ML20138G965

NPDES Noncompliance Notification:On 960428,calibration of Flowmeter Used to Measure Spray Pond Flow Was Not Checked on Routine Basis Because Person Required to Develop Maint Was Unaware of Requirements.Installed New Meter

ML20138G965
Person / Time
Site:	Limerick
Issue date:	12/24/1996
From:	Boyce R PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Oneil S PENNSYLVANIA, COMMONWEALTH OF
References
NUDOCS 9701030083
Download: ML20138G965 (4)

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Robert W. Boyos Plant Manager .

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. Limenck Generttng Staton 4

PECO NUCLEAR nco % c -

Limenck Generatng Staton i A Unit of PECO Energy Po Box 2300 l Sanatoga PA 19464-0920 61o 718 2000

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December 24,1996-l Steven J. O'Neil  !

Chief, Operations Section l PA. Department of Environmental Protection Bureau of Water Quality Management Suite 6010, Lee Park l 555 North Lane l Conshohocken, PA 19428 l

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SUBJECT:

Limerick Generating Station, Units 1 and 2 Five Non-Compliances Identified From the Extemal Audit of NPDES Permit No.

PA 0051926

Dear Mr. O'Neil:

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In a NPDES non-compliance letter to the PA Department of Environmental Protection (DEP)

- dated April 28,1996, PECO Energy committed to performing a comprehensive audit of the implementation of the NPDES Permit for the Limerick Generating Station (LOS). As a result of the audit, five (5) issues were identified and a corrective action plan was developed to address each issue. These issues involve some interpretation of the NPDES Permit requirements, and are

- conservatively being reported as non-compliances of the NPDES Permit. None of these issues involve any adverse environmental impact. The five non-compliances involve:

1. Calibration records for an installed flowmeter,

2. Retention of records for laboratory instrument calibrations,

3. Two storm culverts that do not appear on site drawings,

4. The Preparedness, Prevention, and Contingency (PPC) Plan does not include all of the L " Supplemental Guidance for the Development and Implementation of the PPC Plan under the

[ NPDES Storm Water Permitting Program," and the L 5. Composite sampling for Ou: fall 001.

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l. 9701030083 961224 c (N ()

PDR ADOCK 05000352: /, U S PDR y L 010033 l

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4 December 24,1996 l Page 2 l Descriotion of Each Non-Comoliance. Cause. and the Corrective Actions Taken to Prevent I Recurrence:

l. The calibration of the flowmeter used to measure the Spray Pond flow was not checked on a  !

routine basis as required by records retention provisions of the NPDES Pennit. This was J

omitted because the person required to develop the maintenance and calibration frequency was unaware of the requirements of the NPDES Permit. Although the instrument was ,

maintained as required to provide the data needed as input to the Outfall 001 flow measurement, no calibration records could be located. Site Engineering contacted the 1 manufacturer to identify the proper calibration procedure and was unable to obtain l l information. The manufacture no longer supports this instrument. The Spray Pond flow is a very low volume discharge and contributes to approximately 1% of the daily total blowdown.

The blowdown occurs during three distinct periods; rain, makeup to maintain a minimum pond level due to evaporation, and makeup for water chemistry control. A review of the data obtained from this flow meter indicated that the average daily discharge from the Spray Pond is 86,000 gallons. To date, the average daily flow from Outfall 001 is 7.8 million gallons.

Therefore, the error in reporting flow as a result of this instrument's calibration status is inconsequential. LOS plans to install a new flow meter to allow for ease of reading and calibration. Following installation, the new flowmeter will be maintained by routine calibration.

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2. Currently a corporate computer data base is utilized for the retention of calibration records  ;

for instrumentation used to comply with NPDES Permit requirements. The NPDES Permit i' Part A, Section 3.g requires calibration data records to be retained for three (3) years. At LGS, however, only an indication of satisfactory completion of the calibration was maintained and not the data. This practice has been established since the original NPDES Permit. This is contradictory to the 3 years of retention of maintenance and calibration records required by the NPDES Permit. LGS is confident in the reliability of the instruments due to its calibration program and has upgraded the tasks used for NPDES compliance to transfer records and instrument maintenance logbooks to the Chemistry Section individual -

responsible for DMR preparation for the required 3 year retention.

3. During the audit, two storm water culverts were identified at LGS that did not appear on the site drawings and were not identified to the DEP as storm water outfalls. The identified . i

- culverts to date are the result of erosion abatement efforts (i.e., rip rap). These culverts had I

( been in existence before the issue of the 1995 NPDES permits and the requirement to have i

updated site drawings for these culverts was not identified. A site wall down is planned to l ensure no further unidentified culverts exist. Following this walkdown appropriate drawings

will be updated and submitted to your office by June 30,1997. The PPC Plan will be

. upgraded to include wording that alerts station personnel to the requirements of the addition  !

} of culverts. The revised PPC Plan is expected to be issued by January 31,1997.

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December 24,1996 Page 3 l

4. The present PPC Plan does not include all of the " Supplemental Guidance for the Development and Implementation of the PPC Plan under the NPDES Storm Water Permitting Program." This requirement was not communicated to the site.with the 1995 ,

revision to NPDES Permit. The PPC Plan is undergoing a complete rewrite using an I environmental consultant, CM2H Hill, and will include the supplemental guidance for storm water. The revised PPC Plan is expected to be issued by January 31,1997.

t l 5. . LOS performs a time weighted composite sample for Outfall 001. The permit requires a flow I

weighted composite sample for this outfall. The time weighted composite sampler has been j in service since the 1995 NPDES Permit was issued. The PECO Corporate Environmental ~ '

l Group has been in phone contact with the DEP discussing this issue and our ability to seek

( relief from the regulation. The use of a flow weighted composite sampler would require a l significant modification since the total Outfall 001 flow is a summation of four inputs; Unit 1 l cooling tower blowdown, Unit 2 cooling tower blowdown, radwaste discharge, Spray Pond l overflow and Holding Pond discharge. - Each input has a separate flow meter, and these l meters do not have the capability to be linked to a single data acquisition system for recording. The Chemistry Section has contacted a major manufacturer of a flow weighted I composite samplers to determine the practicality ofinstalling a flowmeter. The current discharge configuration does not allow for the accurate installation of a flow weighted composite sampler. The Chemistry Section is performing a side by side comparison of the

. two methods using manual collection of flow data. The results of the comparison will be l- used to seek relief from the present regulation and the continued use of the present sampling methodology, or will be utilized tojustify a major modification to Outfall 001. Collection of the data will be completed in December 1996. Following analysis of the data, a follow-up l letter addressing our recommendations is expected to be issued by January 31,1997.

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

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! Sincerely, i ll! / /  !

blR%  !

For R. W. Boyce l

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• U.S Nuclear Regulatory Commission 4 Document Control Desk

! Docket Nos. 50-352/352 Washington, D.C. 20555 P

i H. J. Miller Administrator, Region I, USNRC Docket Nos. 50-352-353 N. S. Perry USNRC Senior Resident Inspector, LOS

. Docket Nos. 50-352/333 i

Program Management Section (3WM52) a Permits Enforcement Branch Environmental Protection Agency j I '

Water Management Division Environmental Protection Agency Water Permits Section Region III 841 Chestnut Building Philadelphia,PA 19107 ,

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