ML20248C946

NPDES Noncompliance Notification:On 980414,total Iron Discharge Through Outfall 001 Exceeded Limits Set in Ltr Dtd 960508.Total Iron Discharge Limit Exceeded During Cleaning Evolution.Limit Revised

ML20248C946
Person / Time
Site:	Limerick
Issue date:	05/27/1998
From:	Boyce R PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Oneil S PENNSYLVANIA, COMMONWEALTH OF
References
NUDOCS 9806020281
Download: ML20248C946 (5)

Text

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. Robert W. soy:o )

Plant Manager 4 Lrnerick Generat:ng station v

• PECO NUCLEAR eccoen c - nv Limenck Generating station i A Unit of PECO Energy PO Box 2300 sanatoga. PA 19464-o920 61o 718 2000 May 27,1998 Steve J. O'Neil Chief, Operations Section Department of Environmental Protection Water Management Program Suite 6010, Lee Park 555 Nodh Lane .

Conshohocken, PA 19428 -

SUBJECT:

Limerick Generating Station NPDES Permit No. PA0051926 High Total Iron During Chemical Cleaning

Dear Mr. O'Neil:

On April 14,1998, while performing a chemical cleaning of a chilled water system, total iron discharged through Outfall 001 exceeded limits set in a letter dated May 8,1996. The Pennsylvania Department of Environmental Protection imposes a discharge limit of 1.5 ppm Total Iron at Outfall 001 during cleaning with Betz Deposi-Trol 855D. The Total f ron discharge limit was exceeded during this cleaning evolution. The analysis result was 1.55 ppm Total fron.

During the event, cooling tower iron was measured at 1.8 ppm exclusive of the cleaning solution used to clean the chiller. A sample of the chiller solution was analyzed, a calculation was performed for dilution, and the contribution to the outfall sample from the cleaning solution was 0.04 ppm. This event was not due to the cleaning evolution, but a natural occurrence of the cycling of river iron within the cooling tower similar to that of total suspended solids. Since total iron is not a monitored parameter, the actual cooling tower total iron concentration was not known in advance of the cleaning.

Since the time of this exceedance, PECO Energy has contacted Mr. Sohan Garg and Mr. Robert Ryan concerning the application of the limit. Based on our discussions, it is our understanding that the limit is being revised (as per Chapter 93.5.a," Application of Effluent Limitations") and the concentration of Total Iron reported will not exceed the new limit. Therefore, no further actions are being pursued by PECO Energy.

If there are any questions please do not hesitate to contact Mr. Tim Moore at (610) 718-3400.

S' cerely, ---

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Q' 9806020201 990527 2 PDR ADOCK 05 S

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o- k May 27,1998 Page Two 4

'cc: U.S. Nuclear Regulatory Commission Document Control Desk Docket Nos. 50-352/352 Washington, D.C. 20555 H. J. Miller

. Administrator, Region 1, USNRC Docket Nos. 50-352-353 .

A. L. Burntt '

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 !!!

i_ 841 Chestnut Building Philadelphia, PA 19107 s.

PECO ENERGY COMPANY PAGE 0001 PEP ISSUE

SUMMARY

ISSUE NBR: 10008245 STATUS /DATE: PLNNED 21MAY98 LAST UPDATE: 21MAY98 14:32 ISSUE

SUMMARY

ADMIN CHILLER TOTAL IRON ABOVE 1.555 PPM SIGNIFI6ANCE LEVEL  : 3 ISSUE OCCDRRED DATE/ TIME: 14APR98 14:40 PACILITY/ UNIT INVOLVFD: LG 0 ISSUE DISCOVERED DATE/ TIME: 14APR98 17:22 RESPONSIBLE EAC PACILITY: LG PRINT DATE: 27MAY98

=========================== INITIATION ==========================

ISSUE DESCRIPTION:

SAMPLE TAKEN FROM 001 DISCHARGE FOR DISSOLVED AND TOTAL IRON AFTER A CHEMICAL CLEANING OF ADMIN CHILLER .

TOTAL IRON WAS REPORTED AS 1.555 PPM HHICH IS ABOVE OCR NPDES LIMIT OF 1.5 PPM.

IMMEDIATE CORRECTIVE ACTIONS TAKEN:

• SAMPLES OBTAINED FROM RIVER COMPOSkTE AND ADMIN CHILLER CLEANING TO BE ANALYZED FOR BACKGROUND IRON VALUES.

CHEMISTRY HAS CONTACTED CORPORATE ENVIRONMENTAL NO MORE CHEMICAL CLEANINGS WILL BE PERFORMED WITH BETZ 855D UNTIL THE ISSUE IS RESOLVED WITH THE STATE.

=========================== ASSIGNMENT ==========================

)

INTERIM CORRECTIVE ACTION TO BE TAKEN:

NO CLEANINGS WITH BETZ 855D WILL BE PERFORMED UNTIL ISSUE IS RESOLVED. ___

=========================== EVALUATION ==========================

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ADDITIONAL ISSUE INFORMATION/ ISSUE DISPOSITION: l THIS EVENT WAS INTIATED WHEN A SAMPLE AT OUTFALL 001 WAS CBTAINED AND ANALYZED FOR TOTAL IRON. THE VALUE OBTAINED

• WAS 1.55 PPM WITH A DISCHARGE LIMIT OF 1.5 PPM.

DURING THE EVENT, COOLING TOWER TOTAL IRON WAS '

MEASURED AT 1.8 PPM EXCLUSIVE OF THE CLEANING SOLUTION OF THE CHILLER. A SAMPLE OF THE CHILLER SOLUTION WAS j ANALYZED, A CALCULATION WAS PERFORMED FOR DILUTION, AND THE CONTRIBUTION TO THE OUTPALL SAMPLE FROM THE CLEANING SOLUTION WAS 0.04 PPM.

~ THIS EVENT WAS NOT DUE TO THE CLEANING EVOLUTION BUT NATURAL OCCURRENCE OF TOTAL IRON WITHIN THE COOLING TOWER.

n CORPORATE ENVIRONMENTAL HAS CONTACTED THE PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION (DEP) CONCERNING THIS ISSUE. AT THE WRITING OF THIS PEP THE DEP IS IN AGREEMENT THE LIMITS PROPOSED ARE TOO RESTRICTIVE.

" THE DEP IS REEVALUATING THE LIMITS IMPOSED SINCE 1.

NO CREDIT WAS GIVEN TO DILUTION INTO THE REVIEVING WATER.

PECO ENERGY COMPANY PAGE 0002 7 EP ISSUE

SUMMARY

ISSUE NBR: 10008245 STATUS /DATE: PLNNED 21MAY98 LAST UPDATE: 21MAY98 14:32

=========================== EVALUATION ==========================

2. THE NORMAL DISCHARGE FROM THE COOLING TOh'ER FOR TOTAL IRON IS BETWEEN 1 TO 3 PPM. THIS IS DUE TO CYCLING OF RIVER WATER IN THE COOLING TOWER 4-6 TIMES RIVER IRON CONCENTRATION.

s ALTHOUGH THE DEP AGREES THAT THE LIMITS NEED TO BE CHANGED, AS OF THE TIME OF THIS WRITING THE DEP HAS NOT INDICATED WHAT THE NEW LIMITS WILL BE.

AN EVAL WILL BE INITATED TO TRACK THE RESPONCE FROM THE DEP IN CORRECTING THE LIMIT IMPOSED FOR TOTAL IRON DURING THE USE OF BETZ 855D. -

A

• THE LIMIT IMPOSED WAS BASED ON A LETTER OF REQUEST TO PERFORM CHEMICAL CLEANING WITHIN LIMERICK'S SYSTEM USING BETZ 855D A CALCIUM CAROBONATE SCALE DISOLVING CHEMCIAL.

THE EXCEEDENCE OF THE LIMITS OF THE LETTER IS NOT A VIOLATION OF THE NPDES PERMIT SINCE THIS REQUEST IS OUTSIDE OF THE PERMIT PROCESS.

A A LETTER WILL BE SENT TO THE DEP INFORMING THEM THAT THE IRON LIMIT IN THE LETTER WAS EXCEEDED, AND TO REINFORCE THE ONGOING NEGOTIATION TO CORRECT THE TOTAL IRON DISCHARGE LIMIT.

CAUSES OF ISSUE: '

CAUSE 1 (lZ) OTHER THIS EVENT WAS NOT DUE TO THE CLEANING EVOLUTION BliT NATURAL OCCURRENCE OF TOTAL IRON WITHIN THE COOLING TOWER.

s CORPORATE ENVIRONMENTAL HAS CONTACTED THE PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION (DEP) CONCERNING THIS ISSUE. AT THE WRITING OF THIS PEP THE DEP IS IN AGREEMENT THE LIMITS PROPOSED ARE TOO RESTRICTIVE.

THE DEP IS REEVALUATING THE LIMITS IMPOSED SINCE

1. NO CREDIT WAS GIVEN TO DILUTION INTO THE REVIEVING WATER.

2.

THE NORMAL DISCHARGE FROM THE COOLING TOWER FOR TOTAL IRON IS BETWEEN 1 TO 3 PPM. THIS IS DUE TO

' CYCLING OF RIVER WATER IN THE COOLING TOWER 4-6 TIMES RIVER IRON CONCENTRATION.

ALTHOUGH THE DEP AGREES THAT THE LIMITS NEED TO BE CHANGED, AS OF THE TIME OF THIS WRITING THE DEP HAS NOT INDICATED WHAT THE NEW LIMITS WILL BE.

bd

2. THE MANAGEMENT SYSTEM DID NOT IDENTIFY THE IMPLICATION OF AN UNREASONABLY RESTRICTIVE LIMIT. WORK CONTROLS COULD HAVE BEEN IMPLEMENTED TO ENSURE THE CLEANING ACTIV-ITY DID NOT TAKE PLACE WHEN IRON LEVELS WERE EXCEEDING THE LIMIT.

^

l PECO ENERGY COMPANY PAGE 0003  !

PEP ISSUE

SUMMARY

ISSUE NBR

10008245 STATUS /DATE: PLNNED 21MAY98 LAST UPDATE: 21MAY98 14:32 l

=========================== EVALUATION ==========================

GENERIC IMPLICATIONS:

THIS IS RELATED TO A SPECIFIC CHEMICAL CLEANING PROCESS AND THE LIMITS IMPOSED TO 'iHE PROCESS. THIS CLEANING WAS PERFORMED ON THE EMERGENCY DIESIL GENERATOR WITH THE WATER DISCHARGING TO THE SPRAY POND. SAMPLES OT THE SPRAY POND WERE WITHIN LIMITS OF THE DEP'S LETTER. THIS ISSUE IS DUE TO CYCLING OF THE RIVER WATER IN THE COOLING TOWER AND NOT BECAUSE OF IRON ADDED BY THE CLEANING PROCESS. THERE ARE NO FURTHER GENERIC IMPLICATIONS TO BE INVESTIGATED. -

THE PRESENCE OF LIMITS IN THE PERMIT WHICH ARE NOT

• ADMINISTRATIVELY IDENTIFIED OR CONTROLLED IS A GENERIC IMPLICATION. EVAL 03 IS GENERATED TO REVIEW THE PERMIT AND VERIFY ALL LIMITS HAVE ADMINISTRATIVE CONTROLS.

COMPLETED CORRECTIVE ACTIONS TO PREVENT RECURRENCE:

SINCE THE CLEANING SOLUTION IS NOT THE CAUSE OF THE EXCEEDENCE NO ADDITIONAL ACTIONS ARE REQUIRED DURING CLEANING EVOLUTIONS. CHEMISTRY WILL NO APPLY THE CHEMICAL UNTIL FINAL CHANGES FROM THE DEP ARE RECIEVED.

COMPLETED BY PIRL  : PILLER,'bJ ASSIGNED ORG SUPERVISOR APPROVAL: COONEY/KEMPER HP APPROVAL: NOT REQUIRED EAC APPROVAL:

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