RA-18-0192, Notification to North Carolina Department of Environmental Quality

Notification to North Carolina Department of Environmental Quality

ML18281A011
Person / Time
Site:	Harris
Issue date:	10/08/2018
From:	Hamilton T Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
53590, RA-18-0192
Download: ML18281A011 (7)

Text

Tanya M. Hamilton

(_~ DUKE Vice President Harris Nuclear Plant ENERGY 5413 Shearon Harris Road New Hill, NC 27562 919.362.2502 October 8, 2018 Serial: RA-18-0192 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400/Renewed License No. NPF-63

Subject:

Notification to North Carolina Department of Environmental Quality Ladies and Gentlemen:

In accordance with Section 5.4 .2 of the Shearon Harris Nuclear Power Plant, Unit 1 (HNP},

Environmental Protection Plan (Nonradiological}, issued as Appendix B to the Renewed Facility Operating License No. NPF-63, Duke Energy Progress, LLC (Duke Energy), is providing a copy of the follow-up report submitted to the North Carolina Department of Environmental Quality (NCDEQ) related to the September 7, 2018, sodium hypochlorite spill reported in Event Notification #53590.

Duke Energy initially reported that the spill exceeded the 100-pound Reportable Quantity (RQ),

but further investigation has determined that the spill did not exceed this RQ, as explained in the attached report to NCDEQ. The difference between the value initially reported and the updated value is due to Duke Energy having used several conservative assumptions in the value reported to the National Response Center and NCDEQ the day of the spill. This value represented, at the time, the worst-case scenario of the spill. Once the incident ceased and the area was remediated, the calculation was performed again with more accurate values. The updated calculation shows that the volume of spilled product was less than the RQ, and the new value will be recorded internally.

If you have any questions or require additional information, please contact Jeff Robertson, Manager - Regulatory Affairs, at (919) 362-3137.

Sincerely, Tanya M. Hamilton Enclosure cc: J. Zeiler, NRC Senior Resident Inspector, HNP M. Barillas, NRC Project Manager, HNP C. Haney, NRC Regional Administrator, Region II

Tanya M. Hamilton Vice President Harris Nuclear Plant 5413 Shearon Harris Road New Hill, NC 27562 919.362.2502 October 8, 2018 Serial: RA-18-0192 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Shearon Harris Nuclear Power Plant, Unit 1 Docket No. 50-400/Renewed License No. NPF-63

Subject:

Notification to North Carolina Department of Environmental Quality Ladies and Gentlemen:

In accordance with Section 5.4.2 of the Shearon Harris Nuclear Power Plant, Unit 1 (HNP),

Environmental Protection Plan (Nonradiological), issued as Appendix B to the Renewed Facility Operating License No. NPF-63, Duke Energy Progress, LLC (Duke Energy), is providing a copy of the follow-up report submitted to the North Carolina Department of Environmental Quality (NCDEQ) related to the September 7, 2018, sodium hypochlorite spill reported in Event Notification #53590.

Duke Energy initially reported that the spill exceeded the 100-pound Reportable Quantity (RQ),

but further investigation has determined that the spill did not exceed this RQ, as explained in the attached report to NCDEQ. The difference between the value initially reported and the updated value is due to Duke Energy having used several conservative assumptions in the value reported to the National Response Center and NCDEQ the day of the spill. This value represented, at the time, the worst-case scenario of the spill. Once the incident ceased and the area was remediated, the calculation was performed again with more accurate values. The updated calculation shows that the volume of spilled product was less than the RQ, and the new value will be recorded internally.

If you have any questions or require additional information, please contact Jeff Robertson, Manager - Regulatory Affairs, at (919) 362-3137.

Sincerely, Tanya M. Hamilton Enclosure cc: J. Zeiler, NRC Senior Resident Inspector, HNP M. Barillas, NRC Project Manager, HNP C. Haney, NRC Regional Administrator, Region II

Document Control Desk Serial: RA-18-0192 Enclosure 1 Duke Energy Progress, LLC - Harris Nuclear Plant Follow-up Report Regarding Sodium Hypochlorite Spill - September 7, 2018 National Response Center Incident # 1223960 (5 pages including cover)

Tanya M. Hamilton

( ~ DUKE Vice President Harris Nuclear Plant ENERGY 5413 Shearon Harris Road New Hill, NC 27562 919.362.2502 October 5, 2018 Serial: RA-18-0186 John W. Walch Eastern Unit Supervisor, Waste Management North Carolina Department of Environmental Quality 1646 Mail Service Center Raleigh, NC 27699-1646

Subject:

Duke Energy Progress, LLC - Harris Nuclear Plant Follow-up Report Regarding Sodium Hypochlorite Spill - September 7, 2018 National Response Center Incident# 1223960

Dear Mr. Walch:

This letter follows the report made by Duke Energy Progress, LLC (Duke Energy), to the Department by phone on September 7, 2018, regarding a sodium hypochlorite spill at Harris Nuclear Plant. Duke Energy initially reported that the spill exceeded the 100-pound Reportable Quantity (RQ), but further investigation has determined that the spill did not exceed this RQ, as explained further below and in the attachment.

Although, in retrospect, reporting of the release was not required, Duke Energy is providing the attached report to assure the Department that the event was appropriately managed. This report contains the following:

• A site map locating the spill

• The narrative as to the incident - the cause and the chemical volume released

• The excavation dimensions

• The final disposition of the excavated material The difference between the value initially reported and the updated value is due to Duke Energy having used several conservative assumptions in the value reported to the National Response Center and Department of Environmental Quality the day of the spill. This value represented, at the time, the worst-case scenario of the spill. Once the incident ceased and the area was remediated, the calculation was performed again with more accurate values. The updated calculation shows that the volume of spilled product was less than the RQ, and the new value will be recorded internally.

If you should have any questions, please do not hesitate to contact Bob Wilson at 919-362-2444 (office), 919-714-3937 (mobile), or Bob.Wilson@duke-enerqy.com, or Robert Sapp at 980-373-7900 (office), 980-219-9990 (mobile), or Robert.Sapp@duke-enerqy.com .

Sincerely, O)OAD ~ ~~~

Tanya M. Hamilton

Serial: RA-18-0186 Attachment Report on September 7, 2018 Sodium Hypochlorite Spill at Harris Nuclear Plant Prepared by Duke Energy for the North Carolina Department of Environmental Quality, Division of Waste Management Site Map Showing Spill Location:

Serial: RA-18-0186 Attachment Narrative:

On September 7, 2018, at approximately 21:15 EDT, it was discovered that the Normal Service Water (NSW) Sodium Hypochlorite (NaOCl) injection line had become uncoupled, spilling some of the NaOCl solution from its 21:00 EDT injection cycle on the ground. The coupling was a double-ended male barbed fitting that joined two lengths of the injection tubing and was laid atop the Circulating Water (CW) basin curb (see image below). The approximate area affected by the spill was 8' x 50' or around 400 square feet. The spilled material was entirely contained on site and did not reach any jurisdictional surface waters.

The NSW injection pump operates on an automatically-timed schedule. Every 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (03:00, 09:00, 15:00, 21:00), the pump runs for a 25-minute interval, injecting approximately 75 gallons of NaOCl into the NSW pump inlet. The pump draws suction from either NaOCl Tank A or Tank B and is manually aligned to either tank. During the leak, the pump was aligned to the A tank.

At the time of the event, flow rate in the line was thought to be 4 gallons per minute (gpm). A test to better understand the flow rate was performed by Chemistry personnel on September 8, 2018. Flow through the NSW injection line was collected in a carboy over a 120-second interval.

Using this method, the flow was most nearly calculated as 3.0 gallons per minute.

The Certificate of Compliance (COC) provided by Oltrin Solutions states that, at the time of shipping, the NaOCl had a nominal concentration of 15%, with specific gravity of 1.215 g/ml.

However, NaOCl decomposes and loses potency when exposed to sunlight and air, so the solution that leaked onto the ground had a lower concentration than when it was delivered.

Chemistry personnel conducted a test of the Tank B solution on September 9, 2018, and determined that the solutions concentration was most nearly 14 wt%.

Other factors exist for which conservative assumptions were made that influence the total spilled solution weight. It is conservatively assumed that the coupling was detached at the beginning of the run time. In reality, it is more likely that the coupling became detached after the start of the cycle. Because these values are unknown, it is conservatively assumed that the line was spilling for the entirety of its 25-minute run time. Additionally, the flow test mentioned in this analysis was performed while the pump was aligned to Tank A with a level of approximately 4800/5500 gallons. At the time of the spill, the level in the tank was more nearly approximately 1800/5500 gallons. A lower level head in the tank at the time of the event could correlate to a lower flow rate than calculated in the test.

Serial: RA-18-0186 Attachment The test to determine chemical concentration was performed on Tank B. The NaOCl in Tank B was 5 days old at the time of the test. The NaOCl in Tank A at the time of the leak was 7 days old. Because both batches of NaOCl started with the same wt% of NaOCl, but solution in Tank A decomposed for 2 days longer than the tested solution, it is likely that the wt% of the leaked solution was lower than 14%.

Based on the details of the spilled NaOCl event that are discussed above, the quantity of NaOCl that spilled on the ground was conservatively calculated to be 96.66 lb. This value is lower than the estimate in the original report because it is calculated using smaller, but closer to actual, flow rate and chemical concentration and conservatively considers only 10% of the leakage being captured in the CW basin. The calculated mass of NaOCl that spilled on the ground on September 7, 2018, is less than the 100 lb. RQ.

Excavation Dimensions and Final Disposition:

The whole area (8' x 50') was excavated until no more wetted soil was observed. The excavated soil was placed into two roll-off containers to be disposed of off-site by Shamrock Environmental Services. Approximate volume was 20 cubic yards. The roll-offs are currently awaiting Waste Industries approval and transportation to the facility by Shamrock Environmental Services.