ML20246N028

NPDES Noncompliance Notification:On 890714,unpermitted Discharge to Outfall 009 Occurred.Enhanced Administrative Controls Implemented to Ensure Spray Pond Level Maintained Such That Blowdown Occurs at Controlled Rate

ML20246N028
Person / Time
Site:	Limerick
Issue date:	08/31/1989
From:	Mccormick M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Bauer R PENNSYLVANIA, COMMONWEALTH OF
References
NUDOCS 8909080021
Download: ML20246N028 (5)

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iNL. Y; PHILADELPHIA ELECTRIC CCMPANY.

LIMERICK GENER ATING STATION P. O. BOX A SAN ATOG A. PENN5Y LV ANI A 19464 August _31, 1989 Mr. Robert:Bauer,1 Jr.

Department of Environmental Resources Bureau of Water Quality Management 1875 New Hope Street Norristown,.PA 19401

Subject:

Unpermitted Discharge Li Outfall 009, Limerick Generating Station, NPDES Permit No. PA-0051926

Dear Mr..Bauer:

This letter is a follow-up to the incident documented in the July'19, 1989 Noncompliance letter. The referenced letter has been attached for your convenience.

Enhanced administrative controls.have been implemented to ensure spray pond level is maintained such that blowdown occurs at a controlled. rate. These controls involve changes to the

-Emergency Diesel-Generator Test Procedure to manually isolate Service Water from-the Emergency Service Water (ESW) Pump Suction. The ESW pumps will then only take suction from the -

' Spray Pond.and return that water to the Spray Pond, thereby eliminating the increase in Spray Pond water level due to the periodic Diesel Generator Testing. -

In addition, a design change is being evaluated to reposition the. strainer in the blowdown line to.the blowdown pipe inlet in order to reduce flow restriction in the pipe. This design change will take advantage of the spray ponds surge capacity and improve control of the discharge rate from the pond. This evaluation will-be complete and appropriate changes implemented by October 1, 1989.

These actions should prevent recurrence of this incident in.

the future.

Sincerely, f

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M.G. Mccermick, Jr .C-,

g7) Plant Manager RSU:kaa 7 8909080021 890831 PDR ADOCK 05000352 S PDC

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Page 2 cc: U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Administrator Region I Office of Inspections and Enforcement U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Station Resident NRC Inspector Tom Kenny, M.C. #NRC Program Management Section (3WM52)

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

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u PHILADELPHIA ELECTRIC-COMPANY LIMERICK GENER ATING STATION P.O.90X A SAN ATOG A. PENNSYLV ANI A 19464 y;

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July 19,l1989 l ,.

Mr.' Robert Bauer, Jr.

Department'of Environmental Resources I

'. Bureau of. Water-Quality Management 1875 New Hope Street Norristown, PA 19401

Subject:

Unpermitted Discharge to Outfall 009, Limerick Generating Station, NPDES Permit No. PA-0051926 i-

Dear Mr..Bauer:

q On ~ July 14,- 1989 at approximately 3:00 p.m. oral i notification of a non-compliance with the provisions of our l NPDES permit was given ' to Mr. Norld Leyland.- Upon completion l of our preliminary investigations an hour later, the details 1 of the non-compliance were presented to Mr. David Burke. j At 1100 that.same day, water was observed to be flowing i from the spray pond blowdown manhole. Routine surveillance of the manhole was in place due to past overflow problems.  !

A subsequent inspection of outfall 009, which ultimately l

-would collect- this overflow, revealed water ' flowing at- l approximately 25 gallons per minute. Upon checking the j spray. pond, it was discovered that the level had risen three  ;

inches since the previous afternoon. A barrier was in use .l that .would allow controlled pond discharge at a rate that j the normal drain line could handle, yet still prevent level increases that-would overflow the shoreline. The.three inch

. increase brought the level above that of the barrier. While this prevented overflowing pond edges, it produced greater flow than the normal drain line was designed for. This resulted- in overflow from an associated manhole, and ultimate discharge through outfall 009. 1 l

.The- discharge from outfall 009 was stopped at l l approximately-ll45 by repositioning the barrier to account l 1 for the level change. The level of the pond was then l

lowered by pumping the water to the Unit 1 cooling tower.

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Subsequent investigations revealed that one of several L. ~intertie valves between our Emergency Service Water (ESW)

L system, which operates from'the Spray Pond, and our normal-service water system, which operates from a cooling tower, was left open. .This' allowed water to flow into the spray c ~ pond'at approximately 700 ' gallons 'per minute. The=.ESW system was in operation for approximately three hours before the discharge was terminated. We determined based on the visual observations at 009, the estimated total discharge

. was 5000 gallons. . However, as mentioned-to Mr. Burke,.there is approximately 100 yards of land between the outfall-and the river.~ Therefore,-it is very unlikely that any of this water actually entered the river. The discharged water was of pH 8c5 and.of discharge quality for the normal outfall 001.

>Although. this is a recurrence of a similar event in April 1989, the corrective actions taken at that time, and the . heightened awareness of the situation, substantially decreased the extent- of the discharge. This recurrence appears. to. be due in part to a procedural deficiency. A meeting is planned to discuss this event and to develop corrective actions to prevent recurrence. We will inform you of these actions by September 1, 1989.

Sincerely, 4 <

[g M. J. McCormick, Jr.

v Plant Manager SCD:sjm sed 7/14/89.1 cc: U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Administrator Region I office of Inspections and Enforcement U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Station Resident NRC Inspector Tom Kenny, M.C. #NRC

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