ML20206R349

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NPDES Noncompliance Notification:On 981102,500 Gallons of 12% Sodium Hypochlorite Released to Environ.Caused by Failure of Tank Discharge Fittings & Subsequent Leaks from Secondary Containment.Culvert Was Flushed Repeatedly
ML20206R349
Person / Time
Site: Limerick Constellation icon.png
Issue date: 12/21/1998
From: Coyle W
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Miller H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 9901190273
Download: ML20206R349 (14)


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Lirnarick Genstating stitlan )

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EN RGY ecco c"e'av c e=" "v PO Box 2200 Sanatoga, PA 19464 0920 l

l December 21,1998 l

Mr. H. J. Miller Administrator, Region i U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406

Dear Mr. Miller:

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Per Umerick Generating Station - Unit 1 Technical Specifications, Docket Number 50-352, Appendix B

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

Pennsylvania State Agencies.  :

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 gations 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.

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

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

Sincerely,

/ /

' Will Coyle Environmental Compliance Manager cc:

l LGS Env File ,

W. Coyle '

M. Alphonso ,  %, p

T. Moore I

9901190273 DR 981221 P p ADOCK 05000352 i

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! , Limtri k Gener tlIg SL ti:n l . A w.

PECO ENERGY ;gl;;g c~"v Sanatoga. PA 19464 0920 November 13,1998 I

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! Ms. Donna Suevo PA Department of Environmental Protection Division of Storage Tanks Lee Park, Suite 6010 555 North Lane Conshohocken, PA 19428

Dear Ms. Suevo:

On November 2,1998 the Limerick Generating Station reported the relesse of an RO 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.1'1004 (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,

~

Michael P. Gallagher,  !

Plant Manager l MPG /AJF:ve cc: J. D. von Suskil W. J. Coyle M. J. Alfonso l J. J. Rogan l Environmental files 0

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1. '

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

Michael P. Gallaaher. Plant Manaaer Limerick Generatina Station Sanatoca. PA 19464 (610) 718-2000

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

Limerick Generatina Station Everareen and Sanatoaa Roads Sanatoaa. PA 19464 l (610) 718-2000

3. Date, time and location of the incident.

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

1998. The level did not droo enouah to trio the low level wamina at the Station. On l 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 personnel.

The release occurred from the Unit 1 temocrary sodium hvoochlorite storace tank. The tank was located 10 ft south of the Unit i acid / chlorination buildina on a caved sur' ace.

Secondary containment was constructed around the tank. however the containment allowed 350 callons of the total 500 callons 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 ofleast resistance the product flowed alona this swale and into a culvert. Travelina throuah the culvert the product was halted at its northem end by existina debris and soil. Acoroximately 120 callons of product was recovered from the culvert.

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

The incident was caused by an incomoatible fittina attached to the temocrary sodium hvoochlorite storace tank. The comoonent failed acoroximately 5 days after installation.

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 ecuates to 437 Dounds of sodium hvoochlorite (RQ = 100 pounds). The pH rance of i this materialis 10 to 12 deoendina on hydroxide concentration and aae.

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

There was no release to water or air.

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l Land contamination covered an sooroximate area of 250 ft in lenoth. 24 to 72 inches in width and UD to 24 inches deen. 75 feet of this area consisted of asphalt and was samoted and removed.125 feet of this area consisted arass and soil alona a swale and was samoted and removed. 50 feet of this area consisted of a 14 inch diameter culvert runnino 5 ft beneath a roadway. The culvert was flushed repeatedly and rinsed with a 5%

solution of sodium sulfite.

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

i 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 l disposed of as hazardous waste. All other solids are beina handled as residual wastes. l All liaulds were oumoed into the Unit 1 Coolina Tower to assist in alcal control durina the restoration of the sodium hvoochlorite iniection system. Under normal ooeratina conditions. 500 callons of sodium hvoochlorite is injected into the coolina tower daily.

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

1 intecrity testina will be performed on all new or temporary tanks lines and containment systems.

Comoatibility analyses will be performed on all new or temporary systems and comoonents with reaard to chemical. ohysical and environmental interferences, l

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I UmIritk CanIriting StstlIn )

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I PECO ENERGY ;gJ;;;co-,

sanatoga. PA 19464 0920 1

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I November 13,1998 '

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Mr. George Bartow  ;

Coordinator LEPC l Montgomery County Office of Emergency Preparedness l Eagleville Road i

Eagleville, PA 19403

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Dear Mr. Bartow-

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i- On November 2,1998 the Umerick Generating Station reported the release of an RQ for l sodium hypochlorite,, National Response Center Case Number 462231. The attached 14 day Follow-up Report is being sent to meet the requirements set forth in Section 304 (c) of l l 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)). 1 If you have any questions regarding this issue please contact Will Coyle, Acting l Environmental Compliance Manager at (610)718-2500.

Sincerely, h

Michael P. Gallagher Plant Manger MPG /AJF:ve cc: J. D. von Suskil W. J. Coyle M. J. Alfonso J. J. Rogan )

Environmental files

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

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l THIS REPORT has been prepared by or on behalf of the below-named company or 'l individual in order to provide emergency notification information about a hazardous material release l

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 Right-to-Know Act of 1986 (SARA Title til) (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)).

i RELEASE INFORMATION

1. Name of Company, Owner or Operator. l PECO ENERGY- Limerick Generatina Station
2. Address of Company, Owner or Operator:

Limerick Generatina Station Everareen and Sanatoaa Roads Sanatoaa Pa 19464

3. Chemical Name of Substance Released:

12.5% solution. Sodium Hvoochlorite

4. Quantity Released (LB):

437 counds 1 i

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

The release occurred from the Unit 1 temocrary sodium hvoochlorite storaae tank. The I

tank was located 10 ft south of the Unit 1 acid / chlorination buildina on a caved surface.

Secondary containment was constructed around the tank however due to existina holes in the containment 350 callons of the total 500 callons lost from the tank was released.

On 11/3/98 excavation resumed and was completed to a depth of 6 inches alona the entire lenoth of the soill(excludina pavement). Excavation areater than 6 inches beaan the aftemoon of 11/3/98. Soil removal was allowed to oroceed at 3 to 6 inch intervals due to potential underaround interferences. Soil color and odor were used as indicators for hvoochtonte contamination. 20 a soil samoles were taken at increasina depths and from the excavation side walIs until contamination levels were found to be <0.02 Dom 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 pumped approximately 120 callons of product from the culvert and -

performed the first of three 300 aallon water flushes through the Dioe. Contamination

'evels were reduced to 37 Dom residual oxidant upon comple+ ion of the initial flush.

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 uo to 21

~ inches in low-lyina crass areas to achieve contamination levels below 0.02 com residual oxidant The south end of the culvert (uostream) was excavated to a coint where further excavation would impact the road support and was halted. Contamination levels were less than 1oom residual oxidant in this area. The north end of the culvert (downstream) was excavated the evenina of 11/5/98. Upon removal of the soil and asphaft. free product was found at a deoth of 10 inches. Excavation continued around the face of the Dioe and eventually exposed 16 inches of the oice and to a deoth of 14 inches. At thh3 point contamination levels were found to be less than 1 com residual oxidant and tM emvation was halted '

due to road succort imoact The second flush of the culvert was performed 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 to 11 com residual oxidant The third and final flush included a wash with 100 callons of a 5% sodium sulfite solution and nnse with 200 callons of water on 11/6/98. Sodium sulfite was used to neutralize any remainina sodium hvoochlorite solution. Contamination levels were reduced to <0.02 com residual oxidant completina remediative activities in the culvert Asohalt removal continued at a width of 5 feet and deoth of 6-9 inches to where soil samples came back less than 0.02 com residual oxidant initially, low levels of contaminant (less than 15 com residual oxidant) were found in the Davement under1 avers.

Gackfillina operations commenced immediately upon completion of samplina due to nuclear safecaurd restrictions on excavation. Verbal acoroval 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 backfillina were como!eted on 11/6/98 Final aradina and recavina operations will be on-coina.

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s The product flowed alona a crack in the esohalt until reachina the arass swale alona the eastem edae of the asphalt. Following the oath ofleast resistance the product flowed alona this swale and into a culvert. Travelina throuah the culvert the product was halted at its northem end by existina debris and soil. Acoroximately 120 aallons of oroduct was recovered from the culvert. t The release did not leave the Site nor did it reach naviaable waters.

j 6. Date, time and duration of Release: -

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 /> on November 1.1998.

The level did not droo 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 personnel performina scheduled rounds.

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

] Ground X Highway Surface 1

8. Actions taken to respond to and contain the release, including the name of the any cleanup j contractor: (provide complete description - use separate page if necessary):
initial Response

l The release was caused by a chemically incomoatible camlock fittina attached to the a

temocrary tank. To isolate the fittina and the leak. the valve upstream of this fittina was closed. Booms and spill Dads were used to contain and redirect the flow as it exited the secondary containment. A load of earth and stone was dumped at the Davement-crass

) interface to stoo flow to the arass area. The tarpaulin placed beneath the tank and containment durina construction acted as a cartial catch-basin for product leakina throuah j the secondary containment.

s Cleanuo and Restoration:

1 Lewis Environmental was contracted to oerform the Site cleanuo and restoration. Spill

  • l Dads and booms were deployed to absorb the remainina free product collectina in cracks and deoressions in the Davement. containment basin. taroaulin and arass.

Decontamination and removal of all free product from the spill area was comoleted on 11/2/98, excludina the downstream culvert. Containment was placed beneath the valve and fittina to prevent further contaminant release. l i

To prevent release to waterways and other non-contaminated areas due to rain or i catastrophic tank failure. an earthen berm was constructed at the downstream end of the release. Lewis Environmental maintains 24 son 1 reAnonse coveraae.

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

N90s

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

There were no iniuries or oorsonnel exmsures as a result of this release.

11. Acbons to be taken to mrtigate pote'ntial future incidents (describe in detail):

Intearity testina will be Deifsiried on all new or temocrary tanks. lines and containment systems, Comoatibility analyses will be DeifDrivied on all new or terrariaiv systems and wimrrients with reaard to chervi,c l. ohysWI and envice ,ir,6atal interferences THIS REPORT was prepared by the undersgned on behalf of the company or individual named in paragraph 1. The information provKled herein is true and correct to the best of my knowledge and belief.

NOTE: If you have any suggestions about preparation of this repo? call the Pennsylvania Emergency Management Agency at (717) 783-7250 between 8am and 4pm Monday through Friday.

Prepared By: ' '

i (Name)'

Plant Manager (Title or Position)

(610)718-2000 (Telephone Number) 11/13/98 j (Date) l E __ _

Umirlik Ccn:ratin; StatlIn A

v. . l PECO ENERGY  ;;=J;;;c a "v l sanatoga. PA 19464-0920 November 13,1998 l

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Mr. Dick Rodney Commonwealth of Pennsylvania Pennsylvania Emergency Management Agency P.O. Box 3321 Hanisburg, Pa 17105

Dear Mr. Rodney:

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 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, Michael P. Gallagher Plant Manager MPG /AJF:ve cc: J. D. von Suskil W. J. Coyle M. J. Alfonso J. J. Rogan Environmental files

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PENNSYLVANIA EMERGENCY MANAGEMENT AGENCY P.O. BOX 3321 HARRISBURG,PA 17105 HAZARDOUS MATERIAL EMERGENCY NOTIFICATION REPORT THIS REPORT has been prepared by o'r 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 Secbon 304 (c) of the Emergency Planning and l

Community Right-to Know Act of 1986 (SARA Title fil) (42 U.S.C.11004 (c)) and Section 206 (d) of the Hazardous Material Err,ergercy Planning and Response,Act (35 P.S. 6022.206 (d)).

RELEASE INFORMATION

1. Name of Company, Owner or Operator:

PECO ENERGY- Limerick Generatino Station l

l 2. Address of Company, Owner or Operator:

\

i Limenck Generatina Station \

i i Evemreen and Sanatoaa Roads g, l Sanatoca. Pa 19464,,,

3. Chemical Name of Substance Released:

12.5% solution. Sodium HvDochlorite

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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 i temoorary sodium hvoochlorite storace tank. The tank was 's iod 10 ft south of the Unit 1 acid / chlorination buildina on a caved surface.

) Secondary containment was constructed around the tank, however due to existina holes in i .

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

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oroduct flowed alona a eneck in'the asonalt until readiirs the aross swale alona the n edae of the asahsit. Fodowma the D&Gi of';251 r--esrice the crvduct fic;;cd s;c6c this irr.!& and into a culvert. Tr ;c:.ia Oiivuoh the culvert the Dic-jtd was halted at its neitiorn and tw ex:+bic d=biis and soH. Aeuicxirn__.'; 120 c4"-ys of cr-ite was recovered frer6 the culvert l

The release did not leave the Site nor did it reach naviaable we'=r=.

6. Date, time and duration of Release:

~ Reviev* of tank level indica % re.dd the r 'm t+]an at 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br /> on Novoni The 'e c! did not dico enouah to trio low 'r/c! wamina at the SM-:-i. On Novernts 2.199 0618 hours0.00715 days <br />0.172 hours <br />0.00102 weeks <br />2.35149e-4 months <br /> the r:' a was de':ct+1 tw Swinn sersennel perfbrmina scieduled rounds.

7. Releasewas into: Air Surface Water Sewer l

Ground X Highway Surface l

l 8.

Acbons 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 Resoonse:

The release was e=uaad by a che.ii.iiv inccinu.Uble camlock CiGiic c--l ied to the ternuci rv tank. To +-lete the fittina and the leak. the valve t:ceb-sin of this 0;;na was dc ed Scene and soill n=ds were uaad to contain and red;i.ct the flow as it exM+1 the secer4.rv cuni inin-rit. A load of earth and stone was dun ,ed at the cr/c.neni-arass inteiform to stoo flow to the crass area. The taroaulin dr+3 benoani the tank and cuni.ininent durina constrtw*m me+ad as a cartial .Wi-teGi for Dic-ite leakina throuch the seccreo,v ccni.inment Cleanuo and Resturoi;ca:

Lewis Emrirciuiient.1 was cunLM+1 to perform the Site cleanuo and recic-abun. Soill cede and bOwn e v.Gre da'*>ved to ahaarb the remainina free Orc-jtd ce+:tna in cracks and doui s.; ens in the er c. rent. containment basin. tarpa_qlin and arass.

Decontamination and removal of all free product from the soill area was completed on 11/2/98. exdudiac the downstream culvert. Containment was olaced beneath the valve and ;"ec to orevent further contaminant release.

To orevent release to waterways and other non-contaminated areas due to rain or c L iivehic tank failure. an earthen berm was constructed at the downstream end of the release. Lewis Environmental maintains 24 soill resoonse coveraae.

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' On 11/5/98 excavation resumed and was cu ..C_E j to a death of 6 l aches al crc the entire lorsth of the soin (e:-@-@s Davement). Everation oraater thaa 6 incIss t+3an the

& Tera 006 of 11/3/98. Soil Terruval was afice.;d to 0,T-:==d at 3 to 6 inch intervals due to noteaGai undeiu,vond inteif.i.6c . Soil twiar and odor were u=ari as ir,1k=-s for hvDcclA,iito cGat.fi..;&:-i. 20 a soH s.,, _.:es were takea at incr asts decths and from the excavauva side war,. until contamination levels were found to be <0.02 oom residual oxidant i

! The soil was found to termnate at the end of a 50 ft culvert runnina beneath a site road.

Initial c.u,,i.ra;r.=G -i levels in the culvert were 740 Luin ros; dual 0:-ij+ai. Lewis

' Envircan .i.; ou6 wed asuiedri i iv 120 n="-:-is of oroduct from the cuhlert and .

l l Leifviir d the first of three 300 a*8an W -flushes throuah the DiDe. Contamination Sveh: wie reduced to 37 Dom residual avirient ucca ccr60l.dca of the initial flush.

Excavation continued on the crass area on 11/4/98 and the contaminated Davement area was cut and Dr s.i.d for;-:cevation later that day. Evrmation reacted d+:ths up to 21 inches in low-Mrs sr s areas to achieve contaminstk.,a !cyc!s bekyw 0.02 com residual

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l The south end of the culvert (va=*eam) was evr ava'ari to a coint where further e:-:cavation would irr.,.ct the road monaart and was baliari. CO ,;.fi. ation levels were less than inom residualcx;dantin this area. The north end of the culvert (down Gwam)was excavated the ;;a;,6 of 11/5/98. Uoon removal of the so# and asahalt. free Dic-jur4 was found at a douG, of 10 lacties. Everation continued around the face of the oice and eventually exposed 16 iaches of the nice and to a danth of 14 inches At this point contamination levels wie found to be less than 1 Dom rasiriue! oxidant and the excavation was halted l dee to road suecartinx+:1

! The second flush of the culvert was seifunied 11MP98. 300 aallons of water was oumoed into the south end of the culvert and c#+:t+1 at the north end. The levels were reduced to 11 com residualoxidant s.

i The third and final flush inrbia<4 a wash with 100 annans of a 5% sodium sulfite solution  !

and i;a.e with 200 aanons of water on 112/98. Sodium sulfite was "=a<4 to neutralize any rera.inina sodium hvDGctil66i soluton Cent i. ation k . 's were redtrari to <0.02 com residual cxki.at. ccinu;.G.,c rerr+14Gve actmties in the culvert AschMt removal continued at a width of 5 feet and deoth of 6-9 inches to where soil seinu; cons back fess than 0.02 com residual oxidant initially. Iow levels of contaminant l

Gess than 15 uum residual oxidant) were found in the cavement undertavers.  ;

Backfillina coerations commenced immediatelv uoon comoletion of samolina due to nuclear safecaurd restrictions on excavation. Verbal aooroval was received from the Pa DEP to backfin as documented in the attached letter dated November 5.1998 from J.J.

Rocan.

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The excavation and backfininn were comoleted on 115/98. Final aradina and recavina l Oceranens wiH be on-coina.

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9. ' Any kn' own or anticipated acute or clironic health risks maented with the release (describe in detail-if not appispin, state none):

None.

10. Advice on rnedical attention for aW individuals (if wupi;.i.):

There were no iniuries or oersonnel avar=ures as a r==ut of this r-'--- .

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"11. Actions to be taken to mitigate potential future inbdents (describe in detail):

)

Inteority testino win be D ifciT6.d on aN new or temocrary tanks. lines and containrnent systems, I

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.QO.Tiu ubii;tv analyses wHI be L.ifuri,,,,d on aR new or t&T,0viev systems and  !

wi iuvi, - with reoard to ct,&Ti.i. ohvairal and erwiiviiiii.in., interfererv==

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l l THIS REPORT was prepared by the undersigned on behalf of the company or individual l narned in paragraph 1. The infeiri uc6 pnuded herein is true and correct to the best of my knowledge and belief. .. .

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

Prepared By-(Name)

Plant Manager (Title or Position) l (610)718-2000

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(Telephone Number) 11/13/98 l (Date) 1 I

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