ML20141M055

NPDES Noncompliance Notification:On 920206,rain Water Pumped from Eletrical Manhole Into Storm Water Runoff Drain Due to Inadequate Procedural Guidance.Blue Drains to Be Labelled, Indicating Use for Storm Water Runoff Only by 920801

ML20141M055
Person / Time
Site:	Limerick
Issue date:	03/25/1992
From:	Doering J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Bauer R PENNSYLVANIA, COMMONWEALTH OF
References
NUDOCS 9203310255
Download: ML20141M055 (3)

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• PHILADELPHIA ELECTRIC COMPANY LtMf; RICK GENER ATING STATION P. O, BOX A SAN A TOG A, PCliNSYLV ANI A 19464 (215) 327 4200 s a t. toco J. DO E ft t N G, JM.

umanet a e ssic aat was statiew March 25, .992 Mr. Robert Bauer, Jr.

Department of Environmental Resour.ces Bureau of. Water Quality Mana]cment Suite 6010, Lee Park

- 555 North-Lane Conshohocken, PA 19428

SUBJECT:

Noncompliance with NPDES Permit No. PA-0051926 Limerick Gene:ating Station Pumping of Electrical Manhole Contents into Storm Water Runoff Drain .

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Dear Mr. Bauer:

Description of the Noncompliance

.On--February 6, 1992, at approximately-0730 hours, contractor personnel hegan pumping out rain water that had accumulated in-electrical manhole number 006, whl,ch is located behind the Main Transformers in:fcont of the Unit 2 Turbine Enclosure. At approximately 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br />, Chemistry personnel discovered that the' discharge from this pumping operation was being directed to a

"_B LU E" storm water drain. This particular drain (E-3.3) is part l of he storm water collection network for Outfall number 005 that l discharges directly into Possum Hollow Creek and is specified by the NPDES permit to be utilized only for storm water runoff.

,fp, # l y fg 9203310255 920325 ppg ADOCK-050003S2 PDR _

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_2 Cause of the Noncompliance

.The cause of this noncompliance was_a lack of adequate procedural guidance-for_the dewatering process. In order to I obtain approval for pumping out a manhole, contractor peraor.nel i nitiated afdewatering permit.that indicated where the uater was to be pumped from and to, whether a chemistry sample was  :

required, and approval of Shift Supervision. 'Even though the proper dewatering approval form was used to get the necessary L signoffs authorizing the manhole to be pumped out, the directions for the; contractor personnel to follow were not specific enough to-prevent'them from sending the discharge to a " BLUE" storm water drain. This lack of adequate' direction was a result of a lack of_ procedural guidance for the use of the dewatering permit.

Duration of the Noncompliance .

The pumping ~ operation began'at-0730 hours, on' February 6, 1992. _At approximately'0905 hours0.0105 days <br />0.251 hours <br />0.0015 weeks <br />3.443525e-4 months <br /> the-discharge hose from the-

• pump in electrical manhole' number 006 was moved to the nearest

" GREEN" normal- waste drain which discharges .tcy a holding pond ,

-which'is!'a monitored release point. Based _on a maximum pump rate of 75-gallons /minate.the-calculated discharge _ volume that went to' .

- Outfall1005 during the 45 minute period was 7,125 gallons of t water. Because this was an' electrical manhole containing rain  ;

, _ water or ground water, Chemistry personnel did not expnct any contaminants:in the'waser. However,;because the. discharge was

- directed.to an unmonitored release point, a sample of the

- discharge water f rom this manhole was collected .euu3 analyzed .for

- pH.and; total suspended solids. The pH was 7.65 and the' total suspended _ solids content _was only 0.4 mg/L.

Corrective' Actions Upon discovery.cf the noncompliance, Chemistry personnel

' informed the contractor personnel who were working on the job

, thatLthe pump discharge was~not allowed to go into a_" BLUE"_ storm water drain and directed them to move the diccharge hose to the nearest "GREPh" normal waste drain. The contractor personnel

-immediately complied with:this request.

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i Prevention of Future Occurrences Chemistry Night Orders issued on March 13, 1992, included guidance on handling' of dewatering. Information : requests.

Operations personnel: issued a memo to all shift Managers on March 13, 1992 describing proper' methods for-handling dewatering

. permits. The' memo and nl.ght orders emphasized the point that no  ;

pumping snould be routed-to-a " BLUE" drain. A procedure will be )

- written by-May 1,-1992,-to provide specific guidance for the use ~

H of-the dewatering permit. -Additionally,-an action to labellall {

" BLUE" drains to indicate use for storm water runof f only is y expected to'be' completed by August 1, 1992.

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' Sincerely, l

/

p.*

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.DCS/rak cc: -U.S. Nuclear Regulatory Commission.

Document Control Desk.

Docket Nos, 50-352/50-353 *

Washington,- D.C.-

20555

. .T. T.. Martin Administrator,. Region lI, USNRC

Docket:Nos. 50-352/50-353

~T. J. Kenny . .

USNRC Senior Resident-Inspector, LGS Docket Nos.'50-352/50-353 J

. Program-Management Section (2WMS2)

Permits Enforcement-Branch Water"ManagementLDivision Environmental Protecticn-Agency

. Water Permits Section Region:III:

r 841 Chestnut Building F Philadelphia,.PA 19107.  ;

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