SCH07-077, Discharge Confirmation Report

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Discharge Confirmation Report
ML071840494
Person / Time
Site: Salem  PSEG icon.png
Issue date: 06/25/2007
From: George Gellrich
Public Service Enterprise Group
To:
Office of Nuclear Reactor Regulation, State of NJ, Dept of Environmental Protection
References
FOIA/PA-2010-0209, NJDEP 07-05-24-0259-32, SCH07-077
Download: ML071840494 (27)
v • d • e


Text

PSEG Nuclear LLC P.O. Box 236, Hancock Bridge, NJ 08038-0236 0 PSEG NuclearLLC JUN 2 5 2007 SCH07-077 CERTIFIED MAIL RETURN RECEIPT REQUESTED ARTICLE NUMBER: 7006 0100 0004 0656 7468 Bureau of Discharge Prevention New Jersey Department of Environmental Protection 401 East State Street - P.O. Box 424 Trenton, New Jersey 08625-0424 Attention: Discharge Confirmation Reports RE: PSEG NUCLEAR LLC - SALEM GENERATING STATION NJDEP CASE NO. 07-05-24-0259-32 DISCHARGE CONFIRMATION REPORT In accordance with N.J.A.C. 7:1 E-5.8, PSEG Nuclear LLC ("PSEG Nuclear") is submitting the enclosed discharge confirmation report. This report describes the release of approximately 20,000 gallons of water containing Hydrazine from a catastrophic failure of the 24 Demineralizer Vessel sight glass from the condensate polisher system at Salem Unit 2. The discharge was reported to the New Jersey Department of Environmental Protection (NJDEP) hotline and assigned case number 07-05-24-0259-32. This discharge was also reported to the Nuclear Regulatory Commission pursuant to that agency's requirements.

The enclosed report contains the information as known at the time of this report. In accordance with the regulations, additional information regarding this discharge will be provided as it becomes available.

If you have any questions regarding this information, please contact Mr. Clifton Gibson of my staff at (856) 339-2686.

Sincerely, George H. Gellrich Salem Plant Manager

NJDEP SCH07-077 JUN 2 5 2007 Attachments (2)

C U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Mr. Jim Werner Salem County Department of Health 98 Market Street Salem, NJ 08079 2

NJDEP SCH07-077 DISCHARGE CONFIRMATION REPORT SALEM GENERATING STATION NJDEP Case No. 07-05-24-0259-31

1. Name, Address and Telephone Number of Individual Who Reported Mr. Robert Cordrey Operations Superintendent PSEG Nuclear LLC - Salem Generating Station P. 0. Box 236, M/C S01 Hancocks Bridge, New Jersey 08038 (856) 339-5200
2. Name, Address and Telephone Number of Person Submitting Report George H. Gellrich Salem Plant Manager PSEG Nuclear LLC - Salem Generating Station P. O. Box 236, M/C S07 Hancocks Bridge, New Jersey 08038 (856) 339-1740
3. Name, Address and Telephone Number of Owner/Operator of Facility Where Discharge Occurred PSEG Nuclear LLC P. O. Box 236 Hancocks Bridge, New Jersey 08038 (856) 339-2686
4. Source of Discharge, If Known On May 24, 2007 at approximately 0232 hours0.00269 days <br />0.0644 hours <br />3.835979e-4 weeks <br />8.8276e-5 months <br />, the operations control room was notified by a chemistry technician that several thousand gallons of condensate water, condensed steam, had discharged from #24 Condensate Polishing System Demineralizer Vessel (CPS-DMV) into the yard area east of the Unit 2 Condensate Polisher building. Using operator knowledge of the condensate water steam plant treatment chemicals (specifically Hydrazine) the spill was promptly reported through the NJDEP hotline. The cause of the discharge was a complete catastrophic failure of the 24 CPS-DMV upper sight glass due to stress risers in the glass.

3

NJDEP SCH07-077

5. Location of Discharge Name: PSEG Nuclear LLC - Salem Generating Station Street Address: Alloway Creek Neck Road Lot & Block: Lot 4.01, Block 26 Municipality: Lower Alloways Creek Township County: Salem County Zip Code: 08038-0236 Site Map: The location of the Salem Unit 2 Condensate Polisher Building is identified on the Site Map in Attachment A.
6. Common Name and CAS No. of Hazardous Substance Discharged Hydrazine, CAS No. 302-01-2 Ammonia, CAS No. 1336-21-6
7. Quantity of Hazardous Substances Discharaed The approximate volume of wastewater discharged is 20,000 gallons based upon flow rates and system pressure expected during the release. Based on normal concentrations of steam plant treatment chemicals in the system, the, maximum mass of hydrazine and ammonia in the 20,000 gallons is less than 9 grams of hydrazine and less 13 grams of ammonia. However, the condensate water discharged was approximately at a temperature of approximately 100 degrees F and under approximately 600 pounds pressure, releasing through the 7 inch sight glass area. The spray leaving the sight glass hole allowed degasification of the condensate water and a removal of a significant percentage of the hydrazine and ammonia to the atmosphere.
8. Date and Time Discharge Began, Was Discovered, Ended and Was Reported Case No.: 07-05-24-0259-32 Began: May 24, 2007 at approximately 0232 hours0.00269 days <br />0.0644 hours <br />3.835979e-4 weeks <br />8.8276e-5 months <br /> Discovered: May 24, 2007 at approximately 0235 hours0.00272 days <br />0.0653 hours <br />3.885582e-4 weeks <br />8.94175e-5 months <br /> Ended: May 24, 2007 at approximately 0250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> Reported: May 24, 2007 at approximately 0259 hours0.003 days <br />0.0719 hours <br />4.282407e-4 weeks <br />9.85495e-5 months <br />
9. Detailed Description of Containment, Cleanup and Removal Measures, Sumnmary of Costs Incurred Upon discovery of the spill, the chemistry technicians isolated the 24 DMV, while Salem Unit 2 reactor was being shut down by operations. Site Hazmat responders arrived at the scene to control the area and begin remediation.

Collection of some of the water was maintained in the storm drain system, which leads to DSN 489 of the Site NJPDES permit. Please see letter LR-E07-067 4

NJDEP SCH07-077 (copy included) which discusses the potential discharge to waters of the state.

In accordance with the PSEG Nuclear Discharge Prevention Containment and Countermeasure (DPCC) plan, hydrazine was neutralized in the area using a combination of hydrogen peroxide spray and solar effects (natural attenuation through UV decay) of the hydrazine. Due to the compaction of the engineered fill material on the site, minimal penetration into the surrounding soils occurred.

PSEG Nuclear has done a baseline cost estimate of man-hours (240) and equipment/materials ($160) for the spill cleanup. Contractor support for this cleanup event has totaled $3,600 to date. The total cleanup cost for this event was $3760, plus approximately $15,000 in station labor costs. The majority of the cost for this event is associated with the damage of plant equipment during the event and not the cleanup activities.

10. Corrective Actions,- Preventative Measures Several Preventive measures have been and are being taken to prevent reoccurrence. All sight glasses in the Unit 2 Condensate Polishing System Demineralizer Vessels were replaced before placing Unit 2 back in service. All similar sight glasses in the Salem Unit 1 Condensate Polishing System Demineralizer Vessels are currently being replaced. A new preventive maintenance action has been implemented to replace sight glasses whenever they are removed for maintenance. The 24 CPS-DMV sight glass was the original sight glass, placed into service in 1981 and had last been removed for maintenance work and reinstalled in May of 2002. A further review of potentially superior sight glasses is currently in progress.
11. Name, Address and Telephone Number of Cleanup Entities PSEG Nuclear LLC P. O. Box 236 Hancocks Bridge, New Jersey 08038-0236
12. Description of Sample Date, Type, Quantity and Location All of the following samples were taken and processed following the station's standard operating procedures. Samples were required to contain a minimum of 50ml per the station procedure.

Sample:

1) Oil Water Separator Outlet Time: 0850 on 5/24/07 pH: 7.61 Ammonia: Non-Detected <1 ppm Hydrazine: Non-Detected <1l0 ppb 5

NJDEP SCH07-077

2) Oil Water Separator Inlet Time: 0900 on 5/24/07 pH: 7.72 Ammonia: Non-Detected <1 ppm Hydrazine: Non-Detected <10 ppb
3) Skim Tank #1 Time: 0935 on 5/24/07 pH: 7.74 Ammonia: Non-Detected <1 ppm Hydrazine: Non-Detected <10 ppb
4) Skim Tank #2 Time: 0940 on 5/24/07 pH: 7.43 Ammonia: Non-Detected <1 ppm Hydrazine: Non-Detected <10 ppb
5) Storm Drain C1E Time: 0940 on 5/24/07 pH: 7.42 Ammonia: Non-Detected <1 ppm Hydrazine: Non-Detected <10 ppb
6) Storm Drain C1B Time: 0945 on 5/24/07 pH: 8.66 Ammonia: 2 ppm Hydrazine: 70 ppb
7) Storm Drain C1D Time: 1000 on 5/24/07 pH: 9.68 Ammonia: Non-Detected <1 ppm Hydrazine: Non-Detected <10 ppb
8) Storm Drain C1C Time: 1010 on 5/24/07 pH: 3.45 Ammonia: 10 ppm Hydrazine: 1 ppm
9) Puddle by Cafeteria Time: 1045 on 5/24/07 pH: 7.52 6

NJDEP SCH07-077 Ammonia: 3 ppm Hydrazine: 30 ppb

10) Switch Yard Ground Time: 1250 on 5/24/07 Ammonia: Non-Detected <1 ppm Hydrazine: 20 ppb
11) 2CPS Pipe Trench Time: 1410 on 5/24/07 pH: 9.65 Ammonia: Non-Detected <1 ppm Hydrazine: 20 ppb
12) Oil Water Separator Inlet Time: 0925 on 5/25/07 pH: 7.85 Ammonia: Non-Detected <1 ppm Hydrazine: Non-Detected <10 ppb
13) Storm Drain C1C Time: 1335 on 5/25/07 pH: 7.09 Ammonia: Non-Detected <1 ppm Hydrazine: Non-Detected <10 ppb
14) Storm Drain C1B Time: 1340 on 5/25/07 pH: 6.66 Ammonia: Non-Detected <1 ppm Hydrazine: Non-Detected <10 ppb
15) Switch Yard Ground Time: 1105 on 5/28/07 pH: 7.70 Ammonia: Non-Detected <1 ppm Hydrazine: Non-Detected <10 ppb
16) Switch Yard Ground Time: 1115 on 5/28/07 pH: 7.43 Ammonia: Non-Detected <1 ppm Hydrazine: Non-Detected <10 ppb 7

NJDEP SCH07-077

13. Certification of Financial Responsibility A copy of the Certification of Financial Responsibilities is included as Attachment C.
14. Supplemental Information Additional relevant information, if any, will be provided to the Department if and when it is discovered.
15. Any Additional Information Additional information will be provided upon request.
16. Certification The Certification of George H. Gellrich, Salem Plant Manager, is included as Attachment B hereto.

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NJDEP SCH07-077 A4 TTA CHMENT B1

NJDEP SCH07-077 PSEG Nuclear LLC -

Salem Generating Station Confirmation Report Certification as per NJAC 7:1 E-4.1 1(a)

I, George H. Gellrich, of full age, being duly sworn according to law, upon my oath depose and say:

1. I am the Salem Plant Manager for Salem Generating Station;
2. I certify under penalty of law that the information provided in this document is, to the best of my knowledge, true, accurate and complete.. I am aware that.there are significant civil and criminal penalties, including the possibility of fines or imprisonment or both, for submitting false, inaccurate or incomplete information.

George H. Gellrich Salem Plant Manager Salem Generating Station Sworn and subscribed before me this !'-- day of ..ih-. 2007.

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/ ~iUi ' ~'\-

SHERI L. HUSTON NOTARY PUBLIC OF NEW JERSEY My Commission Expires

NJDEP SCH07-077 A TTA CHMENT 0

Johi G. Y ajari, Jr. Office of Environrmental Counsel

!-s sistaril Genieral Environmrental CounEsel 80 Park Plaza, TME, Newark, NJ 07102 tel: 972.430.5506 fax: 973.8.02.1267 email: John.ValeriJr(copsag.corn April 25, 2007 0~ PfSEG Sr' (. 01 '

4N/}I('S r(C )

VIA FEDERAL EXPRESS Bureau of Release Prevention New Jersey Department of Environmental Protection Station Plaza 4 22 South Clinton Ave, 3 rd Floor - CN 424 Trenton, NJ 08625 Re: Financial Responsibility Documents PSEG Fossil LLC PSEG Nuclear LLC Ladies and Gentlemen:

Enclosed are an original and ten (10) copies of updated financial responsibility documents pursuant to N.J.A.C. 7: 1E-4.4. The enclosed documents include the Chief Financial Officer's Letter and a Guarantee executed by the President and Chief Operating Officer of PSEG Power LLC. Each specifies the eleven major facilities that are covered.

If you have any questions, please do not hesitate to contact me.

G. Valeri, Jr.

Enclosures

L ETTER FROM EXECUTI \VIE VICE TPRESIDENT AND C-lEF FINANCIAL OFFICER I am the Executive Vice President and Chief Financial Officer of PSEG Power LLC, f0 Park Plaza, P.O. Box 1171, Newarlk, New Jersey 07101-1171. This letter is inl support of theuse of the finamcial test of self-insurance and/or guarantee to demonstrate financial responsibility for cleanuLp and removal activities arising from operating:

Bergen Generating Station Victoria TerTace Ridgefield, New Jersey 07657; Hudson Generating Station Duffield & Van Keuren Avenues Jersey City, New Jersey 07306; Kearny Generating Station Foot of Hackensack Avenue Kearny, New Jersey 07032; Essex Generating Station 155 Raymond Boulevard Newark, New Jersey 07105; Linden Generating Station Grasselli Area of Wood Avenue South Linden, New Jersey 07036; Sewaren Generating Station 751 Cliff Road Sewaren, New Jersey 07077-1439; Edison Generating Station 164 Silver Lake Avenue Edison, New Jersey 08817; Mercer Generating Station Laniberton Road.

Trenton, New Jersey 08611; Burlington Generating Station W. Broad Street & Devlin Avenue Burlington, New Jersey 08016;

S al en Generatin g Station

.. Rl oad Foot of B*tto*..n..od P.O. Box 233 6 Hancocks Bridge, New hersey C1l0CB; and l-ope Creek Generating Station Foot of BLlttOnwood Road P.O. Box 236 Hancocks Bridge, New TJersey 0803S in the amountl of at least One Million Dollars ($1,000,000) per occurrence per facility, and Two Million Dollars ($2,000,000) anmual aggregate per facility.

A financial test is also used by this owner or operator to demonstrate evidence of financial responsibility in the following amounts under the following EPA or State ries or regulations (i.e., RCRA, ECPA, UST, etc.):

N/A This owner or operator has not received an adverse opinion, a disclaimer of opinion, or a going concern qualification flonm an independent auditor on his or her financial statements for the latest completed fiscal year.

ALTERNATJVE I (Millions)

1. Ainount of annual DCR aggregate coverage being assured by a financial test and/or guarantee $ )22
2. Amnount of anmual aggaregate coverage for all other Federal or State regulatory costs (i.e. RCRA, ECRA, UST, etc.) covered by a financial test, and/or guarantee $ 0
3. Sum of lines I and 2 $ 22
4. Total tangible assets S 8.069
5. Total liabilities [if any of the amount reported on line 3 is included in total liabilities, you may deduct that amount fioin this line and add that amount to line 6] S 4,723
6. Tangible net worth [subtract line 5 f-om line 4] $ 3,346

YES NO

7. Isfue 6 at least S1 0 million? N) --

S. Is line 6 alI east 10 times line 3? X

9. Have financial statements for the latefs fiscal year beeln filed withi the Securities Exchanee Commission? X _ __
10. H-lave financial statements for the latest fiscal year been filed with the Energy Inforniation Administration? ________

It. Have financial statements for the latest fiscal year been filed with the Ru-al Utilities Services or the Board of X Public Utilities?

12. Has financial inforination beenr provided to Dun and.

Bradstreet, and has Dun and Bradstreet provided a financial strength rating of 4A or 5A? [Anuswer Yes only if both criteria have been met] X I hereby certify that the wording of this letter is identical to the wording specified in Appendix B of N.J.A.C. 7: 1E. as such rules were constituted on the date shown inimruediately below.

Thomas M. O'Flymn /

Executive Vice Pre*i'dhnt and Chief Finaicial 1fcer Date: Aprih,5, 2007

G UAIUN TEE Guarantee made this April-5, 2007 by PSEG Power LLC, a business entity or0anized under the laws of the State of Delaware, herein referred to as guarantor, to the New ersey Department of Envir-onnental Protection ("Department") andto any and all third parties, and obliges, on behalf of its wholly owned operating subsidiaries, PSEG Fossil LLC, which operates the Bergen, Burlington, Essex, Edison, Hudson, Kearny, Linden, Mercer and Sewaren Generating Stations and PSEG Nuclear LLC, which operates Hope Creek and Salern GeneratJing Stations, both of 80 Park Plaza. Newark, New Jersey 07101.

(1) Guarantor meets or exceeds the financial test criteria of N.J.A.C. 7:1E-4.4(g) and agrees to comply with the requirements for guarantors as specified in N.J.A.C.

7: lE-4.4(h).

(2) PSEG Fossil LLC owns or operates the following major facilities covered by this guarantee:

Bergen Generating Station Victoria Terrace Ridgefield, New Jersey 07657; Hudson Generating Station Duffield & Van Keuren Avenues Jersey City, New Jersey 07306; Kearny Generating Station Foot of Hackensack Avenue Kearny, New Jersey 07032; Essex Generating Station 155 Raymnond Boulevard Newark, New Jersey 07105; Linden Generating Station Grasselli Area of Wood Avenue South Linden, New Jersey 07036; S ewaren Generating Station

751 Cliff Road Edison Generating Stat~ion 164 Silver- Lake Aven/ue

]Edison, New Jersey 08817; Mercer Geinerating Station Lamberton Road Trenton, New Jersey 08611; Burlington Generating Station W. Broad Street & Devlin Avenue

. Burlington"NeWJbrsey- 0801 6; . .

PSEG Nuclear owners or operates the following major facilities covered by this guarantees:

Salem Generating Station Foot of Buttonwood Road P.O. Box 236 Hancocks Bridge, New Jersey 08038; and Hope Creek Generating Station Foot of Buttonwood Road P.O. Box 236 Hancocks Bridge, New Jersey 08038 This guarantee satisfies the requirements of N.J.A.C. 7:1E-4.4 for assuring funding In the amount of $1,000,000 per occunrence per facility, and $2,000,000 amnual a-gg-egate per facility for cleanup and removal activities arising from operating the above identified major facilities.

(3) On behalf of our wholly owned operating subsidiaries, PSEG Fossil LLC and PSEG Nuclear LLC, guarantor guarantees to the Department and to any and all third parties that:

hn the event that PSEG Fossil LLC or PSEG Nuclear LLC fails to provide alternate coverage within 60 days after receipt of a notice of cancellati on of this guarantee and the Department has determined or suspects that a discharge has occurred at a facility covered by this guarantee, the guarantor, upon instructions from the Department, shall fund a standby trust fund in an amount sufficient to cover cleanup and renmroval costs, but not to exceed the coverage limits specified in N.J.A.C. 7:1E-4.4(b).

2

]n the everl that the Denariem determines that PSEG Fossil LLC or PSEG Nuclear LLC has failed to perform cleanup and remov'al activities aTIsing out of the operati on of the above-identi ied fadc] iii es, the cruaator, upon written instructions fiom the Department shall fu]d a standby trugi in an am o unt sLufficienit to cover cleanup and reimloval costs., but not to exceed the coverage limits specified above.

(4) Guarantor agrees that if, at the end of any fiscal year before cancellation of this guLaraintee. the guarantor fails to meet the financial test criteria of N.J.A.C- 7:1 E-4.4(g), guarantor shall send within 120 days of such failure, by certified mail, notice to PSEG Fossil LLC and PSEG Nuclear LLC and the Department The guarantee will terminate 120 days from the date of receipt of the notice by PSEG Fossil LLC and PSEG Nuclear LLC or 120 days from the date ofreceipt of the notice by the Department, whichever is later, as evidenced by the return receipt.

(5) Guarantor agrees to notify PSEG Fossil LLC and PSEG Nuclear LLC by certified mail of a voluntary or involuntary proceeding under Title 11 (Banlr-uptcy), U.S. Code, naming guarantor as debtor, within 10 days after conmnencement of the proceeding.

(6) Guarantor agrees to remain bound tunder this guarantee notwitlhstanding any modification or alternation of any obliaation of PSEG Fossil LLC or PSEG Nuclear LLC, pursuant to N.J.A.C. 7:1E.

(7) Guarantor agrees to remain bound under this guarantee for so long as PSEG Fossil LLC or PSEG Nuclear LLC must comnply with the applicable financial responsibility requirements of N.J.A.C. 7:1E-4.4 for the above-identified facilities, except that guarantor may cancel thiis guarantee by sending notice by certified mail to PSEG Fossil LLC and PSEG Nuclear LLC, and the Depart'ent, such cancellation to become effective no earlier than 120 days after receipt of such notice by PSEG Fossil LLC and PSEG Nuclear LLC or 120 days from the receipt of the notice by the Department, whichever is later, as evideniced by the return receipt.

(E) The guarantor's obligation does not apply to an), of the following:

(a) Any obligation of PSEG Fossil LLC or PSEG Nuclear LLC urnder a workers' compensation, disability benefits, or unemplo a*ienit compensation law or other similar law; (b) Bodily injury to an employee of PSEG Fossil LLC or PSEG Nuclear LLC arising from, and in the course of, eniployment by PSEG. Fossil LLC or PSEG Nuclear LLC.

(c) Bodily injury or property damage not related to a discharge arising fro1n1 the ownership, maintenance, use, or entlustmeint to others of any aircraft, motor vehicle, or watercraft; 3

(d) iProperty dama-ge to any property ownled, rented, loaiied to, I tile care, cu,,stod,,,, or control of. or occu-,ied by PSEG Fossil LLC or PSEC Nuclear LLC that is nol the cir-ect resuLt of a discharge frcn tihetflcI, (e) Boclchl damage or p.rojperty dalmage. ror whvich PSEG Fossil LLC ot PSEG ]Nuclear L.LC is obligated to pay damages by reason of the assumption of liability in a conltracl or agreemienl otherthlA a conUtract or agreement entered into to meetl the requiirements of N..AýC. 7: )E-4.4.

(9) Guarantor expressly waives notice of acceptance of this guarantee by the Departnmernt or by PSEG Fossil LLC or'PSEG Nuclear LLC.

I hereby cert-if\ that the wording of this guarantee is identical to the wording specilied in Appendix B of N.J.A.C. 7: ].E as such rules were constituted on the effective date shown muediately below.

Effective date: April 95 2007 PSEG Power LLC Frank Cassidy /

President and Chief Operating OfficN-Signature of wvitness or notary:l.

MARIA RODRIGO NOTARY PUBLIC OF NEW JERSEY My Commission Expires 5/4/2010 4

DEPARTMENT or-ENVIRoNvMENAL PROTECTION Go erno CB P.C . BoRe424 Trenton, N.J. 08625 Tel: (609) 633-0610 Fax: (609) 633-7031 G **Vj IR..RI, JOH-N GENERAL ENVI)RoMENT)

M2ASSISTANT May 1, 2007 John G. Valeri, Jr.

Assistant General Environmental Counsel PSEG Services Corporation 80 Park Plaza, TC5 Newark, NJ 07102 Re: Discharge Prevention, Containment and Countermeasure (DPCC) and Discharge Cleanup and Remova!

(DCR) Plans - Financial Responsibility for the following PSEG facilities:

Bergen Generating Station, Ridgefield Boro,. Bergen County, DIFF# 024900142000 Burlington Generating Station, Burlington Twp, Burlington County, DIFF# 030600142000 Hudson Generating Station, Jersey City, Hudson County, DIFF# 090601488000 Edison Generating Station, Edison Twp, Middlesex County, DIFF# 120501202000 Essex Generating Station, Newark City, Essex County, DIIF# 071401223000 Kearny Generating Station, Kearny Twp, Hudson County, DLF# 090700466000 Linden Generating Station, Linden City, Union County, DIFF# 200900820000 Mercer Generating Station, Hamilton Twp, Mercer County, DIFF# 110300168000 Sewaren Generating Station. Woodbridge Twp, Middlesex County, DT.F# 122501297000 Salem & Hope Creek Generating Station, Lower Alloways Creek, Salem County, DIFF# 170400041000

Dear Mr. Valeri,

Jr.:

Tlhank you for the financial responsibility document submittal, received April 26, 2007, for the above-identified facility.

Thiis updated financial document has been included in the department's copy of the DPCC/DCR plan for~the facility.

Since this document is part of an approved DPCC/DCR plan, this facility must also keep a copy on site at all timtes as required by N.J.A.C. 7: lE-4.6(g).

If you have any questions regarding this letter, please contact me at (609) 777-1329.

Respectfully,

/ 7 efiin'antor/

Principal Environmental Engineer Bureau of Release Prevention c: Beth S. Reddy, Chief, Engineering Review Section Priit Pals, Supervisor, Field Verification Section New, Jersev Is An Eount, ý;' -;. - -

NJDEP SCH07-077 BC Site Vice President - Salem Plant Manager - Salem Manager - Regulatory Assurance Manager - Salem Chemistry, Radwaste & Environmental General Environmental Counsel E. Keating NBS RM 64 File 2.1.1 Salem

PSEG Nuclear LLC P.O. Box 236, I-lancock Bridge, NJ 08038-0236 MAY2 9 200? OPSEG LR-E07-067 NTuiclear LLC Certified Mail Return Receipt Requested Article Number: 7006 0100 0004 0657 0307 Administrator of Water Compliance and Enforcement New Jersey Department of Environmental Protection 401 East State Street, 4th Floor East P0 Box 422 Trenton, New Jersey 08625-0422 RE: PSEG Nuclear LLC - Salem Generating Station NJPDES Permit No. NJ0005622 NJDEP Case No. 07-05-24-0259-31 Retraction of Report of Discharge to Waters of The State and Demonstration of Affirmative Defense of Unanticipated Bypass

Dear Sir/Madam:

In accordance with N.J.A.C. 7:14A-6.10 Noncompliance Reporting, PSEG Nuclear LLC (PSEG) is submitting this report to retract the notification of a possible discharge of water containing hydrazine to the Delaware River through lettered outfall 489, and, if additional information indicates appropriate, providing the bases for an affirmative defense for an unanticipated bypass. The possible discharge was reported to the New Jersey Department of Environmental Protection (NJDEP) hotline and assigned case number 07-05-24-0259-31. This possible discharge was also reported to the Nuclear Regulatory Commission and assigned event number 43382. This report contains information as known at the time of this report. In accordance with the regulations, additional information regarding this discharge will be provided as it becomes available. This report does not retract the discharge to land, PSEG is managing any release of hydrazine to the land in accordance with the approved Discharge Prevention Containment and Countermeasure (DPCC) Plan.

On May 2 4 th, 2007 at approximately 0232, a catastrophic failure of the upper sight glass on 24 Condensate Polisher System demineralizer vessel caused the shutdown of Salem Unit 2. Approximately 20,000 gallons of steam plant water (containing approximately 1 ppm hydrazine) were released outside of the Condensate Polisher building. At the time of the report it was believed that the hydrazine may have entered the stormwater drainage system and been discharged through the Salem Oil Water Separator, DSN 489, to the Delaware River. At 03"10 the Oil Water Separator (Discharge 489) was isolated to prevent or minimize any effluent discharge to the Delaware River. Subsequent sampling

MAY 29*2007 Administrator of Water Compliance and Enforcement LR-E06-0289 and analyses were performed demonstrating that no hydrazine was present in the Oil Water Separator main chamber or effluent chamber, therefore, NO

- hydrazine was-release to-theDelaware River. -Hydrazine which was discharged-to the land is being managed in accordance with the DPCC Plan.

PSEG continues to investigate this event, continues to sample and analyze sources and effluent points for hydrazine, and continues to collect information relative to this event. If additional information indicates appropriate, PSEG believes any water containing hydrazine later found released to the Delaware River from this event is an unanticipated bypass and is herein providing the bases for an affirmative defense for an unanticipated bypass. In accordance with N.J.A.C. 7:14A-6.10(f), the following information is provided:

" Since no hydrazine has been detected in any effluent to the Delaware River, no existing operating logs or other evidence is relevant at this time.

  • Steam plant condensate water, as well as any other secondary water that.

would contain hydrazine, is normally discharged through the Non-Radiological Liquid Waste Disposal System, DSN 48C, following treatment. The catastrophic failure of a component such as a sight glass that has maintained integrity for over 25 years is clearly unintentional.

" This was not a failure of the treatment system, rather, a failure of a component that cause untreated water to leave the system outside of the design configuration.

  • If there were a release of water containing hydrazine to the Delaware River, it would have occurred after 0232 on May 24, 2007. The NJDEP was notified on May 24 at 0259, well within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification requirement of the regulations.

" Although the Department did not specify any remedial measures upon notification, the appropriate remedial measures, including isolating the effluent point, were taken.

" If water containing hydrazine is later determined to have been released from the site, it would be due to the catastrophic failure of the sight glass in a pressure vessel and not a conscious decision of PSEG.

" Based on the information collected to date, PSEG believes it did collect any water containing hydrazine in the Oil Water Separator to avoid a release to the Delaware River.

" This event occurred during normal operation of relevant systems and components.

Although PSEG is retracting the notification of a release of hydrazine to the Delaware River, PSEG is concurrently providing the bases for an affirmative defense of an unanticipated bypass if addition information deems that defense appropriate. In accordance with the regulations, additional information regarding this will be provided as it becomes available.

2

Administrator of Water Compliance and Enforcement MAY 2 9 2007 LR-E06-0289 If you have any questions regarding .this information, please contact Clifton Gibson of my staff at (856) 339-12686.

ZSinc adrl'T . ricker Salem Plant Manager C NJDEP Southern Enforcement Office One Port Center 2 Riverside Drive, Suite 201 Camden, NJ 08102 Attn: Mr. Steven Mathis NJDEP Bureau of Point Source Permitting Region 2 401 East State Street Trenton, NJ 08625-0029 Attn: Ms. Susan Rosenwinkel U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Delaware Emergency Management Agency Attn.: Janet Chomiszak 165 Brick Store Landing Road Smyrna, DE 19977 3

Administrator of Water Compliance and Enforcement LR-E06-0289 MAY 2 9 2007 BC Site Vice President - Salem

.... Plant-Manager- Salem G. Suey W. Gamon Biggs Ed Keating Cliff Gibson SCH06-054 4

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