ML20235C163

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Comments on Vols 1-5 of PSAR & Util Amends 1-6 for Plant,In Response to Boyd 700314 & 1009 Requests
ML20235C163
Person / Time
Site: Limerick, 05000000
Issue date: 07/06/1971
From:
INTERIOR, DEPT. OF, FISH & WILDLIFE SERVICE
To: Price H
US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML20235B311 List: ... further results
References
FOIA-87-111 NUDOCS 8709240372
Download: ML20235C163 (5)
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  • d States Department of the Interior United

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FISH AND WILDLIFE SERV,lCE euntAu or srORT FISHERIES AND WILDLIFL h*

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JUL 8 STI ff g 46

. Mr. Harold L. Price f

., ' Director of Regulation bLlh L L I$

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Washi.rgton, D.C. 20545

  • Y,,,, v H-Dear Mr. Price T['b"

.P 4TT e This is in reply to Mr. Ped's letters cf M.r:h 1h cr.d 0:td,;a 5,, ' ~

'3 1970, requestinc our comments en volunes 1 through 5 of the '

Preliminary Safety Analysis Report and amendments I;os.1 through 6, EM*Lj . nled by the Phila*;niphia Electric Company for the Limerick Cen; rat-l ins Etation, Unitt 2. and 2, Montgomery County, Pennsylvania, /J:C i

Docket Nos. 50-352 and 50-353 p' The project is located on the emot bank of the Schuylkin River about 3

1.7 riles sucthwesi, of the boroucn of Pottstown and about PC,7 miles northwest of Philadelphia. The site includes about 587 acres of land adjoining about one mile of the river.

Two identical boiling water reactors designed for a combined output of 6,586 Wt (2,200 We) win be used. Heat rejected to the circu-lating coolinc water system will be dis:ipated to the atrost.here by y means of four hyperbolic, natural-draft cooling towers. Water re-quirements for the two units will be about 107 c.f.s., of which 34 4 c;f.s. win be used for makeup, 20 c,f.s. vin be used for blow-

, g' - dern, and 33 c.f.s. will be used for other purposes including vatar

,y quality maintenance, miseennneous cooling, drinking and santtary use, and wash water. Facilities will be pro /ided for treating the drinking

  • and tanitary water. Temperature differentia 1L within the plant and imposed on the environ.ent are not specified in the safety analysis report. An State water quality standards for plant discharges are to be met.

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Due to the periodic critically short supply of water in the Schuylkin River and the prior downstream claims on the water, Delaware River water win be used to fulfin the $4 c.f.s. consumptive demand of the project. Delaware River water wi n be diverted and transported by conduit to the East tranch of Perkiomen Creek, then diverted from the creek by conduit to the plant site.. Water velocitie,s through the Schuylkill River water intake win be 0 75 to 1.0 foot per second.

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,'JE Ml The radiological waste collection r,yster includes filters, decinera- i liters, and evaporators. The applicant sistcc that the rMielodcal l

wasu diccharcc: will be ategt 1 percesit of the permissible liuAts prescribed by the Atonic Ener.'ty Co:nission's Code of Federal Repla.

tions, Title 10, Port 20. The applicant plans to conduct both pre-
and postdevelop
ent envirore, ental radiological surveys. Details of-the surveys are not presently availabic.

The Schuylkill River in the project area supports moderate populations of largemouth bass, smallmouth base, walleye, crapp:c, sunrisher,, bull-hand, catfish, carp, and suckers. The amount of tisMn:; is moderate, y but is expected to increase. Water quality is generclly g. sod, but is

-; wbject to Walcalc i,os of acMiu du.ii.:.s;e frc up;tycc. c.ir.ca.

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.: Imprwcment in water qua31ty hon been observed wer the isst decade.

I This trend is expected to continue. The applicant has planned recrea-l M;: tional developments, including acce'ss to the river, 4: a part of q { the project.

p' l Amendment No.1 proposes that a 20-mile reach of East Branch of I 4. Perkiomen Creek be used as part of the water transport system from the Delaware River. This segment of the croer, contains good popula-tions of warmwater fishes such as it.rSemouth bass, crappie, and other

sunfishes. Two channel impoundments within this reach prwide addi.

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r tional fish habitat. The stream has Bood public access and receives i  ! anlerate to heavy fishing pressure. Wstor qv.ality in-the strear: is

_l j. good.

The project tite is located in an area which aupports moderate popu-j lations of phessant, cottonteil, grey squirrel and guail. Migratir.g vaterfowl use the river in spring and fall. Hunting is light in the

'N area because public access is restricted. However, Eastern Pennsylvania is considered to be, some of the better pnensant habitat in the east,ern United States. Most of the hunting is for pheasmt, cottontail, guail,

, and squirrel.

4 The applicant indicates that release of radioactive wastes will be i j only about 1 percent of prescribed enh permissible concentrations. '

While maintenance of these low levels wculd safeguard aan from undue t

radiation exposure, the radiosensitivity of fish and wildlife organ- ,

isme is poorly understood so that it is uncertain that they would be 1 i

safe rates for fish and wildlife. R:4icicotopes of many elements ue concentrated and stored by organisms that require these or chemi-cally similar elements for their normal raetabolic activities. Food chain transfer of these radionuclides may result in concentrations hazardous to fish and wildlife.

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qq l~ To date, there has been little study.of t% effet of Encous and sy i enlid radioactive ustes on vi3dlife. T.wrefore, t!.e applicarit i

)._ should furnish infor.tation on t!.c reta, quantitio, 69 d dig err,a1 yg redius of tho. e radioactive tastes tha: vill to niersed.

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! The $ 6.f.s. of water that vv.dd be lost throuch evaporation in the project cooling process may prwe detrimental to fishery re-i sources.

j Th!r divertice reduces the amount-of available fresh water in the De3avarc River needed for fi:;h and wildlife production in the l

Delcware River and estuary.

This water withdrawal in addition to the i estuary, consumptive uses of water cwid cause* serious water shortages in th i

l We underdand that tNe applicant's pre- and postdevelopment radio-logical ano envaronmensaA monnorire will incluut uardy vasor .

-- samplec and quarterly river sediment, fish, and other biotic su:ples, l h The applicant also will monitor terrestrial vegetat!on semiennusily tad soils annually. Those monitoring proi,rers should be coordinated t

dth the Eureau of Sport Fisheries and Wildlire, the office of Water

  • Prop es of the D:vironmental Protection Atener (Federal B> Pennsylvania, fish Com:sission, and other natural resource)c, obse scencies. _ The appliennt's monitorier pro ram should be expandad to the i <

k include and aquatic plants and benthic animals such as clams, crayfish, insects.

, Fishes which depend en various food webs includins i some bottce feeding species such as suckers, carp, and catfish and scoe L i piseivorous species such as bat 4 and crappie also should be sampled.

ij The terrestrial animals such as cottantail, pheasant, and squirrel should be sasipled quarterly. Animals with different food habits are likely to differ significantly in their concentration of radionuclides.

Possible adverse effects of thermal and ehemical water-purifyinc d additive discharges and o' f water intake velocities also are

concern, The Delsware River intake and pumping facilities could entrein signi. '

mile reach of the Fast Branch of Parkiomen Creek w

. by.the proposed transport of $ c.f.s. of Delaware River water.

a Water quality of the creek would be degraded, and the larger flows

would cause accelerated stream bed and bank erosion. However, the M j. lower two-thirds of the affected reach could benefit free the larger, y more constant flows.

The applicant should include in the environmental monitoring program, studies which show the effects of the project on fish and wildlife of the affected stream sections, j

The monitoring elso should be planned, implemented, and evaluated in cooperation with the appropriate Federal and State regulatory agencies.  ;

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6 f] Tbc prcoperetional study rhodd inventory the natural resources, ih

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  • deter;dr.e hir uno, u.d set forth the effect the project is expected to have on the resuarecs. Ti! e postopciational study should verify j  :

the c clynes and include remedial r.cacures, if deemed necessary by i%

s the appropriate aten-les.

I If the nonitoring pregams dioelose ht plant operation will or has

} remited in enviro.tental chnnges detriacntal to fish and wildlife, i prwision for r.odifyire, project structures and operations to proteet' these resources should be planned and put into effect.

In view of this agency's policy to maintain, protect, and improve the f quality of the fich and wildlife recources and the environment, it is reccer.caced that the cmstruction pernit for this project not be, issued untn tb eTpHear.t pr~f19.e: tw c =1::1er, tith :::ur=; e:t'.::::t:r/

f$ to the Secretary of the Interior that the project would be cora;tructed l" and operated in a ranner which wi31 neither harmfully reduce the water i*M(a j.

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quality in the r.ffected arca, nor create intoleraMc adverse effects on fish and vildlife re:curecs. Such a::utcn:cs should tc dcaonstrated by the Philadelphia Electric Company as follws

1. Cooperate with the Bureau of Sport Fisheries and Wildlife, the Federal kater Quality AcLainistration, the l

t Pennsylvania Came Connaionian, the Pennsylvania Fish Ccmaission, the Pennsylvania sanitary Water Board, and

' other interested Federal and State agencies in the plan-aing, itaplementation, and evahation of the pre- and post-development radiolc61 cal and environmental monitoring ,

' 8 yrograms. j i l j 2. Prepare and provide five copies of the pree2velcpment I i

>t radiological and environmental monitoring programs to the

gylj Secretary of the Interior for evaluation prior to project aparation.

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3. Provide infonsation on the rates, quantities, and din-persion of radioactive wastes that will be diccharged from the plant.

x 4. Include in the pre- and postdevelopment radiological sonitoring pro;;ran, representative aquatic plants, tenthic animals, and terrestrial birds and mar.:mals. Samples should be collected at appropriate locations and times.

5. Construct, operate, and maintain such fish protective facilities over the intake structures as are necessary to prevent significant damages to the fishery resources of the e Schuylkill and Delmiare Rivers.

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6. Inchde pre- and postoperctionel envjron: ental studies
z.  ! of the tuenty-nile reach of the 3 cst Err.nch of Perkio an de. t* Crech und 6t. the Delnware ilivur inta2e to deterntne and rcetiP/, if necc:: try, the crfects of tran:portin , Dolnware F,her vat.rs to the pla::t. T rse studies should bc rlt.nned

, , and coadacted by the ripplic:.nt it. cooperation with the appropriate Feder:d said State flun and wilulite conservation acencles.

i: 7 To protect the fish and wildlife recources, make such l

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l podifiestions in pecject .str.:cture and operation as say be 1 Getcri.ined necenst.ry by the interestod Federal and State

{ a6encies.

The opportunity of providing our ccrments is asuscisted.

gi Sincerely yours,

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