ML20059M439
| ML20059M439 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 09/24/1990 |
| From: | Mccormick M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Bauer R PENNSYLVANIA, COMMONWEALTH OF |
| References | |
| NUDOCS 9010040179 | |
| Download: ML20059M439 (3) | |
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PHILADELPHIA' ELECTRIC COMPANY -
2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 t21si e414ooo j
September 24,1990
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Mr. Robert Bauer, Jr.
Department.of Environmental' Resources.
Bureau of Water Quality Management 1875 New Hope Street Norrisuown, PA 19401
SUBJECT:
Noncompliance with NPDES Permit Limerick Generating Station NPDES Permit No. PA-0051926 Dear tir.. Bauer i
DESCRIPTION 09 NONCOMPLIANCE 1
During the August reporting
- period, five. samples were.
collected from nischarge Peint 001 and analyzed for total
- ine.
One es ve samples'taken was above the permit limit of 1.0 m <'.
The sample was collected on 8/22/90 and 1
analyzed on
/30,90.
The result of 1.2 mg/l was received.by Station per,nnel on 10/90.
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CAUSE OF T'
.s E
'A review of the c4ta for the month of August indicated that i
total zinc, as de: ermined by our colorimetric test,-
was i
within our administ.ative limit. The analysis results. for
-each cooling tower's
- blowdown, taken on 8/22/90, and'
-i analyzed by the Ni 'F 3 approved method, did not support the result reported tor the 001 Discharge sample.
Zinc l
concentrations in Unit 1
and Unit 2
Cooling Towers on' 8/22/90 were 0.71 mg/l and 0.78 mg/l respectively.
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DURATION OF THE NONCrHPLIANCE The River Water-Usage Log data $2eet for this day shows that 9.9 million 9allone of cooling water was discharged.
However, basrd xn gdditional sample' data stated previously, weLdo not feti thaq the total cine concentration in our 001 Discharge *?a Xctually in excess'of the permit limit.
C,QHRECTIVE 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 rates-on 8/22/90 did not indicate there was any problem with the cooling water sinc levels.
It is therefore our belief that this sample was not representative of the actual discharge on that
- day, and that actual cine levels were'within the Limerick NPDES Permit limits.
PREVENTION OF FUTURE OCCURRENCES Difficulty with obtaining representative samples from the 001 Discharge sample line has been a recurring problem-as zine will adsorb onto accumulated ~ solids.-
In.an attempt to correct this situation, we previously implemented concurrent sampling at each cooling tower's blowdown.pcint, ineser. red the sample line diameter, implemented a new sampling method, specified a
higher line flow--
rate,- posted sampling-instructions at the
. sample-point, and.. reviewed the importance of this-issue with our technicians.
These sampling difficulties have been compounded by fluctuations in makeup water-turbidity.
A review of plant data _shows that two days before the sample date, makeup' water turbidity increased by a factor of 20, apparent 1y' fouling the' sample line.
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1 To compensate ifor the limitations of the normal sample L
point, it is planned to continue-sampling each cooling tower's: blowdown: at an alternate 1 sample point on the day of 001 Discharge monitoring.
The alternate sample point is 4
l much closer to the actual blowdown from each cooling
- tower, and 1.as a
number of design features that. should help preclude silt fouling.
Samples from this point will be analyzed by the NPDES _ approved method and used to determine g
L the validity of _ suspect. values determined at the 001 Discharge.
l Sincerely,
?r H.JhMcCormick,_Jr.
RSU Plant Manager cci 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-p Station Resident NRC Inspector Tom Kenny, H.C.#
NRC Program. Management Section (3WH52)
Permits Enforcement Branch
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Water Management Division l
Environmental Protection Agency Water Permits.Section Region III l
841 Chestnut Building i
Philadelphia, PA 19107 y
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