L-2008-140, Wastewater Permit Number FL0001562, Request for Minor Revision Notification
| ML081910151 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 06/20/2008 |
| From: | Jefferson W Florida Power & Light Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| FL0001562, L-2008-140 | |
| Download: ML081910151 (9) | |
Text
JUN 2 0.2008 FPL L-2008-140 10 CFR 50.36 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555-0001 Re:
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Wastewater Permit Number FL0001562 Request for Minor Revision Notification In accordance with Section 3.2.3 of the Turkey Point Units 3 and 4 Environmental Protection Plan (Appendix B of Facility Operating Licenses DPR-31 and DPR-41), enclosed is a copy of the request to revise Wastewater Permit Number FLO0O 1562.
A minor revision to the Turkey Point Wastewater Permit is requested to change the currently approved GE chemicals utilized for process water treatment in Units 1, 2 and 5 plant operations, to equivalent Nalco products. Additionally, FPL requests approval for the use of PT-7000 monoethanolamine (MEA) as an alternative to 19% Ammonia in the Unit 5 Heat Recovery Steam Generators only. Pleasenote that the individual Material Safety Data Sheets (MSDS) for the Nalco products listed in page 1 of Attachment D of the permit revision application are not included in this transmittal.
Should there be any questions, please contact us.
Very truly yours, William Jefferson, Jr.
Vice President Turkey Point Nuclear Plant Enclosure cc:
Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant an FPL Group company
ENCLOSURE TO L-2008-140
Florida Power & Light Company, 700 Universe Blvd., Juno Beach, FL 33408 I=PL June 20, 2008 Mr. Bala Nori, P.E.
Industrial Wastewater Section Florida Department of Environmental Protection 2600 Blair Stone Road MS 3545 Tallahassee, FL 32399-2400 RE: Florida Power & Light Company Turkey Point Power Plant, Dade County NPDES Permit No. FL0001562 Minor Permit Revision Request: Chemical Vendor Change
Dear Mr. Nori:
Provided are the following items for FPL's minor revision request to the Turkey Point Plant Industrial Wastewater Permit. A minor revision is requested to allow for the replacement of chemical vendors and the associated exchange of equivalent products.
- 1. Three copies of DEP Form 62-620 910(9)- Wastewater Permit Minor Revision Application
- 2. Three copies of Attachments A: Project Summary
- 3. Three copies of Attachments B: Equivalent Products Letter from New Vendor
- 4. Three copies of Attachments C: Chemical Details Spreadsheet
- 5. Three copies of Attachments D: Chemical MSDS
- 6. FPL check payable to the Department for the $250 application fee.
FPL's Turkey Point Plant is planning to switch vendors that supply the process water treatment chemicals used in plant operations in order to reduce costs.
Your prompt attention to this request is appreciated. If you have any questions or need additional information please contact me at (561) 694-4022.
Sincerely, Andy Flajole Environmental Specialist Power Generation Division an FPL Group company
n APPLICATION FOR A MINOR REVISION TO A WASTEWATER FACILITY OR ACTIVITY
__FORA PERMIT
- 1. Instructions
- a. In accordance with Rule 62-620.325, F.A.C., this form must be submitted to the appropriate Department district office or approved local program when requests for minor revisions to a permit or minor modifications to a facility are made by a permittee, except for transfer of a permit to a new permittee and addition of a major user of reclaimed water to a Part III reuse system. Application for transfer of a permit to a new permittee shall be made on DEP Form 62-620.910(11). Application for addition of a major user of reclaimed water shall be made on DEP Form 62-610.300(4)(a)1.
- b. Each applicable item must be completed in full in order to avoid delay in processing of this form. Where attached sheets or other technical documentation are provided, indicate appropriate cross-references.
- c. Three (3) copies of this application with supporting documentation shall be submitted with this form.
- d. All information is to be typed or printed in ink. Dates are to be entered in MM!DD/YR format.
- e. This application and attachments shall be signed in accordance with Rule 62-620.305, F.A.C. Also, as applicable, this application and all attachments shall be signed and sealed by a professional engineer registered in Florida in accordance with Rule 62-620.310, F.A.C.
- 2. Facility Information
- a. Permit Number:
FL0001562
- b. Facility Identification Number:
FL0001562
- c. Project/Facility Name:
Turkey Point Power Plant
- d. Contact Name:
Mr. H.O. Nunez Number and Street:
9760 S.W. 344 Street City/State/Zip Code:
Florida City, FL 33035 Telephone (305) 242-3822
- 3. Type of Revision
[ Correct Typographical Errors' - Submit one copy of each page of the permit showing revisions being requested.
D Change Improvement Schedule' - Provide a description of the improvement, a list of the dates to be revised, and a reason for the proposed change in each date.
El Change Expiration Date of Permit' - Provide the current and proposed expiration dates for the permit and the reasons for the proposed change.
E] Change Staffing Requirements 2 - Describe the proposed change and submit justification for the change in accordance with Chapter 62-699, F.A.C.
A processing fee is not required.
DEP Form 62-620.910(9)
A processing fee is required with the application Effective October 23, 2000 in accordance with Rule 62-4.050, F.A.C.
E] Change Monitoring and Reporting Requirements 2 - Describe the proposed change and submit justification for the change in accordance with Chapter 62-601, F.AC.
El Modify Approved Pretreatment Program' - Describe the proposed modification and provide the information required by Rule 62-625.540, F.A.C.
El Delete Point Source Outfall1 - Identify the outfall and explain why the outfall is being eliminated.
El Modify or Expand Approved Residuals Land Application Sites2 - Attach a new or updated Agricultural Use or Dedicated Site Plan as required by Chapter 62-640, F.A.C.
[
Minor Modification to the Facility2 - Provide a description of the proposed modification. If applicable, attach any reports, plans, and specifications which have been developed to implement this modification.
El Other2 - Provide appropriate documentation. Describe.
- 4. Certifications
- a. Applicant or Authorized Representative I certify under penalty of law that I have personally examined and am familiar with the information submitted in this application and all attachments and that, based on my inquiry of persons immediately responsible for obtaining the information contained in the application, I believe that the information is true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of An ic prisonment p
(Signature of Applican rjuthorf Representative)
(Date)
(
Name (please type)
Mr. H.O. Nunez Title Plant General Manager Phone:
(305) 242-3822 Company Name Florida Power & Light Company Address:
9760 S.W. 344 Street City/State/Zip Code:
Florida City, FL 33035
- b. Professional Engineer Registered in Florida I certify that the engineering features of this project have been (designed) (examined) by me and found to conform to engineering principles applicable to such projects. In my professional judgement, this facility, when properly constructed, operated, and maintained, will comply with all applicable statutes of the State of Florida and rules of the Department.
A Name (please type):
Mr. Edward Preast Florida Registration Number:
33225 Company Name:
Florida Power & Light Company Address:
700 Universe Boulevard City/State/Zip Code:
Juno Beach, FL 33408 Phone Number:
(561) 691-2679 6dk4r-
'?J 00 (Seal, Signature, Date, and Registration Number)
'If signed by the authorized reprowtat1ve, attach a letter of eauthoriation In accordance Rule 62-620,305, FA.C.
2 DEP Form 62-620.910(9)
Efrective October 23, 2000
Florida Power & Light Turkey Point Plant Chemicals Minor Permit Revision Attachment A PROJECT
SUMMARY
Florida Power & Light Company (FPL) operates the Turkey Point Plant under NPDES Permit No. FLOO01562.
FPL's Turkey Point Plant is planning to switch vendors that supply the process water treatment chemicals used in plant operations in order to reduce costs. FPL is submitting information on the equivalent Nalco products will replace the current GE chemicals utilized for process water treatment as authorized under the current permit. In addition, FPL requests approval for the use of monoethanolamine (MEA) as an alternative to 19% Ammonia in the Heat Recovery Steam Generators (HRSGs) only.
Attachment B is a letter from Nalco stating that the proposed products are chemical equivalents to the GE commodities in use. There are 2 exceptions where the proposed chemicals are very similar, but due to the manufacturer's proprietary formulas cannot be declared equivalent: Nalco's Elimin-Ox and 3DT-187.
Nalco's Elimin-Ox is a 6.25% carbohydrazide product that FPL proposes to use instead of GE's Cortrol OS5007, a 7% hydrazine product.
According to the manufacturer, Elimin-Ox provides comparable equipment protection but is safer and more environmentally-friendly than standard hydrazine products.
Nalco's 3DT-187 is a dispersant and scale inhibitor that is a blend of two proprietary components: a tagged-HSP dispersant and the scale inhibitor phosphinosuccinic oligomer. FPL proposes to use 3DT-187 instead of GE's AEC3145 and AZ8104 products in the Cooling Tower.
FPL desires to use PT-7000 (monoethanolamine) as an alternative to the commodity chemical 19% Ammonia in the Boiler Feedwater. Use of PT-7000 (MEA) will provide similar protection to our HRSGs.
19% ammonia will still be used to protect other infrastructure at Turkey Point.
Attachment C is a spreadsheet providing details such as chemical names, dosages, etc. for all of the Nalco products. Attachment D consists of the MSDS for the Nalco equivalent products and the proposed new chemical monoethanolamine (PT-7000).
James W. Boak ATTACHMENT NA LCO Key Account Manager jboak@nalco.com January 28, 2008 Florida Power & Light Company 700 Universe Blvd Juno Beach, FL 33408 Attention: Mary Polk, Andy Flajole
Subject:
Nalco products for Turkey Point compared to GE products Per your request, we have completed analysis of the Nalco chemical products to be used at FPL's Turkey Point plant compared to the current GE chemical Products. As shown on the attached sheet, all the Nalco chemicals are equivalent to the GE chemicals except for three. The three exceptions are as follows:
Li Nalco's Elimin-Ox (6.25% carbohydrazide) replacing GE's Cortrol OS 5007 (7%
hydrazine) o Carbohydrazide (Elimin-Ox) is a much safer and less hazardous chemical than hydrazine o
Carbohydrazide also performs better than hydrazine in the steam cycle feedwater system passivating steel surfaces to minimize corrosion and iron/copper transport into the boiler.
L Nalco's 3DT187 replacing two GE's products, AEC3145 and AZ8104.
3DT187 contains the following:
o A dual function phosphonate inhibitor for both cathodic (pitting) corrosion and calcium carbonate scale inhibition. The active material is a patented, proprietary chemical called Phosphinosuccinic Oligomer (PSO).
o Phosphoric Acid for anodic corrosion inhibition o
A "tagged" organic High Stress Polymer (HSP) dispersant.
u Nalco's PT-7000 (monoethanolamine) replaces commodity 19% aqua ammonia as the neutralizing amine needed to elevate pH in the condensate and minimize corrosion.
o MEA has a much lower volatility compared to ammonia and therefore is more, effective in reducing corrosion in the steam cycle in areas of initial condensation.
If you have questions, please feel free to contact me at your earliest convenience.
Sincerely; Jim Boak Key Account Manager - FPL Corporate Offices o 1601 Diehl Road o Naperville, IL 60563-1198 o 630-305-1000 yeaarsof
Florida Power & Light Company, Street Address, City, State Zip 123-456-7890 FPL Attachment D Florida Power & Light Turkey Point Plant Chemicals Minor Permit Revision MSDS The following Nalco products' MSDS are included for FDEP's review:
- 1. 7357
- 2. 8322
- 3.
1336
- 4. 7330
- 5.
BT-3000
- 6. Y302104
- 7. Y302104
- 8.
PT-7000
- 9.
19H
- 10. Elimin-Ox
- 11. 1389
- 12. 1393
- 13. 3DT-187
- 14. 73286
- 15. 7468 Molybdate Molybdate/Tolytriazole Tolytriazole Isothiazoline Tri-Sodium Phosphate (Liquid)
Tri-Sodium Phosphate (Powder)
Ammonia (Aqueous)
Monethanolamine Hydrazine Carbohydrazide Dispersant (HSP)
Scale Inhibitor (HEDP)
Dispersant and Scale Inhibitor (HSP)
Corrosion Inhibitor Foam Control-Silicon Based an FPL Group company