ML20126G999

NPDES Noncompliance Notification:On 921104,dissolved Oxygen Monitoring Equipment at Bradshaw Reservoir Discharge & Water Processing Facility Became Fouled by Organic Concentrations. Caused by Heavy Rainfall.Manual Samples Will Be Obtained

ML20126G999
Person / Time
Site:	Limerick
Issue date:	12/24/1992
From:	Doering J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Noll P NESHAMINY, PA
References
NUDOCS 9301050033
Download: ML20126G999 (3)

Text

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i PIllLADEI PIIIA ELECTRIC COMPANY LIMERICK GENERATING STATION P. O. BOX 230)

SANATOGA, PA 19464-2300 (215) 327-1200 INT. 2000 December 24, 1992 J DornMG, Jn.

ruur usunam llM(RCK GhMAftNG STAtKW Mr. Peter G. Holl Department of Health Neshaminy Manor Center Doylestown, PA 18901

Subject:

Noncompliance with NPDES Permit No. PA 0052221 Bradshaw Reservoir Dissolved Oxygen Discharge Monitoring

Dear Mr. Noll:

DESCRIPTION OF NONCOMPLIANCE On November 4, 1992, at approximately 2300 hours0.0266 days <br />0.639 hours <br />0.0038 weeks <br />8.7515e-4 months <br />, the Dissolved Oxygen (DO) Monitoring equipment at the Bradshaw Reservoir discharge and at the Water Processing Pacility became inoperable

• when the detectors became fouled by organic concentrations in the '

Water. The NPDES Permit No. PA 0052221 requires continuous monitoring of Discharge 001 for DO and maintenance of a daily average of at least 5.0 mg/L and an instantaneous minimum reading of 4.0 mg/L. Discharge 001 is the effluent-from the Bradshaw Reservoir that is pumped to the East Branch of the Perkiomen Creek.

As a result of the inoperable monitoring equipment, the recorded DO concentrations were believed to be less than the actual DO concentrations as demonstrated by periodic These samples samples obtained indicated during the time of the equipment inoperability.

an average DO concentration of approximately 11 mg/L, well above the minimum limit of 5.0 mg/L. Because no system or. environmental perturbations occurred which would have significantly impacted DO concentrations, we have concluded that the true DO concentrations

(-

L were in compliance with permit limitations. However, the failure to perform continuous monitoringThe of DO concentrations Bradshaw Reservoirconstituted pump station noncompliance with the permit. 1989 without needing to alter has been in operation since August,

-operations to comply with permit limits for DO concentrations in the water.

CAUSE OF THE NONCOMPLIANCE The cause of this noncompliance was fouling of the DO detector probes-as a result of high organic concentrations inThe thedetector Bradshaw Reservoir water due to unusually heavy rainfall.-

membrane becomes less permeable to oxygen when it is fouled.

Instrumentation and Controls (I&C) personnel had cleaned the probes on November'3, 1992, one day prior to this event.- aOn November 4, 1992,;the recorded DO concentrations were identified to be 9301050033 921224 1 PDR ADDCK 05000352-S PDR

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decreasing, therefore, I&C personnel were requested to clean the probes. However, because the fouling occurred quickly, I&C perconnel were unable to clean the probes in time to prevent their inoperability. With the probes fouled and the associated equipment inoperable, continuous monitoring of DO concentration could not be achieved.

DURATION OF Tile NONCOMPLIANCE The duration of the noncompliance was approximately 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br /> beginning on November 4, 1992 at 2300 hours0.0266 days <br />0.639 hours <br />0.0038 weeks <br />8.7515e-4 months <br /> and ending on November 6, 1992 at 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br />. During this time period DO concentrations were not continuously monitored as required by the permit. In accordance with the contingency plans in the Limerick Generating Station (LGS) Makeup Water System Operating Plan and station operating procedures, samples were obtained manually during this '

time period. The results of the sample analyses indicated that DO concentrations remained well above the minimum levels prescribed-by the permit.

CORRECTIVE ACTION ,

When DO concentrations were noticed to be decreasing Operations personnel notified I&C personnel of the need to clean the probes dnd notified the System Manager. In the interim, manual monitoring of DO levels was instituted. These interim arrangements and sample results were communicated to Mr. Peter Noll by the System Nanager on November 5, 1992 at 1345 hours0.0156 days <br />0.374 hours <br />0.00222 weeks <br />5.117725e-4 months <br />. Upon completion of cleaning of _ *,

the probes by 1&C personnel, the monitoring equipment was restored to operability on November 6, 1992 at 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br />.

PREVENTION OF FUTURE OCCURRENCES In the event of equipment inoperability, contingency plans are included in the LGS Makeup Water System Operating Plan which has been submitted to the PA DER. These. plans include obtaining and.

analyzing manual 4amples until the continuous monitoring 1 equipment-is restored to operable status. A change.will be made by. December-30, 1992 to Surveillance Test (ST) procedure ST-6-111-640-0, " River- j Water Monitoring' Daily Log," to enhance awareness of Operations personnel of the_importance of timely corrective actions for an- <

identified decreasing DO concentration. This enhanced-awareness will also be communicated to Operations-and I&C personne1Jin:a memo from the Systcm Manager by December 30, 1992. , Procedure ST-6-lll-640-0 will subsequently be revised to incorporate additionali  ;

guidance for more;promptly recognizing a-DO probe thatfis becoming.

fouled.- This-revision _is expected to be completed by January 29, 1993.

sincerely,. -

O

/

U) 1 DCS:cah. ,

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. . . Page-3 4-cc: 'U.S. Nuclear Regulatory Commission l Document Control Desk Docket Nos. 50-352/50-353 Washington, D.C. 20555 ,

T. T. Martin Administrator, Region I, USNRC Docket Nos. 50-352/50-353 T. J. Kenny USNRC Senior Resident Inspector, LGS-Docket Nos. 50-352/50-353 F R. Bauer, Jr.

Pennsylvania Department of Environmental Resources Regional Water Quality Manager .

Lee Park, Suite 6010 l 555 North. Lane "

Conshohocken, PA 19428 Program Management Section (3WM52) '

Permits Enforcement Branch Water Management Division l Environmental Protection Agency Water Permits Section Region.III 841 Chestnut Building ->

Philadelphia,'PA 19107 bcct D.-H. Helwig - SMB1-1 3 G. L. Roach - SSB1-1 T. J. Jackson - SSB2-1 i-G. J. Beck 52A-5 J. A. Muntz - SSB3-1 G. J. Madsen - SMB2-4 G. M. Morley, Jr. --S9-2 3 H. W. Vollmer - 638-1 Commitment Coordinator -52A-5 PA DER BRP Inspector - SMB2-4 '

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