Text

Request Biocide/Corrosion Treatment Plan Approval, NPDES Permit No. TN0026450
	ML050680462
Person / Time
Site:	Sequoyah
Issue date:	03/07/2005
From:	Howard S; Tennessee Valley Authority
To:	Myers P; Office of Nuclear Reactor Regulation, State of TN, Dept of Environment & Conservation
References
	-RFPFR, TN0026450
	Download: ML050680462 (113)
	v • d • e

Tennessee Valley Authority, Post Office Box 2000, Soddy-Daisy, Tennessee 37379-2000 March 7, 2005 Ms. Pamala Myers Permit Section Tennessee Department of Environment & Conservation Division of Water Pollution Control 6th Floor, L & CAnnex 401 Church Street Nashville, Tennessee 37243-1534

Dear Ms. Myers:

SEQUOYAH NUCLEAR PLANT (SQN) - NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT NO. TN0026450 - REQUEST BIOCIDE/CORROSION TREATMENT PLAN APPROVAL Sequoyah Nuclear Plant (SQN) requests permission to implement the following changes to the Biocide/Corrosion Treatment Plan. The changes are necessary for SQN to address mollusk and microbiologically induced corrosion issues in plant systems that are essential for the safe and reliable operation of the plant. These systems are designed in accordance with Nuclear Regulatory Commission requirements and must function as designed in the event plant shutdown is required. As indicated in the plan, the plant's safety related systems must be routinely chlorinated for four to twelve hours per day and occasionally must be chlorinated twenty-four hours per day. Attached please find a complete Biocide/Corrosion Treatment Plan with the following requested changes highlighted.

1. Authorization to use H-130M, Barquat 4250-Z (also known as H-150M), and/or Spectrus CTI 300 for mollusk control.

2. Authorization to use the detoxifying agent bentonite clay when required. Bentonite clay will be used at a minimum ratio of 5 ppm clay to 1 ppm product.

3. SON requests in this plan to Increase the chlorine discharge limit at Outfall 101 to 0.1 mg/L for TRC. This is consistent with TDEC's comments back to WBN in the July 30, 2004 Biocide/Corrosion Treatment Plan Approval letter. (reference the plan overview). This discharge limit will be determined by mass balance calculation.

SQN plans to show compliance by use of mass balance calculations when possible. In the event detoxification with bentonite clay is required, SQN will obtain and analyze a daily confirmatory sample for the active ingredients in H-130M, Barquat 4250-Z (also known as H-150M), and/or Spectrus CT1300 during application. This analytical result may be used in conjunction with calculations to demonstrate protection of the receiving stream. These records will be maintained on site in accordance with NPDES permit requirements. Please note that SON has conducted and passed quarterly toxicity testing in conjunction with non-oxidizing biocide treatments with H-1 30M during the current permit term.

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Ms. Pamala Myers March 7, 2005 Page 2 SQN requests written approval of this Biocide/Corrosion Treatment Plan no later than April 7, 2005 in order to facilitate more effective treatment during the spring months. SQN is also providing this request to update the NPDES permit application submitted on June 30, 2003.

The attached plan reflects all the changes implemented since issuing the last NPDES permit and provides a more accurate initial reference for the Raw Cooling Water treatment chemicals and programs proposed during the NPDES permit renewal process.

SQN will request changes to this plan whenever changes in active ingredients, discharge concentrations, or maximum daily usage are necessary. Changes in the trade name of the products and minor changes in equipment or methods of application will not require additional reviews or authorization for this plan.

If you need additional copies or have comments or questions, please contact Ann Hurt (423-843-6714) or myself (423-843-6700).

I certify under penalty of law that this document and all of its attachments were prepared under my direction or my supervisor in accordance with a system designed to assure qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

Sincerely, Stephanie A. Howard Principal Environmental Engineer Signatory Authority for J. Randy Douet Site Vice President Sequoyah Nuclear Plant Enclosures cc (Enclosures):

Mr. Edward M. Polk, Jr., P.E. Nuclear Regulatory Commission Manager, Permit Section ATTN: Document Control Desk Tennessee Department of Washington, D.C. 20555 Environment & Conservation Division of Water Pollution Control 6th Floor, L & C Annex 401 Church Street Nashville, Tennessee 37243-1534

Raw Water Chemical Additives at Sequoyah Nuclear Plant PRODUCT PURPOSE FREQUENCY ACTIVE INGREDIENTS REPRESENTATIVE AQUATIC TOXICITY DISCHARGE OF /DESCRIPTOR CONCENTRATION' DISCHARGE (ppm active ingredients) (ppm active ingredients)

PCL-401 Dispersant to Continuous Anionic Copolymer 48-h LC 50=798 (D. magna) < 0.2 facilitate iron during cool 96-h LC5 0 =>2850 (bluegill sunfish) corrosion inhibition weather months PCL-222 2 Dispersant to Continuous Orthophosphate, 48-h LC 50=798 (D. magna) < 0.2 facilitate iron Hexametaphosphate 96-h LC50 =>2850 (bluegill sunfish) corrosion inhibition Anionic Copolymer Biodctcrgent Surfactant to Periodic Ethylene Oxide - Propylene 3 brood IC 25=28 (C. dubia) < 2.0 73551 facilitate oxidizing Oxidc copolymer 7-d NOEC=105.4 (P. promelas) biocides (EO/PO copolymer)

Towerbrom 960 Oxidizing Biocide Periodic Sodium Bromide & Sodium 48-h LC5 0=2.43 (D. magna) < 0.10 Chlorine (Chlorination) Dichloroisocyanurate 48-h LC 50=0.679 (P. promelas) (Total Residual)

H-130M 4 Non Oxidizing Periodic Didecyldimethylammonium 3 brood IC2 s='0.139 (C. dubia) <0.05 Biocide Chloride (DDAMC) 7-d IC25 =0.104 (P. promclas)

(Mollusk Control)

Barquat 4250-Z Non Oxidizing Periodic Alkyl Dimethyl Benzyl Toxicity testing of Barquat is currently < 0.05 (also known as Biocide Ammonium Chloride & underway (3/1/05) at Environmental Testing H-150M) 4 (Mollusk Control) Alkyl Dimethyl Ethylbenzyl Solutions, Inc., Asheville, NC.

Ammonium Chloride Spectrus CT1300 4 Non Oxidizing Periodic Alkyl Dimethyl Benzyl 48-h LC50=0.18 (C. dubia) <0.05 Biocide Ammonium Chloride & 96-h LC50=0.36 (P. promelas)

(Mollusk Control) Ethyl Alcohol Coagulant Detoxification of Periodic Sodium Silicate No toxicity data is available. No treatment < 10.0 Aid -353 non oxidizing (Bentonite Clay) standards are applicable. This is an industry

. biocides standard for detoxification.

1. The maximum discharge concentration is indicated EXCEPT where noted. Concentrations are achieved through dilution and/or detoxification with bentonite clay.

2. Toxicity of PCL-222 assumed tobe similar to PCL-401. No actual toxicity data available for this product. Tests will be conducted at a toxicity lab under contract to the manufacturer.

3. Detoxification chemicals are applied when required.

4. SQN plans on using the non-oxidizing biocides H-130M, Barquat 4250-Z (also known as H-150M), and/or Spectrus CT 1300 for mollusk control.

3/7/2005 SQN Biocide/Corrosion Treatment Plan I

Raw Water Chemical Application Guide1 Product Injection Points Max Feed In Plant Frequency of Average Estimated Maximum Daily (ppm) Target Application Duration of Max Days Usage (lbs/day) 2 (Ppm)_Application. per Year PCL-401 3 ERCW Train A & B 2.6 2.6 Daily during 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day 217 1480 cool weather months PCL-222 Copolyme? RCW Train A & B 0.8 0.8 Daily 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day 365 760 and RCW PCL-222 Phosphate' ERCW Train A & B 2.4 2.4 Daily 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day 365 2280 and RCW Biodetergent 73551 ERCW Train A & B 2.5 2.5 208 days 0.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months per day 208 50 and RCW per year Towerbrom 9604 ERCWTrain A & B 1.5 1.5 312 days 4-12 hours 312 1425 and RCW per year per day H-130M5 ERCW Train A & B 3.0 3.0 24 per year 3-5 days 120 855 and RCW Barquat 4250-Z ERCW Train A & B 3.0 3.0 24 per year 3-5 days 120 855 (also known as and RCW H-150M) 5 .

Spectrus CT13005 ERCW Train A & B 3.0 3.0 24 per year 3-5 days 120 855 and RCW Coagulant Aid-35 ERCW Train A & B 30 30 24 per year 3.5-5.5 days 132 8520 and RCW

1. Concentrations and usage are expressed for the active ingredient(s) shown on the first page of this plan.

2. Maximum Daily Usage provides an indication of loading in the receiving stream. It is the maximum amount of active ingredients for the worst case scenario of flow and feed concentration being proposed plus a 10% margin of error. SQN will request a change to this plan should an increase in maximum daily usage becomes necessary for the continued safe operation of the plant.

3. PCL-222 is a blend of copolymer, orthophosphate, and hexametaphosphate. PCL-222 is injected into the RCW system continuously, except during periods of other chemical injection due to common injection lines. PCL-222 is injected into the ERCW Train A & B system only during warm weather months. During cool weather months PCL-401 is injected.

4. Towerbrom 960 is 96% active product producing 57% free halogen (chlorine or bromine). Chlorine will be less than NPDES permit limits at NPDES discharge point (Outfall 101). Also, please note that the routine usage includes the proposed 24 hr/day chlorination activities. That is why the maximum dailyusage (lbs/day) is higher than the 4-12 hours per dayusage that is most typical of 'Routine Chlorination'. See the rationale documents for more information on chlorination.

5. SQN plans on using the non-oxidizing biocides H-130M, Barquat 4250-Z (also known as H-150M), and/or Spectrus CT 1300 for mollusk control.

3/7/2005 SQN Biocide/Corrosion Treatment Plan 2

Calculations Showing Worst Case Scenario (final values rounded to the nearest 5 Ibs)

PCL-401 2.6mg I lb 43,000 gal 3.785 L 60 min 24 hr 1.10 = 1480 lbs/day PCL-401 2.6 ppm active L 454,000 mg min gal 1 hr day PCL-222 0.8 mg I lb 71,800 gal 3.785 L 60 min 24 hr 1.10 = 760 lbs/day PCL-222 copolymer 0.8 ppm active L 454,000 mg min gal 1hr day PCL-222 2.4 mg 1 lb 71,800 gal 3.785 L 60 min 24 hr 1.10 = 2280 lbs/day PCL-222 phosphate 2.4 ppm active L 454,000 mg min gal I hr day BlioDet 73551 2.5 mg 1 lb 71,800 gal 3.785 L 60 min 0.5 hr 1.10 = 50 lbs/day BioDetergent 73551 2.5 ppm active L 454,000 mg min gal 1 hr day TB-960 1.5 mg 1 lb 71,800 gal 3.785 L 60 min 24 hr 1.10 = 1425 lbs/day TB-960 1.5 ppm active L 454,000 mg min gal 1 hr day H-130M 3 mg 1 lb 21,500 gal 3.785 L 60 min 24 hr 1.10 = 855 lbs/day H-130M (quat) 3 ppm active L 454,000 mg min gal 1 hr day Barquat 4250-Z 3 mg 1 lb 21,500 gal 3.785 L 60 min 24 hr 1.10 = 855 lbs/day Barquat 4250-Z (also known as (also known as H-150M)

H-150M) 3 ppm active L 454,000 mg min gal 1 hr day Spectrus CT1300 3 mg 1 lb 21,500 gal 3.785 L 60 min 24 hr 1.10 = 855 lbs/day Spectrus CT1300 3 ppm active L 454,000 mg min gal 1 hr day _

CA-35 1 30 mg I lb 21,500 gal 3.785 L 60 min 24 hr 1.10 = 8520 lbs/day CA-35 30 ppm active L 454,000 mg min gal 1 hr day

1. Coagulant Aid-35 is fed at 5x product dose (or lOx active dose) for quatcrnary amines. It may be applied to the ERCW A & B Train and RCW when required.

Max ppm feed dose of 30 ppm is based on the worst case scenario of 3 ppm active H-130M, Barquat 4250-Z (also known as H-1SOM), and/or Spectrus CT1300 max feed dose, with a maximum ERCW/RCW flow rate of 21,500 gpm.

3/7/2005 SQN Biocide/Corrosion Treatment Plan 3

TN0026450 RATIONALE for Raw Water Chemical Additives SQN Raw Water Treatment Programs The fundamental approach and active ingredients for the various treatment programs at SQN have not changed significantly in more than seven years. Products with slightly different formulations of the same active ingredients or constituents of concern and the processes or frequencies of applying those products have changed periodically.

1. Dispersants and surfactants used year round to facilitate removal of corrosion products from carbon steel piping has changed recently with some differences in active ingredients, but all have been of low toxicity.

2. Treatment with oxidizing biocides has had prior approval. Based on quarterly toxicity testing, toxicity concerns are being addressed for oxidizing biocides.

3. Treatments with non-oxidizing biocides use quaternary amine compounds for mollusk control. Detailed calculations are performed for each treatment to ensure discharge limitations are observed.

4. The most significant changes in this proposal are:

The addition of continuous (24hr/day) oxidizing biocide treatments for mollusk control.

SQN plans to increase the number of non-oxidizing biocide treatments from four to eight for mollusk control. One treatment is defined as injections into three systems RCW, ERCW-A train and ERCW-B train.

Detoxify non-oxidizing biocides using bentonite clay when required.

SQN requests in this plan to increase the chlorine discharge limit at Outfall 101 to 0.1 mg/L for TRC this is consistent with TDEC's comments back to WBN in the July 30, 2004 Biocide/Corrosion Treatment Plan Approval letter. (reference the plan overview). This discharge limit will be determined by mass balance calculation.

3n12005 SQN Biocide/Corrosion Treatment Plan Rationale 4

TN0026450 RATIONALE for Raw Water Chemical Additives SQN Treatment Plan Overview and Toxicity Summaries Document Summary nE . An overview of the proposed raw water treatment programs at SQN.

Plan Overview This document describes the process for detoxifying SQN's effluents a= from the application of quatemary amines as a molluscicide. The Detoxification process references H-130M but is applicable to Barquat 4250-Z (also known as H-1 50M) and Spectrus CTI 300 as well.

Several bench top toxicity studies on individual products and the synergistic effects of the various treatment programs have been conducted for TVA nuclear facilities. The simulated effluents tested included the molluscicide H-1 30M contained in this treatment plan.

INResults from these studies are incorporated into the attached summary Vof toxicity endpoints compared with projected instream product Toxidty Ass ssmnt Summary concentrations. Reports are available upon request. Ongoing documentation for protection against synergistic and/or chronic impacts by SQN's treatment programs is provided by routine 7-day toxicity testing at Outfall 101 (diffuser discharge). SQN has not failed a toxicity test at Outfall 101 during quarterly testing under the current chemical additive plan.

A short summary prepared by Calgon with information on how quatemary amines work.

Quatemary Anines 3n12005 SQN Biocide/Corrosion Treatment Plan Rationale 5

TN0026450 RATIONALE for Raw Water Chemical Additives SQN PCL-401 (Anionic Copolymer)

A dispersant commonly used in water treatment programs. PCL-401 is a copolymer-dispersant used to minimize fouling and under-deposit corrosion in the ERCW system. This product makes carbon piping corrosion inhibitors more effective. PCL-401 is not considered hazardous per OSHA regulations and appears to be of very low toxicity according to the MSDS and bench top studies conducted by TVA.

Document Summary trj Material Safety Data Sheet.

PCL-401 MSDS.pdf Product Bulletin PCL401 PB.pdf PCL-222 (Anionic Copolymer/Phosphate)

A dispersant commonly used in water treatment programs. PCL-222 is a copolymer- phosphate dispersant used to minimize fouling and under-deposit corrosion in the ERCW and RCW systems. This product makes carbon piping corrosion inhibitors more effective. PCL-222 is not considered hazardous per OSHA regulations and appears to be of very low toxicity according to the MSDS and compliance with WET limits during on-going quarterly testing.

Document Summary Material Safety Data Sheet.

PCL-222 MSDS hi". P Product Bulletin PCL-222 PB I Biodetergent 73551 (Ethylene OxidelPropylene Oxide Copolymer) I Biodetergent 73551 is a surfactant commonly used in water treatment programs to remove and disperse "soft foulant" (biofilm-enmeshed mud, silt and clay) from piping systems. When Towerbrom 960 is used for routine chlorination treatments, this product is added into the ERCW and RCW systems for approximately 30 minutes prior to initiating treatment to enhance the effectiveness of chlorination. This product has a low toxicity and will be discharged at low concentrations.

Document Summary Material Safety Data Sheet.

Biodetergent 73551 MSDS.pdf Product Bulletin 73551 PB.pdf 3/7/2005 SQN Biocide/Corrosion Treatment Plan Rationale 6

TN0026450 RATIONALE for Raw Water Chemical Additives SQN Towerbrom 960 (Sodium Bromide & Sodium Dichloroisocyanurate)

Towerbrom 960 is an oxidizing biocide generating bromine and chlorine solutions when dissolved in water. Chlorine is monitored to ensure discharge limitations are met when this product is used in the ERCW and RCW systems. In system samples are collected during the treatment and analyzed according to NPDES permit requirements and used in a mass balance calculation to derive the discharge concentration to ensure discharne limitations are met.

Document Summary Material Safety Data Sheet.

Towerbrom 960 MSD6.pdf Product Bulletin Towerbrom 960 PB.pdf H-130M (Didecyldimethyl ammonium Chloride)

H-130M is a quatemary amine used for mollusk control. Actual discharges are based on calculations that assume no demand in the system, therefore increasing the safety margin for instream protection.

SQN is requesting with this application that the number of injections and durations be adjusted, but that the current maximum allowable discharge concentration of 0.05 ppm remains unchanged. SQN plans to ensure water quality is not threatened by adding bentonite clay to detoxify the active ingredient when required. TVA's own studies as well as those of the manufacturer of this product indicate that bentonite clay will be effective at detoxifying this product.

Document Summary Material Safety Data Sheet.

H-130M MSDS.pdf Product Bulletin H-130m PB.pdf 3/7/2005 SQN Biocide/Corrosion Treatment Plan Rationale 7

TN0026450 RATIONALE for Raw Water Chemical Additives SQN Barquat 4250-Z (also known as H-150M)

Barquat 4250-Z (also known as H-150M) is a quatemary amine used for mollusk control. Actual discharges are based on calculations that assume no demand in the system, therefore increasing the safety margin for instream protection. SQN is requesting with this application that the number of injections and durations be adjusted, but that the current maximum allowable discharge concentration of 0.05 ppm remains unchanged. SQN plans to ensure water quality is not threatened by adding bentonite clay to detoxify the active ingredient when required. The manufacturer of this product indicates that bentonite clay will be effective at detoxifying this product.

Document Summary I Material Safety Data Sheet.

M1 Barquat 4250-Z MSDS Product Bulletin Barquat 4250-Z PB l Spectrus CT1300 l Spectrus CT1300 is a quatemary amine used for mollusk control. Actual discharges are based on calculations that assume no demand in the system, therefore increasing the safety margin for instream protection. SQN is requesting with this application that the number of injections and durations be adjusted, but that the current maximum allowable discharge concentration of 0.05 ppm remains unchanged. SQN plans to ensure water quality Is not threatened by adding bentonite clay to detoxify the active ingredient when required. The manufacturer of this product indicates that bentonite clay will be effective at detoxifying this product.

Document Summary Material Safety Data Sheet.

Spectrus Cr1300 MSDS

- o Product Bulletin Spectrs Cr1300 PB 3t7/2005 SQN Biocide/Corrosion Treatment Plan Rationale 8

TIN0026450 RATIONALE for Ram, Water Chemical Additives SQN Coagulant Aid-35 (Sodium Silicate)

Bentonite Clay. An industry standard for detoxifying effluents and water treatment. No toxicity data is available for this product. Wide spread use as a flocculant and as a detoxifying agent for organics. TVA and manufacturer studies indicated bentonite clay is very effective at removing the constituents of concern of the non-oxidizing biocides proposed in this treatment plan. The primary end product following absorption of the constituents is carbon dioxide from degradation of the complex organic molecules.

Compliance with TSS limitations will be met during use of this product.

Document Summary I Material Safety Data Sheet.

CA-35 MSDS.pdf Product Bulletin CA-35 PB.pdf 3M~2005 SQN Biocide/Corrosion Treatment Plan Rationale 9

TN0026450 Raw Water Chemical Additives SQN AN OVERVIEW OF RAW WATER CHEMICAL ADDITIVES Inspection and chemical treatment programs have been implemented at Sequoyah Nuclear Plant (SQN) to control fouling, plugging, and pipe wall thinning of the raw water systems. Most of the chemicals used in these treatment programs are added at three locations Essential Raw Cooling Water (ERCW) intake for ERCW A train and ERCW B train and Raw Cooling Water (RCVW pump suction header for RCW to ensure these raw water systems are protected. These systems, the ERCW and RCW, are essential for the safe and reliable operation of the plant. SON plans to show compliance with the treatment plans below using mass balance calculations where possible.

CARBON STEEL CORROSION INHIBITION SQN currently uses a combination of three chemicals to provide corrosion protection for carbon steel piping in the plant: a biodetergent 73551 ethylene glycol oxide/propylene glycol oxide copolymer, a dispersant copolymer PCL-401 and a dispersant copolymer with a phosphate additive PCL-222. SON recently received approval for use of the biodetergent 73551 and it is injected into ERCW and RCW. SQN has used the dispersants PCL-401 and PCL-222 for seven years. PCL-401 contains a copolymer with no phosphorous. PCL-401 is only injected into the ERCW system during months when the average ambient temperatures are below 35 degrees Fahrenheit. PCL-222 is injected into the RCW system year round and is injected into the ERCW system when the average ambient temperature is above 35 degrees Fahrenheit. The concentration of ethylene glycol oxide/propylene glycol oxide copolymer in the plant effluents will not exceed 2.0 ppm, and copolymer and phosphorous in the plant effluents will not exceed 0.2 ppm. It will continue to be necessary to apply these chemicals year round.

RAW COOLING WATER BIOCIDE TREATMENTS Protection of the raw cooling water systems from macro-invertebrates (mollusks) requires oxidizing and non-oxidizing biocide treatments. Oxidizing biocide treatments are aimed at both macro-invertebrate and microbiologically induced corrosion (MIC) control. Non-oxidizing biocides are aimed at macro-invertebrate control. SON plans to continue treating plant systems for mollusk control with a non-oxidizing biocide, H-1 30M, previously approved by the Division of Water Pollution Control. SQN also requests authorization to use additional quaternary amines to supplement the treatment program when needed. SON plans to detoxify non-oxidizing effluents when required.

ROUTINE RAW WATER TREATMENT WITH OXIDIZING BIOCIDES (CHLORINATION)

To control macro invertebrates and microbiologically induced corrosion, routine raw water treatments with oxidizing biocide (chlorination) are necessary for

1. SQN plans to treat two to five days per week during cool weather periods and five to seven days per week during warm weather periods for four to twelve hours per day.

2. SON plans to treat twenty-four hours per day for approximately 90 days per year and/or when veligers are present.

3. Shorter (24-72 hour) periods of continuous oxidizing biocide treatment will also be required following treatments with the non-oxidizing biocide.

The active ingredients in Towerbrom 960 produce 57% free halogen (chlorine and bromine) in solution. TVA plans to control the effluent concentration of Towerbrom 960 by controlling effluent Total Residual Oxidants to 0.10 mg/L in the plant effluent (TROs is defined for purposes of this plan to include residual chlorine and bromine and is to be quantified using Total Residual Chlorine (TRC) test). Water quality criteria for TRC are 0.019 mg/L as the Criteria Maximum Concentrations

((CMC) are water quality criteria for acute exposures) and 0.011 mg/L as the Criteria Continuous Concentrations ((CCC) are water quality criteria for chronic exposure). Although the 0.1 mg/L effluent limit will exceed the CMC, it is recognized that TRC reacts and dissipates rapidly between Monday, March 07, 2005 I

TN0026450 Raw Water Chemical Additives SQN the point of measurement and the point of discharge at the receiving stream. Therefore it is anticipated that an effluent limit of 0.1 mg/L for TRC will comply with water quality criteria. SQN requests in this plan to increase the chlorine discharge limit at Outfall 101 to 0.1 mg/L for TRC this is consistent with TDEC's comments back to WBN in the July 30, 2004 Biocide/Corrosion Treatment Plan Approval letter. This discharge limit will be determined by mass balance calculation.

NON OXIDIZING BIOCIDE TREATMENT (MOLLUSK CONTROL)

Due to an increase in the clam infestations seen in the plant piping necessary for safe shutdown of the plant, SQN plans to use the non-oxidizing biocides H-1 30M, Barquat 4250-Z (also known as H-150M) and/or Spectrus CT1 300 for 24-120 hours, 4-8 times per raw water system (RCW, ERCW-A, and ERCW-B) per year. SQN will show by mass balance calculation that the required concentrations are being met for each application. SQN plans to detoxify the effluent by treatment with bentonite clay when required and confirm the effectiveness of detoxification with daily sampling for the active ingredient in the effluent during the treatment period. For additional information refer to the detoxification document in the rationale for this treatment plan.

Monday, March 07, 2005 2

Detoxification Plan Note: This document describes the process for detoxifying SQN's effluents when required from the application of quatemary amines as a molluscicide. The process references H-1 30M but is applicable to Barquat 4250-Z (also known as H-I 50M) and Spectrus CT1300 as well.

Background

H-130M is a non-oxidizing liquid organic molluscicide containing a quatemary amine (quat) compound. H-130M effectively controls the zebra mussel and Asiatic clam in their veliger, juvenile, and adult forms. Due to the toxicity of H-130M to non-target organisms, a plant's discharge may need to be treated with CA-35, bentonite clay. CA-35 complexes with quatemary amines. The combined complex is not harmful to aquatic species or benthic organisms.

Effective dosage of H-1 30M is a function of water temperature. As water temperature decreases, the amount of H-130M required or the length of treatment is greater for the same mortality rate. Below 60 TF, the effectiveness of H-130M drops off quickly and dramatically due to lower mollusk metabolism rates and slower chemical reactions.

Generally, 70-72 TF is considered to be ideal, providing highest mortality for lowest chemical dosage and duration. At very high temperatures (low to mid 80s), mollusk metabolism is also known to decrease and therefore filter-feeding rate may decrease.

Therefore, the vendor does not recommend applications at very high temperatures.

Table 1 illustrates recommended treatment dosages and durations for mollusk control at SQN. This information is based on seminar literature and flow-through R&D data.

Treatments must be maintained at the target active residuals as measured (using a mass balance calculation) at the system outlet, for the entire duration.

stEm . Teatentni* rdt Dos Tage Acie u 0t ERCW/ H 13DM with 60-85 6.0 3.0 24-120 RCW CA-35 clay detox at.5: ratio to H-130M product Table 1: Recommended H-130M Treatment Dosage and Duration H-130M Iniection Plan SQN plans on injecting H-130M to obtain 3.0 ppm active residual at the ERCW/RCW system outlet during treatment of RCW and each train of ERCW for a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Based on the time required to rotate system equipment, to meet system demand and to see acceptable concentrations in low flow areas and components during the treatment, the typical treatment will most likely last 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months and, potentially, as long as 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months . The ERCW system chemical injection will occur in the respective ERCW pump pit of the ERCW train being treated. For example, if treating the ERCW A train, H-130M will be injected to the ERCWA pump pit. The RCW system injection will occur in the suction header feeding the RCW pumps.

1

Detoxification Plan Increased consumption of H-130M may occur due to higher system demand in all treatments. Therefore, the H-130M injection dose may need to increase to 6.0 ppm as product or higher to achieve 3.0 ppm active residual at the system's low flow components.

Clay detoxification feed rate will increase in proportion prior to raising the H-130M injection rate. If clay detoxification is halted to a discharge path due to malfunctions of any type, injection of H-130M will immediately stop.

ApplicationlEquipment Description One clay detoxification feeder is required to feed CA-35 at the discharge point. A clay feeder consists of a feed augur, hopper, eductor, pump, and piping enclosed in a small trailer. Clay is unloaded in the hopper and transferred to the eductor by the feed augur.

Clay mixes with the drive water creating clay slurry which is then injected into the selected discharge point by a pump. Clay feed rate is controlled by the feed augur. The augur has two settings: low (154 lbs clay/hr max) and high (617 lbs clay/hr max). Based on anticipated system flow rates, the maximum total anticipated clay feed rate is 355 Ibs/hr during a typical treatment, which is easily within the capacity of the feed augur system.

The hopper can hold as much as 150 pounds of clay, maximizing the time of unloading clay. Equipment set-up and components may vary slightly depending on vendor used for detoxification. Bentonite clay will be used at a minimum ratio of 5 ppm clay to 1 ppm product.

A technician will be responsible for proper and continuous operation of the trailer. Due to the critical nature of detoxification during the molluscicide treatment, the technician will be under the close supervision of an experienced vendor representative. If any problem is observed to be preventing clay feed, H-130M injection will be immediately terminated, the discharge paths will be isolated, and SQN staff notified.

Sampling To confirm effective detoxification for NPDES discharge purposes, daily samples will be collected at the NPDES discharge point (Outfall 101) for each day of treatment and during the treatment process and will be either analyzed on site or will be shipped to an analytical laboratory and analyzed using a methylene chloride extraction method with a MDL of 0.02 ppm quatemary amine.

Tentative Treatment Schedule In accordance with TVAN procedures, a minimum number of molluscicide treatments are established to exceed no more than eight treatments per year. A treatment is defined as injection of H-130M into each ERCW train A & B and the RCW system. Injections of H-130M are not conducted concurrently as only one train or system has injection occurring at any time.

2

Detoxification Plan Estimated Chemical Usage Table 2 lists the expected H-1 30M chemical use and feed rates during typical molluscicide treatments of RCW and each train of ERCW. Table 3 lists the expected CA-35 chemical use.

Spring Treatment 21,bUU 28.U 35__I_ 1U,Utu 1st Veliger Peak 21,500 90 6.0 35 3,150 Treatment 2nd Veliger Peak 21,500 90 6.0 35 3,150 Treatment 3 rd Veliger Peak 21,500 90 6.0 35 3,150 Treatment l t

4 h Veliger Peak 21,500 90 6.0 35 3,150 Treatment 5th Veliger Peak 21,500 90 6.0 35 3,150 Treatment 6t hVeliger Peak 21,500 90 6.0 35 3,150 Treatment Fall Treatment 21,500 288 6.0 35 10,080 Total Annual Usage (Ibs) 39,060 Table 3: Expected CA-35 Chemical Usage

.. .~t

....... i n.....i ur n Spring Treatment 21,500 292 180 52,560 1st Veliger Peak Treatment 21,500 94 180 16,920 2nd Veliger Peak Treatment 21,500 94 180 16,920 3rd Veliger Peak Treatment 21,500 94 180 16,920 4 th Veliger Peak Treatment 21,500 94 180 16,920 5th Veliger Peak Treatment 21,500 94 180 16,920 6th Veliger Peak Treatment 21,500 94 180 16,920 Fall Treatment 21,500 292 180 52,560 WilTot~1 Ann~ ~It~slle (I: >jgj; ..... 206,640 3

Product Toxicity Data Summary and Comparison with Maximum Instream Wastewater Concentrations (IWC)

Cone. @ 101 Instream Waste Chemical Organism1 Acute Endpoints Chronic Endpoints Maximum Conc.

(ppm as active) (pppm as active) Discharge Conc. 1Q10 -3491 MGD

(< Acute endpoints) 101 -1532 MGD

(< Chronic cndpoints))

_ 48-h LCso 96-h LCsn NOEC IC2 5 (ppmas active)

PCL-401 D. magna 798 -

Bluegill - >2,850 - 0.2 0.088 Rainbow Trout - >1,397 - .

PCL-2222 D. magna 798 _

Bluegill - >2,850 _ 0.2 0.088 Rainbow Trout - >1,397 Biodetergent D. magna >200 -

73551 C. dubia - - 28 P. promelas - - - 105.4 2.0 0.88 Bluegill - >200 -

Rainbow Trout - >200 -

Towerbrom D. magna 2.43 _ _ .

960 P. promelas 0.679 - - 0.1 0.044 Blue Gill - 0.417 - -

Rainbow Trout . 0.359 H-130M C. dubia' - 0.172 0.139 D. magna 0.094 - -

3 P. promelas - 0.172 0.104 Bluegill - 0.46 -

Rainbow Trout - 1.10 - 0.05 0.022 3 0.144 H. azteca - -

C. tentans 3 - - >1.50 U. imbecillis3 - 0.159 w/o 9-day LC50 silt; wv/silt w/o

>0.300 silt=0.047; U v_/silt>1.50 _ __

Product Toxicity Data Summary and Comparison with Maximum Instream Wastewater Concentrations (IWC), continued Cone. 101 Instream Waste Chemical Organism' Acute Endpoints Chronic Endpoints Maximum Cone.

(ppm as active) (ppm as active) Discharge Cone. 1Q10 -3491 MGD

(< Acute endpoints) 101 .1532 MGD l l t(<Chronic endpoints)

___ 48-h LC50 96-h LCso NOEC lC 2 5 (ppm as active) (ppm as active)

Barquat C. dubia _ _0.05 0.022 4250-Z (also P. promelas known as H-150M)4 Spectrus C. dubia 0.18 CT1300 NOEC 0.08 D. magna 0.06 - - -

NOEC 0.03 P. promelas - 0.36 - -

NOEC 0.20 Rainbow Trout - 1.0 - - 0.05 0.022 NOEC 0.6 L. variegatus - 0.74 - -

C. tentans - 0.25 - -

l__NOEC

_ 0.07 l G. - 0.04 -

pseutolimnacus I l Notes:

1. Data Source: Manufacturer unless otherwise noted.

2. Toxicity of PCL-222 assumed to be similar to PCL401. No actual toxicity data available for this product. Tests will be conducted at a toxicity lab under contract to the manufacturer.

3. Data Source: TVA/Contractor

4. Toxicity testing of Barquat 4250-Z (also known as H-150M) is currently underway (3/1/05) at Environmental Testing Solutions, Inc., Asheville, NC.

2

Paper No.

524 IAmnw I camd In ww 100 Zemn MusNd Coftrd Afppcatpis at 1wdaral Facltes C It MXGcxjh, P. Gill and R A. MuA C83811Corprto P.O. Box 1346 Pkt+/-xshPA15230 Absac Siwe tbeir Introchacion Into US vatrwA Zebra Mussels (Drdgjsapocmrpho) have

- raidly tn out the Ge lakes and MtsIa regiocs These =uscl hav continued to coniZO the htak pipe OfI1mr1 'Rdgta wupes ad water dstrfttion sstes throuhout the affected arms. Their cogoizatio huscompromised pla sfety and prw otoefficiecmy, and steadily icreased coO to water Wm.

lTe design oteah induxriaI pla waern dilrftda sem is unique. A comprehenive zebu miPl cotrl s ro udn the bedstailable q =o must be consdered in ch qefc sitton.T pper diScu the watcdW we afowe sraleg (a atemayryimonla-ba=sed mo cide) nthe battle agi U dm mnnel. Tbe cmercl life cye fan industi mollumcide began with initial tUmicity sieairig In the adratocy. The emltioa coninned at p sites thrg fied tal and gLications. L4 s kend frs thMese expenn=s helped direct our dkxu toward the develoment ofla seond geuion program.

Keywrxdx Zebra mual mouscidde, intake Maucturc uacrlbin& aMlnc salt of endotl and quaknauy sammnrnm MoWtd&

INTRODUCTION Zetca mwaiel hae betn d as far wA as, ew Oreazs, LA and a far 't as Oklahoma.

(Figur 1). Aditkinal Infatiof this orpnixsm is e d to codmie a a vy low rate. As an example, CG'bkCvW (Asian CLam) wm first ftcnd in the state of Wazhinim and can nw be fon i wca fiesh water aystezr in the US. Th spread of Aian car took nerly twerty years from the fte of t heir inroductio Bca= ct ra m se reent ntroductm into the North Am can wgat ys (within the lat tn Yas) plats and idUistral fili Were not pteparnd to hadthe pr ms aociated with their Inktaion. In Europk, indstri bave adopted modified dcsgn tha minlmze the coloniut pnvl= pn of zdxa mmL Due to the apdt xped involv mosENorth Amencan courpan are not We to modify exitting Ike structr at all pln fties.

Copyright 01998 by NACE Internationa. Requests forpermission to publish this manuscript In any form, in part orin whole must be made In writlng to NACE International. Conferances Division. P.O. Box 218340, Houston. Texas 77218-8340. The malerial presented and the views expressed in this paper are solely thoso of the authorts) and are not necessariy endorsed by the Assodatlon. Printed In the U.S.A.

Generally, Imh design changes arc most co efficiently Implemed during new costruc This is a rel dilemsa for failitics.

As reported in a varvey conducted by the New York Sea Grant publciliom Dpisa 2, a I extpe related to zba mussels at 339 hities totled

$69,070,780. IL additiontothe ilons fdollars ptonmnimizing zdramusel infesion, pasnts slouldered the additional risk of plugged safy relatedequipment valve sea.s and fire water systems. Tbe mean expcditure per aclity w.s $205,570. In some a. they alw incurred the aitional expens related to lost production due to pluggod scrons and bet exchanx=

equipment Zbra mussld infestatios also have caused municipal water spplir great difficulties in maitining sufficient wave spplies to thdr customes Chemical control f mollusk colonization has beixae the most accepted method of treatment Of thxs chlorine is th most commonly used moluacicd H vr, reglatory agad and companies ha expressed increased coDn5s over chlorinated organic compounds, fe oxdants and indirect trif-loamines' Thse chemicals can perist in the enviromen Storge and hanlin of lap quantities of chlorine are regulated under SARA Title m. Deftoification of chlorine is notd prior to discharge. Chlocination can also incr the corrosio potntial. Al of' these fctors cold lad to the ecter abandonment of chdore as an option.

A class of chemical known as quaternaly compounds (Quatz) is nw being used as an altative to chlori for conlrol f macrabauing Quats function by interkring with oxygen trner a the g membran of the zbra musuel. N4omy an S-24 hour continuous applicion of Quats is wed to disinfect distriution system piping several times during the mollusk brooding snL Co02 mainaind keping h size ofte zeb mu populationsch that they will no intorfe with the heat cmhange equpmenL Quats may need to be deactivated prior to disch , particularly In once through cooling qs M.

LABORATORY VERICATION OF QUATS AS A MOLLUSCICIDE In 1989. a coxnp hv research roect was begun to dvelop a IUnacide for industrial U9G A litt seurxd of the phyiology and bioloi vcs of D rzziena polymorpha was initiated A ebra ue farm was devDepe4 to Ob m usse U1ecimn and tosg vaiou poential mluacicides on then (See Figure 2)S.

Screening of quaternay ammoaium compounds and ther possible chemicals by Static RcCwal Studies w the b first Mp in the verification p Boca= of the icsua oS quatemnary aminommn compounds ainst Adan CUM CorbiCakr a quteraryamounim compound was evaluatedat an irstri faityalogLakeEre. A feld trdeterminddthattquatemary ammoiurn compounds wre ifeclive at the teotod concentration range (0.0 - 2.50 n*4l active) achievAng 100% motlality. B;ft=c we Uilized at this faility with zdim musses cdcimated to the plant intae war. Te water temperr during these series of lts was 22 C. A second series of tests werc perfood in the late fal wbho the water temperature had dropped. During this sees oftests noe chemi was needed to HUl the musss than in th firs seies ottests.' Due to the varying relts in the fied. it wai decided to verify and aempt to duplicate them results ne controlld laboratory coitions Thu deciio was made with the intention of registerng the quaternary ammonium compaoud as a mllusci M= l1boraty phas inwolved the coosuvWt= of the fiow-through test charnb=

(Figure 3).7 Tcsing of rznsc in a dynamic *ytnm like flow through te chabe belps stimlate biological activies in the umel In studie performed boh in laboratory and field appicaos,a consta Mf ofrehu water oive the mussels encouraged active filtr n Thbe testing of the munsselsa various concentrations and tenperalure hePs-oPtimiz the treatment strtegie and mTiniini the a unt of product used in the applcation. Qust dusae for zebra musel control is a fim otf water tnerature. As the water uoperaure decreases, 52412

the anxznt of Quats repirud to control the zebra mnsds is higher. At 220C, 0.25 mg/L active coKtul of didecyl dimdhyl m oum cmloride ac ed 100lY. mortality in 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months .

While at IS OC the same dose achieved 100% moitality in 240 burs By increasing the:

contmtion to 0.50 mglL actv cocintmatim of didecyl ducthiyl aiuunxiium chloride, the time required to aichiev 100% mortality at 221C was 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Using the ue dlooe and lowering the watm temp tur to 184C, resulted in an inC'eas fron 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months lo 120 bours in order to achieve 100% mortality (Figur 4)'.

Before the product cIld be used In the field, an effective mans odeactivating the product had to bcaddrescd sofbbtoicy wc y ad demosrated its tyto dwvate thc quat ay mociumcompound. In stdis peralbed in labdtoy uangdeionized wter 9 mg/l of bcntnite cay was n eodod to deaetivate 5 mgfl ofthe Quits product( Figure 5).9 In the el whr the sem w= hu u M concetaion oicaionk chage partices, amount ofbentoalte clay neddto deactivate the Quaft is lower.

AZcbra lMuslD fiionTnhikrwas constmacted (Figure 6).le'Ib trailerwas designed to be portabk and adf containd The trailer operates at rmte sites using e V from an afttahed lcticad nerator uit Bentoite clay I delivesrd tbwgh ahopper to auger which the clay dispers into an eductor that te= 273 m 3/day waterflow. The clay ulury is then introced to the discharge at this point Afkr i everl diffaet scenos in the 1boratoy, the product was taken to th tntigaig field for efmcy t at industrial sitcs.

LESSONS LZARNED No two industrial water distributio rstems ae alike. It is critical to inVestigate the entire ystmL Input should be gathered by all peting groups invlve Mollus conarol iues

- l Ive - r,cit - s . C3vrnmentxad amaaugeen.t -

Each group ade& to be cocmldtd and be in agrocmeat an the raultiplan . May faors ur invold in the desion to use a chemical for mollusk control. The four main fdors are the physical characteristics of the plant, the nature of the Chemical to bc applied economics and the frequency of alication" Afr these critr for zebra mus cont strategy had bee condr4, the molusclicide was a Wd at sevral indUstrilities. At ch fiity treged. more ait Wedge of cdat intake structures, as well a an increased underStanding of biology of the zebra mwels as it has adaptd to the North America. wwr wcuirtd Th strategy Ws modified accordingly at each site.

Cbeakal Applicafla ad Pant Db~str m Systm Coaskntow As previously ntiooed~it is important to thoroughly understand tbe system to be treate A study of distrutioa syutm diag wjl hp dtermine wht the Sim thma ofmusk infsto xists. But do not rely on plant bu int kr the wbole picture Updates and modificatd to eisng Iab amctures ar mot awas depicted on the blueprint Operators and mnance persowd may have the best kowledgcof s nnecation or deviations from the original systenm Potabic waterysem, eye wach sato, and showe should be circumvalted during applicat o f a chelical mollusktretment In sm cgses it isoncXa n ory to cither time the treatment wiUh Oa.e, wkwds, or during evaung hors to avoid conflic with the opeabon or vlilability o ohi systems in the plat 52413

It has also ben obsaerved that mollusk infestation within a ditribtinN system primarily affects the fist onelhird length ctp In our eperience, we hav rever sCen or heard of a discharge system had a plugging problcx due to mollusks Where cooling toirs are Intelgr to the operation of an industrial waler didribution system, it isagoodpractictoblwdown 1te tand minimI cksofconceaftbatiothe daypiorto applicatioof a Mollusk control program. Wen t atment Is started, the cooling tower blowdown should be shut off and the sstm dosed with the Qut at the desired concentration based on ystes m e Natual dectvtiowill oc due to lids n th system and cont with disftruction system wmc When chemical Leves meet discharge levels, the blowm valve is opened and normal operation it remed. Some Qusts tend to caue foam in cooling toweu It is important to cboo a do nte tha will kb c yt min;mi tb amount farngenerated It may be necesry to ha antifoam available at Icast the first timc a cooling to%= is trated in cam excessve amou= Offoam am genatedL Fnruwator systems had beca tratd usin a trat and soka method. The fatd end of the ystem su fwusM d while Quas was being added to the servi wae qe A rcsidual of Quats was measured usn an Colorimerc Defterination cfDidoqyldimcthylammonlum Chloride methoD 12 Wh . residUal Was found, t hydnt Is off and different lals Wr operated 7tis co0tinod untl the entire fire w tr t cotained tred water. The sytex is then allowed to sit for twnty-four hoss and then flusbed The key to effective Utraftent Isto maintain an active rcsidua of Qumt during fthp~recried treatment period while achieving tde desird conct tim In the cas of Do k tbe water, hemic must be coatinuall added to keep the rsidual at the desired levd. In the case of the firewatr yste, oc the reia lel s ach, the rt uis IyboW upand mantained withou the need for additional chemical.

Anoh km learned was bow to start up a treatment to gpt quick results with the optimum amount of cdmicaL Mnyplants hav tanks or amp Uta in varou parts of the aSStcm.

If thesebtakontain anm of wa that lMtim aslo , it is impont dose the are itC alonthe dayoftreattas theremu otf rystemis treated. In this anner the netiedtramtiont is teted at the rame tint. Alhoh It my sound insigWifiat, acscess or failure of an applicatin depends on reaching the effdctive redual as quiky as posibLe A trcat acbedul is Ms;cd to pv 0cCs and tbc potenil riU that the pAnt is willing to endr Some facilities chose to treat ooo per year at the eod of the breeding season, which is normally in September. Others slop the bcing tatment, but Ve twice later in the year. First treatment is right aer the peak vdig releas during the mummer, and the second treatrent is in the fall aflr velige numb r diminish It is impont to modntor both the adult and Vdlr pOPulati in the source water. ThIS ihoud be done continosy when wate temperature is abe 13IC Tbe prese of either settling adts c a khi densty ofvaigers win iathe need bce a tcaumeuL Currt industry procedares aoutine both moitoring protocos and sampling potowl. Monitming forjw kicor adult m ds on artificial wbstzates (coactc bcs, PVC) hould be cate at critical intakc structur Mmx than one monitoing site is rlcomm due to the variability of seting mudssls Monitoing for ve = the soure watcrooduip a knon amow mnt oplant water thrgh at kast a 40 micron plakon net with a specimen cup on the cad. Microsopic obevtion of tbe residual matrial wi allow dtmi ofthe umbr of velirn per unit volume of water. Tracking this dat will mr l the trends inbreeding activity that will be useful in timing zcbra muisW t nt aPpCieAtLo 3 524/4

In cm plant, z1zbra msel shs 'wefiymd in beatCexhanger tm when mintenance Personne wuer working Ca the echangm. Mitzu Personnel fluabed the sbells otit ofthe "ym When, the inpparanci of =bra inussel sbells began to Incroa at this plant. the plant persoard decided to dose a mollhuidd One day aftedrbt tredmax wn appl, the plant persau imelt wrm uprind when a slug of =bra musd tisu -limed up crkitial beat ectcangers in the plit and ficc an egwy cxlage. The mater was cean up and the plt wa pat b on e. Withm, anoe 241w period, the hot chazgers we cagain ftled. but Ws time by zfta mussel die~s. The two outages cmisod the plant to l= apprxit*ly one million dollan in los pnxhactio tin and woodse dean up cods.

The thoory behind diive peiodic Qua teatmnts Jis that cam a di5tRxti rier i disneed or mu l fie. it is kept ean by klling off nxilasicolonies beoe they grow to proportions that would plug critca eqamxpmz in a water diatriouiicii ' m One a system is dlean, only veligms ar linxuced into the phAaion a cotinciul badis daring the broeding ~ci Well-timed Utrueametswil kil the vdl~ea and issu a clean system.

Moitrigthe zeb nwuw~pp~atialon Isthkeyfcr the iiial ftxea~t. Irnmediat reactics~ to the prsnmwm of the organism can help elimirt netto rbes Temperatusre As a part of the zooitoring protocoo, a log of the cuixrutiro: water temperature sbould be maintafned. It hus benourczperiew that water tempmrture is an important criterion for ~efiacy ofadchmical trmatment prograin Zebra ure lmiuntbheactilyhiNphcing in orerfor the chemica to do Its job,. At wate tempeatures below 16 11r the activity of ebra =wsels ulow dramaticW4y. Although chemica treatment can still accomplish the dosired efet w=ra mussel control will require mmr chenilcal aud/or lonser UtsetmenL The saine appliatio that would tak 24 booms at tempeaIure above 16 IC might take as long s3 daysto yieldthe ameresdutsblow16'C waterterpemtw'e hs extceded=&ctmerntim WiIeraenn the cmof tratment.

Waterd Velcity In additionto tempcatm~cwatrvelocity Safcs zebra mumlcolocLzuioa Zebmamussels preferwater ow rate 1.5 n/Scc cikiss Ccdooiztku edfwater sys with awatr velocity oar 1.5 rn/ are rar Intak for&W grew Lad qytm with wpate vilodika ls than 1.5 /ec a high roek ar 1s.el It has b=n d~obrvd that zebra nuissels ofte nted to coloniz distebston, systc to a greater degree thin thk urrounding am trea *m; and l A coatatudr flow Along with e7 n lad concentrated in a = a Wll p vvid6 the zebra, mussel with a perfect breding Mce main Circuatin water in soine came Isno a co~n becas the waer Wiocity is high anogh to daoourago zbra musse attachmien For e anmI, coossldcr a water flow rate In the atr lopat 0902 m3lday whil the lm aincrvuating water now rate Is 2,725,500 plat srvce m/lday In thissitutia an adqat evice wate trcatmnict might he Quats caiiiirotisly applied at 1.5 mg/i activc f*3r24 houms No deactivation octhe Cliemical was nedled due to the

,sufficiet dilution w~t& the main circlulain wAte wteRM. The resides value Of the Qust in the dischar was'ellbelow wxatrqualit:y ei standards raviroensa Fateand DeaictivtOw Sincie Quat bhra a cationic carg, it is gnally acptod tbat fth molluacidal mone of action ivolves; congelation of n on IM zebra mud gil Mm nding or the QUats to the 524U5

gill will shut down cctin biochemical raction in the zebra immel (external membrane bound co-czymes and resplrtion).

The afflnity for Quats to adhere to the turcs of gills is the primary conc=r in effluent WLdeM In order to prcb m tiis mode of action in non-ptr d organisms, bmtocite clay is added to the dichag water. Th clay has aulightly anonic char on te sarfvc and ends to ndl when added to . Theclay ct likoM a q V ad adsot amy =mining Quat, The adsorption onto the clay the Quat unamailb to Dtch to the gs Of o-targete

Extend" studies wo. condmocbd on tbh cdy ad Quats complw Adsorption ad desoition sPudi showedthatheQa oained c xed to the y afterdi a into tebetlc roinme Bimilility and degradotio with acclimated and nacl; becicria have shown that te Qmaawerestillavailable fr bodegrnadatonbut ata reducd lveL" Ofher studes including dispersa system evaluatimn xisk assessent and degrdatioa using natura sedime~nt concldd tham the clay.4uats complex was stablek and had no advese effect on the evronmemt.

- In addition to theme togM ace txici work was tae during tatmet application. Results Jima all facilities tested showed no rtsidua toxkcit ont daphrua and fifthad minnows in either acutc ordchrok tes.

- Decvaion ofthe csica is a snar part of the tatment. Speiaizddcay fbod equipment is used to delic apreibed ma caylur tO yth dichargstream. Cnstant monigig if the clay feed is neded to insure continuos feed of the cly to the disharge system Clay foodr art at each outfall and cookised with the curent analytical procedurs, =Ake the Quats ucatmt pwgram equipaent and labor intersh.

In additionto thect reated to decivation atthe Qousompanie art still uncornfotabe with the Idea ofadding clay to deactvatc the chemical. In order to elimiate the ue of clay in the process, a search for an altermative treatment was instituted.

A SECCOND GENECRATION CHMICAL APPROACH Quata were first umcd to control Asian clam (Cowbica~ew) and niormis withi coolig tower systems."' It was logkda that the use of Qualm Cod be extended to control of the zebra musvAls Even though Quat chemistry bas be= shown to biodegrade: in the c"n'ircinnt and no accumlaste, many users would lake to ayoid the use of bentodwt clay for deactivation. Inhtstry has wiled for a mort proactin vetreatnt protocol for veligr control than the curret periodic treatment process. Contiing research into alterate cherumisre has resulted in the development ijfa now chemica approach. WIth a nmbc large need for Zebra Mussel control and the desir'efor laternate approaceb for conitrol, the iearc began fora second generation. MOlUacicide.

A combinatlonctcndOtball ndfiming amine c~nnrvillyknwn asEVAC-A')(a-in ash of endotafl) was identfied asan almmteraieto exiing chemitries The amin saltaifmenohall baa several whadvatges that positio ituas a scond genertion appVah to mollask carntrol. isted below arethemajOrdiffaencesbewen theamIn sak tredo~thall and Qucherismy.

mA440hy se onwudl]

Obetcclyf O:Id as ot

IThe amn salt of ndothalcan be applidwithtaitthe --:1for deacivaionwith bcaionite clay

Periodic trcatments ofonly Sbours for the aMin lti en(Cd0(thAU00mPare welWith 10- to 24-hr appLications for Qua e istere demarkofE to dkcheNorth America, Ie EVACrM is M N.Ndimcthyhak SflWC)X21t if endothallE 7-=.62j.1) h43.**>4~Ii Amid 524/6

T mine salt cianSothal can be apUed on a ruiza wbedi thruhout the brooding nson for contrnl ligc.

7U czmiro txl fIe of the amin salt of dohal s better than Quats, iho its half-life is only 24 bours, while the a4 lf of Quats is 2 das.

In rooent field applyations, th aminw salt of cdall perfonned cffecid yagaist zebra nusl& Thre conoostration lewsO w kstad Bkfficay1 ults axshown Figur 7. In thc first bais of test,, I 3 act amin salt of endothall ffilvcy killed all the rImJ ls in a 24-bour cxpowe. The mext us were perkmed uming 2 mWl active amn nit of cndothalL Within hounn cheical feed, 90% f themuss wt dead or not Iabv e chemical feedwasdiscontinned. A cosuanflow rrice wdawasmrint-ined ethetestd usads witl ndothall. 10 boars, a=llinls remether dead or ot reoive.

TUe lad scries of tests c doe at 5 mjf active amin Wlt of eadotbhl. Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months the stat of cbcaical feed, 85% of the mmd wo dead or not rexodiD& Chemcal feed continued until al muwnls we dead or not responding (Figure 8). 2 i t at fcoda l cbemistyrqra theE irt FRA 4 rv podt to tc mollusk coetrDl to the =t eve. The molxdal mode ofactim of ts product is not completely undestood The proa m to me the Sil ne snesm of the mmiluhsk which interferes with oxyse tznsfer. Te xmim sat alao baa a MA aity with surfce It ad to pipng WAls and ymeaded soUdS in waler dxftzxeios* At normal use cfccro, the prodtct does not cdst in dicare wae in sifiant smomt.

Con ol veliger ispoibl ithoot thc useofoxidiz nt dcis and the h associated with oxidanMt In a study condwWcby a power genedrtig comrnnY. sefttlment of yeligers decreased by 66% 217 dlinatjoa of ft nerd for 6CxifCato bybenalocte Clay smplif the applicati of te ami sat of adotall. This is a step in the right dirc and buil on lessons lared fro epiene pined with Qoat applcx s CONCLUSION Ztbra mussel cotr cosidmo ar he lo oWa. New cwostruction wil have to tke Molusk iiling io eccann in te sin of edistribiin systemt. Me8 syts VM cond to rquir monu* aebmnt methos particulary m t zebma -se anp mpands A reben cotcrol m sttaterntbe devckcdta Ihe peation and safety goals of pant OWrs an qpratm. Te 9eme fo zlumte coctrot ucwtbds coob e. While currnt traQemt mvoe Qumat d dokne. a =w sllusdciie bas b= devloped. 1b deVe men afthis Dnw Idcld& was; bid on fed cxcriences Qan seific nw& unique to zebra mu, control in industrial applications.

524/7

Fiu 1 -Diwluio map of =ra munel colocizatio Average pH 7.85 Chlorine Residual 0 Mng/L Dissolved Oxygen >6 mgfL Total Solids 170-390 mgfL 1 Calciumh 30-50 mgfL Potassium <0.50 mg/L Hol Stciizaionil Tank Tank Figur= 2 - Ztba Mond Hdding Tank 524/8

iocide Feed Tank

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Mmd 524111

MATERIAL SAFETY DATA SHEET

.ALCO - PRODUCT

. . :: . .:EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC

1. CHEMICAL PRODUCT AND COMPANY IDENTIFICATIONl PRODUCT NAME: PCL-401 APPLICATION: WATER TREATMENT COMPANY IDENTIFICATION: Nalco Company 1601 W. Diehi Road Naperville, llinois 60563-1198 EMERGENCY TELEPHONE NUMBER(S): (800) 4249300 (24 Hours) CHEMTREC NFPA 704M/HMIS RATING HEALTH: 0/1 FLAMMABILITY: C/1INSTABILITY: 0/0 OTHER:

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

2. P COMPOSITIONINFORMATION ON INGREDIENTS Based on our hazard evaluation, none of the substances in this product are hazardous.

3.O l HAZARDS IDENTIFICATION l

- EMERGENCY OVERVIEW**

CAUTION May cause irritation with prolonged contact.

Do not get in eyes, on skin, on clothing. Do not take internally. Use with adequate ventilation. In case of contact with eyes, rinse immediately with plenty of water and seek medical advice. After contact with skin, wash immediately with plenty of water.

Wear suitable protective clothing.

May evolve oxides of carbon (COx) under fire conditions. May evolve oxides of nitrogen (NOx) and sulfur (SOx) under fire conditions.

PRIMARY ROUTES OF EXPOSURE:

Eye, Skin HUMAN HEALTH HAZARDS - ACUTE:

EYE CONTACT:

May cause irritation with prolonged contact.

SKIN CONTACT:

May cause irritation with prolonged contact.

INGESTION:

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

Nalco Company 1601 W. Diehl Road

Naperville, Illinois 60563-1198 (630)305-1000 1/9

:MATERIAL SAFETY DATA SHEET NALCO:: :PCL-401 PRODUCT EMERGENCY TELEPHONE NUMBER(S)

- .(800) 424-9300 (24 Hours) CHEMTREC INHALATION:

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

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.

4. 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. If symptoms 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.

5. FIRE FIGHTING MEASURES FLASH POINT: None 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. May evolve oxides of nitrogen (NOx) and sulfur (SOx) 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.

Nalco Company 1601 W. Diehl Road

Naperville, Illinois 60563-1198 (630)305-1000 2/9

MATERIAL SAFETY DATA SHEET PRODUCT NA A..

rn..

.. _ PCL-401 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC

6. ACCIDENTAL 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.

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.

7. HANDLING AND STORAGE HANDLING:

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

STORAGE CONDITIONS:

Store the containers tightly closed.

SUITABLE CONSTRUCTION MATERIAL:

PVC, Buna-N, HDPE (high density polyethylene), Polyurethane, Polypropylene, Polyethylene, Stainless Steel 304, Compatibility with Plastic Materials can vary; we therefore recommend that compatibility is tested prior to use.

UNSUITABLE CONSTRUCTION MATERIAL:

Brass, Hypalon, Viton, Neoprene, EPDM

8. EXPOSURE CONTROLS/PERSONAL 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.

HAND PROTECTION:

Neoprene gloves, Nitrile gloves, Butyl gloves, PVC gloves Nalco Company 1601 W. Diehl Road

Naperville, Illinois 60563-1198 (630)305-1000 319

MATERIAL SAFETY DATA SHEET

.A4

...........I....... ..... . . PRODUCT PCL-401 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC SKIN PROTECTION:

Wear standard protective clothing.

EYE PROTECTION:

Wear chemical splash goggles. Wear chemical splash goggles.

HYGIENE RECOMMENDATIONS:

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

9. l PHYSICAL AND CHEMICAL PROPERTIES PHYSICAL STATE Liquid APPEARANCE Light yellow ODOR None SPECIFIC GRAVITY 1.16-1.20 SOLUBILITY IN WATER Complete pH () 4.2-5.0 VISCOSITY 20- 160 cps FREEZING POINT 25 F /

VAPOR PRESSURE Same as water VOC CONTENT 0.00 % EPA Method 24 Note: These physical properties are typical values for this product and are subject to change.

10. STABILITY AND REACTIVITY STABILITY:

Stable under normal conditions.

HAZARDOUS POLYMERIZATION:

Hazardous polymerization w4ll not occur.

CONDITIONS TO AVOID:

Freezing temperatures.

MATERIALS TO AVOID:

Strong oxidizing agents HAZARDOUS DECOMPOSITION PRODUCTS:

Under fire conditions: Oxides of carbon, Oxides of nitrogen, Oxides of sulfur

11. TOXICOLOGICAL INFORMATION The following results are for the product.

Nalco Company 1601 W. Diehl Road

Naperville, Illinois 60563-1198 (630)305-1000 419

MATERIAL SAFETY DATA SHEET PRODUCT

.. . . . . . . . ...S+...

PCL-401 EMERGENCY TELEPHONE NUMBER(S)

... .... .. ... .... (800) 424.9300 (24 Hours) CHEMTREC ACUTE ORAL TOXICITY:

Species LD50 Test Descriptor Rat 5 g/kg Product Rating: Non-Hazardous ACUTE DERMAL TOXICITY:

Species LD50 Test Descriptor Rabbit 2 g/kg Product Rating: Non-Hazardous SENSITIZATION:

This product is not expected to be a sensitizer.

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).

12. ECOLOGICAL INFORMATION ECOTOXICOLOGICAL EFFECTS:

The following results are for the product.

ACUTE FISH RESULTS:

Species Exposure LC50 Test Descriptor Rainbow Trout 96 hrs 4,900 m/1 Product Bluegill Sunfish 96 hrs > 5,000 mg/l Product Rating: Essentially non-toxic ACUTE INVERTEBRATE RESULTS:

LSpecies l Exposure l LC50 l EC50 l Test Descriptor Daphnia magna -148 hrs 2,800 m/l 7 Product Rating: Essentially non-toxic MOBILITY:

The environmental fate was estimated using a level III fugacity model embedded in the EPI (estimation program interface) Suite TM , provided by the US EPA. The model assumes a steady state condition between the total input and output. The level III model does not require equilibrium between the defined media. The information provided is intended to give the user a general estimate of the environmental fate of this product under the defined conditions of the models. If released into the environment this material is expected to distribute to the air, water and soil/sediment in the approximate respective percentages; Air I Water I Soil/Sediment

} <5% @ 30 - 50% 1 50 - 70%

The portion in water is expected to be soluble or dispersible.

Nalco Company 1601 W. Diehl Roads Naperville, Illinois 60563-1198 (630)305-1000 519

MATERIAL SAFETY DATA SHEET PRODUCT

....... ....*.. PCL-401 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC BIOACCUMULATION POTENTIAL This preparation or material is not expected to bioaccumulate.

If released into the environment, see CERCLA/SUPERFUND in Section 15.

13. l DISPOSAL CONSIDERATIONS I 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. I TRANSPORT INFORMATION I 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 I Hazard Class may vary by packaging, properties, and mode of transportation. Typical Proper Shipping Names for this product are as follows.

LAND TRANSPORT:

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

Proper Shipping Name: PRODUCT IS NOT REGULATED DURING TRANSPORTATION MARINE TRANSPORT (IMDG/IMO):

Proper Shipping Name: PRODUCT IS NOT REGULATED DURING TRANSPORTATION

15. l REGULATORY INFORMATION I 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.

CERCLAJSUPERFUND, 40 CFR 117,302:

Notification of spills of this product is not required.

Nalco Company 1601 W. Diehl Road

Naperville, Illinois 60563-1198 (630)305-1000 6/9

.. ... g .. .. . MATERIAL SAFETY DATA SHEET PRODUCT

. . ... .. .. ... .... . . . ........... PCL-401

.. .... ... . . . ... EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC I

SARANSUPERFUND 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 Ust 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 116.4 / 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.

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.

Nalco Company 1601 W. Diehl Road

Naperville, Illinois 60563-1198 (630)305-1000 7/9

MATERIAL SAFETY DATA SHEET PRODUCT

-.............. C: ......

.. .... . ... .. . . ...... ... .. PCL 401 EMERGENCY TELEPHONE NUMBER(S)

(800) 424.9300 (24 Hours) CHEMTREC 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.

INTERNATIONAL CHEMICAL CONTROL LAWS AUSTRALIA All substances in this product comply with the National Industrial Chemicals Notification & Assessment Scheme (NICNAS) and are listed on the Australian Inventory of Chemical Substances (AICS).

EUROPE The substances in this preparation have been reviewed for compliance with the EINECS or ELINCS inventories.

THE PHILIPPINES All substances in this product comply with the Republic Act 6969 (RA 6969) and are listed on the Philippine Inventory of Chemicals & Chemical Substances (PICCS).

116. lOTHER INFORMATION I 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.

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, WashingtQn, 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), Ariel 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.

Nalco Company 1601 W. Diehl Road - Naperville, Illinois 60563-1198 (630)305-1000 8/9

.s ..... ... ......

MATERIAL SAFETY DATA SHEET PRODUCT

~.*. -. -. *....

-. -....-. . .... PCL-401

...... EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC 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: 02/26/2004 Version Number: 1.4 Nalco Company 1601 W. Diehl Road - Naperville, Illinois 60563-1198 (630)305-1000 9/9

I Or ON-SITE EXPERT PRODUCT BULLETIN PCL-401 Scale Inhibitor PRODUCT BENEFITS

Stable In Chlorinated Water- There is no need to increase dosage during periods of chlorination.

Prevents the Formation of Calcium Phosphate C) 0

-Scale inhibition under severe conditions of

Contains No Heavy Metals - Contains no zinc or calcium phosphate supersaturation is cost- chromate. It can be used in systems where current effectively attainable with TRC-233'. The deposi- discharge regulations prohibit the use of heavy tion of calcium phosphate scale from orthophos- metals.

phate present in the cooling water system, either as

Convenient to Use - Supplied as a liquid and can the result of the inorganic phosphate corrosion be fed directly from the shipping container or bulk control practice or from orthophosphate in the storage tank. The need and associated costs for make-up, is effectively controlled by a threshold premixing chemicals is eliminated.

mechanism. Control of calcium phosphate is achieved without the need for costly pretreatment, undesirable pH depression and excessiveblowdown. GENERAL DESCRIPTION

Inhibits Scale Formation in High pfllAlkalinity PCL-401, based on pHreeGUARD" technology, is a Water - Formulated to control potential scaling liquid product formulated to control the deposition of problems with calcium phosphate and low to calcium scales in once-through and recirculating moderate degrees of calcium carbonate super- cooling water systems. The product contains the saturation scaling. Typical acid feed rates are copolymer TRC-233. It is particularly effective for greatly reduced, and in many systems, acid feed controlling the precipitation of calcium phosphate.

may be eliminated entirely. PCL-401 is a dispersant for suspended material such as

Complements Good Corrosion and Biological silt and metal oxides. This dispersant action maintains Control - For systems in which zinc is still the insoluble material in suspension, facilitating its permissible for use as a corrosion inhibitor, removal from the system. For a general description of PCL-401 can be used to complement heavy metal the typical chemical and physical properties, see the corrosion control programs without pH control. PCL-401 Material Safety Data Sheet.

Deposits provide media for the propagation of biological growth and cause localized corrosion of PATENTS metal surfaces. PCL-401 prevents the formation of These products are covered under U.S. Patents deposits and disperses suspended solids. Cleaner 4,552,665 and 3,709,816.

surfaces deter further biological growth and assure better performance of corrosion inhibitors.

Iron Oxide Deposit Control - Functions as a (Continued on Reverse Side) dispersant keeping metal oxides and silts fluidized, minimizing deposition in equipment and on heat exchanger surfaces.

NALCO CHEMICAL COMPANY One Nalco Center

Naperville, Illinois 60563-1198 by N.:Lco Registered Trademarks of Naloo Chemical Company 02000 Naloo Chemical Company AN1 Rights Reserved pHreeGUARD and TRC-233 are Registered Trademarks o Calgon Corporation Printed in U.S.A 11-00 A A_

NALCO MATERIALS COMPATIBILITY STORAGE AND HANDLING Compatible materials of construction for bulk storage The recommended rminimum storage temperature for tanks include high density, low density, or cross- PCL-401 is within the range of 15-20'F. Best if used linked polyethylene, fiberglass with isophthalic or within'l2 months from the time of receipt. If product bisphenol resins, epoxy phenolic or vinylester lined freezes, it does not lose its integrity. Restore for use steel, 304 or 316 stainless steel.Compatible materials by warming slowly until product thaws; agitate.

for pump "liquid ends" and piping include polyethyl-ene, polypropylene, PVC, 304 or 316 SS, Viton, Buna-N, Teflon, neoprene, Hypalon, Kynar. SHIPPING PCL-401 is shipped to on-site storage facilities via bulk.

CONTROL TESTING DOT Hazardous Class Not Restricted In recirculating waters, product performance is DOT Proper Shipping Name Not Restricted ultimately confirmed by equipment inspection and/or Not Applicable UN Number by monitoring heat transfer. In once-through waters, product dosages are generally below detectable limits.

Product feed rates are adjusted based on water quality REMARKS and system flow.

If you need assistance or information, please call your nearest Nalco representative, or our Naperville office FEEDING AND DOSAGE at 630-305-1000. For more news about Nalco, visit our website at www.nalco.com.

PCL401 should be fed at a point in the system where turbulent flow will assure good mixing. The product For Medical and Transportation Emergencies may be fed either neat or diluted and must not be involving Nalco products, call (24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months response):

mixed with other water treatment chemicals prior to (800) I-M- ALERT (800-462-5378).

feeding. Dosage rates will vary depending upon system parameters and water quality. Your Nalco representative will assist you in establishing a treat-ment program to fit your specific cost performance criteria.

MATERIAL SAFETY DATA SHEET PRODUCT o, ONDEO 6s Nalco PCL-222 EMERGENCY TELEPHONE NUMBER (800) 424-9300 (24 Hours) CHEMTREC

1. I CHEMICAL PRODUCT AND COMPANY IDENTIFICATION PRODUCT NAME: PCL-222 APPLICATION: SCALE INHIBITOR COMPANY IDENTIFICATION: ONDEO Nalco Company ONDEO Nalco Center Naperville, Illinois 60563-1198 EMERGENCY TELEPHONE NUMBER: (800) 424-9300 (24 Hours) CHEMTREC NFPA 704M/HMIS RATING HEALTH: 0/1 FLAMMABILITY: 111 REACTIVITY: 0/0 OTHER:

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

2. l COMPOSITIONIINFORMATION ON INGREDIENTS Based on our hazard evaluation, none of the substances In this product are hazardous.

3. l 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. May evolve oxides of phosphorus (POx) under fire conditions. May evolve oxides of nitrogen (NOx) and sulfur (SOx) under fire conditions.

PRIMARY ROUTES OF EXPOSURE:

Eye, Skin HUMAN HEALTH HAZARDS - ACUTE:

EYE CONTACT:

May cause irritation with prolonged contact.

SKIN CONTACT:

May cause Irritation with prolonged contact.

INGESTION:

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

MATERIAL SAFETY DATA SHEET 0-0D PRODUCT 0,6 N E V ac PCL-222 EMERGENCY TELEPHONE NUMBER (800) 424-9300 (24 Hours) CHEMTREC INHALATION:

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

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.

4. l FIRST AID MEASURES I 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:

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

INHALATION:

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

NOTE TO PHYSICIAN:

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

5. l FIRE FIGHTING MEASURES I FLASH POINT: >200IF1>93*C( )

EXTINGUISHING MEDIA:

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

FIRE AND EXPLOSION HAZARD:

May evolve oxides of carbon (COx) under fire conditions. May evolve oxides of phosphorus (POx) under fire conditions. May evolve oxides of nitrogen (NOx) and sulfur (SOx) 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.

ONDEO Nalco Company ONDEO Nalco Center' Naperville, Illinois 60563-1198 (630)305.1000 2/8

Q 0 MATERIAL SAFETY DATA SHEET -

o .. ONDEO PRODUCT a Naco PCL-222 EMERGENCY TELEPHONE NUMBER (800) 424-9300 (24 Hours) CHEMTREC

6. l ACCIDENTAL RELEASE MEASURES I PERSONAL PRECAUTIONS:

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.

Do not touch spilled material. Ventilate spill area If possible.

METHODS FOR CLEANING UP:

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. SMALL SPILLS: Dispose of material in compliance with regulations Indicated In Section 13 (Disposal Considerations).

ENVIRONMENTAL PRECAUTIONS:

Do not contaminate surface water.

7. l HANDLING AND STORAGE HANDLING:

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

STORAGE CONDITIONS:

Store the containers tightly closed.

8. I 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.

HAND PROTECTION:

Nitrile gloves, Butyl gloves, PVC gloves, Neoprene gloves SKIN PROTECTION:

Wear standard protective clothing.

EYE PROTECTION:

Wear chemical splash goggles.

ONDEO Nalco Company ONDEO Nalco Centers Naperville, Illinois 60563-1198 (630)305-1000 3/8

MATERIAL SAFETY DATA SHEET PRODUCT itNatco PCL-222 EMERGENCY TELEPHONE NUMBER (800) 424.9300 (24 Hours) CHEMTREC HYGIENE RECOMMENDATIONS:

Keep a safety shower available. If clothing Is contaminated, remove clothing and thoroughly wash the affected area.

Launder contaminated clothing before reuse. Keep an eye wash fountain available.

9. l PHYSICAL AND CHEMICAL PROPERTIES PHYSICAL STATE Liquid APPEARANCE Clear ODOR Sharp SPECIFICGRAVITY 1.3 @ 77-F/25QC DENSITY 10.8 lb/gal SOLUBILITY IN WATER Complete pH (100 %) 4-5 VAPOR PRESSURE Same as water EVAPORATION RATE Same as water

10. lSTABILITY 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 oxidizers (e.g. chlorine, peroxides, chromates, nitric acid, perchlorate, concentrated oxygen, permanganate) may generate heat, fires, explosions and/or toxic vapors. Contact with strong alkalies (e.g. ammonia and Its solutions, carbonates, sodium hydroxide (caustic), potassium hydroxide, calcium hydroxide (lime), cyanide, sulfide, hypochlorites, chlorites) may generate heat, splattering or boiling and toxic vapors.

HAZARDOUS DECOMPOSITION PRODUCTS:

Under fire conditions: Oxides of carbon, Oxides of phosphorus, Oxides of nitrogen, Oxides of sulfur Ill. I TOXICOLOGICAL INFORMATION I 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 Govemmental Industrial Hygienists (ACGIH).

ONDEO Nalco Company ONDEO Nalco Centers Naperville, Illinois 60563-1198 (630)305-1000 418

MATERIAL SAFETY DATA SHEET 0 0 PRODUCT 0 PCL-222 EMERGENCY TELEPHONE NUMBER (800) 424-9300 (24 Hours) CHEMTREC

12. ECOLOGICAL INFORMATION ECOTOXICOLOGICAL EFFECTS:

No toxicity studies have been conducted on this product.

MOBILITY AND BIOACCUMULATION POTENTIAL High phosphate levels In surface water can cause eutrophication with subsequent algal blooms and oxygen depletion.

If released Into the environment, see CERCLAJSUPERFUND In Section 15.

13. l DISPOSALCONSIDERATIONS 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. I TRANSPORT INFORMATION l l 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: ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S.

Technical Name(s): SODIUM PHOSPHATE, TRIBASIC UN/ID No: UN 3082 Hazard Class - Primary: 9 Packing Group: IlI Flash Point: > 93 *C / > 200'F DOT Reportable Quantity (per package): 40,000 lbs DOT RQ Component: SODIUM PHOSPHATE, TRIBASIC AIR TRANSPORT (ICAO/IATA):

Proper Shipping Name: ENVIRONMENTALLY HAZARDOUS SUBSTANCE, LIQUID, N.O.S.

Technical Name(s): SODIUM PHOSPHATE, TRIBASIC UN/ID No: UN 3082 Hazard Class - Primary: 9 ONDEO Nalco Company ONDEO Nalco Center' Naperville, Illinois 60563-1198 (630)305-1000 5/8

MATERIAL SAFETY DATA SHEET

0. 0' 0 ,filing

-1:1.0 IDNDEO PRODUCT 6

11 .6 Nalco PCL-222 EMERGENCY TELEPHONE NUMBER (800)424-9300(24Hours) CHEMTREC Packing Group: IlIl IATA Cargo Packing Instructions: 914 IATA Cargo Aircraft Limit: NO LIMIT (Max net quantity per package)

MARINE TRANSPORT (IMDG/IMO):

Proper Shipping Name: PRODUCT IS NOT REGULATED DURING TRANSPORTATION

15. l 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.

CERCLAISUPERFUND, 40 CFR 117, 302:

This product contains the following Reportable Quantity (RQ) Substance. Also listed is the RQ for the product. If a reportable quantity of product is released, it requires notification to the NATIONAL RESPONSE CENTER, WASHINGTON, D.C. (1-80D-424-8802).

RO Substance RQ Sodium Phosphate, Tribasic 40,000 lbs 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 1910.1 200.

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 chemical substances In this product are on 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:

This product contains the following substances listed In the regulation:

Substance(s) Citations Sodium Phosphate, Tribasic: Sec. 311 ONDEO Nalco Company ONDEO Nalco Centers Naperville, Illinois 60563-1198 (630)305-1000 618

MATERIAL SAFETY DATA SHEET PRODUCT S

AONDEO V Nalco PCL-222 EMERGENCY TELEPHONE NUMBER (800)424-9300(24Hours) CHEMTREC 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 11Ozone 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.

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.

16. l OTHER INFORMATION 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., (Arlel 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.

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.

ONDEO Nalco Company ONDEO Nalco Center- Naperville, Illinois 60563-1198 (630)305-1000 7/8

MATERIAL SAFETY DATA SHEET o vik-I ONDEO PRODUCT v X4 Natco PCL-222 EMERGENCY TELEPHONE NUMBER (800)424-9300(24Hours) CHEMTREC 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), Ariel 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: 06105/2000 Replaces: 04112/1999 ONDEO Nalco Company ONDEO Nalco Center* Naperville, Illinois 60563-1198 (630)305-1000 8/8

Nalco Company 1601 W. Diehl Rd.

N"NALCO (630) 305-1000 Naperville, Illinois 60563-1198 U.S.A.

18 January 2005 To Whom It May Concern:

Thank you for your interest in PCL-222. This product contains the following components:

Substance Name CAS Number Percent (wt)

Sodium bisulfite 7631-90-5 0.2649 Sodium polyphosphate 68915-31-1 13.88 Sodium sulfate 7757-82-6 0.042 Waler 7732-18-5 58.502 Monopotassium phosphate 7778-77-0 15.57 Dipotassium phosphate 7758-11-4 2.857 Acrylic acid, polymer with sodium amps, sodium salt 37350-42-8 8.8842 This compositional information for PCL-222 is considered proprietary by our company. It is being released with the expectation that it will be viewed only by those employees of your Company that have a need to know.

If you have any further questions about PCL-222 or other Nalco products, please call me at 630-305-2578.

Sincerely, Kevin M Cheatham Marketing Development Manager

MATERIAL SAFETY DATA SHEET

. . . . . . . ... . . PRODUCT 73551 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC

1. I CHEMICAL PRODUCT AND COMPANY IDENTIFICATION PRODUCT NAME: 73551 APPLICATION: DEPOSIT PENETRANT COMPANY IDENTIFICATION: Nalco Company 1601 W. Diehl Road Naperville, Illinois 60563-1198 EMERGENCY TELEPHONE NUMBER(S): (800) 424-9300 (24 Hours) CHEMTREC NFPA 704M/HMIS RATING HEALTH: 0/1 FLAMMABILITY: 1/1 INSTABILITY: 0/0 OTHER:

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

2. l COMPOSITION/INFORMATION ON INGREDIENTS Based on our hazard evaluation, none of the substances in this product are hazardous.

3. l 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:

May cause irritation with prolonged contact.

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.

Nalco Company 1601 W. Diehl Road Naperville, Illinois 60563-1198 (630)305-1000 1/8

::: :::-MATERIAL

.... SAFETY DATA SHEET w xs~goPRODUCT 73551 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.

4. 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 waterto drink. If symptoms develop, seek medical advice.

INHALATION:

Remove to fresh air, treat symptomatically. If symptoms 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.

5. I FIRE FIGHTING MEASURES FLASH POINT: > 400 'F / > 200 `C ( COC )

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.

6. l ACCIDENTAL RELEASE MEASURES l 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.

Nalco Company 1601 W. Diehl Road

Naperville, Illinois 60563-1198 (630)305-1000 218

MATERIAL SAFETY DATA SHEET PRODUCT 73551 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.

7. l HANDLING AND STORAGE I 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.

8. l EXPOSURE CONTROLS/PERSONAL PROTECTION l 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.

HAND PROTECTION:

Neoprene gloves, Nitrile gloves, Butyl gloves, PVC gloves SKIN PROTECTION:

Wear standard protective clothing.

EYE PROTECTION:

Wear chemical splash goggles.

HYGIENE RECOMMENDATIONS:

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

9. PHYSICAL AND CHEMICAL PROPERTIES PHYSICAL STATE Liquid Nalco Company 1601 W. Diehl Road

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

MATERIAL SAFETY DATA SHEET

...A......

L.C-,

sr -'s PRODUCT 73551 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC APPEARANCE Clear Colorless ODOR None SPECIFIC GRAVITY 0.99 - 1.03 @ 77 0F /25 -C SOLUBILITY IN WATER Complete pH (100 %) 6.6 -7.0 Note: These physical properties are typical values for this product and are subjectto change.

10. I STABILITY AND REACTIVITY STABILITY:

Stable under normal conditions.

HAZARDOUS POLYMERIZATION:

Hazardous polymerization will not occur.

CONDITIONS TO AVOID:

Freezing temperatures.

MATERIALS TO AVOID:

None known HAZARDOUS DECOMPOSITION PRODUCTS:

Under fire conditions: Oxides of carbon

11. TOXICOLOGICAL INFORMATION The following results are for the polymer.

ACUTE ORAL TOXICITY:

Species LD50 Test Descriptor Rat 2,300- 16,000 mg/kg The following results are for the polymer.

Rating: Non-Hazardous 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

12. l ECOLOGICAL INFORMATION I ECOTOXICOLOGICAL EFFECTS:

Nalco Company 1601 W. Diehl Road

Naperville, Illinois 60563-1198 (630)305-1000 4/8

. . . . . .. . . . . .. . . . .. . MATERIAL SAFETY DATA SHEET C7:'-'W A. PRODUCT

-10 73551 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC The following results are for the product.

ACUTE FISH RESULTS:

Species Exposure LC50 Test Descriptor Rainbow Trout I 96 hrs l > 1,000 mg/I IProduct Bluegill Sunfish 96 hrs > 1,000 mgA l Product Rating: Essentiallynon-toxic ACUTE INVERTEBRATE RESULTS:

Species I Exposure LC50 EC50 Test Descriptor Daphnia magna l 48 hrs I> 1,000 mg/l I Rating: Essentially non-toxic CHRONIC FISH RESULTS:

Species Exposure IC25 LOEC Test Descriptor Fathead Minnow 7 Days 527 mgA 500 mg/l Product CHRONIC INVERTEBRATE RESULTS:

Species l Test Tvpe IC25 l End Point l Test Descriptor Ceriodaphnia dubia 3 Brood 141 mq/ 7 Reproduction Product ENVIRONMENTAL HAZARD AND EXPOSURE CHARACTERIZATION Based on our hazard characterization, the potential environmental hazard is: Low If released into the environment, see CERCLNSUPERFUND in Section 15.

13. lDISPOSAL 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.

1 14. l TRANSPORT INFORMATION I 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 as follows.

LAND TRANSPORT:

Proper Shipping Name: PRODUCT IS NOT REGULATED DURING TRANSPORTATION AIR TRANSPORT (ICAOIIATA):

Nalco Company 1601 W. Diehl Road ' Naperville, Illinois 60563-1198 (630)305-1000 5/8

MATERIAL SAFETY DATA SHEET PRODUCT N A":L d U.

73551 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300(24 Hours) CHEMTREC Proper Shipping Name: PRODUCT IS NOT REGULATED DURING TRANSPORTATION MARINE TRANSPORT (IMDG!IMO):

Proper Shipping Name: PRODUCT IS NOT REGULATED DURING TRANSPORTATION l15. l REGULATORY INFORMATION I 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.

CERCLAJSUPERFUND, 40 CFR 117,302:

Notification of spills of this product is not required.

SARAISUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986 (TITLE 1II)- 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)

FOOD AND DRUG ADMINISTRATION (FDA) Federal Food, Drug and Cosmetic Act:

When use situations necessitate compliance with FDA regulations, this product is acceptable under: 21 CFR 173.340 DefoamingAgents,'21 CFR 175.105 -Adhesives, 21 CFR 176.200 Defoaming Agents used in coatings, 21 CFR 176.210 Defoaming agents used in the manufacture of paper and paperboard, 21 CFR 176.300 - Slimicides, 21 CFR 177.1200 - Cellophane, 21 CFR 177.1400 - Hydroxyethyl cellulose film, water-insoluble, 21 CFR 178.1010 -

Sanitizing solutions, 21 CFR 178.3120 - Animal glue This product has been certified as KOSHER/PAREVE for year-round use INCLUDING THE PASSOVER SEASON by the CHICAGO RABBINICAL COUNCIL.

Nalco Company 1601 W. Diehl Road

Naperville, Illinois 60563-1198 (630)305-1000 618

MATERIAL SAFETY DATA SHEET PRODUCT

.NALCO 73551 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC FEDERAL WATER POLLUTION CONTROL ACT, CLEAN WATER ACT, 40 CFR 401.15 / formerly Sec. 307,40 CFR 116.4 /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 11Ozone 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.

STATE RIGHT TO KNOW LAWS:

The following substances are disclosed for compliance with State Right to Know Laws:

Water 7732-18-5 Polyalkylene glycol Proprietary 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.

16. OTHER 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 if your product application is consistent with our recommendations. Together we can implement an appropriate risk management process.

Nalco Company 1601 W. Diehl Road ' Naperville, Illinois 60563-1198 (630)305-1000 718

MATERIAL SAFETY DATA SHEET PRODUCT Pi 73551 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC 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.

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), Ariel 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 : 03/01/2004 Version Number: 1.8 Nalco Company 1601 W. Diehl Road

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

Product Name:

Biodetergent 73551 Soft Foulant Deposit Cleaner Product Descriotion And Anolication:

Biodetergent 73551 is a non-ionic compound used to remove and disperse "soft foulant" (biofilm-enmeshed mud, silt and clay) deposits in cooling water systems including cooling tower fill, condenser water-side tubes and tube-side heat exchangers. Biodetergent 73551 demonstrates superior cleaning action through a combination of chemical solubilization and physical scrubbing by entrained air bubbles. Once soft foulant aggregates are dislodged into the bulk fluid, Biodetergent 73551 prevents re-establishment of soft-foulant deposits.

Biodetergent 73551 may be powerful enough to use as a primary cleaner, but it should be complemented with biocide usage so that dislodged microbial populations are killed and not given any chance to re-establish on surfaces.

Physical & Chemical Properties:

These properties are typical. REFER TO SECTION 9 OF THE MSDS FOR THE MOST CURRENT DATA.

Form Liquid Density 8.425 Ibfgal (1.01 kg/l]

Specific Gravity at 770 F [25 0C] 0.99 - 1.03 pH (neat) 6.6 -7.0 Freeze-Thaw Recovery Complete Flash Point > 200OF [p 930C]

Odor None Freeze Point 260 F [-30 C]

Solubility in Water Complete Appearance Light Yellow Active Constituents:

Active Wt%

Blend of Nonionic Surfactants ....... ... 20

Regulatory Approvals:

73551 is not a biocide and does not need to be registered by the EPA as a pesticide.

Due to its low toxicity, Biodetergent 73551 has many government approvals that make it Ondeo-Nalco's "Green Alternative" to Biodetergent 73550. The following is an excerpt from the MSDS that details the FDA approvals for this product Refer to Section 15 of the MSDS for further information.

"FOOD AND DRUG ADMINISTRATION (FDA) Federal Food, Drug and Cosmetic Act:

When use situations necessitate compliance with FDA regulations, this product is acceptable under: 21 CFR 173.340 Defoaming Agents, 21 CFR 175.105 - Adhesives, 21 CFR 176.200 Defoaming Agents used in coatings, 21 CFR 176.210 Defoaming agents used in the manufacture of paper and paperboard, 21 CFR 176.300 - Slimicides, 21 CFR 177.1200 - Cellophane, 21 CFR 177.1400 - Hydroxyethyl cellulose film, water-insoluble, 21 CFR 178.1 010 - Sanitizing solutions, 21 CFR 178.3120 - Animal glue" Materials of Compatibility:

Compatible Not Tested Polyethylene (Cross Linked) Aluminum Polyethylene (High Density) Bunn N Polypropylene Carbon Steel EPDM CPVC Viton Stainless Steel (304)

Stainless Steel (316)

Silicone 65 Polyvinylchloride (PVC)

Polyethylene (Low Density)

Kynar Buna N Dosage And Feeding:

The specific dosage of Biodetergent 73551 will vary depending on the characteristics of your system and the Bio-Manage objective for your microblo control program. Your Nalco representative will recommend the optimum dosage for cost-effective control and results.

Biodetergent 73551 is Ondeo-Nalco's "Green Altemative" to Biodetergent 73550 that has toxicity characteristics that prevent its use in once-through systems. Biodetergent 73551, however, can be used safely in once-through systems.

Dosage:

Major System Cleaning:

Optimum dosage for Biodetergent 73551 is system dependant. In general, higher dosages are required for systems that are heavily fouled with inorganic material and biological growth. The recommended dosage for cleaning heavily-fouled surfaces is 20-30 ppm.

Typically, this dosage may generate "nuisance" foam at the air-water interface. If foaming is a concern, apply 10 ppm but expect the cleaning to take longer. Cleaning heavily-fouled tower fill, can, for example, take between eight to 12 weeks. Cleaning time for heat exchange surfaces and direct contact cooling systems, such as those found in steel mills varies from systems to system. Smaller cooling water systems will take approximately two to four weeks to clean.

Maintenance Dose:

Use between 5-10 ppm Biodetergent 73551 continuously as a maintenance dose to prevent build-up of soft foulant deposit on newly cleaned surfaces.

73551 Typical Dose Rates Dirty - Clean-Up Clean -

Maintenance 10 - 50 ppm 10 - 20 ppm Bio-Control:

Biodetergent 73551 alone will penetrate and remove biofilms, however cleaning action is greatly improved and redeposition minimized when applied in conjunction with a well managed bio-control treatment. Reducing biological activity improves the ability of Biodetergent 73551 to penetrate and remove deposits.

It is common to see biological activity and biocide demand increase substantially during clean-up due to the release of organic and biological material from system surfaces. Biocide feed should be adjusted to overcome this additional demand. Again as the system is cleaned, the biocide demand will decrease.

NOTE: If a considerable amount of debris is released, blowdown should be increased to help relieve the system of the increased water carried solids.

Risk: Foaming is the most common potential concern when applying Biodetergent 73551. The lower the bulk water temperature, the greater the tendency to create foam. Initiating treatment at lower dosage is recommended and increasing gradually until the foaming is observed or the target dose is reached. Avoid overdosing. It's a good idea to have a small amount of antifoam on hand to suppress foam. Recommended antifoam products are 71D5 PLUS orwater-based products such as 7463 or7465. Keep in mind

that antifoam will inhibit Biodetergent 73551 from working. Use sparingly. Even spraying antifoam onto the "nuisance" foam as a defoamer is an excellent way to manage foam generation and minimize inhibition of the product.

Biodetergent 73551 removes deposits and increases suspended solids. In some cases, this will cause filter backwash cycles to increase. Solids that are too heavy to disperse will migrate to the low-flow areas of the system and accumulate. The most common area for accumulation is the sump. Removal of accumulated solids is recommended and will hblp overall control by reducing the sludge layer where bacteria can accumulate and re-innoculate the system. Larger material that is delaminated can enter the recirculation line if the screens are not sealed. These solids will accumulate in strainers and can restrict flow. Locating in line strainers and monitoring pressure drop is recommended particularly during clean up of a dirty system. A symptom of restricted flow would be decreased condenser cooling.

Environmental And Toxity Data:

Refer to Material Safety Data Sheet sections 6 and 12 for all aquatic and mammalian toxicity information. Contact research for assistance with questions regarding degradation products.

Safety And Handling:

Handling: Avoid eye and skin contact. Do not take internally. Ensure all containers are labeled. Close containers when not in use.

Storage:

Storage Conditions: Store containers closed. Ensure all containers are labeled. Close containers when not in use.

Additional Information:

If you need assistance or information, please call your nearest Nalco representative, or our Naperville office at (630) 305-1000.

For Medical and Transportation Emergencies involving Nalco products call ( 24 -hour response): (800)1-AM-ALERT or (800) 462-5378.

MATERIAL SAFETY DATA SHEET NAUS '.. PRODUCT

... ........ . TOWERBROME 960 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC

1. I CHEMICAL PRODUCT AND COMPANY IDENTIFICATION PRODUCT NAME: TOWERBROM@ 960 APPLICATION: BIOCIDE COMPANY IDENTIFICATION: Nalco Company 1601 W. Diehl Road Naperville, Illinois 60563-1198 EMERGENCY TELEPHONE NUMBER(S): (800) 424-9300 (24 Hours) CHEMTREC NFPA 704M/HMIS RATING HEALTH: 3/3 FLAMMABILITY: 111 INSTABILITY: 21/2 OTHER: OXIDIZER 0 = Insignificant 1 = Slight 2 = Moderate 3 =High 4 = Extreme

2. l COMPOSITIONIINFORMATION ON INGREDIENTS Our hazard evaluation has identified the following chemical substance(s) as hazardous. Consult Section 15 for the nature of the hazard(s).

Hazardous Substance(s) CAS NO % (w/w)

Sodium Dichloroisocyanurate 2893-78-9 60.0 - 100.0 Sodium Bromide 7647-15-6 5.0 - 10.0

3. HAZARDS IDENTIFICATION

- EMERGENCY OVERVIEW**

DANGER CORROSIVE. CAUSES EYE AND SKIN DAMAGE. IRRITATING TO NOSE AND THROAT. HARMFUL OR FATAL IF SWALLOWED. Prolonged ingestion of large amounts may cause adverse central nervous system effects.

Strong Oxidizer.

Do not get in eyes, on skin, on clothing. Remove contaminated clothing and wash before reuse.

Wear goggles and face shield and rubber gloves when handling.

Not flammable but can act as an oxidizing agent, enhancing the burning rate of other materials. Water Reactive; material will react with water and may release a flammable or toxic gas. In addition, nitrogen trichloride, which can present an explosion hazard, can be generated slowly by the reaction of small quantities of water with a high concentration of this product. Decomposes; flammable and/or toxic gases will form at elevated temperatures (thermal decomposition).

PRIMARY ROUTES OF EXPOSURE:

Eye, Skin Nalco Company 1601 W. Diehl Road

Naperville, Illinois 60563-1198 (630)305-1000 1/9

MATERIAL SAFETY DATA SHEET N ALC

...... : ......... :TOWERBROMW O PRODUCT 960 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC HUMAN HEALTH HAZARDS - ACUTE:

EYE CONTACT:

Corrosive. Will cause eye bums and permanent tissue damage.

SKIN CONTACT:

May cause severe irritation or tissue damage depending on the length of exposure and the type of first aid administered.

INGESTION:

Not a likely route of exposure. Corrosive; causes chemical bums to the mouth, throat and stomach. Can cause central nervous system depression, nausea, dizziness, vomiting, or unconsciousness.

INHALATION:

Not a likely route of exposure. Irritating, in high concentrations, to the eyes, nose, throat and lungs.

SYMPTOMS OF EXPOSURE:

Acute:

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

Chronic:

Excessive exposure may cause central nervous system effects, nausea, vomiting, anesthetic or narcotic effects.

AGGRAVATION OF EXISTING CONDITIONS:

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

14. l FIRST AID MEASURES EYE CONTACT:

PROMPT ACTION IS ESSENTIAL IN CASE OF CONTACT. Immediately flush eye with water for at least 15 minutes while holding eyelids open. Get immediate medical attention.

SKIN CONTACT:

Remove contaminated clothing. Wash off affected area Immediately with plenty of water. Get immediate medical attention.

INGESTION:

DO NOT INDUCE VOMITING. If conscious, washout mouth and give water to drink. Get immediate medical attention.

INHALATION:

Remove to fresh air, treat symptomatically. Get medical attention.

NOTE TO PHYSICIAN:

Probable mucosal damage may contraindicate the use of gastric lavage. Based on the individual reactions of the patient, the physician's judgement should be used to control symptoms and clinical condition.

Nalco Company 1601 W. Diehl Road s Naperville, Illinois 60563-1198 (630)305-1000 2/9

MATERIAL SAFETY DATA SHEET NALCQ

. . .. .... ... .... .. ::... :...:..E [PRODUCT BR M 6

.EMERGENCY TELEPHONE NUMBER(S)

- --- - -(800) 424-9300 (24 Hours) CHEMTREC

5. FIRE FIGHTING MEASURES FLASH POINT: None EXTINGUISHING MEDIA:

Use water spray to cool containers exposed to fire and massive quantities of water to dilute material involved in a fire or spilled from containers. Do not use ABC or other dry chemical fire extinguishers since there is the potential for a violent reaction.

FIRE AND EXPLOSION HAZARD:

Not flammable but can act as an oxidizing agent, enhancing the burning rate of other materials. Water Reactive; material will react with water and may release a flammable or toxic gas. In addition, nitrogen trichloride, which can present an explosion hazard, can be generated slowly by the reaction of small quantities of water with a high concentration of this product. Decomposes; flammable and/or toxic gases will form at elevated temperatures (thermal decomposition).

SPECIAL PROTECTIVE EQUIPMENT FOR FIRE FIGHTING:

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

6. lACCIDENTAL RELEASE MEASURESl PERSONAL PRECAUTIONS:

Restrict access to area as appropriate until clean-up operations are complete. Ensure clean-up is conducted by trained personnel only. Ensure adequate ventilation. Do not touch spilled material. Use personal protective equipment recommended in Section 8 (Exposure Controls/Personal Protection). Notify appropriate government, occupational health and safety and environmental authorities.

METHODS FOR CLEANING UP:

Sweep up and shovel. Dispose of material in compliance with regulations indicated in Section 13 (Disposal Considerations). DO NOT allow water to come into contact with this material.

ENVIRONMENTAL PRECAUTIONS:

This product is toxic to fish. Do not discharge effluent containing this active ingredient into lakes, streams, ponds, estuaries, oceans or other waters, unless in accordance with the requirements of a National Pollutant Discharge Elimination System (NPDES) permit and the permitting authority has been notified in writing prior to discharge. Do not discharge effluent containing this product to sewer systems without previously notifying the local sewage treatment plant authority. For guidance contact your State Water Board or Regional Office of the EPA.

7. l HANDLING AND STORAGE I HANDLING:

Do not get in eyes, on skin, on clothing. Do not take internally. Use with adequate ventilation. Avoid generating dusts. Keep the containers closed when not in use.

STORAGE CONDITIONS:

Store the containers tightly closed. Store in suitable labelled containers. Store separately from bases. Keep in dry place. Store away from organic chemicals and other oxidizable materials, reducing agents, acids and alkalis. DO NOT allow water to come into contact with this material.

Nalco Company 1601 W. Diehl Road

Naperville, Illinois 60563-1198 (630)305-1000 3/9

MATERIAL SAFETY DATA SHEET 00NALCO:): PRODUCT TOWERBROM 960

~.... .. .. . .... EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC

8. I EXPOSURE CONTROLS/PERSONAL PROTECTION OCCUPATIONAL EXPOSURE LIMITS:

Exposure guidelines have not been established for this product. Available exposure limits for the substance(s) are shown below.

Manufacturer's Recommendation:

Substance(s)

Sodium Dichloroisocyanurate ENGINEERING MEASURES:

General ventilation is recommended. Local exhaust ventilation may be necessary when dusts or mists are generated.

RESPIRATORY PROTECTION:

If dusts are generated, use an approved air-purifying respirator. An organic vapor/acid gas cartridge with dust/mist prefilter may be used. In event of emergency or planned entry into unknown concentrations a positive pressure, full-facepiece SCBA should be used. If respiratory protection is required, institute a complete respiratory protection program including selection, fit testing, training, maintenance and inspection.

HAND PROTECTION:

Neoprene gloves, PVC gloves, Butyl gloves SKIN PROTECTION:

Wear chemical resistant apron, chemical splash goggles, impervious gloves and boots. A full slicker suit is recommended if gross exposure is possible.

EYE PROTECTION:

Wear a face shield with chemical splash goggles.

HYGIENE RECOMMENDATIONS:

Eye wash station and safety shower are necessary. If clothing is contaminated, remove clothing and thoroughly wash the affected area. Launder contaminated clothing before reuse.

9. PHYSICAL AND CHEMICAL PROPERTIES PHYSICAL STATE Crystalline, Granular APPEARANCE White ODOR Slight Pungent SOLUBILITY INWATER Moderate pH (1 %) 6-7 MELTING POINT Decomposes 460 - 480 OF / 240 - 250 *C VOC CONTENT 0.0 % EPA Method 24 Nalco Company 1601 W. Diehl Road

Naperville, Illinois 60563-1198 (630)305-1000 419

MATERIAL SAFETY DATA SHEET

^2::" PRODUCT

.... TOWERBROM 960

........ ......:... .....: EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC Note: These physical properties are typical values for this product and are subject to change.

10. I STABILITY AND REACTIVITY STABILITY:

Stable under normal conditions.

HAZARDOUS POLYMERIZATION:

Hazardous polymerization will not occur.

CONDITIONS TO AVOID:

Moisture Avoid temperatures greater than 400 OF MATERIALS TO AVOID:

Do not bring in contact with organic materials and reducing agents. DO NOT allow water to come into contact with this material.

HAZARDOUS DECOMPOSITION PRODUCTS:

Oxides of nitrogen (NOx), disodium oxide, bromine, and traces of phosgene (under fire conditions); chlorine (released in presence of moisture) and other chlorine containing compounds; hypobromous acid, hypochlorous acid, and cyanuric acid (released when dissolved in water); nitrogen trichloride, an explosion hazard (generated slowly by the reaction of small quantities of water with high concentration of this product).

11. I TOXICOLOGICAL INFORMATION The following results are for a similar product.

ACUTE ORAL TOXICITY:

Species LD50 Test Descriptor Rat 1,350 mg/kg Rating: Non-Hazardous ACUTE DERMAL TOXICITY:

Species LD50 Test Descriptor Rabbit > 5g/kg Rating: Non-Hazardous SENSITIZATION:

This product is not expected to be a sensitizer.

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).

Nalco Company 1601 W. Diehl Road

Naperville, Illinois 60563-1198 (630)305-1000 5/9

MATERIAL SAFETY DATA SHEET

..., AVC PRODUCT

... . ..... . . .. TOWERBROM 960 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC

12. lECOLOGICAL INFORMATION ECOTOXICOLOGICAL EFFECTS:

The following results are for the product along with results on the active substances.

ACUTE FISH RESULTS .

Species Exposure LC50 Test Descriptor Fathead Minnow 96 hrsl 0.7 mg/l 50% Active Ingredient Sheepshead Minnow 96 hrs 3.42 m/ll Inland Silverside 96 hrs 2.7 mg/l 50% Active Ingredient Rating: Very toxic ACUTE INVERTEBRATE RESULTS:

Species Exposure LC50 EC50 Test Descriptor Daphnia magna 48 hrsl 2.5_m___l_ l 50% Active Ingredient Mysid Shrimp (Mysidopsis 48 hrs 3.54 mg/I bahia ) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Mysid Shrimp (Mysidopsis 96 hrs 4.4 mg/I 50% Active Ingredient bahia)

Rating: Toxic If released into the environment, see CERCLWSUPERFUND in Section 15.

13. l DISPOSAL CONSIDERATIONS If this product becomes a waste, it could meet the criteria of a hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA) 40 CFR 261. Before disposal, it should be determined if the waste meets the criteria of a hazardous waste.

Hazardous Waste: D001, D003 Pesticide wastes are acutely hazardous. Improper disposal of excess pesticide, spray mixture, or rinsate is a violation of Federal law. If these wastes cannot be disposed of by use according to label instructions, contact your State Pesticide or Environmental Control Agency, or the Hazardous Waste Representative at the nearest EPA Regional Office for guidance.

114. I TRANSPORT INFORMATION :1 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 as follows.

LAND TRANSPORT:

Proper Shipping Name: DICHLOROISOCYANURIC ACID, SALTS, MIXTURE Technical Name(s):

Nalco Company 1601 W. Diehl Road s Naperville, Illinois 60563-1198 (630)305-1000 6/9

.. ......... MATERIAL SAFETY DATA SHEET

.AV PRODUCT TOWERBROM 960

.. . . . . EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC UN/ID No: UN 2465 Hazard Class - Primary: 5.1 Packing Group: Il Flash Point: None AIR TRANSPORT (ICAO/IATA):

Proper Shipping Name: DICHLOROISOCYANURIC ACID, SALTS, MIXTURE Technical Name(s):

UN/ID No: UN 2465 Hazard Class - Primary: 5.1 Packing Group: II IATA Cargo Packing Instructions: 511 IATA Cargo Aircraft Limit: 25 KG (Max net quantity per package)

MARINE TRANSPORT (IMDG/IMO):

Proper Shipping Name: DICHLOROISOCYANURIC ACID, SALTS, MIXTURE Technical Name(s):

UN/ID No: UN 2465 Hazard Class - Primary: 5.1 Packing Group: Il

15. l REGULATORY INFORMATION NATIONAL REGULATIONS, USA:

OSHA HAZARD COMMUNICATION RULE, 29 CFR 1910.1200:

Based on our hazard evaluation, the following substance(s) in this product is/are hazardous and the reason(s) is/are shown below.

Sodium Dichloroisocyanurate: Oxidizer, Irritant Sodium Bromide: Eye irritant CERCLA/SUPERFUND, 40 CFR 117,302:

Notification of spills of this product is not required.

SARA/SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986 (TITLE 1II)- 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 this product to be hazardous. The product should be reported under the following indicated EPA hazard categories:

X Immediate (Acute) Health Hazard Nalco Company 1601 W. Diehl Road

Naperville, Illinois 60563-1198 (630)305-1000 7/9

MATERIAL SAFETY DATA SHEET

.. NALCQ~ JV% ..PRODUCT

. ..... : TOWERBROM 0 E960

.EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC Delayed (Chronic) Health Hazard X Fire Hazard Sudden Release of Pressure Hazard X Reactive Hazard 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)

NSF NON-FOOD COMPOUNDS REGISTRATION PROGRAM (former USDA List of Proprietary Substances & Non-Food Compounds):

NSF Registration numberforthis productis: 121816 This product is acceptable for treatment of cooling and retort water (G5) in and around food processing areas.

FEDERAL INSECTICIDE, FUNGICIDE AND RODENTICIDE ACT (FIFRA):

EPA Reg. No. 935-71-1706 In all cases follow instructions on the product label.

FEDERAL WATER POLLUTION CONTROL ACT, CLEAN WATER ACT, 40 CFR 401.15 / formerly Sec. 307,40 CFR 116.4 / 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 11Ozone 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.

STATE RIGHT TO KNOW LAWS:

This product is a registered biocide and is exempt from State Right to Know Labelling Laws.

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.

Nalco Company 1601 W. Diehl Road

Naperville, Illinois 60563-1198 (630)305-1000 8/9

MATERIAL SAFETY DATA SHEET PRODUCT

. ~.

-. TOWERBROM© 960

-.... EMERGENCY TELEPHONE NUMBER(S)

. .. . . .. . . .. ... . . (800) 424-9300 (24 Hours) CHEMTREC WHMIS CLASSIFICATION:

E - Corrosive Material, C - Oxidizing Material 116. l OTHER INFORMATION 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.