ML20198J281

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NPDES Noncompliance Notification:On 981102,release of 500 Gallons of 12% Sodium Hypochlorite to Environment Occurred. Caused by Failure of Tank Discharge Fittings.Integrity Testing Will Be Performed on All New Tanks.With
ML20198J281
Person / Time
Site: Limerick Constellation icon.png
Issue date: 12/21/1998
From: Coyle W
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9812300131
Download: ML20198J281 (14)


Text

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PECO ENERGY  ;;cg;;;fgc -a "v Sanatoga, PA 19464-0920 i

l December 21,1998 Document Control Desk U.S. Nuclear Regulatory Commission l

Washington,DC 20555  !

Desk Administrator:

Per Limerick Generating Station - Unit 1 Technical Specifications, Docket Numoer 50-352, Appendix B

" Environmental Protection Plan," notification is being made of submMal of non-routine reports to ,

Pennsylvania State Agencies, l l

Under Appendix B, Section 5.4.2 "Non-routine Reports," LGS is required to submit a report of any non-routine occurrence to the Commission. The non-routine event involved the release of 500 gallons of 12% sodium hypochlorite to the environment. The release was caused by a failure of the tank discharge fittings and subsequent leaks from the secondary containment. j l

Attached are the reports sent to the Pa Department of Environmental Protection, Penrsylvania l Emergency Management Agency and the Montgomery County Emergency Planning Commission. The event is referenced under the USCG National Response Center Number 462231.

If you have any questions regarding this submittal, please contact me at (610) 718-2500.

Sincerely, b' f Will Coyle Environmental Compliance Manager cc:-

LGS Env File W. Coyle M. Alphonso f g

T. Moore

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9812300131 981221 P PDR ADOCK 05000352L S PDR gj r- o.

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  • Limerlik Cener; ting St;tioa
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l PECO ENERGY

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Sanatoga. PA 19464 @ 20 November 13,1998 Ms. Donna Suevo '

PA Department of Environmental Protection Division of Storage Tanks j

Lee Park, Suite 6010 555 North Lane l

Conshohocken, PA 19428 l

Dear Ms. Suevo:

On November 2,1998 the Limerick Generating Station reported the relesse of an RQ for sodium hypochlorite, National Response Center Case Number 462231. The attached 15 day Follow-up Report is being sent to meet the requirements set forth in Section 304 (c) of EPCRA (42 U.S.C.11004 (c)) and Section 206 (d) of the Hazardous Material Emergency Planning and Response Act (35 P.S. 6022.206 (d)).  ;

If you .have any questions regarding this issue please contact Will Coyle, Acting l Environmental Compliance Manager at (610) 718-2500. I Sincerely, Michael P. Gallagher, Plant Manager t

MPG /AJF:ve cc: J. D. von Suskil W. J. Coyle

M. J. Alfonso i J. J. Rogan Environmental files u

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1. Name, address and telephone number of the individual filing this report 1

' Michael P. Gallaaher. Plant Manaaer Limerick Generatina Station Sanatoaa. PA 19464 (610) 71822000 i

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2. Name, address and telephone number of the installation or site where the incident occurred.

!Imerick Generatina Station i Everareen and Sanatoaa Roads Sanatoaa. PA 19464 (610) 718-2000

3. Date, t:me and location of the incident.

Review of tank level indicators revealed the release beaan at 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br /> en November 1.

1998. The level did not drop enouah to trio the low level wamina at the Station. On November 2.1998 at 0618 hours0.00715 days <br />0.172 hours <br />0.00102 weeks <br />2.35149e-4 months <br /> the release was detected by Station oersonnel, The release occurred from the Unit 1 temporary sodium hvoochlorite storaae tank. The tank was located 10 ft south of the Unit 1 ccid/ chlorination buildina un a Daved surface.

Secondary containment was constructed around the tank. however the containment allowed 350 aallons of the total 500 aallons lost from the tank to be released to the environment.

The product flowed alona a crack in the asohalt until reachina a arass swale alona the eastem edae of the asphalt. Followina the oath of least resistanca the product flowed l alona this swale and into a culvert. Travelina throuah the culvert the product was halted at its northem e.nd by existina debris and soil. Acoroximately 120 aallons of product was recovered from the culvert.

4. A brief description of the circumstances causing the incident.

The incident was caused by an incompatible fittina attached to the temporary sodium i hvoochlorite storaae tank. The component failed aooroximatelv 5 days after installation.

l The resultina leak was released to the environment throuah holes in the temocrary secondary containment.

5. Description and estimated quantity (by weight or volume) of materials or wastes involved.

350 callons of a 12.5% solution of sodium hvoochlorite was released to the environment.

This eaustes to 437 counds of sodium hvoochlorite (RQ = 100 pounds). The pH rance of this materialis 10 to 12 dependina on hydroxide concentration and ace.

6. An assessment of any contamination of land, water or air that has occurred due to the incident.

.T.,j}ere was no re' esse to water or air.

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Land contamination covered an accroximate area. o12,.50 ft in lenath. 24 to 72 inches in

' width and uo to 24 inches deeo. 75 feet of this area consisted of asohalt and was  !

sampled and removed.125 feet of this area consisted crass and soil alona a swale and I i w

. as samoted and removed. 50 feet of this area consisted of a 14 inch diameter culvert i runnina 5 ft beneath a roadway. The culvert wasjur,hed repeatedly and rinsed with a 5%

solution of sodium sulfite.

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7. Estimated quantity and disposition of all recovered materials or wastes that resulted from the incident, and plans for ultimate disposa!.

Upon completion of excavation and decontamination 120 cubic vards of waste material have been aenerated. Two 55 aallon drums of oroduct soaked materials must be disposed of as hazardous waste. All other solids are beina handled as residual wastes.

All lioulds were cumoed into the Unit 1 Coolina Tower to assist in alcal control durina the restoration of the sodium hvoochlorite iniection system. Under normal operatina conditions. 500 callons of sodium hvoochtonte is iniected into the coolina tower daily.

8. A description of what actions you intend to take to prevent a similar occurrence in the future.

Intecrity testina will be oer*; .med on all new or temporary tanks. lines and containment systems.

1 Comoatibility analyses will be oerformed on all new or temporary systems and comDonents with reoard to chemical. ohysical and environmenul interferer ces.

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i PECO ENERGY  ;;=,l;;;;c-"v Sanatoga. PA 19464 4920 l

November 13,1998 I

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1 Mr. George Bartow Coordinator LEPC Montgomery County Office of Emergency Preparedness ,

Eagleville Road Eagleville, PA 19403 I Dear Mr. Bartow-On November 2,1998 the Limerick Generating Station reported the release of an RQ for ,

sodium hypochlorite, National Response Center Case Number 462231. The attached 14 l day Follow-up Report is being sent to meet the requirements set forth in Section 304 (c) of EPCRA (42 U.S.C.11004 (c)) and Section 206 (d) of the Hazardous Material Emergency Planning and Response Act (35 P.S. 6022.206 (d)).

If you have any questions regarding this issue please contact Will Coyle, Acting Environmental Compliance Manager at (610)718-2500.

Sincerely, l  % '

Michael P. Gallagher Plant Manger MPG /AJF:ve cc: J. D. von Suskil W. J. Coyle M. J. Alfonso l J. J. Rogan l Environmental files 4 *

. . 1 PENNSYLVANIA EMERGENCY MANAGEMENT AGENCY P.O. BOX 3321 HARRISBURG,PA 17105 HAZARDOUS MATERIAL EMERGENCY NOTIFICATION REPORT I

THIS REPORT has been prepared by or on behalf of the below-named company or individual in order to provide emergency notification information about a hazardous material release that occurred from a facility or vehicle that is either owned or operated by the named company or individual. Submission of this report is required by Section 304 (c) of the Emergency Planning and Community Righ*-to-Know Act of 1986 (SARA Title 111) (42 U.S.C.11004 (c)) and Section 206 (d) of i

the Hazardous Material Emergency Planning and Response Act (35 P.S. 6022.206 (d)). l

. RELEASE INFORMATION I 1

1. Name of Company, Owner or Operator.

l PECO ENERGY- Limerick Generatina Station

2. Address of Company, Owner or Operator. l l

Limerick Generatina Station I Everareen and Sanatoaa Roads Sanatoaa. Pa 19464

3. Chemical Name of Substance Released:

12.5% solution. Sodium Hvoochlorite

4. Quantity Released (LB):

437 counds

5. Location of Release: (describe site of release at the facility or, if a transportation accident, the highway milepost, intersection or other appropriate identifier):

The release occurred from the Unit 1 temocrary sodium hvocchlorite storaae tank. The tank was located 10 ft south of the Unit 1 acid' chlorination buildina on a caved surfagg Secondary containment was constructed around the tank. L owever due to existina holes in the containment 350 aallons of the total 500 aallons lost from the tank was released.

On 11/3/98 excavation resurT ed and was comoleted to a depth of 6 inches alona the entire lenath of the soill(excludina pavement). Excavation areater than 6 inches beoan the aftemoon of 11/3/98. Soil removal was allowed to proceed at 3 to 6 inch intervals due to Dotential underaround interferences. Sc!! color and odor were used as indicators for hvoochlonte contamination. 20 a soil samoles were taken at increasina deoths and from the excavation side walls until contamination levels were found to be <0.02 com residual oxidant The spill was found to terminate at the end of a 50 ft culvert runnina beneath a site road.

Initial contamination levels in the culvert were 740 com residual oxidant Lewis ,

Environmental comoea approximately 120 callons of product from the culvert and -

performed the first of three 300 aallon water flushes throuah the pipe. Contamination hels were reduced to 37 com residual oxidant upon completion of the initial flush.

l Excavation continued on the crass area on 11/4/98 and the contaminated oavement area was cut and creoared for excavation later that day. Excavation reached depths up to 21 inches in low-lyina arass areas to achieve contamination levels below 0.02 com residual oxidant The south end of the culvert (uostream) was excavated to a point where further excavation would imJact the road support and was halted. Contamination levels were less than icom residual oxidant in this area. The north end of the culvert (downs 7eam) was excavated the evenina of 11/5/98. Upon removal of the soil and asohalt free product was found at a deoth of 10 inches. Excavation continued around the face of the pioe and eventually exposed 16 inches of the Dioe and to a deoth of 14 inches. At this Doint contamination levels were found to be less than 1 com residual oxidant and the excavation was halted due to road support impact The second flush of the culvert was Derformed 11/6/98. 300 callons of water was cumped into the south end of the culvert and collected at the north end. The levels were reduced tq 11 com residualoxidant The third and final flush included a wash with 100 callons of a 5% sodium sulfite solution and rinse with 200 callons of water on 11/6/98. Sodium sulfite was used to neutralize any remainina sodium hypochlorite solution. Contamination levels were reduced to <0.02 com residual oxidant completina remediative activities in the cutvert Asphalt remowi continued at a width of 5 feet and death of 6-9 inches to where soil samoles cc.me back less than 0.02 com residual oxidant Initially, low levels of contaminant dess than 15 com residual oxidant) were found in the cavement undertavers.

Backfillina operations commenced immediately upon completion of samplina due to nuclear safeaaurd restrictions on excavation. Verbal approval was received from the Pa DEP to backfill as documented in the attached letter dated November 5.1998 from J J.

Roaan.

The excavation and backfilline were completed on 11/6/98 Final aradina and repavina l operations will be on-aoina.

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l The oroduct flowed aloca a crack in the asohalt until reachina the crast, swale alona the eastem edae of the asohilt. Followina the oath of least resistance the oroduct flowed alona this swale and into a culvert. Travelina throuch the culvert the product was halted at its northem end by existina debris and soil. Acoroximately 120 aallons of product was recovered from the culvert. .

The release did not leave the Site nor did it reach naviaabh waters.

6. Date, time and duration of Release:

Review of tank level indicators revealed the release becan at 2100 hou,s on November 1.1998.

The level did not drop enouah to trio low level wamina at the Station. On November 2.1998 at 0618 hours0.00715 days <br />0.172 hours <br />0.00102 weeks <br />2.35149e-4 months <br /> the release was detected by Station oersonnel performina scheduled rounds.

7. Release wasinto: Air Surface Water Sewer Ground X Highway Surface _,
8. Actions taken to respond to and contain the release, including the name of the any cleanup contractor. (provide complete description - use separate page if necessary):

initial Response:

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The release was caused by a chemically incompatible camlock fittina attached to the temocrary tank. To isolate the fittina and the leak. the valve upstream of this fittina was

, closed. Booms and spill cads were used to contain and redirect the flow as it exited the secondary containment. A load of earth and stone was dumoed at the cavement<rass interface to stoo flow to the crass area. The taroaulin olaced beneath the tank and containment durina construction acted as a cartial catch-basin for product leakina throuah the secondary containment.

Cleanuo and Restoration:

Lewis Environmental was contracted to perform the Site cleanup and restoration. Spill '

pads and booms were deoloved to absorb the remainino free product collectina in cracks and depressions in the cavement. containment basin, tarpaulin and crass.

Decontamination and removal of all free oroduct from the spill area wcs completed on 11/2/98. excludina the downstream cuNert. Containment was olaced beneath the valve and fittina to prevent further contaminant release.

To prevent release to waterways and other norx:ontaminated areas due to rain or catastrochic tank failure. an earthen berm us constructed at the downstream end of the i

re.ipase. Lewis Environmental maintains 24 spill resmnse coveraae.

9. Any known or anticipated acute or dronic health risks associated with the release

. (describe in detail-if not appropriate, state none):

None.

10. Advice on medical attention for exposed individuals (if appropriate):

There were no iniuries or oersonnel exoosures as a result of this release.

11. Actions to be taken to mitigate poten' tial future incidents (describe in detail):

Inteonty testina will be performed on all new or temocrary tariks. lines and containment systems.

Comcatib!!:tv analyses will be performed on allSwv or temocrary systems and comoonents with recard to chemical. ohysical and environmental interferences.

THIS REPORT was prepared by the undersigned on behalf of the company or individual named in paragraph 1. The information provided herein is true and correct to the best of my knowledge and belief.

NOTE: If you have any suggestions about preparation of this report, call the Pennsylvania Emergency Management Agency at (717) 783-7250 between Sam and 4pm Monday through Friday.

Prepared By: '

(Name)'

, Plant Manager (Trtle or Position)

(610)718-2000 (Telephone Nurr;ber) 11/13/98 (Date) l L .. . . . . .. .

l Limeri k Cener tixg St:tlin v .

O M mGY eccoe"<avce-a v Po Box 2300 Sanatoga. PA 19464-0920 November 13,1998

- Mr. Dick Rodney l Commonwealth of Pennsylvania Pennsylvania Emergency Management Agency  ;

P.O. Box 3321 l Harrisburg, Pa 17105 l

Dear Mr. Rodney:

l On November 2,1998 the Limerick Generating Station reported the release of an RO for sodium hypochlorite, National Response Center Case Number 462231. The attached 14 day Follow-up Report is being sent to meet the requirements set fodh in Section 304 (c) of EPCRA (42 U.S.C.

11004 (c)) and Section 206 (c) of the Hazardous Material Emergency Planning and Response Act (35 P.S. 6022.206 (d)).

If you have any questions regading this issue please contact Will Coyle, Acting Environmental Compliance Manager, at (610)718-2500.

Sincerely, Michael P. Gallagher  ;

Plant Manager -

MPG /AJF:vc cc: J. D. von Suskil l W. J. Coyle l M. J. Alfonso l J. J Rogan Environmental files J

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l PENNSYLVANIA EMERGENCY MANAGEMENT AGENCY P.O. BOX 3321 i

HARRISBURG,PA 17105 HAZARDOUS VATERIAL EMERGENCY NOTIFICATION REPORT l

THIS REPORT has beeri prepared by or' on behalf of the below-named company or-individual in order to provide emergency notification information about a hazardous material release that occurred from.a facifity or vehicle that is either owned or operated by the named company or individual. Submission of this report is required by Section 304 (c) of the Emergency Planning and Community Right-to-Know Act of 1986 (SARA Title lil) (42 U.S.C.11004 (c)) and Section 206 (d) of the Hazardous Material Emergency Planning and Response,Act (35 P.S. 6022.206 (d)).

RELEASE INFORMATION I

1. Name of Company, Owneror Operaton PECO ENERGY- Limerick Generatino Station
2. Address of Company, Owner or Operaton Limerick G3neratino Station Evemreen and Sanatoca Roads

(,

Sanatoca. Pa 19464

3. Chemical Name of Substance Released:

12.5% solution. Sodium Hvoochlo_r_itg t '.

4. Quantity Released (LB):

437 counds

5. Location of Release: (describe site of release at the facility or, if a transportation accident, the highway milepost, intersection or other appropriate identifier):

The release occurred from the Unrt 1 temocrary sodium hypochtonte storace tank. The l

l tank was located 10 ft south of the Unit 1 acid / chlorination buildino on a caved surface, Secondary containment was constructed around the tank, however due to existino holes in

! the containment 350 cations of the total 500 callons lost from the tank was released.

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i Eg.ILroduct flowed alona a crack in'the asohalt until reach;nc the cross swale alona the 2

gallerddoe of the aschsit. Followina the oath of:m==* r=*41=nce the crvduct flowed

. i alona tnis ;riva;a and intog culvert Travelina throuah the culvert the oroduct was halted at 1

its northem and by aviabna debris ano soil. Anoroxiirc :/120 c="-3ns of crcduct was

! Igggyaisd fruin the culvert {

i The release did not leave the Site nor did it reach naviaable waters.  !

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6. Data, time and duration of Release: '

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t Review of tank level lr#-ste6 revantari the rda=*a becan at 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br /> on November 1.1 j The W/c! did not druc enouah to trio low b/c! wamina at the Station. On Novarnber 2.199; 0618 hours0.00715 days <br />0.172 hours <br />0.00102 weeks <br />2.35149e-4 months <br /> the r;:::M was detected by Station cGrscenei cerformina scheduled rounds.

1, j

, 7. Release was into: Air Surface Water Sewer j

Ground X Highway Surface l
8. t Actions taken to respond to and contain the release, including the name of the any cleanup contractor: (provide complete description - use separete page if necessary): l initialResoonse:

The release was caused by a chemically inccracatible camlock Gibuc 2 -hed to the i

terncci v tank. To inninha the fittino and the leak. the valve uu= Loam of this ;Lic was cksed. Scucio and soill onde were "*ad to conta.n and redirect the flow as it exited the )

ggnd&cv containment A load of earth and stone was dumoed at the cavernent-arass i intoi!.co to 5100 flow to the crass area. The taroaulin dec+1 benesth the tank and wntaintnent durina construr+ian ar+ art as a oartial Wi-basin for Dicduct leakina throuah the s6condsiv containment Cleanuo and Restoration:

Lewis Envronmental was cciiirct+1 to perform the Gite cleanuo and restoration. Soill '

cais and bcurc= were deoloved to nhanrb the remainina free oroduct m!Mac in cracks and deuiessicas in f 9e Davement containment basin. taroaulin and cross.

Decontamination and removal of all free oroduct from the soill area was comoteted on 11/2/98. excludina the downstream culvert Containment was placed beneath the valve gnd__fittina to orevent further contaminant release. '

To orevent release to waterways and other non-contaminated areas due to rain or cataiuvchic tank failure. En earthen berm was constructed at the downstream end of the isis &5=. Lewis Environmental maintains 24 soill regoonse coverace.

i l On 11/3/98 excavation resumed an21 was ccir- 'M_-j :o a d+_,e of 6 irdie. m;cre the entire IMi of the soill fri4tinn oevement). Eve =vation armater than 6 inches haaan the

.itemoon of 11/3/98. SoR rernovalwas ana==d to cir-:22-1 at 3 to 6 Irich intervals due to Octone.i und.iciudnd interferences Soil cefor and cdvi w.,6 usad as inIr-s for hvDccleviii. cunion a,etlun. 20 a soil samnia= were tak a at inim-:L s d;,es and from the eE.V.uun side wai;. until coriterr; .r--i lavsis wie found to be <0.02 gurn residual 041.nt 1 I

The soill was found to tornii,iate at the end of a 50 ft culvert runnina u'sneem a site road.

l Initialcui,i nii,+E-:6 levels in the culvert were 740 seni r.;.edual c: M+it. L /.is

' Environn,.ni.; ouniu d suviumiir;___.'; 120 a. mans of crc-1.W ficr6 the culvert and .

' Deifviir+,d the first of three 300 annan water flushes throuah the oice. Contamination levels wie reduced to 37 Dem raaidual oxidant upon cviivMc6 of the initial fiush.

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i Excavation continued on the arass area on 11/4/98 and the cunt.minated Davern nt area i

was cut and Diec .d foravenvation later that day. Evenvation reached d+ "is uo to 21 inches in low-i#s cras. areas to achieve ccrit.niinst;un :e/d 've;cw 0.02 Dom resuual oxidant The south end of the culvert (una' ream) was aveav2t+1 to a Ocint w',ere fuimer excavation w

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_ould imbact the rcad anancvt and was h=Nad. Contamir+"- s 'r/d were k.ss than 1oom resMualc%.ntin this area. The north end of the culvert (downes ein)was excavst+1 the evorers of 11/5/98. Uoon removal of the soil and esu;i.;t. free rF-9_W was found at a deem of 10 inct . Evenvation continued around the face of the cioe and eventually i

exDcsed 16 irdies of the oice and to a depth of 14 lrdies. At this point cuni irai.Ucn levels %i found to be less than 1 com raaidus! ovident and the e:-:c2v.Lun was hM+1 l hio iced suascit in--1 l -

The second 9ush of the culvert was sceifunvied 11 AS/98. 300 as"-ws of water was oumoed into the south end of the culvert and coilacfad at the north end. The le. !s were reduced to 11 uu,ni Uualgx.jdgg., . q, The third and final flush inctndad a wash with 100 aalfons of a 5% sodium sulfite solutios, and iino with 200 cenans of wateron 11/5/98. Radium sul0te was used to neutralize any remainina sodium hvoochlorite solution. Contaminatian 'e. !s were raducad to <0.02 com I,esidual exidant. comoletino rerrM2We actmties in the culvert i

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I Asohalt removal continued at a width of 5 feet and death of 6-9 inches to where soil seine;.s c i.e back less than 0.02 com residual oxidant initially. low levels of contaminant dess than 15 Lar6 resuaal oxidant) were found in the pavement underiavers.

i BackflIlino coerations commanced immediatelv upon comotetion of samolina due to nuclear sofocaurd restrictions on ey::avation. Verbal aporoval was receive,d from the Pa

.DEP to backfill as documented in the a*=ched letter dated November 5.1998 from J.J.

Roaan.

The excavation and backfillina were completed on 11/6/98. Final aradina and recavina l gggations will be on-aoina.

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9. Any known or anticipated acute or chronic health risks associated with the release (describe in detail-if not approprate, state none):

4 Hone

10. Advice on medical attention for exposed individuals (if appropriate):

There were no iniuries or oersonnel emures as a result of this release.

~ . . .

^11 Actions to be taken to mitkjatepotential fi4ure incidents (describe in detail):

Intearity testina will be Deifemwd on all new or temoorary tanks. fines and containment systerrs Comoat:bility analyses will be oerformed on all new or temooraev systems and comucronts with reoard to chem;cd. ohv=W and environmental interferences.

THIS REPORT was prepared by the undersigned on behalf of the company or individual named in paragraph 1. The inicinWk,6 provided herein is true and correct to the best of my knowledge and belief. ., .

NOTE: If you have any :,oggestions about preparadon of this report, call the Pennsylvania Emergency Management Agency at (717) 783 7250 between 8am and 4pm Monday through Friday.

Prepared By:

(Name)

Plant Manager (Title or Position)

(610)718-2000 .

(Telephone Number) 11/13/98 (Date)

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