ML20126M769

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NPDES Noncompliance Notification:On 841120 & 21,turbine Bldg Sump Flooded & Oily Waste Treatment Sys Temporarily Bypassed.Caused by Main Boiler Feed Pump Leakage.Leakage Cut to Flow Level Turbine Sump Pumps Could Handle.W/Addl Repts
ML20126M769
Person / Time
Site: Palisades Entergy icon.png
Issue date: 12/03/1984
From: Fobes R
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: Morley F
MICHIGAN, STATE OF
Shared Package
ML20126M704 List:
References
M905, PAL-84-11-AD103, NUDOCS 8506200458
Download: ML20126M769 (16)


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a. ui 4 2ci. istri 7oeesso December 3, 1984 j-District Supervisor Mr Fred Morley Plainve11 District Office Building 621 North 10th Street PO Box 355 Plainvell, MI 49080 FILE NO: P10.2.1 INCIDENT NO: PAL-84-11-AD103 This is in regard to NPDES Permit No MI 0001457 for the Conpany's Palisades Plant. In accordance with Part II, A4, the attached " NPDES Notification,"

Incident No PAL-84-11-AD103, is submitted as a report of an apparent'bypasting of vastewater treatment facilities at this plant.

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If you have any questions regarding the attached report, please contact this office.

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R L Fobes Senior Environmental Advisor CC USEPA, Enforcement Div, Region V BCC RBDeWitt, P-26-117B KFBieszke, P-24-329 BDJohnsca, P-24-606 BkEarguglio, JSC-220A l

JTFirlit. Palisades JRSchepers, Palisades SFPierce, Palisades l

ATUdrys M-1023 8506200458 850531 PDR ADOCK 05000255 R

PDR.

l OC1284-0003A-ENO3-TP13 i

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File No P10.2.1 Incident No: PAL-84-11-AD103 b

NPDES Notification Apparent Difference From Daily Average / Maximum Limitation l

November 29, 1984 I

l Plant: Palisades Permit No: MI 0001457 l

l Outfall

Description:

Turbine Sump Oil Separator Outfall Code No: 800218 i

Discharge (00G)

Parameter: NA Parameter Code No: NA 1.

Date of Incident:

11/20/84 and 11/21/84 2.

Identification of specific effluent limitation or monitoring requirenent affected:

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Any diversion from, or bypass of, facilities necessary to maintain compli-ance with terms and conditions of the permit is prohibited.

3.

Descriptics of Incident:

From 11/20/84 at 1910 hours0.0221 days <br />0.531 hours <br />0.00316 weeks <br />7.26755e-4 months <br /> until 11/21/84 at 0740 hours0.00856 days <br />0.206 hours <br />0.00122 weeks <br />2.8157e-4 months <br />, the plant's oily vaste treatment syste= vas temporarily bypassed because of an energency situation where the turbine building su=p became flooded. A portable su:p pump was utilized to pu=p the ficodvater directly to the plant's cain discharge (001), bypassing the oily vaste treatment s3 stem. Estimated total discharge flow was less than 7000 gallons.

4.

Apparent Cause:

During the plant's return to power, the main boiler feed pumps were placed in operation. Leakage from these pumps (esticated at 100 sp= of demineral-ised water) resulted in the flooding cf the turbine building su=p in excess of the su=p pump's capacity.

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5.

If not immediately corrected, the anticipated time the condition is expected to continue:

NA l

6.

Corrective Action - The following corrective action was taken or vill be I

taken to reduce, eliminate and prevent recurrence:

The feed pump leakage was reduced to where the turbine building sump pump could handle the inflow. Two samples of the undiluted floodwater were collected for oil and grease analysis. The analytical results will be included in the MOR for November 1984. The samples appeared visually clear of any oil'or grease.

f' RP1284-0003A-ENO3-TP14 I

Filo No P10.2.1 Incident No PAL-84-11-AD103 7.

Additional Commients:

The final discharge to Lake Michigan (Outfall 001) showed no visible oil.

8.

Signed: R L Fobes y g g l

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RP1284-0003A-ENO3-TP14 l

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uc~,.- 4..~.. s.x,m m W.c Ng an 492 e Ar.. Coc. SM 78 8-C S SO May 10, 1985 M905 Mr Galen Kilcer Groundwater Ouality Division Michigan Department of Natural Resources 621 Tenth Street PO Box 355 Plainvell, MI 49080 REPORTS OF OIL, SALT OR POLLUTING MATERIAL LOSS -

DEMINEPALILZER REGENERAhTS AND CAUSTIC LOSSES PALISADES PLANT, COVERT, MICHIGAN Enclosed are two Reports of 011 Salt or Polluting Material losses, Fort R4616, applicable to recent losses of de=ineralizer regenerants and caustic soda at the Cc=pany's P.alisades Plant near Covert, Michigan. These losses were discevered at 11:00 PM on May 1, 1985 and 1:15 PM on May 2, 1985, respec-tively. Both events were reported to the Plainuell District MDNR at 4:30 PM on May 2, 1985.

Should you require ary additional infor=ation regarding this catter, please contact this office.

R L Fobes Senior Environmental Advisor BCC ATUdrys, M-1023 DHAndrews, Palisades JRSchepers, Palisades JFFirlic, Palisades BDJohnson, P-24-606 j

1 OC0585-0016A-ENO3 i

STATE OF MICHIGAN DEPARTMENT OF NATLRAL RESOURCES REPORT OF OIL, SALT OR POLLUTING MATERIAL LOSSES Pursuant to the provisions of Act 245 of the Public Acts of Michigan 1929 as amended, regulations have been issued which repre 1

that all owners, managers or operators of vessels, oil storage or on fand facilities shall notify the Water Resources Commission or his authorized represerttative of oil, salt and polluting material losses. This notification shall be made promptly by telephone or telegracn, giving briefly the particulars, and by mail, giving a detailed account of events and conditions.

I esti corroe,y Nem.

May 3, 1985 Consumers Power Company - Palisades I

Locatsn of Loss (se 50ecif cJ Polisades Plant, 277780 Blue Star Mecorial Highway, Covert, MI 49043 l

Neutralizer Tank (T921) See Palisades SPCC/ PIP App C May 2. Location "N" i

Meteve Lost Amount Name of brface Water snevec l

,Ccu0 tic Soda (NaOH) 1875 gallons Not Applicable l

Does Loss men C =a.,.

Tsme of Discovery May 2, 1985 1315

.h of Ex ws.t of Natures Resources Repressetetswe Contactea Rich Sadowski, MLNR, Plainve11 Field Office j

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Tewocea or Teeersonea av nmom re.

l D;vid H Andrews, Laboratory Supv-Environmental 5/2/85 1630 a

c af Loss oncewee Two oe sow -... ano otner oet as

  • Soo Attached Report i

aserm c Lose uncruce como.ete oe.creten of ommeses Sao Attached Report Aectones C--

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Onctuoe Metmoa of Control, Plans for Provention of Recurrence, etc I i

522 Attached Report

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VM sY ( M eeI Concusers Power Company-Palisades David H Andrews/RLFobes 24 Hr Emergency Notifiestion Number 1900) 292 4708 Environmental Department Pamell Road

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Jackson. Miceween MIO585-0017A-EN03

    • 8

10/73

STATC OF MICHlGAN DEPARTMENT OF NATURAL RESOURCES REPORT OF OIL, SALT OR POLLUTING MATERIAL LOSSES Pursuant to the provisions of Act 245 of the Public Acts of Michigan 1929 as amended, regulations have been issued which require that all owners, managers or operators of vessels, oil storage or on land facilities shall notify the Water Resources Commission or his authorized representative of oil, salt and polluting material losses. This notification shall be made promptly by telephone or telegraph, giving briefly the particulars, and by mail, giving a detailed account of events and conditions.

Deie company Name May 3, 1985 Consumers Power Company - Palisades Locatun of Loss (Be specific)

Palisades Plant, 277780 Blue Star Memorial Highway, Covert, MI 49043 N:utralizer Tank (T921) See Palisades SPCC/ PIP App C May 2. Location "N" Mater 4J Lost Amount Name of Surface Water anvosved Denineralizer Regenerants 840 gallons Not Applicable kfT %gj"

T[3'00 '

'V Y EIY D o"EkT,"% N,"T U YnTr'e*If Y OS**8 b ee 3*v"II if'IEIr N,"L*aN ratory Supv-Environmental

/2/85 1630 Cause af Loos unciude Type c iauipment and Otner Dets es)

See Attached Report t r3 f de ete Description of Demees)

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gitjoggg gt hod of Control, Plans for Prevention of Recurrence, etc )

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'CIn:umers Power Company-Palisades David H Andrews/RLFobes 24 Hr Emergency Notifiestion Number Return this form to:

Environmental Department Pernell Road Jenkson, Michigen MIO585-0017A-ENO3 mesis 1C/73

CONSUMERS P0k'ER COMPANY PALISADES PLANT Demineralizer Regenerants & Caustic Losses May 1 and 2, 1985 Narrative Report I.

Sequence of Events Leading to and Involving the Spill April 30 2020 Hrs Tank T921 filled with demineralizer regenerants May 1 1915 Caustic added to T921; no leak at this time

  • May 1 2300 Chemistry personnel sampled T921; leak i

l discovered, pH 1.9, leak estimated at 5 gal / min May 1 2315 25 gal caustic added to T921 l

May 1 2340 Chemistry personnel sampled T921, pH 2.33 May 2 0032 T921 contents released to Lake Michigan via outfalls 00F/001; release met requirements of NPDES Permit MI0001457 May 2 "0148

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T921 at 50% level; leak has ceased l

May 2 0235 T921 empty (release completed)

May 2 1115 Received load of caustic (50%NaOH) for Tank T907, makeup demineralizer caustic tank May 2 1315 overflowed T907 to chem sump; chem sump automatic pump to neutralizer tank (normal discharge point)

May 2 1315 Neutralizer tank leaking caustic to sand under tank: concentration is approximately 20% Sodium Hydroxide May 2 1400 Started filling T921 to 50% in preparation to neutralize contents, pH of leak 14 May 2 1530 pH 13.5; requested 60 gallons acid added

  • It was previously reported that discovery was at 2315 rather than 2300.

MIO585-0018A-ENO3

May 2 1602 Pumping leaking water from sand area under T921 to chem sump (pucps manually off)

May 2 1610 pH 13 May 2 1625 60 gallons acid added to T921 May 2 1700 T921 pH 12.02 (high solids), requested 22 gal acid May 2 1715 Acid (22 gal) added May 2 1750 T921 pH = 1.7 (solids = 12.0 mg/1)

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May 2 1820 Started release of T921 to Lake Michigan through outfalls 00F/001 May 2 1930 Neutralizer tank empty; release secured May 2 2100 Lab Supv-Env requested valves and pump breakers on systems leading to neutral-irer tank be caution tagged to prevent a third accident i

II.

Nature of the loss 1

The demineralizer regenerants lost from 2300 hrs on 5/1 to 0148 hours0.00171 days <br />0.0411 hours <br />2.44709e-4 weeks <br />5.6314e-5 months <br /> on 5/2 included 200 gallons during the 40 minutes from discovery until the pH was analyzed at 2.33 and 640 gallons from then until the leak ceased at 0148 hours0.00171 days <br />0.0411 hours <br />2.44709e-4 weeks <br />5.6314e-5 months <br /> on 5/2. The 840 gallons were contained in the sand-immediately under the east half of the tank (T921). As a precautionary measure, one bag of slaked line was spread in the area to insure neu-tralization of the acid. These regenerants contained an equivalent of 11.8 lbs of unneutralized sulfuric acid lost to the soil (200 gal x 3.785 1/ gal x 0.013 eq/1 x 49g H SO /eq x lb/454g) + (640 gal x 3.785 2 g 1/ gal x 0.0046 eq/1 x 49g H SO /eq x lb/454g) = 11.816 y 4 None of the listed regenerants reached Lake Michigan as an uncontrolled I

spill'(although the major portion of the tank contents was released to the Lake through outfalls 00F/001 as a normal release in conformance with the requirements of NPDES Permit MI0001457 and Plant procedures).

There were no personal injuries associated with this loss and no proper-ty damage.

The caustic loss included 225 gal of 20% caustic from the time of discovery until contents were diluted with water (45 min x 5 gal / min) plus 900 gallons of 0.1 normal caustic solution from time of dilution until pH dropped to 12.2 plus 250 gallons 0.01 normal caustic solution until pH reached 1.7 at 1750 hours0.0203 days <br />0.486 hours <br />0.00289 weeks <br />6.65875e-4 months <br />. An additional amount of 500 gallons-was lost during draining of the tank for a total volume lost of 1875 gallons. About 50% of the lost caustic was pumped back into the MIO585-0018A-ENO3

participating in an effort to effect changes to the physical tank and the systems, and maintaining the system to prevent or minimize future spill. events. Until all aspects of the operation are scrutinized, it is impossible to predict what changes will be made; however, results from this effort should be available later this year.

VI.

Cleanup An evaluation is being performed at the present time to ascertain the type and extent of cleanup required following a loss of this nature.

Any cleanup action should be started the week of May 6, 1985 unless unforeseen factors delay the cleanup.

DHAndrews/5-3-85 1

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1 MIO585-0018A-ENO3

che ical s q frc: the ground althcugh =c credit is assu ed fer this areunt..The tctal a ece of caustic lest is 413 peu-ds as fc11evs:

(225 gal x 3.7551/ gal x 200g/l KaOH x lb/45tg) + GOO gal x 3.7551/ gal x Ag/l KaOH x lb/454g) + (250 gal x 3.7551/ gal x.ag/l NaCE x Ib/454g)

= 413 lbXaOH-No injuries occurred as a res=1: cf this less and ::e cf the lest material reached Lake Michigan.

III. Cause cf Less The nernal regeneratics of the Plant zakeup de=ineralizers results in the accurulation of about 35,0C0 gallers of rege=erants (pH 2) in tank T921.

A=y flav in the internal ceating of the tank allevs this errre-sive liquid to contact the carben steel shell resulting in eventual thrcugh vall failure cf the tank. Because of the heat tracing and insulatics c the task, it is pessible to not =ctice small leaks. The current leak started with pH 2 vater sitting in the tank fer ever 24 he=rs before initiatics of a leak sufficiently large eneugh to escape fr== the i=sulatic: ja:iet.

The caustic less had an additienal failure associated with it in that the level indicatie= c the T907 caustic storage ta k is currently ineperable; censequently, the cperater did =ct k: v until the tani crerfleved that it was full. Additietally, there are no instructiets te c;erati=g perse :e1 to isolate feedvarer purity buildi=g sun; y

,s fre=

the neutralizer tank during a leak event; cceseque=tly, the centents of' the chenical susp were pu= ped (autesatically) frc an e:vire tertally-safe location to an envire :nertally-unsafe locatics (7921) where up =

the-leak free the tank was reinitiated.

1Y.

Plant Respe ses to the Spill Open discovery, the shif"t supervisor inveked the Palisades SPCC/ PIP a:d

=ctified the Duty On-Call Superintendent and then the Lab Superviser-Envirecaestal was centacted. Proper instediate actiers to elizinate the leak by er;tyi=g the tank were taken while insuring that the quality of the Plant effluent was net adversely affected to zitigate the leak.

Plant Operating and Chemistry perse::el teck the recessary steps to reduce the ce=sequerees of the leak by adding line fer the acid spill and purping as much as possible of the caustic back to the chemical surp. All of these actions were perferned within the persenal prctec-tive ccustraints of the Consumers Power Accident Protectie Manual insuring that no injuries veuld be received as a result.

V.

Actices Being U=dertaken to Prevent er Minitize Future Potential for Spill Ter the shcrt term, all lines leading to the neutralizer ta=k have been caution tagged to prevent reoccurrence cf the leak. Maintenance C$rders have been written to inspect the tank fer leaks and repair the leaks as found. Operations Chemistry and Engineering perse e1 vill be

-MIO585-0018A-Et03

REcni,u-gy %,t APRI S;r5 s

F consumers gg NUCLEAR UCl,,#,;,,4 g

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General Off ces 212 West Michigan Avenue. Jackson. M chigan 49201. Area Code 517788-0550 April 17, 1985 M905 Mr Galen Kilmer Groundwater Quality Division Michigan Department of Natural Resources 621 Tenth Street PO Box 355 Plainwell, MI 49080 REPORT OF OIL, SALT OR POLLUTING MATERIAL LOSS -

SULFURIC ACID LOSS, PALISADES PLANT, COVERT, MICHIGAN Enclosed is a Report of Cil, Salt or Polluting Material Losses, Form R4616, applicable to a recent sulfuric acid loss at the Company's Palisades Plant near Covert, Michigan. This loss was discovered at 5:10 AM on April 10, 1985 and reported to the Plainwell District MDNR at 10:30 AM on April 10, 1985.

Should you require any additional information regarding this matter, please contact this office.

c.

R L Fobes Senior Environmental Advisor BCC BWMarguglio, JSC-220A ATUdrys, M-1023 DHAndrews, Palisades JRSchepers, Palisades JFFirlit, Palisades BDJohnson, P-24-606 OC0485-0029A-EN03

i STATE OF MICHIGAN DEPARTMENT OF NATURAL RESOURCES REPORT OF OIL, SALT OR POLLUTING MATERIAL LOSSES i,

Pursuant to the provisions of Act 245 of the Public Acts of Michigan 1929 as amended, regulations have been issued which require that all owners, managers or operators of vessels, oil storage or on land facilities shall notify the Water Resources Commission or his authorized representative of oil, salt and polluting material losses. This notification shall be made promptly by telephone or telegraph, giving briefly the particulars, and by mail, giving a detailed account of events and conditions.

1 Date Company Name April 15, 1985 Consumers Power Corpany Location of Loss (Be Specific)

CP Co - Palisades Nuclear Plant, 277780 Blue Star Memorial Highway, Covert, MI 49043 "A" Cooling Tower Acid Trench (SW Corner of "A" Cooling Tower)

Matenal Lost Amount Name of Surface Water involved 93% Sulfuric Acid 332 Gallon N/A Date Loss was Discoverso Time of Discovery April 10, 1985 0510 Hours Nams cf Department of Natural Resources Representative Contacted Rich Sadowski-Plainwell Tvephoned or Telegraphed by Whom Time David H Andrews 1030 Hours Cause of Loss (incluoe Type of Equipment end Other Details)

At 1840 Hrs on April 9, 1985, the "A" cooling tower acid pump was returned to service following repairs. At 0510 hours0.0059 days <br />0.142 hours <br />8.43254e-4 weeks <br />1.94055e-4 months <br /> on April 10, 1985, it was discovered that a flange in the acid feed line to the tower had separated due to failure of the bolts. The i

acid pump was immediately shut off and the leaking flange repaired.

N ture cf Loss Onclude Complete Gescription of Damage)

The majority of the acid was contained in the concrete trench for the acid feed line.

The remainder was. contained in the sand at the spill location.

1 Additiensi Comments Unclude Method of Control, Plans for Prevention of Recurrence, etc I The acid was neutralized in place by the addition of lime. Lime was added to the puddles of acid and general area where the acid spilled onto the ground. Additional lime will ha cdded to yield a neutral pH throughout the area. To prevent recurrence, acid resistant bolts will be installed at the flange.

Company Nome By (Signature)

Consumers Power Company David H Andrews/RLFobes g [ [

24 Hr Emergency Notification Number Return this form to:

Environmental Department Parnall F,oed Jackson, Michigan MIO485-0032A-ENO3

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CODSumBIS e

Power Company

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3 General offices: 212 West Michigan Avenue, Jackson, MI 49201 * (517) 788 4550 January 10, 1985 M905 Mr Galen Kilmer Groundwater Quality Division Michigan Department of Natural Resources 621 Tenth Street Plainwell, MI 49080 REPORT OF OIL, SALT OR POLLUTING MATERIAL LOSS -

CAUSTIC LOSS - PALISADES PLANT, COVERT, MICHIGAN Enclosed is a Report of Oil, Salt or Polluting Material Losses, Form R4616, applicable to a caustic loss at our Pelisades Plant located near Covert, Michigan. This loss was discovered et 4:00 PM on October 12, 1984 and report-ed to the Michigan Water Resources Commission Hotline at 4:30 PM on October 12, 1984 Should you require any additional infornation regarding this matter, please contact this office.

5W Ronald L Fobes Senior Environmental Advisor i

1 RLF/fch l

i BCC BWarguglio, JSC-220A ATUdrys, M-1023 JRSchepers, Palisades DHAndrews, Palisades BDJohnson, P-24-606 OC0185-0046A-ENO3

e STATE OF MICHIGAN DEPARTMENT OF NATURAL RESOURCES REPORT OF OIL, SALT OR POLLUTING MATERIAL LOSSES Pursuant to the provisions of Act 245 of the Public Acts of Michigan 1929 as amended, regulations have been issued wnich require that all owners, managers or operators of vessels, oil storage or on land facilities shall notify the Water Resources Commission or his authorized representative of oil, salt and polluting material losses. This notification shall be made promptly by telephone or te:egrapn, giving briefly the particulars, and by mail, giving a detailed account of events and conditions.

Data Comseny Name 1-10-85 Consu=ers Power Cc=pany Location of Loss tBe Soecifica i

Palisades Plant, Route 2, Ecx 15k, Covert, Michigan L90k3 Marenar Lost Amount Name of Surf ace Water invoevec 507. Cuastic Soda (NaOH) 50 gallens NA Date Loss vues Discoverec Trne of Discovery 10/12/Sk 1600 Name of Depa tment of featural Resources Representative Contacted FIAS Operator Teiepnoned or Telegrapned Dy Whom Time

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D li Andrevs 1630 Caae of Loss Unciuoe Type of Ecuement sno Otner Detaits)

The caustic transfer line to the vaste neutralizer tank (T921) serarated due to insufficient support.

i Nature of Loss Unctuce Complete Description of Damage)

About 50 gallons of 50f. NaOH stilled ento and soaked 1 +o the en-4 n da-ae+k i

the tank.

Addstional Comments Unclude Metnod of Control, Plans for Prevention of Recurrence, etc !

Se :uence of events to date: 10/12 - Srill. 4 ediat e.eti--

r,--+4+4-n+4 -c a.- cr-- ere

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10/15 Analyze and dete:=ine extent of loss 10/31-11/15 - Generate purchase documents for soil re= oval i

12/17 - Remove effected soils and replace with clean material Commeny m.m.

av (s,wturel Consu=ers Power Cc=pany DHAndrevs/ELTobes 24 Hr Emergency Notification Number gry (800) 292-4706 i

Environmental Department Parnell Road

.lackson, Michigan Ra616 ton 3

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h C*fcat 212 Wes! WN A.*%e Joca sce, w r 432:1 * ($171784,0553 January 15, 1985 M905.1 Mr Galen Kil=er Michigan Depart =ent of Natural Rescurces Plainvell District Office 621 N 10th Street l

Plainvell, MI 49050 TFESPOF. MEA MINEFX. OI' 1.EAK AT TEE PAhISADES FLANT As we discussed over the telephene en January 9, 1955, the folleving infer:a-tien is provided relative to the transfer =er cil leak at the Ce pany's Pali-sades Nuclear Plant which was verbally reperted to yeu en February 24, 195t.

At that tire, Mr F.cger Ehiting cf cur staff provided yeu a preli=itary de-scriptie cf the leak but no written account of the i=eident er of the Ce:pa-ny's follev-up action was provided.

The incident involved the Plant's Static: Power Transfor:er No 1-1 which vas knevn threugh testing to centaf: PC3-conta:1:ated (53 pp=) =ineral oil dielectric fluid. The leak was first detected in late Neve:Ser, 1953 by a

=aintenance engineer; he subsequently (February 21,195t) centacted the Plant's senior chemist who appraised hi= of the unit's lev-level PC3 centa=1-natics and brcught the leak to the attentien of the Ce:pany's Envirennental Depart =ent.

The leak criginated fre= a defective bushing near the tcp cf the transfer =er which allowed a s=411 quantity (<1 pint / day) of =ineral cil to seep dev: and drip into the catch basin /su=; syste: beneath the unit. There was concern that although the leaked = iteral cil had been initially centained in the catch ent syster, sete of the oil =ight have been inadvertently dis-charged to the surrounding soil and to a stor= drain during "as =eeded" purping of the su=p.

To ec= fir = pessible centa:ination, sa:ples for PC3 analysis were taken fre: (1) the soil / rocks that were part of the catch basic around and under the transfer =er, (2) fre= soil near the su=p and ster: drain, (3) fre: absorbent pads placed in the se=p, and (4) fre= subsurface water in the surp. In additien, (5) mineral oil fre= the transfer =er was retested to confir: its PC3 cencentratien. PCB concentratices feund in the five catego-ries cf sa:ples (in the order stated above) were: (1) 0.2 - 16.8 pp=; (2) <0.1

- 1.3 pp=; (3) 12.9 - 61.4 pp=; (4) <1 pp:; and (5) 65.7 pp=.

Based en analysis cf these results, it was concluded that the PC3 ce=ta:inatien of concern was restricted to the soil / rocks around and under the transfer:er and to the abserheet pads in the su=p.

Cleanup activities were therefore fecused on these areas.

OC0185-0040A-ENO3

2 Following repair of the transformer and retrofilling with non-PCB oil in early April 1984, cleanup and repair of the transformer catch basin ard sump was 1

performed. This operation resulted in the removal and replacement of approxi-i

~

aately 30 cubic yards of soil / rocks from the area near the transformer and the disposal of the absorbent pads which had been periodically replaced in the sump while avaiting repair of the transformer. The operation was concluded by t

testing a final water sample from the sump (it tested <1 ppm PCB) and pumping the sump water into the storm drain.

As discussed with you, because there was no loss of PCBs to the environment (it was retained in the transformer catch basin / sump system and ultimately properly disposed), no formal report of this loss will be made to the DNR.

Should you require more information or have any questions about this matter, feel free to contact me at 517-788-2475.

Sincerely, fP-

  • 2 Lloyd D Everhart Senior Aquatic Biologist LDE/feh CC BWarguglio, JSC-220A P.CHittle, JSC-202A DAndrews, Palisades HJDelinck, JSC-207 l

DC0185-0040A-EN03