ML023520199

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Letter Informing That Pnpp Has Enlisted Nalco Chemical Company to Provide Replacement for the Scale Inhibitor Product Currently in Use in the Plant
ML023520199
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 12/11/2002
From: Hayes J
FirstEnergy Nuclear Operating Co
To:
Office of Nuclear Reactor Regulation, State of OH, Environmental Protection Agency
References
PY-CEI/OEPA-0388L
Download: ML023520199 (10)


Text

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FENOC Perry Nuclear Power Plant 10 Center Road Perry, Ohio 44081 James R. Hayes 440-280-7519 Manager- Radwaste, Environmental, Chemistry Fax: 440-280-5681 December 11, 2002 PY-CEI/OEPA-0388L

-Ohio Environmental Protection Agency Division of Surface Water P. O. Box 1049 Columbus, OH 43216-1049 Ladies and Gentlemen, The Perry Nuclear Power Plant (PNPP) has enlisted Nalco Chemical Company to provide a replacement for the scale inhibitor product currently in use in the plant Circulating Water (CW) system. The product currently in use for calcium scale control is Nalco DYNACOOL 1385, which was approved for use under Director's Final Findings and Orders on March 20, 1998. PNPP intends to replace the DYNACOOL 1385 with NALCO 23283 scale inhibitor/dispersant.

The chemical will be injected continuously into the suction forebay of the CW system to achieve a maximum concentration of 15 ppm NALCO 23283 and a 1.5 ppm active organic phosphate in the CW system. The discharge flow rate from the CW system is approximately 12,000 gpm. This combined with the minimum 24,000 gpm service water discharge flow rate at the plant discharge results in a discharge concentration of 5 ppm whole product and 0.5 ppm active phosphate residual.

Attachments 1 and 2 contain the information requested by Mr. Eric Nygaard of the Ohio Environmental Protection Agency during a telephone conversation on November 25, 2002. PNPP hopes to initiate this change in March and would appreciate a timely response to meet this goal. If you have any questions or require additional information, please contact Mr. Leo Harte at (440) 280-5514.

Very Truly Yours,

ýkýr d 0AW1' Attachments cc: OEPA Northeast District Office NRC Region III NRC Resident Inspector NRC Project Manager K,ý I NRC Document Control Desk (Docket No. 50-440)

Attachment 1 Information for Obtaining Approval for Cooling Water Additive

1. The name of the additive to be used and general product information.
a. The Material Safety Data Sheet (MSDS) is attached.
b. NALCO 23283 is a liquid phosphonate scale inhibitor and polymeric dispersant designed for scale inhibition and silt dispersion. The product is an aqueous solution of potassium phosphonate (11%) and acrylic polymer (11%).
c. 1-hydroxyethylidene-1, 1-diphosphonic acid (HEDP).
d. Calcium carbonate scale inhibitor.
e. No FIFRA or EPA ID number is applicable.
2. The concentration of the additive to be used (mg/i).
a. To be applied to the suction forebay of the Circulating Water (CW) pumps continuously.
b. To be applied to the suction forebay of the Circulating Water (CW) pumps continuously.
c. The application and feed system begins with a 3000 gallon bulk storage tank, constructed of high density cross linked polyethylene, and is in accordance with ASTM D1998-96. Flexible, reinforced tubing will connect the tank to a metered chemical feed pump system. The product will be fed through the tubing via floor penetrations into the suction forebay and a dilution water header. The circulating water system will be maintained at 15 ppm (mg/1) product and 1.5 ppm (mg/I) active phosphate. The system tank level, online concentration and a pump visual inspection are performed daily. A grab sample analysis and pump calibration check are performed weekly.
3. The expected concentration of the additive contained in the discharge or blowdown immediately prior to entering state surface waters.
a. Blowdown from CW system maximum - 12,000 gpm.

Service Water (SW) flow to the discharge average - 36,000 gpm, minimum - 24,000 gpm.

Dilution ratio 2:1 minimum, 3:1 average.

Effluent whole product concentration average - 3.75 ppm, maximum- 5 ppm.

Effluent active phosphonate concentration average - 0.38 ppm, maximum- 0.5 ppm.

Analytical limit for quantification for P =.01 ppm.

b. There will be no detoxification.
4. The average flowrate (MGD) and the outfall number of each outfall containing the additive.
a. The average flowrate from the discharge structure is 70 MGD (SW flow combined with CW flow) from outfall 31B00016004.
5. Name of the state surface water that receives the discharge.
a. Lake Erie receives the combined discharge.
6. Toxicity and environmental information.
a. 96-hour static acute LC50 to Rainbow Trout = >1000 mg/1.

48-hour static acute LC50 to Daphnia Magna = >1000 mg/1.

b. The n-octanol partitioning coefficient is not applicable for this product.

In the environment, the phosphonate ingredient reverts to orthophosphate and carbon dioxide and the acrylic polymer ingredient is absorbed to solids.

MATERIAL SAFETY DATA SHEET PRODUCT Nalco NALCO 23283 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC

11. 1CHEMICAL PRODUCT AND COMPANY IDENTIFICATION PRODUCT NAME: NALCO 23283 APPLICATION: COOLING WATER INHIBITOR COMPANY IDENTIFICATION: Ondeo Nalco Company Ondeo Nalco Center Naperville, Illinois 60563-1198 EMERGENCY TELEPHONE NUMBER(S): (800) 424-9300 (24 Hours) CHEMTREC NFPA 704M/HMIS RATING HEALTH: 0/1 FLAMMABILITY: 1/1 REACTIVITY: 0/0 OTHER:

0 = Insignificant 1 = Slight 2 = Moderate 3 = High 4 = Extreme

12. 1 COMPOSITIONIINFORMATION ON INGREDIENTS Based on our hazard evaluation, none of the substances in this produci are hazardous.
13. 1 HAZARDS IDENTIFICATION

"**EMERGENCY OVERVIEW**

CAUTION May cause irritation with prolonged contact.

Do not get in eyes, on skin, on clothing. Do not take internally. Wear suitable protective clothing. Keep container tightly closed. Flush affected area with water.

May evolve oxides of carbon (COx) under fire conditions.

PRIMARY ROUTES OF EXPOSURE:

Eye, Skin HUMAN HEALTH HAZARDS -ACUTE:

EYE CONTACT:

Can cause mild, short-lasting irritation.

SKIN CONTACT:

May cause irritation with prolonged contact.

INGESTION:

Not a likely route of exposure. No adverse effects expected.

INHALATION:

Not a likely route of exposure. No adverse effects expected.

Ondeo Nalco Company Ondeo Nalco Center

  • Naperville, Illinois 60563-1198 (630)305-1000 1/8

"i-o MATERIAL SAFETY DATA SHEET PRODUCT "o o Nalco NALCO 23283 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC SYMPTOMS OF EXPOSURE:

Acute :

A review of available data does not identify any symptoms from exposure not previously mentioned.

Chronic:

A review of available data does not identify any symptoms from exposure not previously mentioned.

AGGRAVATION OF EXISTING CONDITIONS:

A review of available data does not identify any worsening of existing conditions.

14. 1 FIRST AID MEASURES EYE CONTACT:

Flush affected area with water. If symptoms develop, seek medical advice.

SKIN CONTACT:

Flush affected area with water. If symptoms develop, seek medical advice.

INGESTION:

Do not induce vomiting without medical advice. If conscious, washout mouth and give water to drink. If symptoms develop, seek medical advice.

INHALATION:

Remove to fresh air, treat symptomatically. Ifsymptoms develop, seek medical advice.

NOTE TO PHYSICIAN:

Based on the individual reactions of the patient, the physician's judgement should be used to control symptoms and clinical condition.

15. 1 FIRE FIGHTING MEASURES FLASH POINT: > 212 OF/> 100 °C ( PMCC)

EXTINGUISHING MEDIA:

This product would not be expected to bum unless all the water is boiled away. The remaining organics may be ignitable. Use extinguishing media appropriate for surrounding fire.

FIRE AND EXPLOSION HAZARD:

May evolve oxides of carbon (COx) under fire conditions.

SPECIAL PROTECTIVE EQUIPMENT FOR FIRE FIGHTING:

In case of fire, wear a full face positive-pressure self contained breathing apparatus and protective suit.

16. 1ACCIDENTAL RELEASE MEASURES PERSONAL PRECAUTIONS:

Do not touch spilled material. Restrict access to area as appropriate until clean-up operations are complete. Use personal protective equipment recommended in Section 8 (Exposure Controls/Personal Protection). Stop or reduce any leaks if it is safe to do so. Ventilate spill area if possible.

Ondeo Nalco Company Ondeo Nalco Center* Naperville, Illinois 60563-1198 (630)305-1000 2/8

oMATERIAL SAFETY DATA SHEET SNaico NALCO 23283 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC METHODS FOR CLEANING UP:

SMALL SPILLS: Soak up spill with absorbent material. Place residues in a suitable, covered, properly labeled container. Wash affected area. LARGE SPILLS: Contain liquid using absorbent material, by digging trenches or by diking. Reclaim into recovery or salvage drums or tank truck for proper disposal. Contact an approved waste hauler for disposal of contaminated recovered material. Dispose of material in compliance with regulations indicated in Section 13 (Disposal Considerations).

ENVIRONMENTAL PRECAUTIONS:

Do not contaminate surface water.

17. 1HANDLING AND STORAGE HANDLING:

Avoid eye and skin contact. Do not take internally. Ensure all containers are labelled. Keep the containers closed when not in use.

STORAGE CONDITIONS:

Store the containers tightly closed.

18. 1 EXPOSURE CONTROLSIPERSONAL PROTECTION OCCUPATIONAL EXPOSURE LIMITS:

This product does not contain any substance that has an established exposure limit.

ENGINEERING MEASURES:

General ventilation is recommended.

RESPIRATORY PROTECTION:

Respiratory protection is not normally needed. FULL FACE RESPIRATOR MASK - YELLOW CARTRIDGE AND PREFILTER HAND PROTECTION:

Neoprene gloves, Nitrile gloves, Butyl gloves, PVC gloves NEOPRENE, NITRILE, NATURAL RUBBER OR PVC GLOVES, SLICKER SUIT, RUBBER BOOTS SKIN PROTECTION:

Wear standard protective clothing.

EYE PROTECTION:

SAFETY GLASSES Wear chemical splash goggles.

HYGIENE RECOMMENDATIONS:

Keep an eye wash fountain available. Keep a safety shower available Ifclothing is contaminated, remove clothing and thoroughly wash the affected area. Launder contaminated clothing before reuse.

Ondeo Nalco Company Ondeo Nalco Center

  • Naperville, Illinois 60563-1198 (630)305-1000 3/8

MATERIAL SAFETY DATA SHEET "Q-o PRODUCT ONDEO Naico NALCO 23283 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC HUMAN EXPOSURE CHARACTERIZATION:

Based on our recommended product application and personal protective equipment, the potential human exposure is:

Low

19. 1PHYSICAL AND CHEMICAL PROPERTIES PHYSICAL STATE Liquid APPEARANCE Light brown ODOR None SPECIFIC GRAVITY 1.18 @ 77°F/25°C SOLUBILITY IN WATER Complete pH (100 %) 4.5 FREEZING POINT 20 OF / -6.6 °C 110. 1STABILITY AND REACTIVITY STABILITY:

Stable under normal conditions.

HAZARDOUS POLYMERIZATION:

Hazardous polymerization will not occur.

CONDITIONS TO AVOID:

Freezing temperatures.

MATERIALS TO AVOID:

Contact with strong acids (e.g. sulfuric, phosphoric, nitric, hydrochloric, chromic, sulfonic) may generate heat, splattering or boiling and toxic vapors.

HAZARDOUS DECOMPOSITION PRODUCTS:

Under fire conditions: Oxides of carbon

11. 1TOXICOLOGICAL INFORMATION No toxicity studies have been conducted on this product.

CARCINOGENICITY:

None of the substances in this product are listed as carcinogens by the International Agency for Research on Cancer (IARC), the National Toxicology Program (NTP) or the American Conference of Governmental Industrial Hygienists (ACGIH).

HUMAN HAZARD CHARACTERIZATION:

Based on our hazard characterization, the potential human hazard is: Low Ondeo Nalco Company Ondeo Nalco Center- Naperville, Illinois 60563-1198 (630)305-1000 4/8

MATERIAL SAFETY DATA SHEET PRODUCT Oo*ONDEO Nalco NALCO 23283 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC

12. ECOLOGICAL INFORMATION ECOTOXICOLOGICAL EFFECTS:

The following results are for the product ACUTE FISH RESULTS:

Species Exposure LC50 Test Descriptor Rainbow Trout 96 hrs > 1,000 mg/I Product Sheepshead Minnow 96 hrs > 1,000 mg/I Product Rating: Essentially non-toxic ACUTE INVERTEBRATE RESULTS:

I Species I Exposure ILC50 EC50 I Test Descriptor Daphnia magna 48 hrs > 1,000 mg/i Product Rating : Essentially non-toxic ENVIRONMENTAL HAZARD AND EXPOSURE CHARACTERIZATION Based on our hazard characterization, the potential environmental hazard is: Low Based on our recommended product application and the product's characteristics, the potential environmental exposure is: Moderate If released into the environment, see CERCLAISUPERFUND in Section 15.

113. 1 DISPOSAL CONSIDERATIONS If this product becomes a waste, it is not a hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA) 40 CFR 261, since it does not have the characteristics of Subpart C, nor is it listed under Subpart D.

As a non-hazardous waste, it is not subject to federal regulation. Consult state or local regulation for any additional handling, treatment or disposal requirements. For disposal, contact a properly licensed waste treatment, storage, disposal or recycling facility.

114. 1TRANSPORT INFORMATION The information in this section is for reference only and should not take the place of a shipping paper (bill of lading) specific to an order. Please note that the proper Shipping Name / Hazard Class may vary by packaging, properties, and mode of transportation. Typical Proper Shipping Names for this product are:

LAND TRANSPORT:

Proper Shipping Name: PRODUCT IS NOT REGULATED DURING TRANSPORTATION AIR TRANSPORT (ICAO/IATA):

Proper Shipping Name: PRODUCT IS NOT REGULATED DURING TRANSPORTATION Ondeo Nalco Company Ondeo Nalco Center- Naperville, Illinois 60563-1198 (630)305-1000 5/8

MATERIAL SAFETY DATA SHEET

< 1 0NDEO PRODUCT Vo Nalco NALCO 23283 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC MARINE TRANSPORT (IMDG/IMO):

Proper Shipping Name: PRODUCT IS NOT REGULATED DURING TRANSPORTATION

15. REGULATORY INFORMATION NATIONAL REGULATIONS, USA:

OSHA HAZARD COMMUNICATION RULE, 29 CFR 1910.1200:

Based on our hazard evaluation, none of the substances in this product are hazardous.

CERCLA/SUPERFUND, 40 CFR 117,302:

Notification of spills of this product is not required.

SARA/SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986 (TITLE III) - SECTIONS 302, 311, 312, AND 313:

SECTION 302 - EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355):

This product does not contain substances listed in Appendix A and B as an Extremely Hazardous Substance.

SECTIONS 311 AND 312 - MATERIAL SAFETY DATA SHEET REQUIREMENTS (40 CFR 370):

Our hazard evaluation has found that this product is not hazardous under 29 CFR 1910.1200.

Under SARA 311 and 312, the EPA has established threshold quantities for the reporting of hazardous chemicals.

The current thresholds are: 500 pounds or the threshold planning quantity (TPQ), whichever is lower, for extremely hazardous substances and 10,000 pounds for all other hazardous chemicals.

SECTION 313 - LIST OF TOXIC CHEMICALS (40 CFR 372):

This product does not contain substances on the List of Toxic Chemicals.

TOXIC SUBSTANCES CONTROL ACT-(TSCA):

The substances in this preparation are included on or exempted from the TSCA 8(b) Inventory (40 CFR 710)

FEDERAL WATER POLLUTION CONTROL ACT, CLEAN WATER ACT, 40 CFR 401.15 / formerly Sec. 307,40 CFR

/ formerly Sec. 311 :

None of the substances are specifically listed in the regulation.

CLEAN AIR ACT, Sec. 111 (40 CFR 60, Volatile Organic Compounds), Sec. 112 (40 CFR 61, Hazardous Air Pollutants), Sec. 602 (40 CFR 82, Class I and II Ozone Depleting Substances):

None of the substances are specifically listed in the regulation.

CALIFORNIA PROPOSITION 65:

This product does not contain substances which require warning under California Proposition 65.

MICHIGAN CRITICAL MATERIALS:

None of the substances are specifically listed in the regulation.

Ondeo Nalco Company Ondeo Nalco Center ' Naperville, Illinois 60563-1198 (630)305-1000 6/8

Q OMATERIAL SAFETY DATA SHEET

< Ný DE ý,32160PRODUCT Nalco NALCO 23283 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC STATE RIGHT TO KNOW LAWS:

None of the substances are specifically listed in the regulation.

NATIONAL REGULATIONS, CANADA:

WORKPLACE HAZARDOUS MATERIALS INFORMATION SYSTEM (WHMIS):

This product has been classified in accordance with the hazard criteria of the Controlled Products Regulations (CPR) and the MSDS contains all the information required by the CPR.

WHMIS CLASSIFICATION:

Not considered a WHMIS controlled product.

CANADIAN ENVIRONMENTAL PROTECTION ACT (CEPA):

The substances in this preparation are listed on the Domestic Substances List (DSL), are exempt, or have been reported in accordance with the New Substances Notification Regulations.

116. 1OTHER INFORMATION Due to our commitment to Product Stewardship, we have evaluated the human and environmental hazards and exposures of this product. Based on our recommended use of this product, we have characterized the product's general risk. This information should provide assistance for your own risk management practices. We have evaluated our product's risk as follows:

"*The human risk is: Low

"*The environmental risk is: Low Any use inconsistent with our recommendations may affect the risk characterization. Our sales representative will assist you to determine ifyour product application is consistent with our recommendations. Together we can implement an appropriate risk management process.

This product material safety data sheet provides health and safety information. The product is to be used in applications consistent with our product literature. Individuals handling this product should be informed of the recommended safety precautions and should have access to this information. For any other uses, exposures should be evaluated so that appropriate handling practices and training programs can be established to insure safe workplace operations. Please consult your local sales representative for any further information.

REFERENCES Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices, American Conference of Governmental Industrial Hygienists, OH., (Ariel Insight# CD-ROM Version), Ariel Research Corp.,

Bethesda, MD.

Hazardous Substances Data Bank, National Library of Medicine, Bethesda, Maryland (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.

Ondeo Nalco Company Ondeo Nalco Center

  • Naperville, Illinois 60563-1198 (630)305-1000 7/8

MATERIAL SAFETY DATA SHEET Q0 PRODUCT DNDEO Na[co NALCO 23283 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC IARC Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to Man, Geneva: World Health Organization, International Agency for Research on Cancer.

Integrated Risk Information System, U.S. Environmental Protection Agency, Washington, D.C. (TOMES CPS#

CD-ROM Version), Micromedex, Inc., Englewood, CO.

Annual Report on Carcinogens, National Toxicology Program, U.S. Department of Health and Human Services, Public Health Service.

Title 29 Code of Federal Regulations, Part 1910, Subpart Z, Toxic and Hazardous Substances, Occupational Safety and Health Administration (OSHA), (Ariel Insight# CD-ROM Version), Ariet Research Corp., Bethesda, MD.

Registry of Toxic Effects of Chemical Substances, National Institute for Occupational Safety and Health, Cincinnati, OH, (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.

Ariel Insight# (An integrated guide to industrial chemicals covered under major regulatory and advisory programs),

North American Module, Western European Module, Chemical Inventories Module and the Generics Module (Ariel Insight# CD-ROM Version), Ariel Research Corp., Bethesda, MD.

The Teratogen Information System, University of Washington, Seattle, WA (TOMES CPS# CD-ROM Version),

Micromedex, Inc., Englewood, CO.

Prepared By: Product Safety Department Date issued: 08/08/2001 Ondeo Nalco Company Ondeo Nalco Center - Naperville, Illinois 60563-1198 (630)305-1000 8/8