ML20214R659
| ML20214R659 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/22/1986 |
| From: | Sugarman R DEL-AWARE UNLIMITED, INC., SUGARMAN & ASSOCIATES |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#386-872 OL, NUDOCS 8609290241 | |
| Download: ML20214R659 (27) | |
Text
_ _. _
7 13 1
DXKULO UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOAR _Q OFFICE e P i : M 00CKEitNb T Si"VICL In the Matter of Docket No. 50-352 $$
Philadelphia Electric Company :
50-353 OL (Limerick Generating Station, :
Units I and II)
MOTION TO REOPEN PROCEEDINGS FOR FURTHER CONSIDERATION OF ENVIRONMENTAL IMPACTS OF PROPOSED BUT NOT YET INCURRED CONSTRUCTION Intervenor Del-AWARE Unlimited hereby moves that the Board reopen its determination and Order of March 8, 1983 herein, and avers as the basis thereof the following:
1.
The special proceedings relating to cooling water issues were hoard in September and October 1982, and resolved by this Board on March 8, 1983, which decision was affirmed by the Appeal Board, and the Commission declined review.
2.
One of the originally admitted contentions was that the Bradshaw Reservoir (the holding reservoir proposed to be constructed by PEco as part of the diversion from the Delaware River to supply water to Limerick) would be unsafe to f
operate, and threatened to allow seepage and potential collapaa.
This contention was admitted as contention V-16b.
3.
During the hearings, the intervenor stipulated to withdraw this contention on the grounds that PECo had supplied analysis and data showing that the reservoir would have sufficient stabilization, based on its proposed rate of filling 1
8609290241 860922
}
gDR ADOCK OSO 2
o and draw down (changes in water volume inside the reservoir).
For the reasons stated below, the Stipulation is now inoperative, and the proceedings must be reopened.
4.
Changes in water volume have a significant effect on stability of the earthen structure, in that rapid and frequent changes in decree of moisture on the slopes cause significant destabilization of the banks, thus permitting seepage and potential collapse.
5.
In these proceedings, PECO proposed a reservoir of 70 million gallons, substantially in excess of its maximum 46 million gallon daily need, virtually equal to the anticipated maximum need of itself and its co-users of the i
reservoir, the Neshaminy Water Resources Authority.
i 6.
Neither the reservoir nor the entire water diversion system have been built'or are operational.
7.
On or about July 9, 1986, PECO proposed a drastic reduction in the size of the reservoir, and a drastic alteration in its configuration.
A copy of the new PECO
- proposal, in the form of an application to Pennsylvania Department of Environmental Resources for a dam permit, is attached hereto an Exhibit A.
l 8.
In addition to entailing significant l
I destabilization of the reservoir itself, the reduced sizo of i
the rosorvoir substantially impedon the applicant's ability to regulato flows into the east branch of the Perkiomon Creek 1
(to which the reservoir would dischargo), thereby incurring 2
.'n significant and adverse erosive effect due to rapid changes in discharge rates into the water body.
9.
Since this Board's determination of March 8,
1983, both the Pennsylvania Environmental Hearing Board and the Administrative Law Judge of the Pennsylvania PUC have found, after full hearing, that the original proposed volume of discharge into the east branch of Perkiomen Creek would cause significant erosion and pollution to that Creek.
10.
Included in the findings was that the diversion would cause substantial pollution of the Perkicmen via transfer of lead, zinc and heavy metals.
11.
These findings corroborated earlier suppressed concerns of the AEC staff, since documented to the Commission.
Copies of DRBC memos noting that AEC Oak Ridge scientists writing the draft EIS concluding the Perkiomen would be
" destroyed" and did not recede despite " pressure applied" at an emergency meeting.
(Exhibit B).
12.
The new proposal significantly enhances and increases those risks.
PECO's new proposal is twenty percent smaller than its proposal at the CP stage, and, in any event, the CP proceedings did not dispose of operating impact questions.
See Special Prehearina Conference Ordel, June 1,
1982, pages 87 to 89.
13.
In addition to the foregoing, the facts have changed concerning the availability of alternative sources of
)
water, such that it is now apparent that the project would be 1
capable of operating without any of the diversion water.
3
14.
Specifically, as reported to this Commission (see Exhibit C), the Delaware Basin Commission has adopted revision to its previous orders, permitting PECO to utilize water resources in the Schuylkill River (on which Limerick is located) sufficient to provide supplemental cooling water for the Limerick.
- 15. There is no longer any basis to fear that the DRBC would not likewise make water available to PECO in the future in the event that the diversion is not constructed.
- 16. The foregoing factors constitute new and significant matters which should be considered by the NRC under its obligations to consider environmental consequences before f
granting operating license for Unit 2 or authorizing an operating license for Unit 2; and in further consideration of t
the operating license for Unit 1.
- 17. Inasmuch as the revision to thn Dradshaw Reservoir has just been proposed within the last ninety days, and was not brought to the attention of the intervenor until more recently, this application is timely.
- 18. As demonstrated in the past, no other participant or party can be expected to litigate this matter before this Board.
19.
The matters raised herein would have a significant and substantial effect on the conclusions of the commission, and are necessary to be considered by the 2
j commission in light of its responsibility under the National i
4
Environmental Policy Act and the Atomic Safety and Licensing Act.
WHEREFORE, intervenor Del-AWARE Unlimited requests that this Commission order that the hearings herein be reopened and the contention V-16b reinstated, and to admit a new contention relating to the erosive effect on the Perkiomen,.and the availability of alternatives to the water diversiori, as stated herein.
Respectfully submitted, J
s ROBERT J.
SUGARMAN Counsel for Intervenor Del-AWARE Unlimited, Inc.
Of Counsel:
R. J. Sugarman Associates 16th Floor, City Place 101 North Broad Street Philadelphia, PA 19107 (215) 751-9733 Dated:
3 1
1715Wd3/mrw j
1 i
5
5, t
EH - W'M - 12: Rev 6.84 COMMONWEAt.TH OF PENNSYLVANIA t.
DEPARTMENT OF ENVIRONMENTAL RESOURCES APPLICATION FOR DAM OR WATER OBSTRUCTION PERMIT
.. 7......E...19..e In compliance with the provisions of the Act of November 26,1978, P.L.1375, as amended (32 P.S.
5693.1 et seq.) known as the " Dam Safety and Encroachments Act"; Act of October 4.1978, P.L. 851 (32 P.S. 5679.101 et seq..), known as the " Flood Plain Management Act"; and the Administrative Code, Act of April 9,1929. P.L.177, as amended, which empowers the Department of Environmental Resources l
to exercise certain powers and perform certain duties by law vested in and imposed upon the Water Supply Commission of Pennsylvania, and the Water and Power Resources Board.
Philadelphia E
...n o.......n n...n............
..........n...
...........................l. e c t. r i c...C o..m..p a..n..y Appf. cant hereby makes application for the consent or permit of the Department of Environmental Resources to om F) MY,XMh4a""ti m o d i f y, E KMF_.4X5 KEUtniddit.t.h..e...d..e.s..i. gn...o..f...B..r. a d..s.h..a. w....R. e..s..e. r..v..o. i..r..,p.r. e. v..i.o..u. s.l. y.. a. p,p.r. o..v. e.c n
in permit number DAM 09 181 dated September 2, 1982.
vv rn,yvvvvyyvxh.M....ys.IN..o.n.e.)......................................................................................................
uioffg, cf (Here state name of stream or other body of water.)
l a t a p o i n t.....i. n. P. l..u. m.. s..t. e..a..d...T..o.w..n..s.h..i. P.,...B..u..c.k..s...C..o.u..n..tJ..a..t... t..h. e...N. o..r..t.h..e. a.s..t...c..o. r..n. e.r (Here give location. by distar'ce from mouth of stream, County, township. or municipal boundary. afso give city. town or townshi and county in which located I
- a..n..d. B..r.a..d..s.h..a.w....R.o..a. d....i.m..m..e.d..i. a..t..e. l. y..w..e. s.t...o..f... t..h..e...D. a. q&.b.o..r.
I femt em:pm ntx...........(. S,u,, 3,t,t a,c,h m,9 n t,, M,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
tHere state fully the purpose, necessity, and description of the proposed obstruction.)
....................e..........e...
.......e.................e............e.......................................................................
..............................................................................................................................................)
.............................................................................................................................,........FI y
.......C3.........9.....f....,.......
y['
o
- e. t. o s
n Rec'd Ck [ ~
'. c '. 5 '.S f (d
/.,
f, r,
5 Ant S
I ;' i l t
' ' 7~~ ~
(Continued on other side) l' t..)
/
p o
f g,
in accordance with the complete maps, plans, profiles, and specifications filed with this application and made a part hereof.
B y.........V
- S
- II..........Y.."..'...
m f A'.lD-2 1. h M.I. 73.5.9.9...............................................
....?.r. v 3,c y,,,P re s id n t.. ? 1? l ar.? ??e i
Telephone No. of Apphcant (signature and Title) 2301 Market Street j
j Philadelphia, PA 19101 CHECK ONE:
0 Privately Owned O Partnership 1
G Corporation O Government Agency l
If privately owned, the individual owner must sign. One l
or more members authorized to sign on behalf of an en-
]
tire partnership must sign. For a corporation, signatures of the president, vice president or other responsible of-SEAL:
ficial must sign and affix the corporate seal. For political subdivisions, we require signatures of the chief officer or officers, or other rcsponsible officials empowered to sign for the political subdivision with the seal affixed and WITNESS:
attested by the clerk.
?
..............Y.......h........<..........$..Lu........................
l If a fictitious name entity, are you registered with the Pennsylvania Department of State? O Yes O No i
Effective September 27,1980, all applications for pe'rmits, except those submitted by federal, state, county or municipal agencies, must be accompanied by a check payable to " Commonwealth of Pennsylvania" in accordance with the following schedule:
Dams Water Obstructions and Encroachments
- Class A
$200 Bridges Over 15 foot Span
$100 Class B
$200 Enclosures
$100 Class C
$ 50 ChannelChanges
$100 Commercial Dredging
$100 All Others 6 50 A single application may be submitted or a single permit may be issued for multiple structures and activities which are part of a single project or facility or part of related projects and facilities, located in a single coun-ty, constructed, operated, or maintained by the same person or persons. Where a single application covers multiple structures or activities other than a single structure and related maintenance dredging, the applica-tion fee shall be the sum of fees set forth above for the applicable structures and activities but shall not exceed $600. All stream crossings located within a single county for the installation of a public service line l
shall be treated as a single structure or activity.
I Duplicate applications with duplicate set of plans shall be submitted to Department of Environmental Resources, 1
j Bureau of Dams and Waterway Management, P. O. Box 2357, Harrisburg, PA 17120.
This application, together with all maps, plans, profiles and specifications, and all papers, information and 1
data filed in connection therewith, will remain on file in the Department.
l
- Based on size classification as defined in i 105.91 of Chapter 105, Rules and Regulations.
1 ATTACHMENT A DESCRIPTION OF PROPOSED MODIFICATION TO PERMIT NUMBER DAM 09-181 The volurne of the tradified Bradshaw Reservoir will be reduced by realigning the north corner of the originally pennitted reservoir to preserve the area classified by the U.S. Army Corps of Engineers as "wetlanos".
The modified reservoir will conform to the original
. design, except in the north corner, as shcwn on the attached site plan.
This nodification will result in a reservoir with a water surface area of approxlrnately 7 acres and e capacity of approximately 25 million gallons. The construction of the reservoir will be the same as that I
shown in the original permit ntrrber DAM 09-181, i.e.
the dikes will be formed frmi material excavated to create the bottom of the reservoir.
The top elevation of the reservoir embankment will be the same as originally designed and the height will still vary frcm 5 feet to 20 feet due to the contours of the existing ground. The embanlonent slopes will remain unchanged and will be gentle with a rise of 1 foot in a horizontal run of 2.75 feet for the outside slopes and 1 foot in a horizontal run of 3 feet for the waterside slopes. The ptmping station will be unchanged and will rem in in its original location.
Both the spillway and inlet structure will require relocation due to the realignment of the dike. However, they will remain unchanged in design and will operate in the same manner as originally designed.
The modified reservoir will not significantly change the envirorrnental effects evaluated with the original reservoir. All construction Ir: pacts, noise concerns, end aesthetics will be unchanged.
There will be a reduction in land use which is considered to be a slight benefit.
The. proposed modification to Bradshaw Reservoir will not include any changes which will alter the DER's Division of Dam Safety's previous review of the safety and engineering aspects of the project.
The results of said review were presented in the Envirorynental Assessment Report dated August 1982 prepared by the DER.
It was stated in the report that the reservoir compiles with all design, operating, and safety standards established under the Pennsylvania Dam Safety and Encroactynents Act.
I i
i JUL 0 31986 t09-18@
p 93
.,f.- -
R
.a
~
.=
?,
c
=
~ 2 r.
=
\\
L,
. /
\\
0, e,
s 4
s y,~'e-n
/
^
a
~
T,-
I
,z %
's.
0 f
=,
/,,
7;'u L,
v u
n
~f
=
E j;
N p
Y' -
,p'4\\,..
., )
..., s s
s N
.l e
s A
o
\\'~E L o T
/
r' r
~
w_E L
{ )\\
..F l. ^'
\\
e N
\\
A T
s n.
I
. /, '* a-I
/
.,' ; s i
x S
D-u
, s.
o.
i y
E A
1 g
h.
,T
,x d
Jn,m.
I s
\\
A 3.
(,,
a C
s y
O
'c,:f.
yr L*g.
.c
'e L-
.i E
f ',f R
., f.,
0
/,,
[
%.!. e /,i. * !, T y // '6
^
- 8
'f t,
p 9
7,. _
1 l
M
.G'.$
r
., All,~ x%
l l' fb.
3 A
r I
t[i
,)
,s
.e i
,f
.,0
- j.
,W
@~
L j
M Dr h
r p'
U
/
~
NokI A, -]/,,.
\\
J
<N. '
s p*
3
_< 6//
f
- . n<j -
f
,J C
.,f -
y.
'/
,r ):
9., 7 -
[
- ',',. f -r-
.. h',, E u 8,
.M
/
f 2 Css t "-
.. './
l, e,
=i.
., = '
t.
./
S?
L
==,
x l
m==
L9 1
,,>F
,'e fh,
'g *:, J,.,,.w;g, I
=
r l
=
,O
/.
,/,,
S
- p. ~E '
/
- $.W*Cs.
9
,[ '
,, J 2
L"
- =
f*
}(.
f s h, y
JI z.
7]'
j l
i 4
- 2, ON h,
.q
}
1 g
o.
t}l 'cq
~
' 0 l__
T 1,
,K
.E
. E
., A K
)
j jm i
C
. n
., I. D" Gl Tf b
c
_mh
.w
_c&
I
[
I N
- ?
D L
_ 6 EIG
.s i
- Ef _ _ -
. _ D 'O T
=
._ E
_Lf__.
5t I
S
._ N E
_A C/
1 O
D\\
j,)/.
c_n
.I o,
4 L Y
w n
~
.N
- R n
E
)
l
=
s I. S ? -A.-
L G
f A
'c
~
pru=i in
.I 5
g.l,
.\\
N Ef~w mz
.'s R-
]
{
I
/
l D
/
Gg
~
u yTejm I
lf
~
L e
Al=,q..r!
O
. ~
'. f N
I
,,')
G
)'
"a
=
/
=
I ls'.
~-
O'
,f
,. J/
g R
I) x.
1 a
yN.
s e
l
?
[) '
W y\\,
b
\\
\\
.t a
, f.,vi
]
g I
. c-if'.=,
ys(
iyj
., =:
=
'I..!
~
ib'
~
f M 'y,
\\,i
, f. J f,.
F1 }
E y dhyEWf.:
yPJ lnllj l
lI l qzJ0 } U {-
l
{na / lt l
,e
[
,]
-l L 2. L... /
MEMORANDUM Mr. Herbeit A. Howlett October 25,1972 TO D A T E
.r. Rob L. Gel FROM SUBJECT Dob unna, in a cenver:ction with a Mr. O:: r Sisman, Ock Ridga National Lcbcra:orie:, whoJ2 ptcporing the draft Eis on the Limerick Project for AEC, lecmad yc:tcrdcy thet one of the conclusions in the draft EIS was that the Perkiomen Cree! would be " destroyed" If it wcre used in connection with the Delaware PJver divers!on to the Limerick Proicct.
Since this is a direct contradletion to the cc,n lusiens that we cro new preparing in the finci EIS for the Point Plecsant.Freja:1, wo colled ST:m:n today to see if their draft statement, which is scheduled to be relected publicly in about a week, could be held up until a meeting could be errenged to discus this inuo. Wo further icorned that Oak Ridge did not hcyo evallable fer their con:Idarction tha additional studies done by Lehigh Univer Ity, DREC staff, Bourqucrd and others, that cro ovalichte to us.
Sismen agreed that this was a problem wo should try to rc cive immedictcly and a meriing is EcIng crranced to do this. Mann shculd be sottina up a meetina in further conversctica with SI: mon on Thurschy, Octo!:er 26. Hopsiully it con be crrenged for c:rly next weck.
I clso collod Jim Votrcno et AEC to explain this prob!cm to him cod he was culto sympathetic in egrecing to c!ictrgt to rcrolve this probicm immedictoiy.
He will be inv!ted to cttend the meeting as well.
Robart L. Goodell RLG:mb e
l wW" l /
-. -. _ - - - - +
.c.
-r.
r MEETING TO DISCUSS POINT PLEASANT DIVERSION AEC - Bethesda 10/30/72 - 1 p.m.
4 Name Representing l
James B. Vetrano Environmental Projects -AEC U c.'
- b ?
4'M !
i j
Carl J. Baren Delaware River Basin Commission i
Robert L. Goodell Delaware River Basin Commission i
George W. Knighton AEC - L lbC N t C.tuni 6.0. 0 c. ;- )
/
Lawrence Chandler AEC - OGC Bob Mann Delaward River Basin Commission R. Q. Purple AEC - L ( Mtv.s. 3 2 ;
.u. 4, Og, s. % g )
< c..
4 J. R. Traba14ea ORNL(3sm.c.,s7j
- ' '"' f ' "
- 0. Sisman ORNL (L *-a cic+ It.w L a., g t,Q 4
D. Muller AEC - L (%%7-D.cact.a, buo. Q,v;)
George Lear AEC(Lw*ouc h - sNa. h %,e s e,
Bill Dircks CEQ I
1 1
J e
i I
i r
I
3
..4
- t
.'.s'
- J'o '*
- e
. ~*..
r
. i nae E
A sM 5 's I L-
.n
.s.g
- s. !
- b A -.
of j
- e
..,.f k
...a.-
- -Q
- n 4. 't.,,
- t 1,
.,, J.. [e.'
I
- i
..[.~.,-'.
- e
. 3.' m
. g t.*
~,
....s.=='.
. t s ' _ y.
s
..g
,~ ~ ~ *,,*
.*$+
. **~,
e.
.e.-,,.*-.'
.i t.
.g-p Q'
.....,....w.,
? 2.
.T* u.m '
-. N.'."
. C
- j. 6.- ~
n.u
~
l
s
' se OO.
r jQ..
O
,a...
. u, P...
,. 2".
j' 4
4
'.. y g p
i
5 '. o'
.e.
~
a.
/
3
(
A, 9
i,,.- -
l q _._. _ -
- ',]..
..,s s, *.:: :
a.
s
. M'.g " T
?..
r c,.,L.'.. 5.* [. 4 -
J[,
e 4
- ' ffig'
'-.e tl gm,'d. f** 'd.'s k.118' #
,y*
3
- h'".
in $ 1kn,d:( g.. (s.f4.
A y 5. n..e
,.u 3 a-4
.ac,
,... q.s.-
.,.# u.e
..2.m.
..u.. (e g'..p %n. ~
s..m cptp q.W.V. %,%.,
w.
- .%..u.-w
.,;=.
s.
y,,
. re
.. e g.
- n...
s.
- n. ?...?. f.+y\\.,w; <M..L.
V,.
, :,,E,. 3
~gr u
t
$$?$'2$fi.YN._ qc g3.p.g.,.
n,>; s.:y; q. n.
r
's.,.v,.1. 6 -
.... pyy.
- Y.bNN"N$
.J ' '
-U
~
'.*c %..S m ;h..;n m %. %.9pG t %. 7.:.
.-n g
i.-
L.:.- -.
- t. _
.,,.....~y..
vs-e x.
.. [ '.[.
1 i,,,,.,* * -,.
,g aw e.
.. ~. _..e s.
7..
s..:
- eL y
o se, d'"p l 4*
a't.e,.
pfg.
s gg,
.s...
- ~.=w.
v..
j.
1
.,.o sf.g
_,-,y'
.gl e
-... n
- s...
6*.
t
~
Q^.?w
- s. 9..,. ~
.t.
e
, j-I
.I
' n, '
.. w i.* ? ' I' *.',._
~
e p.
- g,.g-J -
9
'gg
.,._see.
.
- I$'.he _.%.
G.
&._ -e
~. *.
s.-.
,. -.. % C., -
)
.*. ',. w a N.g.
'..),,.
m m _e5 g.,
y
.. 4 J
e e
9 e
...~_
MEMORANDUM To Mr._ James. E...Wr.ight DATE O.c.to_ bed.1, ).?.R FRCM
)dr Fobert._L._Nono suaJECT
.limer.ick. Generating.. Station Pt. Plecsont Diversion i
Representetives of the Atomic Energy Commission, the Ook Ridge Laboratories, cnd DRSC met in the AEC offices at Bethesda, thryland, Nonday, October 20,1972, to discun I
the environmentcl impact stetements of the subject proiccts. Specifically the meeting wes coiled to review the cpparent differences of opinion recording the.cnvironmentol impact of the Delowere River water on Perklemen Creek.
i The Limerick EI3, presently in draft form, prepared by Cok Ridge for the AEC indicates the mcst significent cdverse envircnmental inipoet to be serious ccologiccl impoirment of the Perkiomen Creek resulting from heavy chlorinction of the Delowere River water and
~'
major ercsion'and sedimentation in the cost branch due to 2500 feet of stroom chennelizc-tion and the increcsed stream velocity. The Pt. Plecsont final siatement offers citernativos I
to chlorination but does not indicate any stream channelization or soll ercsion. As a re.sult, the statement claims on envircnmental enhancement of the Perkioenen Creek.
Discussien made the AEC cwcre of means of treating the Delowore water other then.chlorino-l tion. This will be reflected in their statement. However, the matter of streom channeliza-tion was news to CRBC. It wcs clso,disccvoreEl that AEC hed much more dctoiled and recent l
informetion on the Perkiomen Creek made cvoilabl.e by the opplicent (fhilodelphia Electric) but not received by DRBC. As (i result no resolution of our differences could be made'.
Pressure epplied to tha Ook Ridge eceiogist did not alter his. posit, ion en the Creek. He felt there would be o major Icss of spawning orcos for both permanent and migratory equatic-
' life due to the increcsod velocity even though the chlorine", issue wcs resolved. He fevgred the use of a pipe for the diversion. Their EIS suggests o pipelina os the preferred citornative.
It was determined that the Limerick E!S would be altered to reflect alteractives to chlorino treatment end thct.h drcit would not be mede public until the Perkioman Creek issue was resolved. Mr. Goodell informed the AEC that Cli3C stoff would not be adverse to the use of a pipeline in. lieu of the Creck.: A discussion en whether the Limerick EIS need include study cf the Perkiomen resolved that the method of delivering water to the plant wos e direct port of the project end therefore must be included, Three options to the prebicm were po:ad end DRBC staff indicated that thcy would wriio to AEC cfter the November S mactinD of the Commissioners stating DRSC's recommended opprocch.
~
O
-,m
--~+~
Y a
2 J
The options cre:
DRBC would ogeln study the Fbrkiomen Creek using the information supplied by a.
the Fhilcdelphic Electric Company to AEC and then discuss the situation with Cck Ridge to resolve differences. This would be done bcfore the draft Limerick statement was publir,hed for revicw. Pt. Plecscnt statement would also reflect chen0es.
b.. Dr.3C would elimincte from the Pt. Plecsent stetement oil ref rcnce to the Perkiomen diversion end Limerick citing the Limerich statement cs the source. CP.3C r. toff would complete a above and comment en the draft Limerick EIS regarding the Perkiomen problem, DRBC and AEC would propose to the cpplicant to utilize a pipeline. Both statements c.
wobid reflect this decision.
l The AEC staff were very concerned over the prospect of available water for plant operation especielly the uncertainty of an ovcilcble reservoir.
Robert L. //cnn RLM/kf
//r. H.A. Howlett, Mr. R.L. Goodell, Mr. W.B. Whitell, Mr. C. Beren cc:
9 g
g g
og 4
- a;
D AWARE RIVER BASIN COMMISSION c'
MEMORANDUM c
TO._
Mr,..Ja mes.f,. Wr igh t..
DATE O.c.tober 31,.1.972_
FRCM _ Mr. Robert...L. Mann SUBJECT Point Pleasant lmpact Staternent_
As a result of further study of the subject project and the meeting with AEC on the Perkiomen Creek problem, I recommend the following approach to completing the final statement:
- a. The final statement be rewritten omitting the Perkiomen Creek divenion. Reference can be made to the Limerick statement for commentary on water delivery to the generating
- station,
- b. The rewritten final statement should include up to date information from Bucks County on the use of water treatment, more in-depth data on the Neshaminy Creek, aesthetic treat-ment of the pumping station and any other matters raised by the reviewers.
- c. The alternatives discussed need to include that of no action and the water supply without Tocks Island or other reservoirs.
- d. The revised final statement will not need to be recirculated for comment because the project has not changed.
- e. The final statement would include discussion on the availability of water for Limerick insofar as pumping station facility is concerned. Reference would be made to water supply conditions for Limerick if established by DRBC.
I believe this approach would be the path of least resistance. Even though the draft commented on was developed prior to the recent EIS requirements, I am certain EPA would critically assess the final in its present form.
[/ 'fll t
I Robert L."Mann RL/4/kf ec: Mr. H.A. Howlett, Mr. J.W. Thursby
b D6i. AWARE RIVER BASIN COMMISStuN MEMORANDUM Individual copies
~
yo
. lames F. Wright ' and H. A.. Howlett oarg _. _.De.cembe_r. 13, 1972 FROM Ro.b.ert.L...Wnn SUBJECT.. Limerick and Pt.]jeasant_ ).
(
~
~t Although our meeting with AEC here in the Commission offices November 15 concluded with a concensus of opinion tha the East Branch Perkiomen would not be adversely affected by the diversion, the draft impact statement on Limerick In'~cludes much infor-motion to the contrary.
There are contradictory statements in the timerick draft which will probably co'nfuse
~
some reviewers and excite others. The summcni indicates enhancement of the Perkiomen.
Pages 5-4 through 5-6 include information raising many serious questions on water quality and velocity of flow, all of which were openly discussed at our meeting'. It seems that although corrections wer.e. inserted into the statement, all of the potentially controversial material was left in the draft.
There is more content to the concern for the Perkiomen than for any other ir$ pact excep,t radioactivity. The draft, for instance, avoids any discussion on the immense' fogging.
impact related to the cooling towers.
s
/
s Robert L. Mann
~
RLM/kf 9
DELAWARE RIVER BASIN COMMISSION RECFiVED P. O. BOX 7360 WEST TRENTON, N. J. 08628 SEP 121986 Project Review S. D. Snil NOTICE OF COMMISSION ACTION Date: 4/30/86 Docket No.
D-69-210 CP (Final)
Revision Nos. 5 and 6 Project Sponsor:
Philadelphia Electric Company 2301 Market Street
, Philadelphia. Pennsylvania 19101
'ttention: Vincent S. Bover. Senior Vice President Project
Description:
Temporary docket revisions, during 1986, which include substitution of DO for temperature constraints; substitution of Titus and Cromby consumptive use al' 1 cations to Limerick.and releases f rom Tamaqua reservoirs.
Referred by:
Action by Commission:
Included in the Commission's Comprehensive Plan for the Delaware River Basin and approved pursuant to Section 3.8 of the Delaware River Basin Compact. See attached docket for terms and conditions.
Explanatory Note:
This action has been taken by the Commission in accor-dance with its responsibilities under Sections 3.8, 11.1 and 11.2 of the Delaware River Basin Compact. The Commission maintains a comprehensive water resources plan for the Delaware l
River Basin and reviews water resources projects proposed by other public and private agencies. Review of. projects enables j
the Commissien to prevent conflicts among water users and to protect the integrity of the Comprehensive Plan.
hm M, AA2.sm 1,
I Susan M. Weisman, Secretary enc.
cc:
All interested parties; Commissioners 0 / 11 ff-
J DOCKET NO. D-69-210 CP (Final)(Revision No. 5)
DELAWARE RIVER BASIN COMMISSION i
I Philadelphia Electric Company Limerick Electric Generating Station Limerick Township, Montgomery County, Pennsylvania l
PROCEEDINGS The Philadelphia Electric Company (PECO) applied, on December 16, 1985, for a temporary modification of Docket No. D-69-210 CP (Final). The appli-cation was amended with a submission of supplemental information on January 22, 1986.
The application was reviewed for temporary revision of the project in the Comprehensive Plan and approval of these temporary changes under Section 3.8 of the Delaware River Basin Compact. A public hearing on this applica-tion by PE was held by the DRBC on January 22, 1986. The hearing record remained open until 5:00 p.m. February 14, 1986. Twenty comments were received an( et.tered into the hearing record on this application.
DESCRIPTION Purpose.--The purpose of this application is to obtain temporary relief, through December 31, 1986, from two existing docket limitations and thereby increase the frequency that water may be withdrawn from the Schuylkill River l
for evaporation at Limerick Unit 1.
The two existing limitations are:
(1) l PECO may not withdraw water from the Schuylkill River for gvaporative use at their Limerick Station when the temperature rises above 59 F and (2) water for evaporative use may not be withdrawn from the Schuylkill River when the flow at Pottstown gage (not augmented by releases from Commission sponsored reservoir storage) falls below 530 cfs for one Limerick unit in operation.
They requested temporary substitution of dissolved oxygen (DO) monitoring in place of temperature restriction in the original docket and they also requested the option of transferring the existing consumptive use of Schuyl-kill Basin waters from currently operating generating units on the Schuylkill i
River to the Limerick Unit 1 generating unit. This would allow the operation of the nuclear fueled unit in lieu of existing fossil fueled units when 9
~
l existing docket limitations would otherwise preclude consumptive use of the Schuylkill River water for the Limerick Generating Unit 1.
4 k
j 1
D-69-210 CP (Final)(Revison No. 5) (PECO/00/ Temperature) 2 Location.--Existing intake facilitics are located as follows:
River Mile Intake 92.47 - 71.15 Titus Limerick 92.47 - 48.22 92.47 - 39.1 Cromby Dissolved oxygen monitors have been installed approxinately 200 feet upstream of each of six dams and at the Limerick site.
The six dams are located as follows:
Fairmount Dam 92.47 - 8.49 Flat Rock Dam 92.47 - 15.6 Plymouth Dam 92.47 - 20.7 Norristown Dam 92.47 - 23.95 Black Rock Dam 92.47 - 36.6 Vincent Dam 92.47 - 44.7 Physt!.al features Design criteria.--The applicant proposes substitution of dissolved a.
oxygen limitations of a daily average of 5.1 mg/l and 4.2 mg/l instantaneous in lieu of the current temperature limitation (59 F) in order to reduce the number of days that PECO would be required to replace evaporative losses or cut back the operation of the Limerick Unit 1.
PECO has requested approval to withdraw water from the Schuylkill River for consumptive use at Limerick whenever flow conditions are met and DO values at five of the six designated stations exceed the 5.1 mg/l minimum daily average and the 4.2 mg/l minimum instantaneous values.
The applicant also proposes that when existing Schuylkill River flow constraints (Ref. DRBC Docket No. "D-69-210 CP (Final)"] or the above requested DO constraints restrict the consumptive use for Limerick Unit 1, operation of Units 1, 2 and 3 at the Titus Generating Station of the Metro-politan Edison Company and Unit 2 at the Cromby Generating Station of the Philadelphia Electric Company be curtailed as necessary to allow the equiva-lent consumptive use at the Liuerick Generating Station.
Docket No. D-74-32 (Revised), approved on October 8, 1980, acknowl-edged that the addition of a cooling tower at the Titus Station would result in a maximum consumptive use of 3.5 mgd.
The Cromby Generating Station was operating prior to the formation of the DRBC and the water use has not subsequently been substantially altered. Accordingly, there are no docket decisions establishing the con-sumptive use at that station. However, in 1976, the DRBC issued a Certifi-j cate of Entitlement to PECO establishing the quantities of water that could be used at the Cromby Station and not be subject to DRBC water use charges.
The entitlement established a quantity of 88.401 mg/ month (2.9 mgd) for the Cromby Station. Proportioning the total consumptive use between Unit I (150 mw) and Unit 2 (201 mw) indicates that up to 50.628 mg/ month (1.7 mgd) is the maximum consumptive use for Unit 2.
- -~_ __.
D-69-210 CP (Final)(Revison 5o. 5) (PECO/DO/ Temperature) 3 Transferring the 3.5 mgd from Titus Units I, 2 and 3 and 1.7 mgd from Cromby Unit 2 would provide up to 5.2 mgd for consumptive use at Limerick. This 5.2 mgd, if used for operation of Limerick Unit 1, would enable the Unit to generate power at levels up to approximately 25 percent of full power.
b.
Facilities _.--All existing facilities of the Limerick Electric t
remain as approved by Dockets Nos. D-69-210 CP (Final) and Generating Project D-69-210 CP (Final)(Revised). No new f acilities are required at the existing Titus or Cromby generating stations. The DO monitors were installed'as described in DRBC Docket No. D-69-210 CP (Final)(Revised), which was approved on May 29, 1985 and expired on December 31, 1985.
+
Cost.--There are no construction costs associated with the implementa-tion of this project.
Relationship to the Comprehensive Plan.--The applicant is requesting revision of the Limerick Generating Station Project as included in the Com-prehensive Plan by Docket No. D-69-210 CP (Final).
FINDINGS
)
The Limerick Generating Station was included in the Comprehensive Plan i
by Docket decision No. D-69-210 CP (Final) on November 5, 1975, which also i
incorporated the project description and docket decision D-69-210 CP dated March 29, 1973. Docket No. D-69-210 CP (5/29/73) includes a section headed
" FINDINGS" subheading " Source of Water Supply 1.
Schuylkill River" which reads as follows:
j "Schuylkill River water at the plant site may be~used for noncon-l sumptive use whenever the effluent discharged back to the river meets all applicable water quality standards.
"Schuylkill River water at the plant may be used for consumptive use when flow (not including future augmentations of flow from Commission-sponsored projects) as measured at the Pottstown gage i
is in excess of 530 cfs (342 mgd) with one unit in operation and 560 cfs (362 mad) with two units in operation with the following exceptions:
"(a) There shall be no withdrawals when river water' tempera-tures below the Limerick station are above 15 C except during April, May and June when the flow as measured at the Pottstown gage is in excess of 1791 cfs (1158 agd).
"(b) Use of the Schuylkill River will be limited to a with-I drawal that will result in an affluent that meets all f
applicable water quality standards.
i 4
i
D-69-210 CP (Final)(Revison No. 5)
(PECO/D0/ Temperature) 4 "The constraints on nonconsumptive use of Schuylkill River water are necessary to prevent violation of total dissolved solids, stream quality objectives and effluent quality requirements of the Commission's water quality regulations. The constraint on con-sumptive use of Schuylkill River water is to protect water quant-ity and water quality below the Limerick Station. Both sets cf constraints would be suspended in the event of any operational emergency requiring a shutdown of the plant."
As part of the docket decision No. D-69-210 CP (Final)(Revised) para-graph (a) above was revised for the period.ending December 31, 1985, to read as follows:
I
"(a) No withdrawals for consumptive use shall be made from the Schuylkill River or the natural flow of any of its tribu-taries whenever dissolved oxygen in the Schuylkill River at or below Limerick as measured at any one or more of the monitoring locations:
(i) is less than 7.0 mg/l instantane-ous during the period March 1 to June 15, or (ii) is equal to or less than 5.1 mg/l daily average or equal to or less than 4.2 mg/l instantaneous value during the remainder of the year."
I:onitoring data collected between August 9 through November 30, 1985, shows that there were 31 more days that Schuylkill River water was available for censumption using the D.O. limitation.in lieu of the existing temperature limit.
If the D.O. limit had been in effect for all of 1985, the record indicates a gain of 58 days when Schuylkill River water would have been available for consumptive use at Limerick.
PsCO has requested that the proposed D.O. limits be met at five out of six mo11toring points noting that individual monitoring sites may be impacted by localized conditions resulting from point source discharges.
Ihwever, one of the purposes of the original 59 F temperature limita-tion was to prohibit any further degradation of D.O. during low D.O. con-dicions, by allowi:.g depletion of streamflow via consumptive use at Limerick.
Regardless of the cause of low D.O. at any one of ti.e monitoring sites, depletion of streamflow by consumptive use at Limerick could aggravate the D.O. problem.
PECO has also requested that the proposed D.O. limits of 5.1 mg/l aver-age and 4.2 mg/l instantaneous apply throughout the year and have stated that a more restrictive limit during the fish spawning season is overly conservstive.
l I
l
D-69-210 CP (Final)(Revison No. 5)
(PEC0/D0/ Temperature)
In the previous temporary approval to substitute D.O.
limit s f or t em-perature during 1985, a limit ot 7.0 mg/l from March I to June 15 was included in response to the recommendation of the Pennsylvania Fish Commis-sion (PFC).
In response to this pending application for 1986, the PFC, under date of January 17, 1986, requested that additional monitoring stations be required towards the head end of Plymouth, Norristown and Black Rock pools to monitor the D.O. and to use the limit of 7.0 mg/l as measured at those sites during the March 1 - June 15 period to keep those areas suitable for spawning of smallmouth bass.
In a subsequent letter dated April 4, 1986, the PFC stated the D.O.
limits in game fish spawning areas should be an average of 7.0 mg/l and a minimum of b.0 mg/1.
Approval of the portion of the application to transfer existing con-sumptive use from Titus and Cromby to Limerick and allow the transferred consumptive use by Limerick Unit I to occur regardless of the existing docket constraints also requires revision of the project in the Comprehensive Plan and approval of those revisions under Section 3.8 of the Compact.
The Titus Generating Station is two miles downstream from Reading, Pa.
and approximately twenty-three miles upstream from the Limerick Generating Station. Accordingly, any cutbacks in the consumptive use at Titus and transfer for consumptive use at Limerick will increase the quantity of streamflow in the Schuylkill River from Titus to Limerick. The flow increase for the twenty-three mile segment would be a maximum of 3.5 mgd (5.4 cfs).
Cromby Generating Station is located approximately nine miles below the Limerick facilities and conversely, the cutback in consumptive use at Cromby and transfer for consumptive use at Limerick will decrease the quantity of streamflow in the Schuylkill River from Limerick to Cromby. The decrease in streamflow could be a maximum of 1.7 mgd (2.6 cfs). This represents approxi-mately one percent of the Q -10 fl w f r that nection of the Schuylkill 7
River.
Below Cromby there would be no change in the flow regime caused by the proposed transfer.
The transfer of the location of the consumptive use from Titus to Limerick will result in a slight lowering of total dissolved solids level in the Schuylkill River between Titus and Limerick. At a flow of 360 cfs and with the Titus units operating, the TDS level averages about 375 mg/l and calculations indicate that if the three units were shut down, the TDS should drop to 370 mg/1. At Limerick, when operating with a consumptive use of 5.2 mgd, the TDS would increase f rom 370 mg/l to 378 mg/l and below Cromby there should be no change in TDS resulting from the proposed transfer.
Titus Units 1, 2, and 3 are coal fired, having an elettric generating capacity of 234 mw and Cromby Unit 2 is oil fired and has an electric gener-ating capacity of 201 mw.
If the three Titus units and Cromby Unit 2 are all shut down and Limerick Unit l's generating capacity is limited to the trans-ferred consumptive use (250 mw), there will be a net reduction of generating capacity of 185 mw.
The applicant has indicated this loss of generating capacity, if needed, will be replaced with power generated with no additional consumption of Delaware Basin water.
4 e
D-69-210 CP (Final)(Revison No. 5)
(PECO/D0/ Temperature) 6 The net effect on f uel and interchange costs resulting f rom the proposed transfer range from a savings of $3.5 million/ month to an additional cost of 0.7 million/ month. The savings would occur if the 185 mw could be purchased from economical units outside the Delaware River Basin. The additional cost was computed assuming a 10 percent reduction in consumptive use was in effect and the 185 mw were generated within the Delaware Basin by gas turbines.
The PJM (Pennsylvania, New Jersey and Maryland) Interconnection system has reviewed the PJM load and capacity situation for 1986 summer peak load conditions and considered the reduction of 185 mw in PJM generating capacity and concluded that the temporary loss of capacity associated with this'appli-cation will not cause the PJM system to be short of capacity to meet the demand. Additionally, if needed, PECO has agreed that in the event of a PJM shortage, they would curtail Limerick and allow Titus and Cromby to resume operation as needed to meet demands.
DECISION I.
The Comprehensive Plan of the DRBC as amended by Docket No.
D-69-210 CP (Final) on November 5, 1975, is hereby revised as follows:
(1) For the period ending December 31, 1986, the provisions of Docket No. D-69-210 CP, [ attached and included as part thereof to D-69-210 CP (Final)] headed " FINDINGS," " Sources of Water Supply," "1. Schuylkill River" paragraph "(a)" on page 5 are temporarily suspended, and in place thereof the following provision is substituted:
"(a) No withdrawals for consumptive use shall be made from the Schuylkill River or the natural flow of any of its tribu-taries whenever dissolved oxygen (i) is less than 7.0 mg/l daily average or 6.0 mg/l instantaneous during the period March I to June 15 at any one of the monitoring sites in riffle spawning areas located below Limerick approved by the Executive Director in consultation with the Pennsylvania Fish Commission (PFC) or (ii) is equal to or less than 5.1 mg/l daily average or equal to or less than 4.2 mg/l instantaneous value at any of the six exisiting monitoring stations temporarily approved by DRBC Docket No. D-69-210 CP (Final)(Revised).
(2) For the period ending December 31, 1986, the provisions of Docket No. D-69-210 CP, [ attached and included as part thereof to D-69-210 CP (Final)] headed " FINDINGS," " Source of Water Supply," "1.
Schuylkill River" is further revised by the addition of a new paragraph "(c)" on page 5 which reads as follows:
l
~ _ _
a.
D-69-210 CP (Final)(Revison No. 5)
(PECO/D0/ Temperature) 7
"(c) Water may be withdrawn for consumptive use at Limerick whenever the consumptive use at Titus Generating Station or the Cromby Generating Station has been curtailed. The consumptive use at Limerick shall not exceed the volume equal to a quantity saved by the curtailment of generat-ing units at Titus and/or Cromby generating stations.
The maximum quantity that can be considered saved in this process is 3.5 mgd at Titus and 1.7 mgd at Cromby."
(3) For the period ending December 31, 1986, the following condi-tions shall be added to the. provisions of Docket No. D-69-210 CP (Final), " DECISION" on page 15, subheaded "II.":
"o.
Accurate dissolved oxygen measurements shall be taken at I
all sites designated by the Executive Director in consultation with the PFC from March 1 to June 15.
"p.
Detailed plans of the location of each new dissolved oxygen monitoring site shall be submitted to and approved by the Executive Director and the PFC.
"q.
The calibration, maintenance and operation of all dis-i solved oxygen monitors and any interim manual measure-ments of dissolved oxygen shall be under the supervision and control of the U.S. Geological Survey.
"r.. Weekly records of,all dissolved oxygen monitoring shall be submitted to th.e Commission in writing within three working days, together with a log of power plant opera-tions and consumptive water use.
Such information shall be a matter of public record.
"s.
PECO shall immediately notify the Commission whenever dissolved oxygen levels at any monitoring station trigger the criteria set forth in this docket, and advise the Commission of all alternative steps taken.
"t.
Philadelphia Electric Company shall maintain accurate records of all water withdrawals and discharges at the Limerick generating plant. The time of any change in the rate of water withdrawal must be recorded. PECO shall maintain records of water withdrawals at the Cromby generating station. The time of any change in the rate of withdrawal due to a change in the operation of Unit 2 shall be recorded.
~.
S D-69-210 CP (Final)(Revison No. 5)
(PECO/D0/ Temperature) 8 "u.
PECO shall arrange for Metropolitan Edison Company to maintain accurate records of all water withdrawals at the Titus generating station. The time of any change in the rate of water withdrawal due to a change in the operation of Units 1, 2 and 3 shall be recorded. This information shall be submitted to PECO and a copy to DRBC each time there is a change in the operation of Units 1, 2 and 3.
"v.
PECO will compile the information recorded for the Limerick and Cromby plants together with the information supplied by Metropolitan Edison Company for the Titus plant, into a format that clearly demonstrates compliance with the operating requirements of this docket.
"w.
Water may not be withdrawn for use at Limerick in lieu of operating Titus Units 1, 2 and 3 unless Titus Units 1, 2 and 3 have not operated for the previous 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.
"x.
Water may not be withdrawn for use at Limerick in lieu of operating Cromby Unit 2 unless Cromby Unit 2 is reduced within 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of the use of the transferred water at Limerick.
"y.
PECO will notify DRBC staff by telephone each time there is a change in the operation of Titus Units 1, 2 and 3 and/or Cromby Unit 2 operations as a result of the condi-tions imposed by,this docket. The notification shall be in advance or at.the time of the change.
In addition, PECO will submit to DRBC a copy of all recorded informa-tion once each week.
If, at any time, the Executive Director determines that the proposed project is not operating as planned or is causing substantial impacts on the water resources of the Basin, he may cancel or suspend this approval and all operation thereunder shall terminate until subsequent action by the Commission."
(4) The provisions set forth in paragraphs (1), (2) and (3) above shall terminate on December 31, 1986, unless otherwise extended or directed by the Commission, and all provisions of Docket No. D-69-210 CP temporarily suspended by this docket shall become operative in full force and effect.
II.
The above revisions of the Limerick Nuclear Generating Station project are approved pursuant to Section 3.8 of the Compact, subject to the conditions listed above.
BY THE COMMISSION DATED:
April 29, 1986 1
- ~ _ _
00LKETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 16 EP 26 P1 :03 ATOMIC SAFETY AND LICENSING BOA 3D OFFILE OF 3i a A"Y 00CMLImggidVICI In the Matter of Docket No. 50 fb2 OL Philadelphia Electric Company :
50-353 OL (Limerick Generating Station, :
Units I and II)
CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the foregoing Motion to Reopen Proceedings for Further Consideration of Environmental Impacts of Proposed But Not Yet Incurred construction, by mailing a copy of the same to the
'j,,5}/
following persons this 'gh day of 1986.
Helen F. Hoyt, Esquire Chairperson, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Jerry Harbour Atomic Safety and Licensing Board l
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 i
i Dr. Richard F.
Cole Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission 1
Washington, D.C.
20555 Ann Hodgdon, Esquire Benjamin H. Vogler, Esquire U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Troy B.
Conner, Jr. Esquire Conner & Wetterhahn 1747 Pennsylvania Avenue, N.W.
1 Washington, D.C.
20006
i
,j.
o i
l, Edward G.
Bauer, Esquire Vice President & General Counsel Philadelphia Electric Company J
2301 Market Street l
Philadelphia, PA 19101 Secretary 1
U.S. Nuclear Regulatory Commission 1
Attn:
Chief, Docketing & Service Branch Washington, D.C.
20555 i
l Atomic Safety & Licensing Appeal Board U.S.
Nuclear Regulatory Commission l
Washington, D.C.
20555 Charles W.
Elliott, Esquire j
Brose & Poswistilo 325 North 10th Street Easton, PA 18042 I
Martha W.
Bush, Esquire i
Kathryn S.
Lewis, Esquire 1500 Municipal Services Building 1
15th & J.F.K.
Boulevard Philadelphia, PA 19102
}
John E. Flaherty, Jr., Esquire l
Fred T. Magaziner, Esquire l
Lois Reznick/ Esquire J
Dechert, Price & Rhoads i
3400 Centre Square West I
1500 Market Street l
Philadelphia, PA 19102 l
Jay M. Gutierres, Esquire U.S. Nuclear Regulatory Commission Region I i
631 Park Avenue King of Prussia, PA 19406 k
ROBERT J.T SUGARMAN
]
i i
1 i
1715wd3/mrw I
i i
J 4
...w.
~,.---,,,cy,,
,,.,. -,,,. - --i y
-f.---e r
p..-------,,-7._,-,y
,-s
.-w
-,r.