ML20034C081
| ML20034C081 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 04/26/1990 |
| From: | Maine Yankee |
| To: | |
| Shared Package | |
| ML20034C080 | List: |
| References | |
| NUDOCS 9005020047 | |
| Download: ML20034C081 (91) | |
Text
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I MAINE YANKEE ATOMIC POWER COMPANY j
APPLICATION TO DISPCSE OF SLIGHTLY CONTAMINATED STEAM GENERATOR WASTI: CHEMICAL CLEANING SOLUTION l
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l 8457R 9005020047 900426,9 PDR ADOCK 0500030 PDC p
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TABLE OF CONTENTS lagt
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TABLE OF CONTENTS................................................
ii' LIST OF TABLES...................................................
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1.0 INTRODUCTION
1
2.0 DESCRIPTION
OF WASTE.............................................
2 2.1 Physical Properties........................................
2 2.2 Chemical Properties........................................
2 2.3 Radiological Properties....................................
3 2.4 Operational Factors........................................
4 3.0 PROPOSED DISPOSAL METH0D.........................................
6 4.0 RADIOLOGICAL ASSESSMENTS AND RESULTS.............................
7 4.1-Comparison to MPCs and Plant Effluent......................
8 4.2 Dose Estimate for Disposal at Hazardous Waste Facility.....
10 4.2.1 External Exposure to a Truck Driver During. Transport...................................
11 4.2.2 External Exposure to a Waste Processing' 3
Facility Employee..................................
11 4.2.3 Exposure to an Intruder Due to Disposal at Waste Facility Landfill............................
12 4.2.3.1 Direct Exposure Due to Standing Atop the Material.........................
12 4.2.3.2 Intruder Exposure.After Site Closure......
12 4.2.3.3 Exposure Due to Liquid Release Pathway....
14 5.0 ENVIRONMENTAL IMPACT C0NCERNS....................................
17 6.0 SUMHARY AND CONCLUSIONS..........................................
18
7.0 REFERENCES
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ATTACHMENT A - Chemical Cleaning of Maine Yankee Steam Generators -
A-1 ATTACHMENT B - Dupont, Audit Information Wastewater Treatment Facility Chambers Works B-1 8457R m
LIST OF TABLES Number Title Eggg 2.1' Chemical Cleaning Solution 5
2.2 Radiological Parameters and Properties 5_
4.1 Comparison of MPC Liquid Discharge Limits 15 4.2 Comparison of Liquid Waste Activities 15 4.3 Usage Factors 16 l
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l MAINE YANKEE ATOMIC POWER COMPANY
~ APPLICATION FOR APPROVAL T0' DISPOSE OF SLIGHTLY CONTAMINATED l
l CHEMICAL CLEANING ~ SOLUTIONS
1.0 INTRODUCTION
t Maine Yankee has generated an inventory of approximately 10,500 gallons of chemical cleaning solution as a result of cleaning the secondary side of
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L its three steam generators to improve heat transfer and reduce the potential L
for tube failure.
Eight batches of solution were generated ~ in the process of chemically cleaning the secondary sides of the three steam generators. Three
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batches had no detectable activity, and the remainder had activity levels in
~7 the 10 pCi/mi range for. gamma emitters when counted for 3,000 seconds.
Changing regulations at radioactive waste disposal sites have made f uture disposal of mixed' wastes (both chemically hazardous and radioactively contaminated) problematical at best. Disposal as radioactive waste will
. require cheraical treatment and solidification to a stable waste,: thereby increasing the disposal volume by at least a factor of two.- This-option, if available ut all, is not consistent with utilizing the limited radioactive waste buriel volume available in an efficient manner.
t A radiological evaluation of processing and disposal as a hazardous.
waste has been performed. Based upon the results of this evaluation and-l conditions of processing and disposal presented herein, Maine Yankee Atomic Power Company requests' authority under 100FR20.302(a) to dispose of _ the slightly contaminated chemical cleaning solution in the same manner as I
noncontaminated chemical cleaning ~ solution of the same type.
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2.0 DESCRIPTION
OF WASTE 2.1 Physical Pronerties During April and May of 1987, Maine Yankee performed chemical cleaning of the secondary side of each of its three steam generators to remove 1
l accumulated tubesheet area oxide deposits (sludge).
The removal of the tubesheet sludge is considered a reasonable preventative maintenance action to avoid copper-induced pitting attack on the steam generator tubes, and to-enhance the validity of eddy current inspections.
Since F.c :e Yankee had not experienced any significant tube leaks during its operating history,-it was expected that the removed sludge would be nonradioactive. However, upon analysis of the sludge resulting from the cleaning activities, it was determined that approximately 10,500 gallons (39,746 liters) of slightly -
contaminated waste cleaning solution had been generated. Attachment A, Chemical Cleanine of Maine Yankee Steam Generators,-provides a description of the cleaning process and chemical properties of the cleaning solution. This l
solution is currently being stored in Lv0 fifty-five (55) gallon drums on the Maine Yankee site.
2.2 Chemical Properties Due to the nature of the cleaning solution, it will necessarily be' classified as hazardous waste under RCRA requirements of the U.S. Environmental Protection Agency. The majority of the cleaning solution is made up of a generic Steam Generator Owner's Group (SGOG) iron solvent, nonsolvent, a Combustion Engineering (CE) modified SGOG copper solvent, and related rinse solutions. The chemical formulation of the solvents are presented in Table 2.1, chemical clesning solution, an excerpt from Attachment A.
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2.3 Radiolonical Propertleg i
1 Eight separate batches of waste chemicals were generated during the
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steam generator cleaning process. All of these batchen were mixed and sampled j
prior to transfer to one holding tank. Representative one liter samples from each batch were counted for 3,000 seconds by a Ge(Li) gamma spectrometer and analyzed for the presence of 6 emitting radionuclides.
The-sample size and counting times resulted in a Lower Limit of Detection (LLD) in the range of IE-7 p01/ml. Three of the eight batches were below the LLD.
For purposes of this analysis / application, it is conservatively assumed that the specific activity of the total inventory is at the highest measured activity level for all radionuclides detected. Table 2.2, Radiological Properties and Parameters, lists the radiological parameters used in this application.
The total activity at time t (January 1990) was estimated by o
Atot(*) " 0" (M"Y 1907) Y '
Where tot (t) = t tal a tivity at time t [pcil, o
A o
Sa
= specific activity [pci/ml] at time of original analysis.
o V
= volume of solution [ml] assumed to be [40',000 liters).
o A
= radiological decay constant [yr-].
o at
= elapsed time [yr] assumed to be 2.67 years for this application.
It should be recognized that the activity estimates are conservative due to the use of maximum concentrations of each nuclide and assuming that concentration is to be constant throughout a 40,000 liter volume. 8457R
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2.4 Oggrational Factors Upon approval of this application, Maine Yankee plans to proceed to schedule the transfer for processing and disposal of the waste chemical cleaning solution to a licensed hazardous waste facility operated by Dupont Environmental Services in Deepwater, New Jersey. Maine Yankee has contracted services from Advanced Environmental Management Services, Incorporated for support in the transfer of this waste.
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i TABLE 2.1 Chemical Cleaninn S 1ution Q
150i20 g/l EDIA pH 10.0iO.2 with NH 0H 4
l 1.010.2% Hydrazine Used for Cooldown pH 7.0f0.2 with NH 0H (Also Used for Checkout Rinse) 4 i
O.75f0.05% C01-801' I
200tS*F Cocoer Solvent Cocoer Rinse CE Proprietary 10i5 ppm Hydrazine pH 10.0f0.2 with NH 0H 4
Used for Heatup J
Final Cleanup Rinse Passivation DI Water 300130 ppm Hydrazine Used for Final Heatup pH 10.0A0.2 with NH 0H 4
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TABLE 2.2 Radiological Parameters and Properties Specific Activity Total Activity Half-Life (uCi/ml)
(uci)
Nuclide (vr)
May 1987 May 1987 January 1990 Co-60 5.27 7.39E-7 29.56 20.81 2n-65 0.67 6.12E-7 24.48 1.55 Cs-137 30.17 1.76E-7 7.04 6.62 s
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c 3.0 PROPOSED DISPOSAL METHOD It is proposed that the slightly contaminated waste cleaning solution be processed and disposed of as hazardous waste without regard to its radioactive content.
It is proposed to utilize the services of an EPA' I
licensed contractor who will pick up truckload quantities of the waste at our facility and transport the material to the Dupont Wastewater Treatment Plant, Chambers Works, in Deepwater, New Jersey. At the time of processing, the waste may be co-mingled with other waste. Attach:nent B contains a description of the Dupont Waste Facility and processing method.
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4.0. RADIOLOGICAL ASSESSMENTS AND RESULIS L
The radiological assessment is divided into two approaches, both using the parameters in Table 2.2.
The first approach was to compare the radioactivity concentrations and total activity in the cleaning solution waste to 10CFR20, Appendix B, Maximum Permissible Concentrations (MPCs) and' actual I
plant liquid releases from 1987 through 1989.
The second approach estimates a dose using conservative assumptions for potential or limiting pathways L
encountered through processing and dispos al at the hazardous waste f acility.
The following outline describes the radiological assessments which have been-I consideredt l
l Radiological Assessment Aeproaches s
1.
Site Release Criteria 1
(a) Comparison to 100FR20, Appendix B MPC limits.
(b) Comparison to 1987, 1988, and-1989 actual plant releases.
2.
Dnse Impact Assessment (a) Potential or Limitine Pathway Excesures l
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Transportation dose to truck driver, ii. Dose to worker processing waste.
iii. Doses due to activity disposal at waste facility secure landfill (direct dose due to standing on waste, inhalation, ingestion of vegetables grown on landfill, and cow milk).
iv.
Dose to individual intaking liquid effluent of waste facility containing waste radioactivity. 8457R
4 4.1 Comnarison to MPCs and Plant Effluents
_j The waste activity concentrations in the cleaning :,olution were compaud to the most restrictive MPC values from 10CFR20 Appendix B (Reference 1) to show that this waste presents minimal radiological concarn.
l-l Table 4.1 sumarizes the radiological parameters for this comparison.
As prescribed in 100FR20, a summation of the' ratio of nuclide discharge concentration, to its appropriate MPC value, shall be less than or equal to
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[ _0_i_.I with credit for dilution in plant liquid effluent MPC.
g where l
C' "
total activity of nuclide i i (uci)
A liquid effluent dilution volume V-(ml)
V = 3.98E+11 ml (420,000 gpm normal discharge flow rate-time 4.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for average batch waste discharge time)
Z_.C.i_ = 5.23E-11 (Co60) + 3.89E-12 (2n65) + 1.66E-11 (Os137)
2.61E-6 <<1.
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As can be seen, the diluted activity concentration would be very much l
less than the MPC limits of 100FR20, Appendix B. if the cleaning solution could be discharged as routine radioactive liquid effluents.
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Alternatively, calculating the nuclide concentration to MPC ratio without credit for dilution also demonstrates that the radioactive levels in the cleaning solution could-easily meet site release criteria if'the hazardous chemical component did not prevent its discharge as normal waste liquid from the site (see Table 4.1 for parameter values); 8457R w
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['_bi_(nodilution)=[5.20E-7(Co60)+3.88E-8(Zn65)+1.66E-7(Cs137))-
'1E-4 2E-5 j
MPC.1-
[ 1.(no dilution) = 2.60E-2 <1.
MPCg 4
For comparison.to'the actual-1987, 1988, and 1989 plant releases (Reference 6), the total cleaning waste activity was compared to the j
actual fission and activation product (not including H-3) activity releases.-
The data on Table 4.2 compares actual plant releases-to the Circulating Water System to the waste cleaning solution activity: presently in storage.
i Table 4.2 illustrates that the total activation and fission product activity of the cleaning solution'is on the order of 0.002% of the average annual liquid waste activity' released from the plant between 1987 and 1989.
During this perio6, a total of 503 batch liquid waste discharges occurred which would result in an average total activity level per batch discharge of 2.81E-3 curies (excluding tr: tium). :In comparison, the total activity in the.
steam generator waste cleaning solution at~2.90E-5 curies, discharged as a single batch, represents only 1.0% of the average activity normally detected in plant effluent waste discharges.
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The total activity and concentration ratios show clearly that the nuclides detected in the steam generator cleaning solution waste are of little or no radiological concern in comparison to normal plant effluents which themselves are well within site release criteria and as per 100FR20 Appendix B, footnote 5** may be' considered as not present.
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- From 100FR20, Appendix B, Note 5; "For purposes of this note, a radionuclide may be considered as not present in a mixture if t (a) The ratio of the concentration of that radionuclide (C ) to A
the concentration limit for-that.radionuclide specified in Table II of Appendix B'(MPC ) does not exceed 1/10.
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(b) The sum of such ratios for all the radionuclides considered as not present in the mixture does not, exceed 1/4, i.e.,
j (C /MPCA+CB 3
MPC..... + 11/4)."
A 4.2 Dose Estimate for Processine and Disposal as Hazardous Waste i
A radiological evaluation has been. performed for the processing and f
disposal of steam generator chemical cleaning solution waste at a licensed I
hazardous waste treatment and disposal facility.
The evaluation included dose estimates due to potential pathways including:
1.
Dose to the worker due to transporting the waste to the disposal facility.
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Dose to a disposal facility worker processing the waste solution.
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3.
External dose to an individual standing on top of the waste disposal facility landfill.
4.
Inhalation of resuspended material, and_ ingestion doses to an individual who stands on and grows' food on the waste disposal facility landfill.
5.
Dose to an individual who ingests-the' liquid effluent from the-waste disposal facility.
In all cases, very censervative assumptions were usedt long exposure 4
times, low dilution values, and constant _ activities.
4.2.1 - External Exposure to a Truck Driven Durine Transport The external dose rate f rom a 5,000-gallon tank filled with the i
cleaning solution wastes was calculated for the purpose of estimating exposures associated with shipping the waste to a disposal facility. A three-dimensional point-kernel shielding code for the determination of direct radiation from gamma radiation emanating from a self-attenuating cylindrical 1
source (DIDOS-IV, Reference 9) was utilized to calculate the external dose rate from the tank truck.
The truck was modeled as a cylindrical _ radiation source with a radius equal to 0.9 me:ers and a length of 7.6 meters. A dose-rate of 2.09E-4 millirems (mrems) per hour for a point one meter from the end of the cylinder along the axis was calculated. No credit for shielding-l l
provided by the tank truck or cab was assumed.
The dose to a truck driver l
making three 600-mile trips, the distance between Wiscasset, Maine and j
Deepwater, New Jersey, at an average of 30 miles per hour is estimated to be j
1.26E-2 mrems.
Based on this calculation, this_ pathway will not lead to I
significant exposure of any individual during transportation'of the waste solution.
4.2.2 External Exoosure to a Waste _frocessine Facility Employee l
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Due to the chemical properties of waste handled at.the Dupont facility,
_ employee's exposure time is kept to a minimum.
There is no. holdup time for incoming waste;-all waste is treated immediately.
Using the dose rate from l
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Section 4.2.1 above, conservatively assuming that it requires an employee ~ a full eight-hour day to process each truckload of waste, and not taking any
, credit for dilution or increased distance from the waste, a waste processing facility employee's dose is estimated to be 5.02E-03 mrem.
4.2.3 Exposure to an Intruder Due tp Disposal at Waste Facility fandfill All precipitates from the disposal process are disposed of on-site in secure landfills.
(See Figure " Secure Landfill" in Attachment A.) For the purposes of this calculation, the following dose scenarios were assumed.
In each case, the total undecayed activity is assumed to be present at the time the intruder occupies the site.
4.2.3.1 Direct Exoosure Due to Standine Atoo the Mateeini I
i It is assumed the total activity is uniformly distributed within the mass of waste produced at the facility in one day (from Attachment B, 120 tons j
per day). This waste is spread in a one-inch thick layer, forming a circular source of approximately 93 feet radius. At this point, it is assumed an intruder arrives to occupy the site, spending 2,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> per year standing at~
the center of this source. This is an extremely conservative assumption in~
l that no credit is taken for shielding or dilution by future disposal and cover l
1 operations at this controlled facility. Considering realistic occupancy times and shielding provided by cover material, doses of 100 to 1,000 times lower _
than reported herein might represent an upper bound.
i The resulting dose rate one meter above the unshielded mass of waste is calculated to be 1.72E-4 mrem /bour or 0.34 mrem for 2,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of exposure.
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4.2.3.2 Intruder Exposure After Site Closure i
Closure requirements for this site specify capping of the waste.with a t
minimum six foot soil and clay cover.
It is assumed the total activity is mixed with this cover materials over the five-acre area of this secure 8457R i
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landfill. No credit is taken for an institutional control period (zero decay) and the intruder.is assumed to_insnediately occupy the site and provide for his food needs by growing crops on_the site.
L The following pathways were addressed for the inadvertent intruders l.
(a) Inhalation of resuspended radioactivity.
(b) Ingestion of leafy vegetables.
(c) Ingestion of stored vegetables.
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(d) Ingestion of cow milk.
(e) Liquid pathways.
Radiation exposures were computed for all pathways, with one l
exception. The liquid pathway was considered to be "not credible" considering the double liner and monitoring requirements imposed on the disposal facility by the U.S. Environmental Protection Agency (USEPA).
The liquid pathway is I
considered in the following section as a direct release to the river.
It should be noted that agricultural activities are not permitted on closed secure landfill sites, and in all probability, should they occur, the impacts due to the hazxrdous characteristics of other wastes disposed in the facility would far outweigh the minimal radiological impacts due to-disposal of this cleaning solution. This radiological impact evaluation is not expected to be representative of any existing or potential pathway, but has been performed to demonstrate that these pathways could also be accommodated within any existing or proposed dose criteria for release or disposal.
Pathway data-and usage factors as applicable to the disposal facility are shown in Table 4.3, which are consistent with Regulatory Guide 1.109 (Reference 2) guidelines and Maine Yankee's Off-Site Dose Calculation Manual (ODCM) (Reference 5) for assessment of off-site radiological impact due to routine releases, with the following exceptions: >
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t (a) The soil. exposure time for spreading of the radioactivity content was changed from a standard of 15 years to 1 year.
(b) The fraction of stored vegetables grown onithe contaminated land was conservatively increased from 0.76 to 1.0'.
(c) The crop exposure time was changed from 2,160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> to 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> to reflect the condition that no radioactive material ~will be dispersed directly on crops for human or animal consumption, the deposition on crops of resuspended radioactivity being insignificant 1y small; that is, crop contamin'ation is only through i
root uptake.
The maximum' calculated hypothetical whole body doce from these unlikely inhalation / ingestion exposure pathways is'4.51E-3 mrem to child.
The maximum hypothetical organ dose is 9.66E-2 mrem to teen lung.
4.2.3.3 Exposure Due to Liquid Release Pathway e
To estimate the upper bound dose impact resulting fLom a potential upset in waste processing that hypothetically results in release of radioactivity to the Delaware River, it is-assumed the total radioactive content of the cleaning rolution remains in the liquid phase and is released to the river over a one-day period. Dilution credit is taken only for the 28.8 million gallon per day release.from the facility.
No further credit is assumed for dilution in the Delaware River. An individual is assumed to consume this liquid at the " reference man" rate of 2.2. liters per day for a full year. Based upon ICRP-30 models and recommendations, the annual dose i
estimate is 6.41E-3 mrem.
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TABLE 4 1 2
Nuclides. Activities. Volumes. MPCs Specific Activity Total Activity Without With MPC (uci)
Dilution (1) Dilution (2)
(Most Restrictive) fu l/ml)
(uci/ml) e Nuclide January 1990 0o-60 20.81 5.20E-7 5.23E-11 I 3E-5 Zn-65 1.55 3.88E-8 3.89E-12 S 1E-4 Cs-137 6.62 1.66E-7 1.66E-11 S 2E-5 (1) Volume of waste used was 40,000 liters.
(2) Volume of plant liquid discharge dilution flow during normal power operation and average batch waste discharge duration (420,000 gpm x 4.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) - 3.98E+11 ml. effluent was 3.18E+9(1/d).
TABLE 4.2 Comparison of Liould Waste Activities A,etual Plant Liould Releases (C1) 1931 1283 193 2 SG Cleanine Solution (Ci) 00-60 1.63E-1 4.96E-2 3.47E-2 2.08E-5 Cs-137 3.88E-2 2.90E-2 1.60E-2 6.62E-6 Zn-65 ND*
ND*
9.39E-8 1.55E-6 Total all Fission / Activation Products 8.81E-1 3.49E-1 1.83E-1 2.90E-5
- Not detected.
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TABLE 4.3 I
Usage Factora Vegetables Leafy Veg.
Milk Meat Inha}ation Individual (kg/vt1_.
(km/vr)
(1/vr)
(km/vr)~
(m /vr)
Adult 520 64 310 110 8,000 Teen 630 42 400 65 8,000 child 520 26 330 41 3,700 330 1,400 Infant VEGETABLE PATHWAY Sj;ored Vegetables Leafy Venetables Agricultural productivity (kg/m2) 2.0 2.00 Soil surface density (kg/m2) 240.0 240.0 Transport time to user (hours),
0.0 0.0 Soil exposure time (hours) 8,766.0 8,766.0 Crop exposure time to plume (hours)
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.0 Holdup after harvest (hours) 1,440.0 24.0 Fraction of stored vegetables grown in garden 1.0 Fraction of leafy vegetables grown in garden 1.0 COW-MILK PATHWAY Pasture Feed Stored Feed 2
Agricultural productivity (kg/m )
,7 3,0 Soil surface density.(kg/m2) 240.0 240.0 Transport time to user (hours) 48.0 48.0 Soil exposure time (hours) 8,766.0 8,766.0' Crop exposure time to plume (hours)
.0
.0 Holdup after harvest (hours)
.0 2,160.0 Animals daily foed (kg/ day) 50.0 50.0 Fraction of year on pasture
.5 Fraction pasture when on pasture 1.0
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I 5.0 ENVIRONMENTAL IMPACT CONCERNS Attachment B provides environmental information on-the proposed disposal site, Dupont Environmental Services, Chambers Works Wastewater
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Treatment Plant.
Some of the information included ist o-Description of disposal techniques.
o Description of the site including topography, geology, and meteorology.
o A description of nearby land uses.
o A description of the sites emergency and site closure plan.
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6.0
SUMMARY
AND_ CONCLUSIONS The maximum calculeted annuci exposure of 0.34 mrem, resulting from stanaing on the exposed waste material for 2,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> is considered extremely conservative, perhaps by a factor of 100 to 1,000.
The transportation dose to the truck driver making three trips from Maine to Delaware reprosents the most probable real exposure and is estimated at 1.26E-2 mrem.
Other pathways evaluated result in lower potential exposures and present no radiological impact.
The radiological evaluation demonstrates that disposal of 21pci of Co-60, 1.5 pCi of Zn-65, and 7 pCi of Cs-137, as a hazardous waste without regard to its radioactive content has no significant radiological impact, and is well below the Maine Yankee site release requirements, the ALARA dose criteria of Appendix I to 10CTR50, and result in exposures which are only small fractions of annual exposures received from natural background sources.
It is, therefore, concluded that the disposal of the accumulated secondary side steam generator cleaning solution (10,500 gal.) generated at Maine Yankee should be permitted as a hazardous waste product without concern for the radioactivity contents. 8457R
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7.0 REFERENCES
1.
Code of Federal Regulations, Energy 10, Parts 20, Codified and Reissued as of November 1988.
2.
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.109, Calculation of Annual-Doses to Man From Routine Releases of Reactor Effluent for the Purpose of Evaluation Compliance With 10CFR50, Appendix I.
3.
Annals of the Internationel Committee on Radiation Protection.
Publication 30, 1981.
4.
Federal Guidance Report No. 11, Limiting Values of Radionuclide Intake and Air Concentration and Dose Conversion Factors for Inhalation, Submersion and-Ingestion, 1988.
l 5.
Maine Yankee Atomic Power Company Off-Site Dose Calculation Manual.
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6.
Maine Yankee Atomic Power Company, Semiannual Release Reports:
January-June 1987
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July-December 1987 January-June 1988 i
July-December 1988 January-June 1989 July-December 1987 7.
Audit Information Wastewater Treatment Plant Chambers Works, Dupont Environmental Services, Sweetwater, New Jersey.
l 8.
Chemical Cleaning of Maine Yankee Steam Generscors, Pacific Nuclear Fervices, Final Report, June 1987.
9.
J. N. Hamawi, / DIDOS-III - A Three-Dimensional Point-Kernel Shielding Code for Cylindrical Sources, ENTECH Engineering, Inc., Technical Report P100-R2, December 1982 (updated to version DIDOS-IV, October 1989, Yankee Atomic Electric Co.)
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ATTACHMENT
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CHEMICAL CLEANING OF MAINE YANKEE L
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June 1987 I
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' FINAL REPORT l
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.by Pacific Nuclear Services y
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'2939 Park Drive Richland, WA 99352 9
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CONTENTS P_Rai S-1.
I PROJECT
SUMMARY
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1.0 INTRODUCTION
2.0 PROCESS DESCRIPTION
'2-1 3-1 3.0-SYSTEM DESIGN 3-1 3.1 Design Basis 3-1 3.2 System Description-3,
3.3 Other System Features d.
4.0 SYSTEM INSTALLATION 4-1 t
5.0 STEAM GENERATOR. CLEANING APPLICATION-5 l 5.1 Steam Generator #2 5-2 l
5.2 Steam Generator #3 5-35 5.3 Steam Generator #1 5-60 6.0 WASTE DISPOSAL
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APPENDICES A
SG #2--Detailed' Chemistry Data and PNS Process Recommendations B
SG #3--Detailed Chemistry Data and PNS Process Recommendations C
SG #1--Detailed Chemistry Data and PNS Process Recommendations-4 4
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3 PROJECT
SUMMARY
y In April-May ' 19 87, Pacific Nuclear Services chemically cleaned the
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three steam generators (SGs) at-the Maine Yankee Atomme Power Plant
'(MY) in:Wiscasset, Maine.
Corrosion monitoring for the cleaning was providad by Combustion Engineering (CE).
wa s ' t o remove accumulated The objective of _ the chemical cleaning.
tubesheet area oxide deposits (sludge) to a level of about 24' inches above the tubesheet, while staying well below the level of the first tube support plate located at ~ 51 inches above the tubesheet.
MY considered efficient removal of the tubesheet sludge to be a prudent and reasonable action to avoid copper-induced pitting attack on the SG tubes and to enhance the validity of eddy current inspection (ECT) in determining the integrity of the tubes.
Although a small number of tubes had been plugged in each SG, MY had-never experienced any significant tube leak during operation.
Therefore it was assumed that the sludge would be non-radioacitve and could be economically disposed of as industrial chemical waste.
In order to protect this option, the chemical cleaning system and the waste storage tanks provided by Pacific _
Muclear-were 2
decontaminated to less than 600- dpm/100 cm before delivery to Maine Yankee.
I Pacific Nuclear's cleaning equipment began arriving in January.
By mid-March personnel mobilization had commenced.
Equipment installation and hydrotest were completed-on _ April 5,
- 1987, as a,
non-critical path activity.
On April 8,
1987, PNS was given access for connection to SG #2 and the chemical cleaning operation was started the following day.
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- Tp porformSnco schedulo cnd duration for cleaning each. SG is summarized as follows:
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i l-12_8 Start (1)
Completion (2)
Duration-2 April 9 0 1315 April 15 6 0400 5 Days 15 Hours 3
April 17 9 1515 April 22 9 2200 5 Days 7 Hours 1
April 29 0 0700 May 3 9 2200 4 Days 15 Hours P
(1) Injection of Checkout Rinse
'a (2)Draindown of Passivation Solution The chemical cleaning process used was a slightly modified version l
of the Steam Generator ' Owner's Group (SGOG) process developed by EPRI.
The process consisted of alternate iron solvent and - copper solvent steps.
The same process sequence was used to clean each SG as follows:
(
Checkout Rinse, 2 Iron Steps, 2 Copper Steps, 1 Iron Step, 2 Copper Steps, Final Rinse / Passivation The SGs were water lanced by CE both before and after the chemical cleaning process.
The chemical cleaning process removed about 800 lbs of sludge from the tubesheet area of each SG.
The water lance operation removed an r
additional 550-1230 lbs of sludge from each SG.
The total sludge l
l removed ranged f rom 1290 lbs for SG #2 to.2105 lbs for SG #3.
The results for each SG are summarized in Table S-1.
Based on post-cleaning ECT of SG #2 and visual examinations in all three SGs, the chemical cleaning appears to have completely removed the cold-log sludge pile and left a 4-10 in. deep ridge of hard sludge on the hot-leg side in the center area of the tube bundle-between the stay rods.
The tubes were visibly clean in all three
[
SGs.
S-2
i l
1 J
J f
Table S-1 SLUDGE REMOVAL
SUMMARY
Sludae Removed (1bs)
SG #2 SG #3 SG #1 Pre-Cleaning Sludge Lance:
436 1,078 1,038 Chemical Cleaning:
. Fe 508 555 501
. Cu 116 147 131
. Zn 45 41 42
. Ni 13 18 15
. Filtered Solids 54 111 84 Subtotal 736 872 773 Post-Cleaning Sludge Lance 118 155 201 Total Sludge Removed 1,290 2,105 2,012-l l
l S-3
l l
I
1.0 INTRODUCTION
I In January 1>87, Maine Yankee Atomic Power Company (MY) contracted f
Pacific Nuclear Services (PNS) to chemically clean the three (3) MY i
The SG cleaning was to be accomplished by cleaning the SGs one at a
time.
Under terms of MY Contract No. 44699-00, Pacific Nuclear's scope of work included the following:
. Provide all necessary chemical cleaning personnel and process equipment.
. Provide sufficient waste storage tanks for segregated storage of iron solvent, copper solvent and rinse wastes.
. Decontaminate the chemical cleaning equipment and waste tanks prior to shipment to MY.
. Provide sufficient chemicals for performing 4 iron and 3 copper cleaning steps in each SG, plus contingency chemicals for an extra step in each SG.
i
. Provide freeze protection for all outside process lines.
. Perform the engineering and procedure preparation necessary to safely apply the cleaning process.
. Provide process monitoring and chemistry analysis during the cleaning.
Provide ion exchangers (if necessary) for processing of rinse waste solutions.
(
Provide other consumables and spare parts, as necessary.
Sludge pile estimates provided by CE were used as the basis for planning the SG cleaning.
The CE estimates were:
. A sludge loading of 715 lbs/SG Sludge composition of 46-66 wts iron, 3 - 15 wtt copper, 1 8 wtt zine and 1
-5 wt% nickel, depending on location of the sludge
.A chemical cleaning process consisting of 4 iron and 3 copper steps for each SG
~
1-1 1
. Application titos of up to 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> for tho loto iron steps and 1 - 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for tho coppor steps
. Use of the generic SGOG iron solvent and the CE proprietary modification of the SGOG copper solvent
.A maximum flow rate of 200 gpm during the iron step and 400 gym during the copper and rinse steps Isolation of the SG blowdown line, except for SG draining l
t The SG sludge was expected to be non-radioactive.
Pacific Nuclear's chemical cleaning system was, therefore, supplied either as new equipment or as used equipment having less than 600 dpm/100 cm contamination.
The chemical mixing equipment and most of the process equipment was mounted in C-vans and located outside of containment in a non-contaminated area.
The equipment area was, however, controlled as a radiation zone to limit any potential for contamination.
Four waste tanks for solvents and rinse solutions and one waste tank for holdup of cooling water were placed in a diked area adjacent to the radiation zone.
~
B l
l l
t l
l i
l-2
2.0 PROCESS DESCRIPTION Chemical removal of sludge from the tubesheet area of the MY SGs was planned as a multi-step application of the generic SGOG iron solvent t
and the CE proprietary modified SGOG copper solvent.
Appropriate 1
rinse solutions were planned when changing between iron solvent and i
copper solvent steps.
The chemical formulation of solvents and rinses is presented in Table 2-1 along with several key process l
parameters.
The application sequence and duration of the process steps for cleaning each SG are listed in Table 2-2.
i 4
I 6
l l
l 2-1
a Table 2-1 CHEMICAL CLEANING CONDITIONS Iron Solvent.
Iron Ri.nig 150 20 g/l EDTA pH 10.010.2 with NH 0H 1
4 1.01 2% Hydrazine Used for Cooldown 0
pH 7.0 0.2 with NH 0H (Also used for Checkout 1
4 0.75 0.05% CCI-801 Rinse) 1 I
p' O
200 S F i
Codder Solvent CoDoor Rinse CE Proprietary 1015 ppm Hydrazine pH 10.0 0.2 with NH 0H 1
4 Used for Heatup Final Cleanuo Rinse Passivation DI Water 300130 ppm Hydrazine pH 10.0 0.2 with NH 0H Used for Final Heatup 1
4 Pre-cleaning Estimate of Sludge Loading:
715 lbs/SG before water lance.
System Volume:
1150 50 gallons / step.
1 Recirculation Rate:
200 gpm during iron step and 400 gpm during copper and rinse steps.
Nitrogen Purge:
Nitrogen blanket for all steps.
Purge SG when changing from iron to copper or copper to iron steps.
Corrosion Monitoring:
Provided by CE.
e i
l t
Table 2-2 j
SG CLEANING PROCESS
SUMMARY
i Time (Hours)
Operation SG #2 SG #3 EQ_si Checkout Rinse and Heatup 12 3
5 re Step #1 6
4.8 6.3 f
Fe Step #2 10 21 15 Fe Rinses and Cooldown 28*
4 3.5 Cu Step #1 2
2 1.5 Cu Step #2 2
3.5 2.5 Cu Rinse and Heatup 4
3.5 3.5 Fe Step #3 28 44 31 Fe Rinses and Cooldown 4
8*
5.5*
l Cu Step #3 2
2.5 2
Cu Step #4 1.5 2
2 Cu Rinse 11**
3 3
Final Rinse 2
7 8
Draindown 0
2 1
Passivation 10 10 10 t'
- Three iron rinse steps were applied (rather than two) due to temporary unavailability of the blowdown line for SG draining or use of extra inhibitor.
- Includes 8 hr " hold" while decision was made to terminate process.
2-3
3.0 SYSTEM DESIGN 3.1 Desian Basis The chemical cleaning system was designed based on the following criteria:
1)
Continuous recirculation of cleaning solutions at nominal flow rates of 200 gpm for iron solvents and 400 gpm for copper i
sc1 vents and rinses.
2)
Use ct modularized components to minimize on-site support requirements for equipment setup and teardown.
3)
Non-radioactive MY SG sludge, allowing most equipment to be located outside containment.
3.2 System Description
5 The Pacific Nuclear chemical cleaning system. consisted of six (6) basic subsystems:
1)
Process Equipment Van (PEV) 2)
Chemical Handling Vans (CHV) 3)
Chemical Mix Tank (T-29) 4)
Waste Holdup Tanks 5)
Process Pumps (in Containment) 6)
Steam Generator Attachments 3.2.1 Process Equipment Van (PEV)
The PEV was a specially modified 40' cargo van which housed the following major components:
4 3-1 i
HEX 60A - 0 300 kw inn 3rsion typ3 heat Cxch0ngor.
an in-line plate type heat exchanger used for HEX 60B cooling process fluid.
l two in-line process filter assemblies, each F-40A&B containing 27 filter cartridges.
The filters were utilized on an alternating basis during the iron solvent and copper solvent steps.
I_,2,1 - a 30 ft 3 capacity ion exchange column used during final system cleanup.
a process sampling station utilized to monitor
.T-lj.
process perf ormance as well as a vented sink to terminate system high point vents.
P 2.1 - an air-operated, double acting, diaphragm pump used for the draindown of equipment in the PEV between process
[
steps.
MCP Main Control Panel containing manual and automatic controls for all process equipment as well as remote indications for all process parameters.
A computerized Data Acquisition Center (DAC) was included in the control' panel and continuously monitored all process
- data, Providing a
CRT display and/or printed record of all process events.
P Utility Services Distribution manifolds were located in the PEV for supply of nitrogen, air and primary water.
The PEV was located outside of the Reactor Building and was the center for monitoring and control of the cleaning process.
3.2.2 Chemical Handling Vans (CHV)
Three modular Chemical Handling Vans were used for handling and transfer of the various chemicals used in the process.
These vans were equipped with stainless steel suction wands and air diaphragm pumps to withdraw liquid chemicals from the shipping drums.
All three vans were equipped with an internal steel liner to contain liquids in the event of a leak or spill.
3-2 i
. CHV #1 This von w3s ustd to transf er motorcd aCounts et
,hydrazinc, c1'c. niu3 hydr 0xide end inhibitor frca shipping dru2s to tho T-29 cix tonk.
Tho van was equipp:d with twa air diaphragm pumps, a metering tank, a flow integrating meter and associated valving mounted on a skid assembly.
The skid was also equipped with a breathing air system and bubble hood respirators for personnel protection during chemical transfers.
CHV #2 This van was used for storage and transfer of EDTA.
EDTA was pumped from standard drums to a 630 gallon i
temporary storage tank by an air-operated diaphragm pump.
The required volumes of EDTA were then transferred from the storage tank to the T-29 chemical mix tank.
CNV #3 This van was used for storage and injection of hydrogen peroxide.
An air-operated diaphragm pump was used H02 directly during the copper solvent steps to inject 2
into the suction of the - process recirculation pump located in containment.
3.2.3 Chemical Mix Tank (T-29) i The T-2C Chemical Mix Tank was a 10.00 gallon horizontal pressure vessel subdivided into three compartments.
The center compartment was used for rinse solution mixing.
The two end compartments were used for iron solvent and copper solvent mixing.
Each compartment contained its own internal heater and the two compartments used fat the solvent mixing each had an internal mechanical mixer.
A vent blower was mounted on top of the Lauk to exhaust chemical fumes to a temporary stack located on top of tne Radwaste Building.
A centrifugal pump mounted under the tanks was used to inject the solutions into the main recirculation system after. mixing.
l l
3.2.4 Waste Holdup Tanks (T-48) l
'ffluents from the SG cleaning wsre transferred Chemical and rinse e
to four 22,000 gallon waste holdup tanks located outside the Reactor Building near the PNS chemical cloaning equipment vans.
Each tank was equipped with an internal submersion heater to prevent i
freezing.
One tank was provided for copper solvent waste, one for iron solvent waste and two for the chemical cleaning rinse wastes.
3-3
'A,fifth tank (T-48G) W3s originally provid0d to b3 o spare W3sto tank.
At MY's request, this tank was used instead for collection of HEX 60B cooling water for holdup and analysis prior to discharge.
3.2.5 Process Pumps in Containment Recirculation flow within the secondary side of each SG was perf ormed utilizing the Pacific Nuclear P-12 process pump.
This is a 75 hp centrifugal pump, capable of providing flow rates in excess of 400 gpm.
An integral closed system on the pump provided seal I
water cooling during operation.
The pump was placed on the floor at the
-2 ft elevation of containment.
An air-operated diaphragm pump (P-38) was located near the P-12 pump for system draining.
During draindown between steps, the SG blowdown line was valved into the suction of this pump to ensure complete removal of any residual liquid heel from the top of the tubesheet.
3.2.6 Steam Generator Attachments Injection and removal of solvent and rinses to the steam generators was performed through secondary side handhole openings located at the 90 and 270 quadrants.
Specially fabricated handhole covers were provided for each handhole to allow the attachments necessary for system operation.
Integral with the 270 cover was a special scoop to allow a pump suction very close to the top of the tubesheet.
This allowed the i
optimum arrangement for sludge removal in the blowdown lane.
An air-operated valve was attached externally to this handhole cover to provide automatic is'olatLon in the event of a system upset.
The 90 handhole cover contained penetrations for level and pressure instrumentation, flexible inlet piping and the process corrosion probe.
3-4 l
3.3 Other System Features cleaning system hor.ing and stainless steel piping between the steam generator and the process recirculation pump (suction) was 4"
size.
Process lines between the P-12 pump and the Process Equipment Van and back to the steam generators (discharge) was 3" size.
All lines external to the Reactor Building and exposed to the environment were protected from freezing by heat tracing and insulation wrap.
The process lines located outside of containment were also routed in a lined hose-through to contain minor system leaks, if any occurred.
Emergency spill equipment was supplied by MY and consisted of 55-gallon barrels containing absorbent
- pillows, ropes, personnel protective clothing, as well as other safety items depending.on location and i:azard potential.
e 0 e
I i
O 3-5 f
I
i 4. 0, SYSTEM INSTALLATION The PNS chemical cleaning equipment was primarily installed outside of containment.
The equipment arrangement outside containment was as shown in Figure
- 4. l.
The chemical cleaning supply and return lines were routed to the Process Equipment Van (PEV) from the system f
recirculation pump (P-12H) located at the
-2' elevation inside containment.
The system drain pump (P-38) and the CE corrosion monitor vessel were located near the P-12 recire.
pump inside containment.
The chemical cleaning flow path is shown in Figure 4-2.
i l
r
)
4
'I i
4-1 l-
f Figuro 4-1 i
MRINE YRNKEE
"'I "O'
Isl,'
SG CHEMICAL CLEANING c
Solvent gegy,nt t
i t
<I ng' 1
t
^
v T-4sA Rinse CHY"2
[DTA CHY"1 NH 0H 4
NH 24 j
0 T-400 Cooling vater CHY"3 i
l H022
\\
i 4-a n
v 4
i Process Equipment Van i
I I
i i.
To r
Cu R
Fe i -
S/G t
e c -
From l
S/G i
4-2 i
6 s
v
e
- ww-
,~ -, -,., -,,, -.., -
,-w
...m.,
,-.-.,,e,
.,,c, w.,
w.3
Figure 4-2 PROCESS FLOM SCHEMRTIC l
l N
/
)
j 27O' NANENOLE 98*RANONOLE p
q L (
J J
i TUBESHEET l
,l l
i j
- TO IlfASTE TRNKS i
i PROCESS EQUIPMENT UAN i
1:
- t 1:
NERTER FILVERS IX F
$)
n s
N 02 1:
1:
COOLER 2
2; INJECTION l,
a FROM CNEM MIN TANK 4-3
.. ~.. -.....
i 500 CHEMICAL CLEANING APPLICATION i
The three (3)
Maine Yankee SGs were chemically cleaned in the following order:
i SG No. 2 - April 9-15
(
SG No. 3 - April 17-22 SG No. 1 - April 29-May 3 A total of 736 lbs, 872 lbs and 773 lbs of mixed oxides and copper (sludge) was removed from each SG, respectively.
Water lance f
. operations before and after the chemical cleaning removed an additional quantity of sludge from each-SG.
The cleaning process applications and sludge dissolution results were surprisingly similar among the three SGs.
The most significant difference between the SGs was the higher sludge removal
[
accomplished by the precleaning water lance of SGs No.
3 and 1 l
(1,078 and 1,038 lbs, respectively) compared to SG No. 2 (436 lbs).
SGs No. 1 and 3 were both drained from wet layup in preparation for l
cleaning, while SG No.
2 was not placed in wet layup until after completion of the chemical cleaning.
The SG draining operation-apparently flushed several hundred pounds of loose sludge onto the tubesneet from the upper regions of SGs No. 3 and 1.
The chemical cleaning application is described - f or each SG in the following sections.
5-1
5.1.
Steam Generator No. 2 l
The MY steam generator chemical cleaning application started'with SG
_t No.
2.
The precleaning water lance by CE removed 623 lbs of wet sludge (equivalent to 436 lbs of dry sludge).
Consistency of the sludge was mostly like fine silt, but included some tube deposit flakes and some coarse weld slag.
The sludge contained trace amounts of several fission product radioisotopes, probably due to carryover of radioactivity from minor fuel defects experienced during the preceding fuel cycle.
The radioactivity levels were as follows:
Isotope Activity (uci/cm)
Co60 4.0 E-5 Csl34 1.5 E-6 Cs 37 7.3 E-6 l
1131 3.0 E-6 Fe59 5.8 E-6 Zn65 1.0 E-5 The chemical cleaning application was started at 1315 on April 9 with injection of the Checkout Rinse solution and completed at 0400 on April 15 with draindown of the Passivation solution.
The total i
duration was 5 days and 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />.
A total of three Fe and four Cu steps were applied, resulting in removal of a total ad 736 lbs of sludge.
The sequence of the chemical cleaning steps and the ampunt of sludge removed by each step are shown in Figure 5-1.
A more detailed breakdown of the amount and composition of sludge removed by each process step is provided in Table 5-1.
More detailed-information on the application of each process step is presented in the following paragraphs.
e 5-2
Figure 5-1 MAIXE YAXKEE CHEM CLEAXING (PNS)
SG #2 - TOTAL SLUDGE REMOVED 350 300 -
~
250 -
z-m
[
200 -
i l
9 V'
l i
M E
j.
150 -
I W
l l
D 100 -
50 -
Y'
/ /
A
/A
. A m 0
Fe#1 Fe#2 Cu#1 Cuga Fe#3 Cug3 Cuf4 SOLVENT STEP Q
IRON COPPER NICKEL E*3 ZINC M9 FILTERS a-w--
..p tw
.--o g,,
c,<
r9
,=
g, e
t,-
g*-p 4 e
.,y
,w
-e
+-ga-w g-=---
-,e,--.--yew-ar-v-w
--,-erw--nume.-w-eee-,.
we -w-
-we
i e
i Tabla 5-1 i
HAINE YANKEE STEAM GENERATOR CHEMICAL CLEAN 1NG PNS SLUDGE REMOVAL REPORT i
STEAM GENERATOR Ho. 2 l
SUMMARY
OF SLUDGE REMOVED (lbs)
{
3TEP IRON COPPER NICKEL ZINC FILTERS TOTALS OXIDES OXIDES OXIDES
===================================================
Fe#1 223.3 43.9 5.5 23.5 23.0 319.2 Fe#2 190.3 2.2 4.8 16.2 12.7 226.2 Cu#1 1.4 47.3 0.1 0.1 0
48.9 Cu#2 1.1 4.6 0
0 8.6 14.4 Fe#3 91.6 3.2 2.9 4.7 0
102.4 cum 3 0.6 13.5 0
0 9.5 23.6 Cu#4 0.2 1.0 0
0 0
1.2 TOTAL 508.4 115.8 13.3 44.6 53.8 735.9 TOTAL SLUDGE REMOVED FROM SG #2 =
736 lbs 4
4 g
%[
J 5-4 P
5.1.1 Chockout Rinso An Iron Rinse solution (demin water at pH 10.0 g 0.2) was used to perform a full operational checkout of the chemical cleaning system and to heat the SG to 200 F in preparation for an Fe solvent step.
Upon the start of recirculation, the solution immediately became very turbid due to suspension of some SG sludge.
The Fe filter (F-40A) was valved in and very effectively removed the suspended solids.
Early in the Checkout Rinsa step the system flow rate was cycled to verify acceptable operation at the desired rates.
It was found that system operation was stable and flow rates well above 500 gpm could be achieved.
During the Checkout Rinse a 3/8-in PW water supply hose for seal water to Pacific Nuclear's main recire pump skid (P12H) came loose and wetted the area.
Corrective action' included a recheck of all PW supply hose connectiors and placement of an order for a PRV to reduce the PW supply m ssure fro.n 190 1 10 psig te approximately 80 psig.
(The PRV w...
received and installed duting cleaning of SG No.
3.
No further failures were experienced due to the high 4
pressure of the PW supply.)
0 Following several hours of stable operation at 200 F, the Checkout Rinne solution was drained at 0130 on April 10.
5.1.2 Fe #1 Step Injection of the first Fe solvent commenced at 0145 on April 10.
This solvent reacted very rapidly to dissolve the SG tube deposits, reaching a solvent
- iron loading of greater than 8 g/L after less than one hour of contact.
EDTA was depleted after about three hours contact, but the solvent was allowed to remain in the SG while the decision was made to terminate this step and continue with a second Fe step.
The Fe #1 solvent was drained to the Iron Waste Storage Tank (T-48E) after six hours contact.
This step removed a total or 319 lbs of sludge as follows:
5-5 4
--4
t i
Iron Oxide 223.3 C:ppor (Metal) 43.9 Nickel oxide 5.5 Zine oxide 23.5 Filter Sludge 23.0 319.2 lbs Dissolution rates and EDTA depletion for the Fe #1 step are shown in Figure 5-2.
Solvent pH and hydrazine concentration are shown in Figure 5-3.
of particular significance during the re #1. step were:
. The oxide dissolution rate was much more rapid than expected from laboratory results due to the large surface area of oxide deposited on the SG tubes.
Consequently, the chemical cleaning team was not fully prepared to make a quick process decision to change to another iron step so quickly.
. The high dissolution of copper during the first step was also a surprise, as well as being an added benefit.
The dissolved copper reached a maximum of 5.4 g/L about 3-4 hours into the step.
NOTE:
For cleaning of SG No.
3 and 1.
the project team therefore prepared to more quickly decide on termination and repeat of the first iron step.
5.1.3 Fe #2 Step The Fe
- 2 step was not injected until about two hours after draindown of Fe #1 in order to allow time to complete the solvent mixing and heatup to 200 F.
The delayed injection had no apparent detrimental effect on solvent performan*ce as 7.7 g/L of iron was dissolved within the first two hours of contact.
Dissolution of Cu, Ni and Zn was,
- however, lower than for the Fe
- 1 step.
The dissolution rates and free EDTA concentration during the step are shown in Figure 5-4.
Solvent pH and hydra:ine concentration are shown in Figure 5-5.
4 5-6
By,oight hcurs into the stOp, tho free EDTA concentration had bOCn reduced to less than 2% (20 g/L) and the iron dissolution rate had slowed to approximately 0.5 g/L per hour.
The step was terminated after ten hours due to the slow dissolution rate and the fact that a significant quantity of copper had visibly deposited on exposed system surfaces.
Because about 1%
free EDTA still
- comained, it appeared likely that a third Fe step would not be beneficial until after removal of the deposited copper.
5.1.4 Fe Rinses #1, 2 and 3 Concurrent with the Fe #2 step. MY operations began draindown of SG No. 3 in preparation for water lancing.
Because the blowdown system is common to all three SGs, this meant that the blowdown system could not be used for draindown of the Fe #2 solvent.
Without use of the blowdown piping, an estimated 20% heel volume of the Fe #2 solvent was left in the SG.
This necessitated use of three (3) Fe Rinses (rather than the normal two rinses) to provide sufficient removal of dissolved iron before applying the copper steps.
Dissolved Fe concentration in the three rinse solutions was ab follows:
Fe Rinse #1 Fe = 4.02 g/L Fe Rinne #2 Fe = 1.10 g/L Fe Einse #3 Fe = 0.21 g/L Application of the three Fe Rinses required a full day (26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br />) to j
complete because of some unexpected coordination problems.
l 1)
Containment was evacuated 'during removal of the reactor vessel head.
2)
Containment was evacuated when
'iealth Physics obtained Dragger tube readings above tne 0.1 ppm TLV limit for hydrazine nest the SG upper manway.
5-7 m
All. pessible systen leakago sourcos w3re inv0stiq0tCd cnd tho necessary corrections made.
The most significant source of vapors was the H
monitoring system installed by MY at the SG upper 2
manway.
Appropriate corrective actions were taken and safety meetings were repeated for each shift of project personnel.
5.1.5 Cu #1 Step After completion of two (2) Fe steps, a total of 545 lbs of sludge had been removed from SG No.
2, including 46 lbs of copper.
An equally large quantity of copper was believed to be plated out on the exposed SG surfaces and components of the chemical cleaning system.
Because reaction of the Copper Solvent is exothermic and can result in foaming if the peroxide decomposition rate is not controlled (2H 0 2H 0+0 )
it was decided to inject the 2 2 2
2 peroxide in two stages (two equal injections of 1.5%).
The second injection would not be made until the reaction from the first injection wa:
under control.
In fact, the exothermic reaction was very well controlled by careful use of the system cooler (HEX-60B).
The solution temperature was maintained between 98-105 F for the entire Cu #1 step as shown in Figure 5-6 taken from the PNS Data Acquidition !iystem.
Dissolution of copper was rapid.
As shown in Figure 5-7.
the dissolved copper concentration reached a value of 4.9 g/L after one hour and increased only slightly (to 5.1 g/L) during the second hour of the step.
This is consistent with the Hydrogen Peroxide depletion data shown in Figure 5-8.
Since the final dissolved copper concentration of 5.1 g/L exceeded the CE guideline value for repeating the Cu step (greater than 1.0 g/L) and because the hydrogen peroxide was depleted when copper dissolution stopped. PNS recommended that a second copper step be applied.
5-8
I TherCforo, after tw3 hours contact, tho Cu #1 stop was droin;d to
- h'e T-48F Cu solvent waste tank.
Again, the SG blowdown lines were f
not.vailable for draindown, leaving about a 154 heel of solution in the SG.
5.1.6 Cu #2 Step.
The Cu #2 solvent was injected and recirculated without peroxide to reestablish the required 100 F starting temperature.
The i
concentration of dissolved copper was measured as 0.78 g/L before perxoide injection establisning the efficiency of draindown as follows:
(0.78/5.10)(100) = 15% Solution Heel Injection of 3% Hydrogen Peroxide was again well controlled as shown j
by the process temperature data of Figure 5-9.
Temperature was l
controlled between 100-106 F using the HEX-60B cooler.
Copper dissolution was very slow in this step, demonstrating that almost all the accessible copper had been dissolved by the Cu #1 ster.
The copper dissolution rate and free EDTA concentration are shown in Figure 5-10.
After correction for the 0.78 g/L copper left from the solution heel of Cu #1, this step dissolved only 0.50 g/L of new copper.
Solvent pH and Hydrogen Peroxide concentration are shown in Figure 5-11.
At this point, PNS recoinmended terminating the copper dissolution until one or more additional iron steps were run to expose more copper.
5-9
5.1.7 Cu hinso #1 i
i After draindown of the Cu #2 solvent, a Copper Rinse solution (demin water with 10 ppm Hydrazine and pH 10.0 with Ammonium Hydroxide) was
[
injected and recirculated for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to heat the SG to 200 F for the Fe #3 step.
A filter assembly, which had become plugged during 4
the Cu #2 step, was changed out and weighed dtring this step.
A total of 8.6 lbs of sludge was ramoved by the f11cer.
l 5.1.8 Fe #3 Step After application of two (2) Fe steps and two (2) Cu steps, a total i
of 609 lbs of sludge had been chemically removed from SG No.
2.
With all the readily soluble sludge gone, it was assumed that this third Fe step would reach a steady dissolution rate after the first few hours and then slowly continue to dissolve oxides from the surface of any remaining sludge pile.
The dissolution rates observed for the Fe #3 step are shown along with the free EDTA concentration in Figure 5-12.
The solvent pH and hydrazine concentration are shown in Figure 5-13.
The curve for iron dissolution supports the assumption that only a small su face area of iron oxide remained available.
Oxide dissolution during this step was considered to have occurred in three phases, as calculated in Table 5-2:
l 0-6 hours -
Easily accessible sludge (exposed by copper removal in the previous Cu #1 and #2 steps) was dissolved at a rate of about 6 lbs iron o'xide/hr (430 ppm Fe/hr).
6-15 hours -
Sludge dissolution slowed to about 3.8 lbs iron oxide /hr (274 ppm Fe/hr) indicating only deep sludge pile iron oxides and/or system construction materials were dissolving.
Dissolution of Cu, Ni and Zn essentially stopped.
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Table 5-2 IRON DISSOLUTION RATES FOR FE #3 Time Interval Iron Conc.
Rate of Chance (hrs)
CAgpce (a/L) c/L/hr Dom /hr lbs oxide /hr 2.58/6ht 0.43 430 6.0
.0-6 0- 2.58
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6-15 2.58 - 5.05 = 2.47/9hr 0.27 274 3.8 15-27 5.05 - 7.14 2.09/12hr 0.17 174 2.4
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15-27 hours - Sludga dissolution further slcw0d to o rato of cbout 2.4 lbs iron oxido/hr (174 ppa Fe/hr).
After 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> contact, PNS - recommended that the Fe #3 step be terminrted.
The rationale for terminating the step at that time was discussed between MY, CE and PNS.
The following information was evaluated in arriving at the decision to terminate Fe #3.
1)
CE qualification testing had established a
base materials corrosion rate equal to 140 ppm Fe/hr.
Without substantial field data to support this value, it could not be determined what fraction of the 174 ppm Fe/hr was due to corrosion and what fraction due to sludge dissolution.
2)
SG No. 3 would not be ready for chemical cleaning for 2-4 more days.
3)
Chemical cleaning system operation was very stable with little apparent risk of equipment failure or other system problems.
4)
CE's online corrosion monitor read a
constant 1800 mpy until completion of the copper steps.
Its reliability for useful inf ormation during the Fe #3 step was therefore suspect.
5)
CE's original criteria for termination of an ' iron step without depletion of EDTA was 200 ppm Fe/hr calculated over the entire step.
At 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />, this value was still 311 ppm Fe/hr (5.6 g/L in 18 hrs).
The above information was evaluated and discussed.
The Fe #3 step was terminated at 27.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> with most consideration having been given to Items 1 and 2.
The Fe #3 solvent wis drained to T-48E in preparation for SG rinsing and two (2) additional copper steps.
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5.1.9 Fo Rinsos #4 cnd 5 Two (2) iron rinse steps were applied to temove residual spent Fe #3 solvent and to cool the SG for the final copper step (s).
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application of these two rinses required only four hours to complete.
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5.1.10 Copper Steps #3 and 4 l
Because the Fe #3 step dissolved 0.35 g/L of copper, it was apparent that additional copper had been exposed and could now be dissolved by a copper step.
The Cu #3 step was started at 2130 on April 13.
After one hour, the dissolved copper was near'a maximum at 1.30 g/L, increasing only slightly during the second hout to 1.35 g/L.
The dissolution rate and free EDTA concentration are shown in Figure 5-14.
Solvent pH and Hydrogen Peroxide concentration are shown in Figure 5-15.
In order to assure that copper removal was as complete as possible, a
fourth Cu step was applied.
After correction for a residual dissolved Cu concentration of 0.15 g/L, only 0.10 g/L of new copper was dissolved by the Cu
- 4 step.
Similar data to the previous copper steps is presented in Figures 5-16 and 5-17.
The reaction exotherm was very well controlled for both the Cu #3 and #4 steps as shown in Figures 5-18 and 5-19.
5.1.11 Copper Rinse #2 The Copper Rinse solution was applied in SG #2 for a period of two hours (0330-0530) on' April 14.
After draindown of the Copper Rinse, there was an 8-hr delay until the final cleanup step was started while the chemical cleaning results were reviewed by all parties and the decision reached that the cleaning was complete.
5-13
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i 5.1.12 Final Rinso and Passivotion At 1400 on April 14, SG No. 2 was filled to the 26-in level with PW water (1300 gallon) and recirculated through the chemical cleaning i
system mixed bed ion exchange (IX) column.
The objective of this step was to rinse the SG surfaces at a level about 2-in above the highest cleaning level and to remove trace amounts of the cleaning chemicals to provide a rinse solution conductivity of less than 2 umhos/cm.
Cleanup to the 2 umhos/cm limit was accomplished very quickly and after two hours of recirculation, the IX column was valved out.
t NOTE:
The post-cleaning water lance leached some additional chemicals and dissolved copper from the remaining sludge pile, as evidenced by'a blue color to the lance water.
Duration of the final cleanup step was, therefore, increased for the remaining two SGs.
Hydrazine and ammonium hydroxide were injected directly into the final rinse to establish Passivation solution chemistry (300 ppm Hydrazine).
The solution was then heated to 200 F to passivate the SG carbon steel surfaces.
The Hydrazine concentration and solution pH were initially lower than desired for the Passivation step. probably due to incomplete cleanup of the SG during the final rinse step.
This was correctad by injecting additional hydrazine and ammonium hydroxide.
A very slight amount of - copper -(0.02 g/L) was removed during the Passivation step.
After ten hours passivation. SG No.
2 was drained to the Rinse Waste Tank (T-48A) and the SG returned to MY for post-cleaning water lance.
5.1.13 Post-Cleaning Inspection Post-cleaning water lance of SG No. 2 removed 118 lbs (169 lbs wet) of additional sludge.
The water lance stream completely penetrated to the tubesheet on the cold-leg side but was lost at about 8-in above the tubesheet in the center of the hot-leg side.
s-14 i
_ Low frrtue'ncy ECT; was ~ porf ormod.on selectod tubos by CE cf tor SG N o',
2 +itemical cleaning.
The results.showed the cold-leg side of-'SG No. 2 was effectively cleaned'down.to the top of the_tubesheet.
The
-hot-leg side still showed a " ridge" of sludge 3-10 inches deep in the center area between the stay rods.
The detailed hot-leg ECT measurements are provided in Table 5-3.-
In all but two cases (tubes 51/50 and-38/49), the sludge height in the measured region was reduced by.at least 1-in, of more importance is the f act that the maximum height-of copper deposition on the tubes
~
in the residual sludge pile was well below the maximum sludge height in all but one case (tube 60/53).
This indicates that copper _was effectively leached from this-residual eludge pile and that - the remaining copper was now located below the sludge surface.
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Table 5-3 ECT RESULTS FOR SG NO.
2*
SG No. 2 Height Above Tubesheet, inches Tube Number Before Cleaning After 2 Fe'+'2 Cu After 3 Fe + 4 Cu Row Column Copper Sludge Copper Sludge Copper Sludge a
48 113 1.4 7.3 1.5 2.6 1.5 2.6-50 101 3.5 4.9 3.5 4.1 48 99 7.4 6.2 6.2 36 97 9.3 6.2 9.9 6.2 9.7 22 95 7.2 4.2 7.0 4.2 6.5 49 92 6.1 8.3 6.1 8.0 50 91 7.3-5.9 8.4 5.2 8.3 54 89 12.3 6.7-8.3 8.1 6.7 7.9 55 88 11.5-7.9-6.3 8.8 6.5 8.1 5
59 88 10.3 6.5-5.7 7.1 5.7 7.0 50 61 3.7 6.4 3.7 6.2 56 57 6.1 9.6 7.2-5.6 8.9 5.4 8.3 50 55 8.9 7.3 8.3 7.5 7.9 61
'54 10.5 9.9 5.8-3.5 6.7 3.5 6.6' 60 53 11.2 11.0 6.2-6.8 6.3 6.41 54 51 10.7.
9.4 7.2-6.3 7.7 6.3 7.7 51
.50 10.0 10.5 10.1-6.5 10.1 6.6 10.6 49 50 9.9 (6.5) 6.3 9.8 6.5 9.6 47 50 6.7 (6.0) 7.8 (6.9-8.9) 10.1 6.8-9.9 38 49 3.9 7.9 5.5 8.1 5.4 7.8 32-
'53 3.4 7.4 3.0 4.9 3.0 4.3 l
49
-46 7.4 9.1 7.2 8.6 l
50 45 7.0 9.2
'7.0 88 49 36 3.3 4.7-3.2 4.3-
-l 50 35 2.6 4.4 2.8 3.9
__ *Results are deposit indications at the maximum height. detected i
above the tubesheet in inches.
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ATTACHMENT B
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AUDIT INFORMATION f
WASTEWATER TREATMENT PLANT CHAMBERS WORKS J
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D't CONTENTS i
3 Page GENERALINFORMATION 1
1 Faculty Name Faculty Address 1
1 Telephone Number
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Audit Contact 1
EPAidentification Number 1
Owner 1
WASTEWATER TREATMENT PLANT OPERATION
'2 Services Offered 2.
Type of Treatment 2
Wastes Accepted 2
Wastes Excluded 2
Process Description 2
StorageTime.
2 i
Waste Through-Put Rate 2
Health and Safety
'3 Analysis 3
Preacceptance Waiting Period 4
i Residuals 4
I An:Icipated Closure Date 4
Closure Plan.
4 5
REGULATORY. STATUS..
5 Environmental Permits -
Permitted Drum Storage Capacity 6
.a Permit Contacts 6
Compliance 6
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Monitoring 6
l Record Keeping 7
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- ENVIRONMENTAL MANAGEMENT.
8 Safety, Health, and Erw' eniTeGJ Ouality Policy 8
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Corporate Erwironmental Management Organization 9
Erwironmental Services Management 9
Public Perception of FacRity 9
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CONTENTS (CONTINUED)
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-10 HISTORY 10 Site Opened 10 l
Previous Land Use 10 Manufacturing ActMtles 10 Waste Disposal On-Site Commercial Wastewater Treatment Plant
- 11.
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FACIUTY LOCATION AND SITING 11 Location 11 kramaNity Size.
12 Staff 12 l
Proximity of Population 12 Surrounding Land Use 12 i
Wind 12'
. Drinking Water 13 Groundwater Quality 13 SurfaceWater -
14
.. Regional Climate 14 Flood Potential 14 Geology F
14 Hydrogeology L
Seismic ActMty 4
4 l
-15 15-FINANCIAL
SUMMARY
15 l
Financial Stability 15 l-Insurance Qosure Costs L
l APPENDIXES Parameters of Acceptable Wastewater Quality
- 5. Diagram of Wastewater Treatment System and Process Flow Chart A.
C. OperatorTrainingRecord D.~
Diagram of a Secure Landfill Letter of Compilance E.i F.
Organization - Environmental Services G. FacilityMap H. InsuranceUabilityCoverage a
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GENERAL INFORMATION FACluTY NAME Du Pont Environmental Services Chambers Works Wastewater Treatment Plant (WWTP) l :..
FACIUTY ADDRESS' Route 130 Deepwater, New Jersey 08023 4
TELEPHONE NUMBER (609) 299-8098/299 4099 AUDIT CONTACT J.J. Douglas (609) 540 2148 i
EPA IDENTIFICATION NJD 002385730 (same as state)
NUMBER OWNER 4
Name E.l. du Pont de Nemours and Company, Inc.
j Wilmington, Delaware 19899 Officers E.S. Woolard, Jr., Chairman of the Board and Chief Executive Officer -
E.P. Blanchard, President and Chief Operating Officer s
A.W. Dunham, Group Vice-President, Chemicals and Pigments Department
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Dun &
001315704 Bradstreet No.
Type of Public-common stock a
Ownership Founded 1802 l
Incorporated Delaware,1899 Previous Owner None Facility 1
Relationship Operating unit to Parent 1
Du Pont EnvironmentalServices May 1989 i
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y WASTEWATER TREATMENT PLANT OPERATION -
SERVICES Wastewater treatment, including analysis of material to be treated and OFFERED'
. disposal of' treatment residue.
TYPE OF TREATMENT Chemical and biological neutralization, precipitation, stabilization, carbon adsorption, biological oxidatlon, and filtration.
WASTES Aqueous waste including acids, caustics, cyanides (< 100 ppm), paints and ACCEPTED inks, solvents, inorganics, organics, pesticides, sulfides, biostudges, and prNately funded Superfund wastes. For parameters of acceptable waste, see Appendtx A.
Material is accepted in bulk (tank car and tank truck) and in 55-gal drums.
WASTES Solids, explosNes, radioactives, PCBs (> 50 ppen), dioxins, domestic, EXCLUDED pathologic wastes, and wastes banned from land disposal.
I PROCESS The system is a continuous process. The wastewater is treated in primary where it la neutralized and solids are precipitated.. Solids are removed, dewatered in large filter presses, and deposited in the on site secure landfill,
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Prirnary-treated effluent is then sent to secondary and tertiary treatment, where l
organics are destroyed by biological oxidation or adsorbed onto carbon. After final clarification, the completely treated waters are discharged into the Delaware River Sulfides and heavy metals are pretreated before entering the system. A diagram and process flow chart of the WWTP is included in Appendix B.
Drums are either flushed, crushed, and landfilled in the secure landfill or flushed I
and reclaimed by a reclaimer Only drums that are completely empty and flushed (not just RCRA empty) are directed to the reclaimer, i-i STORAGETIME None. Wastes are immediately treated.
WASTE 20,000 gpm THROUGH PUT RATE Wastewater from commercial generators is around 200 gpm, or 1% of the total treatment stream.
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HEALTH AND SAFETY Perimeter fencing, controlled access with round;the-clock guards.
S.ecurity Emergency Fully trained and equipped emergency response team that can handle any transportation emergency off. site. The response team is renowned.
Response
throughout the east coast, both as a response team and as a training group for other organizations. On site, there is a fully trained and equipped emergency-f response unit that can handle fires, both structural and chemical, and hazardous substances releases.
Training Required training provided to all employees, including RCRA emergency 4
training, fire safety, first ald/CPR, noise protection, general safety, SARA Title I and Ill, and OSHA Hazardous Waste Operations Emergency Response. See Appendix C for an operator training record.
Alarms Disaster, emergency, and hazard alarms in all hazard areas.
Health Monitoring Pre-employment physicals given to all employees. Annual testing. Records are maintained. Hospital on site, i
ANALYSIS l
l Analysis Preacceptance screening includes TSS, DOC, pH, and compatibility with.
l-Performed.
biodegradation; further analysis is based on judgment of specific waste stream.
Waste analysis plan includes parameters for which each waste is analyzed, test.
Waste
' Analysis Plan methods used, sampling methods, frequency with which initial analysis will be.
renewed, waste analyses that waste generators supply, and methods and quality assurance used to sample and identify wastes received.
Sampling All shipments are sampled as they arrive.
Laboratory Both in-house and outside laboratories.
Certification State certified Chambers Works Quality Control Laboratory -
DEP Certification No.17291 ETC -
DEP Certification No.12257 -
Personnel Laboratories are staffea as required under New Jersey certification.
Du Pont EnvironmentalServices May 1989 3
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i PREACCEPTANCE Maximum of one week for pre-acceptance sample analysis; WAITING PERIOD emergency, one day, t
RESIOUALS Type r1 Filtered sludge, which includes prirnary sludge and spent carbon.
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Rate 120 dry tons of filter cake por day.
Disposal Double lined, secure; hazardous waste landfill on site; RCRA -
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i permitted. A diagram showing the design of the secure landfillis
- i included in Appendix D.
No. of Units One (four areas).
..e Area I - 1975-1979; total area 5 acres; single liner and teachate collection system; cover clay with vegetation.
a.
Area II 1978-present; total area 5 acres; double liner and y-
.j leachate collection and leak detection systems. Leachate treated in on site WWTP.
,j Area Ill 1981 present; total area - 5 acres; double liner, teachate.
collection and leak detection systems. Leachate treated in on-
- -6 site WWTP,
, -1 l.J Area IV 1988-present; total area - 7.5 acres; double liner, leachate collect!on and leak detection systems. Leachate treated In on-site WWTP.
.m.
J Design 1,200,000 W3 Capacity l
ANTICIPATED 1996 CLOSURE DATE CLOSURE PLAN Facility has written closure and post closure plans for the landfill.
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May 1989 Du Pont EnvironmentalServices
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C-REGULATORY STATUS 5:
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f ENVIRONMENTAL PERMITS WASTEWATER TREATMENT FACluTY <
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Permitting Type of Permit lasus Expiration p,
Aaency Egm8 SEDbE EAlf Ealf
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3-NJDEP/ EPA Treatment Plant NJ0005100 9/1/87 9/1/92 0
NJPDES/DSW NJOEP SWA/ Certificate of TOA 1713H 1/4/80 12/31/891 Registration (Hazardous Waste Facility),
3 1
i EPA RCRA Part A NJD 002385730 11/19/80 Indefinite 2_
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l.D. Registration 2
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NJDEP/ EPA Secure I.andfill 170801HP01 9/30/88 9/30/93 Final RCRA Part B C-Permit 1 We are granted legal permit status in New Jersey on a yearty basis until a Part 8 permit is issued.
2 Part 8 permit application was submitted in August 1983. Completeness review is done, M-technical review complete (corrective action under way),
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PERMITTED DRUM 700 5tH;ial drums (38,500 gals) 5 STORAGE i'
New Jersey Department of Environmental Protection. DMslon of -
PERMIT Hazardous Waste Management CONTACTS Frank Coolick, Assistant Director, HazardousWaste Regulation Elemwd
[
(609) 292 9880 n
t Thomas Sherman, Chief, -
l Bureau of Hazardous Waste Engineering i
(609) 292 9880 i
Jack Allen Ben Wilber i
Stateinspectors I.
(609) 346 6000 i
COMPL!ANCE Final WWTP permit application in review.
l RCRA Permit Securelandfill permk received.
Status SARA Notification fUed.
Title til Letter of A letter of compilance is included as Appendix E.
Compilance MONITORING Monitoring conducted for the entire property with approximately 140 Groundwater wells. Reports submitted to NJDEP montNy and quartetty.
4 Twenty-nine parameters are monitored at the river discharge; the WWTP effluent is monitored for priority pollutants. Biological testing Wastewater is performed at both the WWTP effluent and the river outfall.
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i Required air monitoring is performed at the WWTP surge tanks.
i Nonrequired air monitoring is performed over the rest of the WWTP.
Air i
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l RECORD KEEPING 1
Waste All analytical results entered into signed log or into computer system.
Analysis Billing analysis automatically entered into computer billing system.
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Erwironmental Coniputerized fue system..
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, aste M hazardous waste shipped to facility must be accompanied by a W
3 manifest. Manifest and necessary documentation are kept on file for Manifest three years.
1 Manifests can be tracked by shipment date, tog number, and generator, i
Operating Computerized logs include laboratory data, manMests, monitoring Logs results, and waste processing dates and methods, f
Inspection
. includes schedule for inspection of grounds and all equipment t
Logs
' and date and time of inspection and inspector name. Records exist from facility opening.
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E.1, DU PONT DE NEMOURS AND COMPANY EXECUTIVE COMMITTEE h
SAFETY, HEALTH, AND ENVIRONMENTAL QUAUTY POUCY t
tm i-WHEREAS, safety, health, and environmental quality have long been of primary importance to the Du 2
Pont Company:
5-E RESOLVED, that this Company as a matter of policy:
1.
wHi comply with all applicable laws and regulations related to safety, health, and environmental quality in its manufacturing, product development, marketing and distribution activities; 2.
will routinely review its operations for the purpose of making safety, health, and environmental qualky improvements, beyond those legally required, where such improvements provide significant 3
i benefits at reasonable cost;
-f 3,
wHl determine that each product can be made, used, handled, and disposed of safely and j
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consistent with appropriate safety, health, and environmental quality criteria; and I
4, will inform employees and the public about the safety and health effects of its products and workplace chemicals; and wul provide leadership in establishing programs to respond to emergencies involving hazardous materials in communities where the Company has a significant presence.
RESOLVED FURTHER, that this policy shall apply to domestic and foreign consolidated subsidiaries, and
(
to affHlates for which this Company or a consolidated subsidiary has operating responsibility. This policy
)
l will be administered through line management of such subsidiaries or affiliates I
r' RESOLVED FURTHER, that this Company will endeavor to have domestic and foreign affiliates, where it i.
does not have operating responsibuity, adopt comparable safety, health, and environmental qualky
[
l policies:
c RESOLVED FURTHER, that each department is responsible for the developmant and implementation of 4
plans and programs to ensure that its operations comply with the safety, health, and environmental quality policy and to assist in promotion of public acceptance of corporate efforts to protect the safety and health of employees, customers, and the public and to protect the environment.
RESOLVED FURTHER, that all previous statements relating to the foregoing hereby are rescinded.
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l May 1989 Du Pont EnvironmentalServices l
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CORPORATE
. j ENVIRONMENTAL
.l MANAGEMENT-ORGANIZATION l
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Quality j
CommRies DU PONT oirociar of CORPORATE Enviroam*ad ENVIRONMENTAL-
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-MANAGEMENT F
STRUCTURE Safety.HeeNh.
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- Environmental Aflairs Steeme Committee i
e Enykonmental Control DMalon at chammers works i
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i ENVIRONMENTAL A complete organization chart for Du Pont Environmental Services is SERVICES included as Appendbc F.
MANAGEMENT Chain of Responsibilities are clearly defined to respond prompdy and Command adequately to any emergency situation.
Experience Business manager has over 10 years experience in waste management; staiff operate facility with no major problems.
L Knowledge of Staff is knowledgeable about and understands regulations and Regulations
- regularly receives information about changes.
PUBUC There have been no complaints by the public conceming the PERCEPTION operation of the WWTP, r
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a HISTORY b
P$
- i SITE OPENED 1893..
u PREVIOUS LAND USE Famdng MANUFACTURING Site originally manufactured smokeless powder and in 1917 expanded ACTIVITIES to produce other organic chemicals. All operations related to nitrocellulose and explosive products ceased in late 1970s.
Chemical processing at the plant currently includes the production of organic chemicals and organic intermediates.-
e WASTE DISPOSAL Waste disposal on-site since 1917.
ON SITE During the 1960s, landfills and waste piles were constructed on site to dispose of waste material generated by chemical operations. The
. Wastewater Treatment Plant was constructed in the mid 1970s. At no l
time were incinerators or waste piles used to dispose of wastes from commercial generators. All waste piles on site are now closed.
7 5
COMMERCIAL Opened to commercial generators it' 1979-80 when capacity d
WASTEWATER became available.
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FACILITY LOCATION AND SITING x
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The Wastewater Treatment Piant is part of Chambers Works faci!!!y,-
l whlch is located hiong the Delaware RNor and Salem Canal at the l
LOCATION base of the Delaware Memortal Bridge in Deepwater, New Jersey, it i
lies in both Pennsvute and Camey's Point townships. A site map is i
included as Appendix G.
4 f
Chambers Works is located on Route 130, just north of I-95 and near ACCESSIBluTY the southem end of the New Jersey Tumpike. The site is also accessible by raB and barge.
i 1440 acres Entire ChambersWorks Faculty:
SIZE 40 acres for WWTP; 25 acres for landfill.
Active acreage:
Total Chambers Works personnel. 3400 STAFF WWTP - 100 t
Works Manager R.D. Stewart Waste Management G.T. Halsey Manager WWTP Manager S.R. Aldrich, Jr.
1.aboratory J.P. Ryan Manager H.W. Tumer Safety Manager A.C. Stein Emergency l
Response
l Manager I
I Environmental A.H. Pagano f
All WWTP operators are first class chemical operators with over 10 Manager I
WWTP Operators years of service.
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The velage of Deepwater and several residential developments (single homes, apartments, and two mobus home parks) Ile within a :
PROXIMITY OF 2-mie redlus from the NNE to the SSW of the Chambers Works.-
,i-POPULATION -
Penns Grove, New Jersey, lies to the NNE, between 2 and 4 miles from the plant. Pennsvule, New Jersey, is to the south and is also within 2 to 4 m5es of the plant.
The closest residence is about 1/2 mie from the WWTP boundary.
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Predominant land use within three miles of the plant is commercial '
it' and industrial. The closest industrial or commercial complex is. ~
1 SURROUNDING i'
LAND USE located within 1 mie of the facNity.
Plantis bordered by:
North: Undeveloped,IJnde Mfg.
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~ East: Hwy 130, residences South: Salem Canal,I-96, Atlantic Electric Power Plant i.
West: Delaware River 5
e WlND Mostly from the SW; occasionally from the NE during winter.
l Prevailing Direction Stagnation Only during dog days of summer.
Periods r
Nonattainment area (volatile organics; Penns Grove nonattainment I
Attainment for carbon monoxide).
Status No known use of shallow ground water in vicinity.of facility. Drinking DRINKING WATER water supply for the area comes from the Raritan aquifer. The Raritan aquifer is separated from the Pleistocene aquifers by a clay layer, 5 to -
50 ft thick.
Shallow groundwater use is limited to industrial.
f GROUNDWATER l
QUAlJTY l
Drinking water (Raritan aquifer).
Usable Aquifer Use t
Du Pont EnvironmentalServices May 1989 12.
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" SURFACE WATER Delaware River less than 1000 ft to the west; two streams (Henby Nearest Bodies Creek and Whooping John Creek) run through the site before enterin0 the Delaware River.,
Brackish, nondrinking water source; Zone 5 Deiswere River.
Ouality Trested westewater is discharged to the Delswere River.
Bodles RooeMng Emuent Industrial or commercialsupplies Use Within 3 Mies I
Distanceto:
r User Vitake Closest, over 1 mio i
Coastal On Chambers Works site wetlands Fresh water On Chambers Works site wetlands Critical On ChambersWorks site habitat l
REGIONALCLIMATE
. Cne Year, p
24-Hour 2.0 to 3.0 in.
Design Storm e,
s A ou,.m Precipitation Du Pont EnvironmentalServices May 1989 13
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.1 Annual Evapo-2549 in.
transpiration 3
i FLOOD POTENTIAL in 100 year coastaltidalRood plain c
3 F
GEOLOGY
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3 Surface Alluvial deposits of the Delavers River flood plain.
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(:,
' To 200' interuedded clay, sR, sand, and gravel
- j 4 Below 200' Igneous, metamorphic ~ rock Sol Sandyloam Ground Cover Marsh grassee HYDROGEOLOGY Aqu#ers Glacial equNor, fourzones: A,0-16 ft: 8,040 ft; C,30-70 ft: D,50110 ft. Raritan aquNor, two zones: shallow and deep. Clay, below 100 ft.
AquWer 4 o 104 cm/sec).
j Permeabalty Moderate (10 t
i i
Depth to First Unsaturated At the surface Zone
)
}
Depth to 25 ft
}
Groundwater S
(_
i Groundwater Glacial aquifers: into Chambers Works, toward interceptor wells.
t Flow Direction Rarttan: shadow, toward Atlantic City Sectric (to the south): deep, under the Delaware River, toward Delswers.
v i
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SEISMICACTIVITY Low (USGS Zone 1) 4 I,
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L.
i
.I May 1989 Du Pont EnvironmentalServices
[
14-
O.
j FINANCIAL
SUMMARY
M>
(
FINANCIAL Firm has never Ned for battruptcy.
?
STABluTY See Du Pont Annual Report.
INSURANCE Self4nsured $4,000,000/occurrenos;$8,000,000/annualaggregate 59 Canier DuPont Single policy com both Suoden/ General UmbRy and 9
Nonsudden/Enviisik.w4 Impairment Uabaty. -
x G
t
' Ct.OSURE COSTS Closure WWTP $4,491,000 Landfill C - $1,790,000 Post Closure WWTP $0 y.
i LandfillQ $300,000/yr 1
n 2
Method of Standby Trust Agreement and Latter of Credt 5
Guarantee Financial assurance documents are included in Appendix H.
C' l
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Ou Pont EnvironmentalServices i
May 1989 15
a
' I 'l 1
1 i
Appendix A l'
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J PARAMETERS OF ACCEPTABLE WASTEWA'IER QUAUTY 1
WASTEWATER TREATMENT PLANT (WWTP)
DU PONT, CNAMBERS WORKS
,l{
DEEPWATER, NEW JERSEY q\\
1.
Aqueous wastes and mktures of aqueous wastes having the following EPA hazardous j
waste numbers can be nocepted at the WWTP(1,2):
l "C7 Numbers:
"K" Numbers:
l C100 C329 K002-K000 L
C110 C334 KD17 C120 C336 K026 K031 K035 C143 C340 C142 C377 K041-K042 i
C149 C388 KD44-K045 C157 C396 K047-K052 C158 C401 K006 C100 C406 K071 C176 C415 K073
}
C184 G416 K064-K086(3) -
i C187 C433 K007-K006 l
C188 C434 K105 C190 C440 K106 l
C214 C442
-K011
'i C220 C458 l
C262 C467 "P' Numbers (4):-
}.
s C274 C468 C283 C477 P022 C291 C492 P028 l
C297 C502 P105
[
C306 C503 P120 j.y C313 C504 l
C325 C505 0
I s
'D' Numbers:
'F" Numbers:
L D0010017 F014 I.
f F015 i
- (
i F019 i
i (1) Any other waste numbers listed on 'r.ccir.li,g manifests should be questioned and contact made -
with Environmental and Regtdatory Affairs before acceptance.
3 (2) These waste codes are denned.st 40 CFR Part 261 and NJAC 7:268.1 et seq.
(3) K086 caustic wash or water wash only.
(4) These are aqueous wastes containing small quantitles of these materials, not the pure materials.
1 j
- +,
i AppendixA l
l l
Page 2 i
l 1-i V Nutr3ers:
. T Numbers:
+
)
l U002 U123 X721 X727 U007-U130 X728 U000
- U133, X900 I
Uo12' U134 X930 U022 U140 X940 Uo32 U161 i UO43 U164 ll Uo44 U163 l Uo61 U166 Uo62 U180 ij UO70 U188 l UO73 U196 ~ UO79 U210 U000 U211 I Uo02 U220 u i. U112 U226 i U113 U228 U114 U239 U120
- U242 U122 l,
2. To protect WWTP personnel, the WWTP does not accept, for treatment, materials that are classified as carcinogens by the Occupational Safety and Health Administration (OSHA), American Conference of Govemmental Industrial Hygienists (ACGlH), or Intemational Agency for Research on Cancer (IARC). If a. wastewater contains less than 0.1% (the concentradon described in the current OSHA Hazards Communication Standard for ridxtu.'as) of a carcinogenic material, it may be accepted for treatment after l.. review. Du Pont reserves the right to add compounds to the llats of these three agencies, at its sole discretion. 3. Human and animal wastes are not annerwart a ~4. Material must be free Sowing and pumgable. ,y ~ 1 e Material must t's a persistant aqueous phase with no water immiscible layer present.- j' l 6. 08 and water mixtures require special protreatmort and must be evaluated and approved prior to j l acceptarce. l L-- 7. Wastewater that contains cwor 50 ppm PCBs is not acceptable; lowcr levels require review and approval priorto acceptance. l l 2. Wastewater must not be radioecdve or contain explosives. lli 9. Wastewater must not contain detectable levels of dioxins. 4 j e i -~~
f li Appendix A Page3 9.
- 10. Special handling of wastewaters containing sulfides and free cyanide is required to avoid contact wth acidic waste streams that would result in generation of dan 0etous levels of H S or HCN. Wastewater 2
' containing sulfide or cyanide must be reviewed and approved.
- 11.. insecticides, pesticides, herbicides and/or fish toxin contaminants must be specified. Wastewater ceniidnir.g any of these contaminanta may be accepted only after rev6ew.
l ..o
- 12. In addition to such specific limits, wastewater w81 not be if R:
? e materially increases the hazards or risks to health or the environment incident to trnepor&5 'j treatment, or disposal; e exceeds any current or future capacky limk or cames operating problems in the WWTP: e causes significant hazard to the health of the bacterial population of the WWTP; or e jeopardttes the ab8ky of the WWTP to comply with the ofRuont limits of its permits.
- 13. Wastewater otherwise acceptable under the above specific limits nonetheless may be designated 1
unacceptable by Du Pont if k originates from a notorious source, or if ks delivery to the WWTP could J cause significant public relations concems. 9
- 14. Certain RCRA hazardous waste are impacted by Federal L.and Ban regulations. These wastes can be j
accepted ONLY after the proper documentation procedures have been followed. Contact Du Pont for specific information on wastes affected by the I.and Bans. l i 1 4 e i al dI N 1 3 3. e l J 1
..q \\ \\ l,/ \\ t \\ %\\ f }\\ aa j E I gh l g o ag f.o }hj), k o ,s $ nkk. [ y_ b,.. g e l f. O/ ,3 0 t \\ 6 + s,(,~ ^' i 1 t
. i. a t. L. w 6L u w w i-m u u L_. m L. m. m... g Waste Water Treatment Plant Flow Sheet ~ ^ j l ( &8 i l l Primary Surge Tanks Neutralizers Clarifiers ) I II I Y I 3 l l , by .ig~t u a 4 Wastewater m from Cham s Works g j ( 3 .4 ._ n.-- X "{.1 Outside Wastewater g% A J m f 8econdary trucks g' Clarifiers. 4 -4 alors Carbon Slurr [ m -t. ~ g eiii,.ie- .m. ,_, g, s s 5 45-50 presses Chambers Works' m g ci.an.oonne wei.r c ~ to River '[ L h ... ~,. -.-e c -c. ,,,y
,e en e WASTElJATER TREATMENT ' PLANT-TRAINING RECORD MM 116tl NAME BUILDING' SHIFT a t OATETRAI$dINGCOMPLETED 1 1 1-1 SUBJECT 1 1997 l-1999 1 1989 1 1 1 1 1 CHECMICAL AND PHYSICAL HAZARDS COMMUNICATION 1 3/22 I-I l-1 1 1 'l T0XIC SUBSTANCE CONTROL ACT SECTION (C) & (Ell '1/38 1 1 _l 1 1 1 1 i EMPLOYEE ACCESS TO EXPOSURE & MEDICAL'RECORDSI 1/38 1 f f .f i 1 1 1 1' f HEARING CONSERVATION' f 2/21 I I l 1-1 1 1 AIR LINE AND COMF0 II RESPIRATOR 111/19/9E1 1 1 l 1 1 1 1 !!16 it0TI ale P.EE k 11 1 6 1 111 E IE E1Q6P.E 1 1 1 1 I 4/E I i 1 MASK i 1 1 1 1 PROTECTIVE CLOTHING I 1/14 1 1 1 1 1 1 1 FIRE PAD TRAINING 1 4/7 1 1 1 j 1 1 1-1 E INSPECTION k CONTROL QE EMER6ENCY atG 1 1 1 1 o MONITORING EOUIPMENT-1 3/7 I I I l 1-1 1 1 REY PARAMETERS I 3/7 I I I 1 1 1 1 COMMUNICATIONS AND ALARM SYSTEMS I 3/7 I I I I i 1 1 1 EMERGENCY RESPONSES I 3/7 I I i 1 1 1 1-1 \\ l 3/7 I I i ,,J SPILL CONTROL AND S.A.F. CODES 1 1 1 1 1 I 3/7 1 1 I OPERATION SHUTDOWN i REMARMS 1 1 1 w.
SECURE L.ANDF LL 't ~ 3 D i c= i 3 FTTOP SOIL r l1 F' eo n--i W'MS- =' s M *M '.'CN*b7&.'4 MaWe' AWww. g Z'P ? Va i '&" %1VaMI M%N s%%-'Ja A l h ? I .m. j To i j - TREATMENT A PLANT l CLAY Otsu n- .E l yy ^ I _1 - g - - -:/ \\ _~ Ma (%X1Nw *&RG & M:Gt G=0 e\\'T L gy m' I e. aRAv w uMER 80TTOM UNER 7 V V -T. - OETECTION A CHAMSER g V Apri1989 > > p..wwe~ = = n ..., ~,.
f _ J LETTER OF COMPLLANCE l h.- i .== J I. ou PONT DE NEMouRs E COMPANY WILMINGTON. DELAWARE 19896 l' j en2wicau ane ciowcurs oceanrueur <1 -1 ' Technical Laboratory (D) Chnchers Works l_ D30pwater, New Jersey 08023 8 DATE: CONTACT'NAME 2 COMPANY-NAME-5 i. ADDRESS CITY / STATE /3IF TO WHOM IT MAY CONCERN: Please be advised that we have been-contacted by in connection with disposal of liquid waste. We have advised that the Du Pont Company Nastewater Treatment Facility will. essist them in the disposal of their liquid chemical / industrial waste after the same has been properly analysed and. assuming: o l, that the liquid is within the framework.of our capacity. t Our EPA Humber is NJD 002385730. It is our intent to 'l cporate our treatment facility in compliance with"all cyplicable State and Federal.regulhtions. .{ If I can be of further assistance, please. feel free to r cell me, sincerely yours, ,g ! ~ Lh r 1
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.'s i DU PONT ENVIRONMENTAL SERVICES 1 ORGANIZATION .ie i, 'l 'j Director .!l1 Salsty and Erwironmental Servimos G.C. Tunis, Jr. 1 J i l + i .4 [ Mana Weste ger_ D A H81ard i 1 i ) PrtnolpalConsultants. Erwtronmental W.C.SeekN W.J.Touhey Re0ulatory and Weste adi i Servlees Mana0er M.Henson Regulatory & Waste Servlees Specialist ] J.l. Douglas l '.J Senior Commercial Assistant J.M. Reed t Servios Coordinators J.P.Cardie.W.C. Wilms Jr. D.L Smith. LR. Taylor Mana0er Martisting e-Q.T.Halsey l Sr. Amoeurd Managers e, D.N.Weson, J.C.Lutness, J.P.Straub J.R.Whiteside, s.z.unw e AccourtMana0ers C A Herten. E.C. Jones. J.H. Coley, Jr., J.C.WIson Account Representatives 2 R.L Davis C.R. Davis, A. Chiesa I'* November 1989 ..,,,--,.-...e---.- -w-,,......--.---,., ..,,-.,-m....,~#..:,,,.-%---.e,,, ,~.~.-..,-p., m-wwe.,---..m - w em%.-e-,
MU-1844A (Rev. 12/81) FACILITf MAP Q Key 1.ecatiess and Driving testrictions q !} CilAlllERS WORKS i 17 v 1 c N I i T. g ~ f9 gg l g !3 l s f b 4 Jg ,t j i 1 25 38 s o e Y* f 15 j 12 h, ~~ II l, l 4 g} s ~ +,, u*//;h }. 'o j l} s 8,.s me.0/{f A4SC0FF.
- 12. x _
l 4 3 n,,w,....M. / 33 A.ns J Q PICKUPsp0f J6 ,a 'a lHITE PROD. RD. )' 226 8
- I 4:064:50P.M.
Jg 14 - NE CAY CEST.0 P.M. i U100 M. itz AE o hp 4I sue 4m 2I I e )( .0$ED EAST. .0U2 4:0k.0 P.M. \\ 35 r= t l CANAL ROAD 2* 'PON50L" RO. FROM "E" CORR AL l EXIT TO 80WY. RO. 500THSOU2 a j ONE CAY TRAPPic = 9 4:00 4:30 P.M. W .a O.UT SOUM) 300 4148 P.M, 0 '.a 12.00 M.1120 A.M.
- MON.. PRt.
l **.t .- hMN } =l 4 J,' 4',s = ONE wAv r t'.stattT .,,tX." ROAD $0UTH60UN0*"T1 i \\ 80VTN00UNO ALLTIM68 p3gg 9, . 5:0$ P,M. ONE WAY l/</
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- Y THRU FRIDAY FROM Cas=Av l/
4l I I0UNO CLD540POA05-luy TO CANAL ROAD ' 3 LAME ONLY) l ggg l e s ,y 8 l ,.0 S BROADWAY GATE l CANAL ROAD GATE ONE wAY TRAFFIC T OPEN ALL HOUR $ I OPEN ONLY g. y 6 A M. 5:00 P.M. "C" CORRAL ROAD k-enoAOWAY
- ""'.M.
3 Y ONE CAY TRAFFIC CLO5ED FROM 4:004:45 A, ? T 't 5 T:00 0.00 A PEDESTRIAN WALK OUT SO.UND 'g-i* rrwwwwyr rrr- .s. ,f 4.0 4: $ P.M. e# MON..F RI. CANAL ROAD 80WY.
- fae r
r ~ = ENTRAM,,,, \\ ,,,3S4:00 P.E & lt:00 P.E.12:JS AJL TO BRIDGE 00 $PE w 1 r i si T ( '8 . T c - c.;., ii. 4 n ,c t... ,no 3 x -i-c.,. n cc u..A c,
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,,I.!;.... . INSURANCE LIABILITY COVERAGE } E. l. ou PONT ok hE bums & COMPANY 3 - Wit MINGTON. DEL AWARE 19494 i e l j Lt046 OLFatt el*.1 I, March 31,1989 i i i *a ) 1 CERTIFIED MAIL. RETURN RECEIPT REQUESTED l .J i l,, New Jersey Department of Environmental Protection Division of Waste Management I.] 32 East Hanover Street ) Trenton, NJ 08625 Attn: Hazardous Waste Financial Requirements i
Dear Sir or Madam:
'1 Financial Assurance Package - Liability Coverage l Hazardous Waste Management Facilities E. I. du Pont de Nemours and Comoany ? { Pursuant to New Jersey's requirements, enclosed is J E. l. du Pont de Nemours and Company's (Du Pont's) " updated" hazardous waste management facilities' financial assurance package for liability coverage. The enclosed package contains the following: ] . A Chief Financial Officer's letter, dated March 31, 1989, ) incorporating the general financial data for Du Pont as of December 31, 1988. The letter is worded in accordance with i the requirements of N.J.A.C. 7:26 9 (Appendix A). } A copy of Du Pont's 1988 Annual Report containing, on page ) 29, the " Report of Independent Accountants" (Price Waterhouse) regarding their examination of Du Pont's ' financial statements for 1988. A copy of Price Waterhouse's "Special Report", dated l March 31,1989, as required by N.J.A.C. 7:26 9 (Appendix A), } } l \\ -.. = -. - - -
o" If you have any questions r;garding th3 enclosed pack ^go, please call me on (302) 774 5113. Sincerel, ^ w Guy V Johnson Counsel Enviroriment Group i GVJ:glj )
- Enc, f
6 f 1 4 e ) 4 0 l t 5 e e m w
4 ~d1E][ h[:)
==.; . !. ou PoNT or NrMouRs E COMPANY WILMINGTON. DELAWARE 19998 aon wcc enesioCwt-nwawet March 31, 1989 emtrrawawciALorneta e i Neu Jersey Department of i Environmental Protection 32 East Hanover Street Trenton, NJ 08625 Gentlemen: j i I am the chief financial officer of E.'I. du Pont i de Nemours & Company,1007 Market Street, Wilmington, DE 19898. This letter is in support of the use of the financial test to i demonstrate financial responsibility for liability coverage, is j specified in N.J.A.C. 7:26-9.1 et seq. The owner or operator identified ablove is the owner or t operator of the,following facilities for which liability. coverage i is being demonstrated through the financial test specified in 4 N.J.A.C. 7:26-9.1 et seg. See Exhibit A. This owner.or. operator is required to file a Form 10K with e i the Securities and Exchange Commission (SEC) for the latest fiscal year. The fiscal year of this owner or operator ends on December 31. The figures for the following items marked with an asterisk are derived from this owner's or operator's independently audited, year-end financial statements for the latest completed fiscal year, ended December 31, 1988. ALTERNATIVE I j i (dollars in millions) 1. Amount of annual aggregate liability coverage to be demonstrated.............................. 67 4 02. Current Assets.................................... 10 238 03. Current liabilities............................... 6 696 4 Net working capital (line 2 minus line 3) 3 542 15 020 i 5. Tangible net worth................................ 06. If less than 90% of assets are located in the 19 911 U.S. give total U.S. assets..................... Yes No 7. Is line 5 at least $10 million?................... X. 8. Is line 4 at least 6 times line 17................ X 9. Is line 5 at least 6 times line 17................ X' i - 010. Are at least 90% of assets located in X the U.S.? If not, complete line 11............. 11. Is line 6 at least 6 times line 17................ X SCTTER TMINGS rom SETTCM LIVING )
4 ) e. 2-j 1 hereby certify that the wording of this letter is identical to the wording specified in N.J. A.C. 7:26-9 ( Appendix A), as such regulations were constituted on the date shown immediately below: .J. uindlen n Vice President - Finance March 31, 1989 e t 6 e E -gy, e-w e-w-
= l i E. I. DU PONT DE NEMOURS & COMPANY l Facilities For Which Liability Coverage Is Being Demonstrated Through The Financial l Test Specified in N.J.A.C. 7:26-9.1 Et. Sec. l i i i J EPA Facility Identification Site and Address Number NJO 00238 5730 Chambers Wprks Deepwater, NJ
- 08023, i
NJO 00237 }819 Repauno Gibbstown, NJ 08027 NJ4 00082 0159 Parl~in Parlin, NJ 08859 ^ t i NJO 00244 4024 Parlin Parlin, NJ 08859 NJO 00217 3946 Pompton Lakes Pompton Lakes, NJ 07442 1 t 1 i + i r t 0838s Exhibit A l i
f. Itutty booth bevtalit'3h bt'tti neitpnont 21b t,ta DQQ ' Phitaotismia, PA 191034094 PriceiIhierhouse 7 March 31, 1989 E. I. du Pont de Nemours and Company ' We have audited the consolidated balance sheet of E. I. du Pont de Nemours and Company and its consolidated sub-sidiaries (the " Company") as of December 31, 1988 and the related consolidated statements of income, stockholdgys' equity and cash flows for the year ended December 31, 1988, our report, with respect thereto, is included in the Annual Report to Stockholders of the company for the year 1988. We have not audited any financial statements of the Company as of any date or for any period subsequent to December 31, 1988 and've have not applied any other procedures except for,those described in this letter. At your request, we have performed the procedures enumerated below with respdct to selected financial data of the Company as contained in the accompanying letter dated i March 31, 1989 from J. J. Quindlen to a regional administrator of the United States Environmental Protection Agency (the " Agency"). These procedures were performed solely to assist you in complying with the regulations of the Agency under authority of the Resource Conservation and Recovery Act and this report should not be used for any other purpose. The procedures we performed are summarized as follows:
- 1. We compared the amounts in the accompanying letter for total liabilities, net worth, current assets, current liabilities, the sum of. net income plus depreciation, depletion and amortization, and total assets in the. United states'with amounts in the j
company's December 31/ 1988 consolidated financial l statements. 3
- 2. We compared the amount in the accompanying letter 9
for tangible not worth to amounts in the accounting i' records used to prepare the Company's December 31, 1988 consolidated financial statements. I
- 3. We compared the response to, "Are at least 90% of assets located in the U.S.?" in the accompanying letter with the data in the Company's December 31, i
} 1988 consolidated financial statements. 1 i
2 d, O 1 s. March 31, 1989 E. I. du Pont de Nemours and company Page 2 9
- 4. We compared the response to, "Are' total assets in the U.S. at least 6 times the annual aggregate-liability coverage and/or current closure and post-closure cost estimates as out)he data in theined per Item 17" in the accompanying letter with t
~ company's. December 31, 1983 consolidated financial 9tatements. Because the above procedures were not sufficient to consti- ,tute an audit in accordance with generally accepted audit-ing standards, we do not express an opinion on any of the data referred to above. 'In connection with the procedures referred to above, no matters came to our attention that caused us to believe that the specified data should be adjusted. This report relates only to the data specified above and, accordingly, we do not express an opinion or any other form of assurance on any other data appearing in the company's letter. f( b i e r 3 4 e}}