ML20141G027
| ML20141G027 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/27/1997 |
| From: | Boyce R PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Oneil S PENNSYLVANIA, COMMONWEALTH OF |
| References | |
| NUDOCS 9707030269 | |
| Download: ML20141G027 (3) | |
Text
.
~
(
Robert W.Boyne i
Plant Manager
+
Umerck Generat ng Stauon l
PECO NUCLEAR esm ee-c-env Limerck Generating Station A Unit of PECO Energy PO Box 2300 i
Sanatoga. PA 19464-o920 1
610 718 2000 June 27,1997
~
l j.
Steven J. O'Neil Chief, Operations Section Department of Environmental Resources Bureau of Water Quality Management Suite 6010, Lee Park I
555 North Lane l
Conshohocken, PA 19428 l
l
SUBJECT:
Limerick Generating Station, Unit 1 and 2 l
Two Non-Compliances of NPDES Permit No. PA-0051926 l
1 l
Dear Mr. O'Neil:
Description of the Non-Compliances:
Non-Compliance #1 1
On May 12,1997, the Unit 1 cooling tower overflowed thereby requiring sampling at Outfall 021.
The required samples were collected and preserved per 40 CFR Chapter 1 Paragraph 136.3 Table ll. During the transfer of data from the chain of custody (COC) sheet to the sample bottle label, the requirement to analyze the sample for Kjeldahl nitrogen was omitted. The NPDES j
l Parmit only requires this parameter to be monitored and reported, and no limitation is specified.
Non-Compliance #2 On May 21,1997, the Net Total Suscended Solids (TSS) for the cooling towers was identified to be 82.3 ppm, thereby exceeding the NPDES permit daily limit of 60 ppm. This elevated TSS reading also caused the monthly average of 30 ppm to be exceeded.
Cause of the Non-Compliances:
Non-Compliance #1 l
The cause of the Kjeldahl nitrogen analysis omission was perconnel error. Although the responsible station individual is knowledgeable of the NPDES Permit requirements and correctly filled out the COC sheet, the individual failed to transcribe the proper analysis requirement to the sample bottle label. A contributing factor to this non-compliance was the off-site laboratory review is limited to sample bottle accounting and the laboratory does not cross check the sample g
g requirements of the COC sheet to the sample bottle markings. As such, the Kjeldahl nitrogen analysis requirement on the COC sheet was not identified as missing on the sample bottle.
h}
onnn4 m
9707030269 970627
/
PDR ADOCK 05000352 l(({ ((} l{ll,kk,!!!!!1i,
S PDR
l l
June 27,1997 Page Two Following discovery of this incident, the sample was available at the off-site laboratory, however, the sample was not maintained after analysis at 4'C as required by 40 CFR Chapter 1 Paragraph 136.3 Table 11. The sample was analyzed and reported in the May DMR with applicable remarks conceming sample storage.
Non-Compliance #2 The cause of the elevated TSS daily limit and monthly average has two causal factors. First, the Schuylkill River TSS levels had recently spiked due to transient conditions related to storm runoff.
This resulted in unusually high turbidity in the cooling tower make up water. Second, the sample line had accumulated solids which were purged into the sample during its collection. An investigation revealed that the sample tubing had been in service for over 12 months and was fouled. The tube fouling was confirmed by elevated zinc concentrations which coincided with the elevated TSS results.
Actions to Prevent Recurrence:
Non-Compliance #1 The responsible individual was counseled on the need to self check and to ensure that the COC sheet and sample bottle are in agreement before allowing the sample to be shipped to the off-site laboratory. The off-site laboratory was instructed to perform a cross check of the sample requirements of the COC sheet to the sample bottle markings. The sample bottle label has been upgraded to include a listing of analyses that are performed by the off-site laboratory so that the required analysis, in accordance with the NPDES Permit, can be circled. In addition, this non-compliance will be discussed at a Chemistry Group All Hands Meeting to emphasize the need to self check.
Non-Compliance #2 The elevated TSS resulting from weather and river conditions does not have an action that will prevent its recurrence. The sample tubing was replaced and all further analyses to date have had zero Net TSS. This tubing will be changed out semi-annually using existing plant scheduling tools.
If there are any questions please do not hesitate to contact Mr. Tim Moore at (610) 718-3400.
Sincerely, i
j
.j June 27,1997 Page Three cc:
U.S. Nuclear Regulatory Commission Document Control Desk Docket Nos. 50-352/352 Washington, D.C.
20555 H. J. Miller Administrator, Region I, USNRC Docket Nos. 50-352-353 N. S. Perry USNRC Senior Resident Inspector, LGS Docket Nos. 50-352/353 Program Management Section (3WM52)
Permits Enforcement Branch Environmental Protection Agency Water Management Division Environmental Protection Agency Water Permits Section Region ll1 841 Chestnut Building Philadelphia, PA 19107 1