ML20065M681

NPDES Noncompliance Notification:On 901003,routine Weekly Discharge 001 Sample Exceeded Max Permit Limits for Grease & Oil.Sample Contained 43.7 Mg Per Liter of Oil & Grease. Abnormal Reading Believed to Be Caused by Oily Silt

ML20065M681
Person / Time
Site:	Limerick
Issue date:	11/29/1990
From:	Mccormick M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Bauer R PENNSYLVANIA, COMMONWEALTH OF
References
NUDOCS 9012110159
Download: ML20065M681 (3)

Text

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i PHILADELPHIA ELECTRIC COMPANY LIMERICK GENER ATING ST ATION P. O. DO X A l

S AN ATOG A. PENNSY LV ANI A 19464 l

'215) 3271200 s av. 2000 )

1. A . J. M o s# M c K , J.r., P t .

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November 29, 1990 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 October 3, 1990, a routine weekly Discharge 001 sample was collected and sent to the Corporate Chemistry Lab to be analyzed for oil and grease. Station personnel received the analysis -

result on November 13, 1990. The sample result was 43.7 mg/l which exceeded the instantaneous maximum permit limit of 30 mg/l for oil and grease in Discharge 001. The remainder of the oil and grease samples from Discharge 001 for the month of October were well below the limit, and therefore, the monthly average permit limit of 15 mg/l was not exceeded.

CAUSE OF THE NONCOMPLIANCE The sample result of 43.7 mg/l is an abnormally high reading for Discharge 001. The normal sample results are typically in the range of 0.8 to 1.6 mg/1. Following further investigation, we believe the sample taken on October 3, 1990, was not representative of the 001 Discharge flow. The sample taken contained silt that had a high oil and grease content. Visual examination of the silt that was flushed from the piping of one of the 001 Discharge sample pumps indicated that the material was primarily coagulated solids with oil and grease, which is indicative of the settled sludge found in the Holding Pond.

9012110139 901129 4 PDR ADOCK 05000352 ' S S PDC

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4 The discharge pipe from the Holding Pond connects into the 001 Discharge line approximately 25 feet upstreamOnofOctober where the 001 3, 1990, Discharge sample pumps draw their suction.

when the sample was taken, it is believed that some of the accumulated silt dislodged from the sample piping and wasThe effluents to the 001 D collected in the sample. so other than the Holding Pond do not contain oil and grease, therefore, the potential source of the oil and grease is the Holding Pond. When the 001 sample was collected a separate sample was also taken from the 201 Discharge line because The sample there was a discharge from the Holding Pond in progress.

from the Holding Pond discharge contained 2.8 mg/l oil and grease. Therefore, we have concluded that the sample was not representative of the actual flow out Discharge 001 and believe that the 001 flow was below the-limit for oil and grease.

However, we recognize that the source of the oil and grease is the Holding Pond and are taking corrective actions. The cause of l the oil and grease that was discharged from the Holding Pond was the same as reported in our previous NPDES Noncompliance-Letter dated October 26, 1990.

DURATION OF THE NONCOMPLIANCE an actual For the reasons stated aboveRecent weHolding do not _believePond that problems caused the noncompliance occurred.

Discharge 001 sample system to accumulate solids fouled with oil  ;

and grease, thereby causing the sample result to beThe concentration of this material in unrepresentatively high.

our 001 Discharge was not believed to be great enough to have caused an actual violation of our oil and grease permit limits for that discharge.

CORRECTIVE ACTION In addition to the corrective actions described in-our NPDES Noncompliance Letter dated October 26, 1990, the Discharge 001 sample piping is routinely flushed daily and after the weekly 001 sampling is performed. Ongoing discussions with the Corporate Chemistry Lab are continuing in order to remedy the problem of untimely notifications of noncompliance.

' PREVENTION OF FUTURE OCCURRENCES A contractor-has been procured to remove the sludge The contractor from.the has Holding Pond and Waste Water Settling. Basin.

begun to remove sludge from the Holding-Pond and has been informed that-this facility must have-first priority for his System Engineers are sludge removal and cleaning operation.

continuing to investigate the best method for determining the sludge levels so that future cleaning of the Holding Pond and-Waste Water Settling Basin can be initiated to avoid future noncompliance.

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The revision of plant training programs has been initiated as per the action specified under the " Prevention'of Puture Occurrences" ,

paragraph in our previous NPDES Noncompliance Letter dated -

l, October 26, 1990. t 1

Sincer y, f 7 jh -.

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M. J )dMcCormick, Jrl  !

Plant. Manager JCE/JLP/rak i

ccs.U.S. Nuclear Regulatory Commission Document Control Desk-Washington, D.C. 20555 ,

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) Administrator Region I U.S. NuclearLRegulatory Commission j 475 Allendale Road

-King.of Prussia, PA 19406- -

Senior Resident Inspector,10SNRC T.J. Kenny, Limerick,.M/C A2-5 Program Management Section (3WM52)

Permits Enforcement Branch-Water, Management. Division '

Environmental. Protection Agency.. ,

Water Permits Section

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Region III i 841 Chestnut Building Philadelphia, PA 19107 i

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