ML20085F628

NPDES Noncompliance Notification:On 910916,400 Gallons of 0.23 Ppm Chlorinated Stormwater Discharged from Sodium Hypochlorite Storage Tank Secondary Containment to Ground. Caused by Maint Personnel.Corrective Steps in Progress

ML20085F628
Person / Time
Site:	Hope Creek
Issue date:	10/15/1991
From:	Hagan J Public Service Enterprise Group
To:	NEW JERSEY, STATE OF
References
NLR-E91231, NUDOCS 9110220252
Download: ML20085F628 (14)

Text

i O PSEG PutAc Service Electoc and Gas Company P O B0m 236 Hancocks 4dge New Jersey 08038 Nuclear Department 1 CERTIFIED MAIL OCT15)W)

RETURN RECEIPT REQUESTED NLR-E91231 Bureau of Discharge Prevention New Jersey Department of Environmental Protection and Energy 401 East State Street CN027 Trenton, New Jersey 08625-0027 Attention: Discharge Confirmation Report Dear Sirst DISCHARGE OF CHLORINATED WATER FROM PUBLIC SERVICE ELECTRIC AND GAS (PSE&G) HOPE CREEK GENERATING STATION (CASE #91-9-16-1058-24) - 30 DAY CONFIRMATION REPORT As per the requirements of NJAC 7:1E-5.8, PSE&G has prepared a report (copy attached) confirming the discharge of 400 gallons of 0.23 ppm (originally reported as 0.40 ppm) chlorinated storawater from a Sodium Hypochlorito (15%) storage tank uecondary containment to the ground, which occurred at Hope Creek Generating Station on September 16, 1991. The discharge occurred entirely within PSE&G property, and no injuries resulted.

As the quantity of chlorine did not exceed a " Reportable Quantity" (RQ) of 1 pound under 40 CFR 302.4, (400 gallons x 8.34 gallons / pound x 0.000023% = 0.00077 lbs.), no notification of the release was reported to any agency other than the New Jersey Department of Environment 1 Protection and Energy (NJDEP2) and the Nuclear Regulatory Commission (NRC) , as required under 10CFR50.72, Significant Events.

PSE&G, in making the notification, believes that it acted in accordance with the intent of NJAC 7:1E, Subchapter 5, which requires all major facilities to notify the NJDEPE of discharges of petroleum and other potentially hazardous substances in any concentration. Hovover, field analysis of the water conducted immediately after the discharge, and confirmatory laboratory analysis shortly thereafter, indicated residual chlorine concentrations at levels consistent with potable water.

Jb4Encyrgy People, 5 9110220252 911015 "' " "" "

PDR ADOCM 05000354 S PDR

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001 1 5 1991 NJDEP 2 NLR-E91231 i

In retrospect, PSE&G believes that the discharge of the i stormwater, initiated by maintenance personnel in the course of routine activities, was an error which resulted from an ,

incomplete understanding of Hope Creek procedures and which released nothing more than water chlorinated at levels consistont l with drinking water quality to the ground. Based on this i subsequent analysis, PSE&G was not obligated to notify the NJDEPE since the event was not a discharge of a hazardous substance.

As a result of this discharge, PSE&G has conducted a follow-up investigation of the incident, and has implemented steps to educate all personnel performing this maintenance task and provide more guidance at secondary containment and tank truck unloading areas to prevent the reoccurrence of such events.

Should you have any questions concerning the information  ;

contained herein, or require additional information,'please contact Mr. Thomas Costantino of Licensing and Regulation at (609) 339-1459.

Since ely, I

s.

J H an Gene al anager -  :

Hope eek Operations ttachment i

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. NLR-E91231 C New Jersey Department of Environmental Protection and Energy-Division of Environmental Quality Bureau of Communications and Support Services-CN 411  !

Trenton, ?.aw Jersey 08625 New Jersey Department of Environmental Protection and Energy Southern Bureau of Regional Enforcement ,

20 E. Clementon Road l Gibbsbovo, New Jersey 08026 Attention: Mr. William Dunphee United States Nuclear Regulatory Commission I

Document Control Desk-Washington, D.C., 20555 Salem County Department of Health 98 Market Street Sales , New Jersey 08079 Attention Mr. James Warner i

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ATTACHMENT 1 DISCHARGE CONFIRMATION REPORT - SUPPLEMENTAL INFORMATION I RELATED TO DISCRARGE OF CHLORINATED STORMWATER FROM l

HOPE CREEK GENERATING STATION - CASE #91-9-16-1058-24 i INDIVIDUAL REPORTING DISCHARGE:

Engineer - Environmental Licensing Public Service Electric and Gas Nuclehr Department P. O. Box 236, M/C N21 Hancocks Bridge, New Jersey 08036 (609) 339-1459 1 INDIVIDUAL SUBMI7 TING CONFIRMATION REPORT:

General Manager - Hope Creek Operations Public Service Electric and Gas Nuclear Department P. O. Box 236, M/C N21 Hancocks Bridge, New Jersey 08036 (609) 339-1229 FACILITY OWNER / OPERATOR:

Public Service Electric and Gas Co.

P. O. Box 570-17G Newark, New Jersey 07101-0570 INDIVIDUAL (S) RESPONSIBLE FOR THE DISCHARGE:

General Hanager - Hope Creek Operations Public Service Electric and Gas Nuclear Department P. O. Box 236 M/C H07 Hancocks Bridge, Now Jersey 08036 DISCHARGE SOURCE:

Hope Creek Service Water -

Sodium Hypochlorite (15%) Tank (Secondary Containment)

In the absence of a supervisor who normally oversees the drainage of stormwater from the service water sodium hypochlorite tank secondary containment, stormwater with a total residual chlorine concentration determined to be 0.23 ppa, was discharged from the secondary containment to the ground by maintenance personnel performing routine activities. Accepted practice is to check for residual chlorine in stormwater inside the tank secondary containmont before discharge, and if residual chlorine is detected, the stormwater is discharged into the Service Water system for station use.

l ATTACHMENT 1 (continued) )

DISCHARGE CONFIRMATION REPORT - FUPPLEMENTAL INFORMATION 1 RELATED TO DISCHARGE OF CHIDRINATFD STORMWATEP FROM l HOPE CREEK GENERATING STATION - CASE $91-9-16-1050-24 DISCHARGE IOCATION:

Hope Creek Generating Station j End of Buttonwood Road Blockft 26 Lotf 4 Municipality Hancocks Bridge l Countyt Salem County i zip Code: 08036 l Tax $1 22-1212-800 ,

EPA IDit NJD077070811

- (Map Enclosed - see Figures 1 and 2)

CHEMICAL DISCHARGED:

0.40 ppa Total Residual Chlorine in Stormwater-(Reported) 0.23 ppa Total Residual Chlorine i in Stormwater (Actual)

CAS Number 7732-18-5 (Per New Jersey Worker and Community Right To Know)

QUANTITY DISCHARGED: Approximately 400 gallons (1512 liters)  ;

DATE/T7ME DISCHARGE BEGAN September 16, 1991 0800 Hours DATE/ TIME DISCHARGE ENDED: September 16, 0845 Hourr DATE/ TIME DISCHARGE DISCOVERED: September 16, 0930 Hours DATE/ TIM 3 DISCHARGE REPORTED: September 16, 1058 Hours To NJDEPE. Notline i

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ATTACID4ENT 1 (continued)

DISCHARGE CONFIRMATION REPORT - SUPPLEMENTAL INFORMATION RE1.ATED TO DISCHARGE OF CHLORINATED STORMWATER FROM HOPE CREEK GENERATING GTATION - CASE #91-9-16-1058-24 JUSTIFICATION FOR DELAY IN 15 MINUTE NOTIFICATION:

A 15 minute notification of the discharge was not made for a number of reasons. Those discharging the stornwater, during and af ter the ever.t, had no reason to suspect that the water was chlorinated. There was no odor associated with the stormwater whatsoever, Secondly, the site is located in a remote location of Hope Creek Generating Station. After the station chemistry staff was notified of the discharge and tested for the presence of residual chlorine in the water, substantial time had passed. Once the presence of residual chlorine was identified, efforts to notify the Hotline were undertaken, however, the only telephone near the location is situated inside a building (the Service Water Intake) where pumps and equipment noise make discussion (required for notification) almost impossible. Therefore, notification was made from a less remote location, and 15 minute notification was not possible.

MEASURES TAKEN TO CONTAIN, CLEANUP AND REMOVE THE DISCHARGE:

The presence of residual chlorine in the stormwater discharged from the storage tank secondary containment was not known until 0930 hours0.0108 days <br />0.258 hours <br />0.00154 weeks <br />3.53865e-4 months <br />, 1 1/2 hours after the discharge began. Those at the location had no knowledge of residual chlorine in the water. Consequently, by the time residual chlorine was discovered based on an analysis performed by Hach Kit at 0.40 ppa, the water had percolated through a surface layer of gravel onto the ground. Once this analysis confirmed the presence of chlorine, the discharge was reported to the NJDEPE.

At the direction of the Bureau of Emergency Response, which requested PSE&G perform some form of initial remediation, on-site personnel were mobilized to report to the scene, remove the gravel and wet soil (a quantity of approximately 5 cubic yards) by front-end loader and place it on a vinyl liner. The quantity of soil removed and the depth of soil extraction was based on a visual determination of the extent of water percolation through the soil.

The soil was then exposed to the air until it dried out, and was then extracted for residual chlorine analysis. When the residual chlorine was no longer detected in the soil, it was placed back in its original location. Laboratory analysis later determined the actual concentration of residual chlorine in the stormwater at 0.23 ppm, not the reported 0.40 ppm.

ATTACHMENT 1 (continuwd)

DISCHARGE CONFIRMATION REPORT - SUPPLEMENTAL INFORMATION RELATED TO DISCHARGE OF CHLORINATED STORMWATER FROM HOPE CREEK GENERATING STATION - CASE 691-9-16-1058-24 CORRECTIVE MEASURES:

Maintenance personnel in the course of routine maintenance activities, performed stormwater drainage duties in the absence of a supervisor and were apparently unaware of the generating s':ation accepted practice of testing all accumulations of stormwater in secondary containments for contamination, prior to stormwater discharge. As a result, a number of steps were taken to insure that discharges of this type, and others of a more serious nature, are avoided.

First,the personnel involved were counseled as to the acceptable practice for secondary containment stormwater handling. Secondly, the Maintenance Department management reiterated the proper procedures for management of secondary containment and truck unloading pad stormwater disposition with all mechanics with maintenance duties. Lastly, temporary signs (which will be replaced with permanent signs in the future) were erected on all yard area tank secondary containments and truck unloading pad locations advising maintenance personnel not to drain these areas until they have been sampled by the station Chemistry Department.

INDIVIDUAL INVOLVED IN CONTAINMENT / CLEANUP:

Senior Nuclear Maintenance Supervisor Site Services Maintenance Public Service Electric and Gas Nuclear Department P. O. Box 236, M/C N34 Hancocks Bridge, New Jersey 08038 (609) 339-5041 TYPE, QUANTITY, LOCATION AND DATE OF SAMPLES:

(copies of Laboratory Data attached)

Samole 1 Water, 25 milliliters (ml.), from the ground at the site, 9/16/91, approximately 0930 hours0.0108 days <br />0.258 hours <br />0.00154 weeks <br />3.53865e-4 months <br /> (Hach Kit). Before containment / cleanup.

Total Residual Chlorine concentration - 0.40 ppm

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t ATTACHMENT 1 (continued) ,

DISCHARGE CONFIRMATION REPORT - SUPPLEMENTAL INFORMATION RELATED TO DISCHARGE OF CHLORINATED HATER FROM HOPE CREEK GENERATING STATION - CASE $91-9-16-1058-24 Samp3.1 1 Water, 25ml. , from the ground at the site, 9/16/91, approximately-0945 hours, more accurate test method. Before containment / cleanup. ,

Total Residual Chlorine concentration - 0.23 ppu.

Emunia 3 So11,.500g, from the discharge area, 9/17/91, for the continued presence of residual chlorine in the-ground. After containment, *

- during cleanup.

Total Residual chlorine concentration - None Detected f Sarnit_1-Soil, 500g, from the discharge area, 9/17/91, for the continued presence of residual chlorine in the ground. After-containment, during. cleanup.

Total Residual Chlorine concentration - None Detected Samnle 5 ,

Soil, 500g, from the. soil pile removed from the discharge area, 9/17/91, for the continued presence of residual chlorine in the '

soil pile, after cleanup.

Total Residual Chlorine conc 6ntratlon, - None Detected -i

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INDIVIDUAL CONDUCTING ANALYSIS:

Senior Chemistry Supervisor Radiation Protection / Chemistry Department- -i Public Service Electric and' Gas Hope Creek Generating Station

• P. O. Box 236, M/C H36 Hancocks Bridge, New Jersey 08036 (609) 339-2411 O

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Hope Creek Gen >rahng Station Hope Creek Generating Station  !

Lab Results For C12 Analyses l

10/14/91 l 1

t sample #- Description Sample Analysis Results MDL ,

Date Date ag/L mg/L  !

OS-07695 EQ Dike 9/16/91 -9/16/91 0.23 0.05 OS-07704

• Soil Sample 9/17/91 9/17/91 <0.05 0.05 OS-07705' ~* Soil Seaple 9/17/91 9/17/91 <0.05 0.05 l i

OS-07706

• Sol) Sample 9/17/91 9/17/91 <0.05 0.05 .;

• Analycas conducted'on extract of soil sample. The extract was prepared based on 500 gas. of soil per 1000 mis'demin. ,

water,

- Technicians.J. Atkinson/R. Krusz NJDEP Iab Cert # 17451 l

- Method'#408E Q

Reviewed by . M.2% .

- The Energy People

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t ATTACHMENT 1 (continued)

DISCHARGE COHFIRMATION REPORT - SUPPLEMENTAL INFORMATION RELATED TO DISCHARGE OF CHIDRINATED STORMWATER FROM HOPE CREEK GENERATING STATION - CASE $91-9-16-1058-24 QUALITY ASSURANCE PROCEDURES Multiple (duplicate) sample analyses were conducted in an effort to ascertain total recidual chlorine concentration, using blank samples to zero instrumentation. No additional quality assurance (QA) samples were analyzed, on-site laboratory procedures for residual chlorine analysis do not not normally include provision for QA sample spiken and duplicates. This is due to the fact that QA samples do not accurately duplicate the water chemistry of the operations where testing is routinely required.

SAMPLE METH"SOLOGY t All samples taken were placed directly into new (previously '

unused) plastic bottles and taken directly to the station laboratory, NJUEPE certified to perform total residual chlorine analysis. No chain-of-custody procedures were utilized since those performing the sampling either analyzed the samples themselves or observed the sampling. Quality contrci used to verify sample results is consistent with those requirements cited at NJAC 7:18-4.7.11, and consistent with guidelines for routine on-site analysis of this parameter as provided by NJDEPE, Offico of Quality Assurance inspectors. The analytical methodologies performed are as follows:

Parameter Test.Mothodoloav Total Residual Chlorine Standard Methods for the Analysis of Water and Wastewater, 15th Ed.

Method 408E. ,

RATIONALE FOR SAMPLING IhCATION:

All samples were taxen in the area directly impacted by the stormwater discharge including samples from stormwater which had remained on the soil surface and had not percolated into the ground. Addition samples were taken from tne soil removed from the ground and staged. One sample (sample 1) was used to determine the total residual chlorine in the discharged stormwater in the field. Another sample (sample 2) was used to confirm the field analysis at the on-site certified laboratory.

Two samples (samples 3 and 4) were taken of the affected soil during cleanup, and one sample (sample 5) was obtained from the soil after cleanup.

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4 ATTACHMENT 1 (continued) -

DISCHARGE CONFIRMATION REPORT - SUPPLEMENTAL INFORMATION >

RELATED TO DISCHARGE OF CHIORINATED STOPJ0fATER FROM l HOPE CRRJK GENERATING STATION - CASE f91-9-16-1058-24  :

FINANCIAL RESPONSIBILITY: i Financial responsibility is provided through Excess  !

Liability Insurance. This insurance is through the  ;

following carrier 1-Associated Electric and Gas Services, Inc.

Harborside Financial Center 700 Plata Two.

Jersey City, New Jersey 07311-3944 ,

Policy ft X0015A1A91 ,

Effective Datet 8/1/91 ,

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CERTIFICATION -j i

, state of New Jersey:  ;

ss i County of salea  :

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I certify under-penalty cf law that the information provided . ,

- in this document is true, accurate and complete.

I an aware that there are significant-civil and criminal penalties,  !

including fines.or imprisonment or both, for subsitting -

false,_ inaccurate or incomplete information.

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)i 4 Sworn and subscribed before me l cn this,, /5 day of 6c h- A r- , 1991. -

L l'i tupf?h '

Notar;' Public U ',

SP.E5 !., Mtt'4 WOTuy putu; & kG'221-By (;emestist E3 pdm DM De II 5 t

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