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PHILADELPHIA ELECTRIC COMPANY i
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October 5, 1971 T es MAH(4 CDftNELL EA'..s"',"Ur
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Mr Dr. Peter !.. Morric
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Director
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Division of Reactor Licensing Q;,.,,
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Washington, D. C. 20545 4),f;- -
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Re:
Docket Nos. 50-352 and 50-353
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(Limerick Generating Station)
Dear Dr. Morris:
I This ' letter is written in response to the comments which l
have been made by the Department of the Interior, Firh and j.
Wildlife Service, in three 13tgers to Mr. Harold L. Price, dated July 6, August 6, and September 2,1971 I
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Our replies to the co m.ents are presented in the attached response.
We regret that it has taken this much time to present you with the requested information; hewever, the delay has been necessary due to the on-going development of a better environ-f;-
mental radiological monitoring program.
This program was t
J described in Amendment No.11 to the Preliminary Safety Analysis 1.
3 Report for the Limerick Generating Station.
This Amendmeae
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includes a complete revision of Section 2.6, Volume I, Environ-mental Radiological Monitoring Program.
We believe this program i
is responsi"e to the points of concern raised in the Fish and
.I Wildlife leccers.
Yours very y 1 l
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EDWARD G. BAUER, JR.
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July 6,19'/1 Letter from the 11. S. Departrent of the Interior, f
Fish and Wildlife Servf co i
Item No. la i'
Cooperate with the Bureau of Sport Fisheries and Wildlife, the i'
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Federal Water Quality Administration, the Pennsylvania cane Conniesion, the Pennsylvania Tish Commission, the Pern71vcnia Snnitary Water Board, i
and other interestod Federal and State agencies in the plarw.ing, in-plementation, and evaluation of the pre-and post-development rad!ological and environmental monitorin;; pro. rans.
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Response
j On August 25,1971, *hiladelohia Electric Comnany (P.E. Co), and its centu3 tent:, Radiation Maneremnt Cerocration (R.M.C.) held a nectinc !=
li presently solitting sanples with the Pennsylvania Department o't Environ-Harrisburg, Pennsylvania with the below listed federal and state agercies to discuss the fish and wildlife aspects of the radiological environmental monitoring nrogram for the Lixerick Genercting Station (L.O.S.),
Tne existing L.O.S. pre-oocratiora1 radiolo6 cal environmental sonitoring pro-i gram was reviewed in detail and discussed with the at:encies. R.M.C. is mental Resources, Environr. ental Monitoring Branch, and the United Eta.tes Environmental Protection Agancy, Analytical Quality Control Service. The comments which 5.E. Co. has received concerninr: the radiological monitorint q
program have been appreciated.. P.E. Co. looks forward to a continued riose K
relatio,nshin v? th these below listed agencies.
t Agencies which were represented at the L.O.S. radiolog511 environ-mental monitoring coordinating meeting are:
U.S. Bureau of Sport Fishieries ? Wildlife, Upper Darby office.
U.S. Bureau of. Sport Fisheries e Wildlife, Bostn Regional office.
National Marine Fisheries Service, U.S. Derartment of Agriculture.
i Environmental Impact Statement Review Branch, E.P. A.
1 Special St,udies Branch, Office of Radiation Programs, E.P.A.
Office of Water Programs, E.P.A.
j Pennsylvania Department of Environmental Resources, Water Quality Div.
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Pennsylvania Departnant of Environmental Resources, Office of Radio-1,ogical Health.
Pennsylvania Game Commission.
Pennsylvania Fuh Commission.
Pennsylvania Joint Legislative Committee on Conservation.
Pennsy,1vania Environmental Quality Board, e 1-
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h ct are airt trovide five copics of tho. predevelo?..cnt redio-h;'
envirec. ental mn'.toring tro.:rans to the Secretary of c.. : n r. :
t!.< ?nt rf er for evaluation prior to project operation.
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Fr.elor,cd you will find five conids, as requested, of. the L.G.S.
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nre.o: eratinnul surveillance (envirornental) program (Section 2.6 of the 1,.". 5. IBAR )
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Provide t nfor.vit;on o:' the totec, r;tmnt$ tics, cryl dispersion jg,i of radioactive war.tes that trill be discharced from the plant.
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i Enclored you vill find five copi::s of Tables 9 2.1 and 9.L.3
-j dated Apr$1,1971 of the L. O. 5. PCI.P. which provide infor:r.ation 4
on the raten, quantities, and diep.?rsion of radioactive westes.
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Iter.13. h (dl Include in the nic-and cost-develore.ent radiolecient monitorinc i%
rer. cran, renresentatike anuritic ninnts, tenthic animals, r r.d terrcriri'i ps.N bit ds and cw.sela. Sn:.olec shoiild be collected at ar,r,ronriato 10catto:n and times, Responses.
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In the attcched Section 2.6 of the L.O.S. PSAR, rarer to Sections 2.6.1.1.7, 2.6.L.).8, and Tables 2.6.1 a 4 2.6.2 for discucalens of the aquatic environment and terrestrial birds and mammals sampling.
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[:W Constreet, operato, er.d rr.fut.nin occh f.tch protectivb fccililk cycr the intaka of)w tur en on tre rne: '0c to prvv.mi : S nificant t
dcnnr.o to the fithery rewarcon of the Sch;lkill and Dolnuaro Risers.
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Protection of fiebn isa princ design, paranater in b ehlicecring of the water intake structuras on both the Perkionen Creek and tho 6,.v i p
Schaylkill River. The decign incorporates the recormndations of f
our consulting biolo,-iet, Dr. E. C. Raney of Ichthyological Associatos.
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% intnhc structures will be equippad with rotating screena located v4 nir th? etructyn: =c th:t,th; c t;;'..',rc face is v&eeld.i.11, fluh T
with h face of the strecturo. Additionally, openince will ba pro-i vided in both the upstroca and dotrnstroen walls of ths structurce to gg -
allow for passage of fiehos fron tha screen area.
h screens will be equipped with 1h tauco stainions steel mesh with 1/h* clear openings. At design xininun vator level (85 cfs) and maximun plont flow, the approach velocity to the screens wil3 h less than S foot per second which is considorod to be well within the swis er.aed capability of the resident fish population. At hiv.or stnam flous the inlet velocitics will' be further reduced becuse of the increased scroon aren exposed to the unter level.
b ownership and oporation of the pumping Station on the Delaware Riv:r 1: und:r consideration by t:a Delauaro River Bacin Conmission.
This is a joint project to supply both the Bucks County Municipal water noods and the consunptivo voter req"irenents of the Thila-delphia Electric Conpany for the Limerict coo'ing touer operation gjjj durire periods of imt flow in the Schuy1xill River.
PECo thereforo can r:ot anticipe.to the judr,nont of the DFBC regarding
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the do8iEn of the intake structure, however it is expected that fish protection will be one of *he prime cenign psrameters.
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Iten No. 6:
Inc3nde nre~ and oost-operational envirmtwntal studies of the ti4 twenty-mile ts.ch of the hst Branch of P. rkiorrn Crack and at the y
CW Delaware River intake to dewrnirae t.ra re etify, if racescary, the El effects of transporting Delaware River waters to the olent. Ti.ne studies shotftd he plant.ed and condaL.d by the Mplienr.t in coo;<rotion with the ronropriate Federal and Suite fish and wildlife conserv.itica agencies.
l Response:-
The Delaware River Rasin Commission Doc'et No. D-65-76 CP (3),
dated Farch 17, 1971, on the Point Pleasant Pumpics Facilities, in-giuding the water releases in to the East Branch of the Perkicmen,
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hcludes the following findings concerning this water transports j
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- rne proposed Point Flensent, divusic.n would tc ter.:ft:t:1 to the Neshaminy and Perkiomen watersheds and would not be detri:nental to the Delaware if canditions of operation imooned i
hr the Commission are observed.'
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These conditions-were then delineated.
Philade1 Pia Electrie has initiated a radiological environmental I
I monitorine nrorran tions the to-mile reach of the East Brarch of the 3
Tarkiomen Creek and at the Delaware River intake consisting of the i
following: Pre-operational surveillance include nonthly water sam-lee in the Delaware River. inst upstream of the Nint Pleasant intake l
structure and the Workiomen Creek just upstr This water is analysed for grossy{an of the L.O.S. inta j
-f, and for tritium structure.
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on a monthly basis, plus a gamma isotopic ocan is prforawed on a gt quarterly basis.
l Chonical quality studios of the ev.er d the Delaware River, the Perkiomen Creek and the Schuylkill 1nar hr.ve been done by Bett Lab-oratories. Inc. The results of thsc-w.oa indicate that the quality cf water in the Delaware Rivec is bester than the cuality of water in both the Schuylkill River and the Ptrkioner. Creek. Addi-tional studies, conducted by E. H. Bourquard Associa'tes for D.R.B.C.,
Backs County and PECc on the feasibility of the Delaware River pumping facility and on the hydraulic effects of the troposed pumonge into the Perkiomen Creek, are referenced in tlw Philadelphia Electric Comoany's Llanerick Ganerating Station Environmental Report, page 36 Biological studies which were conducted and renorted hv Trembley, Owen, Broadfoot and Mihurskey, "A Biological Survey of the Parkiomen System, May 1,1%7, have been reviewed ard are also referermed in a
Philadelphia Electric Company's Environmental Report.
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160-Resnonr,n t!o, 6 (cor.tIr. red) 1 Acur. tic ecolor/.tudies of tM Sch9y} kill !tiver and Perkf or.cn Creek (incluling th< Sat l' ranch of t!.c Crc ek) are beira conducted by Ichthy 1rmic 51 Amm h.tres.
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g Twelve can,linx 4 reas have imen ertriblished on the Schuylkill t
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plant ette to a osint 5 niles ur.trean from the sita, several lo-
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cations on font tr.ibutary strea::.:; ir.elnded in thic crea are also
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g being snn, led. !'ine locations on thelnst rrench or the Perkion.cn and threr stations on the r. sin eten aru boine r.onitored.
l The ecolecieni mrar.oters being studied at each location include:
Fishes, their snecies, nonilations, behavio' and r
scanning areas, Aquatic Veretation, their snecies, artent and growth, Eacroinvertchrates and benthos snecios and abundance, l
Plankton (limited to Schuylkill River),
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Temperature, Dinsolved oxygen and pit.
The results of sampling by Ichthyological Associates wke it
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difficult to support the premise that a Eood fishery exists in t.he east branch of the Per%io:%n Creek. Of the three snecies montioned i
by the Bureau of Sport Fichcries ard Wildlife, in its letter datri July 6,1971, none have been sampled in significant numbers. Or4
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a few ymmg larremuth boss were taken in the bst Branch cf tht.
Perkior.en Creek and none were er.ptured in the main stem of the Perkioben Creek. Several types of sunfish are abundant in pools at the base of dans and near banks. No crannies have been taken..
N Data will be collected and the studies continued after the 9
plant r.oon into oneration until it it determined that there are minimal detrimental effcets on the ecolory of the Schuylkill River and the Perkior.en Creek including the East *Jranch as a result of the operation of the plant.
Dr. Eugene F. Dudley of the Boston Office of the Department
$l. E of the Interior, Fish and Wildlife Service, visited the Limerick
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Site on V.ay 5,1970, to insoect the site and review the project plans including the water suoply and ichthyological studies. Sev-i
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l eral svarcstions V ich were made by Dr. Dudicy for minimizine the effects of the intake structures on the envirorr.ont have been I
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M Ed incorporated in the scope of the above described studies.
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-To protect ther fich and dblii/c rt ::ources, t-cl.a Loch fjE(
modifications in oject ct.rteture: a:io o sra tio:: as r.n:. be L.
dc termined neceas:ry try the it.tcrested l'ederal and State
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Philadelphia Elect.ric Ccapiiny with its consultants is L,
ut:irc an extenniva effort to ur.&rousnd and, thun, to b.tter
] g protectthe fisii and ididlifo resourcer of the f:roatur Liv.erick it environ unt. Studioc are Leirc cond.icted, and vil be continued after the plar.t in in opar.stion to wonitor for the plant in-
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- g' Pect,*if any, on the envirornent. Should any unexpoeted effect
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be deter:ir.:d, app :priate :t;p,c11.c, ts::c,r, 'w cyalstc t;g h
effect.
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Dated An.-nt 6,1071 This letter reonested cinrifying inforr.ation in cos.nection wita Mitladelphia Elcetric's response to AF4 Question P.25, Suppluent No. 5 and t.he answer to question 2.28 l
The answer to question 2.28 was submitted as the revised scetion 2.6, dated August,1971.
Additional information on the answer to question 2.25 follows:
On pt. : 2.h-1? (:!sted.a,pr$3 le?l) ef tha Man the an17 yy stream water allocation withdrawn from the Schuylkill River is b
listed as the Borcuch of Pottstown allocation'of 8 agd. (or 12.h efs.)
b MAR Tiguren 2.h.h, 2.h.5, 2.h.6, 2.h.7, and 2.h.9 sumarier the natural stream flow statistics as r. assured at the Pottstoun gagine station which is downstream of the Pottstown Municipal Water Intake and therefore reflects its effects on the Schuylkill River stream-1 flow available at the site.
As far as te effects of the plant operations on the river water quality at low streamfluw are concerned, these have been l
analysed and submitted to the Delaware River Basin Comission and i
the Department of Environmental Resources of the Commonwealth of Penn:ylvania. The analysis was nerforr:d at the mininnrs consecuti-t y
7-day flow with a 10-year recurrence interval designated by the j
Delaware River Basin Cossnission for this nuroose.
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The results of this analysis indicate that the effects of the plant operations on the Schuylkill River water quality under thue
+'4a low flow conditions result in a loF rise in the sumer ano a 2cF
- j g'h-rise in the winter outside of a small mixing sone. The resultant increr.se in total solids evaluated under the same prescribed con-ditions is an increase of 29nta for a total concentration of 26h opa.
u This is different than the total concentration (250 pra) published l
in the Environmental Report due to the use of a lower river flow and some refinement in the river solids information.
doth the resultant thermal effects and the resultant chemics)
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effects are well within the -regulatory agencies' water quality criteria for this stream.
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fetter frr.c. U.S. Dor t, of t.ho Interior Fit.h and *.fildlife Service g
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Dated Sen% :a r 2.,,14]1,
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Qj Item No'. 1:
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Temperature inversion and their effect on dis %rsion or stack gas relenses is discust.ed in Scetion P.3.5 o' the arcrid-i
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ment. Theroin it is stated "it may r,erve as an additional I
a holdup, uhorein the adverse effects or poor dispersion are counteracted by a longer period for radioactive decay to occur."'
Although such circumstances would allow a lorcer period for radioactive decay, the ir.nodiate environment would be suljocted to concentrated radirtion levels for a loncer than nornsi period.
J The applicant should outline the probable adverse effects. on 1
- p fish and wildlife resources should this situation arise.
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Response
On an annual basis, it is not expected that there will be any area at the site boundary (maximum exposure area) in which wildlife or aquatic species would receive a whole bch panelleting radiation dose greater than 10 KtD(. This is e conservative dose estimate sir,ee that it assumes that the fish or wildlife
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stay in the. area unsheltered for the entire year.
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Item !!o, 2:
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pi yq ;. t l Qel In Section 12.P.7, Schu/3 kill River intake tor! pure strtetores 49;d are discurr~.1, but velocitics e.t tha intaks scrennn are ont de!!r.-=.ted.
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Since velociti, s greater than 0.75 fps could impose ha ardr.us c;n-
, L ditions to equatie orn:nisms, the npolicant should sttte the expected velocitics at this structure.
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Response
5 Please refer to our previous response.to iten 5 of your July 6 letter.-
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A siniinr questien was stated in iten 5 of the July 6 Tish and e
Wildlife letter. We believe our resnonse to that question aise g
answers the concern expressed here.
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Iten No. 3:
i VMle to icolire1.nnendix I, Sec t ion 3.1.1. discunned C)nso IV cr-ernencies.
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continc.cncy 91hw to orotect fish at.d uildlifo respurccc clsotne o
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should be orovided.
towers and meteorological to.:crs rose totentin) hazards to birds, traticu1r.rly nigrating utcrfcal during certain atco:,rbric hr i
conditions which induce fog.
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Resnsnces Plan requires treediato notification-to the State of Pe Departnent of Environy.ontal Resources - Office of Radiological Health.
velooment and Radiation Control Act - P.L.This Stato Agency 1625 (1965), with having 4,
prim resnonsih414ty in radiation matters, N Acencien Renetar Assjetance Plen"' (REAP), provides for their mana g
site consequences of any substantial radioactive release, incident to the operation of a nuclear reactor.
REAP provides for the notification of other Commonwealth Agencies in order to bring their resources and expertise to bear during the among the organizations which will be notified by ths Offi 1
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Radiolocien1 Health should G o emergency arise.
will provide consultation services to the Office of Radiological Thece acencies Health regarding the possible effects to the fish and wildlife, and may recomend methods to minimite those effects.
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its. environmental monitoring consultant and the gF ecological consultant.
e We believe this nian to be a viable one w C
N protection of our fish and wildlife resarecs.hich will insure
[Q The installation of cooling towers and meteorological teuers S
are necessary for the croner operation of the pisnt for the least l
impset on the environment.
l for obtaining data to confirm predictions of weather used inMeteo I
making certain calculations for plant operation.
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on the flicht of birds than do existing structures such
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buildings, anokestacks, bridges and heat isit.nds created by cities
.The predictability of the ootential hazard is very difficult; however, we do isot anticipate any probleas unique to these towers
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