Text

Responses to Interrogatories.Certificate of Svc Encl
	ML20063B291
Person / Time
Site:	Limerick
Issue date:	08/20/1982
From:	Boyer V; PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	; DEL-AWARE UNLIMITED, INC.
Shared Package
ML20063B285	List: ML20063B282; ML20063B291;
References
	NUDOCS 8208250326
	Download: ML20063B291 (32)
	v • d • e

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n-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of

)

Philadelphia Electric Company

)

Docket Nos. 50-352

)

50-353 (Limerick Generating Station,

)

Units 1 and 2)

)

i APPLICANT'S RESPONSES TO " INTERROGATORIES OF DEL-AWARE UNLIMITED, INC.

ADDRESSED TO APPLICANT PHILADELPHIA ELECTRIC COMPANY" August 20, 1982 i

i I

B208250326 820820 i

PDR ADOCK 05000352 l

9 PDR

Interrogatory 1:

With respect to the impact of the intake i

structure proposed to be located in the Delaware River near Point Pleasant on the flow and related characteristics of the river, please provide the following information:

a.

Please state whether PECO plans to utili:e water from the Delaware River when the flow therein is less than 3,000

("CFS")

and,-

if so, the legal basis or bases upon which PECO will or may do so.

Please include in this answer PECO's intentions, plans or expectations regarding its ability to utilize all or part of the water allocated to the Neshaminy Water Resources Authority ("NWPA") by the Delaware River Basin Commission ("DRBC").

Answer:

Philadelphia Electric Company ("PECO") may use water from rhe Delaware River only in accordance with the terms of the Delaware River Basin Commission ("DRBC") order authorizing such use.

The DRBC order provides:

The Delaware River, as augmented for the purpose of water supply by upstream reservoirs may be used via the Point Pleasant pumping facilities, a pipeline, the East. Branch of Perkiomen Creek and Perkiomen-Creek with the limitations that such use will not reduce the flow as measured at the Trenton gage below 3000 cfs (1940 mgd), and that such use will not be permitted when the flow as measured at the Trenton gage is less than 3000 cfs (1940 mgd), provided that annually after pumping from the Delaware River has commenced, the rate of pumping will be maintained at not less than 27 cfs (17.5 mgd) throughout the normal low flow season for the protection of aquatic life in Perkiomen Creek and its East Branch regardless of ultimate downstream consumptive use requirements.

During periods of high natural flow in East Branch Perkiomen

Creek, pumping from Point Pleasant shall be kept at a

~1evel so as not to aggravate high water levels.

This constraint-would prohibit the use of the Delaware River water when such use would < reduce the flow in the river at the ' Trenton gage below 3000

cfs, which is required to meet the salinity 1

r_

j-i objective in the estuary of 250 mg/l at mile 92.47 (mouth of the schuvlkill l

River).

DRSC Docket D-6 9-210-CP " at 6 i

(March 29, 1973),

i The imposition of this condition was reaffirmed in the DRSC order of~ February 13, 1981 in this proceeding.

With regard to icw flow conditions, DRSC has stated that if it determines:

that the storage will not be adequate for all projected needs of the basin, the applicant will build or cause l

to be built, at its own expense, at a I

location approved by the Cc= mission, for service in

1980, a

reservoir of sufficient storage capacity to assure the wac'er supply needed for consumptive use by the Limerick

plant, during periods when such use would reduce the flow in the Delaware River at the Trenton gage below 3000 cfs.

Storage and -release of water in such facility will be under the Cc= mission's regulation, at the expense of the applicant.

DRSC Docket D-69-210-CP (March 29, 1973) at 7.

t/

/

Interrogatory 1(b):

Please state the maximum anticipated race of pump:.ng via the intake structure for the maximum minute and hour, Answer:

The total maximum anticipated rate of pumping is 95 - mgd, which converts to a rate of 3.96 mg per hour, O.066 mg per minute or 146 cfs, for the combined needs of PECO and NWRA.

1 A

pp 1

s 3

/

Interrogatory 1(c):

Please state the maximum capacity

-of the pumps proposed to be located at Point Pleasant for g

I the maximum minute and hour.

Answer:

The rated capacity of each of the four pumps to be located at Point Pleasant is approximately 16,500 gpm (gallons per minute) or 990,000 gallons per hour.

The total four pump capacity is therefore 3.96 mg per hour or 0.066 mg per minute.

Each turbine pump's rated capacity will be 21 mgd (See NWRA Environmental Report, 1979, Appendix A, p.

5).

,;..r Withk-head conditions suitable for maximum

output, the I

1 maximum output would be 4.0 mg per hour.

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veloc:.cies

~

^

1(d):

Please state the anticicated Interrocatorv in one

foot, five

fcot, and ten ' foot circumferential distances, at each point (or representative points) along such circumferences surrounding the proposed intake screens.

Please indicate the anticipated velocity of the water at such points, noting the location of such points, when the flow of the Delaware River at Trenton is 2,000 CFS.

Answer:

River velocity tests were conducted at flows of 3,000 cfs and 4,500 cfs.

Based on the results of these tests the screens were located about 245 feet from the normal water level shoreline at a point where the stream velocity passing the screens will be above 1 fps (foot per second).

No tests were conducted to determine velocities at a

river flow of 2,000 cfs.

The maximum through-screen velocity will be 0.5 fps.

Screen design is such that nearly uniform velocities are experienced over the entire screen surface.

The icw screen velocity assures a rapid decrease in velocities with distance from the screen.

At a distance of one foot from the screen calculations indicate an inward flow component of approximately 0.071

fps, at five feet 0.0112 fps and at ten feet 0.0037 fps.

The velocity continues to drop as the distance approaches 10 feet.

e m_._-

Interrogatory 1(e): Please state the relationship between the flow of One Delaware River at Point Pleasant and the flow at Trenton, as determined, and state the basis for such determination, at flows of 2,000 CFS, 2,500 CFS, 3,000

.CFS, and 4,000 CFS,.respectively, at Trenton.

Please include in this answer the anticipated velocities at the water surface, at three feet below the water surface, at six feet below the water surface, at nine feet below the water surface, and at twelve feet below the water surface (if the water will be that deep at the given flow) for each flow described in the previous sentence.

Please provide in detail the basis for the determination.

Answer:

The flow relationship between the Point Pleasant site and the Trenton gage is the ratio of the drainage areas at each point adjusted for the change in river storage between the points.

The flow at Point Pleasant is about 97%

of the Trenton flow under normal conditions.

This relationship applies to all the above flows.

With respect to the requested velocities, Applicant has data regarding only a flow of 3,000 cis.

This information is contained in the attached graph to the letter sent January 22, 1982 to the U.S.

Corps of Engineers from E.

H.

Bourquard.

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Interrogatory 1(f) : Please state the anticipated distribution of :ne water sources between Tchickon Creek and the Delaware River through the intake at various flows in velocities, including velocities of 2,000, 2,500, 3,000, 3,200, 3,500, 4,000, 5,000, 6,000, 7,000, 8,000, 9,000, and 10,000. CFS in the Delaware River in combination with those i

of 200, 500, 750, 1,000, 1,500, 2,000, 2,500 and 3,000 CFS i

from the Tohickon Creek.

Answer:

PECO does not have information responsive to this interrogatory.

l l

Interrogatory 1(h): Please state whether PECO has given any consiceration to the utilization of any hydrolic and/or hydrologic computer models or other means to simulate the operation of the intake, and if so, what determination was made'and the basis therefor.

If such a simulation was made or attempted, or is planned to be made or attempted, clease describe the circumstances in detail, and indicate the' dates of such. tests,, the availability of such data, the identity or the Individual and organization making such tests or determinations, and their relationship to the applicant.

I Answer:

No.

Interrogatory 2:

With respect to impacts of the proposed relocation of the intake facility.on the American

Shad, a.

Please describe in detail any studies relating to the impact of the proposed facility en and currents within the eddy and the anticipated affects of such impacts on the American Shad.

Answer:

The intake structure is not in the eddy.

See:

(1)

" Biological Evaluation of the Proposed Water Intake in the Delaware River at Point

Pleasant, Pennsylvania," (November 1980), Paul Harmon.

(2)

"DRBC Final Environmental Assessment for the Neshaminy Water Supply System,"

(August, 1980),

Section IV-E(3).

(3)

E.

H.

Sourquard January 22, 1982 letter to COE provides a velocity study (currents).

)

i

Interrogatory 2(b): Please identify and describe the contents and conclusions of any studies respecting the differences in impact of the location of the intake on the stream bank (as originally proposed),

its location as described in PECO's application to the Corps of Engineers, and its location as presently proposed (January, 1982) on the

spawning, larvae, nursery and feeding area of the American Shad.

Interrogatory 2(c):

Please provide in detail all measurements, studies and reports, indicate the methodology and the basis used, and identify all documents relating to such consideration.

Answer:

PECO has no application before the COE.

(1)

January 22, 1982 letter from E.

H.

Sourquard to the Corps of Engineers.

(2)

" Biological Evaluation of the Proposed Water Intake in the Delaware River at Point

Pleasant, Pennsylvania,"

prepared for NWRA by P.

Harmon, November 1980.

Interrogatory 2(d):

Please provide any information relating to and descr:.ce any documents which relate to or discuss findings of shorrnosed sturgeon in the intake area and/or in the Delaware River at or above New

Hope, Pennsylvania.

Answer:

(1)

" Assessment of the Impacts of the Proposed Point Pleasant Pumping Station and Intake on the Shortnose

Sturgeon, Acicenser Brevirostrum,"

prepared by Harold M.

Brundage, III of IA, January 1982.

(2)

Letter of October 29, 1981 from Paul Harmon, RMC to Cary H.

Rush, PECO; (3)

Letter of August 20, 1981 from Paul Harmon to Robert Flowers, NWRA.

(4)

Letter of June 29, 1981 to Robert Flowers, NWRA from Paul Harmon; (5)

Letter of June 10, 1982 from Harold M. Brundage to U.S. Marine Fisheries Service; (6)

Letter and biological opinion of National Marine Fisheries Service, July 19, 1982, 4

Interrogatory 7:

With respecu to the Bradshaw Reservoir:

l i

a.

Please identify and describe all engineering and other studies quantifying or estimating the extent of leakage from the 3radshaw Reservoir into the groundwater, and provide any and.all infor: nation on which such estimates and conclusions were based.

Answer:

(1)

" Supplemental Data and Info.mation Accompanying Permit Application for Bradshaw Reservoir, November 1981, prepared by E.

H. Sourquard for PECO and submitted to DRBC.

(2)

" Project Manual for Bradshaw Reservoir and Pumping Station," by E. H.

Sourquard, November 1981.

I C

-Interrogatory (b) :

Please identify and describe all

' studies of stab:.lity of the reservoir.-

Answer:

" Slope Stability. Evaluation for Bradshaw Reservoir," June 1982, by E.-H. Bourquard.

q-.

Interrocatorv 13:

Please identify all documents constituting, relating to, or considering the operating plan for the Point Pleasant intake, in and of itself and as related to the Bradshaw Reservoir and/L. proposed releases to the Perkiomen Creek.

Please identify any final or presently final documencs relating to or constituting such operating plan.

Answer:

(1)

DRBC Docket D-69-210 CP, November 7, 1975 (Final);

(2)

DRBC Docket D-65-76 CP (8), (February 18, 1981);

(3)

DRBC Docket D-79-52 CP, February 18, 1981.

(4)

Point Pleasant, Pennsylvania Pumping Facilities Feasibility Study Prepared by E.H.

Bourquard Associates, Inc.

March, 1970 (5)

Final Environmental Impact Statement Point Pleasant Diversion Plan Bucks and Montgomery Counties, PA Prepared by Delaware River Basin Commission February, 1973 (6)

Cooling Water Supply for Limerick Nuclear Power Station Prepared by Tippett-Abbett-McCarthy-Stratton May, 1973 (7)

Environmental Report on Neshaminy Water Supply System Neshaminy Water Resources Authority, Bucks County Prepared by Neshaminy Water Resources Authority February, 1979 (8)

Environmental Report - Bradshaw Reservoir Transmission Main, East Branch Perkiomen and Perkiomen Creeks Prepared by Philadelphia Electric Company July, 1979

(9)

Agreement Between the Neshaminy Water Resources Authority and Philadelphia Electric Company for

.the Construction and Operation of Water Supply Facilities February 12, 1980 (10) Environmental Assessment for the Proposed North Branch Water Treatment Plant Sponsored by the Neshaminy Water Resources Authority and a Review of Related Components Sponsored by the Neshaminy Water Resources Authority and the Philadelphia Electric Company Prepared by Delaware River Basin Commission February 15, 1980 (11) Final Environmental Assessment for the Neshaminy Water Supply System Prepared by Delaware River Basin Commission August, 1980 (12) Point Pleasant Pumping Facilities, Design Report-No.

4, Proposed Criteria and Methods for Control of Point Pleasant Pumping Facilities Prepared by E.H. Bourquard Associates, Inc.

January, 1974 (13) Study of Monitoring, Control and Operation of the Makeup Water Supply System for the Limerick Generating Station, Units 1 and 2' Prepared by Bechtel Pcwer Corporation May, 1974 (14) Intraaffice Memorandum of April 19, 1982, Limerick Generating Station, Units 1 and 2: Makeup Water System Control, D.

L.

Morad, PECO

Interrogatory 14:

With respect to the relationship between

?ECO, Ichthyological Associates, Inc.,

E.

H.

Sourquard Associates, Inc.,

NWRA, Harmon, as well as any organizations related to or affiliated with any of them,

-please state the following:

a.

Whether PECO ever had an cwnership interest in Ichthyological Associates, Harmon or any related entity or predecessors, or successors, and the dates of such interests, and whether Ichthyological Associates was employed as a researcher by PECO during any of such times.

Please respond specifically to each section of the foregoing question.

Answer:

PECO has never had an ownership interest in Ichthyological Associates

("IA").

IA was engaged by PECO under contract to perform biological research as required in i

connection with several generating stations.

In December, 1977, the contract was terminated with IA and the personnel operating at Limerick and Muddy Run Station became part of the Radiation Management Corporation ("RMC").

1 RMC is an organization established by a

group of electric utilities to perform certain technical services in connection with nuclear generating stations.

PECO was one of the founders and holds an ownership interest therein.

Paul Harmon was an employee of IA and is currently the general manager of environmental services for RMC.

He was never an employee of PECO.

RMC and Mr. Harmon perform much work for PECO but they also have contracts.with others for research and testing. services.

IA has been employed by the Public Service Electric and Gas Company for consultation on the Salem. Generating

Station, of which PECO has an approximately 42% ownership share.

I

~

g

Interrogatorv 14 (b) :

The extent to which PECO had access to data and analyses, reports, or other information prepared by E.

H.

Bourquard, and/or technical consultants for the NWRA.

Please state whether and to what extent PECO participated in joint scoping and study meetings.

Identify the personnel who attended such meetings and the dates of their attendance.

Please stace the extent to which the data described above in this subparagraph (b) is or has been made available to PECO and the terms on which it is or has been made so available, and describe any relationships, financial or otherwise, pursuant to which there has been mutual availability of data between

NWRA, its consultants (including but not limited to E.

H.

Bourquard, Dresnack and Richman), and PECO.

Answer:

PECO has engaged E.

H.

Bourquard's services as a

consultant on various Limerick matters since 1970.

Bourquard has atso performed consulting services for NWRA.

Initially on an informal basis and later, following the execution of an Agreement between the NWRA and PECO for water supply

services, in accordance with documented procedures, there has been a

steady exchange of

data, analysis, reports and other information regarding Point Pleasant.

PECO has frequently attended major design

meetings, reviewed drawings, studied consulting engineers reports, analyzed schedules and considered project costs.

PECO has offered comments, made suggestions and supplied some information regarding design work.

Several PECO engineers have been involved throughout the past years, but most of them have been involved in a limited area.

During i

the last two years as the design has neared completion, V.S.

Boyer, J.L.

Allen, W.H.

Dickinson and D.T.

Morad have had the most frequent and broad contact with the NWRA and E.

H.

?

Bourquard.

The terms-authorizing the transfer of information are contained in the aforementioned Agreement.

A list of specific meetings between PECO personnel and NWRA and its consultanrs follows:

July 29, 1980 Meeting between EC, E.

H.

Bourquard and W.

H.

Dickinson to discuss the evaluation of intake screens.

January 24, 1981 E.

H. Bourquard, Dave Marano, Dave Morad and W.

H.

Dickinson met to review design of the Bradshaw Reservoir.

January 24, 1981 E. H. Sourquard, Hershel Richman and W.

H.

Dickinson met with Corps of Engineers regarding permits.

April 21, 1981 E.

H.

Sourquard, Dave Morad and W.

H.

Dickinson met regarding the Bradshaw layout.

June 17, 1981 E.

H. Bourquard, Dave Morad and some electrical engineers met to discuss electrical features of Bradshaw.

September 17, 1981 The NWRA, E.

H.

Bourquard, Dave Morad, W.

H.

Dickinson and some electrical engineers met to review the overall status of design for the water supply project.

December 16, 1981 NWRA Ichthyological Associates, E.

H.

Bourquard, and W.

H.

Dickinson met with the Corps of Engineers to review the permits.

February 23, 1982 NWRA, E. H.

Bourquard, V.

S.

Boyer, J.

L.

Allen, E.

J.

Bradley and W.

H.

Dickinson met regarding permits, overall design and scheduling.

t

March 10, 1982 E.

H.

Bourquard, Robler, Dave Morad and W.

H.

Dickinson met regarding the

heating, ventilating and air conditioning.

Acril 20, 1982 Dave Morad and electrical engineers met

. with Moxey regarding motor starting.

May 12, 1982

NWRA, V.

S.

Boyer, and W.

H.

Dickinson met regarding design and schedule.

June 15, 1982 Hershel Richman, Ann Newell and Joe Schuldenrein (an archeologist) and W.

H.

Dickinson met regarding the archeological search of the property.

I l

Interrocatorv 15:

Please state the name of each and every person who, on behalf of PECO has contacted or made contact with any legislative or executive official of the federal government in the last two years for the purpose of discussing or otherwise presenting information concerning approval of the Point Pleasant diversion (e.c.

contacts relating to permits from the Corps of Engl.neers, DRBC ap, proval, and any other contacts relating to the withdrawal or water from the Delaware River and facilities related thereto).

Please include the dates of such contacts, the names of the persons and agencies contacted, and the substance of each such contact.

Please also state the results of any such contacts, and identify any dccuments reporting on such results including any reports stating that an official has contacted or been contacted by another official, and the results and commitments arising from such contacts.

Answer:

October 20, 1981 V.S.

Boyer met with Col. Baldwin, COE, to inquire as to the status of the schedule for the COE review of the pending applications for permits.

Col.

Baldwin discussed the need for a survey concerning the shortnose sturgeon as set forth in the memorandum of the meeting dated October 20,

1981, already furnished to Del-Aware.

December 9, 1981 V.S. Boyer and W.H.

Dickinson discussed matters relating to the j

intake structure with John Burns, COE, as set forth in the memorandum dated December 9,

1981, already furnished to Del-Aware.

1 i

W.H. Dickinson attended a meeting

. December 16, 1981 with the Corps of Engineers, NWRA and Icthyological' Associates during which matters related to the three issues were discussed as set forth in the memorandum dated December 21,

1981, already furnished to Del-Aware.

V.S.

Boyer, together with Robert June 14, 1982 Flowers and Hershel

Richman, met with Col.

Baldwin, COE, regarding the NRC Prehearing Conference Order and advised the Corps of the three issues the Board would consider in the NRC hearing beginning October 4, 1982.

Interrogatory 16:

Please state the minimum height above sea level of the' proposed intake at its present location during operation for the NWRA cr for PECO.

Answer:

The uppermost surface of the screen will be at elevation 66 feet.

This elevation will not change during operation.

Interrogatory 20:

Please identify and describe the contents and conclusions of any reports, or evaluations of reports, submitted by intervenors or other opponents of PECO in any proceeding before an agency, and made available to PECO of its technical consultants (including, but not limited to, reports by GKY Associates, Ezra Golub, and Edwin

.Beemer) relating to hydrolics, hydrology, location of the intake and the ambient velocities, the effects of blasing, or any other impacts.

Please identify any reports relating to water quality information submitted by intervenor or any other opponent of PECO to the Pennsylvania Department of Environmental Resources, the~ Corps of Engineers, or any other

agency, and made available to PECO or any its technical consultants.

Answer:

In a letter dated October 3, 1981 to the COE, Edwin F.

Beemer, Jr.

questioned the geological input submitted to the Corps as part of the NWRA application for the Point Pleasant facilities.

The Corps forwarded a copy to E.

H. Bourquard who transmitted it to PECO.

Applicant has obtained a copy of a draft report dated May 10, 1982 prepared by GKY Associates, Inc.

which addresses questions concerning the Point Pleasant Pumping Station.

Applicant has provided its consultants with a copy of this report.

Several of Applicants' consultants have prepared preliminary analyses of this report.

Generally, PECO's consultants have preliminarily concluded that the report contains deficieincies.

A letter dated June 4, 1982 from E.

H.

Bourquard to ~ Robert A.

Flowers (copy attached) discusses some of these deficiencies.

Dear Sco:

The referenced report appears to consist, for the.mos; part, of that fir ='s concept of what the Corps of Engineers should examine 2-d o= DER in connection with their permit reviews; apparen:ly prepared without knowing what hese agencies have examined.

The par: dealing with h.vdroloc.v. includes a number of cal analyses which profess to show sta: s::.

dura ion of River flows less the frequency and chan 3000 cfs at Trenton.

Unfortunately, the basic data covers a period of only 17 years, 1963-79, and includes the most severe and lanc.thv (1963-67) drought of record which has been classified as having a frequency of once in 100 to 500 years.

included in a short Naturally, wi:h such a drought cre heavily weightedperiod of record, the results of the analyses toward low flows. An examination of river flows in the years 1969 cbulation of Attachmen thru 1979 as shown in the upper 6 on page A-6r cives a more normal, typical, view of low flow conditions.

or n the hydraulics part, the use of 57 pumper trucks is cited to illustrate that have adverse effect flow and velocity patterns at the intake will on shad propagation.

has The writer eviden:ly no information on the flow and velocity patterns of this type of intake to be installed and, also, must not be aware that the intake is in the main stream channel of backwater area.

the River, not in a The part on water surface elevation at the intakes questions the existence of the Kingwood Township, Study, yet proposes N.J.,

the use of cross-sections Flood Insurance davolop low flow information.

from the Study to copies can be obtained from DR3C or the FEMA officeThe Kingwood Study does and phia.

However, the sections are in Philadel-while usable for flood 3,000 feet or more apart and, for low flow computations.flowlines,' are not particularly suitable In any cas.e, intake s,ite when relatedthe actual water level m;ccurements at the flowc yield a more accurate to adjusted Trenton rating for the site, as is confirmed

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P. L. Harman's Ccmments to "GXY & Associates, Inc.",

J. T. Phillippe report letter dated May 10, 1982 9 August 1982 1.

Page 1, Para.1.

reference to "interbasin transfer of water."

All water and biota withdrawn by the Point Pleasant pumping Station (PPPS) and diverted-out of the-=5iiThat:e River will never-theless remain within the Delaware River Basis) 2.

Page 2, Para.1.

.Philli?pe states that projected system demands and pumping schedules were not available for review at the time the subject letter report was prepared.

This castwnsiderable doubt on his understanding of the intake operation, particularily the timing of withdrawals as related to Delaware River flows and biota (and life stages) likely to be present in the River when withdrawals occur.

3.

Page 7, Part. 3.

reference several statements regarding water quality and quantity.

Such statements as:

(a) "there may be a shift in quality" (b) "such a shift...can have" Anything is possible; these statements are sheer speculation.

He presents no data to support his statements.

(c) " water diverted from the Delaware will have an impact in terms of quality and quantity on the Perkiomen and Neshaminy Creeks" This is a meaningless statement in terms of supporting a particular position.

Every action has an impact; not all impacts are deleter-ious.

He did not say whether this particular impact muld be negative or positive.

4.

Page 10, Para. 3.

" shad spawning area" Phillippe included no references or data to support his statement that "the area immediately downstream from Toh,1ckon is recognized as a shad spawning area of considerable biological importance."

The major spawning grounds for American shad in the Delaware River were sham by Chittenden (1969) to be much further upriver, between

v

. 4 Dingman's Ferry, Pennsylvania (river km 381) and Hancock, New York (river by 531).

Point Pleasant is at river km 253.

I know of no data showing that shad fishivo and associated recrea-tional activities are important to the economy of the Point Pleasant area.

Philippe states that "the river at the location of the proposed intakes is relatively shallow and flat."

In fact, the intake will be located in water about 10 feet deep; this is relatively deep in comparison to the reach just upstream of the Point Pleasant Canoe Rental boat ramp.

The Lumberville wingdam forms a relatively large and deep pool.

5.

Page 10, Para. 4 - Page 11, Para.1.

The impact of the water diversion was evaluated with respect to shad in terms of location, design, and capacity in my November 1980

" biological evaluation".

Several other documents also address this subject, e.g., offsetting storage-release requirements in OR8C's decision, hence Merrill Creek; NWRA's environmental report (February 1979), e.g., page V-19 "The proposed intake structure will meet the latest Environmental Protection Agency design criteria..." and subse-quent statements by NWRA to utilize the best available intake techno-logy.

(More information can be generated with regard to what has been evaluated should this be desireable at a later date.)

6.

Page 11, Para. 2.

The pum;ing station will not affect the backeddy area because the intake will be locaf.ed-out-4n-thhiver current and not in the bac.ceddy.

How4vir, 67 pumper trucks

'esumably on the river bank)

~

pumping all a' nce certain 1srupt the backeddy.

O s

i l

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of

)'

)

Philadelphia Electric Company

)

Docket Nos. 50-352 i

)

50-353 (Limerick Generating Station,

)

Units 1 and 2)

)

CERTIFICATE OF SERVICE I hereby certify that copics of " Applicant's Responses to ' Interrogatories of Del-Aware Unlimited, Inc. Addressed to Applicant Philadelphia Electric Company,'" dated August 20, 1982 in the captioned matter have been served upon the following by hand delivery, as noted below, or by deposit in the United States mail this 20th day of August, 1982:

Judge Lawrence Brenner (2)

Docketing and Service Section

{

Atomic Safety and Licensing Office of the Secretary Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.

20555 Washington, D.C.

20555

Stephen H.

Lewis, Esq.

Judge Richard F. Cole Ann P. Hodgdon, Esq.

Atomic Safety and Licensing Elaine I. Chan, Esq.

Board Counsel for NRC Staff U.S. Nuclear Regulatory Office of the Executive Commission Legal Director Washington, D.C.

20555 U.S. Nuclear Regulatory Commission Judge Peter A. Morris Washington, D.C.

20555 Atomic Safety and Licensing Board Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington,-D.C.

20555

. Commission-Washington, D.C.

20555 Atomic Safety and Licensing Appeal Panel Philadelphia Electric Company U.S. Nuclear Regulatory ATTN:

Edward G. Bauer, Jr.

Commission Vice President &

Washington, D.C.

20555 General Counsel 2301 Market Street Philadelphia, PA 19101

Hand Delivery

r

. c Mr. Frank R.

Romano Walter W.

Cohen, Esq.

61 Forest Avenue Consumer Advocate Office of Ambler, Pennsylvania 19002 Attorney General 1425 Strawberry Square Mr. Robert L. Anthony Harrisburg, PA 17120 103 Vernon Lane Moylan, Pennsylvania 19065 W. Wilson Goode Managing Director Mr. Marvin I. Lewis City of Philadelphia 6504 Bradford Terrace Philadelphia, PA Philadelphia, PA 19149 Steven P.

Hershey, Esq.

Judith A. Dorsey, Esq.

Community Legal 1315 Walnut Street Services, Inc.

Suite 1632 Law Center Philadelphia, PA 19107 North Central Beury Bldg.

3701 North Broad Street Charles W. Elliott, Esq.

Philadelphia, PA 19140 123 N.

5th Street Suite 101 Donald S.

Bronstein, Esq.

Allentown, PA 18102 1425 Walnut Street Philadelphia, PA 19102 Mr. Alan J. Nogee 3700 Chestnut Street Mr. Joseph H. White, III Philadelphia, PA 19104 11 South Merion Avenue Bryn Mawr, PA 19010 Robert W. Adler, Esq.

Assistant Counsel Dr. Judith H. Johnsrud Commonwealth of Pennsylvania Co-Director, ECNP DER 433 Orlando Avenue 505 Executive House State College, PA 16801 P.O.

Box 2357 Harrisburg, PA 17120

Robert J.

Sugarman, Esq.

Sugarman & D<P '7th Thomas Gerusky, Director Suite 510 Bureau of Radiation North American 2 11 ding Protection 121 South Broad Street Department of Environmental Philadelphia, PA-19107 Resources 5th Floor, Fulton Bank Bldg.

James M.

Neill, Esq.

Third and Locust Streets Box 511 Harrisburg, PA 17120 Dublin, PA 18917 '

Director Pennsylvania Emergency Management Agency Basement, Transportation and Safety Building Harrisburg, PA 17120

Hand Delivery Robert M.

Rader

.

ML20063B291

Text

Dear Sco:

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