ML052760154

Discharge Confirmation Report Describing the Discharge to the Ground of Approx. 650 Gallons of Wastewater Containing a Dilute Solution of Hydrazine & Ammonia from a Leak in the Condensate Polisher System at Salem Unit 1

ML052760154
Person / Time
Site:	Salem
Issue date:	09/23/2005
From:	Benyak D Public Service Enterprise Group
To:	Office of Nuclear Reactor Regulation, State of NJ, Dept of Environmental Protection
References
-RFPFR, 05-08-24-1630-16, FOIA/PA-2010-0209, LR-E05-0453
Download: ML052760154 (21)

Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, New Jersey 08038-0236 SEP 2 3 2005 o Psix-LR-E05-0453 Nuclear LLC CERTIFIED MAIL RETURN RECEIPT REQUESTED ARTICLE NUMBER: 7004 2510 0005 2135 9299 Bureau of Discharge Prevention New Jersey Department of Environmental Protection 401 East State Street - P.O. Box 424 Trenton, New Jersey 08625-0424 Attention: Discharge Confirmation Reports RE:

PSEG NUCLEAR LLC - SALEM GENERATING STATION NJDEP CASE NO. 058-24-1530-16 DISCHARGE CONFIRMATION REPORT

Dear Sir or Madam:

In accordance with N.J.A.C. 7:1 E-5.8, PSEG Nuclear LLC ("PSEG Nuclear') is submitting the enclosed discharge confirmation report. This report describes the discharge to the ground of approximately 650 gallons of wastewater containing a dilute solution of hydrazine and ammonia from a leak in the condensate polisher system at Salem Unit 1. The discharge was reported to the New Jersey Department of Environmental Protection (NJDEP) hotline and assigned case number 05-08-24-1530-

16. This discharge was also reported to the Nuclear Regulatory Commission pursuant to that agency's requirements.

The enclosed report contains the information as known at the time of this report. In accordance with the regulations, additional information regarding this discharge will be provided if and when it becomes available.

• NT 95-2168 REV. 7/99

NJDEP SEP 2 3 2005 LR-E05-0453 If you have any questions regarding this information, please contact Mr. Clifton Gibson of my staff at (856) 339-2686.

Sincerely Darin Benyak Director - Regulatory Assurance Attachments (2)

C U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Mr. Jim Werner Salem County Department of Health 98 Market Street Salem, NJ 08079 2

NJDEP LR-E05-0453 DISCHARGE CONFIRMATION REPORT SALEM GENERATING STATION NJDEP Case No. 05-08-24-1530-16

1.

Name, Address and Telephone Number of Individual Who Reported Mr. Eric Powell Operations Superintendent PSEG Nuclear LLC - Salem Generating Station P. O. Box 236, MIC S01 Hancocks Bridge, New Jersey 08038 (856) 339-5200

2.

Name, Address and Telephone Number of Person Submitting Report Mr. Darin Benyak Director - Regulatory Assurance PSEG Nuclear LLC - Salem Generating Station P. O. Box 236, M/C N21 Hancocks Bridge, New Jersey 08038 (856) 339-1740

3.

Name. Address and Telephone Number of OwnerlOperator of Facility Where Discharge Occurred PSEG Nuclear LLC 80 Park Plaza Newark, New Jersey 07102 (973) 430-7000

4.

Source of Discharge, If Known On August 23, 2005 at approximately 1545 hours0.0179 days <br />0.429 hours <br />0.00255 weeks <br />5.878725e-4 months <br />, a chemistry technician noticed during his daily rounds standing water north of the Salem Unit 1 Condensate Polisher building.

This standing water had a ring of white reside around it. This ring prompted the technician to sample this water for components consistent with the wastewater found in the condensate polisher building. The water was tested for pH and hydrazine. The results showed a pH of 6.37 and a hydrazine concentration of 30 ppm. This is consistent with the wastewater found in the condensate polisher building containments.

The volume approximated at the time of discovery and through the following cleanup activities in the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was 500 gallons. Upon discovery, the extent of the spill to the engineered fill appeared to be small enough to facilitate a clean-up within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

However, during the course of the cleanup, PSEG Nuclear made the determination that the cleanup could not be completed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the time it was discovered.

PSEG Nuclear immediately then notified NJDEP of the spill by calling the NJDEP hotline.

3

NJDEP LR-E05-0453

6.

Location of Discharge Name:

Street Address:

Lot & Block:

Municipality:

County:

Zip Code:

Site Map:

PSEG Nuclear LLC - Salem Generating Station Alloway Creek Neck Road Lot 4.01, Block 26 Lower Alloways Creek Township Salem County 08038-0236 The location of the Salem Unit 1 Condensate Polisher Building is identified on the Site Map In Attachment A.

6.

Common Name and CAS No. of Hazardous Substance Discharged The discharged material was wastewater containing a dilute solution of hydrazine and ammonia. The CAS numbers for hydrazine and ammonia are as follows:

Hydrazine, CAS No. 302-01-2 Ammonia, CAS No. 1336-21-6

7.

Quantity of Hazardous Substances Discharged The approximate volume of wastewater collected during the cleanup was 650 gallons, after which the excavation remained dry for approximately a week before the excavation was filled.

It is believed that this volume includes some amount of rainwater and that the actual volume of wastewater discharged was less than 650 gallons.

8.

Date and Time Discharge Began, Was Discovered, Ended and Was Reported Case No.:

05-08-24-1530-16 Began:

Unknown but not observed during daily inspection rounds prior to August 23, 2005 Discovered: August 23, 2005 at approximately 1545 hours0.0179 days <br />0.429 hours <br />0.00255 weeks <br />5.878725e-4 months <br /> Ended:

August 24, 2005 at approximately 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> Reported:

August 24, 2005 at approximately 1530 hours0.0177 days <br />0.425 hours <br />0.00253 weeks <br />5.82165e-4 months <br /> Description of Containment. Cleanup and Removal Measures, Summary of 9.

Costs Incurred Upon discovery of the discharge, the first responders placed inflatable bladders in the surrounding storm drains to block any material from entering the drains and secured the scene, to prevent exposure to personnel traveling in the area. A contractor, Clean Harbors, was then contacted for support.

Clean Harbors collected the free liquid from the ground by a vacuum-truck, (approximately 500 gallons). Gravel fill from the area was then removed and placed in a lined roll off dumpster. A ditch was constructed along the foundation of the building to collect 4

NJDEP LR-E05-0453 any further liquid. This liquid was collected until September 3, when the last of the wastewater was removed from around the building. All gravel fill, which could be visually identified as being affected was removed.

The gravel was removed using a bobcat excavator and placed into a lined roll off. No free liquid was identified in the roll off.

PSEG Nuclear has not yet been invoiced for the costs of the spill contractor to date but expects the costs of cleanup to be approximately $10,000.

10.

Corrective Actions - Preventative Measures Several corrective and preventive measures have been or are being taken to prevent future spills from the Salem Unit I Condensate Polisher.

The containment pit that was discovered to be the source of the leak was repaired on August 28e. A daily inspection of this system now includes observations of day-to-day volume changes in the system. Additional internal inspections will be conducted as indicated. The amount of wastewater allowed in the system has also been minimized using administrative controls to further reduce the potential of leakage. The excavation used to collect water was left in place for several weeks prior to refilling to help identify any additional leaks but has remained dry.

Clean gravel from offsite will be used to replace the soil and gravel removed from the site as part of the cleanup work.

11.

Name, Address and Telephone Number of Cleanup Entities PSEG Nuclear LLC P. O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Clean Harbors 2858 Route 322 - P.O. Box 337 Bridgeport, New Jersey 08014 (856) 467-3102

12.

Description of Sample Date. Time, Quantity and Location PSEG Nuclear collected samples of the wastewater when it was first discovered, during the active cleanup activities and during the passive collection activities through the excavated trench. All of the following samples were taken and processed following the station's standard operating procedures.

5

NJDEP LR-E05-0453 Date Time Hydrazine (ppm)

Ammonia (ppm pH 8/23/05 1545 30 6.37 8/23/05 1545 30 6.19 8/24/05 1055 20 200 6.94 8/24/05 1315 7

8/24105 1420 7.5 8/24105 1445 125 (uncertain) 8124/05 2130 5

150 8/25/05 1420 10 300 XX 8/25/05 2127 4

200 8.51 8/27/05 1135 0.7 150 8.53 8/29/05 0755 30 ppb 15 8.71 8/30/05 1025 50 ppb 15 8130/05 1250 50 ppb 20 8.83 8/31/05*

1345 Non-detect

• Excavation remained dry following 8/31/05.

Records of the results of these analyses are kept inspection.

on-site and available for NJDEP

13.

Certification of Financial Responsibilitv A copy of the Certification of Financial Responsibilities is included as Attachment C.

14.

Supplemental Information Additional relevant information, if any, will be provided to the Department if and when it is discovered.

15.

Any Additional Information Additional information will be provided upon request.

16.

Certification The Certification of Darin Benyak, Director - Regulatory Assurance, is included as Attachment B hereto.

6

NJDEP LR-E05-0453 X TTA CHMENT A 7

NATF11 PtAN' Location of A

Discharge M

pal6r.

C014t)EN E

Po B

CLEAN..F CILITIES L MG B

PA

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NJDEP LR-E05-0453 ATTACHMENT B 8

NJDEP LR-E05-0453 PSEG Nuclear LLC -

Salem Generating Station Confirmation Report Certification as per NJAC 7:1 E-4.1 1(a) 1, Darin Benyak, of full age, being duly sworn according to law, upon my oath depose and say:

1.

I am the Director - Regulatory Assurance for Salem Generating Station;

2.

I certify under penalty of law that the information provided in this document is, to the best of my knowledge, true, accurate and complete. I am aware that there are significant civil and criminal penalties, including the possibility of fines or imprisonment or both, for submitting false, inaccurate or incomplete information.

Darin Benyak Director - Regulatory Assurance Salem Generating Station Sworn and subscribed before me this 2,Mpeo day of Vewkeieg 2005.

9

NJDEP LR-E05-0453 ATTACHMENT c 10

• F-LIG-23-2004 10: 1 Jqhz. O. VrAeri, Jr,

• A.

WOU COimei-Al EnvirTMOinneLal Counsel PSE&G OEC OEco of t:nvironmaontai Oou.wes 110 Pak Plaza, T¶S*, NIrwark, NJ 07)02 Vol: 73.430.6606 fnx 973.a2,1267 amail: John.VulerlJr@pse1,,cofl 1Te.5 td

.dbY t

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. I]V1Ie o PSEG Svvcl'0s CoryJ7iration April 26, 2004

'YA FED1ERAL EXPRMSS Bureau of Relcase Prevention New Jersey Deprtnent of Environmental Protection Staton laza 4 22 South Clinton Avenut, 3" Floor CN 424 Tenton, New Jersey 08625 Re:

Fintncial Responsibility Docume$ts PSEG Fossil LLC PSEG Nuclear LLC Ladies & Gentlemen:

I Enclosed is an ogil and ten (10) copies of updated financial responsibility docrments pursuant to N.1A.C. 7:1E-4.4. Thr enclosed documents iuclude the Chief Financial Offioer's Letter and a Guarantee executed by the. Vice President and General Counsel of PSEC P ower LLC. Each specifies the eleven major facilities that are covered,.

If you have any questions, please do not hesitate to contact me.

Very JOVljb

)

Enclosures

,zr.5 Bud 1e-(b r. w-4/ -Ld RUG-23-200 4 13:0i1 PSEA OEC bcc:

i1. W. Borden, Esq. (w/attach)

C, T. NedIy (w/attach)

I,]P. Ryan (w/aitach)

M. G. Cullen (w/attach)

. H. Peacb (w/attach)

B. S. Petrovski (w/attach)

M. D. Schwartzkopf (w/attach)

X, M. Eggers (w/attarh)

T. IE. Syed (w/attach)

J

hUG-23-2004

+/-3:02 PSEG OEC 973 802 +/-267 P. 05/12 Thornrn All. O'Jllynu Public Service EnLorprise Group lncorpor- -d zuca:tl6 Vic-Preoidenit 80 l'ark Plamb. 4i, ITi.,

Newalit, WXJ 07103J-and Chiul Y1Inancial Cirfliifir W: g7S.430.5662 fzuc 073.021.2150 LETTER FROM EXECYJTIYE VICE PRESIDENT AND CHIEF? f11INAC1AI OY"FIC13R I am the Execuive Vice President and Chief-Financial Offcer of FSEC3 Power LLC, 80 ParkPlaza, P.O. Box 1171, Newark, New Jersey 07101-] 171. This letter is in support f thle use "of the fmansial test of self-insurance" and/or "guarantee" to demongtrate financial responsibility for ciealnup and removal activities arising from opcrating:

Bergen Generating Station Victoria Terrace Ridgefield, New Jersey 07657; HIudson Generating Smaion Duffield & Van Keuren Avenies Jersey City, New 3ersey 07306; Kearny Generating Station Foot of iaekensack Avenue Kearny, New Jersey 07032; Essex Generaing Station 155 RaymoOnd Boulevard Newark, New Jersey 07105; Linden Generating Station Giasselli Area of Wood Avenue South Linden, New Jersey 07036; Sewaren Generating Station 751 CliffRoad Seware,4NewJersey 07077-1439; Edison Generating Station 164 Silver Lake Avenue.

Edison, New Jersey 08817; Meroer Generating Station Lamberton Road Trenton,.New Jersey 08611; Burlington Generating Station W. Broad Stieet & Devlin Avenue Burlington, New Jersey 0801 6;

RUJG-23-20 04 i3:02 PE.

E PSE&G OEC 973 802 1267 P.01/i2

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Salem Generating Station

Foot of Buttonwood Road P.O. Box 236 Hancocks Bridge, New Jersey 08038; and Hope Creak Generating Station Foot of Buttonwood Road P.O. Box 236 HAncooks Bridge, New Jersey 08038 in the amount of at least One Million Dollars ($1,000,000) per occurrence per facility, and Two Million Dollars ($2,000,000) annual aggregate per facility.

A "financial.test" is also used by this Howner or operator" to demonstrate evidence of financial responsibility in the following amounts under the following EPA or State rules or Tegulafiiots (i.e., RCRA, ECRA, UST, etc.):

NIA This "ovwner or operator" has not meceived an adverse opinion, a disclaimer of opinion, or a going conen qualificailon from an independent auditor on his or her financial statements for the latest aompleted fiscal year.

ALITERNATIVE I (Mlions)

1.

Amount of annualDCR aggregate coverage being assured by a financial test and/or guarantee

2.

Amount of annual aggregate coverage for all other Federal or State regulatory costs (ire. RCRA, ECRA, UST, etc.) covered by a financial test, and/or guarantee

3.

Sum of lines I and 2

4.

Total tangible assets

5.

Total liabilities [if any of the amount rcported on line 3 is included in total liabilities, you may deduct that amount-from this line and add that amount to line 6]

S 22 S

0 22 7,620 5.123

.,J.

6.

Tangible net worth [subtract line 5 from line 4]

S 2,497

fUG-23-2004 13:32 PSE&G OEC 973 802 1267 P.

YES NCO

7.

Is line 6 at least $10 million?

X

8.

Is line 6 at least 10 times line 3?

X

9.

Have financial statements for the latest fiscal year been filed with the Securities Exchange Commission?

X

10.

Have financial statements for the latest fiscal year been filed with the Energy information Administration?

x

11.

Rave Efnantial statements for the latest fiscal year been filed with the Rural Electrification Administration?

X

12.

Has financial information been provided to Dun and Bradstet, and has Dun and Bradstreet provided a fimnncial strength rating of 4A? [Answer'Yes only if both criteria have been met]

X I hereby certify that the wording of this letter is identical to ie wording specified in Appendix B of N.J.A.C. 7:1E, as such rules were constituted on the date shown immediately below.

oDms M. O'Flym, Executive Vioc President an

.Chief Financial Officer Date: ApzB 26, 2Q04

RUG-23-2 0 0 4 13:02 PSE&G OEC YY5 HUM 12!bY

r. WtbI1 PSEG Power LLC So Pork Plsm&, MaNark. NJ 0710024194 tel: 973.430.70rI0 C I PSEG GUARANTEE Guaranree made this April 20, 2004 by PSEC} Power LLC, a business tntity organized under the laws of the State of Delaware, herein referred to as guarantor, to the New Jersey Dtpartmert of Environmental Protection ("Department") andto any and all third parties, and obliges, oc behalf of itswholly owned operating subsidiaries, PSEG Fossil LLC, which operates thc!BergepmBurlington, Essex, Edison, Hudson, Kearny, Linden, Mercer aid.Sewaref Generating Stations and PSEGNuclear, LLIC, which operates Hope Creek and Salem Generating Stations, of 80 Park Plaza, Newark, New Jersey 07101.

(1)

Guarantormeets or exceeds the financial test citeria of N.J.A.C. 7: 1E-4.4(g) and agrees to comply with the requirements for guarntors as specified in NJ.A.C.

7:E I4.4(h).

(2)

This guarantee satisfies the requirements for assudng funding in the amount of

$1,000,000 per occurence and $22,000,000 amnual aggregete for cleanup and.

removal activities. arising from operating the above identified major facilities.

(3)

On behalf of our wholly owned operating subsidiaxies, PSEG Fossil LLC and PSEG Nuclear LLC, gurntor guarantees to the Depatent and to any aod all third parties that:

In thb event that PSEG Fossil LLC or PSEG 1uclear LLC, fails to provide alternate coverage within 60 days after receipi of a notice of cancellation of this guarantee and the Department has detemimed or suspects that a discharge has occurred at a facility covered by this guarantee, the guaramor, upon instructions from the Department, shall fund a standby trust fund in an amount sufficient to cover cleapup and removal costs, but notto exceed the coverage limits specified inR.3.A.C. 7: IE4.4(b).

In the evmt that the Department determines that PSEG Fossil LLC or PSEG Nuclear LLC has failed to perform cleanup and removal activities arising out of the operation of the above-identified facilities, the guarantor, upon written instructions from the Department, shall fund a standby trust in an amoumn sufficient to cover cleanup and removal costs, but not to exceed the coverage limits.specified above.

9j

M,7-, MMO i I.:)a,7 P. PIq/1 ?

RG-23-2004 13:03 PSE&G OEC, (4)

Guarantor agrees that if, at the end of any fiscal year before cancellation of this guarantee, the guarantor fails to meet the financial test crflerja of N.J.A.C. 7: 1E-4.4(g). guarantor shall send within 120 days of such failurc, by certified mail, notice to PSEG Fossil LLC and PSEG Nuclear LLC and the Department. Thc

-guarantee will terminate 120 days from the date of receipt of the notice by PSEG Fossil LLC and PSEG Nuclear LLC or 120 days from the date of receipt of the notice by the Department, whichever is later, as evidenced by xbe return rtceipt.

(5)

Guarantor agrees to notify PSEG Fossil LLC and PSEG Nuclear LLC by certified mail of a voluntary or involuntary proceeding under Title 1I (Bankruptcy), US.

Code, naming guarantor as debtor, within 10 days after con-nnencernent of the proceeding.

(6)

Guarantor agrees to remain bound under this guarantee notwithstanding -any inodificatipn or alternation of any obligation of PSEG Fossil LLC or PSEG Nuclear LLC, pursuant to N.J.A.C. 7: 1E; (7)

Guarantor agrees to remain bound under this guarantee for so long as PSEG Fossil LLC or PSEG Nuclear LLC must comply with the applicable financial responsibiliy requirements of NJ.A.C. 7:IE-4,4 for the above-identifid facilities, except that guarantor may cancel this guarantee by sending notce by ce'rtfied mailio SEG Fossil LLC and PSEG Nuclear LLCJ, and the Department, such cancellation to become effective no earlier than 120 days after receipt of such notice by PSEG Fossil LLC and PSEG Nuclear LLC, as evidenced by the return receipt.

(8)

The guarantor'.s obligation does unt apply to any of the following:

(a)

Any obligetion of PSEG Fossil LLC or PSEG Nuclear LLC, under a worker's compensation, disability benefits, or unemployment compensation law or other similar law; (b)

Bodily injury to an employee of PSEG Fossil LLC or PSEG Nuclear LLC, arising fiom, and in the course of, employment by PSEG Fossil LLC or PSEG Nuclear LLC;-

(6)

Bodily injury or property damage not related to a discharge arising from the ownership, maintenance, use, or entrustment to orfiers of any aircraft, motor vehicle, or-watercraft; (d)

Property damage to any property owned, rented, loaned to, in the care, custody, or corotrol of, DO occupied by PSEG Fossil LLC or PSEG Nuclear LLC that is not tbe direct result of a discharge from the facility; (c)

Bodily damage or property damage foi which PSEG Fossil LLC or PSEG Nuclear LLC is obligated to pay damages by reason of the assumption of liability in a contract or agreement other than a contract or agreernent

)

.entered into to meet the requirements of NI..A.C, 7:1 E-4.4.

I UG-23-2004 13:03 PSEWS DEC U02 12bY F - IUI12 (9)

Guarantor expressly waives notice of acceptance of this guarantee by the Department or by PSEB Fossil LLC or PSEG Nuclear LLC.

I hereby certify that the wording of this guarantee is identical to the wording spccified in Appendix 13 of NJ.A. C. 7:1E as such rules were constituted on the effective date shown immediately below.

Effective date: April 20, 2004 PSEG Power LLC 14arold F. Borden Vice President and General Counsel PSEG Power LLC Signature of witness or notary:

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DI(i Park Plumu, T06, 1lewarIt, NJ 0710.2 wal: 973.430.,6506 m. 873.8O2.126/

snalil: J Dbr.'mloriJr@ys~w~u~..oan 0 PSEG Se~rnvccs Corp oration To:

Harold W. Borden, Eaq.

Chrisfine T. Needy John P. Ryan hMichael G. Culle.

Yames H. Pearb Bruce S; ?etroyski Mark D. Schwartzkopf James Eggers From: John G. Valeri Jr., Esq.

Dv+/-o: Ma 6, 2Q04-Re:

DPCC JDCRkns -Financial Responsibility Enml.osed please find a copy of NJD1PBs aclcrnwledgement of receipt of updated financial responsibility dDouments. As indicated in the ltteg, eadh generating station must keep a copy of the finncial responsb y documeits on-pite. A copy of those d6cuments were previously forwarded to you undier sqparate cover.

If you have any questions orrequire additional copies of financial responsiilit documents, please contact me.

JGCVjb CC:

Cbristopher J. McAuliffe, Esq.

Tasweer M. Syed

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973 802 i267 P. 12/12 RUG-23-200 4 PSESJG DEC

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De~partment of Environmenalk Prtecdion Bureau of Relengh Prevanflon FL 0. Box 424 Trenton~, N.J. 0B526 181!

(609) 6!33*D10 Fax: (609) 6N.7031 James E. Mt-Groevoy Goverflor Er~mdley 1~4.

Camnpball May 3, 2004 Jomh G.Valeri, Jr.

Assistant General Environmntal Counsel PSEG Bzrvices Corporation so ParkPI=a, T5C.

Ncwrk NJ 07102 Re:

Discharge Prevention, Containment and Countermeasure (DPCC) and DiBsharge Cleanup and kenoval (DCR) Plans - Finman Responsibility for PSEG Fossil LLC and.PSEQ Naholcar T12C fwflfities in NJ Bergen- 024900142000 Burlington- 030600142000.

Essex - 071401223000 Hudson - 090601488000 Lindn-200900920000 Mercer-110300168000 Salem &EHope Creek-170400041000 Edison - 120501202ODD 1 Zamy - 090700466000 Sewarn-122501297000 DcarWr. Valeri:

Thank you for the updated financial TcsponsHili ydoomnents, dated April 26, 2004 for tbe above-referencod major facfi6es in New Jersey.

The financial tcst of self imsmmce and gumantee 'have been included in the departments copies of thc D)PCC/ICF plans for fhe above referenced ofilibies. Sinoe these documents are Jpart of approved DPCCTDCR plans, these facilities must also keep a copy c site as iaquiredby NJA.C. 7:IE4.6(i):

If you have 4ny question regarding this letter, please contact Philip Polios at (6.09) 292-1 690.

Paul Baldauf, Ehe Bureau of Release P enti L a; Beth S. Reddy, Section Chief, Engineering Review Section Prit R. Pals, Supervisor, Field Verification Seotion Philip Polios, Chemical Safety Engineer Audrey S. Dorofy, Chemical Safety Engineer Chris~tplier Lucien, Principal Environmethtal tngineer

'Yefirn Kantor, Principal Environmental Engineer Roy Soong, Environimcntal Bngineer JHN a.

V ALERI n=OffWT~EM. N~nMAZD(TA] 7iNi