ML20063K158

Requests LGS NPDES Permit PA0051926 Be Amended to Allow Use of R.J.D Products,Inc Formula 65 Foaming Agent to Perform Condenser Leakage Testing at LGS

ML20063K158
Person / Time
Site:	Limerick
Issue date:	02/15/1994
From:	Matty R PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Garg S PENNSYLVANIA, COMMONWEALTH OF
References
NUDOCS 9402280285
Download: ML20063K158 (6)

Text

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2301 Market Street .;

PO Box f.699 FMadelphia. PA 191014 699 5 215 841 4000 i

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February 15.1994  ;

i Mr. Sohan Garg Department of Environmental Resources (

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Lee Park. Suite 6010 555 North Lane '

Conshohocken, PA 19428

Dear Mr. Garg:

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Subject:

Limerick Generating Station NPDES Permit No. PA0051926 }

Pursuant to Chapter 92.7. " Reporting of New or increased Discharges." we are requesting that the ,

subject permit be amended to allow the use of RJ.D. Products. Inc. Fonnula #65 Foaming Agent to perfona condenser leakage testing at Limerick Generating Station. The foam will be applied over an i entire tube sheet, and a vacuum will then be applied on the steam side of the condenser. The vacuum '

will cause the foam to recede into any leaking tubes. Upon completion of testing, the foaming agent '

i will be washed from the tube sheets to the cooling tower basin and eventually discharged, via cooling tower blowdown, to outfall 001. Typical usage will be approximately 1.5 gallons of agent per tube sheet with a total of 24 tube sheets to be tested. 'Ihe maximum expected concentration of the product in the cooling tower basin is 8 ppm. If needed, an anti-foaming agent (previously approved) will be l applied to the cooling tower basin to control potential fo:uning problems. Attached is the product  !

infonnation sheet and material safety data sheet.  !

A copy of this letter (including any attachments or enclosures) is being sent to the U.S. Nuclear  ;

Regulatory Commission (USNRC) in accordance with the Limerick Generating Station. Units 1 and 2.

Environmenttu Protection Phm. Section 3.2. which stipulates that USNRC shall receive a copy of any j '

prop sed changes to the NPDES pennit at the same time that the pennitting agency is notified.

t Testing of the condenser is scheduled to begin shortly, therefore, we would appreciate your immediate i attention and response to our request. If you have any questions or require additional infonnation.. 3 please contact me at CIS) 841-5177.'

Sincerely.

l

-Nk Robert M. Matty, Jr.

Engineer

, Environmental Affairs 22002S Attachment 9402280285 940215 PDR STPRG ESGPA PDR ,

cc: U.S. Nuclear Regulatory Commission. Document Control Desk

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(Docket Nos. 50-352 and 50-353 & License Nos. NPF-39 and NPF-85) .

T. T. Manin. Administrator. USNRC. Region 1 f..

N. S. Perry. USNRC Senior Resident Inspector. LGS d 7 p w-. < g, - r - , ._. w w e-7

. FEB-02 ,,94 WED .14:30M 1p: LIMERICK CHEMISTRY TEL NO:2721 4009 PC2 THE F04u PaooucTs. inc. FOAM METHOD OF LEAK DETECTION Robert J. Duncan Pres. of RJD FO AM FRODUCTS has been operating a Foam Business for over 25 years.

HeIs well experienced in condenser tesf ng. Please feel free to call me or our distributors if you have any quest:ons.

Introducing RJD FOAM PRODUCTS, manuf acturing Foam Generators and a Foam Agent for industry.The RJD FOAM GENERATOR and FORMULA 65 FOAM AGENT, LEAK DETECTOR were origina!!y designed to meet the needs of Util:ty Companiesin testing of their condensers for leakage. FoamTesting of condensers has proven very successful and is superier to all presently used methods.This aspect of cut business has been steadily growing and extensive research has resulted in our improving our present Agent.We now offer,in one I size, a well engineered Foam Generator to 011 the varied needs of indus*ry. While the enginal purpose of the I

Foam Generator, condenser testing, still requires the ma;or portion of our producticn. we are now promoting ciher uses 1or our products.

1 Wherever the use of Foam is applicable, the RJD GENERATORS and FOAM AGENT are the answer to high volume. Iow cost, portable foam production.

Shown at the right are some *cn site' ph0tos ci foam testing'a 200 MW condenser at a larg e Eastern Utility.

The enc! sed reprint from Combustion magazine detai!s the operation.

' FOAMING AGENT The RJD Foam Agent is cf the highest quality,is perfectly safe. is des'gned ic: Strong 6im strength and wiu foam in presence of sea water.The fcam generation method used provides a dry ! cam with equal distribution of the active materials throughout the entire foam film. -

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. FEB-02 '94, IJED 1.4:32t1. ID: LIMERICK CHEMISTRY TEL NO:2721  ::039 PC3

1. MN SPECIFICATIONS

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, ag The RJD Foam Generators as illustrated.

The Model No.1-965-42,42 gallon tank capacity -

20 gais, of liquid, requires one gallon of Foaming Agent when charging.

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- The 42 gal. modelis for use on condensers over 50 MW capacitywherelarge amounts of foam are required.

Tuto-sheets are s'udsed in a few minees. Sads are fed continuousy hem the 1 14 fn delivery hose Model No.1 965-42, consists of a heavily constructed glass-lined tank, which stores the liquid and is imed with

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a a stainless steel ag!!ating jet, level-valve, and drain

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% valve. A separation and control tank unit is mounted at

'" - M the tank ou' Jet connection.

'Ys 4 m 9- aw This unit is fitted with a separating baffle, pressure-

- gauge, safety-valve, fill connection, control and delivery

- hose. The unit is also f:tted with the remote operated

- " control-valve and air regulater. All fittings are of high

- quahty brass.

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- The entire asserr.bly is mounted on a sturdy do'ly pro-f'/-]

,j vided with large wheets for ease of mobihty. '

Note: All units operate with air pressures from 150

. suds are smoorhed our by eserator and rne erWre tube-ends are plugged as aflustrated. psig to 75 psig. Alr censumption is not excessive as the 5/32' jet only requires 35 psig. All units are designed to operate at between 2 3 psig, for best results.

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. .L ]a FowULA 65 m y . . , ,

Two tubes show up as Inaders ss ne vacuum on the steam side causes the suds to recede ktro he Isalong fube.

3 FEB 2 '94 14: 37 LIMERICK CHEMISTRY PAGE.203

FEB-02 '94 WED.1.4:305 ID: LIMERICK CHEMISTRY TEL ND:2721 #C09 PD4 Experience with the Use of Foam for CondenserLeak Detection quantities, and a reasonable cost.

The modern high temperature, high pressure team genet-ator requires water of the highest possible punty. One The foam agent must have the following qualities:

source of contamination has been and continues to be leaks from the condenset. Obviously condenser leakare A. Must be absolutely safe to use. harmless to hamans.

. should be held at a minimum and whenever leaksanimal h life , marine life..f abrics and metalse -

develop they should be quickly located and plugged. Un_

fortunately leak detection on condensers has always been B. Must have the ability to produce a stable dense foam costly and time. consuming. of high film strength with excellent cohesive and adhesive properties.

At present the principal methods of le'ak detection are:

C. Must be stable in the presence of sea w ater. ,

A. The use of plastic sheeting material to seal tube ends.

How the Method Works B. Hydrotesting. using a fluorescent dye and black light de:ection. When testing a condenserforleaks.both tube sheets are sealed with foam. When the steam side of the tube is ex-C. Rame testing using candles. . posed to vacuum. a vacuum wil be created inside of a

. .. .. . leaking tube and the fearri plugs will reced-into the tube.

b. Observation for drying tube ends. When the steam side is exposed to pressure the inside of the tube will become pressuriced and foam plugs willbe E. On a split condenser, mounting a manometer exter-' forced out. -

nal to the conderiser water

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',boxc slowly, filling waterbox ,

and observing leM1 at which condu~ctivity changes, thus locating the relative honzontal toeation of the leak. 3 Testing, Unit in Service F. Use of supersonic listening devices. One. Half CondenserOut of Service .

- G. Sclectively plugging each tube end using a solid plus A. With an air hose. thorcughly blow water from tubes on one end and an inclined manometer or a sensitive diap.

. and tube sheets; this minimizes foam dilution. -

hragm alarm device, plugged into the other end.

B. Foam both tube sheets' generously. forcing the foam ,,

All of these are slow, and, relatively ineffective. But a .

mto the tubes. Brush down sheets using a soft broom or a new method has been developed reccatly- the foam test.

rubber squeegee. Next, apply a second foam coating. di.

trig method. It is far superior in sensitivity and time re.

re.cting the foam toward tohe top of the sheet, allowing it quired to any of the methods mentioned. For ex. ample, t fl w over the emire sheet. Brush sheets from to down both halves of a 200 MW condenser are effectively tested -

and observe for leaks.

on-the line of off-the-line in less than 3 bours.

C. When a leak is detected. jet the tube with air to iden-Foam Testing Develoment tify to the worker at the other end. ela:e temporary plugs in each end of the tube. A vacuum will be observed when Foam testing of condensers has been under develop plugs are withdrawn. The leaking tube may be verified by ment for almost twenty years. it was necessary to find the plugging one end and insening a sensitive water manome.

means to produce a satisfactory foam quickly,in large ter into the other end.

Reprinfed from COMBUSTION, March f 965

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1 FEB ' g ' 94_14 : ;37 LltFJULCE_IHFJiLST Rv 17erdacuae i

FEB-02 *jM WED 14:32M ID: LIMERICK CHEMISTRY- TEL NO:2721 2009 P05

,o--.. JOHN R. ROBINSON, INC. e.....

ctEAN No samts e

LEAK 8 "ECT*" POWER PLANT SPECIALTIES -

38 05 30th STREET "A" 5* " "5 ' "

• "*'""""*^"^"" LONG ISLAND CITY, N.Y.11101 U.S.A. LEAKV CONDENELR TUSE3 Am COWDENSEn QUN$

1 800 726-1026 FAX: 718-786 6090 718 76G 6088 4

. 'In reply to your request for the ebmical breakdown of the R.J.D. Foaa Products, Inc'. - 2.J.D. Special Foam' Agents -

New'and beproved Formula #65, please note the following:

INaprWT inionic' datergent * . . . . .

Itosphates '

Silicates '-

Sodium nitrite- -

- Water ,

Ve thank you for the opportunity to be of, service to you.

If you need asy further data, please do not hesitate to contact our office. , ,

Very truly yours, JOHN R. ROBINSON, INC..

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FEB 2 '94 14:38 LIMERICK. CHEMISTRY PA@$2$$5

5 EB-02 '94 IJED 14:30M ID: LIMERICK CHEMISTRY TEL NO:2721 1:209 P06 l

t1ATERIAL SAFETY DATA SHEET FOAM AGENT 1/5/93 SECTION I: GENERAL INFORt1AT10N ,

PRODUCT NAME: FORMULA 65 CHEMICAL NAME AND5fNONYMS: FOAM AGENT CHEMICAL FAMILY: ANIONICSURFACTANT FORMULA: MIXTURE MANUFACTURER: RJD FOAM PRODUCTS INC, OlST BY J OHN R ROBINSON INC.

30-05 30 ST. Ll.C. N.Y 11101 TEL.718-786-6088 SECTION 11: COMPOSITION . "

HAME  % CAS" Wahr 90 Sodium laury1 sulfate 7-8 68585- 47-7 Sodium nitrite <l 7632 0 Sodium tripolyphosphate <1 7758 2 Sodium metasilicete - 4.5 6834- 92-0 SECTION til: PHYSICAL DATA '

Boiling point: over 212 deg r (100 deg C.) Critipal Temp; not applicable Solubilityin vster: complete . Specific Gravitg: 1.02 ,

Viscesity: 5-20 cps Eveporation rate: not determined Yapor pressure: not determined Decomposition Temp: not determired Percent volatile by volume: 90

. Corrcsion rate: f:ot appilceble .

Yspor density: rot applicable ,. ,

pH: 1.0- 10.9 freezing pmnt: 50-58 deg. F cloud point Appearance and odoh strav colored liquid; bland odor

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SECTION IV: FIRE AND EXPLOSION' DATA - . . .

NON FLAMMABLE NOT EXPLOSlVE ~

SECTION V: HEALTH HAZARD DATA Effects of overexposure: not applicable Threshold LimitValue: not applicable Emergency and first Aid Procedure:: In esse of ecddentsl ege centset, flush eyes immediately with 1 plenty of veter for at least 15 minutes. Ifirritation persists consult physician. Prolonged or repeated

' contact vith skin may esuse irritstion; vash off skin vith veter, ifingested, consult physician.

. SECTION VI: REACTIVITY DATA l STABILITY: STABLE-HAZARDOUS POLYMERIZATIONWILL NOT OCCUR - AVOID STR NG0XIDIZING AGENTS l

.SECTION Vil: SPILL OR LEAK PROCEDURES for concentrated product,small spills may be zoeked up vith absorbent and disposed ofin eccordance vith all applicsble federal, state and local requistions. Material collected vith absor bent may be disposed in a permitted landfill in accordance .

vith federal, state, and local regulations. Highly diluted solutions may be flushed into sevege disposal

. systems as vould crdinary household detergents and shempoos vithout noticeable harmful effects. l

. SECTION Vill: SPECI AL PROTECTION INFORMATION Respiratory Protection: not normally required. Yentilation: not normally required.

Eye protection: PreYent concentrate from 3plashing into eyes. Safetg glasses recommended.

Skin: Riree vith veter. Contsminated clothing: Rinse out thoroughly before reusing. l NONE  !

.SECTION IX: SPECIAL PRECALITIONS:

1 FEB 2 '94 14: 38 LIMERICK CHEMISTRY PAGE.003