SCH10-054, PSEG Nuclear LLC - Salem Generating Station NJDEP Case No. 10-0408-200307 Discharge Confirmation Report

PSEG Nuclear LLC - Salem Generating Station NJDEP Case No. 10-0408-200307 Discharge Confirmation Report

ML101310155
Person / Time
Site:	Salem
Issue date:	05/05/2010
From:	Eilola E Public Service Enterprise Group
To:	Office of Nuclear Reactor Regulation, State of NJ, Dept of Environmental Protection, State of NJ, Dept of Environmental Protection, Bureau of Coastal Mgmt
References
10-0408-200307, SCH10-054, FOIA/PA-2011-0113
Download: ML101310155 (20)

Text

cc: U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Bureau of Nuclear Engineering (BNE)

Attn: Ms. J. Lipoti 33 Arctic Parkway PO Box 415 Trenton, NJ 08625 NJDEP - Water Compliance and Enforcement Southern Water Enforcement Attn: Steven Mathis 2 Riverside Drive, Suite 201 Camden, NJ 08103 Lower Alloways Creek Township 501 Locust Island Road PO Box 157 Hancock's Bridge, NJ 08038 2

PSEG Nuclear L.L.C.

RO. Box 236, Hancocks Bridge, NJ 08302 SCH 10-054 0 P E May 05, 2010 NuclearL.L.C.

Certified Mail, Return Receipt Requested Article Number: 7008 0150 0000 5749 3065 Bureau of Discharge Prevention New Jersey Department of Environmental Protection 401 East State Street, PO Box 424 Trenton, New Jersey 08625-0424 Attention: Discharge Confirmation Report RE: PSEG Nuclear LLC - Salem Generating Station NJDEP Case No. 10-0408-200307 Discharge Confirmation Report

Dear Sir/Madam:

PSEG Nuclear LLC ("PSEG Nuclear") is submitting the enclosed voluntary discharge confirmation report. This incident was reported to the New Jersey Department of Environmental Protection (NJDEP) hotline and assigned case number 10-0408-200307 by Operator # 18.

By way of background, and as more fully explained in the attached report, this incident involved the potential discharge of tritium. The incident was also reported to the NRC and to the NJDEP-Bureau of Nuclear Engineering (BNE) pursuant to the site's Radiological Groundwater Protection Program (RGPP). Tritium is a radionuclide, and, pursuant to the Atomic Energy Act, is regulated exclusively by the NRC. Given the nature of the incident, the nature of the reports to both BNE and NRC are considered voluntary under both the RGPP and federal regulations.

PSEG Nuclear notes that NJDEP personnel have been actively involved in the investigatory process. We have enjoyed a cooperative working relationship with the NJDEP and will continue to keep NJDEP informed on a regular basis as the investigation proceeds.

If you have any questions regarding this information, please contact Ms. Christine Neely at 856-339-1844.

Sincerely, Ed Eilol Jr.

Plant Manger - Salem Attachments (4)

bc: Site Vice President - Salem Plant Manager - Salem NRC Resident Manager - Regulatory Assurance Manager - Salem Chemistry, Radwaste & Environmental H. Gregory L. Cataldo 1:3

VOLUNTARY DISCHARGE CONFIRMATION REPORT SALEM GENERATING STATION NJDEP Case No. 10-0408-200307

1. Name, Address and Telephone Number of Individual Who Reported;-

Mr. Thomas Byykkonen Operations Shift Manager PSEG Nuclear LLC - Salem Generating.Station Hancocks Bridge Road Lower Alloways Creek, New Jersey 08038 (856) 339-5200

2. Name, Address and Telephone Number of Person Submitting Report Mr. Mark Pyle

Title:

Manager Chemistry; Radwaste and Environmental PSEG Nuclear LLC - Salem Generating Station Hancocks Bridge Road Lower Alloways Creek, New Jersey 08038 (856) 339-2331

3. Name, Address and Telephone Number of Owner/Operator of Facility Where Discharge Occurred PSEG Nuclear LLC Hancocks Bridge Road Lower Alloways Creek, New Jersey 08038 (856) 339-5200

4. Source of Discharge, If Known On April 6, 2010 at approximately 2003 hours0.0232 days <br />0.556 hours <br />0.00331 weeks <br />7.621415e-4 months <br /> an onsite catch basin (CB) was sampled because there was a steam relief valve which lifted and released steam. The steam condensed, and had flowed across the ground to the CB. Upon sampling, positive/elevated levels of tritium were found.

The catch basin downstream of the initial sample was also positive for tritium. The manhole farthest downstream that discharges to the Delaware River was also sampled but no tritium above the BNE/NRC reporting threshold was found.

The discharge has been blocked however the initial influent and ultimate source of the elevated tritium is still under investigation.

4

5. Location of Discharge Name: PSEG Nuclear LLC - Salem Generating Station Street Address: Hancocks Bridge Road Lot & Block: Lot: 4.01 Block: 26 Municipality: Lower Alloways Creek County- Salem :. . - "- . .-.-

Site Map: The locations of the catchi'-basins are identified on the Site Map in Attachment B. - .

6. Common Name and CAS No. of-Hazardous Substance Discharged Radionuclides (Tritium) CAS# - n/a

7. Quantity of Hazardous Substances Discharged Unknown.

8. Date and Time Discharge Began; Was Discovered, Ended and Was Reported Case No.: 10-0408-200307 Began: Unknown Discovered: April 6, 2010 at approximately 0830 hours0.00961 days <br />0.231 hours <br />0.00137 weeks <br />3.15815e-4 months <br /> via initial sampling Ended: Still under investigation Reported: April 8, 2010' at approximately 2003 hours0.0232 days <br />0.556 hours <br />0.00331 weeks <br />7.621415e-4 months <br /> The report to the hotline was a courtesy notification and not a required 15-minute notification since tritium, a radionuclide, and, pursuant to the Atomic Energy Act, is regulated exclusively by the NRC. The NRC requirements for.- reporting tritium in our onsite system were followed and the incident was. also reported to the NRC and the NJDEP-Bureau of Nuclear Engineering (BNE) pursuant to the. site's 'Radiological Groundwater Protection Program (RGPP) monitoring and reporting requirements.

Specifically, PSEG Nuclear notified NRC on April 7th because levels of tritium were confirmed above the voluntary reporting threshold and an updated report was also made on April 8th. Accordingly, PSEG Nuclear notified NJDEP-BNE on April 7, 201.0.

5

9. Detailed Description of Containment, Cleanup and'Removal Measures, Summary of Costs Incurred Upon receipt of the initial sample result, a detailed sampling plan was initiated to include the catch basins and associated manholes to determine if the station was discharging tritium offsite. The catch basins/man holes. were plugged and kept isolated from those downstream. The plugs remain in place and the downstream discharge has been stopped. As of the date of this report, the initial source of tritium is still under investigation by a cross functional team, including engineers, station operators and environmental professionals.

There is also active participation and/or attendance by personnel from both the NJDEP and the NRC with status updates PSEG Nuclear continues to conduct investigation team meetings in which both new information and planned activities were discussed and explained. NJDEP and NRC have been invited to all of these meetings, and NJDEP has participated in the majority of those meetings. Again, NJDEP has been, and will continue to be invited to attend all of these meetings.

10. Corrective Actions - Preventative Measures PSEG Nuclear is investigating the incident and developing corrective actions in accordance with its NRC-mandated corrective action program under 10 CFR Part 50 Appendix B. Any report generated under the corrective action program will be provided to the NJDEP-BNE. In the interim, the catch basins have been isolated and blocked to prevent a discharge to the river.

11. Name, Address and Telephone Number of Cleanup Entities PSEG Nuclear LLC Hancocks Bridge Road Lower Alloways Creek, New Jersey 08038 (856) 339-5200

12. Description of Sample Date, Type, Quantity and Location Samples for tritium were collected per our project sampling plan and the RGPP at various locations within the onsite storm drain system. A number of new sampling wells have been drilled in response to this incident. As with all aspects of our response to this incident, NJDEP-BNE is actively involved in our sampling efforts and is receiving targeted split samples for analysis.

13. Certification of Financial Responsibility A copy of the Certification of Financial Responsibilities is included as Attachment C.

14. Supplemental Information None

15. Any Additional Information Additional information will be provided upon request.

16. Certification The.Certification is included as Attachment A..

7

TTA CHMENT A 8

PSEG Nuclear LLC -

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

I, Carl Fricker of full age, being duly sworn according to law, upon my oath depose and say:

1. I am the Site Vice President - Salem for PSEG Nuclear;

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.

Si* President - Salem

,/Virc Sworn and subscribed before me this

• day of May 2010.

SHERI L KEYES Commission # 2051967 Notary Public, State of New Jersey.-

My Commission Expires January 15, 2014 9

TTA CHMENT 10

Wi\

ck26 -

53.01 -

1)i-i* -

MATCH LINE ----

LEGEND .

a NOTES.

REFERENCES:

. t7 VýV. GENERAL SITE PLAN SALEM&HOPECREEK GENERATING STATIONS BLOCK 26

• LOTS 4, 4.01, 5 & 5.01 Shoot 1 03 P-E- NUCLEAR O --

IJ

t.

TTA CHMENT 11

Kieran Alexandra Brown Law Department Assistant General Environmental Counsel 80 Park Plaza, T5C, Newark, NJ 07102-4194 tel: 973.430.6124 fax: 973.802.1267 email: kieran.browvn@pseg.com 0 PSEG Selrvices ('o~porahlion April 27, 2010 VIA FEDERAL EXPRESS Bureau of Release Preventio i New Jersey Department of Environmental Protection Station Plaza 4 22 South NJ Trenton, Clinton 08625 Ave, 3rd Floor - CN 424 Re: Financial Responsibility Documents -..

PSEG Fossil LLC PSEG Nuclear LLC Ladies and Gentlemen:

Enclosed are an original and ten 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.

Sincerely, Kieran A. Brown Enclosures

GUARANTEE Guarantee made this April A."7, 2010 by PSEG P.ower LLC, a business entity organized under the laws of the State of Delaware, herein refen'rd to as guarantor, to the New Jersey Department of Enviromiental Protection ("Department") and to any and all third parties, and obligees, 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 Salem Generating Stations, of 80 Park Plaza, Newark, New Jersey Q71ý01.

(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.

7:1E-4.4(h).

(2) PSEG Fossil LLC, a wholly owned subsidiary of guarantor, 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 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 Lamberton Road Trenton, New Jersey 08611; and Burlington Generating Station W. Broad Street & Devlin Avenue Burlington;:New.Jersey 08016.'

PSEG Nuclear LLC, a wholly owned subsidiary of guarantor, operates the

" f6llowing m ajor facilities covered by this guarantee' Salem Generating Station Foot of Buttonwood Road P.O. Box 236- - * .

Hancocks Bridge, New Jersey 08038; and Hope Creek Generating Station Foot of Buttonwbod Road P.O.tBox 236 Hancocks Bridge, New Jersey 08038 This guarantee satisfies the requirements of N.JMA.C. 7:IE-4.4 for assuring funding in the amount of $1,000,000 per occurrence per facility and $2,000,000 annual aggegate 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:

In the event that PSEG Fossil LLC or PSEG Nuclear LLC fails to provide alternate coverage within 60 days after receipt of a notice of cancellation of this guarantee and the Department has'deternnined 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 removal costs, but not to exceed the coverage limits specified in N.J.A.C. 7:1 E-4.4(b).

Irn the event that the Department determines that PSEG Fossil LLC or PSEG Nuiclear LLC has failed to perform cleanup and removal activities 2

arising out of the operation of the above-identified facilities, the guarantor, upon written instructions from the Department, shall fund a standby trust in an amount sufficient to cover cleanup and removal 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 guarantee, the guarantor fails to meettthe financial test criteria of N.J.A.C. 7: IE-4.4(g), guarantor shall send within 120 days of such fail-re, by certified mail, notice to PSEG Fossil LLC and PSEG:Nuclear LLC andthe Department. The guarantee will terminate 120 days fromthedate of receipt of the notice by PSEG Fossil LLC and PSEG Nuclear LLC or 120 days from the date of rýceipt 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 II (Bankruptcy), U.S.

Code, naming guarantor as debtor, within 10 days after commencement of the proceeding.

(6) Guarantor agrees to remain bound under this guarantee notwithstanding any modification or alteration of any obligation 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 comply with the applicable financial responsibility requirements ofN.J.A.C. 7:1E-4.4 for the above-identified facilities, except that guarantor may cancel this guarantee by sending notice by certified mail to PSEG Fossil LLC and PSEG Nuclear LLC, and the Department, 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 date of receipt of the notice by the Department, whichever is later, as evidenced by the return receipt.

(8) The guarantor's obligation does not apply to any of the following:

(a) Any obligation of PSEG Fossil LLC or PSEG Nuclear LLC under a worker's compensation, disability benefits, or unemployment 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, employment by PSEG Fossil LLC or PSEG Nuclear LLC.

(c) Bodily injuly or property danage not related to a discharge arising from the ownership, maintenance, use, or entrustment to others of any aircraft, motor vehicle, or watercraft; (d) Property damage to any property owned, rented, loaned to, in the care, custody, or control of, or occupied by PSEG Fossil LLC or PSEG Nuclear LLC that is not the direct result of a discharge from the facility; 3

(e). Bodily damage or~property damage for wlhch PSEG Fossil LLC or PSEG Nuclear LLC is obligated to pay damages by reason of the assumption of liability in a contract oragreement other than a contract or agreement entered .into to'meet the requirements of N.J.A.C. 7: 1E-4.4.

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

-:I hereby certify that the wording of this guarantee is identical'to the wording specified in Appendix B of N.,.A.C. 7:1E as such rules-Were constituted on-the'effective date shown immediately below. .

Effective date: April X7 , 2010 PSEG Power LLC Williami Levis President and'Chief Operating Officer Signature of witness or notary*/____ ._ L_.." ....

SIAVOYVIIS 4

LETTER FROM EXECUTIVE VICE PRESIDENT AND CHIEF FINANCIAL OFrFICER I amn the Executive Vice President andChief Financial Officer of PSEG Power LLC, 80 Park Plaza, P.O. Box .1171, Newark, New Jersey 07101-1171. This letter is in support of the use of the financial test of self-insurance and-guarantee to: demonstrate financial responsibility for cleanup and removal activities arising from operating:

Bergen GeneratingStation:

Victoria Terrace Ridgefield, New Jersey:. 07657, Hudson Generating Station Duffield & Van Keuren Avenues Jersey City, New Jersey 07306; Keanly Generating Station Foot of Hackensack Avenue Keaniy, 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 Lamberton Road Trenton, New Jersey 08611; Burlington Generating Station W. Broad Street & Devlin Avenue Burlington, New Jersey 08016;

Salem Generating Station Foot of Buttonwood Road P.O. Box 236 Hancocks Bridge, New Jersey 08038; and Hope Creek Generating Station Foot.ofButionwood Road.

P.O.: Box 236".

Hancocks Bridge, New Jersey 08038 in the amount of at least One Million Dollars ($S1,000,000) per occurrence per facility, and Two Million Dollars ($2,000,000) annual 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 rules or regulations (i.e., RCRA, ECRA, UST, etc.):: -

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

ALTERNATIVE I (Millions)

1. Amount of annual DCR aggregate coverage -

being assured by a financial test and/or guarantee $ 22

2. Amount of annual aggregate 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 $ 10,203

5. Total liabilities [if any of the amiount reported on line 3 is included in total liabilities, you may deduct that anmount from this line and add that amount to line 6] $ 5,866

6. Tangible net worth [subtract line 5 from line 4] $ 4,337 YES NO

7. Is line 6 at least $10 million? X

8. Is line 6 at least 10 times line 3? X

9. Have financial statements for the latest fiscal year been filed with the Securities Exchange Commission? X

10. Have financial statements for the latest fiscal year been filed with the Energy Information Administration? X

11. Have financial statements for the latest fiscal year been filed with the Rural Utilities Services or the Board of Public Utilities? X

12. Has financial information been provided to Dun and Bradstreet, and has Dun and Bradstreet provided a financial strength rating of 4A or 5A? [Answer 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 immediately below.

Caroline Dorsa Executive Vice President and Chief Financial Officer Date: April Q7, 2010