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| ENVIRONMENTAL REPORT - OPERATING LICENSE STAGE REVISION 6 PAGE CHANGES The attached pages, tables, and figures are considered part of a controlled copy of the Limerick Generating Station EROL. This material should be incorporated into the EROL by following the instructions below.
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| REMOVE INSERT VOLUME 1 Pages 2.1-1 thru 2.1-6 Pages 2.1-1 thru 2.1-6 Table 2.1-2 Table 2.1-2 Table 2.1-9 Table 2.1-9 Table 2.1-12 Table 2.1-12 Table 2.1-15 Table 2.1-15 Table 2.1-16 Table 2.1-16 VOLUME 3 Table 6.1-32 Table 6.1-32 (pgs 162)
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| VOLUME 4 Page E310.3-1 Page E310.3-1 Page E310.10-1 Pages E310.10-1 thru -5 Page E320.1-1 Page E320.1-1 Page E320.2-1 Page E320.2-1 Pages E451.5-1 thru Figure E451.11-1 8210040278 820930 PDR ADOCK 05000352 C pyg
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| O CHAPTER 2 THE SITE AND ENVIRONMENTAL INTERFACES 2.1 GEOGRAPHY AND DEMOGRAPHY 2.1.1 SITE LOCATION AND DESCRIPTION 2.1.1.1 Specification of Location Limerick Generating Station is located in southeastern Pennsylvania on the Schuylkill River, about 1.7 miles southeast of the limits of the Borough of Pottstown, and about 20.7 miles northwest of the Philadelphia city limits. The Schuylkill River passes through the site, separating the western portion, located in East Coventry Township, Chester County, from the eastern portion, located in Limerick Township and Pottsgrove Township, Montgomery County, Pennsylvania. Figure 2.1-1 identifies the general location of the Limerick site, and Figure 2.1-2 shows the immediate environs, within 5 miles of the site.
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| The Universal Transverse Mercator coordinates of the Limerick Unit 1 reactor are 4,452,582.462 meters north and 449,984.170 O- meters east, Zone 18T. The corresponding Greenwich coordinates for Unit 1 are 40013'26.67" north latitude and 75035'16.27" west longitude. The Unit 2 reactor is located at 4,452,582.462 meters north and 450,033.548 meters east, Zone 18T of the Transverse Mercator Coordinate System, with corresponding 40013'26.64" north latitude and 75035'14.15" west longitude coordinates.
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| 2.1.1.2 Site Area The land portion of the site consists of 595 acres, as shown in Figure 2.1-3. The property within the site boundary is owned by Philadelphia Electric Company except as noted below. The site boundary is shown in Figure 2.1-3 As shown in Figure 2.1-3, the site is traversed by several public roads, a Conrail right-of-way, and the Schuylkill River. These areas, including the island in the river, are considered public passageways and not part of the site property.
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| The site is located in gently rolling countryside, traversed by numerous valleys containing small streams that empty into the Schuylkill River. On the eastern bank of the Schuylkill River, the terrain rises from just under el 110 MSL, at the river, to approximately el 300 MSL toward the east, which is the highest ground on the site boundary. Two parallel streams, Possum Hollow Run and Brooke Evans Creek, cut through the site in wooded O valleys, running southwest into the Schuylkill River. Grade in the area of the reactor and turbine enclosures is about el 217 2.1-1 Rev. 1, 09/81
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| LGS EROL MSL. On the western bank of the river the terrain is relatively flat, rising only about 50 feet from the shore to the western edge of the site. One small stream flows southeastward through the site to the Schuylkill River.
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| The exclusion area for Limerick Generating Station, shown in Figure 2.1-3, is defined as the area encompassed by a radius of 2500 feet from the center of each reactor unit. The property within the exclusion area is owned by Philadelphia Electric
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| . Company, except as noted below. As shown in Figure 2.1-3, the
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| ) exclusion area is traversed by several public roads, a Conrail right-of-way, and the Schuylkill River. These areas, including the island in the river, are considered public passageways and not part of the sit property. Arrangements for control of public access to these areas in the event of an emergency have l
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| been made with the Pennsylvania State Police and with Conrail, as
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| ( described in the Emergency Plan.
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| There are no outstanding mineral rights within the exclusion area.
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| The locations of principal station structures are shown in Figure 2.1-4. In addition, the Limerick Atomic Information Center is 1ocated on the site property. The information center, owned and operated by Philadelphia Electric Company, is open to the public during specified hours. Admission to the information center is controlled by Philadelphia Electric Company.
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| A power plant simulator, used for training operating personnel, is cdjacer.t to the site. Tnis facilit/ ir p3rcted by Osncrc:
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| Physics Corporation. Use of the facility is controlled by Pniladelphia Electric Company.
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| 2.1 1.2 Eoundaries for Establishing Effitent Release Limits The boundary line of the restricted area, as defined in 10 CFR Part 20, is identical to the site boundary line shown in Figure 2.1-3. The land area within the boundary lines is owned by Philadelphia Electric Company. Control of public passageways is discussed in Section 2.1.1.2.
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| There are no permanent residences within the restricted area.
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| Station effluent release points are shown in Figure 3.1-2.
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| 2.1.2 POPULATION DISTRIBUTION 2.1.2.1 Population Within 10 Miles The population distribution within 10 miles, as a function of distance and direction, for the decades 1970 through 2020 and for 1983, is listed in T . ales 2.1-1 through 2.1-7. The 1970 and 1980 Rev. 6, 09/82 2.1-2
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| data are taken from actual census data and the other years are taken from projections (Table 2.1-15). The 1983 projections are considered to be representative of population near the year of 1
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| initial station operation, and the 2020 projections represent i
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| population near the end of station operation. These projections are based on 1970 census data and have not been revised based on 1 1980 census data. The 1980 data shows that population has decreased. A map, keyed to Tables 2.1-1 through 2.1-7, is provided in Figure 2.1-5.
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| I
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| ' The population distribution within 10 miles is based upon the number of households, obtained from a 1980 meter count of Philadelphia Electric Company's residential customer billing file, and a 1980 meter count of Metropolitan Edison Company's billing file. A factor of 2.88 persons per residential meter in j Philadelphia Electric Company territory, and a factor of 2.70
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| ; persons per residential meter for the Metropolitan Edison Company 1 territory were used to convert the meter count into population.
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| Projected populations were determined by using county projection
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| .i factors obtained from state agencies. Where information was not available to the year 2020, Philadelphia Electric Company entended the available information through that year.
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| Table 2.1-15 lists the sources of population information. l Population for the year 1983 was estimated by Philadelphia Electric Company by extrapolation of data between 1980 and 1990.
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| Projections for the years 2010 and 2020 were made by increasing projections for the year 2000 at a rate of 20% per 10-year 4
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| period. -
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| 2.1.2.2 Population Between 10 and 50 Miles Population distribution between 10 and 50 miles for the decades between 1970 through 2020 and for the year 1983 is listed in Tables 2.1-8 through 2.1-14. 1980 population distributions are based on the assumption that the population of each civil division occurs at the centroid of that civil division. The location of the centroid of the civil division by ring and sector determines the sector into which the population of the civil division is assigned. A map, keyed to Tables 2.1-8 through 2.1-14, is provided in Figure 2.1-6.
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| Projected populations were determined by using county projection factors obtained from state acencies. Where information was not available to the year 2020, Philadelphia Electric Company extended the available information through that year..
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| Table 2.1-15 lists the sources of population information.
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| Population changes for 1950 through 1980 in the counties within 50 miles of the station are indicated in Table 2.1-16.
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| 2.1-3 Rev. 6, 09/82
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| 2.1.2.3 Transient Population l The transient population in the site area is classified as daily or seasonal. The daily transients result from an influx of employees to local business and industrial facilities. Local industries, and their location and employment, are listed in Table 2.1-17. The only industries with a significant daily transient population are Mrs. Smith's Pie Company, Sircom Knitting Company, and Crouse Company.
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| Seasonal transients result from use of recreational areas, of which there is only the Countryside Swim Club, Inc., within 1.3 miles of the station. The maximum daily attendance at the swim club is estimated to be 800, with a daily average of 400 during the summer season.
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| A 1976 creel survey of people fishing the Schuylkill River within 5 km of the station showed that 96 percent lived within 10 km of the river and thus do not comprise a transient population. These data also projected 1980 fishing pressure within 5 km of the l station at 8800 angler hours for the principal fishing months of May through September. The average time spent fishing was 3.5 hours from shore and 4.7 hours by boat. Less than 20 percent of the fishing pressure came from boats. Table 2.1-42 describes boating hours per year as cited by the Pennsylvania Fish Commission. Based on these data and data collected in a 1980 creel survey conducted as part of the Limerick preoperational program, an average of 1100 boaters per year could be expected to use,the Schuylkill River within 10 miles of the station, most of which would occur below Vincent Dam (3.3 miles below the station).
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| 2.1.2.4 Ace Distribution The age distribution in Montgomery County compared with the U.S.
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| population in 1970 is shown below:
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| Ace Percent in ;ae Group Montoomery County United States l 0-11 21.4 22.4 l 12-17 12.2 11.9 18 and over 66.4 65.7 Total 100.0 100.0 There is no reason to believe that there will be a significant difference in age distribution in the year 2000 between the United States and Montgomery County. The United States age distribution in 2000 is shown below:
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| l Rev. 4, 07/82 2.1-4
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| l LGS EROL O Ace Percent in Ace Grcup 0-11 17.3 12-17 9.2 18 and over 73.5 2.1.3 USE OF ADJACENT LANDS AND WATERS The general land use character of the area within 5 miles of the Limerick site is rural and open, and contains one major forest, located in northern Limerick and Lower Pottsgrove Townships. A discussion of local land use was provided in Section 2.1.4 of the Limerick Generating Station Environmental Report - Construction Permit Stage (Revised). There have been no major changes in actual or projected land use patterns.
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| Present and projected land use within a 5-mile radial area of Limerick is presented in Tables 2.1-18 and 2.1-19. The Urban development and population concentration near Limerick lies outside a 2-mile ring and, historically, has been orient'ad along the Schuylkill River, with recent suburban growth spilling out over municipal boundaries. About half of the 1970 population was located in the Boroughs of Pottstown, Royersford, Spring City, 0
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| , and unincorporated areas of So'uth Pottstown and Kenilworth.
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| Pottstown Borough, with a 1980 population of 22,729 people, is the largest local municipality. The borough's population declined from 1960 to 1970 and continued to decline from 1970 to 1980.
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| 2.1.3.1 Industries Industries with 10 or more employees within 5 miles of Limerick Generating Station are listed in Table 2.1-17. The number of employees, products, and locations is listed for each establishment.
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| The nearest industry to the site is the Pottstown Trap Rock Quarry, Inc. Operations of the quarry include the detonation of explosives in the process of quarrying stone. However, the use of explosives is infrequent and only enough explosives for one particular application are brought to the quarry. There are no explosives stored on the quarry site. Other industries located within 1.3 miles of the station include Hooker Chemical Company, Mahr Printing, Inc., Eastern Warehouses, Inc., Amerind-MacKissic, Inc.,
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| l and Structural Foam, Inc. The location of these industries is shown in Figure 2.1-7. Hooker Chemical Company is the only establishment near the Limerick Generating Station that has significant quantities of hazardous materials stored onsite. These materials are listed in Table 2.1-20.
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| O As shown in Figure 2.1-8, there is a natural gas pipeline adjacent to the site, consisting of two separate pipes, cperated by the 2.1-5 Rev. 6, 09/82
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| LGS EROL Columbia Gas Transmission Company, and an oil pipeline operated by Atlantic Richfield Company within the site area. Other pipelines within 5 miles of the station are operated by Philadelphia Electric Co, Mobil Oil, Texas Eastern Transmission Corp, Transcontinental Gas Pipe Line Corp, and UGI Corp. Pipe sizes, age, operating pressure, etc., are listed in Table 2.1-21. At the present time, there are no plans to utilize these pipelines to transport products other than those currently transported.
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| 2.1.3.2 Transportation Routes The major transportation routes located within 5 miles of the site include the following:
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| : a. U.S. Route 422, an east-west highway passing approximately 1-1/2 miles to the north of the site.
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| : b. Pennsylvania (PA) Route 100, a north-south highway passing approximately 4 miles west of the site.
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| : c. Pennsylvania (PA) Route 724, a southeast-northwest highway passing approximately 1 mile southwest of the site.
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| : d. The Consolidated Rail Corporation line (formerly Reading Company), passing through the site along the north bank of the Schuylkill River. The line is comprised of three tracks and has a rail spur serving the station.
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| : e. The Consolidated Rail Corporation line (formerly Pennsylvania Central Railroad), running in north-south direction, passing along the western boundary of the site.
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| These transportation routes are shown in Figure 2.1-8. Planned changes to local transportation routes include the extension of the Schuylkill Expressway, and Interstate Route No. 76 from Valley Forge to the terminus of the Pottstown bypass, U. S. Route 422.
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| The proposed alignment follows the Schuylkill River, generally about a mile away, and passes near the northern boundary of Royersford Borough. About midway through Limerick Township, the expressway veers northward to join with U.S. Route 422. In the vicinity of the Limerick site, the expressway is located farther away from the Schuylkill River than in any other location.
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| Expressway interchanges now exist along the Pottstown Bypass at PA Route 100, Hanover Street, Keim Street, PA Route 724, Firestone Blvd., Township Line Road (presently labeled Eiergreen Road on all street signs), and existing U.S. Route 422. The PA Route 100 interchanges are modified types, which necessitate turning movements across traffic flow to get onto and off the ramps. This turning movement tends to lower traffic capacity of the feeder streets, as well as the ramps.
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| Rev. 4, 07/82 2.1-6
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| O O O LGS EROL TABLE 2.1-2 POPULATION DISTRIBUTION 0-10 MILES 1980 DISTANCE (MILES)
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| Sector 0-1 1-2 2-3 3-4 4-5 5-10 10-Mile Total N 58 682 894 397 753 3,158 5,942 l NNE 46 1,088 244 478 204 2,428 4,488 l NE 46 40 202 334 276 3,732 4,630 l ENE 12 58 199 380 228 5,139 6,016 l E 20 150 271 389 418 5,120 6,368 l ESE 29 179 297 268 579 9,223 10,575 l SE O 369 141 4,844 4,055 6,830 16,239 l SSE 6 190 285 2,664, 1,587 20,992 25,724 l S 3 343 331 164 340 3,864 5,045 l SSW 12 611 308 513 268 1,848 3,560 l SW 69 181 204 311 300 1,783 2,848 l WSW 46 179 533 458 1,596 1,899 4,711 l W 35 118 1,754 1,515 1,054 2,239 6,715 j WNW 60 320 2,992 11,076 3,545 9,791 27,784 l NW 0 288 1,872 6,667 1,309 4,004 14,140 j NNW 0 711 1,727 1,237 1,304 6,555 11,534 l l
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| Total 442 5,507 12,254 31,695 17,816 88,605 156,319 l Rev. 6, 09/82
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| O O O '
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| LGS EROL TABLE 2.1-9 POPULATION DISTRIBUTION 10-50 MILES 1980 DISTANCE (MILES)
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| Sector 0-10 10-20 20-30 30-40 40-50 50-Mile Total N 5,942 7,884 53,061 55,728 24,830 147,445 l NNE 4,488 24,323 185,370 175,555 38,751 428,487 l NE 4,630 18,810 19,791 25,253 49,483 117,967 ENE 6,016 54,025 52,445 19,874 36,108 168,468 l E 6,368 60,790 88,479 178,907 331,487 666,031 ESE 10,575 124,311 654,399 609,017 105,734 1,504,036 ,
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| SE 16,239 84,571 1,042,915 509,968 182,225 1,835,918 l SSE 25,724 24,010 260,063 31,240 22,748 363,785 l S 5,045 71,662 37,832 329,479 23,712 467,730 l SSW 3,560 41,678 25,473 47,226 48,771 166,708 l SW 2,848 7,171 34,583 11,577 18,878 75,057 l WSW 4,711 9,298 24,662 72,930 133,537 245,138 l W 6,715 4,729 17,437 49,786 74,846 153,513 l 4 WNW 27,784 120,554 72,875 25,831 29,043 276,087 l NW 14,140 9,026 17,164 17,026 63,480 120,836 l NNW 11,534 12,706 16,031 7,502 34,491 82,264 l Total 156,319 675,548 2,602,580 2,166,899 1,218,124 6,819,470 l l
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| O O O
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| ; LGS EROL TABLE 2.1-12 POPULATION DISTRIBUTION 10-50 MILES 2000 DISTANCE (MILES)
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| Sector 0-10 10-20 20-30 30-40 40-50 50-Mile Total N 11,927 6,829 46,286 46,773 25,174 136,989 NNE 5,381 25,272 215,644 183,280 37,574 467,151 NE 5,026 32,778 23,802 31,732 52,752 146,090 ENE 3,526 52,418 61,837 25,372 39,811 182,964 E 16,987 66,515 140,102 263,769 476,933 964,306 ESE 19,812 168,561 747,667 699,313 105,747 1,741,100 SE 13,336 116,919 1,252,024 724,448 143,256 2,249,983 SSE 51,068 38,367 269,704 35,137 29,640 423,916 S 8,090 95,506 39,132 436,266 24,908 603,902 SSW 5,268 44,671 37,951 52,662 68,035 208,587 SW 6,591 6,461 52,976 13,528 20,704 100,260 WSW 5,069 11,030 23,711 74,921 152,049 266,780 W 6,268 3,932 17,805 49,845 79,117 156,967 WNW 36,978 132,836 76,946 20,317 26,559 293,636 NW 15,742 8,414 18,249 14,247 51,353 108,005 NNW 11,216 10,593 15,770 5,735 29,634 75,190 l Total 222,281 821,102 3,039,606 2,677,345 1,363,246 8,125,826 j l
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| 4 Rev. 6, 09/82
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| LGS EROL O TABLE 2.1-15 SOURCES OF PROJECTED POPULATIONS State 1970 1980 1983 1990 2000 2010 2020 Delaware 1 7 8 2 6 6 6 Maryland 1 7 8 3 6 6 6 New Jersey 1 7 8 4 4 6 6 Pennsylvania 1 7 8 5 5 6 6 Year of Estimate 1 U.S. Census 1970 2 Division of Urban Affairs, University of Delaware 1975 3 Maryland Department of State Planning 1975 4 New Jersey Department of Labor and Industry, 1975 Division of Planning and Research, Office of Business Economics 5 Pennsylvania Department of Education 1975 6 Philadelphia Electric Company 1977
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| : 7. U.S. Census 1980
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| : 8. Philadelphia Electric Company, based on 1977 State-supplied data O .
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| Rev. 6, 09/82
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| LGS EROL l TABLE 2.1-16 BUREAU OF50CENSUS MILES OF THE POPULATIONS SITE OF COUNTIES WITHIN COUNTY _
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| S'1 ATE __ 1950 1900 1970 New Castle DE _
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| 1980 218,679 307,446 385,856 Cecil 399,002 MD 33,356 48,40d 53,291 Burlingten NJ 60,430 Camden 135,910 224,499 NJ 300,743 Gloucester NJ 392,035 323,132 362,542 Hunterdon 91,72/ 456,291 NJ 134,640 471,650 Mercer NJ 42,736 54,107 17t',681 1S9,917 Salem 229,781 266,392 69,718 87,361 NJ 49,508 303,968 Somerset NJ 59,711 307,863 Warren 99,052 60,346 NJ 54,374 143,913 198,372 64,b76 63,220 73,879 203,129 Berks PA 64,429 Bucks PA 255,740 275,414 Carbon 144,620 296,382 PA 308,567 312,509 Chester PA 57,558 52,889 415,056 479,211 Delaware 159,141 210,606 50,573 52,285 PA 414,234 270,311 Lancaster PA 553,154 316,660 Leoanon 234,717 600,035 PA 278,359 319,693 555,007 Lehigh 78,905 362,346 PA 90,853 Monroe 198,207 99,665 PA 33,803 227,536 255,304 109,829 Montgomery PA 39,567 273,582 Northamptcn 353,068 45,422 PA 516,682 69,409 Philadelphia PA 185,243 201,412 623,799 643,621 Schuylkill 2,071,605 214,368 PA 2,002,51/ 1,948,609 225,418 York 200,577 173,027 1,688,210 PA 202,737 160,089 238,336 272,603 160,630 312,963 1
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| Rev. 6, 09/82
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| O O O LGS EROL TABLE 2.1-16 BUREAU OF CENSUS POPULATIONS OF COUNTIES WITHIN 50 MILES OF THE SITE COUNTY S'iATE 1950 1900 1970 1980 New Castle DE 218,679 307,446 385,850 399,002 Cecil MD 33,356 48,40d 53,291 60,430 Burlingtcn NJ 135,910 224,499 323,132 362,542 Camden NJ 300,743 392,035 456,291 471,650 Gloucester NJ 91,72/ 134,640 172,681 159,917 Hunterdon NJ 42,736 54,107 69,718 87,361 Mercer NJ 229,781 266,392 303,968 307,863 Salem NJ 49,508 59,711 60,346 64,676 Somerset NJ 99,052 143,913 198,372 203,129 Warren NJ 54,374 63,220 73,879 84,429 Berks PA 255,740 275,414 296,382 312,509 Bucks PA 144,620 308,567 415,056 479,211 Carbon PA 57,558 52,889 50,573 52,285 Chester PA 159,141 210,606 270,311 316,660 Delaware PA 414,234 553,154 600,035 555,007 Lancaster PA 234,717 278,359 319,693 362,346 Leoanon PA 78,905 90,853 99,665 109,829 Lehigh PA 198,207 227,536 255,304 273,582 Monroe PA 33,803 39,567 45,422 69,409 Montgomery PA 353,068 516,682 623,799 6a3,621 Northamptcn PA 185,243 201,412 214,368 225,418 Philadelphia PA 2,071,605 2,002,51/ 1,948,609 1,688,210 Schuylkill PA 200,577 173,027 160,099 160,630 York PA 202,737 238,336 272,603 312,963 Rev. 6, 09/82
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| s METEOROLOGICAL SENSOR A' MANUFACTURERS PARAMETER COMPONENT MODEL NO.
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| Aerovane Wind Speed Impeller Gene- Bendix/120 rator and Recorder Bendix/141 Combination of Components Aerovane Wind Direc- Wind Vane and Bendix/120 tion Recorder Bendix/141 Combination of Components Satellite Wind Speed 3-cup Anemo- Bendix/241691 meter and Recorder Bendix/141 Combination of Components Satellite Wind Direc- Wind Vane and Bendix/241695 tion Recorder Bendix/141 Combination of Components Temperature Sensor L&N/8197 (Ambient)
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| Constant Current LSN/445372 Power Source Recorder Speedomax W Combination of Components (1)
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| Temperature Sensor L&N/8197 (Difference)
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| Constant Current LSN/445372 Power Source I
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| wrg
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| i LGS EROL TABLE 6.1-32 (Page 1 of 2) 4D SYSTEM SPECIFICATIONS AND ACCURACIES COMPONENT SYSTEMC*3 REGULATORY COMMENTS /
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| ACCURACY ACCURACY GUIDE 1.23 SPECIFICATIONS
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| : 1. 5 mph (0-10 mph) Starting Speed of 1.8 mph Stopping Speed of 0.7 mph i 1 mph (> 10 mph) 2 element recorder i.5 mph 1.5 mph accu-racy / starting speed 1 mph 128 2 element recorder 120 150 4 i. 5 mph (. 5-50 mph) Starting Speed <.5 mph 2 element recorder 1.5 mph 1.5 mph accu-racy / starting speed <1 mph
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| ) 128 2 element recorder 120 150 1.2*F 400F-1200F, 1 ma i.03%
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| i.060F 6 points, 10 seconds /
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| point i.360F Dual range recorder 1.4160F i. 50 C (i. 9 0F) 1.98F=i.50C l 10.10F Matched Pairs 10.070F Negligible 40-120*F 1 ma 1 0.03%
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| Rev. 6, 09/82 i
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| 1 l
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| -s METEOROLOGICALSENSORh 1
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| MANUFACTURER #j PA_RLJ8ETER COMPONENT MODEL NO.
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| Recorder L&N/Speedomas
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| (*) Iotal system accuracy from the square root of ths Regulatory Guide 1.23: 10.150C ( 0. 270F) i l
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| i s .-
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| LGS EROL TABLE 6.1-32 (Page 2 of 2) 1D SYSTEM SPECIFICATIONS AND ACCURACIES COMPONENT SYSTEM (1) REGULATORY COMMENTS /
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| ACCURACY ACCURACY GUIDE 1.23 SPECIFICATIONS W 10.0720F 6 Points l 10 Seconds / Point l sum of the squares = 10.120F l 1
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| l Rev. 6, 09/82
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| LGS EROL O
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| QUESTION E310.3 (Section 2.1) ,
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| Please revise the demographic data and projections using data from the 1980 Census. (EROL Section 2.1.)
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| RESPONSE ,
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| p
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| ~
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| Section 2.1 has been changed to provide data from the 1980 census. Projections based on the 1980 census information are developed by state and federal, agencies.
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| i O
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| O E310.3-1 Rev. 6, 09/82
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| 1 LGS EROL QUESTION E310.10 (Section 2.6)
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| Identify any impacts to cultural resources in the vicinity of the plant property and transmission line corridors which could potentially result from the operation and maintenance of the plant. Provide copies of any correspondence with the State Historic Preservation Officer on this subject. (EROL Section 2.6)
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| ===RESPONSE===
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| There will be little or no impact to cultural resources in the vicinity of the transmission lines resulting from the operation and maintenance of these lines. As noted in the response to Question 290.12, all lines will be built on existing transmission.
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| and railroad rights-of-way and will not require new access roads.
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| An archeological secvey was made by John Milner Associates, Inc.,
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| 309 North Matlack Street, West Chester, PA 19380. This report was submitted to the Pennsylvania PUC on August 23, 1982 in response to their request. A copy of PECo's letter of i notification to Pennsylvania Historical and Museum Commission and
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| \m.s/ a reply from Brenda Barrett, Director of Bureau for Historic Preservation, are included with the response to Question E310.10.
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| \J E310.10-1 Rev. 6, 09/82
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| PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 ,
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| PHILADELPHI A. PA.19101 l (215)8414000 a no.=t come .=o ec st c, os...'"'"' January 13, 1982 l
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| l l
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| Pennsylvania Historical and Museum Commission l Mrs. Frank Piasecki, Chairpe,rson Box 1026 Harrisburg, FA 17120 l
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| To: Administrative Officer in Charge This is to advise you that on December 9, 1981, a petition was filed by Philadelphia Electric Company before the Pennsylvania Public Utility Commission as of Docket No. P-810309, seeking a declaratory order determining that certain proposed transmission lines are excluded from siting review requirements, or, in the alternative, for a waiver of such requirements. This notice is being sent to you in accordance with and in compliance with instructions of the Commissicn.
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| The lines in question are as follows: I
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| : 1. A proposed 230 kV line from the proposed Limerick Generating Station in Limerick Township, Montgomery County, to Cromby Generating Station in East Pikeland Township, Chester County, on the westerly side of the Schuylkill River, along right-of-way owned in part by Philadelphia Electric Compnay and, in part, by Conrail (formerly, the Pennsylvania Railroad). This proposed line will be approximately 8.63 miles long.
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| : 2. A proposed 230 kV line from the proposed Limerick Generating Station in Limerick Township, Montgomery County, to Cromby Generating Station in East Pikeland Twonship, Chester County, on the easterly side of the Schuylkill River along right-of-way owned in part by the Philadelphia Electric Company and, in part, by Conrail (formerly, the Reading Corpany). This proposed line will be apprcximately 8 miles long.
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| : 3. A proposed 230 kV line from Cromby Generating Station in East Pikeland Township, Chester County, to the Plymouth Meeting Substation of Philadelphia Electric Company in Plymouth Township, Montgomery County, along right-of-way in part presently owned and used by Philadelphia Electric Company and, in part, owned by Conrail. The portion presently owned by Philadelphia Electric Company contains a 66 kV line on lattice type structures which will be replaced by the proposed line.
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| This proposed line will be approximately 13.5 miles long.
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| E310.10-2 Rev. 6, 09/82
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| Page 2 January 13, 1982
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| : 4. A proposed 230 kV line from Cromby Generating Station in East Pikeland Township, Chester County, to the North Wales C. Substation of Philadelphia Electric Company in Upper Gwynedd Township, Montgomery County, along right-of-way presantly owned by or subject to an easement in favor of Philadelphia Electric Company and containing along its entirety a 138 kV line. This proposed line will be approximately 16 miles long.
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| : 5. A proposed 500 kV line from the proposed Limerick Generating Station in Limerick Township, Montgomery County, to the Whitpain Substation of Philadelphia Electric Company in Whitpcin Township, Montgomery County, along right-of-way presently owned by Philadelphia Electric Company and containing several transmission lines along all or part of this right-of-way, including a 500 kV line. This proposed lir.e will be approximately 16.5 miles long.
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| A copy of the application is available without cost upon written request to:
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| Philadelphia Electric Company 2301 Market Street,N3-1 Philadelphia, PA 19101 Attention: George N. DeCowsky Chief Electrical Engineer O Very truly yours, 42f h George N. DeCowsky
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| :ss Chief Electrical Engineer Philadelphia Electric Company E310.10-3 Rev. 6, 09/82 1
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| 1 1
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| O January 22, 1982 Pennsylvania Historical and naseum Ccanaission Mrs. Frank Piasecki, Chairperson Box 1026 Harrisburg, PA 17120
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| ==Dear Mrs. Piasecki:==
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| Enclosed is a copy of Docket P-810309, a petition by the Philadelphia Electric Courpany to the PA PUC. This docket was inadvertently omitted in our earlier letter to you dated January 13, 1982.
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| Very truly yours, b2 A. t. xuone Philadelphia Electric Ccampany ALM:LCY Enclosure i
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| .i i
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| O E310.10-4 Rev. 6, 09/82
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| COMMONWEALTH OF' PENNSYLVANIA PENNSYLVANIA HISTORICAL AND MUSEUM COMMISSION wlLLIAM PENN MEMORIAL MUSEUM AND ARCNIVES SulLDING j SOX 1036 N ARRIS BURD. PENNSYLVANI A 1712D January 26, 1982 Mr. George N. DeCowsky Chief Electrical Engineer Philadelphia Electric Company 2301 Market Street P.O. Box 8699 Re: Proposed 230 kV line from proposed Philadelphia, PA 19101 Limerick Generating Station to Cromby Generating Station, Mer.igomery & Chester Counties, File No. ER F2 042M 0047
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| ==Dear Mr. DeCowsky:==
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| The above named application has been reviewed by the Bureau for Historic Preservation in accordance with Section 106 of the National Historic Preservation Act of 1966, Executive order 11593 and the regulations of the Advisory Council on Historic Preservation (36 CFR 800).
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| There is a high probability that archeological resources may be O(/ affected by this project. A survey or limited testing of the area should the undertaken to locate potentially significant archeological resources.
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| Guidelines and instructions for this phase are available from this office.
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| If you have any questions, please call Kurt Carr at (717) 783-5216.
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| i Sincerely,
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| ?renda Barrett Director Bureau for Historic Preservation (717) 783-8947 E310.10-5 Rev. 6, 09/82
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| | |
| LGS EROL QUESTION E320.1 Provide the following:
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| A production cost analysis which shows the difference in system production costs associated with the availability vs unavailability of the proposed nuclear addition. Note, the resulting cost differential should be limited solely to the variable or incremental costs associated with generating electricity from the proposed nuclear addition and the sources of replacement energy. If, in your analysis, other factors influence the cost differential', explain in detail.
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| : a. The analysis should provide results on an annual basis covering the period from initial operation of the first unit through five full years of operation of the last unit.
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| : b. Where more than one utility shares ownership in the i proposed nuclear addition or where the proposed facility is centrally dispatched as part of an interconnected ,
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| pool, the results of the analysis may be aggregated for i all participating systems.
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| : c. The analysis should assume electrical energy requirements grow at (1) the system's latest official l s forecasted growth rate, and (2) zero growth from the i latest actual annual energy requirement. l
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| : d. All underlying assumptions should be explicitly identified and explained.
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| : e. For each year (a'nd for each growth rate scenario) the following results should be clearly stated: (1) system l
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| production costs with the proposed nuclear addition available as scheduled; (2) system production costs without the proposed nuclear addition available; (3) the capacity factor assumed for the nuclear addition; (4) l the average fuel cost and variable O & M for the nuclear addition and the sources of replacement energy (by fuel l l
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| l type) - both expressed in mills per kWh; and (5) the proportion of replacement energy assumed to be provided l l by coal, oil, gas, etc. (The base year for all costs
| |
| : should be identified).
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| ! RESPONSE I
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| The requested information will be provided in the first quarter of 1983.
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| j E320.1-1 Rev. 6, 09/82 j
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| LGS EROL p
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| OUESTION E320.2 Provide 30 yr levelized fuel and O & M costs (fixed and l variable). Provide escalation, discount rates and all other variables assumed in calculating these costs.
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| l l
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| 1 RESPONSE i The requested information will be provided in the first quarter of 1983.
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| O i
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| l l
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| l l
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| l l
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| l i
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| ,i l
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| l
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| }
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| E320.2-1 Rev. 6, 09/82
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| LGS EROL QUESTION E451.5 (Section 2.3)
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| Much of the information presented in the discussion of severe weather phenomena is not up to date. For example, the frequency of hurricanes is based on a period of record ending in 1963 and the tornado statistics are based on a period of record that ended in 1976.
| |
| : a. Identify all hurricanes that have affected the site area since 1963 and update the number of storms (winds exceeding 74 mph) for those which have occurred since 1967.
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| : b. Identify tornadoes that have occurred in the vicinity of the site since 1976, and provide revised estimates of mean path area, annual frequency and strike probability of tornadoes resulting from this change in data base.
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| : c. Similarly, update the occurrence of thunderstorms, hail, ice storms and freezing rains, and peak winds.
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| ===RESPONSE===
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| () The requested information wil1 be provided in October 1982.
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| O E451.5-1 Rev. 6, 10/82
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| | |
| I LGS EROL QUESTION E451.6 (Section 2.3)
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| [
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| Section 2.3.1 of the ER provides a description of air quality in the vicinity of the site. Describe station sources of criteria air pollutants as defined by the Environmental Protection Agency, including estimated emissions, and compare these emissions to the j DeMinimus criteria established by the Environmental Protection
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| : Agency (EPA). If station emissions are above the DeMinimus j levels, provide a quantitative assessment of the impact of station emissions on local air quality using current EPA guidelines on atmospheric dispersion modeling.
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| .i
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| ===RESPONSE===
| |
| The requested information will be provided in the fourth quarter
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| ! of 1982, i,
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| i O
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| i i
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| l l
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| 1 i
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| i i
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| i i
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| i i
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| lO E451.6-1 Rev. 6, 10/82 i
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| r LGS EROL QUESTION E451.7 (Section 2.3.2)
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| Tables 2.3.2-26 through 2.3.2-31 present wind direction frequency distributions and Tables 2.3-2 through 2.3.2-25 present joint frequency distributions of wind direction and wind speed by atmospheric stability class. In both of these sets of distributions, c-lms are distributed by wind direction.
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| (1) Provide the~ definition of calm wind conditions, based on data reduction procedures, used to produce the frequency of calms in the tables.
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| (2) Provide a description of how the calm conditions were distributed according to the joint frequency of wind direction, wind speed and atmospheric stability class (vertical temperature difference method) in the tables and provide the actual frequencies of calm distributed by wind direction and atmospheric stability.
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| (3) Provide the basis for any departure from the definitions O of calm in Regulatory Guide 1.111. Regulatory Guide 1.111 states that calms should be defined as hourly average wind speeds below the starting speed of the vane and anemometer, whichever is higher, and that calms, in joint frequency distributions should be assigned, as a separate wind speed class, to wind directions in proportion to the directional distribution, within an atmospheric stability class, of the lowest noncalm wind speed class.
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| | |
| ===RESPONSE===
| |
| (1) Meteorological Evaluation Services, Inc. (MES) is the meteorological consultant for Philadelphia Electric.
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| MES chart reading procedures state that wind speed shall be read as an hourly average. In the case of calm winds, this would be an hourly average of zero mph.
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| (2) During the five-year period (1972-1976) of record, chart reading procedures for wind directions during calm hours changed. Calm hours during the period 1972-1975 were assigned a direction of 777, indicating the trace was O uninterpretable. However, examination of the charts from this period indicated that in most cases a direction could be obtained, and that despite the E451.7-1 Rev. 6, 09/82
| |
| | |
| LGS EROL limitations of such a procedure, it was preferable to an arbitrary assignment of direction for a given calm hour.
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| Accordingly, the chart reading procedures were changed, and beginning January 1, 1976, a direction was read for each calm hour.
| |
| When calm hours were entered into the joint frequency distributions, those calm hours with uninterpretable directions were distributed uniformly among the directional sectors. Those calm hours with valid directions were put into the sector indicated by that direction. All calm hours were arbitrarily classified as stable and were entered into Class F in the lapse rate distributions.
| |
| Tables E451.7-1 through E451.7-7 contain distributions of calm hours from Tower 1, Tower 2, and the Satellite Tower. In each case the distribution of calm hours which were included in the Class F, 0-3 mph category of each wind rose are compared with the distribution of calms according to the Regalatory Guide 1.111 technique.
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| Because calm hours were arbitrarily placed in Class F in O
| |
| the earlier wind roses, it was possible for a calm hour with a missing delta temperature to be entered into the distribution. For this reason, the total number of I calms in the Regulatory Guide 1.111 type distribution .
| |
| does not match the earlier totals. l (3) Regulatory Guide 1.111 states that calms should be defined as hourly average wind speeds' below the starting speed of the vane or anemometer. The starting threshold of the Bendix six-bladed Aerovane is 1.8 mph. However, it is a well-known fact that once a propeller is set in motion, it can operate at speeds below the starting threshold. Unpublished tests conducted by Brookhaven National Laboratory at the New York University wind tunnel during the 1950s showed that the stopping threshold of the six-bladed Aerovane was roughly 1 ft/sec (0.7 mph) lower than the starting threshold.
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| This indicates that hourly averages of 1 mph are possible.
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| l l
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| In addition, MES chart readers are trained to .
| |
| distinguish a calm wind trace from a 1 mph trace based on an analysis of both the speed and direction traces.
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| Figure E451.7-1 shows typical light wind speed traces, Rev. 6, 09/82 E451.7-2
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| LGS EROL
| |
| () and an example of the differentiation between calm and 1 mph wind speeds. The hours ending at 6 and 7 a.m. are calm wind traces, evidenced not only by a O mph wi.nd speed, but also by a " boxy" directional trace. However, during the hour ending at 8 a.m. and continuing into the following hour, both the speed and direction traces have become active, with speeds fluctuating between 0 and 2 mph. Both of these hours would be read as 1 mph.
| |
| The primary reason that calm hours were included in a 0-3 mph wind rose grouping rather than a separate class was to provide compatibility with MES dispersion models.
| |
| However, it should be noted that Regulatory Guide 1.111 does not specifically say that calms should be assigned "as a separate wind speed class."
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| O O
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| E451.7-3 Rev. 6, 09/82
| |
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| LGS EROL O TABLE E451.~7ZT LIMERICK GENERATING STATION WEATHER STATION No. 1 JOINT FREQUENCY DISTRIBUTION OF CALM HOURS 1972-197C 30-FT. LEVEL Regulatory Guide 1.111 Technique Directional Stability Class Sector Class F A B C D E F G NNE 247 0.04 0.19 0.41 13.76 42.01 52.40 32.45 NE 242 0.04 0.19 0.41 16.46 44.96 61.76 45.20 ENE 261 0.05 0.38 0.36 28.69 66.82 82.35 70.70
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| 'E 273 0.04 0.14 0.63 29.40 98.51 155.33 93.89 ESE 240 0.03 0.05 0.50 13.41 66.33 86.71 47.52 Os SE 240 0.01 0.19 0.54 13.76 74.93 77.36 41.73 SSE 244 0.05 0.38 1.04 21.29 71.00 61.76 16.23 S 254 0.10 0.47 1.49 27.52 88.93 79.23 15.07 SSW 241 0.10 0.28 1.13 21.05 62.64 40.55 20'.86 SW 265 0.08 0.33 0.99 12.35 57.24 49.91 17.39 WSW 235 0.09 0.66 1.40 14.94 55.27 47.41 32.45 W 242 0.12 0.76 0.99 18.58 82.79 94.82 83.45 WNW 249 0.06 0.38 0.81 17.76 88.19 146.60 125.18 NW 247 0.05 0.24 0.45 12.82 74.44 126.60 88.01 NNW 240 0.05 0.24 0.32 12.82 54.78 54.90 47.52 N 254 0.07 0.14 0.54 15.41 47.17 54.27 38.25 Total 3974 1 5 12 290 1076 1272 816 Source: Meteorological Evaluation Services, Inc.
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| O Rev. 6, 09/82
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| LGS EROL a TABLE E451.7-2 i
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| LIMERICK GENERATING STATION WEATHER STATION No. I j JOINT FREQUENCY DISTRIBUTION'OF CALM HOURS 1972-1976 175-FT. LEVEL Regulatory Guide 1.111 Technique Directional .
| |
| Stability Class Sector Class F A B C D E F G NNE 39 0.09 0.11 0.24 5.54 7.92 5.81 3.40 NE 40 0.09 0.27 0.15 3.69 8.44 6.37 1.59 ENE 38 0.09 0.16 0.12 7.46 11.19 4.87 2.72 E 43 0.04 0.11 0.15 8.31 17.56 10.11 5.21 l /'' ESE 44 0.09 0.00 0.24 4.85 11.02 5.62 2.04
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| : SE 43 0.13 0.16 0.15 3.77 7.75 9.18 8.61 SSE 42 0.17 0.27 0.36 6.62 11.02 10.49 4.08 S 48 0.09 0.32 0.74 10.62 17.73 13.11 8.38
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| * i i SSW 48 0.57 0.48 0.59 8.15 16.87 10.30 6.80 SW 42 0.30 0.32 0.44 4.54 13.26 9.74 7.93 WSW 41 0.17 0.37 0.41 6.23 11.36 11.24 6.57 )
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| l W 39 0.43 0.48 0.38 5.77 18.25 20.98 11.56 l WNW 43 0.13 0.16 0.47 5.46 18.08 21.73 17.90 ;
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| NW 40 0.09 0.32 0.18 4.08 17.S0 15.92 12.69 I j NNW 38 0.22 0.05 0.18 4.46 10.50 12.17 3.85 l l N 45 0.30 0.43 0.21 5.46 10.16 9.37 5.67 l l
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| 1 Total 673 3 4 5 95 209 177 109 l l
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| Source: Meteorological Evaluation Services, Inc.
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| O Rev. 6, 09/82
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| LGS EROL TABLE E451.7-3 LIMERICK GENERATING STATION WEATHER STATION No. 1 JOINT FREQUENCY DISTRIBUTION OF CALM HOURS 1972-1976
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| ~
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| 270-FT. LEVEL Regulatory Guide 1.111 Technique Directional Stability Class Sector Class F A B C D E F G NNE 34 0.16 0.07 0.22 4.06 6.93 7.40 2.89 NE 33 0.05 0.09 0.13 3.04 8.26 3.70 3.37 ENE 28 0.05 0.16 0.16 5.45 8.26 - 5.88 3.85 E 35 0.07 0.12 0.16 6.40 8.59 8.27 4.58 ESE 26 0.05 0.09 0.19 4.,44 6.44 3.70 1.45 01 SE 35 0.07 0.12 0.22 3.17 5.78 8.05 3.13 SSE 29 0.09 0.05 0.35 4.69 7.59 5.22 2.89 S 28 0.09 0.28 0.62 6.85 11.23 10.44 7.23 SSW 32 0.30 0.16 0.62 5.45 11.56 9.36 7.23 SW 30 0.23 0.14 0.43 4.69 8.75 10.66 6.75 WSW 31 0.16 0.09 0.43 3.93 8.26 11.53 8.19 W 32 0.26 0.21 0.38 4.25 12.55 14.36 5.78 WNW 32 0.12 0.09 0.32 4.56 12.22 12.62 8.91 NW 27 0.14 0.16 0.22 3.99 10.73 11.97 9.15 NNW 31 0.07 0.07 0.24 3.42- 6.11 5.66 6.02 N 27 0.09 0.09 0.32 3.61 7.76 7.18 4.58 Total 490 2 2 5 72 141 136 86 Source: Meteorological Evaluation Services, Inc.
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| O Rev. 6, 09/82
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| LGS EROL
| |
| ( TABLE E451.7-4 LIMERICK GENERATING STATION WEATHER STATION No. 2 JOINT FREQUENCY DISTRIBUTION OF CALM HOURS 4/72-3/73 30-PT. LEVEL Regulatory Guide 1.111 Technique Directional Stability Class Sector Class F A B C D E F G NNE 113 0.00 0.00 0.00 2.39 18.22 0.00 3.55 NE 113 0.00 0.00 0.00 0.30 5.20 3.56 0.00 ENE 113 0.00 0.00 0.00 2.17 19.70 3.56 0.00 E 113 0.00 0.00 0.00 5.09 29.37 1.78 0.00 ESE 113 0.00 0.00 0.00 3.66 45.73 19.58 10.64 Oxs SE 113 0.00 0.00 0.00 1.57 37.55 33.83 39.02 SSE 113 0.00 0.00 0.00 3.96 81.42 215.42 205.72 S 113 0.00 0.00 0.00 4.04 45.36 67.65 31.92 SSW 113 0.00 0.00 0.00 2.69 18.59 24.93 10.64 SW 113 0.00 0.00 0.00 0.37 5.58 3.56 0.00 WSW 113 0.00 0.00 0.00 1.94 12.27 8.90 3.55 W 113 0.00 0.00 0.00 3.89 27.51 30.27 10.64 WNW 113 0.00 0.00 0.00 3.22 45.73 51.63 14.19 NW 112 0.00 0.00 0.00 1.12 30.86 56.97 35.47 NNW 112 0.00 0.00 0.00 3.14 52.05 138.87 78.03 N 112 0.00 0.00 0.00 3.44 30.86 28.49 10.64 Total 1805 0 0 0 43 506 689 454 Source: Meteorological Evaluation Services, Inc.
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| O Rev. 6, 09/82
| |
| | |
| LGS EROL TABLE E451.7-5
| |
| (
| |
| LIMERICK GENERATING STATION WEATHER STATION No. 2 JOINT FREQUENCY DISTRIBUTION OF CALM HOURS 4/72-3/73 159-FT. LEVEL Regulatory Guide 1.111 Technique Directional Stability Class Sector Class F A B C D E F G NNE 45 0.00 0.00 0.00 0.82 8.08 7.77 6.01 NE 45 0.00 0.00 0.00 0.44 6.97 4.78 1.72 ENE 45 0.00 0.00 0.00 1.53 9.47 6.57 2.58 E 45 0.00 0.00 0.00 1.64 15.88 7.77 5.15 ESE 45 0.00 0.00 0.00 1.64 22.29 27.49 12.03 O, SE 45 0.00 0.00 0.00 1.26 16.72 20.92 13.74 SSE 45 0.00 0.00 0.00 1.64 16.16 25.10 27.49 S 45 0.00 0.00 0.00 1.31 13.93 17.93 12.03 SSW 45 0.00 0.00 0.00 1.26 9.20 11.95 12.89 SW 45 0.00 0.00 0.00 0.22 6.69 12.55 5.15
| |
| ! WSW 44 0.00 0.00 0.00 0.87 6.69 14.94 7.73 W 44 0.00 0.00 0.00 1.80 10.87 28.69 13.74 WNW 44 0.00 0.00 0.00 1.04 12.54 22.11 22.33 NW 44 0.00 0.00 0.00 0.49 13.65 21.52 28.35 NNW 44 0.00 0.00 0.00 1.31 13.37 20.92 16.32 N 44 0.00 0.00 0.00 1.75 14.49 8.97 7.73
| |
| ! Total 714 0 0 0 19 197 260 195 Source: Meteorological Evaluation Services, Inc.
| |
| l O
| |
| Rev. 6, 09/82
| |
| | |
| LGS EROL O TABLE E451.7-6 LIMERICK GENERATING STATION WEATHER STATION No. 2 JOINT FREQUENCY DISTRIBUTION OF CALM HOURS 4/72-3/73 304-PT. LEVEL Regulatory Guide 1.111 Technique Directional Stability Class Sector Class F A B C D E F ^G NNE 11 0.00 0.00 0.00 0.41 3.88 1.15 1.07 NE 11 0.00 0.00 0.00 0.23 2.26 1.73 0.53 ENE 11 0.00 0.00 0.00 0.52 2.31 5.17 1.33 E 11 0.00 0.00 0.00 0.52 4.68 1.15 1.07 ESE
| |
| ()
| |
| 11 0.00 0.00 0.00 0.52 7.11 2.60 0.80 SE 11 0.00 0.00 0.00 2.75 0.36 2.31 1.87 SSE 10 0.00 0.00 0.00 5.01 0.67 6.35 1.33 S 10 0.00 0.59 0.00 0.00 5.65 4.91 3,47 SSW 10 0.00 0.00 0.00 0.23 3.55 2.89 0.80 SW 10 0.00 0.00 0.00 0.10 1.78 2.60 1.33 WSW 10 0.00 0.00 0.00 1.78 0.39 2.02 2.67 {
| |
| W 10 0.00 0.00 0.00 0.62 3.55 4.62 3.73 I WNW 10 0.00 0.00 0.00 0.49 5.01 5.48 4.27 NW 10 0.00 0.00 0.13 3.88 0.00 10.10 4.00 l NNW 10 0.00 0.00 0.00 0.52 4.91 3.72 1.60 N 10 0.00 0.00 0.00 0.70 3.23 2.89 2.13 {
| |
| i Total 161 0 0 0 7 63 58 32 Source: Meteorological Evaluation Services, Inc.
| |
| O Rev. 6, 09/82
| |
| | |
| LGS EROL
| |
| () TABLE E451.7-7 LIMERICK GENERATING STATION SATELLITE TOWER JOINT FREQUENCY DISTRIBUTION OF CALM HOURS 1/75-12/76 32-FT. LEVEL Regulatory Guide 1.111 Technique Directional Stability Class Sector Class ,F A B C D E F G NNE 95 0.00 0.00 0.19 4.00 9.07 6.55 7.28 I NE 92 0.00 0.00 0.00 3.77 11.08 2.62 4.85 ENE 95 0.00 0.00 0.00 7.30 11.59 7.86 12.13 E 129 0.00 0.00 0.00 16.48 69.52 32.73 14.56 ESE 182 0.00 0.00 0.38 8.00 86.15 70.70 41.26 O SE SSE 183 149 0.00 0.00 0.00 0.00 0.19 0.95 8.47 10.59 97.74 86.15 75.94 57.94 19.42 9.71 S 93 0.00 0.91 2.08 11.06 44.33 57.61 4.85 SSW 78 0.00 0.91 1.32 5.53 13.10 14.14 0.00 SW 78 0.00 0.23 0.00 3.18 9.57 5.24 2.43 WSW 78 0.00 0.69 1.51 4.94 16.63 2.62 2.43 l W 80 0.00 1.60 2.46 6.71 39.80 2.62 7.28 l
| |
| WNW 116 0.00 1.14 1.51 6.94 53.91 15.71 19.42 NW 120 0.00 0.91 1.14 7.53 70.03 23.57 24.27 NNW 143 0.00 0.91 1.70 9.42 68.52 61.54 33.98 N 106 0.00 0.69 0.57 7.06 41.82 51.06 12.13 l
| |
| l
| |
| , Total 1817 0 8 14 121 729 508 216 l
| |
| (
| |
| Source: Meteorological Evaluation Services, Inc.
| |
| l O Rev. 6, 09/82 I
| |
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| s WIND DIRECTION WIND SPEED LIMERICK GENER ATING STATION UNITS 1 AND 2 ENVIRONMENTAL REPORT C
| |
| i N
| |
| x-- TYPICAL LIGHT WIND TRACES FIGURE E 451.7-1 R EV. 6, 09/82
| |
| | |
| LGS EROL QUESTION E451.8 (Section 2.3)
| |
| Five years (1972-1976) of data record have been submitted in joint frequency distribution form. Regulatory Guide 4.2 (Revision 2) states that the data set should include the most recent one year period for an operating license application.
| |
| Provide the joint frequency distributions of wind direction and wind speed by atmospheric stability class (as defined by vertical temperature difference) for the most recent annual cycle of meteorological data (1980 or later) for all levels of wind and vertical temperature difference measurements based on data from tower 1 and, if available, from the other towers. The data year selected should represent conditions which were unobstructed by temporary terrain modifications. Provide the frequency (hours and percent) of calms (as defined in question E451.7 from Regulatory Guide 1.111) by stability class and do not include calms in the joint frequency distribution tables by wind direction.
| |
| | |
| ===RESPONSE===
| |
| Both items 1 and 2 have been transmitted to the NRC by letter from J. S. Kemper to A. Schwencer dated September 1, 1982. One
| |
| (' copy of the magnetic tape and five copies of the joint frequency distributions were included with the letter. As required by Regulatory Guide 1.70, section 2.3.3, this material represents the most recent one-year period of record currently available.
| |
| l l'
| |
| E451.8-1 Rev. 6, 10/82
| |
| __.m- -- ~ - - -
| |
| | |
| LGS EROL i
| |
| OUESTION E451.9 (Section 6.1.3)
| |
| I i
| |
| Table 6.1-32 provides meteorological system specifications and l accuracies. This table does not include the accuracies for temperature difference measurements. Provide the component and system accuracies for these measurements.
| |
| | |
| ===RESPONSE===
| |
| l Table 6.1-32 has been changed to provided the requested information.
| |
| l l
| |
| O l
| |
| i l
| |
| l O E451.9-1 Rev. 6, 10/82 -
| |
| )
| |
| ! l
| |
| | |
| LGS EROL QUESTION E451.10 In Section 5.2B 2.2 of Appendix 5.2B, it is stated that annual average concentration of noble gases are decayed using the average wind speed in each section. Provide the basis for using simple arithmetic averages of wind speed rather than geometric means, since the decay process is an exponential function.
| |
| | |
| ===RESPONSE===
| |
| A comparison was made between the arithmetic mean wind speed by sector and the geometric mean wind speed by sector for meteorological data collected between 1972 and 1976 at Limerick Tower 1, El. 175 ft. The results indicate that the geometric mean wind speeds in each case were slightly lower, by approximately 1 to 2 mph, than the arithmetic mean wind speeds.
| |
| Thus, by using arithmetic mean wind speeds to account for radionuclide decay during transit to a receptor location, our results were slightly more conservative. Although it may be more technically appropriate to use geometric means, use of arithmetic means resulted in doses that were insignificantly higher.
| |
| O i
| |
| i l
| |
| l O
| |
| V E451.10-1 Rev. 6, 10/82
| |
| | |
| LGS EROL I)
| |
| V OUESTION E451.11 Since the long term diffusion estimates are based on wind measured at the 175-foot level and atmospheric stability is based on the Brookhaven Turbulence Class System and the Smith-Singer vertical dispersion coefficients, (1) provide the basis for utilization of these parameters, because they differ from those primarily recommended in Regulatory Guide 1.111, and (2) provide a comparison of these diffusion estimates with diffusion estimates based on wind measured at the 30-foot level and vertical temperature difference as the stability indicator with vertical dispersion curves as indicated in Regulatory Guide 1.111.
| |
| | |
| ===RESPONSE===
| |
| (1) The long-term diffusion estimates for the Limerick Plant were
| |
| (/) based upon the Smith-Singer vertical dispersion parameters and the Brookhaven Turbulence Class system because we believe that this system is more appropriate for the release and terrain characteristics of the Limerick site than the Regulatory Guide 1.111 parameters.
| |
| A. Vertical Dispersion Curves Regulatory Guide 1.111 specifies that the Pasquill-Gifford or P-G dispersion coefficients be used for long-
| |
| -term dispersion estimates. However, there are several sound reasons for using the Brookhaven (Smith-Singer) coefficients instead:
| |
| ! 1. Surface Roughness The P-G dispersion' coefficients were developed primarily from the Prairie Grass diffusion experiments at O'Neill, Nebraska. The Prairie Grass data were collected in extremely flat, smooth terrain with a roughness length, z o, of 3 cm. In contrast, the Brookhaven coefficients were developed in an area of scrub pines and oaks, with O a roughness length of 1 meter. The Limerick E451.11-1 Rev. 6, 09/82
| |
| | |
| LGS EROL region, characterized by a combination of buildings, open fields and trees, is much more lh similar to Brookhaven than to O'Neill, Nebraska.
| |
| : 2. Release Elevation The Prairie Grass experiments consisted of a series of ground level SO, releases, with concentrations measured at downwind distances of up to 800 meters.
| |
| Extrapolation of these curves to distances beyond one kilometer is based on limited observations.
| |
| The Brookhaven dispersion coefficients, on the other hand, are based on both elevated and low level releases. The standard curves published by Smith (Ref. E451.11-1) in the ASME Guide were .
| |
| derived from plumes released at 108 meters and tracked for more than 50 km. In addition, a second set of unpublished dispersion coefficients were developed from low level releases, as shown in FSAR Section 2.3.5.3.4.
| |
| The entrainment coefficients from Regulatory Guide 1.111 specify that the Limerick plume will be elevated 84 percent of the time. In these cases, the standard Brookhaven coefficients were used.
| |
| For the remaining 16 percent of the time, the low level coefficients were used.
| |
| The 1977 AMS workshop on stability classification schemes and sigma curves (Ref 5.2-8) clearly supported the use of the Brookhaven curves in preference to the P-G curves where elevated sources in rolling terrain are involved:
| |
| "For elevated sources, the "Brookhaven" curves (M.E. Smith, 1968)'are an appropriate choice when 6z is less than the effective source height. These curves are based on average concentration measurements from a passive source at an elevation of 108 m. They differ from the Pasquill-Gifford and Turner curves both because the source was elevated and because the measurement site was surrounded by a much rougher surface, mostly forests, ll Rev. 6, 09/82 E451.11-2 i
| |
| | |
| LGS EROL C)
| |
| (, from which 2a equals approximately 1 m.,
| |
| : 3. Averacina Time The Prairi,e Grass project consisted of short duration field experiments, with the P-G horizontal coefficient representing 3 minute averages, and the vertical coefficients 10 minute averages. In contrast, all of the Brookhaven data from which the dispersion curves were derived were hourly averages.
| |
| : 4. Validation l
| |
| While model validation is a somewhat nebulous and controversial area, attempts have been made to verify t' e appropriateness of the more commonly used dispersion coefficients with field data. A recent study by Weil (Ref. E451.11-2) at the coal-
| |
| - fired Dickerson power plant in Maryland found that when using the Gaussian plume model with the C-]s Brookhaven dispersion coefficients, predicted concentrations were within a factor of two during 73 percent of the cases analyzed. Conversely, the P-G coefficients at times resulted in orders of magnitude disagreement between predicted and measured concentrations.
| |
| The Dickerson Plant releases a buoyant plume from stacks approximately 400-feet tall, so the analogy with Limerick is not clearcut. However, the results indicate that the Brookhaven curves are preferable.
| |
| B. Stability Class Determination Because the Brookhaven dispersion coefficients are used in the Limerick analysis, it is reasonable and consistent to use the Brookhaven stability classification system as well. The two were developed together and are part of a cohesive system.
| |
| O E451.11-3 Rev. 6, 09/82 ,
| |
| -,_.,y , . . _ - . ,
| |
| w-.-
| |
| -- - - - c a--. --,- ---
| |
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| |
| | |
| LGS EROL Furthermore, although the classification system based on delta temperature is recommended by NRC, the AT method lh has been criticized by the scientific community. It seems clear that the system produces an inordinately high percentage of neutral hours, and several recent workshops and publications have recommended that the system be changed. Several of these suggestions are worth reiterating:
| |
| : 1. Weber et al. (Ref E451.11-3) conducted a regression analysis comparing several stability classification schemes with vertical dispersion data from the Prairie Grass, Green Glow, and National Reactor Testing Station experiments. The results from this study showed that during unstable conditions, delta temperature did not correlate at all with the measured concentrations. In stable conditions, delta temperature compared favorably with the other stability classification systems, but the authors cautioned that a strict correlation should only be 'ound for delta temperature measured in the surface layer (<10 meters) and that there was no reaaon to expect correlation at higher levels.
| |
| : 2. AMS Workshop - At the 1977 American Meteorological O
| |
| Society workshop on stability classification schemes and sigma curves, there were lengthy discussions of the various methods available to classify stability. The workshop recommended that the standard deviation of the horizontal wind direction fluctuations, sigma theta, be used to estimate horizontal diffusion rates, and that dimensionless ratios of temperature lapse rate and wind speed be used to specify vertical turbulence.
| |
| The workshop also said that there is little physical justification for the current practice of estimating vertical diffusion based on temperature lapse rate data alone.
| |
| It seems contrhdictory that the NRC has referenced the report from this workshop in the proposed Revision 1 of Regulatory Guide 1.23, yet ignored some of these fundamental recommendations.
| |
| : 3. Gifford-(Ref E451.11-4), in a memo to the Advisory Committee on Reactor Safeguards (ACRS) regarding the proposed Revision 1 of Regulatory Guide 1.23, Rev. 6, 09/82 E451.11-4
| |
| | |
| 1 N
| |
| LGS EROL
| |
| () reiterates his objection to the use of delta temperature. Gifford states:
| |
| "My main objection (a long-standing one) to the draft is that it continues to recommend the so called AT-method (or as method as the primary means of determining ay and az (p 6, lines 12 & 13). The problems involved, and limitations of this methodology are clearly set
| |
| *out in the American Meteorological Society workshop report on the subject, Ref. 1 in the proposed revision. This reference (Bulletin AMS, 58, p 1306) states "There is little physical justification for the currently widespread practice of approximating S'" (the stability factor) "by - As alone....in stable conditions the effects of topography....may equally invalidate
| |
| - As and S' as determinants of az".
| |
| The reference goes on to stress O. problems of determining az in other types of conditions (i.e. unstable, daytime) and stresses the poor state of our observational knowledge at present. Finally, problems of the as method (p 1309) are discussed in detail, pointing out the desirability of a more physically based indicator such as the bulk Richardson number S'; and also the problem of measuring as/AZ in a meaningfully shallow layer with present requirements for siting the upper temperature sensor (60 m) is pointed out."
| |
| Clearly, the AT method is not entirely palatable to the scientific community, and there is little doubt that the Brookhaven system is at least as good an indicator of stability. Particularly for the Limerick site and source elevations, the Brookhaven system offers some distinct advantages. The Brookhaven classes are based on the "gustiness" or short-term fluctuations of wind direction trace
| |
| (''N averaged over'an hour and are a physical s ,)
| |
| s representation of the horizontal turbulence of the E451.11-5 Rev. 6, 09/82
| |
| | |
| LGS EROL wind flow. In addition, the Brookhaven system determines the atmospheric stability in the region of the actual effluent release, which was another of the AMS Workshop recommendations.
| |
| (2) Regulatory Guide 1.111 states that wind speeds representative of the vent release elevation should be used for long-term dispersion estimates. Accordingly, wind data from the 175-ft level of Tower 1 were used for the Limerick annual X/0 calculations. This instrument is within 9 ft MSL of the Limerick vent elevation. For the elevation portion of the mixed mode release, wind speeds were not corrected for source elevation. However, for the low level portion of the mixed mode release, speeds were adjusted by standard power law techniques to the 10 meter level.
| |
| Figure E451.11-1 shows a comparison of the annual X/0 values from EROL Table 5.2-4, which were computed using brookhaven dispersion coefficients. These values represented by the dashed line are from a similar calculation with AT stability and the P-G dispersion coefficients of Regulatory Guide 1.111. The comparison shows that the Brookhaven coefficients were more sensitive to terrain elevation because the lower portion of the mixed mode release is set at 10 meters in the BNL model, as compared to a ground level release in the Regulatory Guide 1.111 model. Otherwise, the values are quite similar.
| |
| References E451.11-1 Smith, M.E., Ed.: Recommended Guide for the l Prediction of the Dispersion of Airborne Effluents, ASME, 1968.
| |
| l l E451.11-2 Weil, J.C. and A.F. Jepsen: Evaluation of the l
| |
| Gaussian Plume Model at the Dickerson Power Plant, Atmos. Environ., Vol. 11, pp. 901-910, 1977.
| |
| l
| |
| [ E451.11-3 Weber, A.H., et al.: Turbulence Classification Schemes for Stable and Unstable Conditions, in preprints of the First Joint Conference on Applications of Air Pollution Meteorology, American Meteorological Society, November 1977, pp. 96-102.
| |
| O l
| |
| l Rev. 6, 09/82 E451.11-6
| |
| | |
| I l,
| |
| I LGS EROL l
| |
| i
| |
| : E451.11-4 Gifford, F. A.: Memo to Advisory Committee on Reactor Safeguards Regarding the Proposed Revision 1 of Regulatory Guide 1.23, May 26, 1980.
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| a 3 s 7 e e so 3 3 a e e ? s e at 2 a a e a y aS a 3 3 2 3 4 I 10 10 10 10 l Distance (meters) l LIMERICK GENER ATING STATION UNITS 1 AND 2 ENVIRONMENTAL REPORT s
| |
| COMPARISON OF ANNUAL
| |
| )
| |
| l ( ,/ X/O VALUES USING 175' LEVEL WITH ESE SECTION WIND FIGURE E451.111 REV. 6,09/82
| |
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