ML20058H287

NPDES Noncompliance Notification:On 900905,routine Weekly Sample Collected from Holding Pond Exceeded Limits.Caused by Release of Oil from Pond Surface Prior to Discharge Termination

ML20058H287
Person / Time
Site:	Limerick
Issue date:	10/26/1990
From:	Mccormick M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Bauer R PENNSYLVANIA, COMMONWEALTH OF
References
NUDOCS 9011150130
Download: ML20058H287 (3)

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. PHILADELPHIA ELECTRIC COMPANY LIMERICK GENER ATING ST ATION P. O. DOX A SAN ATOG A. PENNSYLV ANI A 19464 tris) s N oo m. : October 26, 1990 M. J. M.CO M MIC M. J h.. P.E. l

... . . . '2 0 ' .".'.".'U *. . . . ..

Mr. Robert Hauer, Jr.

Department of Environmental Resources Bureau of Water Quality Management -

1875 New Hope Street Norristown, PA 19401 EUBJECT: Noncompliance with NPDES Permit Limerick Generating Station NPDES Permit No. PA-0051926 Dear Mr. Bauert.

DESCRIPTION OP NONCOMPLIANCE

On September 5, 1990 a routine weekly sample was collected ,

l from the'Holdin; Pond (Discharge 201) sample point and sent to the Corporate Chemistry Laboratory to be analyzed for oil and grease. The sample result was 40.3 mg/1, which exceeded the .

instantaneous and daily maximum permit limits of 30 mg/1-and  !

20 mg/1, respectively, for oil and grease in the Holding Pond t

discharge. The calculated monthly average for oil and grease for  !

l' the month of September was 16.7 mg/1, which exceeded the monthly average. permit limit of 15 mg/1. The quantity of oil and grease in the September 5 sample was the primary reason for exceeding l

this monthly average permit limit for the Holding Pond discharge. ,

CAUSE OF THE NONCOMPLIANCE l

! The Holding Pond discharge system is normally operated to discharge water that is below the surface and above the sludge level. The-. surface of the pond occasionally contains small l

quantities of oil carried over from the oil separators and/or released from underlying layers of settled sludge. The discharge l of the oil is normally prevented by use of an oil absorbent boom and by terminating the discharge prior to release of any surface water. Discharges from the pond are also monitored to prevent the water level from approaching the sludge surface. At the time 0%

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d Mr. Robert Bauer, Jr. Page 2 of 3 October 26, 1990 that the September 5 sample was collected, the water level in the Holding Pond was approaching the settled sludge. Turbulence created by the discharge flow draining out of the pond caused an oil film to form on the surface. This noncompliance was caused by the release of some oil from the surface of the pond prior to discharge termination.

DURATION OF THE NONCOMPLIANCE The period of noncompliance began at approximatell 0800 on September 5, 1990, when the Holding Pond discharge was approaching the termination point. The noncompliance period ended at 0930 , when the Holding Pond discharge valve was closed.

The duration of the noncompliance was approximately 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, during which about 52,000 gallons of waste water were released from discharge 201 into the 001 discharge line.

CORRECTIVE ACTION Upon receiving the analytical result for this Holding Pond

' oil and grease sample, a visual inspection of the facility revealed that the settled sludge level was close to the water level where the Holding Pond discharge is terminated. Based on this observation, plant personnel were requested to have all Holding Pond discharges terminated at a level of four feet, which is sufficiently above the sludge surface. This recommendation has been implemented by Operations and the information has been disseminated to shift personnel. Since the noncompliance, the existing oil boom has been replaced with a new boom to improve oil removal.

PREVENTION OP PUTURE OCCURRENCES The Maintenance Department has given a high priority to the procurement of a contractor to accomplish the removal of sludge from the Holding Pond. The System Engineers will initiate a Maintenance Request Form to have the sludge pumped out of the Waste Water Settling Basin, which is in-line ahead of the Oil Separators and the Holding Pond. This will improve control of solids entering the pond and increase the efficiency of the oil separators. The System Engineers are investigating the best method for determining the sludge levels in the Holding Pond and the Waste Settling Basin. This method will be incorporated into the appropriate station operating and routine inspection procedures and will be utilized in determining when to terminate Holding Pond releases and also, when to clean the Holding Pond and Waste Settling Basin. This is expected to be completed by December 15, 1990. There is an existing routine inspection procedure for the oil separators that ensures that the oil separators are adequately maintained and cleaned. Furthermore, plant training programs will be reviewed and revised as necessary l

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Mr. Robert Bauer, Jr. Page 3 of 3 October 26, 1990 i

to incorporate detailed information about our NPDES permit requirements, the plant systems that are utilized to meet these requirements, and conditions and problems that adversely affect the proper operation of these plant systems. These' actions are intended to prevent oil and grease from reaching the Holding Pond and any subsequent discharge violations.

Sincerely, N.(f.McCormick,Jr.

Plant Manager JCE/DBNive

.cct 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 Senior Resident Inspector, USNRC T. J. Kenny, Limerick, M/C A2-5 Program Management Section (3WM52)

Permits Enforcement Branch Water Management Division ,

Environmental Protection Agency Water Permits Section '

Region.III 841 Chestnut Building Philadelphia, PA 19107 t

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