ML20006F545

NPDES Noncompliance Notification:On 900129 & 0202,samples Taken Above Permit Limit of 1 Mg/L.Caused by Excessive Amount of Suspended Solids in Makeup Water Due to Extensive Rainfall.Sampling Program Being Explored

ML20006F545
Person / Time
Site:	Limerick
Issue date:	02/20/1990
From:	Mccormick M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Bauer R PENNSYLVANIA, COMMONWEALTH OF
References
NUDOCS 9002280144
Download: ML20006F545 (3)

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l PHl.LADELPHIA ELECTRIC COMPANY  :

2301 M ARKET STREET )

P.O. BOX 8699 PHILADELPHI A. PA.19101 t

1215) 8414ooo i February 20, 1990 i

Hr. Robert Bauer, Jr.

Department of Environmental Resources Bureau of Water Quality Hanagement ,

1875 New Hope Street >

Norristown, PA 19401

SUBJECT:

Noncompliance with NPDES Permit  !

Limerick Generating Station NPDES Permit No. PA-0051926 l

Dear Mr. Bauer:

DESCRIPTION OF NONCOMPLIANCE During the period between 1/29/90 and 2/2/90 seven samples were collected from Discharge Point 001 and analyzed for total zinc. Two of the seven samples taken were above the permit limit of 1.0 mg/1. Both samples were collected on 1/31/90 and the results were 1.1 and 1.6 mg/1. Station personnel received this noncompliance information after 4:00 PM on 2/7/90. A representative of the DER was contacted on 2/8/90 to notify you about this incident. A waiver of the  :

reporting requirements was granted to allow this noncompliance letter to be submitted with January's Discharge Monitoring Report.

CAUSE OF THE NONCOMPLIANCE

The scheduled weekly sampling day for Discharge Point ,

001 was 1/31/90. A review of the Chemistry balance of plant

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data for that day indicates that total zinc, as determined by our colorimetric test, was within our administrative limits. However, due to extensive rainfall the previous

! day, the amount of of suspended solids in the make-up water was excessively high.

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Further analyses revealed that the iron levels in the i

' samples taken on 1/31/90 were considerably higher than that ,

which would be expected due to the river water contribution  !

On and also much higher than the norr.a1 levels found in cooling  !

tower samples. This information leads us to believe that unusually high amounts of suspended solids and pipe l l-corrosion products were washed into our samples which caused '

a positive error in our analysis results. Our routine daily flushing of the 001 sample line that was implemented after i our previous total zine noncompliance was not sufficient under these unusual conditions to purge all the accumulated I solids and resulting zine from the sample line. 1 This explanation is further substantiated by the results of five additional samples from 001 Discharge, taken on j 2/2/90 during more normal river and cooling water conditions, which were all 0.8 to 0.9 mg/1. During the period between 1/31 and 2/2, chemical treatment rates did not change significantly.

I DURATION OF THE NONCOMPLIANCE Due to a sy;pected plant problem, the five additional samples for total zine were collected on 2/2/90 and sent to the off-site laboratory for analysis. The results, which are all less than our total zine limit of 1.0 mg/1, indicate that our period of noncompliance did not exceed 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

The River Water Usage Log data sheet for this period shows that 17.8 million gallons of cooling water was discharged.

However, based on the reasons stated previously, we do not >

feel that the total zine concentration in our 001 Discharge was actually in excess of the permit limit.

CORRECTIVE ACTION No immediate corrective actions were taken on the day of the noncompliance because no knowledge of the event was available on that day. Additionally, our daily total zine analysis results and chemical addition

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rates did not indicate there was any problem with the cooling water zine levels on 1/31/90.

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PREVENTION OF FUTURE OCCURRENCES '

i Several aspects of our sampling program are being explored. Presently, sample line flow is being left at a constantly high rate which may preclude the need for flushing once the line has been properly conditioned. In addition, we have implemented a program that utilizes our on-site DCP instrument to identify nonrepresentative samples '

before the sampling day has ended, so that prompt resampling, analysis and corrective action can occur. ,

Finally, concurrent samples are being taken directly from each cooling tower blowdown weir. Provided that we i have verified that additional wastes are not being i discharged into 001 from other sources, these samples will {

give an accurate measure of total zine being discharged, for '

comparison to our 001 sample point results. I Sincerely, jg .

H.J. McCormick, Jr. ,

Y Plant Manager JCE cc U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Administrator Region I U.S. Nuclear Regulatory Commission ,

475 Allendale Road King of Prussia, PA 19406 Station Resident NRC Inspector Tom Kenny, H.C.# NRC Program Management Section (3WH52)

Permits Enforcement Branch Water Management Division

( Environmental Protection Agency 0 Water Permits Section Region III 841 Chestnut Building Philadelphia, PA 19107 l