ML20101K466

NPDES Noncompliance Notification:On 960218,discovered That No Records Existed for Bradshae Reservoir Discharge Water Temp for Listed Time Periods.Caused by Temporary Reassigment of Personnel.Review of Staffing in Progress

ML20101K466
Person / Time
Site:	Limerick
Issue date:	03/28/1996
From:	Boyce R PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Bauer R PENNSYLVANIA, COMMONWEALTH OF
References
NUDOCS 9604020380
Download: ML20101K466 (4)

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Robert W.B yc2 Plant Manager Umenck Generating Staten Cik_

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mer PECO NUCLEAR e=n-c-env Limenck Generating Staten A Unit of PECO Energy PO Box 2300 sanatoga. PA 19464-0920 610 718 2000 March 28, 1996 Robert Bauer, Jr. '

Departme,t of Environmental Resources Bureau ot Water Quality Management Suite 6010, Lee Park 555 North Lane Conshohocken, PA 19428

SUBJECT:

Limerick Generating Station, Units 1 and 2 Noncompliance of NPDES Permit No. PA-0052221, Bradshaw Reservoir Discharge Water Temperature Records

Dear Mr. Bauer:

Backgroqnd:

Two instruments are utilized to monitor and record the Bradshaw Reservoir discharge water temperature: 1) the Bradshaw Reservoir temperature monitor, which inputs to a strip chart recorder and to the station's main control room Plant Monitoring System (PMS) computer which computes and ,

retains hourly average temperature values, and 2) the Water l Processing Facility (WPF) temperature monitor, which inputs to a separate strip chart recorder. Prior to the occurrence of this non-compliance, the WPF temperature monitor was inoperable due to flooding of its underground storage vault  ;

in mid January 1996.  !

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Description of the Non-Compliance:

On February 18, 1996, station personnel discovered that no l records existed for the Bradshaw Reservoir discharge water  !

temperature for the following time periods:

February 13, 1996, 0900 to 2400 hours0.0278 days <br />0.667 hours <br />0.00397 weeks <br />9.132e-4 months <br /> (15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />),

February 15, 1996, 0800 to 2300 hours0.0266 days <br />0.639 hours <br />0.0038 weeks <br />8.7515e-4 months <br /> (15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />), and .

February 17, 1996, 1500 to 2400 hours0.0278 days <br />0.667 hours <br />0.00397 weeks <br />9.132e-4 months <br /> (9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />). l I

i 0 2.0 0 M I 9604020380 960328 I C l

PDR ADOCK 05000352 6-s PDR .MJ l

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% E This is contrary to_the requirements of Part C, Section G, of the NPDES permit which requires the Bradshaw Reservoir discharge water temperature to be continuously monitored and recorded. The Bradshaw Reservoir temperature monitor was continuously monitoring temperature; however, no records were obtained during the three time periods stated above.

The events which led to the discovery of this non-compliance are described below.

1. At 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> on February 18, 1996, station personnel identified that the Bradshaw Reservoir temperature recorder was out of strip chart recording paper.

Station personnel immediately installed a new strip chart recording paper cartridge. An evaluation identified that the recorder ran out of paper at 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> on February 13, 1996, however, the temperature monitor remained operable.

2. An analysis of the information retained by the station's PMS computer was performed. After obtaining all Bradshaw Reservoir records available from the PMS j computer files, station personnel determined that no J records of the discharge water temperature existed for the three time periods stated above. The lack of temperature recording by the PMS computer during these three time periods is attributed to technical difficulties that were experienced while installing and testing a new PMS computer. For the remaining time i periods, hourly average temperature values were recorded using temperature data collected at 15 second intervals.

There is no limit on the Bradshaw Reservoir discharge water temperature. Based on the temperature records that were i obtained, the discharge water temperature varied by approximately three degrees F during the entire period in question.

i Cause of the Non-Compliance Three overlapping circumstances resulted in this non-compliance and are described below.

1. Prior to the occurrence of this non-compliance, station personnel that normally check the Bradshaw Reservoir temperature recorder for adequate strip chart recording

paper supply had been temporarily reassigned to other j

duties for the Unit i refueling outage, which commenced i during the first week in February 1996.

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2. As stated previously, the redundant WPF temperature 1 monitor was inoperable prior to and during the period of non-compliance.

3. The PMS computer was replaced with a new computer in February 1996 during the Unit 1 refueling outage.

Because of technical difficulties _that were experienced with the new computer during the time period of this non-compliance, the computer was not continuously l i

retaining and printing hourly average temperature values for the Bradshaw Reservoir. This problem with the PMS computer has since been corrected.

Actions to Prevent Recurrence:  ;

A review of staffing for maintenance of Bradshaw Reservoir and WPF equipment during station outages is currently in -

progress. This review is expected to be completed by April 23,.1996, and appropriate corrective actions will be implemented as necessary.

The redundant WPF temperature monitor was repaired on February 22,-1996. An additional' temperature monitor has also been installed at the WPF. Both redundant WPF '

temperature monitors ~ remain vulnerable to flooding of their underground vault during periods of heavy precipitation.

Plans have been developed to minimize the probability of this vault flooding. These preventative measures are expected to be implemented by June 30, 1996.

If there are any questions please do not-hesitate to contact Mr. James L. Kantner at (610) 718-3400.

Sincerely, l b

DMS:cah i

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cc: U.S. Nuclear Regulatory Commission Document Control Desk Docket Nos. 50-352/353 Washington, D.C. 20555 j l

T. T. Martin Administrator, Region I, USNRC Docket Nos. 50-352/353 .

N. S. Perry USNRC Senior Resident Inspector, LGS Docket Nos. 50-352/353  :

! Program Management Section (3WM52) '

l Permits Enforcement Branch Environmental Protection Agency Water Management Division l Environmental Protection Agency

! Water Permits Section

{ Region III L 841 Chestnut Building.

Philadelphia, PA 19107 1

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