ML14170A020
| ML14170A020 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 06/09/2014 |
| From: | Gregory H Public Service Enterprise Group |
| To: | Office of Nuclear Reactor Regulation, State of NJ, Dept of Environmental Protection |
| References | |
| 14-05-14-1650-51, LR-E14-0090 | |
| Download: ML14170A020 (19) | |
Text
PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 4-0090 0 PSEG Dated: NuclearLLC Certified' 4I, RtUMr*IReceipt Requested Article Number: 7012 1640 0000 4257 4975 Bureau of Release Prevention New Jersey Department of Environmental Protection PO Box 420, Mail Code 22-03D Trenton, New Jersey 08625-0420 Attn: Discharge Confirmation Report RE: PSEG Nuclear LLC - Salem Generating Station NJDEP Case #14-05-14-1650-51, Operator #61 30-day Discharge Confirmation Report
Dear Sir/Madam:
In accordance with N.J.A.C. 7:1E-5.8, PSEG Nuclear LLC (PSEG) is submitting the enclosed discharge confirmation report. This report describes the initial call made to the hotline of the discharge of approximately 5 gallons of diesel fuel oil discharged to the ground.
The discharge was reported to the New Jersey Department of Environmental Protection (NJDEP) hotline at 16:50 hours on May 14, 2014 and assigned case number 14-05 1650-51 by Operator #61. This discharge was also reported to the Nuclear Regulatory Commission (NRC) pursuant to that agency's requirements.
The enclosed report contains the information as known at the time of this report.
Should you have any questions or require further information, please do not hesitate to contact me at (856) 339-1341, Helen.Gregoryvpseg.com.
Sincerely, Helen Gregory Environmental Compliance Manager - Nuclear Attachments (3)
Bureau of Discharge Prevention - Discharge Confirmation Report LR-E14-0090 cc: U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 NJDEP Site Remediation Program P.O. Box 420, Mail Code: 401-05H Trenton, NJ 08625-0420 NJDEP - Water Compliance and Enforcement Southern Water Enforcement Attn: Steven Mathis 2 Riverside Drive, Suite 201 Camden, NJ 08103 Lower Alloways Creek Township 501 Locust Island Road PO Box 157 Hancock's Bridge, NJ 08038 2
Bureau of Discharge Prevention - Discharge Confirmation Report LR-E14-0090 This Page Intentionally Left Blank 3
Bureau of Discharge Prevention - Discharge Confirmation Report LR-E14-0090 Discharge Confirmation Report PSEG Nuclear LLC - Salem Generating Station NJDEP Case No. 14-05-14-1650-51 7:1E-5.8(c), Confirmation Report:
- 1. Name, Address and Telephone Number of Individual who Reported:
Name: Karl Hantho
Title:
Shift Operations Manager PSEG Nuclear LLC - Salem Generating Station PO Box 236 Hancocks Bridge, NJ 08038-0236 (856) 339-5200
- 2. Name, Address and Telephone Number of Individual Submitting Report:
Name: Helen Gregory
Title:
Environmental Compliance Manager - Nuclear PSEG Nuclear LLC PO Box 236 Hancocks Bridge, NJ 08038-0236 (856) 339-1341
- 3. Name, Address and Telephone Number of Owner/Operator of Facility Where Discharge Occurred:
PSEG Nuclear LLC - Salem Generating Station PO Box 236 Hancocks Bridge, NJ 08038-0236 (856) 339-1341
- 4. Source of Discharge, if known:
A flanged connection on a diesel fuel oil supply line to the Service Water Intake Structure (SWIS) Hot Air Furnace leaked causing approximately 5 gallons of diesel fuel oil to the ground.
- 5. Location of Discharge:
Name: PSEG Nuclear LLC - Hope Creek Generating Station Street Address: Hancocks Bridge Road Block/Lot: B-26, L-4.01 Municipality: Lower Alloways Creek County: Salem Site Map: Identified on the Site Map in Attachment B.
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Bureau of Discharge Prevention - Discharge Confirmation Report LR-E1 4-0090
- 6. Common Name and Chemical Abstract Service (CAS) number of each hazardous substance discharged:
- Diesel Fuel Oil (DFO)
- 7. Quantities of each hazardous substance discharged:
- Approximately 5 gallons of DFO.
- 8. Date and Time Discharge Began, Was Discovered, Ended and Was Reported:
Case No. 14-05-14-1650-51 Began: 05/13/14 Discovered: 05/13/14 at 17:05 Ended: 05/13/14 at 17:45 Reported: 05/14/14 at 16:50
- 9. Detailed Description of Containment, Cleanup and Removal Measures Summary of Cost Incurred:
A drip pan was placed under the leaking flange. The inlet isolation valve was closed to isolate and stop the leak. The impacted area was excavated to remove DFO contaminated soil/asphalt. Cleanup costs are estimated to be approximately
$45,000.
- 10. Detailed Description of Corrective Actions or Preventative Measures:
" Stopped and isolated the leak by closing supply inlet valve
- Contained the leak via drip pans
" Cleaned up and removed the soil in the impacted area
- Visually inspected other areas of the line
- Evaluation of the line is planned
- 11. Name, Address and Telephone Number of Cleanup Entities:
PSEG Nuclear LLC - Salem Generating Station PO Box 236 Hancocks Bridge, NJ 08038-0236 (856) 339-1341
- 12. Description of Sample Date, Type, Quantity and Location Four (4) samples were collected from the impacted/excavated area and analyzed by an outside certified lab for Total Extractable Petroleum Hydrocarbon (EPH). At the conclusion of the cleanup, all four (4) sample results were less than the soil cleanup criteria (1700 mg/kg). The following samples were taken:
Sample ID SW-DE-W -sample date 5/23/14 - Total EPH = non-detect Sample ID SW-DE-F - sample date 5/23/14 - Total EPH = 418 mg/kg 5
Bureau of Discharge Prevention - Discharge Confirmation Report LR-E14-0090 Sample ID SW-DE-S - sample date 5/23/14 - Total TPH (initial) = 2330 mg/kg post excavation/cleanup 6/2/14 = 39.8 mg/kg Sample ID SW-DE-E - sample date 6/2/14 - Total EPH = 25.1 mg/kg
- 13. Certification of Financial Responsibility- Included as Attachment C
- 14. Supplemental Information - Initial estimate of 5 gallons; updated estimate of approximately 25 gallons.
- 15. Any Additional Information - In accordance with N.J.A.C. 7:1E-5.3(e)2, the discharge was reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of determining that cleanup could not be completed within 24-hours.
- 16. Certification of highest ranking individual - Included as Attachment A 6
Bureau of Discharge Prevention - Discharge Confirmation Report LR-E14-0090 ATTACHMENT A Certificationin accordance with 7: 1E-4. 1 (a) 7
Bureau of Discharge Prevention - Discharge Confirmation Report LR-E14-0090 Discharge Confirmation Report PSEG Nuclear LLC - Hope Creek Generating Station NJDEP Case No. 14-05-14-1650-51 7:1E-4.11(a), Certification:
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.
Lawrence M.W er Date:
Plant Manager - Salem PSEG Nuclear, LLC 8
Bureau of Discharge Prevention - Discharge Confirmation Report LR-E14-0090 ATTACHMENT B Site Map 9
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GENERAL SITE PLAN SALEM
&HOPE CREEKGERANOTI STATIONS BLOCK28 - LOTS 4. 4.01, 5 & 5.01 ShM 2od 3 SEE SHEET I OF 3 FOR NOTES A REFERENCES, ETC.
Bureau of Discharge Prevention - Discharge Confirmation Report LR-E14-0090 ATTACHMENT C Certification of FinancialResponsibility 10
Kieran A. Brown Office of Environmental Counsel Assistant General Environmental Counsel 80 Park Plaza, T17, Newark, NJ 07102 tel: 973A30.6124 fax: 973.802-1267 email: Kieran.Brown@pseg.com 0 PSEG Sernjire.s Co(]oratiwl April 23, 2014 Bureau of Release Prevention New Jersey Department of Environmental Protection Station Plaza 4 22 South Clinton Ave, 3 rd Floor - CN 424 Trenton, NJ 08625 Re: Financial Responsibility Documents PSEG Fossil LLC PSEG Nuclear LLC Ladies and Gentlemen:
Enclosed are an original and ten copies of updated financial responsibility documents pursuant to N.J.A.C. 7:1E-4.4. The enclosed documents include the Chief Financial Officer's Letter and a Guarantee executed by the President and Chief Operating Officer of PSEG Power LLC. Each specifies the eleven major facilities that are covered.
If you have any questions, please do not hesitate to contact me.
Sincerely, KieranABrw Enclosures
GUARANTEE Guarantee made this April,23, 2014 by PSEG Power LLC, a business entity organized under the laws of the State of Delaware, herein referred to as guarantor, to the New Jersey Department of Environmental Protection ("Department") and to any and all third parties, and obligees, on behalf of its wholly owned operating subsidiaries, PSEG Fossil LLC, which operates the Bergen, Burlington, Essex, Edison, Hudson, Kearny, Linden, Mercer and Sewaren Generating Stations and PSEG Nuclear LLC, which operates Hope Creek and Salem Generating Stations, of 80 Park Plaza, Newark, New Jersey 07101.
(1) Guarantor meets or exceeds the financial test criteria of N.J.A.C. 7:lE-4.4(g) and agrees to comply with the requirements for guarantors as specified in N.J.A.C.
7:lE-4,4(h).
(2) PSEG Fossil LLC, a wholly owned subsidiary of guarantor, operates the following major facilities covered by this guarantee:
Bergen Generating Station Victoria Terrace Ridgefield, New Jersey 07657; Hudson Generating Station Duffield & Van Keuren Avenues Jersey City, New Jersey 07306; Kearny Generating Station Foot of Hackensack Avenue Kearny, New Jersey 07032; Essex Generating Station 155 Raymond Boulevard Newark, New Jersey 07105; Linden Generating Station Grasselli Area of Wood Avenue South Linden, New Jersey 07036; Sewaren Generating Station
.751 Cliff Road Sewaren, New Jersey 07077-143 9; Edison Generating Station 164 Silver Lake Avenue Edison, New Jersey 08817;
Mercer Gerferating Station Lamberton Road Trenton, New Jersey 08611; and Burlington Generating Station W. Broad Street & Devlin Avenue Burlington, New Jersey 08016.
PSEG Nuclear LLC, a wholly owned subsidiary of guarantor, operates the following major facilities covered by this guarantee:
Salem Generating Station Foot of Buttonwood Road P.O. Box 236 Hancocks Bridge, New Jersey 08038; and Hope Creek Generating Station Foot of Buttonwood Road P.O. Box 236 Hancocks Bridge, New Jersey 08038 This guarantee satisfies the requirements of N.J.A.C. 7:1E-4.4 for assuring funding in the amount of $1,000,000 per occurrence per facility and $2,000,000 annual aggregate per facility for cleanup and removal activities arising from operating the above identified major facilities.
(3) On behalf of our wholly owned operating sbsidiaries, PSEG Fossil LLC and PSEG Nuclear LLC, guarantor guarantees to the Department and to any and all third parties that:
In the event that PSEG Fossil LLC or PSEG Nuclear LLC fails to provide alternate coverage within 60 days after receipt of a notice of cancellation of this guarantee and the Department has determined or suspects that a discharge has occurred at a facility covered by this guarantee, the guarantor, upon instiuctions from the Department, shall fund a standby trust fund in an amount sufficient to cover cleanup and removal costs, but not to exceed the coverage limits specified in N.J.A.C. 7:11E-4.4(b).
In the event 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 amount sufficient to cover cleanup and removal costs, but not to exceed the coverage limits specified above.
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(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 criteria of N.J.A.C. 7:lE-4.4(g), guarantor shall send within 120 days of such failure, by certified mail, notice to PSEG Fossil LLC and PSEG Nuclear LLC and the Department. The 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 the return receipt.
(5) Guarantor agrees to notify PSEG Fossil LLC and PSEG Nuclear LLC by certified mail of a voluntary or involuntary proceeding under Title 11 (Bankruptcy), U.S.
Code, naming guarantor as debtor, within 10 days after commencement of the proceeding.
(6) Guarantor agrees to remain bound under this guarantee notwithstanding any modification or alteration 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 responsibility requirements of N.J.A.C. 7:1E-4.4 for the above-identified facilities, except that guarantor may cancel this guarantee by sending notice by certified mail to PSEG Fossil LLC and PSEG Nuclear LLC, 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, or 120 days from the date of receipt of the notice by the Department, whichever is later, as evidenced by the return receipt.
(8) The guarantor's obligation does not apply to any of the following:
(a) Any obligation 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 from, and in the course of, employment by PSEG Fossil LLC or PSEG Nuclear LLC.
(c) Bodily injury or property damage not related to a discharge arising from the ownership, maintenance, use, or entrustment to others of any aircraft, motor vehicle, or watercraft; (d) Property damage to any property owned, rented, loaned to, in the care, custody, or control of, or occupied by PSEG Fossil LLC or PSEG Nuclear LLC that is not the direct result of a discharge from the facility; (e) Bodily damage or property damage for 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 agreement entered into to meet the requirements of N.J.A.C. 7:1E-4.4.
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(9) Guarantor expressly waivesnotice of acceptance of this guarantee by the Department or by PSEG Fossil LLC or PSEG Nuclear LLC.
I hereby certify that the wording of this guarantee is identical to the wording specified in Appendix B of N.I.A.C. 7: 1E as such rules were constituted on the effective date shown immediately below.
Effective date: April -' ,2014 PSEG Power LLC William Levis President and Chief Operating Officer Signature of witness or notary:
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LETTER FROM EXECUTIVE VICE PRESIDENT AND CHIEF FINANCIAL OFFICER I sn the Executive Vice President and Chief Financial Officer of PSEG Power LLC, 80 Park Plaza, P.O. Box 1171, Newark, New Jersey 07101-1171. This letter is in support of the use of the financial test of self-insurance and/or guarantee to demonstrate financial responsibility for cleanup and removal activities arising from operating:
Bergen Generating Station Victoria Terrace Ridgefield, New Jersey 07657; Hudson Generating Station Duffield & Van Keuren Avenues Jersey City, New Jersey 07306; Kearny Generating Station Foot of Hackensack Avenue Kearny, New Jersey 07032; Essex Generating Station 155 Raymond Boulevard Newark, New Jersey 07105; Linden Generating Station Grasselli Area of Wood Avenue South Linden, New Jersey 07036; Sewaren Generating Station 751 Cliff Road Sewaren, New Jersey 07077-1439; Edison Generating Station 164 Silver Lake Avenue Edison, New Jersey 08817; Mercer Generating Station Lamberton Road Trenton, New Jersey 08611; Burlington Generating Station W. Broad Street & Devlin Avenue Burlington, New Jersey 08016;
Salem Generating Station Foot of Buttonwood Road P.O. Box 236 Hancoeks Bridge, New Jersey 08038; and Hope Creek Generating Station Foot of Buttonwood Road P.O. Box 236 Hancocks 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 owner or operator to demonstrate evidence of financial responsibility in the following amounts under the following EPA or State rules or regulations (i.e., RCRA, ECRA, UST, etc.):
N/A This owner or operator has not received an adverse opinion, a disclaimer of opinion, or a going concern qualification from an independent auditor on his or her financial statements for the latest completed fiscal year.
ALTERNATIVE I (Millions)
I. Amount of annual DCR aggregate:coverage being assured by a financial test arid/or guarantee $ 22
- 2. Amount of annual aggregate coverage for all other Federal or State regulatory costs (i.e. RCRA, ECRA, UST, etc.) covered by a financial test, and/or guarantee $ 0
- 3. Sum of lines I and 2 $ 22
- 4. Total tangible assets $ 11,953
- 5. Total liabilities [if any of the amount reported on line 3 is included in total liabilities, you may deduct that amount from this line and add that amount to line 6]- $ 6t44
- 6. Tangible net worth [subtract line 5 from line 4] $ 5,80 YES NO
- 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. Have financial statements for the latest fiscal year been filed with the Rural Utilities Services or the Board of Public Utilities? ______ x
- 12. Has financial information been provided to Dun and Bradstreet, and has Dun and Bradstreet provided a financial strength rating of 4A or 5A? [Answer Yes only if both criteria have been met] ______ x I hereby certify that the wording of this letter is identical to the wording specified in Appendix B of N.J.A.C. 7:IE, as such rules were constituted on the date shown immediately below.
Caroline Dorsa Executive Vice President and Chief Financial Officer Date: April23 ,2014