ML19332A934

Responds to NRC 800714 Ltr Re Violations Noted in IE Insp Repts 50-352/80-09 & 50-353/80-08.Corrective Actions:Sewage Pumped on Continuous Batch Basis from Holding Tanks to Treatment Plant

ML19332A934
Person / Time
Site:	Limerick
Issue date:	08/04/1980
From:	Kemper J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19332A932	List: ML19332A934
References
NUDOCS 8009190048
Download: ML19332A934 (3)

Text

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.s PHILADELPHIA ELECTRIC COMPANY

() 2301 MARKET STREET P.O. BOX 8699

_AUG 0 41960 PHILADEl. PHI . PA.19101 JOHN S. KEMPER vict+ntsIDENT Emessess resse aseo massamCoe Mr. Boyce Grier, Director United States Nuclear Regulatory Commission Office of Inspection and Enforcement, Region I 631 Park Avenue King of Prussia, PA 19406

Subject:

USNRC IE Region I Letter dated July 14, 1980 RE: Site and Office Inspection of May 22-27, 1980 Inspection Report No. 50-252/80-09 .6 50-353/80-08 Limerick Generating Station - Units 1 and 2 File: QUAL 1-2-2 (352/80-09 and 353/80-08)

Dear Mr. Grier:

In response to the subject letter regarding items identified during the subject inspection of construction activities authorized by NRC License Nos.

CPPR-106 and -107, we transmit herewith the following:

Attachment I - Response to Appendix A Should you have any questions concerning these items, we would be pleased to discuss them with you.

Sincerely,

,J. S. Kemper JhC/mmk Attachment 80091000 %

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ATTACHMENT RESPONSE-TO APPENDIX A

~

Item of Noncompliance Deficiency Section 3.E.1 of Construction Permits CPPR-106 and CPPR-107 requires that all work in connection with this proj ect be carried on under the provisions of Permit 4671202, authorized by the

' Department of Environmental Resources, Commonwealth of Pennsylvania under the Act of June 25, 1913, as amended. Standard Condition 16 of Permit No. 4671202~ requires that no untreated or ineffectively treated wastewaters shall at any time be discharged into the waters of the Commonwealth, and special care shall be used to prevent accidental " spills" or similar unusual discharges of all raw, finished and waste materials.

Section 3.E.9 of Construction Permits CPPR-106 and CPPR-107 requires that the applicant take the necessary mitigating actions, including those summarized in Section 4.5 of the Final Environmental Statement (FES), during. construction of the Station and associated transmission lines to avoid unnecessary adverse environmental impacts from construction activities. Section 4.5.1.1 of the FES states that during the early phase of construction organic wastes are collected in mobile facilities and exported from the site to an approved treatment facility. Later, all sewerage will be treated onsite in a state-approved sewago plant to a quality meeting the standards of the Commonwealth of Pennsylvania. No untreated waste will be discharged to the river.

Contrary to these requirements, on February 8, 1978 and July 3, 1979, undetermined amounts of raw, untreated sewage from the site sewage holding tanks spilled from the tanks and entered Possum Hollow Run which flows into the Schuylkill River, i

Response to Deficiency l The July-3, 1979 incident was identified by Corrective Action L Report #263 dated July 3, 1979 in accordance with Section III of'the Limerick Generating Station Construction Pollution Control Program.

- l The sewage header feeding the temporary holding tanks was blocked '

by debris thus causing an accumulation of sewage. A router was used to clear the-line. When the line opened, a volume of material flowed down to the vented tee inlet of the holding tank. At the time of discharge a dipstick was inserted in the vent opening.

I Upon striking the dipstick a small quantity of liquid spieshed out of the opening. Operators standing by immediately removed the dipstLck allowing all material to flow into the tank. The small spill was immediately diluted with a large volume of water.

The run of the tee at the tank inlet was capped on July 16, 1979 to prevent material from splashing out. For operator convenience, a new connection was added to the tank to accomodate the dipstick on July 23, 1980.

The February 8, 1978 incident was identified by Corrective Action Report-1214 dated February 8, 1978 in accordance with Section III of the Limerick Generating Station Construction Pollution Control Program.

At-approximately 8:00 AM the holding tank high-level alarm sounded and investigation-revealed that overflow was occurring. The vendor was immediately contacted to pump out the tank and the overflow ceased at approximately 10:00 AM.

Recurrence of this condition has been made extremely unlikely by installation of connecting piping from the tanks to the sewage pi t.n t so that sewage is now pumped on a continuous batch basis from the tanks to the plant. This work was completed on June 19, 1978.

A manually operated tank bypass has also been installed. This work was completed on July 23, 1980.

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