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Category:NPDES NONCOMPLIANCE NOTIFICATION
MONTHYEARML20206C9871999-04-27027 April 1999 NPDES Noncompliance Notification:On 990319,station Personnel Observed Foam Emanating from Manhole Vent Associated with Outfall 001,no Foam Was Observed on Any Waterway.Caused by Inappropriate Addition of Betz 3625 to Spray Pond ML20207D6171999-02-26026 February 1999 NPDES Noncompliance Notification:On 990111,discovered That Weelkly Analysis for non-oxidizing Biocide Betz 3625 Was Not Performed.Caused by Sample Being Inappropriately Delayed for Future Chemical Addition.Counseled Individuals Involved ML20202F0591999-01-19019 January 1999 NPDES Noncompliance Notification:On 990112,Auxiliary Boiler Source Number OAS502 Found to Have Malfunctioning Opacity Monitor.Caused by Stepdown Transformer within Power Supply. Power Supply Replaced ML20198J2811998-12-21021 December 1998 NPDES Noncompliance Notification:On 981102,release of 500 Gallons of 12% Sodium Hypochlorite to Environment Occurred. Caused by Failure of Tank Discharge Fittings.Integrity Testing Will Be Performed on All New Tanks.With ML20206R3491998-12-21021 December 1998 NPDES Noncompliance Notification:On 981102,500 Gallons of 12% Sodium Hypochlorite Released to Environ.Caused by Failure of Tank Discharge Fittings & Subsequent Leaks from Secondary Containment.Culvert Was Flushed Repeatedly ML20236V2001998-07-27027 July 1998 NPDES Noncompliance Notification:On 980619,geometric Mean Coliform Concentration Calculated to Be 223 Colonies Per 100 Ml.Sample Procedure Enhanced to Ensure Normal Operating Conditions ML20248C9461998-05-27027 May 1998 NPDES Noncompliance Notification:On 980414,total Iron Discharge Through Outfall 001 Exceeded Limits Set in Ltr Dtd 960508.Total Iron Discharge Limit Exceeded During Cleaning Evolution.Limit Revised ML20217N6921998-02-27027 February 1998 NPDES Noncompliance Notification:On 980107 Net Total Suspended Solids (TSS) for Units 1 & 2 Cooling Towers at Outfall 001 Exceeded NPDES Permit Daily Limit of 60 Ppm. Caused by Contaminated Sample Lines.Replaced Tygon Tubing ML20141G0271997-06-27027 June 1997 NPDES Noncompliance Notification:On 970512,sample for Kjeldahl Omitted Due to Personnel Error.Counseled Individual Responsible.On 970521,Net TSS Exceeded NPDES Daily Limit Due to Fouled Sample Tubing.Replaced Sample Tubing ML20137M5511997-03-27027 March 1997 NPDES Noncompliance Notification:On 970228,flow Integrator Used to Measure Spray Pond Effluent Flow Was Identified to Be Malfunctioning & Declared Inoperable Due to Lodged Debris.Revised Procedure for Spray Pond Effluent Flow ML20134G3241997-01-31031 January 1997 NPDES Noncompliance Notification:On 970108,util Informed NRC That PA Dept of Environ Protection Granted Approval for Temporary Discharge at Lgs,Per 961219 ML20138G9651996-12-24024 December 1996 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 ML20135A5851996-11-27027 November 1996 NPDES Noncompliance Notification:On July-Sept 1996 Re NPDES Limit for Fecal Coloform Concentration Not Met.Caused by Inadequate Gasket Installation.Ozonators Overhauled to Ensure Peak Performance ML20134E0641996-10-28028 October 1996 NPDES Noncompliance Notification:During Month of Sept 1996, NPDES Limit for Fecal Coliform Concentration at Discharge of Bradshaw Reservoir Pumps Was Not Met.Caused by Leaking Gaskets on Ozone Gas Diffusers.New Gaskets,Installed ML20129E5681996-09-27027 September 1996 NPDES Noncompliance Notification:On 960805,geometric Mean of Fecal Coliform Concentration Calculated to Be 641 Colonies Per 100 Ml.Cause Suspected to Be Due to Malfunctioning Ozone Disinfection Sys.Adjustments to Sys Have Been Made ML20129E5411996-09-26026 September 1996 NPDES Noncompliance Notification:On 960812,discharge Observed from Unit 2 Cooling Tower Overflow to Outfall 021. Caused by Personnel Error in Performing Required Analysis of Cooling Tower Overflow Sample.Individual Counseled ML20117G7071996-08-23023 August 1996 NPDES Noncompliance Notification:On 960715,geometric Mean of Fecal Coliform Concentration Exceeded NPDES Permit Limit. Caused by Leaking Seals on Ozone Diffusers.Temporary Adjustments Made to Ozone Gas Flow Balance ML20116B3851996-07-24024 July 1996 NPDES Noncompliance Notification:On 960602 Identified Ph Levels Exceeded NPDES Permit Limitations.Caused by Natural Biological activity.CO2 Injection Established,Maintained & Monitored Until 960612 ML20115G1151996-07-12012 July 1996 NPDES Noncompliance Notification:On 960619,resulting Net TSS Value 82.8 mg/1,exceeded Max Daily Limit of 60 Mg/L.Caused by Excessive Storm Water Runoff.Net TSS Revised ML20113C4451996-06-24024 June 1996 NPDES Noncompliance Notification:On 960318,flow Integrator Used to Measure Spray Pond Effluent Flow Declared Inoperable.Caused by Faulty Flow Integrator.Frequency of Use of Instrument Changed to Daily as Stated in Issue Number ML20108A3671996-04-28028 April 1996 NPDES Noncompliance Notification:On 960314,personnel Observed Sewage Overflowing from MH-07 & Into Storm Drain W-4.Caused by Blockage of Pipe Section Between MH-07 & MH-08.Sewer Contract Svc Pressure Cleaned ML20108A3801996-04-28028 April 1996 NPDES Noncompliance Notification:On 960223,identified Seven Issues of Administrative non-compliance/ambiguity W/Permits. Caused by Inadequate Administration.Individuals Gained Better Understanding W/Guidance ML20101K4661996-03-28028 March 1996 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 ML20100P6311996-02-28028 February 1996 NPDES Noncompliance Notification:On 951108,discharge 001 Net TSS in Excess of Maximum Daily Limit.Caused by Flaw in Methodology to Calculate Net TSS concentration.Follow-up Composite Samples Taken ML20072R4601994-08-31031 August 1994 NPDES Noncompliance Notification:On 940708 & 0815,Discharge 001 Total Zinc Concentrations Exceeded Max Daily Limitations.Daily Zinc Trending Analysis Will Be Upgraded & Chemistry Technician Involved in 940815 Event Counselled ML20071L1761994-07-27027 July 1994 NPDES Noncompliance Notification:On 940609,zinc Analyses Indicated That Discharge 001 Total Zinc Levels in Excess of Max Daily Limitations in Both Cooling Towers.Daily Zinc Control Limits Will Be Administratively Maintained Lower ML20149E7291994-07-26026 July 1994 NPDES Discharge Monitoring Rept:On 940713,approx 18 Gallons of Betz Clamtrol CT-1 Inadvertently Released from Injection Sys Located South of LGS Spraypond Pumphouse.Caused by Break in Pump Discharge Line.Polyethylene Piping Replaced ML20065B9221994-03-25025 March 1994 NPDES Noncompliances Notification:On 940204,discharge 001 Maximum Daily Limit of 1.0 mg/1 Total Zinc Was Exceeded. Caused by Low Ph Transient in Unit 2 Cooling Tower Water Sys.Isolated Acid Injection Sys ML20064C7701994-02-25025 February 1994 NPDES Noncompliance Notification:On 940116 & 17 Manual Reactor Scram Occurred.Caused by Failure to Adequately Throttle Cooling Tower Bypass Valves.Procedure Revised ML20059C4941993-10-26026 October 1993 NPDES Noncompliance Notification:On 930907,cooling Tower Blowdown Water Discharged Into Possum Hollow Creek Due to Loss of Two of Four Operating Circulating Water Pumps. Procedures for Performing Excavations Revised ML20056G3921993-08-27027 August 1993 NPDES Noncompliance Notification:On 930710,13,14 & 25, Water Processing Facility (Wpf) Discharge Temp Exceeded Max Limitation of 74 Degrees F.Rev to NPDES Permit,Removing Temp Limits Approved & Wpf Chillers Removed from Svc ML20024H8441993-08-19019 August 1993 NPDES Noncompliance Notification Re Perkiomen Storage Tank Overflow to Possum Hollow Run.Application for Amend to Permit PA0051926 Submitted ML20046B8051993-07-29029 July 1993 NPDES Noncompliance Notification:On 930618,20 & 27,water Processing Facility Temp Exceeded Permitted Max Limitation of 74 Degrees F.Caused by Lack of Training & Written Instructions.Training Provided & Addl Instruction Issued ML20044G7641993-05-21021 May 1993 NPDES Noncompliance Notification:From 930417-18,equipment Problems Occurred Which Rendered Dissolved Oxygen & Ph Monitoring Instrumentation Inoperable.Caused by Debris in Sample Line.Methods for Filtering Flow Under Investigation ML20044C4051993-03-16016 March 1993 NPDES Noncompliance Notification:On 930222,discovered That Contractor Personnel Discharged Treated Water from Fire Hydrant Supplied by Unit 1 Cooling Tower Into Storm Water Drain E-3.2.Caused by Personnel Error.Label Applied ML20128N1251993-02-17017 February 1993 NPDES Noncompliance Notification:On 930103,cooling Tower Blowdown Water Overflowed from Discharge 001 Pipeline & Flowed Into Possum Hollow Creek.Caused by Failure to Throttle Unit 2 Bypass Valves.Procedure Changed ML20128A5071993-01-25025 January 1993 NPDES Noncompliance Notification:On 921117 & 25,analytical Results for inductively-coupled Plasma Analyzer at Discharge Point 001 Exceeded Zinc Concentration.Total Zinc Concentration Analysis Will Be Performed Onsite ML20126G9991992-12-24024 December 1992 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 ML20117A5761992-11-23023 November 1992 NPDES Noncompliance Notification:On 921013 & 14,four of Five Samples Collected from Discharge Point 001 Exceeded Daily Max Permit Limit of 1.0 Mg/L.Caused by Heavy Rains Across Southeastern PA on 921009.Injection Rates Decreased ML20101H5321992-06-26026 June 1992 NPDES Noncompliance Notification:On 920504,crack Discovered on Above Ground Cleanout for Sewage Line Leading from Plant Training Ctr to Plant Sewage Sys Holding Tanks.Caused by Expansion of Sewage Spill Line.Clamps Installed ML20095J1201992-04-23023 April 1992 NPDES Noncompliance Notification:On 920322,cooling Tower Blowdown Water Discharged Into Possum Hollow Creek.Caused by Procedure Deficiency.Sys Operating Procedure S09.4.A Expected to Be Revised by 920501 ML20141M0551992-03-25025 March 1992 NPDES Noncompliance Notification:On 920206,rain Water Pumped from Eletrical Manhole Into Storm Water Runoff Drain Due to Inadequate Procedural Guidance.Blue Drains to Be Labelled, Indicating Use for Storm Water Runoff Only by 920801 ML20091Q4301992-01-23023 January 1992 NPDES Noncompliance Notification:On 911218 Cooling Tower Blowdown Water Discharged to Possum Hollow Creek Resulting in Unpermitted Discharge Due to Failure to Identify & Revise All Appropriate Procedures.Procedure GP-3 to Be Revised ML20086E4981991-11-22022 November 1991 NPDES Noncompliance Notification:On 911016 Underground Fire Water Pipeline Inadvertently Punctured by Contractor Backhoe Ram During Excavation of Trench.Caused by Inadequate Review of Required Prints.Backhoe Ram Operator Terminated ML20082L9871991-08-28028 August 1991 NPDES Noncompliance Notification:On 910707 & 19,electrical Storm Caused Loss of Power to Bedminster Water Processing Facility & Tripped Chillers.On 910721,discharge Temp Exceeded Permitted Limits.Permit Limits Changed ML20217C2131991-07-0808 July 1991 NPDES Noncompliance Notification:On 910629,chillers at Bedminster Water Processing Facility for Bradshaw Reservoir Tripped Due to Unexpected Failure of Logic Control Unit. Chiller Control to Primary Computer Restored ML20077G5771991-06-20020 June 1991 NPDES Noncompliance Notification:On 910528,chiller C at Bedminster Water Processing Facility Tripped Due to High Vibration & Temp at Discharge 001 Exceeding Permitted Instantaneous Temp.Discharge Temp Setpoint Lowered ML20077D8701991-05-17017 May 1991 NPDES Noncompliance Notification:On 910512,cooling Tower Experienced Failure,Causing Large Vol of Cooling Tower Water to Bypass Normal Blowdown Discharge Pathway.Cooling Tower Will Be Inspected During mid-yr Outage ML20070S3071991-03-22022 March 1991 NPDES Noncompliance Notification:On 910204,discovered That Misalignment of Diverter Valve to Outfall 003 May Have Allowed Mixture of Storm Water & Steam Condensate to Be Released from Outfall.Valve Repositioned ML20065M6811990-11-29029 November 1990 NPDES Noncompliance Notification:On 901003,routine Weekly Discharge 001 Sample Exceeded Max Permit Limits for Grease & Oil.Sample Contained 43.7 Mg Per Liter of Oil & Grease. Abnormal Reading Believed to Be Caused by Oily Silt 1999-04-27
[Table view] Category:TEXT-ENVIRONMENTAL REPORTS
MONTHYEARML20206C9871999-04-27027 April 1999 NPDES Noncompliance Notification:On 990319,station Personnel Observed Foam Emanating from Manhole Vent Associated with Outfall 001,no Foam Was Observed on Any Waterway.Caused by Inappropriate Addition of Betz 3625 to Spray Pond ML20207D6171999-02-26026 February 1999 NPDES Noncompliance Notification:On 990111,discovered That Weelkly Analysis for non-oxidizing Biocide Betz 3625 Was Not Performed.Caused by Sample Being Inappropriately Delayed for Future Chemical Addition.Counseled Individuals Involved ML20202F0591999-01-19019 January 1999 NPDES Noncompliance Notification:On 990112,Auxiliary Boiler Source Number OAS502 Found to Have Malfunctioning Opacity Monitor.Caused by Stepdown Transformer within Power Supply. Power Supply Replaced ML20206E2161998-12-31031 December 1998 1998 Annual Environ Operating Rept (Non-Radiological) for Limerick Generating Station,Units 1 & 2 ML20205T0581998-12-31031 December 1998 Annual Radiological Environ Operating Rept 15 for 1998 ML20206R3491998-12-21021 December 1998 NPDES Noncompliance Notification:On 981102,500 Gallons of 12% Sodium Hypochlorite Released to Environ.Caused by Failure of Tank Discharge Fittings & Subsequent Leaks from Secondary Containment.Culvert Was Flushed Repeatedly ML20198J2811998-12-21021 December 1998 NPDES Noncompliance Notification:On 981102,release of 500 Gallons of 12% Sodium Hypochlorite to Environment Occurred. Caused by Failure of Tank Discharge Fittings.Integrity Testing Will Be Performed on All New Tanks.With ML20236V2001998-07-27027 July 1998 NPDES Noncompliance Notification:On 980619,geometric Mean Coliform Concentration Calculated to Be 223 Colonies Per 100 Ml.Sample Procedure Enhanced to Ensure Normal Operating Conditions ML20248C9461998-05-27027 May 1998 NPDES Noncompliance Notification:On 980414,total Iron Discharge Through Outfall 001 Exceeded Limits Set in Ltr Dtd 960508.Total Iron Discharge Limit Exceeded During Cleaning Evolution.Limit Revised ML20217N6921998-02-27027 February 1998 NPDES Noncompliance Notification:On 980107 Net Total Suspended Solids (TSS) for Units 1 & 2 Cooling Towers at Outfall 001 Exceeded NPDES Permit Daily Limit of 60 Ppm. Caused by Contaminated Sample Lines.Replaced Tygon Tubing ML20203H1911997-12-31031 December 1997 Annual Effluent Release Rept 23 for Jan-Dec 1997 ML20216F3371997-12-31031 December 1997 Annual Environmental Operating Rept (Non-Radiological) for 970101-1231 ML20203L5691997-12-31031 December 1997 Occupational Exposure Tabulation Rept for LGS Units 1 & 2 for 1997 ML20203H2201997-12-31031 December 1997 Tower 1 Joint Frequency Distributions of Wind Speed & Direction by Atmospheric Stability Class Rept 13 for 1997 ML20217P1941997-12-31031 December 1997 Annual Environ Operating Rept (Non-Radiological) for Jan-Dec 1997, for LGS Units 1 & 2 ML20217M6471997-12-31031 December 1997 Annual Radiological Environ Operating Rept 14,Jan-Dec 1997 for Limerick Generating Station,Units 1 & 2 ML20141G0271997-06-27027 June 1997 NPDES Noncompliance Notification:On 970512,sample for Kjeldahl Omitted Due to Personnel Error.Counseled Individual Responsible.On 970521,Net TSS Exceeded NPDES Daily Limit Due to Fouled Sample Tubing.Replaced Sample Tubing ML20137M5511997-03-27027 March 1997 NPDES Noncompliance Notification:On 970228,flow Integrator Used to Measure Spray Pond Effluent Flow Was Identified to Be Malfunctioning & Declared Inoperable Due to Lodged Debris.Revised Procedure for Spray Pond Effluent Flow ML20134G3241997-01-31031 January 1997 NPDES Noncompliance Notification:On 970108,util Informed NRC That PA Dept of Environ Protection Granted Approval for Temporary Discharge at Lgs,Per 961219 ML20135D0161996-12-31031 December 1996 Occupational Exposure Tabulation Rept for LGS Units 1 & 2 for 1996 ML20148B6671996-12-31031 December 1996 LGS Units 1 & 2 Annual Radiological Environ Operating Rept 13 for 960101-1231 ML20135C7691996-12-31031 December 1996 1996 Annual Effluent Release Rept No 22 ML20138J5291996-12-31031 December 1996 Annual Environ Operating Rept (Non-Radiological) for Jan- Dec 1996 ML20135C7731996-12-31031 December 1996 1996 Annual Tower No 1 Joint Frequency Distribution of Wind Speed & Direction by Atmospheric Stability Class Rept No 12 ML20138G9651996-12-24024 December 1996 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 ML20135A5851996-11-27027 November 1996 NPDES Noncompliance Notification:On July-Sept 1996 Re NPDES Limit for Fecal Coloform Concentration Not Met.Caused by Inadequate Gasket Installation.Ozonators Overhauled to Ensure Peak Performance ML20134E0641996-10-28028 October 1996 NPDES Noncompliance Notification:During Month of Sept 1996, NPDES Limit for Fecal Coliform Concentration at Discharge of Bradshaw Reservoir Pumps Was Not Met.Caused by Leaking Gaskets on Ozone Gas Diffusers.New Gaskets,Installed ML20129E5681996-09-27027 September 1996 NPDES Noncompliance Notification:On 960805,geometric Mean of Fecal Coliform Concentration Calculated to Be 641 Colonies Per 100 Ml.Cause Suspected to Be Due to Malfunctioning Ozone Disinfection Sys.Adjustments to Sys Have Been Made ML20129E5411996-09-26026 September 1996 NPDES Noncompliance Notification:On 960812,discharge Observed from Unit 2 Cooling Tower Overflow to Outfall 021. Caused by Personnel Error in Performing Required Analysis of Cooling Tower Overflow Sample.Individual Counseled ML20117G7071996-08-23023 August 1996 NPDES Noncompliance Notification:On 960715,geometric Mean of Fecal Coliform Concentration Exceeded NPDES Permit Limit. Caused by Leaking Seals on Ozone Diffusers.Temporary Adjustments Made to Ozone Gas Flow Balance ML20116B3851996-07-24024 July 1996 NPDES Noncompliance Notification:On 960602 Identified Ph Levels Exceeded NPDES Permit Limitations.Caused by Natural Biological activity.CO2 Injection Established,Maintained & Monitored Until 960612 ML20115G1151996-07-12012 July 1996 NPDES Noncompliance Notification:On 960619,resulting Net TSS Value 82.8 mg/1,exceeded Max Daily Limit of 60 Mg/L.Caused by Excessive Storm Water Runoff.Net TSS Revised ML20113C4451996-06-24024 June 1996 NPDES Noncompliance Notification:On 960318,flow Integrator Used to Measure Spray Pond Effluent Flow Declared Inoperable.Caused by Faulty Flow Integrator.Frequency of Use of Instrument Changed to Daily as Stated in Issue Number ML20108A3801996-04-28028 April 1996 NPDES Noncompliance Notification:On 960223,identified Seven Issues of Administrative non-compliance/ambiguity W/Permits. Caused by Inadequate Administration.Individuals Gained Better Understanding W/Guidance ML20108A3671996-04-28028 April 1996 NPDES Noncompliance Notification:On 960314,personnel Observed Sewage Overflowing from MH-07 & Into Storm Drain W-4.Caused by Blockage of Pipe Section Between MH-07 & MH-08.Sewer Contract Svc Pressure Cleaned ML20101K4661996-03-28028 March 1996 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 ML20100P6311996-02-28028 February 1996 NPDES Noncompliance Notification:On 951108,discharge 001 Net TSS in Excess of Maximum Daily Limit.Caused by Flaw in Methodology to Calculate Net TSS concentration.Follow-up Composite Samples Taken ML20108C9281995-12-31031 December 1995 LGS Units 1 & 2 1995 Annual Environ Operating Rept (Non- Radiological) Jan-Dec 1995 ML20100L8861995-12-31031 December 1995 Annual Effluent Release Rept 21,Jan-Dec 1995 ML20108B7391995-12-31031 December 1995 Annual Radiological Environ Operating Rept 12 Jan-Dec 1995 ML20100L8961995-12-31031 December 1995 Tower 1 Joint Frequency Distributions of Wind Speed & Direction by Atmospheric Stability Class 1995 Rept 11 ML20080N1061994-12-31031 December 1994 Annual Effluent Release Rept 20 Jan-Dec 1994 PECO Energy LGS Units 1 & 2 ML20082N5061994-12-31031 December 1994 Annual Environ Operating Rept ML20087H7231994-12-31031 December 1994 Annual Radiological Environ Operating Rept 11 for Jan-Dec 1994 ML20080N1121994-12-31031 December 1994 Tower 1 Joint Frequency Distributions of Wind Speed & Direction by Atmospheric Stability Class 1994 Rept 10 ML20072R4601994-08-31031 August 1994 NPDES Noncompliance Notification:On 940708 & 0815,Discharge 001 Total Zinc Concentrations Exceeded Max Daily Limitations.Daily Zinc Trending Analysis Will Be Upgraded & Chemistry Technician Involved in 940815 Event Counselled ML20071L1761994-07-27027 July 1994 NPDES Noncompliance Notification:On 940609,zinc Analyses Indicated That Discharge 001 Total Zinc Levels in Excess of Max Daily Limitations in Both Cooling Towers.Daily Zinc Control Limits Will Be Administratively Maintained Lower ML20149E7291994-07-26026 July 1994 NPDES Discharge Monitoring Rept:On 940713,approx 18 Gallons of Betz Clamtrol CT-1 Inadvertently Released from Injection Sys Located South of LGS Spraypond Pumphouse.Caused by Break in Pump Discharge Line.Polyethylene Piping Replaced ML20065B9221994-03-25025 March 1994 NPDES Noncompliances Notification:On 940204,discharge 001 Maximum Daily Limit of 1.0 mg/1 Total Zinc Was Exceeded. Caused by Low Ph Transient in Unit 2 Cooling Tower Water Sys.Isolated Acid Injection Sys ML20064C7701994-02-25025 February 1994 NPDES Noncompliance Notification:On 940116 & 17 Manual Reactor Scram Occurred.Caused by Failure to Adequately Throttle Cooling Tower Bypass Valves.Procedure Revised 1999-04-27
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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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- , ce;
- 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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