ML20065F988

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NPDES Noncompliance Notification:On 940324,daily Maximum Discharge of Low Volume & Oily Waste Sys Exceeded.Caused by Overload of Sys Trestment Capacity Due to Excessive Waste Oil.Sump & Downstream Lift Station Cleaned
ML20065F988
Person / Time
Site: Hope Creek 
Issue date: 03/29/1994
From: Thompson F
Public Service Enterprise Group
To: Mathis S
NEW JERSEY, STATE OF
References
NLR-E94059, NUDOCS 9404120118
Download: ML20065F988 (6)


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o O PSEG Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038 Nuclear Department MAR 2 9 ES4 CERTIFIED MAIL l

RETURN RECEIPT REQUESTED ARTICLE NUMBER: Z 691 525 734 NLR-E94059 l

l Mr. Steven Mathis NJ Department of Environmental Protection and Energy Division of Facility Wide Enforcement Southern Bureau of Water and Hazardous Waste Enforcement Suite 301 South 20 East Clementon Road Gibbsboro, NJ 08026

Dear Mr. Mathis:

HOPE CREEK GENERATING STATION NJPDES PERMIT NO. NJ0025411 OIL DISCHARGE TO RIVER I

CASE NOS.

94-03-24-1037-39 AND 94-03-24-1659-11 On March 24, 1994, Public Service Electric and Gas Company (PSE&G) reported a violation of the daily maximum discharge limit for petroleum hydrocarbons from the discharge of the Low Volume and Oily Waste (LV&OW) system, DSN 461C.

In accordance with NJAC 7:14A-3.10(d), PSE&G reported this violation to the NJDEPE Hotline and was assigned Case No. 94-03-24-1037-39.

The LV&OW system is essentially an oil water separator equipped with a crossflow plate pack to enhance gravity separation.

The system treats potentially oily wastewater and stormwater from the Hope Creek site.

Oil and sludge are removed from the separator and transferred to separate storage tanks for disposal.

The treated effluent is then discharged through the cooling tower blowdown line, DSN 461A, to the Delaware River.

The result of the system's effluent sample obtained by Hope Creek i

Chemistry personnel on March 16 indicated a petroleum hydrocarbon concentration of 22.4 mg/1.

The daily maximum discharge limit is 15 mg/1.

PSE&G was informed of the sample results on the morning of March 24 by our contract laboratory, NET Atlantic.

Chemistry personnel immediately took actions to secure the influent lift station to the LV&OW system to prevent further discharges.

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i S. Mathis, NJDEPE 2

MAR 2 91994 l

NhR-E94059 The effluent violation was caused by an overload of the system's treatment capacity due to an excessive amount of waste oil transferred from the Diesel Building sump.

The system remained out of service until both the sump and downstream lift station l

were cleaned.

In order to reduce the potential for future i

violations, caution tags have been hung on inlet drains in the j

diesel fuel oil storage tank room to control the discharge of I

oily wastes to the sump.

At approximately 3:25 p.m.,

an attempt was made to return the LV&ow system to service.

During the restart, Chemistry personnel stationed at the separator observed a small quantity of oily sludge discharging over the effluent weir.

The system was again shutdown and personnel were dispatched to the River'where a small oil sheen was discovered in the area of the cooling tower blowdown outfall.

The sheen was reported to the Senior Nuclear Shift Supervisor for notification of response personnel and regulatory agencies.

The sheen was reported to the NJDEPE Hotline, Case No. 94-03-24-1659-11, and the National Response Center, Case No. 231-592.

The U.

S.

Coast Guard dispatched Petty Officer Michael Thompson to inspect the discharge and cleanup activities.

The oil sheen was limited by wind and wave action to a small area, approximately 20 feet by 30 feet, along the shoreline directly adjacent to the Hope Creek barge slip.

Site Protection personnel immediately took action to place absorbant pads and boom in the area.

Absorbant pads were also used to remove any oil trapped in the riprap along the shoreline.

Cleanup activities were completed at approximately 7:30 p.m.

During the seven hours the LV&oW system was out of service to l

correct the petroleum hydrocarbon effluent violation, the water l

level in the separator dropped several inches due to a leaky influent check valve.

As a result, the separator's oil / water interface reached the level of the effluent weir resulting in the oil discharge.

The separator was taken apart and all oil was removed from the plate pack.

The separator was then refilled with clean water and returned to service without incident at l

approximately 9:00 p.m. on March 25.

A work order has been issued to repair / replace the leaky check valve.

PSE&G contends that the violation of petroleum hydrocarbon limit at the LV&OW system and the oil sheen from the cooling tower blowdown are interrelated and due to a single operational incident.

In accordance with NJAC 7:14-8,5(b), these violations should be treated as a single effluent violation.

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S. Mathis, NJDEPE 3

NLR-E94059 MAR 2 91994 For your information, PSE&G is providing a copy of the " Pollution Incident Witness Statement" prepared by Site Protection personnel-who responded to the oil sheen.

If you have any questions or require additional information, please contact Pat McCabe of my staff at (609) 339-1245.

Sincerely, f

F.

X. Thomson, 1

Manager -

Licensing and Regulation Attachment (1)

C Assistant Director of Enforcement l

NJ Department of Environmental Protection and Energy 401 East State Street CN 029 i

Trenton, NJ 08625-0029 I

Petty Officer Michael L. Thompson U.

S.

Coast Guard 1 Washington Avenue Philadelphia, PA 19147 U.

S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

FROM FICE & SEFETY DEPT.

3.23.1994 9822 P.

2 tis.Dwpuin ent Commanding officar 1 Washington Ave.

ofhnspor1Qtton U.S.

Coast Guard Philadelphia Pa.

gg 19147-4395 gg (215) 271-4800 FRIVACY ACT ST&TEMENT The standard procedure in a pollution incident requires that the investigator collect all necessary information, including private inforisation, to complete the pollution investigation case.

As required by the Privacy Act, Title 5 U.S.C. 552a(e)(3),

the investigator will:

Inform you es to his authority to collect this information.'

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b.

Inform you es to the primary purpose of this information.

1. Authority The investigator, as e Taderal Law Enforcement Of ficer (14 U.S.C. 93(e) and E.O.

11735 of August 3, 1973) is requesting information pursuant to the authority contained in the Federal Water Pollution Control Act, as amended (33 U.S.C.

1321 et seq) 4 and regulations written to enforce this law.

2. Principal _Puroese The statement you prpvide the investigator will be used to determine the cause of this pollution incident and establish the identity of the discharger.

Private information collected by the investigator is necessary to enable him to' contact you, if more information is needed or to clarify information already given.

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Your identity and contact information is needed in order to use 1

your statement et the civil and sometimes criminal proceedings which may result from this investigation.

There are no other uses intended for your private information.

Disclosure of this information is strictly voluntary.

I HAVE READ AND UNDERSTAND THE ABOVE STATEMENT.

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POLLUTION INCIDENT WITNESS ETATEMENT Date/ Time of incident: OkW9// M /6/O Date/ Time of statement:o2.wi+/d2/od i

1. When and where'did you see the pollution incident occur?

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On or about 8,7& 2 VMM iY, an.c1J pollution incident occurred or threatens to occur at N Ar (frek G,v. G&. Nd'ock's BriOe,MD You may be financially responsinle for tnet inciaant.

Under racera.L Statutes, the United States Government may take action to minimize or mitigate damage to the public health or welfare that is threatened or that may be caused by this incident.

Under the Oil Pollution Act of 1990, the responsible party is liable for, among other things, removal costs and damages resultlng from this incident.

The failure or refusal of the responsible party to provide all reasonable cooperation and assistance requested by the Federal On-Scene Coordinator (OSC) will eliminate any defense or entitlement to liraited liability which otherwise might be available under the Act.

You are advised that your failure to properly carry out the removal of the discharge as ordered by the OSC or to comply with any administrative orders necessary to protect the public health and welfare, may subject you to additional penalties.

For such failure, owners, operators, or persons in charge of the vessel or facility from which the oil is discharged are subject under the Federal Water pollution Control Act (FWPCA), as amended, to a civil pensity of up to $25,000 per day of violation or up to 3 times the costs incurred by the-Oil Spill Liability Trust Fund.

Should you ire further information concerning this matter, please contact LT*

7oMv ptH W at the above address and telephone numoor.

As long se the OSC determines that you are taking adequate actions in this matter, Federal removal action will usually be limited to monitoring the progress of your actions and providing guidance as necessary.

Under the FWPCA, as amended, your response actions may be taken into account in determining the amount of any penalty assessed as a result of the discharge.

Sincerely, mVL sut

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Received and Acknowledged:

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