ML20044C405

NPDES Noncompliance Notification:On 930222,discovered That Contractor Personnel Discharged Treated Water from Fire Hydrant Supplied by Unit 1 Cooling Tower Into Storm Water Drain E-3.2.Caused by Personnel Error.Label Applied

ML20044C405
Person / Time
Site:	Limerick
Issue date:	03/16/1993
From:	Doering J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Feola J PENNSYLVANIA, COMMONWEALTH OF
References
NUDOCS 9303220441
Download: ML20044C405 (3)

Text

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t PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION P. O. BOX B00 SANATOGA, PA 19464-2300 (215) 3271200 EXT. 2000 -;

J. DOER:NG, JR.

[i$r$((cYanus swrou March 16 , 1993 Mr. Joseph A. Peola Pennsylvania Department of Environmental Resources Regional Water Quality Manager Lee Park, Suite 6010 555 North Lane i 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 February 22, 1993, at 1515 hours0.0175 days <br />0.421 hours <br />0.0025 weeks <br />5.764575e-4 months <br />, it was identified that contractor personnel were discharging treated water from a fire hydrant supplied by the Unit 1 Cooling Tower into storm water drain E-3.2. Drain E-3.2 is part of the storm water collection network for.Outfall number 005 which discharges directly into Possum Hollow Creek and is specified by the NPDES permit to be utilized only for storm water runoff.

The contractor personnel were hydrolazing the Unit 2 condenser and had placed two one inch diameter bypass hoses into storm drain E-3.2. The discharge from the hoses into storm drain E-3.2 occurred intermittently during hydrolazing when the hydro wands inside the condenser were not in use so that water was bypassed through the hoses into storm drain E-3.2. Hydrolazing of the Unit 2 condenser with bypass flow discharged into storm drain E-3.2 occurred from 1900 hours0.022 days <br />0.528 hours <br />0.00314 weeks <br />7.2295e-4 months <br /> on February 19, 1993 through 0200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> on February 20, 1993, from 0700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> on February 20, 1993 through 0200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> on February 21, 1993, and from 0700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> -

February 22, 1993 until discovery at 1515 hours0.0175 days <br />0.421 hours <br />0.0025 weeks <br />5.764575e-4 months <br /> on February 22, 1993. Upon discovery, tne bypass hoses were routed to the normal waste drain system to terminate the unmonitored release. An estimated 40,000 gallons of treated Unit 1 Cooling Tower water was discharged into storm drain E-3.2 during the period. An ,

analysis of a sample taken from the effluent from Outfall number n '

On e noe n D 9303220441 930316- / -

PDR ADOCK 05000352 <

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'005 during the discharge determined the pH to be 7.52, the total l zinc concentration to be 0.18 ppm, and the total suspended solids l L to be 2.4 mg/L; all values well within NPDES permit limits for  ;

discharges-to the Schuylkill River. No adverse environmental  ;

effects to Possum Hollow Creek were observed. [

i CAUSE OF THE NONCOMPLIANCE l i

l The cause of the noncompliance was a personnel error. The j l- contractor involved in the event had received General Employee r l

Training which informs workers of the types of fluids authorized -j for discharge into color coded drains at Limerick. A l contributing causal factor to this event was that the description i in the work order was inadequate because the job planner did not  !

i understand that hydrolazing equipment operation involves bypass  ;

! flow. Other contributing causal factors were that actions to i label all storm water drains to indicate their use for storm water runoff only are incomplete and that the scope and purpose  ;

of Administrative Guideline (AG) AG-100, " Guideline for ,

Completion of the Site Dewatering Permit," do not clearly cover the circumstances of this event.

PREVENTION OF FUTURE OCCURRENCES r General Employee Training will emphasize that the storm water drains which are color coded BLUE are designed for discharge of -i storm water only and that the provisions of AG-100 must be- ,

followed prior to discharge of any other water into' storm' water drains. The scope and purpose of AG-100 will be clarified. The'  ;

lessons learned from the-investigation into this event will be i communicated to job planners to prevent recurrence during future hydrolazing activities. A label will be applied to all storm '

water _ drains to indicate their use for storm water; runoff only.

If you have any questions please contact Mr.-Gil J. Madsen at ]

(215) 327-1200.

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Sincerely, 1

JLP:cah 3 .

d- .

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=t cc: !U!S UNuclearlRegulatory , Commission..

Document Control Desk _;

f Docket'Nos. 50-352/50-353 l Washington,: D.C. 20555 i T. T. Martin i Administrator, Region I, USNRC l Docket Nos.'50-352/50-353  ;

i T. J. Kenny l USNRC Senior Resident Inspector, LGS ,

Docket Nos. 50-352/50-353 i I

Program Management Section (3WM52) i Permits Enforcement Branch '!

Water Management Division l Environmental Protection Agency 1 Water Permits Section  :[

Region III .l 841 Chestnut Building -

Philadelphia, PA 19107 i

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