ML042390457

Spray Pond Dredging

ML042390457
Person / Time
Site:	Limerick
Issue date:	08/18/2004
From:	Bryan Hanson Exelon Nuclear
To:	Fields J Office of Nuclear Reactor Regulation, State of PA, Dept of Environmental Protection, Bureau of Water Quality Management
References
PA00051926
Download: ML042390457 (16)

Text

Exekln..

Exelon Nuclear www.exeloncorp.com Nuclear Limerick Generating Station P.O. Box 2300 Sanatoga, PA 19464 NPDES Permit August 18, 2004 Ms. Jennifer Fields, P.E.

Chief, Permits Section Water Management Program Department of Environmental Protection 2 East Main Street Norristown, PA 19401 Limerick Generatinq Station Industrial Waste NPDES Permit # PA00051926

Subject:

Spray Pond Dredging

Dear Ms. Fields:

Limerick Generating Station (LGS) is planning to dredge the site spray pond, a 30 million gallon volume of water covering approximately 9.6 acres. This process, depicted in Attachment 1, will utilize a flow driven vacuum device to transfer water and entrained sludge to a settling basin, where, after a nominal hold time, the solids will settle out and be contained. The settling process may be augmented with a polymeric flocculent, which would be introduced at a mixing station prior to sludge deposition in the basin, in an expected dosage range of 25-50 ppm.

MSDS sheets for Cytec SD2065, and toxicity data for similar polymers are included in. The clarified water component will then be pumped either to the Unit I Cooling Tower blowdown weir, with discharge ultimately through Outfall 001 in the Schuylkill River, or back to the Spray Pond.

The following tabulation is a comprehensive list of chemicals that are added to the Spray Pond, along with the respective concentration of each:

Chemical Purpose Concentration as Product Depositrol BL5307 scale / corrosion inhibitor 68.2 - 81.8 PPM Spectrus CT1300 biocide 0.35 PPM AZ8104 copper corrosion inhibitor 4.2 - 8.3 PPM Aquashade algae growth inhibitor 0.5-1.0 PPM provides a chemical composition summary relating to expected water quality of the clarified water component.

Through this correspondence, LGS is requesting authorization to transfer the dredging process decanted water phase from the setting basin, to either Outfall 001 via the Unit I Cooling Tower blowdown weir, or back to the Spray Pond.

Should you have questions regarding this matter, please contact Mr. Robert Alejnikov of my staff at (610) 718-2513. Thank you for your cooperation in this matter.

call

Sincerely; Bryan C. Hanson Plant Manager-LGS. Spray Pond Dredging Process

2. MSDS sheets for Cytec SD2065 and toxicity data for similar polymers

3. Chemical Composition Summary cc:

USNRC Document Control Desk S. Collins, USNRC Region 1 Administrator S. Hansell, USNRC Resident Inspector-LGS

bcc: R. DeGregorio - GML 5-1 B. Hanson - GML 5-1 R. Newmaster - SSB 2-4 R. Alejnikov - SSB 2-4 T. Seglin - KSA N. Chand - SSB 3-3 D. Doran - SSB 3-3 K. Kemper - SSB 2-4 J. Toro - SSB 4-2 D. Dyckman - PABRP - SSB 2-4 L. Knapp - SSB 2-2

ATTACHMENT 1 COOLING 6" RETURN PIPING TO THE COOUNG TOWER DISCHARGE BASIN IMSSB DRY PRIIEPU MP as.a "wA

ATTACHMENT 1 DECANTING PLAN

ATTACHMENT 2 Page 1 of 6 CYTEE CMSDS No: 09084 L~fTECDate:

01/03/202 MATERIAL SAFETY DATA Supersedes.

01/21/1999

1. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION PRODUCT NAME:

SUPERFLOCD SD-2065 Flocculant SYNONYMS:

None CHEMICAL FAMILY:

Liquid Catlonic Polyacrylamide MOLECULAR FORMULA:

Mixture MOLECULAR WGT: Mixture CYTEC INDUSTRIES INC., FIVE GARRET MOUNTAIN PLAZA, WEST PATERSON, NEW JERSEY 07424, USA For Product Information call 1-800/652-8013. Outside the USA and Canada call 1-973/357-3193.

EMERGENCY PHONE: For emergency Involving spill leak, fire, exposure or accident call CHEMTREC:

1-800/424-9300. Outside the USA and Canada call 1-7031527-3887.

2. COMPOSITIONANFORMATION ON INGREDIENTS OSHA REGULATED COMPONENTS COMPONENT CAS. NO.

TWA/CEILING REFERENCE Petroleum distillate 06474247-8 18.0-23.0 500 ppm OSHA hydrotreated light 165 ppm Supplier Isopropanol 000067-63-0 0-0.5 400 ppm OSHA/ACGIH 500 pprn STEL ACGIH

3. HAZARDS IDENTIFICATION EMERGENCY OVERVIEW APPEARANCE AND ODOR: Off-white, translucent liquid; hydrocarbon odor.

STATEMENTS OF HAZARD:

WARNINGI CAUSES SKIN IRRITATION MAY CAUSE EYE IRRiTATION POTENTIAL HEALTH EFFECTS EFFECTS OF OVEREXPOSURE:

The estimated acute oral (rat) LD50, acute dermal (rabbit) LD50 and 4-hour Inhalation (rat) LC50 values for this material are >5,000 mgtkg, >2,000 mg/kg and >20 mglL, respectively.

Direct contact with this material can cause moderate skin and mid eye Irritation.

Overexposure to vapors may cause Irritatlon of the respiratory tract and eyes and may cause central nervous system effects.

Refer to Section I1 for toxicology information on the regulated components of this product.

4. FIRST AID MEASURES Material Is not expected to be harmful by Ingestion. No specific first aid measures are required.

In case of skin contact, remove contaminated clothing without delay. Flush sidn thoroughly with water. Do not reuse clothing without laundering. Get medical attention If pain or Irritation persists after washing or I signs and symptoms of overexposure appear.

In case of eye contact, immediately Irrigate with plenty of water for 15 minutes If vapor or dust of this material Is Inhaled, remove from exposure. Administer oxygen If there Is difficulty In breathing. Obtain medical attention Immediately if necessary.

ATTACHMENT 2 SUPERFLOC0 SD-2065 Focculant MSDS No: 09084 Date: 01/03/2002 Page 2 of 6

5. FIRE FIGHTING MEASURES FLAMMABLE PROPERTIES FLASH POINT: >212 F; 100C METHOD:

Closed Cup FLAMMABLE LIMITS

(% BY VOL):

Not available AUTOIGNITION TEMP:

Not available DECOMPOSITION TEMP:

Not available EXTINGUISHING MEDIA AND FIRE FIGHTING INSTRUCTIONS Use water spray, carbon dioxide or dry chemical to extinguish fires. Use water to keep containers cool.

Wear self-contained, positive pressure breathing apparatus and full fire-fighting protective clothing. See Section 8 (Exposure Controls/Personal Protection) for special protective clothing.

6. ACCIDENTAL RELEASE MEASURES STEPS TO BE TAKEN IN CASE MATERIAL IS RELEASED OR SPILLED Where exposure level is not known, wear NIOSH approved positive pressure self-contained respirator. Where exposure level Is known, wear NIOSH approved respirator suitable for level of exposure. In addition to the protective clothing/equipment In Section 8 (Exposure Controls/Personal Protection), wear rain suit. Spills of this product are very slippery. Spilled material should be absorbed onto an inert material and scooped up. The area should be thoroughly flushed with water and scrubbed to remove residue. If slipperiness remains, apply more dry-sweeping compound.

7. HANDLING AND STORAGE Avoid contact with eyes, skin, and clothing. Wash thoroughly after handing.

To avoid product degradation and equipment corrosion, do not use iron, copper or aluminum containers or equipment.

OSHA regulations (29 CFR 106.a.14), require that the flashpoint of materials of this type be determined by the Pensky-Martens Closed Tester method. The test for this product Indicates it has a flashpoint greater than 200F (93.3C). Although there was no flashpolnt detected below 200F (93.3C) by the Pensky-Martens Closed Tester method, some flammable vapors were evolved during the test as evidenced by the enlargement of the test flame; therefore, caution should be exercised in storage and handling.

8. EXPOSURE CONTROLS/PERSONAL PROTECTION ENGINEERING CONTROLS AND PERSONAL PROTECTIVE EQUIPMENT (PPE)

Where this material Is not used In a closed system, good enclosure and local exhaust ventilation should be provided to control exposure. Food, beverages, and tobacco products should not be carried, stored, or consumed where this material is In use. Before eating, drinking, or smoking, wash face and hands with soap and water. Avoid skin contact. Protective clothing such as Impervious gloves, apron, workpants, long sleeve work shirt, or disposable coveralls are recommended to prevent skin contact. For operations where eye or face contact can occur, wear eye protection such as chemical splash proof goggles or face shield. Eyewash equipment and safety shower should be provided In areas of potential exposure. Where exposures are below the Permissible Exposure Limit (PEL), no respiratory protection is required. Where exposures exceed the PEL, use respirator approved by NIOSH for the material and level of exposure. See "GUIDE TO INDUSTRIAL RESPIRATORY PROTECTION (NIOSH).

9. PHYSICAL AND CHEMICAL PROPERTIES APPEARANCE AND ODOR:

Off-white, translucent liquid; hydrocarbon odor.

ATTACHMENT 2 SUPERFLOC SD-2065 Flocculant MSDS No: 09084 Date: 01/0312002 Page 3 of 6 BOILING POINT:

Aqueous phase -100 C; Oil phase -175 C MELTING POINT:

Not available VAPOR PRESSURE:

Similar to water SPECIFIC GRAVITY:

-1.0 VAPOR DENSITY:

Similar to water

% VOLATILE (BY WT): -50 pH: 3.0-4.0; in water SATURATION IN AIR (% BY VOL): Not available EVAPORATION RATE:

Not available SOLUBILITY IN WATER:

Limited by viscosity VOLATILE ORGANIC CONTENT:

Not available

10. STABILITY AND REACTIVITY STABILITY:

Stable CONDITIONS TO AVOID:

Avoid contact with oxidizing agents.

POLYMERIZATION:

Will Not Occur CONDITIONS TO AVOID:

None known INCOMPATIBLE MATERIALS:

Strong oxidizing agents HAZARDOUS DECOMPOSITION PRODUCTS:

carbon monoxide; carbon dioxide; ammonia; oxides of nitrogen; hydrochloric acid 1 1. TOXICOLOGICAL INFORMATION Toxicological information for the product is found under Section 3. HAZARDS IDENTIFICATION. Toxicological Information on the OSHA regulated components of this product is as follows:

-Petroleum distillates, hydrotreated light (CAS# 64742-478) has acute oral (rat) and dermal (rabbit) LD50 values of >5 g/kg and >3.16 g/kg, respectively. Prolonged or repeated skin contact tends to remove skin oils, possibly leading to Irritation and dermatitis. Direct contact may cause eye Irritation. Overexposure to high vapor concentrations, >-700 ppm, are Irritating to the eyes and respiratory tract and may cause headaches, dizziness, drowsiness, and other central nervous system effects, Including death. Aspiration of minute amounts during Ingestion or vomiting may cause mild to severe pulmonary injury and possibly death. In a 90-day oral gavage (rats) study at 100, 500, or 1000 mglkg, no treatment-related mortalities were observed. There were no significant changes In body weights or food consumption In any dose groups. Increased liver weights were observed In male and female rats a 500 and 1000 mg/kg. Increased kidney weights were observed only In male rats at 500 and 1000 mglkg. Testes weights were significantly elevated In male rats at 1000 mg/kg. Kidney effects, Indicative of light hydrocarbon nephropathy, occured In male rat kidneys at all dose levels. Histological findings of hepatocellular hypertrophy were seeen In the livers of male rats at 1000 mg/kg and in female rats at 500 and 1000 mg/kg. All treatment-related effects were reversible within the 4-week recovery period. Observed kidney effects (Including light hydrocarbon nephropathy and Increased kidney weight) are a unique response by male rats to chronic hydrocarbon exposure, which th U.S. EPA has declared "not relevant to humans".

High-dose liver effects (including hepatocellular hypertrophy, or enlarged liver cells) are a direct consequence of the sustained high-fat "hydrocarbon diet". The No Observed Adverse Effect Level (NOAEL) for this study was 1000 mg/kg.

Isopropanol has acute oral (rat) and dermal (rabbit) LD50 values of 5.0 g/kg and 12.8 g/kg, respectively. The 4-hour Inhalation LC50 (rat) for Isopropanol is >16,000 ppm (40.86 mg/.). Acute overexposure to isopropanol vapor may cause mild Irritation of the eyes and respiratory tract. Chronic overexposure to Isopropanol vapors may cause central nervous system depression, headaches, dizziness, nausea, and staggered gait. Liquid Isopropanol Is a severe eye irritant.

Califomia Proposition 65 Warning (applicable in California only) - This product contains (a) chemical(s) known to the State of California to cause cancer.

ATTACHMENT 2 SUPERFLOCO SD-2065 Floculant MSDS No: 09084 Date: 01/03/2002 Page 4 of 6

12. ECOLOGICAL INFORMATION No aquatic LC50, BOD, or COD data available.

OCTANOUH2O PARTITION COEF.:

Not available

13. DISPOSAL CONSIDERATIONS The Information on RCRA waste classification and disposal methodology provided below applies only to the Cytec product, as supplied. If the material has been altered or contaminated, or it has exceeded Is recommended shelf life, the guidance may be Inapplicable. Hazardous waste classification under federal regulations (40 CFR Part 261 et seq) is dependent upon whether a material Is a RCRA 'listed hazardous waste or has any of the four RCRA "hazardous waste characteristics." Refer to 40 CFR Part 261.33 to determine if a given material to be disposed of is a RCRA "listed hazardous waste'; Information contained In Section 15 of this MSDS Is not intended to Indicate if the product Is a 'listed hazardous waste." RCRA Hazardous Waste Characteristics: There are four characteristics defined In 40 CFR Section 261.21-61.24: Ignitability, Corrosivity, Reactivity, and Toxicity. To determine Ignitability, see Section 5 of this MSDS (flash point). For Corrosivity, see Sections 9 and 14 (pH and DOT corrosivity). For Reactivity see Section 10 (incompatible materials). For Toxicity, see Section 2 (composition). Federal regulations are subject to change. State and local requirements, which may differ from or be more stringent than the federal regulations, may also apply to the classification of the material If it Is to be disposed. Cytec encourages the recycle, recovery and reuse of materials, where permitted, as an alternate to disposal as a waste. Cytec recommends that organic materials classified as RCRA hazardous wastes be disposed of by thermal treatment or incineration at EPA approved facilities. Cytec has provided the foregoing for Information only; the person generating the waste Is responsible for determining the waste classification and disposal method.

14. TRANSPORT INFORMATION This section provides basic shipping classification information. Refer to appropriate transportation regulations for specific requirements.

D.O.T.

SHIPPING INFORMATION NOT APPLICABLE/NOT REGULATED IMO SHIPPING INFORMATION NOT APPLICABLE/NOT REGULATED SHIPPING NAME:

HAZARD CLASS/

Not Applicable Not Applicable PACKING GROUP:

UN NUMBER:

Not Applicable Not Applicable IMDG PAGE:

Not Applicable Not Applicable D.O.T.

OPRODUCT REPOABE OUArY)

Not Applicable HAZARDOUS Not Applicable SUBSTANCES:

TRANSPORT None Required None Required LABEL REQUIRED:

ICAOliATA TRANSPORT CANADA SHIPPING NOT APPLICABLE/NOT REGULATED NOT APPLICABLE/NOT REGULATED NAME:

HAZARD CLASS:

Not Applicable Not Applicable 1e l E%^

l

~ ~A Kg-& A--rtlil.1e Al-& A--§:-L.1-OUDOWIUIPl T CLASS:

1-4UX rppiimala I-quI rApp1l;4Ul

ATTACHMENT 2 SUPERFLOC SD-2065 Flocculant MSDS No: 09084 Date: 01103/2002 Page 5 of 6 UN / ID Not Applicable Not Applicable NUMBER:

PACKING Not Applicable Not Applicable GROUP:

TRANSPORT None Required None Required LABEL REQUIRED:

PACKING INSTR:

PASSENGER Not Applicable Not Applicable cARGo Not Applicable MAX NET QTY:

PASSENGER Not Applicable Not Applicable CAnGO Not Applicable ADDITiONAL TRANSPORT INFORMATION Not Applicable TECHNICAL NAME (N.O.S.):

15. REGULATORY INFORMATION INVENTORY INFORMATION US TSCA:

All components of this product are included on the TSCA Inventory in compliance with the Toxic Substances Control Act, 15 U. S. C. 2601 et. seq.

This product contains a chemical substance that is subject to export notification under Section 12 (b) of the Toxic Substances Control Act, 15 U. S. C. 2601 et. seq. (This requirement applies to exports from the United States only.)

CANADA DSU Components of this product have been reported to Environment Canada In accordance with subsection 25 of the Canadian Environmental Protection Act and are included on the Domestic Substances List.

EEC EINECS:

All components of this product are Included In the European Inventory of Existing Chemical Substances (EINECS) or the "No Longer Polymer' list, or are polymers of which the components are In EINECS, in compliance with Council Directive 67/548/EEC and its amendments.

OTHER ENVIRONMENTAL INFORMATION The following components of this product may be subject to reporting requirements pursuant to Section 313 of CERCLA (40 CFR 372), Section 12(b) of TSCA, or may be subject to release reporting requirements (40 CFR 307, 40 CFR 311, etc.) See Section 13 for information on waste classification and waste disposal of this product.

COMPONENT CAS. NO.

TPQ(lbs)

RQ~bs)

S313 TSCA 12B Isopropanol 000067-63-0 0-0.5 NONE NONE NO YES I PRODUCT CLASSIFICATION UNDER SECTION 311 OF SARA I

l ACUTE (Y) CHRONIC (N) FIRE (N)

REACTIVE (N)

PRESSURE (N)

16. OTHER INFORMATION NFPA HAZARD RATING (National Fire Protection Association)

Fire FIRE:

Materials that must be preheated before ignition can occur.

1 HEALTH:

Materials that, under emergency conditions, can cause temporary Health 2 0 Reactivity incapacitation or residual injury.

REACTIVITY:

Materials that in themselves are normally stable, even under fire Special exposure conditions.

ATTACHMENT 2 SUPERFLOCe SD-2065 Flocculant MSDS No: 09084 Date: 01/03/2002 Page 6 of 6 REASON FOR ISSUE:

Revised Sections 2, 4, 6, 7, 11, 15 I

-j I

Randy Deskin, Ph.D., DABT This information is given without any warranty or representation. We do not assune any legal responsibility for same, nor do we give permission, Inducement, or recommendation to practice any patented invention without a license. It is offered solely for your consideration. Investloation and verification. Before usina any product, read Its label.

ATTACHMENT 2 RE:

Aquatic Toxicity Analysis - Groundwater Treatment Project ButterfieldE Following please find our report on potential aquatic toxicity of the Cytec polyneric flocculants (Superfloc C-1592RS) proposed for use In CY's upcoming Groundwater Treatrent project, as requested.

As you know, many variables contriute to 'whole efflue*e toxicity of a Environmentl wastestream. As this Is a straightforward clarification and dewatering Corporation application, the analysis Is relatively simple and considers the following factors:

0 Obm Sbvet PFuouth, MA 023O0 Nature and mechanism of the producrs tcadcity on aquatic species an:4fn

• Nature of the reeiving ecosystem (CY's exdsting discharge canal)

Design of the treatment process.

• Chermical dosage to treatment process Water discharge flow rate a Residual effluent concentration from freatnent process a Pathway(s) to the reoeMng environment This r dt predicts zero discharge of polymer solids - hence a not toxIcIty of zero - to the surrounding environment, based on the behavior of the products in application and the proposed design of the treatment process.

1.

Aquatic Toxicity of C41592RS Cationic Flocculant C-1692RS was selected for use in the Project based on treatability testing performed on prepared samples made up from representative soil and groundwater samples collected In the construction area (for full test report, see Appendix 'A' - CT Yankee WastewatrTreatnent Testing, dated June 16, 2004, attached). The product is a relatvely low cationic charge (10 mole percent), high molecular weight, liquid emulsion polyacrylamide (EPAM).

Other products tested (anionic, non-Ionic and higher charge cationic products), did not meet performnance spedfications required for the project

ATTACHMENT 2 Page-2 The aquatic toxidcty level of Superfloc C-1592RS tested in *EPA Protocol Waters" Is reported as follows:

Product 96=Hour 1.60 RainbowTrout BluGOIll Sun s C-1692RS 1 -4 ng'L 3 -13mIL Based on tesfing wfith mlar products Al values repored In msnL on sold" basis. Au teats prformed In EPA Protor waters.

The tcoddtry of cationic polymers is nitigated In the environment by the presence of inert solids and soluble organics; hence these reported toxicity levels are not due to soluble tondns in the product but rather by the test conditions, In waters where there are no solids or dissolved organics to which polymer can attach, fte polyrner molecules adsorb to aquatic species - such as a fish's gills, which are negafivh charged to absorb oxygen - and cause suffocation. This Is illustrated by the fact that aquatic toxicity of adnonic and nonionic EPAM's ranges from 75 mg/i to >1000 m/WL hfr freshwater species (48-hr and 9hr LC§0's). compared to 0.5 -4 mg/i for most hilh-charge catlonic products.

Numerous studes document t extremely high efficiency of polymer adsorption by suspended solids in the environment Since toxicity testing uses EPA Protocol water. which is fiee from solids or naturally occurring.

dissolved organics, even low levels of a cationlc compound are reported as

'toxic". Except In the case of an extrene overdose, 100% of polymer.solds attach to Inert solids and organics in the naural environment and are not available at toxic levels for aquatic life. (it should be noted as well that, although testing is reported on a neat product basis, the actual concentration of polymer solids In the neat emulsion Is less than 40% by weight)

An additional toxdyty buffer Is pro'ided in salt-water environments. Aquatic toxicity of cationic polymer is significantly lower for marine organisms than for freshwater species.

ATTACHMENT 2 ALL VALUES AE IN MG/LITER (AS SOLD BASES)

(TESTS PERFORMED IN "EPA PROTOCOL" WATER UNLESS OTHERWISE SPECIFIED) 96 HR LC50 48 HR LC50 RAINBOW BLUEGILL TROUT SUNFISH FATHEAD MINNOW DAPHNIA CERIODAPHNIA MAGNA DUBIA PRODUCT MAGNIFLOC 985N 750

>1000

>1000

>1000 600 MAGNIE;IOC 990N

>100 CATIONIC EMULSION PAMS:

>100 MAGNIFLOC 1555C 5.0 35 (RIVER) 6.7 14 (RIVER)

MAGNIFLOC 1561C MAGNIFLOC 1563C MAGNIFLOC 1590C 2.7, 17, 2.1 7.7 60 (RIVER) 46 (RIVER) 1.14 4.5 13.4 28.7 (WITH ADDITION OF 5 PPM HUMIC ACID)

MAGNIFLOC 1591C 1-4*

3-13*

MAGNIFLOC 1592C MAGNIFLOC 1594C MAGNIFLOC 1596C MAGNIFLOC 1596CSP

• ESTIMATE BASED ON TESTS WITH SIMILAR PRODUCTS.

1-4*

3-13*

• ESTIMATE BASED ON TESTS WITH SIMILAR PRODUCTS.

1-4*

3-13*

• ESTIMATE BASED ON TESTS WITH SIMLAR PRODUCTS.

0.94 5.0 (TAP) 2.5 0.12 0.5-1*

1-4*

0.1-0.2*

• ESTIMATE BASED ON TESTS WITH SIMILAR PRODUCTS.

ATTACHMENT 2 ALL VALUES AE IN MG/LITER (AS SOLD BASES)

(TESTS PERFORMED IN "EPA PROTOCOL" WATER UNLESS OTHERWISE SPECIFIED) 96 HR LC50 48 HR LC50 RAINBOW TROUT BLUEGILL SUNFISH FATHEAD MINNOW DAPHNIA CERIODAPHNIA MAGNA DUBIA PRODUCT MAGNIFLOC 1598C MAGNIFLOC 4518C 0.5-1*

14*

• ESTIMATE BASED ON TESTS WITH SIMILAR PRODUCTS.

0.5-1*

1-4*

• ESTIMATE BASED ON TESTS WITH SIMILAR PRODUCTS.

ANIONIC EMULSION PAMS:

1260 SERIES MAGNIFLOC 1820A MAGNIFLOC 1839A MAGNIFLOC 1849A 32 0.15 0.33, 5.0 (TAP) 53.2 84.4 240 (TAP) 75.2 75.2 89.5 89.5 MAGNIFLOC 1881A MAGNIFLOC 1883A MAGNIFLOC 1885A 50-120*

50-100*

• ESTIMATE BASED ON TESTS WITH SIMILAR PRODUCTS.

120 50-120*

50-100*

• ESTIMATE BASED ON TESTS WITH SIMILAR PRODUCTS.

MAGNIFLOC 1893A 120 NONIONIC EMULSION PAMS:

MAGNIFLOC IOOCSP

>100 MAGNIFLOC 1986N

>100

>100

>100

ATTACHMENT 3 TEST PAR AMPTER REPORTED UNITS SPRAY POND GRAB SAMPLE pH Specific Conductance Alkalinity, "P" Alkalinity, "M" Sulfur, Total Chloride Hardness, Total Calcium Hardness, Total Magnesium Hardness, Total Copper, Total Copper, Soluble Iron, Total Iron, Soluble Sodium Zinc, Total Zinc, Soluble Manganese, Total Manganese, Soluble Phosphate, Total Phosphate, Total Inorganic Phosphate, Ortho-Phosphate, Soluble Ortho-Silica, Total Solids, Total Suspended Sulfide Phosphate, Soluble Total Phosphate, Soluble Total at 250C, pVmhos as CaCO3, ppm as CaCO3, ppm as S04, ppm as Cl, ppm as CaCO3, ppm as CaCO3, ppm as CaCO3, ppm as Cu, ppm as Cu, ppm as Fe, ppm as Fe, ppm as Na, ppm as Zn, ppm as Zn, ppm as Mn, ppm as Mn, ppm as P04, ppm as P04, ppm as P04, ppm as P04, ppm as SiO2, ppm mg/l as S, ppm as P04, ppm Inorganic, as P04 7.6 880 0

114 151 99 257 162 95

<0.05

<0.05 0.09

<0.05 66

<0.01

<0.01 0.14

<0.01 0.8 0.7 0.6 0.5 13.1 38-100 N/A 0.6 0.6