aggrieved citizen by declining to act on PECO's current application until our appeal of the NRC action has been heard and decided.

We ask DRBC again to review the evidence we presented in our letter of 4/16/06 and to consider again the further evidence in our response to the NRC to our petition of 3/5/86 to suspend the operating license. We sent a copy of of this response dated 6/19/86 to DRBC on that date. Our evidence showsthe <

threat to the Schuylkill River from PECo's increased withdraws 3s. Ae you are well aware these increases were never considered originally by DRBC. *It received assent from PECo that it would operate Limerick under the constraints of the River Follower principle. As we showed,the addi tion of Tamaqua water and trane-m for of Titus and Cromby allotments did motremove the severe downstream effects g of Limerick's full power operation, unit 1., during the low flow summer mgnthg,1985 moa Our evidence showed that temperatures at the Vincent dam persisted at 70 -84

$ during July and August 1985 We showed that with Limerick withdrawals down-g streamfromVgacentthewaterremainingin the Schuylkill low flow could rise well above 84 , to a point which could " cook" the river's organisms.

N y We roquest the DRBC to provide us with the record of Schuylkill tempera-e< tures and flow and DO content for the summer months of 1986. We are certain 1 O that the life of the river was damaged while PECo operated Limerick at full power l

@ from 6_/2186 to 10/31/86 with only 8 days of shudown 7/5- 7/12. We insist that I (D o. I this damage not be further augmented by reducing the flow minimum of 530 cfs. r Esc. e / $PDento'n7oAnthony. -, fgentlyyours, PLo t s . Li ki % )

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