ML20248E592

Noncompliance Notification:Hydrazine Solution Discharged from Plant Through Outfall 002 Into Drainage Ditch at Plant Site.Number of Dead Fish Observed in Ditch.Ditch Dammed to Prevent Addl Matl from Leaving Plant Property

ML20248E592
Person / Time
Site:	Waterford
Issue date:	10/02/1989
From:	Mcgaha J LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
W3A89-0186, W3A89-186, NUDOCS 8910050326
Download: ML20248E592 (4)

Text

W .

.? .1-LOUISIANA P O W E R & - L i G H T / WATERFORD 3 SES

• P.O. BOX B + KILLONA, LA 700664751

$u$IysS$

W3A89-0186 A4.05 QA October 2, 1989 U.S.' Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, D.C. 20555

Subject:

Waterford 3 SES Docket No. 50-382' License No..NPF-38 Reporting of Licensee Event Report Gentlemen:

Attached is a copy of a " Notification of Unauthorized Discharge" for Waterford Steam Electric Station Unit 3. The copy of this report is submitted pursuant to Section 5.4.2 of the Environmental Protection Plan (nonradiological), Appendix B to Facility Operating Licensee No. 4 I

NPF-38.

Very truly yours, J.R. McGaha Plant Manager - Nuclear JRM/CRG/rk (w/ Attachment) cc Messrs. R.D. Martin J.T. Wheelock - INFO Records Center E.L. Blake W.M. Stevenson N, D.L. Wigginton NRC Resident Inspectors Office nt( hi ) f s <

, 3 Louisiama POWER & !.lGHT / INTER-OFFICE CORRESPONDENCE mum W3P89-1587 D.04 A4.06 QA October 2, 1989 Ms. Maureen O'Neill, Assistant Secretary Office of Water Resources Louisiana Department of Environmental Quality P. O. Box 44091, Capitol Station Baton Rouge, Louisiana 70804-4091

SUBJECT:

Waterford Steam Electric Station - Unit Number 3 Notification of Unauthorized Discharge

Dear Ms. O'Neill:

On September. 25, 1989, representative.es of Louisiana Power & Light Company's (LP'&L's) Waterford Steam Electric Station - Unit Number 3 (Waterford 3) telephoned your office to report an incident under Part 9.3.2 of the

" Notification Regulations and Procedures for Unauthorized Discharges" (Unauthorized Discharge Regulations). .Hydrazine (CAS number 302012) was released from Waterford 3 in a quantity greater than its reportable quantity of one (1) pound (40CFR302.4 and Part 5.16 of the Unauthorized Discharge Regulations). The notification was made at approximately 5:00 P.M. by the Waterford 3 Operations Shift Supervisor, Mr. A.E. Wemmett.

Telephone notifications'were also made to the National Response Center, Hazardous Materials Unit of the Louisiana State Police, St. Charles Parish Local Emergency Planning Committee, and the U.S. Nuclear Regulatory Commission. David Frazier from the Southeast Regional Office of the Water Pollution Control Division responded to our telephone notification on September 25, 1989, and visited Waterford 3 on September 26, 198% to assess the incident. Representatives of Waterford 3 also discussed the incident and remedial actions with Mr. Marion Fannaly of your office on September 27, 1989.

The hydrazine solution released from the Wate'rford 3 site was discharged through NPDES Outfall 002 into a drainage ditch on the plant site. The ditch continues on LP&L property for approximately one mile, then crosses under Louisiana Highway 3127. There is another ditch which parallels Highway 3127 on the south side of the highway, which after several hundred feet intersects with the 40 Arpent Canal, and eventually drains to Lake Des Allemands.

l "AN EQUAL OPPORTUNITY EMPLOYER"

. s P

W3P89-1587 Page 2 October 2, 1989 Hydrazine is used at Waterford 3 as a water treatment chemical. It is commonly used at power plants to reduce the oxygen concentration in closed piping systems. Usually, the chemical is present in trace quantities (parts per billion). However, when the plant goes into a lengthy outage,,

the concentration in the Condensate System is raised significantly, in this case, to approximately 210 parts per million (ppm).

When plant systems requiring drainage contain hign concentrations of chemicals, the systems should be drained to the low volume waste treatment system. However, on September 24, 1989, a portion of the Condensate System was drained into the Turbine Building floor drains. Outfall 002 receives this drainage as a component of its influent. Outfall 002 is characterized as receiving floor, equipment and stormwater drainage. Treatment is effected by an oil / water separator prior to release.

LP&L became aware of the release of the chemical on September 25, 1989, when contractor personnel notified Waterford 3 supervision that there were .

fish floating in the ditch passing through the construction yard.

Waterford 3 Chemistry technicians were dispatched to investigate the incident. They found a number of dead fish, and collected samples of the water in the ditch at various locations to determine what might have caused the fish kill.

Hydrazine was found to be present in the samples which were collected. The highest concentration of hydrazine was 162 ppm. A review of operations which had been conducted at Waterford 3 over the previous several days indicated that the most likely explanation for the hydrazine being present is as described above. LP&L conservatively estimates that a maximum of 261  !

pounds of hydrazine, at a maximum concentration of.210 ppm, were discharged into the onsite drainage ditch. This is based on the totalizer reading for l Outfall 002 from approximately 8:00 A.M. on September 24, 1989 to l approximately 4:00 P.M. on September 25, 1989, and the measured concentration of hydrazine in the Condensate System prior to the equipment drainage. The quantity of hydrazine actually leaving LP&L property is considerably less, as much of it was retained on company property, and dissipated as it traveled the length of the drainage ditch. Hydrazine reacts with oxygen both in the air and in the water, decomposing into nitrogen gas and water. No hydrazine has been detected in samples collected at the entrance to the 40 Arpent Canal.

l Remedial actions include immediate damming of the ditch as close as  !

possible to Highway 3127 to prevent additional material from leaving LP&L property. (LP&L also owns the property south of Highway 3127, but it is more readily accessible to the public.) The ditch was flooded with potable water for dilution and oxygenation, and the ditch has been further i oxygenated by using compressed air and recirculation pumps. The ditch is l

l

. ., g j W3PC9-1587 Page 3 October 2, 1989 being monitored several times a day at several locations to determine the ,

hydra::ine concentration. This effort began on September 25, 1989, with plans to continue until the hydrazine concentration was reduced to below 0.06 ppm (conservatively based on toxicological data), or rainwater forced l the water out. (Rainwater in sufficient quantity to force the water out would also sufficiently dilute and aerate the residual hydrazine so that there would be no offsite consequences.) The highest concentration of hydrazine is now less than the established 0.06 ppm, and the ditch has beewn clearsd of the fish.

This discharge was not in accordance with Waterford 3 Administrative procedures. Waterford ^, personnel, especially those involved with system operations and treatment of liquid effluents, are being made aware of this incident. In addition, the implementing procedures are being revised to

^

reflect the specific requirements of the administrative procedures. These actions should insure that a situation such as this will not occur again.

Should you have any questions or comments, please contact Ms. Chadi D.

Groome of our Nuclear Licensing & Regulatory Affairs Department at (504)-

595-2846.

Very truly yours.

N.

'J.R. McGaha cc: M.O. Knudson - EPA - Region VI R.D. Martin - NRC - Region IV F.J. Hebdon - NRC - NRR j J. Young - St. Charles Parish LEPC Louisiana State Police - Hazardous Materials Unit

_. _ ._ _ . _ _ ________ 0