ML20046B805

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

ML20046B805
Person / Time
Site:	Limerick
Issue date:	07/29/1993
From:	Boyce R PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Noll P PENNSYLVANIA, COMMONWEALTH OF
References
NUDOCS 9308060238
Download: ML20046B805 (5)

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. PHILADELPIHA ELECTRIC COMPANY h LIMER]CK GENERATING STATION P. O. BOX 2300 SANATOGA, PA 19464-2300 (215) 327-1200 EXT, 2000 ROBERT W. BoYCE etAur umcER July 29, 1993 j LIMERICK CENERATING STATION l

Mr. Peter G. Noll Department of Health Neshaminy Manor Center l '

Doylestown, PA 18901

Subject:

Noncompliances with NPDES Permit Bradshaw Reservoir NPDES Permit No. PA-0052221 l l

Dear Mr. Noll:

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During the month of June 1993, six noncompliances with NPDES  !

Permit No. PA-0052221, Bradshaw Reservoir, occcrred. Each

! noncompliance is described below including the causes and corrective actions.

1. DESCRIPTIONS OF THREE TEMPERATURE LIMITATION-NONCOMPLIANCES

a. On June 18, following a trip of the Bradshaw Reservoir pumps, the Bedminster Water Processing Facility (WPF)' chillers shutdown as designed on low facility inlet flow. A delay'in the restoration of the WPF chillers caused the discharge temperature to exceed the permitted maximum limitation of 74 degrees F between 1200 and 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br /> with a maximum temperature of 75.4 degrees F.

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b. On June 20 at 2116 hours0.0245 days <br />0.588 hours <br />0.0035 weeks <br />8.05138e-4 months <br />, an electrical storm caused a loss 1 of power to the Bedminster WPF chillers, the Bradshaw Reservoir Pump Station, and the Point Pleasant. Pumping i Station. Operations personnel responded and operators were i dispatched to the facilities; however, adequate steps were i not taken to restore the chillers to service by reclosing l electrical breakers for the WPF chillers. A Bradshaw Pump _

i was restarted at 2359 hours0.0273 days <br />0.655 hours <br />0.0039 weeks <br />8.975995e-4 months <br /> to restore flow to the East Branch Perkiomen Creek. On June 21 at approximately 0645 hours0.00747 days <br />0.179 hours <br />0.00107 weeks <br />2.454225e-4 months <br />, the chillers were returned to service and by 0700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> discharge temperature was less than 74 degrees F. As a result of a delay in the restoration of the WPF chillers, the WPF discharge temperature exceeded the permitted maximum limitation'of 74 degrees F between 2359 hours0.0273 days <br />0.655 hours <br />0.0039 weeks <br />8.975995e-4 months <br /> on June 20 and .l $

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.I 0700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> on June 21 with a maximum temperature of 79.5 degrees F. t I

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Additionally, at about 1030 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.91915e-4 months <br /> on June 21, plant personnel i determined that the' discharge temperature control setpoint  ;

for the WPF chillers had changed from 72 degrees F to 75.5 l degrees F. As a result, the WPF chillers were maintaining j

the discharge temperature at approximately 75 degrees F from {

0900 to 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> on June 21. The setpoint change was l concluded by plant personnel to be the result of the  !

electrical storm disturbances. The setpoint change incident I had never occurred previously, and was concluded to be an  ;

isolated occurrence. The WPF chiller setpoint was lowered to. l 72 degrees F at 1030 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.91915e-4 months <br />, and the discharge temperature '

stabilized below the permit limit by 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />.

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c. On June 27, plant personnel again identified that the i Bedminster WPF discharge temperature setpoint had changed i from 72 degrees F_to 75.5 degrees F. This resulted in the  ;

discharge temperature exceeding the permitted maximum i limitation of 74 degrees F between 0700 and 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> with a  !

maximum temperature of about 75 degrees F., The WPF chiller  !

setpoint was lowered to 72 degrees F and the discharge  !

temperature stabilized below the permit limit.

CAUSES OF THE NONCOMPLIANCES' o The cause of the delay in the restoration of the WPF  !

chillers discussed in noncompliances la and^1b was the  ;

lack of adequate training and written instructions to t Operations personnel regarding the necessary prompt  ;

restoration of the WPF chillers following a trip. [

o A contributing factor to the noncompliance discussed in la was the frequent tripping of_the Bradshaw pumps which had been occurring over the preceeding several days for  !

indeterminate reasons. Each trip challenges operators _j to promptly respond in order te control WPF chiller  ;

dischange temperature.

I o The cause of the discharge temperature setpoint change j which occurred in noncompliances 1b and Ic was 'l

-incorrectly concluded to be the result of electrical i storm disturbances. An investigation performed by a WPF-computer specialist on June 27, determined that the electrical storm on June _20 did not cause the WPF ,

computer malfunction. The investigation ~ revealed that ')

the WPF computer temperature control setpoint change '

occurred as a result of a programming deficiency in the WPF computer software. j 1

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Page 3 l PREVENTION OF FUTURE OCCURRENCES ,

o Training was given to appropriate Shift Operations personnel regarding WPF chiller restoration following a e trip, WPF chiller system status recognition utilizing the WPF computer, and the required operator actions to i be implemented in the event the discharge temperature i control setpoint cannot be maintained below 74 degrees ,

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o Additional written instructions were issued to Operations personnel specifying the necessary prompt, complete responses to Brad' haw Reservoir and Bedminster i WPF system trips, and loss of power events.

o Station Management stressed to Operations Supervision l the importance of immediate responses to Bradshaw  ;

Reservoir and Bedminster WPF system problems. l o To address the contributing factor identified for j noncompliance la, internal and external power and 1 control circuits at the Bradshaw facility.are being  !

monitored via event recorders to identify and isolate i the component failures ce_ sing the frequent tripping of the Bradshaw pumps. The appropriate corrective action j will be taken (e.g., replacement or design change) based on the information gatnered.  ;

o On June 27 at 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br />, numerous WPF computer software i I

programming changes were incorporated to ensure that the discharge temperature control setpoint cannot change to ,

a value which is greater than 74 degrees F without j manual manipulations. i l

o The revision to the NPDES permit in response to our j thermal variance request is pending issuance following  :

the 30 day public comment period. Once issued, ,the WPF '

chiller operation will no longer be required since there _

will be no thermal limits.

2. DESCRIPTIONS OF TWO pH LIMITATION NONCOMPLIANCES-

a. On June 19 at 0200 hrs, Operations. personnel identified-that the 'Bedminster WPF discharge pH exceeded the' permitted

. maximum limitation of 9.0 at 2300 hours0.0266 days <br />0.639 hours <br />0.0038 weeks <br />8.7515e-4 months <br /> on June 18. The pH j of the discharge exceeded 9.0 through 0800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> on June-19, with a maximum pH of 9.2.

't In response to the identified increasing trend in pH over..the previous day, a temporary carbon dioxide (CO2) injection

-system was installed at the Bradshaw Reservoir in 'rder'to l avoid high pH however,-the initial CO2 flow rate vos insufficient. The CO2 flow rate was increased to its  ;

maximum, and the pH stabilized below the permit limit at 0800 H hours on June 19. j e

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'b. On the evening of June 19, Operations personnel identified that the WPF discharge-pH permit limit of 9.0 was again being exceeded-(between 1900 hours0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br /> on June 19, and 0500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> on June 20, with a maximum pH of 9.2). At 2330 hours0.027 days <br />0.647 hours <br />0.00385 weeks <br />8.86565e-4 months <br /> on June 19 a manual grab sample was taken to confirm the indicated pH.

CAUSE OF THE NONCOMPLIANCES The cause of both noncompliances was determined to be the result of natural biologial activity enhanced by a raw sewage spill into the Delaware River which occurred on June 12, in the area of Easton, PA. Delaware River pH was equally elevated during this period of time.

PREVENTION OF FUTURE OCCURRENCES A second temporary CO2 sparger and additional-CO2 tanks were installed on June 22, to increase CO2 injection capability.

Since the occurrence on June 19, the natural biological activity has subsided, and pH values have remained below the permit limit. Presently, CO2 injection is not being.

performed.

3. DESCRIPTION OF ONE CADMIUM LIMITATION NONCOMPLIANCE' On June 22, the results of a cadmium grab sample _from June 8, were received and the concentration was slightly greater than the permit daily average limit of 0.0022 mg/L. The actual value was 0.0023 mg/L. This parameter was resampled on three more occasions and in each case-the value was less than 0.0022 mg/L. The monthly average was 0.00054 mg/L.

Inadvertently, this permit limit exceedance was not recognized as a 24-hour reportable condition. Notification was made on July 21.

CAUSE OF THE NONCOMPLIANCE o The cause of the honcompliance is suspected to be the result of a natural occurrence in the Delaware River, o The reason why this noncompliance was not identified as reportable on June 22, was due to an oversight by the System Manager.

PREVENTION OF A FUTURE OCCURRENCE No'long term corrective actions to prevent recurrence are planned.

Notifications of these noncompliances.were made to the Department of Health pursuant to NPDES permit requirements. In each instance, the requirement for submittal of a 5-day report was L

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' waived by the Department.and therefore, the required written  !

report is being submitted in this letter.  !

If you have any-questions please contact Jim Kantner at 327-1200 ' tl extention 3400.

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.i Sincerely, i

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.i DMS:cah cc: U.S. Nuclear Regulatory Commission l Document Control Desk  !

Docket Nos. 50-352/50-353 .

Washington, D.C. 20555 1 l

T. T. Martin Administrator, Region I, USNRC I Docket Nos. 50-352/50-353 N. S. Perry j USNRC Senior Resident Inspector, LGS e Docket Nos. 50-352/50-353  ;

J. A. Feola -

Pennsylvania Department of Environmental Resources j Regional Water Quality Manager I Lee Park, Suite 6010 .

555 North Lane l Conshocken, PA 19428  !

Program Management Section (3WM52) .

Permits Enforcement Branch. ' '

, Environmental-Protection Agency }

Water Management-Division ,

. Environmental Protectior. Agency -j Water Permits Section Region'III ,

841 Chestnut Building *

-Philadelphia, PA 19107 ,

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