ML20062E993
| ML20062E993 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/15/1990 |
| From: | Morley G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Dolchak J PENNSYLVANIA, COMMONWEALTH OF |
| References | |
| NUDOCS 9011270013 | |
| Download: ML20062E993 (13) | |
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1 PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P,0, BOX 8699 PHILADELPHI A, PA.19101-12151841 4000
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November 15,'1990 i
Ms. JoAnn Dolchak Water Quality Specialist Department of. Environmental Resources 1875 New Hope Street Norristown, PA 19401 RE:
Limerick Generating Station, N? DES Permit PA0051926
Dear Ms. Dolchak:
The following is in response to your October 31, 1990 Notice of Violation confirming the results of your September:18,.
1990 inspection which itemized three concerns:
1.
The sewage holding tanks at the facility had overflowed on September 6, 1990 and on September 16, 1990, causing sewage to be discharged.to Possum Hollow Run.
1 Response - We provided'the. Department with a response to-this overflow problem in our letters dated September 14, 1990 and September. 21,.1990 (attached).
As stated in1the attached letters, the actual dates of the overflow were. September 7 and 17, 1990.
As discussed'in the= attached' letters, a routine test has been developed and implemented-to_ perform functional checks of the level: probe' to ensure proper operation.
A Spill Stopper Drain Seal was ordered on October 4, 1990 rather than fabricating a temporary cover for the S-7 Storm Drain. -When the-Spill Stopper Drain Seal is-receivci iexpected November 20, 1990), it will be stored near the S-7 Storm Drain.
In conjunction with lowering the tank high level setpoint from 8 feet.6' inches to 5 feet 10 inches, storage ofEthe Spill Stopper Drain Seal near the S-7. Storm Drain'provides operations personnel sufficient time to follow alarm response procedures.
These procedures require the Spill Stopper Drain Seal to be. installed over the S-7 Storm Drain'to prevent drainage into Possum Hollow' Run.
These actions, along with the actions stated in the attached letters, are expected to prevent t L-1,;,,9 recurrence of'this problem.
y 9o11a70012 901113 DR ADOCK 05000352 I
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Ms. JoAnn Dolchak Pags 2 November 15, 1990 2.
Intake screens on the Perkiomen Creek are cleaned by forcing air ~ through the: screens causing accumulated debris to flow downstream.
Requirement R in Part C of your NPDES-permit-states, " Debris collected on the intake trash racks shall not be returned'to the-waterway".
-Response - The Perkiomen Creek intake screens are.
submerged wedgewire screens.
There are no intake:
trash. racks on the Perkiomen Creek from which~ debris is collected.
The design of the intake structure was reviewed and approved by the-Department and there is no provision in the_ design t6 collect accumulated. debris. -Therefore, we do not'believe.
that we are in noncompliance with'Part C, Other Requirement R of the: NPDES permit. -This was the subject of'a discussion between'you and David Mobraaten the week of November 5, 1990 in:which you indicated that_you would pursue interpretation of this requirement lwith the permit writer.
3.
The holding basin at monitoring point 201 had accumulated solids and a light sheen on the surface.
Response - We have not found the specific requirement which leads you to,believe that:the appearance of the_ Holding Pond is a violation.
However,.we'did incur a-noncompliance with the oil and grease permit limit in September, which is addressed in our letter dated October 26, 1990-tcttached).
Subsequent to that letter',~ actions have been initiated to pump out_the: sludge from-the Waste Water bu*tling Basin and to clean out-thel Holding Pond.
A contractor _was brought on site by the-Maintenance Department to determine the best way.to remove the sludge from both the-Holding Pond and the Waste Water' Settling Basin.
Removal of the sludge is now underway and will be done without violating the NPDES permit.
These' actions, along with the actions stated in the attached letter, are expected.
t to prevent recurrence of-this problem.-
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Ms. JoAnn Dolchak-Page 3 l
November 15, 1990 1
1 If there are any questions, please call David Mobraaten
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at 215-841-5679.
Very truly yours, i
Geo ge M. Mor}ey Director Environmental Affairs DWM/JLP/lth Nuclear Regulatory Commission',f ec:
U.
S.
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
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4 PHILADELPHIA ELECTRIC COMPANY LIMERICK GENER ATING STATION P. O. BOX A SAN ATOG A. PENNSYLV ANI A 19464 f
(215) 327 6 200 sat. 2000 September 21, 1990
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Mr. Robert Bauer, Jr.
Department of Environmental Resources Bureau of Water Quality Management 1875 New Hope Street Norristown, PA 19401 t
Subject:
Overflow of Sewage Holding Tank Limerick Generating Station NPDES Permit No. PA-0051926
Dear Mr. Bauer:
This letter is being submitted in accordance withithe requirements of Limerick Generating Station NPDES Permit No.
PA-0051926 as written follow-up to'a noncompliance notification made'to-the DER on September 17,.1990.-
L On September 17, 1990,'at.0105 hours0.00122 days <br />0.0292 hours <br />1.736111e-4 weeks <br />3.99525e-5 months <br /> a " Sewage' Treatment Facilities" annunciator alarmed in-the Main Control Room.
An -
operator was sent out to investigate and reported that the sewage holding tank next to the access road was approximately 6 inches j
below the overflow level.
The Operations Supervisor on duty immediately initiated the appropriate: plant procedures which
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specified to contact the-sewage removal vendor and perform i
several other notifications.
At 0200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> on September 17, 1990', the. operator reported'that the holding tank had started to overflow.
Operations Supervision. estimated that approximately 40
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gallons / minute of diluted sewage was enterin.g Storm Drain S-7, t
flowing through' Storm Drain S-7.1,;and exiting at Outf all:002 i
into Possum Hollow Creek.- The vendor's tank truck arrived on l
site and~ started pumping at 0230 hours0.00266 days <br />0.0639 hours <br />3.80291e-4 weeks <br />8.7515e-5 months <br />, which terminated the overflow.. An estimated volume of 1,200 gallons ofl diluted sewage l-overflowed ~from the holding tank.-
At 0340 hours0.00394 days <br />0.0944 hours <br />5.621693e-4 weeks <br />1.2937e-4 months <br /> and 0350 hours0.00405 days <br />0.0972 hours <br />5.787037e-4 weeks <br />1.33175e-4 months <br /> on September - 17, 1990, samples l~
l were obtained from the S-7 Storm Drain,'and Possum Hollow Creek L
downstream of Outfall 002, respectively, and sent offsite for fecal coliform: analysis.
At 1245-hours, another sample was o
f obtained;from the Possum Hollow Creek upstream.of Outfall 002 and was also sent offsite for-fecal coliformLanalysis.
During daylight hours, a-visual inspection-was made of-the spill area, lI F
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Page 2 September 21, 1990 1
the storm drain, the connecting outfall, and areas downstream to ascertain if any observable environmental impact had occurred.
There were no signs of any environmental effects on the aquatic life living dcwnstream of the outfall and no solids were discharged.
The analytical result of the S-7-Drain sample was 1
60,000 colonies /100 mis.
The analytical results(of the Possum 3
Hollow fecal coliform samples were 1,900 colonies /100 mls downstream and 650-colonies /100 mls upstream of Outfall 002.
A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> noncompliance notification was made to Robert Bauer of the Pennsylvania DER at 1055 hours0.0122 days <br />0.293 hours <br />0.00174 weeks <br />4.014275e-4 months <br /> on September 17, 1990 in accordance with the NPDES permit.
This report was required because, according to our NPDES permit, this incident is considered to be an unanticipated bypass which exceeded our effluent limitations; The primary cause of this event was that the sewage removal j
vendor (Reifsnyder) unilaterally decided to not make the removal' l
from the Limerick site as he had been directed' subsequent to a spill which occurred during the previous week.
.This decision was made without consulting plant' personnel or management, and was based upon the vendor's estimate.of expected sewage flow into the holding tank during non-outage-periods.
This resulted in an abnormally high tank level.
A similar overflow, which had occurred on September 7,
- 1990, resulted in directing the sewage removal vendor to increase the frequency of waste removal and, at 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br /> each day of the week, completely empty the sewage holding tank.
However, the vendor failed to comply with this request.
In this particular
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instance, the vendor emptied the tank on-September 15, 1990, at approximately 1000' hours, and did not return to the site again-until notified of the overflow on September 17, 1990 at 0230.
Tbe vendor was counseled on the need to contact.the appropriate plant personnel prior to changing the waste removal. frequency.
The vendor agreed he had made a mistake and assured there would-be no reoccurrence.
Additional action taken to reduce the. potential of a future spill is that the tank high level alarm setpoint has been lowered from 8 feet 6 inches to 5 feet 10 inches tank level-(the maximum tank level'is 10 feet).
This will allow more time for reaction by Operations personnel and the sewage removal vendor.
Additionally, the-following actions are planned to be implemented by October-31, 1990, Development of a Routine Test to perform functional checks o
of the sewage-holding tank' level probe to ensure proper-operation.
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Pcgo 3 Sspt0mbar 21, 1990 Fabrication and installation of a temporary cover or seal o
for the S-7 Storm Drain to prevent drainage into Possum Hollow Creek.
On September 24, 1990, plant management and'other appropriate
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personnel will review the recent environmentally related plant deficiencies to determine any additional causal factors and define any necessary corrective actions.
Any additional actions planned to prevent recurrence will be included in a supplement to this letter.
Sincerely, 2
T [:4t o.J. McCormick, Jr.
DCS:rgs l
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Page 4 Saptemb2r 21, 1990 U. S. Nuclear Regulatory Ccmmission cc:
Document Control Desk t
Washington, D.C.
~20555 j
Administrator Region I U. S. Nuclear Regulatory Commission 475 Allendale Road 4
King of Prussia, PA 19406 Station Resideric NRf, Inspector Tom Kenr.y, M. C.
- NRC Program Managemen'; Section (3WM52) i Permits Enforcemtnt Branch Water Management Division Environmental Protection Agency Water Permits Section Region III 841 Chestnut Building Philadelphia, PA 19107 a
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PHILADELPHI A ELECTRIC COMPANY
-l LIMERICK GENER ATING ST ATION P. O. SOX A S AN ATOG A. PENNSYLV ANI A 19464 (215) 3271300. EXT. 3000 September 14, 1990 GR AM AM M. LEtTCH w.........,
Mr. Robert Bauer,~Jr.
Department of Environmental Resources Bureau of Water Quality Management 1875 New Hope Street HECEIVED Norristown, PA 19401 SEP 2 0.1990
Subject:
Overflow of Sewage Holding-Tank e as MORI C' Limerick Generating Station NPDES Permit No. PA-0051926
Dear'Mr. Bauer:
On September 6, 1990, at 2340 hours0.0271 days <br />0.65 hours <br />0.00387 weeks <br />8.9037e-4 months <br /> a " Sewage Treatment l
l Facili*.les" annunciator alarmed id'the Main Control Room.
An operecer was sent out to investigate and, at 2355_ hours, he reported that the sewage holding tank next to the access road was_
just below the overflow level.
The Operations Supervisor on duty!
immediately initiated the appropriate plant procedures which specified to contact the sewage contractor and perform several other notifications.
At 0005 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> on September 7, 1990 the operator reported that the holding tank had started to eserflow.
i Operations Supervision estimated that between 50 to 100 gallons / minute of diluted sewage was entering Storm Drain S-7, flowing through Storm Drain S-7.1, and exiting at Outfall 002 into Possum Hollow Creek.
The contractor's tank: truck' arrived on site and started-pumping at 0133 hours0.00154 days <br />0.0369 hours <br />2.199074e-4 weeks <br />5.06065e-5 months <br />, which terminated :he
- overflow, by 0147 hours0.0017 days <br />0.0408 hours <br />2.430556e-4 weeks <br />5.59335e-5 months <br />, the holding tank had been_ pumped out l
sufficiently for Operations-to clear the annunciator in the Main Control Room.
At 0250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br />, Possum Holles Creek was sampled downstream of Outfall 002 and the sample war, sent'offsite for fecal' coliform 3
analysis.
During daylight hours a visual inspection was made=of the spill area, the storm c*. rain, the' connecting outfall, and areas downstream to ascercain if any. observable environmental impact had occurred.
There were no signs of any environmental effects on.the aquatic life living downstream of the outfall and no solids were discharged.
Tbc analytical result of=the' Possum Hollow fecg1 coliform sample was 27,000 colonies /100 mis.
j
SeptGmb3r 14, 1990 2-A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> noncompliance. notification was made to Marcy Stoltz This of the Pennsylvania DER at 1435 hours0.0166 days <br />0.399 hours <br />0.00237 weeks <br />5.460175e-4 months <br /> on September 7, 1990.
this report was required because, according to our NPDES permit, incident is considered to be an unanticipated bypass which exceeded our effluent' limitations.
The Pennsylvania Fish Commission was notified of the incident at 1515 hours0.0175 days <br />0.421 hours <br />0.0025 weeks <br />5.764575e-4 months <br /> on the same day.
An estimated volume of between 5,000 to 9,000 gallons of diluted sewage overflowed from th6 holding tank.
Maintenance personnel investigated for excessive inputs into the holding tanks and found a toilet in the Administration Building that was flushing continuously.
By 0218 hours0.00252 days <br />0.0606 hours <br />3.604497e-4 weeks <br />8.2949e-5 months <br /> on September 7, 1990 the toilet had been shut off.
Additionally, an increased number of personnel on site for the upcoming Unit 1 Third Refueling Outage-were utilizing the shower facilities.-just after the end of the second work' shift.
These contributions to sanitary waste, in conjunction with the routine inputs caused this overflow.
The sewage contractor has been directed to increase the number of tanker loads that they remove on second shift to provide sufficient tank capacity during this-refueling outage Additionally, administrative controls will be period.
implemented to ensure increased removal frequency as required L
during future periods of high demand.
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l Sincerely yours, T
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J I
M J. McCor k,
Plant Manager JCE/rak 4
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A September 14, 1990 3
cc:
U.S. Nuclear Regulatory Commission i-i Document Control Desk i
Washington, D.C.
20555 i
Administrator Region I U.S. Nuclear Regulatory Commission 475 Allendale Road i
King of Prussia, PA 19406 i
Station Resident NRC Inspector Tom-Kenny, M.C.#-NRC 3
Program Management Section (3WM52)
Permits Enforcement Branch Water Management Division Environmental Protection Agency Water Permits Section Region 1III 841 Chestnut Building
. Philadelphia, PA 19107
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ecw PHILADELPHIA ELECTRIC COMPANY LIMERICK GENER ATING ST ATION P. O. BOX A SAN ATOC A, PENNSYLVANI A thiE4 (2 8 5) 3271200 ext. 2000 '
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Mr. Robert Bauer, Jr.
Department of Environmental. Resources _
Bureau of Water Quality-Management 1875 New Hope Street Norristown, PA 19401
SUBJECT:
Noncompliance with NPDES Permit
~
Limerick Generating Station NPDES Permit No.'PA-0051926-
Dear Mr. Bauer:
DESCRIPTION OF NONCOMPLIANCE On September 5, 1990 a routine weekly sample was collected from the Holding Pond (Discharge 201) sample point'and sentito 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 discharge.
The calculated monthly average for oil and grease for the' month of September was 16.7 mg/1,-which'. exceeded the monthly average permit'11mit of 15 mg/1.
The quantity of oil and grease in the September 5 sample.was the primary reason for exceeding this' monthly average permit limit for the Holding Pond diccharge.
CAUSE OF THE NONCOMPLIANCE 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 occasicnally contains small quantities of oil carried over from the oil, separators and/or released from underlying layers'of settled sludge.
The discharge 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 ~1evel from approaching the sludge surface.. At the time
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 approximately 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 />, l
l 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.
Ubis 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 OF FUTURE 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 mal.'tained and cleaned.
Furthermore, plant training programs will be reviewed and revised as necessary
33 Mr. Robert Bauer, Jr.
Page 3 of 3 October 26, 1990 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.
L i
Sincerely, c
{
M.(d.McCormick,Jr.
Plant Manager JCE/DBN:vc 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 Senior Resident Inspector, USNRC T. J. Kenny, Limerick, M/C A2-5 Program Management Section (3WM52)
Permits Enforcement Branch Water Management Division I
Environmental Protection Agency Water Permits Section Region III 841 Chestnut Building Philadelphia, PA 19107 N
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