ML20128A507

NPDES Noncompliance Notification:On 921117 & 25,analytical Results for inductively-coupled Plasma Analyzer at Discharge Point 001 Exceeded Zinc Concentration.Total Zinc Concentration Analysis Will Be Performed Onsite

ML20128A507
Person / Time
Site:	Limerick
Issue date:	01/25/1993
From:	Doering J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Feola J PENNSYLVANIA, COMMONWEALTH OF
References
NUDOCS 9302020232
Download: ML20128A507 (3)

Text

7 F 1 '. , 1 PIIILADELPIIIA ELECTRIC COMPANY

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LIMERICK GENERATING STATION P. O. BOX 230)

SANA'lOGA PA 19464-2300 (215) 327-1200 EXT 2000 J. DoEnING, JR.

$$tYNo E waswm January 25 , 1993 L Mr. Joser eola Pennsy. Jepartment of Environmental Resources Regiona! .ter Quality Manager Lee Park, Suite 6010 555 North Lane Conshohocken, PA 19428

Subject:

Limerick Generating Station, Units 1 and 2 Noncompliance with NPDES Permit No. PA-0051926

Dear Mr. Feola:

DESCRIPTION OF NONCOMPLIANCE On November 17 and 25, 1992, the routine weekly samples were collected from. Discharge Point 001 and sent to our Corporate Chemistry Laboratory to be analyzed for total zine concentration.

The analytical results obtained from an Inductively 1 Coupled Plasma (ICP) analyzer at our Corporate Laboratory exceeded the Discharge Point 001 limit of 1.0 mg/L for total zinc. The total zinc concentration was found to be 1.8 mg/L on November 17 and 1.1 mg/L on November 25. These results were received by station personnel on December 11, 1992.

CAUSE OF THE NONCOMPLIANCE Based on other plant and analytical data, it appears that zinc discharges in excess of the discharge limitation did not actually occur and that this violation is a result of analytical-problems, f A review of all data for November from our colorimetric screening-method indicated that the total zinc concentration was always below the 1.0 mg/L permit limit. This is consistent with the quantity of chemical _ajected into the cooling tower. However, because our approved method of analysis indicated zinc in excess of our permit limits we are considering-this as a violation and intend to take the corrective actions identified.

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x DURATION-OF THE NONCOMPLIANCE The duration of the _ noncompliance cannot be determined because 'of

'the lack of-follow-up analytical data.- The: daily ~ total:zine:

. concentration as determined from our colorimetric' method was always-below;the 1.0 mg/L permit' limit and chemical usage rates?

were within the historical range. The zinc levels i~n-Dischargeo 001 were acceptable prior to and following_the event, and there were no substantial operating changes that would have increased -

the zine concentration.

CORRECTIVE ACTION No immediate corrective actions were taken as the analytical results were not received until December. The time from_ sampling _

until-receipt of results from the offsite lab did not permit timely investigation and correctionLof; problems. There was no indication,-based on chemical usage rates,_that a problem-existed-at the-time the samples were obtained. Upon, receiving the results, immediate emphasis was-given to ensure-proper sampling technique, and to develop the capability to perform on-site.

analysis using_an ICP analyzer prior to sending samples to our Corporate Laboratory.

PREVENTION OF FUTURE OCCURRENCES Measures are being taken to enable Limerick Generating Statio.i (LGS) to perform the total zine concentration analysis onsite l using an ICP analyzer. This capability will-provide-timely <

l information to permit detection and correction.of analytical-problems and out of specification' conditions.. The Corporate L Chemistry Laboratory will be used until-LGS has this capability.

The requirement to promptly notify LGS Chemistry Supervision when-sample results are in noncompliance with our NPDES permit has-g - been re-emphasized with the Laboratory personnel..

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If you have any-questions please contact Mr. Gil J..Madsen=at (215) 327-1200.

Sincerely,

. f L JLP:cah cc: U.S. Nuclear Regulatory' Commission Document Control-Desk Docket Nos. 50-352/50-353 s

. Washington, D.C.-20555-l 1

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' Program Management Section-(3WM52)

Permits'Onforcement' Branch-

-Water Management Division Environmental Protection Agency Water: Permits Section Region III _ . . _

841 Chestnut-Building

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