ML20136C827
| ML20136C827 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/04/1985 |
| From: | Conner T CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| CON-#485-700 OL, NUDOCS 8511210159 | |
| Download: ML20136C827 (5) | |
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9EIATED CO&mmine LAW OFFICeM CONNER & WETTERII AIIN, I).C.
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TROY B. CONNER, J R.
WAM Q N, D. C, lJ O O O O M ARK J. wETTERHANN ROBERT M. RADER DOtTOtas E. OLsON Jtss7CA H.1AVERTY
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1985 "E"*"ilRa "o?"'EcH uOE rER cFF1E C* @lhh.L c^"'"^oo"""'^'a"'^*
00CnykNCk Mr. Samuel J. Chilk Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 In the Matter of Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2)
Docket Nos. 50-352 and 50-353 [) / _
Dear Mr. Chilk:
As a follow-up to my September 23, 1985 letter to you, I am enclosing a copy of the emergency certification dated October 2, 1985 from Gerald M.
Ilansler, Executive Director, Delaware River Basin Commission, granting PECO's application for emergency approval to utilize, through December 31, 1985, Schuylkill River water for consumptive use at Limerick whenever the flow at the Pottstown gage is in excess of 415 cfs and other docket conditions are met.
Sincerely, k
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Troy
. Conner, Jr.
Counsel for Licensee TBC/dlf Enclosure cc:
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MCA0 QUARTERS LOCaficq October 2, 1985
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ccRALo M. MANsL:n W EST T ACNTON. N J.
EattuTIVE Olmstf04
Dear Mr. Bauer:
This is in response to your letters of September 20, 1985, and two applications for emergency approval concerning water supplies for the Limerick Generating Station.
F.
First to be considered is your request forta re-duction in the Pottstown gage trigger flow.
The Philadelphia Electric Company (PECO) requests DRBC emergency approval to utilise temporarily (through December 31, 1985)
Schuylkill River water for consumptive use to make up for evaporative losses from Limerick Unit I whenever the flow at the Pottstown gage is in excess of 415 cubic feet per second (cfs) and dissolved oxygen (DO) levels exceed those values incorporated in DRBC Docket D-69-210 CF (Final)(Revised May 29, 1985).
Commission staff finds that the project would temporarily conflict with the Comprehensive Plan, in that the 530 cfs trigger requirement is mandated in Docket D-69-310 CP (Final)(Revised May 29, 1985) which is part of the Comprehensive Plan. This will be considered in the staff's review of the application. For purposes of the request for emergency action, however, staff has taken into consideration the following factors:
(1) The request is for a temporary variance from the Comprehtsnsive Plan as related to the 530 cfs trigger flow at the Pottstown gage.
(2) The maximum total dissolved solids (TDS) level anticipated by DRBC Docket D-69-210 CP (Final) with one Limerick unit operating was not expected to exceed 455 parts per aillion (ppe).
(3) If PECO were allowed to withdraw Schuylkill River water at Limerick with a trigger flow of 415 cfs at the Pottstown sage based upon recent TDS background levels and an evaporative rate of 27 efs:
a.
The TDS in the Schuylkill River below Limerick should not exceed 455 ppm; b.
DRBC's effluent limitation of not raising TDS levels to 133 percent above background would not be violated;
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, g, c.
The Pennsylvania Department of Environmental Resources l
j (PADER) primary drinking water standard of 500 ppe for l
TDS would not be violated; and I
d.
Water quality degradation relative to TDS would increase by up to 32 ppe with a trigger flow of 415 cfs in lieu of the present flow of 53C cfs.
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(4) Although the drinking water standard any not be violated, TDS levels in the Schuylkill River are already much higher than in the i
Delaware main stem and other major tributaries.
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(5) Augmented flows released from upstream storage are made to l
improve downstress water quality, and would be rendered less useful if permitted to be evaporated at Limerick.
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(6) Downstream water users, including the City of Philadelphia, are concerned about further degradation of this already heavily j-used river and are also hopeful that adequate stream flows are maintained.
(7) Fish spawning and habitat are not as critical as we move into the cooler fall and early winter months, as they would be during the late spring and suaner.
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I (8) Dissolved oxygen levels M the Schuylkill River are rising now j
because of lower air and waar temperatures, and are expected t
l to continue that trend into tLe winter.
l (9) The Philadelphia Electric Company claims that delays in proceeding i
j with the power ascension program above 25 percent will delay l
cosmercial operation of the Unit and increase costs of Unit No.1 i
by $35 million per month, with an increase in customer fuel cost j
j of $10 million for each month of delay.
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(10) PECO previously agreed to conditions in Docket D-69-210 CP I
i (Final) to limit operation of the Limerick Generating Station l
based upon passing trigger flows in the Schuylkill River, I
i Perkiomen Creek, and Delaware River.
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(11) Use by PECO of water from the Delaware River via the partially i
completed Pt. Pleasant Pumping Station and Bradshaw Reservoir
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has been temporarily prevented based upon actions by other i
parties seeking to prevent construction of that project.
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i Pursuant to section 2-3.9 of the DRgC Administrative Meaual Part II, Rules of Practice and Procedure, based upon the factors enumerated i
I above, and with the approval of the Chairman, I hereby issue and this letter so
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constitutes an emergency certificate to the Philadelphia Electric Company (PECO):
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(1) PECO any withdraw water from the Schuylkill River for Limerick i
Unit No. I when the flow at the Pottstown sage exceeds 415 cfs, (not including augmentations of flow from Commission-directed i
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releases from upstream reservoirs) subject to all other conditions I
set forth in DRBC Docket D-69-210 CP (Final)(Revised May 29, 1985).
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(2) PECO may not withdraw water from the Schuylkill River at Limerick, 1
under this emergency certificate, when the background TDS at i
i the Pottstown sage exceeds 425 ppe.
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(3) PECO shall install an accurate recording TDS monitor at the l
Pottstown sage; the equipment specifications for same shall be I
submitted to the Executive Director for approval prior t'o in-i stallation; and the installation, calibration, maintenance, and operation of the TDs monitor and any interim manual measurements t
l of TDS shall be under the supervision and control of the U. 3.
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Geological Survey (U.g.G.S.).
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(4) Weekly records of all TDS monitoring shall be submitted to the
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Consission in writing within three working days, together with j
a los of power plant operations and consumptive water use. Such i
inforestion shall be a matter of public record.
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(5) PECO shall immediately notify the Commission whenever TDS levels i
at the monitoring station trigger the criteria set forth in (2) above, and advise the Coussission of steps taken to curtail power plant operations.
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This emergency certificate is issued authorising you j
to proceed with the development of this project, pending review, hearing and determination by the Coianission, as required by the rules.
It shall remain in effect i
j through December 31, 1985, or whenever the Commission completes its actions as
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required by the rules, whichever is sooner. The granting of this emergency and I
4 temporary modification in passing-flow requirements shall not be construed as a j
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change in DRBC policy to protect the quality of water in the Schuylkill River on
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3 a long-term basis.
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DRSC action on your request for the use of 10 cfs from Beechwood Pit will be deferred until after our normal public notice /public 3
hearing process has been completed.
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Both the 415 cfs trigger and the 10 efs/ Beechwood Pit applications will be considered at a public hearing on the evening of October 29, I
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in the Valley Forge area. Precise time and location will be announced in the near future.
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Raspectfully, Gerald M. Hansler Edward G. Bauer, Jr., Esquire Philadelphia Electric Ccapany 2301 Market Street Philadelphia, Pennsylvania 19101
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GMK CFD t
cc Cosuaissioner Richard T. Dewling Mr. Dirk C. Hofman Commissioner George J. Kanuck, Jr.
Connaissioner Robert J. Touhay Commissioner R. Timothy Weston Commissioner Henry G. Williams Mr. Irwin H. King Mr. Charles R. Wood (U.S.G.S.)
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