ML20070S307
| ML20070S307 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/22/1991 |
| From: | Doering J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Feola J PENNSYLVANIA, COMMONWEALTH OF |
| References | |
| NUDOCS 9104020232 | |
| Download: ML20070S307 (2) | |
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PHILADELPHI A ELECTRIC COM PANY LtMERICK GENER ATING ST ATION P, 0, 00X A S AN ATOG A, PCNNSY LV ANI A 194 6 4 tais) szt izoo
- m. noo March 22, 1991
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Mr. Joeseph A. Peola Regional Water Quality Manager Southeast Regional Office Lee Park Suite 6010 555 North Lane Conshohocken, PA 19428 Subiect:
Limerick Generating Station, Units 1 and 2 Noncompliance with NPDES Permit No. PA-0051926
Dear Mr. Peola,
During the performance of a Storm Drain System walkdown on February 4, 1991, the plant system engineer identified that a des!qn deficiency in the Storm Drain System existed involving certain normal waste drains located in both the Unit 1 and Unit 2 Reactor Enclosures (RE).
The purpose of the normal waste drains associated with the RE ve tilation fan rooms is to collect liqcid wastes f rom equipment (i.e., heating coils associated with RE supply fans) and floor drains from a non-radiological portion of the plat.* and then route this flow directly to the Holding Pond.
Howerer, the plant system engineer discovered that these normal waste drein lined a.e connected into the Storm Drain System at a point upstream of a diverter valve, SS.3, that directs flow from the storm dcains to the Holding Pond during normal operation or to Outfall 003 during periods of heavy rainfall.
Therefore, when the diverter valve was aligned to Outfall 003, the Storm Drain System design may have allowed the mixture of storm water and steam condensate,-producea from heating coils associated with the RE Supply Fans, to be released at Outfall 003.
This Storm Drain System design has existed since original construction of the plant.
Unpermitted discharges may have occurred intermittently since the Storm Drain System was placed in service in January 1985.
This report is being submitted in accordance with NPDES Permit No. PA-0051926 as a result of a potential unmonitored effluent release fram Outfall 003 which is permitted for storm water runoff only.
No adverse environmental effects have been detected at Outfall 003 that may have occurred as a result of discharging steam condensate diluted by stormwater during heavy rainfalls.
We are currently evaluating the Storm Drain System design to determine a permanent solution.
When this evaluation is completed, we will forward the results in a separate correspondence.
In the interim, J
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9 s'Mr. Joeceph A. Feola Page 2 of 2 March 22 1991 administrative controls have been established to ensure the diverter valve, SS.3, is positioned suc!. that the effected Storm Drain System flow will be directed to the Helding Pond and through Monitoring Point 201 prior to releasing from Outfall 001.
However, during a heavy rainfall, we may not be able to discharge from Monitoring Point 201 as overfilling. quickly as needed to prevent the Holding Pond frem In tais instance, Shift Supervision la instructed in accordance with administrative controls to positioh the diverter valve such that Storm Drain System flow is diverted to Outfall 003.
These administrative controls also instruct Shift Supervision to immediately contact Chemistry personnel to begin sampling and analyzing the effluent (i.e., mixture of stormwater and diluted steam condensate) at Outfall 003 cnce every eight hours primarily for temperature but also for isotopic activity and pH.
These interim actions ensure that all effluents entering the effected portions of the Storm Drain 9ystem will be monitored.
Additionally, we will report this event in accordance wit.h the subject NPDES
- Permit, very truly yours, r
WGS/rgs cc: U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555 Administrator Region I U. S. Nuclear Regulatory Commission 475 Allendale Road f
King of Prussia, PA 19406 Station Resident NRC Inspector Tom Kenny, M.C.# NRC Program Management Section (3WM52)
Permits Enforcement Branch Water Management Division 2nvironmental Protection Agency Water Permits Section Region III 841 Chestnut Building Philadelphia, PA 19107 l
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