ML20246E734

NPDES Noncompliance Notification:On 890406,spray Pond Water Discharged Through Outfall 009.Caused by Removal of Barrier on 890405.Personnel to Direct Discharge of Water Via Pathway in Advance to Ensure Outfall Under NPDES Permit

ML20246E734
Person / Time
Site:	Limerick
Issue date:	04/06/1989
From:	Mccormick M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
References
NUDOCS 8905120004
Download: ML20246E734 (3)

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? PHILADELPHIA ELECTRIC COMPANY l

Lf MERICK GENER ATING 5TATION P O. SOX A S AN ATOG A, PCN N5Y LV A Nir. I 9484 April 27, 1989 Mr. Robert Bauer, Jr.

Department of Environmental Resources Bureau ofl Water Quality Management 1875 New Hope Street

< .Norristown, PA 19401

Subject:

. Spray Pond Discharge Overflow to Outfall 009, Limerick

~

y Generating. Station, NPDES Permit.No. PA-0051926

Dear Mr. Bauer:

On April.6, 1989 at-3:30.p.m. oral notification was given of a Spray Pond ~ water discharge through Outfall 009.

The spray pond normally contains approximately 30 million gallons of river water. _A barrier was placed at the discharge weir to allow the pond to retain approximately 34 million gallons in< support of Emergency Service Water. flow balance' testing.

The barrier was removed at 1:20 a.m. on April 5, 1989. The increased water level caused an abnormally high discharge flow.

The discharge piping _ handled. the majority of flow through the normal outfall (001). At 8:00 a.m. on- April- 6, 1989 station personnel- investigated a report of water overflowing a manhole.

The overflow was estimated at 200 gpm at outfall 009. At that time. samples were taken to determine.pH and residual of Malco 1372. Chemicals are not normally present in the spray pond but Nalco 1372 had been injected during the flow balance testing.

Sample results were pH 7.1 and 1 ppm orthophosphate which is equivalent to 10 ppm Nalco 1372 product residual. The NPDES

. permit limit at outfall 001 on Nalco 1372 is 19.8 ppm monthly average.

8905120004 890406 ~&>

PDR ADOCK 05000352 S PDC

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e Page 2 The discharge from outfall 009 started at 1:30 a.m. on 4/5/89. The discharge was stopped at 6:40 p.m. on 4/6/89 by diverting water from the Spray Pond to the Unit 2 Cooling Tower.

Duration of the discharge was 39 hours4.513889e-4 days <br />0.0108 hours <br />6.448413e-5 weeks <br />1.48395e-5 months <br /> 10 minutes at approximately 200 gpm. Approximately one half million gallons overflowed the manhole and discharged through outfall 009.

The same manhole again overflowed on 4/11/89. The cause was unrelated to'the first incident. This incident resulted from an atypical cooling water valving alignment during Emergency Diesel Generator testing. Automatic initiation of the Emergency Diesels causes an Emergency Service Water pump to start which provides cooling water to the diesel. Supply for the ESW pump is provided from either the Spray Pond (Emergency Service Water) or the cooling tower (Service Water) depending on system pressure.  ;

During the maintenance outage there was little demand for service '

water, and as a result, service water pressure was higher than emergency service water pressure. On 4/11/89, all (8) diesels were tested which caused three ESW pumps to start. Approximately  ;

500 gpm of service water was being discharged into the Spray ,

Pond. The Spray Pond blowdown line was not designed to handle  !

more than approximately 300.gpm. The overflow was a result of this input of service water to the spray pond.  ;

The discharge was stopped at 5:30 p.m. on 4/12/89. Duration of this discharge was 34 1/2 hours. The estimated volume discharged from outfall 009 was 414,000 gallons. Analysis of ,

sampics taken during this discharge verified compliance with discharge limits for outfall 001.

Measures are being taken such that future routine testing of j the diesel generators will not result in this type of incident.

Normal valving will be aligned to ensure prevention of a rapid increase in Spray Pond inventory. In addition, the feasibility of using a flow restricting device on the Spray Pond blowdown weir is being evaluated. This device would limit the outfall from the Spray Pond to a rate which the normal drain line can t handle. l i

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To further' reinforce the importance. of preventing such incidents,'a letter has been issued to site personnel to direct that .any. discharge of water via any pathway other than normal be approved in advance to ensure that the final outfall 'is permissible under the . NPDES permit. Also,-additional training will be provided to. station' personnel concerning the discharging of waste waters from the site.

Sincerely,

~

bJ.McCormick,Jr.

Plant Manager I

RSU sjm i

rsu 4/20/89.1 cc: U. S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 Administrator Region I Office of Inspections and Enforcement U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Station Resident NRC Inspector Tom Kenny, M.C. #NRC Program Management Section Permits Enforcement Branch Water Management Division Environmental Protection Agency Water Permits Section Region III- '

841 Chestnut Building Philadelphia, PA 19107 i

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