Text

NPDES Permit No. TN0026450 - Comments on Draft NPDES Permit
	ML110060691
Person / Time
Site:	Sequoyah
Issue date:	11/10/2010
From:	Church C; Tennessee Valley Authority
To:	Janjic V; Document Control Desk, Office of Nuclear Reactor Regulation, State of TN, Dept of Environment & Conservation, Div of Water Pollution Control
References
	TN0026450
	Download: ML110060691 (116)
	v • d • e

Tennessee Valley Authority, Post Office Box 2000, Soddy Daisy, Tennessee 37384-2000 November 10, 2010 State of Tennessee Department of Environment and Conservation Division of Water Pollution Control Enforcement & Compliance Section 6 th Floor, L & C Annex 401 Church Street Nashville, Tennessee 37243-1534

Dear Mr. Vojin Janjid:

TENNESSEE VALLEY AUTHORITY (TVA) - SEQUOYAH NUCLEAR (SQN) PLANT - NPDES PERMIT NO. TN0026450 - COMMENTS ON DRAFT NPDES PERMIT TVA has reviewed the subject draft permit that was provided to us on October 11, 2010, and offers the following comments for your consideration:

Part I Comments

1. Page 1 of 29, Outfall 101 monitoring requirements:

a. TVA requests that the effluent limits for Total Residual Chlorine (TRC) remain at the current NPDES Permit limit of 0.10 mg/L. Enclosed is a copy of SQN Biocide/Corrosion Treatment Plan Approval and B/CTP Request for Approval submitted to TDEC in March 2005, requesting an NPDES Permit limit of 0.10 mg/L for TRC. TVA's request was based on results from the onsite chlorine demand study which established the method of detection for TRC at 0.08 mg/ L for the SQN site. Also enclosed is a copy of TDEC July 30, 2004, approval for Watts Bar Nuclear's (WBN) Biocide/Corrosion Treatment Plan which established a 0.10 mg/L TRC permit limit for WBN. As previously discussed with your staff, a review of historical samples taken internal to the plant system and calculated for Outfall 101 since 1996 illustrates that the effluent concentrations comply with the allowable water quality based limits.

b. TVA request that TDEC add for clarification the following information as footnote 1 for Outfall 101.

Samples taken in compliance with the monitoring requirements specified above shall be taken as follows: Flow - sampled at diffuser gate prior to entry to the Tennessee River; Ambient Temperature from Station 14 located at Tennessee River Mile 490.5 upstream of SQN; River Temperature - river temperature, temperature rise, and rate of temperature change shall be determined by numerical model.

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2. Page 3 of 29, Outfall 101 monitoring requirements: TVA requests that the last paragraph on this page be changed to read as:

Any substance, including radioactive materials, is of interest to our Agency ifit has reasonable potential to exceed applicable water quality criteria. However, radioactive releases to the environment, notwithstanding point source discharges authorized via this permit, are not regulated under the Clean Water Act, but are instead regulated under the Nuclear Regulatory Commission (NRC) by issuance of an Operating License. Pertinent regulations are found under 10 CFR Part 20 and 10 CFR Part 50. Sequoyah Nuclear Plant effluents that may contain radioactive material are not addressed as part of the NPDES permitting process.

Rationale

1. Page R-5 of R-43, Outfall 101 monitoring requirements: WVA requests that the last paragraph on this page be changed to read as:

Any substance, including radioactive materials, is of interest to our Agency if it has reasonable potential to exceed applicable water quality criteria. However, radioactive releases to the environment, notwithstanding point source discharges authorized via this permit, are not regulated under the Clean Water Act, but are instead regulated under the Nuclear Regulatory Commission (NRC) by issuance of an Operating License. Pertinent regulations are found under 10 CFR Part 20 and 10 CFR Part 50. Sequoyah Nuclear Plant effluents that may contain radioactive material are not addressed as part of the NPDES permitting process.

2. Page R-8 of R-43, Outfall 101 monitoring requirements: WVA requests that the last sentence in Section e. on Polychlorinated Biphenyls (PCB) paragraph be changed to match the permit pages for Outfall 101 and to read as:

PCB monitoring at Outfall 101 will be deleted from the monitoring requirements.

3. Page R-8 of R-43, Outfall 101 monitoring requirements: TVA requests that the effluent limits for Total Residual Chlorine (TRC) remain at the current NPDES Permit limit of 0.10 mg/L. As stated on the Rationale page R-8 of R-43, the Lower Limit of Quantification (LLD) for the colorimetric analysis of chlorine using DPD indicator are extremely variable and dependent upon the sample matrix. WVA has preformed extensive LLD studies for chlorine analysis using EPA-approved analytical methodologies and associated instrumentation. SQN has determined that the LLD for the Tennessee River in the vicinity of SQN is 0.08 mg/L. WVA had this study independently confirmed by Watts Bar Nuclear Plant. Although the 0.1 mg/L effluent limit will exceed the criterion maximum concentration (CMC), it is recognized that the reported values provided by TVA are calculated value based on TRC measurements taken within a small system prior to mixing with the total cooling water flow. WVA's calculated value only takes into account the mixing with the large volume of non-chlorinated cooling water and does not taken into account the dissipation due to elevated temperatures of the water, sunlight, or turbulence of the water prior to being discharged from Outfall 101. With all of these factors included, TVA is providing a very conservative TRC calculated value for Outfall 101. Therefore, it is anticipated that an effluent limit of 0.10 mg/L for TRC will comply with water quality criteria.

As discussed with Robert Alexander of your staff, enclosed is an updated Flow Schematic for SQN Plant.

TVA appreciates this opportunity to provide comments on the draft NPDES permit. A TVA representative will be contacting the division soon to discuss these comments and to ascertain whether a meeting would be appropriate. If you have any questions or need additional information, please contact Sam Hixson at (423)751-6705 in Chattanooga, or by email at swhixson0tva..qov.

I certify under penalty of law that this document and all attachments were prepared undermy direction or supervision in accordance with a system designed to assure that qualifiedpersonnel properly gather and evaluate 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 significantpenalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

Sincerejy, -

Christopher R.Church Site Vice President Sequoyah Nuclear Plant Enclosure cc (Enclosure):

Chattanooga Environmental Field Office U.S. Nuclear Regulatory Commission Division of Water Pollution Control ATTN: Document Control Desk State Office Building, Suite 550 Washington, D.C. 20555 540 McCallie Avenue Chattanooga, Tennessee 37402-2013

S 7 800 STATE OF TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION 401 CHURCH STREET L &C ANNEX 6 TH FLOOR Ap r i 2 7, 2 005 NASHVILLE, TN 37243-1534 Stephanie A. Howard Principal Environmental Engineer Tennessee Valley Authority, Sequoyah Nuclear Plant P.O. Box 2000 Soddy-Daisy, TN 37379-2000 Re: TVA-Sequoyah Nuclear Plant NPDES Permit No. TN0026450 Biocide/Corrosion Treatment Plan Approval

Dear Ms Howard:

The Division of Water Pollution Control (Division) has received and reviewed your letter of March 7, 2005 requesting authorization to implement changes to the raw water treatment plan at the Sequoyah Nuclear Plant (SQN). The revised plan, which you submitted with the letter, included four parts, (1) a copy of the plan in tabular format with accompanying rationale, (2) a plan overview and supporting documentation, and (3) a copy of MSDS sheets and product bulletins for the chemicals to be used, and (4) additional information describing how treatment would be carried out. The format for the plan was discussed at a meeting between SQN and WPC staff in Chattanooga in June 2004. It should also be noted that TVA Watts Bar Nuclear (WBN) Plant is situated upstream of SQN on the same waterway and that some [same] products were previously approved for use at WBN. Some products may.have already been approved for use at the SQN facility, but this approval is an update on the use and properties of those

[chemical] products. The Division appreciates the effort made by TVA to update the format and expand the information in the plan, which makes review much easier.

The SQN raw water treatment plan involves the use of eight (8) chemicals, applied to treat piping systems essential to safety in the event of a shutdown. The chemicals, following treatment under appropriate circumstances, will be discharged to the Tennessee River through the NPDES permitted Outfall 101 (ERCW Train A & B and the RCW) and Outfall 110 (supplemental condenser cooling water line when in closed mode). The chemicals include two corrosion inhibitors, one biodetergent, one oxidizing biocide (chlorination/bromination), three non-oxidizing biocides (quaternary ammonium compounds for mollusk control), and sodium silicate (detoxification). The use of some of these chemicals was approved by the Division in the past based on specific discharge conditions. Other chemicals are new to the plan.

There are certain basic criteria that the Division is following in reviewing this plan to assure that the effluent quality is protective of receiving stream quality. Based on data

Stephanie A. Howard Page 2 of 10 provided by TVA and/or the chemical vendor we have calculated maximum concentrations of the active ingredient(s) in the discharge in order to compare those values with acute and chronic criteria for the ingredients. The objective is to assure that the discharge concentration does not exceed the acute toxicity criteria for each ingredient. The maximum concentration of each active ingredient for Outfalls 101 and 110 - combined has been calculated to compare to the chronic toxicity criteria for [each active ingredient] at the end of the mixing zones. Based on those calculations, some values could exceed CCC criteria, however, TVA has committed not to exceed specific effluent concentrations and it is anticipated that the reactive properties of those chemicals should reduce the concentrations after mixing to acceptable levels. Because there are no federal or state criteria developed for most of the active ingredients in these chemicals, criteria have been derived based on data from the EPA EcoTox database (See Table 1 attached), from TVA, and from the chemical vendors. These derived criteria are compared to the maximum anticipated chemical ingredient instream concentration in Table 2 and discharge concentration in Table 3. Where TVA has committed not to exceed a specific effluent concentration and daily mass loading, those values have been made a condition of the plan approval, provided that water quality criteria are met.

For purposes of this plan evaluation, reference to chemical means the vendor chemical

-name including all active constituents. Where concentration limits have been established, we have specified whether that concentration limit applies to a specific ingredient, to the whole chemical, or to an indicator element for which analytical procedures are available. Unless otherwise specified, where mass limits are applied, they refer to the active ingredient(s) based on maximum daily feed rate.

The eight chemicals are discussed individually below and the conditions for their use are specified. Each chemical is approved for use effective April 27, 2005, subject to these specific conditions:

Chemical Name: Nalco PCL-401 Primary Ingredient: Anionic Copolymer CAS No.: None Provided This chemical is a dispersant designed to prevent the formation of scale in the system.

The chemical contains an anionic copolymer that is proprietary in makeup. Division records show this chemical was included in the submittal as part of the raw water treatment plan for WBN in August 1996 (see letter from Odis E. Hickman, Jr. to Paul Davis). Acute aquatic toxicity data has been presented in the plan from the NALCO MSDS and from TVA data. Based on this data a 48 hr LC50 for Daphnia magna ,of 798 mg/I has been utilized to derive a criterion maximum concentration (CMC) of 399 mg/I and a criterion continuous concentration (CCC) of 79.8 mg/I. TVA has agreed to keep concentrations of the active ingredient at or below 0.2 mg/L in the effluent: Conditions for approval of PCL-401 are (1) that the concentration of the chemical shall not exceed 0.2 mg/I in the plant effluents based on mass balance calculations, and (2) that the total quantity of chemical discharged shall not exceed 1,480 lbs per day.

Stephanie A. Howard Page 3 of 10 Chemical Name: Nalco PCL-222 Primary Ingredient: Copolymer-Phosphate blend CAS No.: (Individual Component CAS numbers available from the Manufacturer)

This chemical contains a copolymer-phosphate blend and is used as a dispersant designed to prevent the formation of scale in the system. Acute aquatic toxicity data was not initially available from NALCO MSDS. However, TVA stated in their B/CTP that "toxicity of PCL-222 is assumed to be similar to PCL-401", and that "tests will be conducted at a toxicity lab under contract to the manufacturer". Tests were performed March 5-12, 2005, and ASci Corporation, Environmental Testing Laboratory provided TVA with data for test endpoints as NOEC and LOEC, which were forwarded to the division on or about March 30, 2005. Division records show this chemical was included in a submittal as part of the raw water treatment plan for WBN in August 1996 (see letter from Odis E. Hickman, Jr. to Paul Davis).

TVA proposes to keep concentrations for each active ingredient (copolymer and phosphate) at or below 0.2 mg/I in the effluent. Conditions for approval of PCL-222 are (1) PCL-222 is injected into the ERCW Train A & B system only during warm weather months, (2) PCL-222 is injected into the RCW system continuously, except during periods of other chemical injection, (3) that the concentration of each active ingredient of PCL-222 shall not exceed 0.2 mg/I in the plant effluents based on mass balance calculations, and (4) that the total quantity of chemical discharged shall not exceed 760 lbs per day for the copolymer, and 2280 lbs per day for the phosphate as detailed in the SQN Raw Water Chemical Application Guide.

Chemical Name: NALCO Biodetergent 73551 Primary ingredient: Ethylene oxide-Propylene oxide copolymer CAS No. None Provided This chemical is a non-ionic copolymer used in advance of non-oxidizing biocide applications to remove and disperse soft foulant deposits in cooling water systems. This chemical was previously approved for use in a July 16, 2004 letter to TVA from Ed Polk.

Nalco Biodetergent 73551 replaced the surfactant, DMAD (CL363 dimethylamide), which was phased out of production in June 2004. Frequency of use would be approximately 208 days per year and duration of use would be about 0.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months per day with a maximum daily usage of 50 lbs/day for all three-injection points.

Data from the EPA EcoTox database shows that the chemical ethylene oxide exhibits acute toxicity to D. magna at 83 to 300 mg/I and to P. promelas at 63 mg/I to 150 mg/I.

Data from the Nalco MSDS shows acute toxicity of the chemical to D. magna with a reported LC50 of >1000 mg/l. The MSDS also shows chronic toxicity to P. promelas at an IC25 of 527 mg/I and for Ceriodaphniadubia at an IC25 of 141 mg/I. Data presented by TVA for the active ingredient show chronic toxicity (IC25) to P. promelas of 105.4 mg/I and to C. dubia of 28 mg/l. TVA has agreed to keep the effluent concentration of the active ingredients at or below 2.0 mg/I. Based on these data, conditions for approval of this chemical are (1) the plant effluent concentration of the active ingredients in Nalco

Stephanie A. Howard Page 4 of 10 Biodetergent 73551 shall not exceed 2.0 mg/I at any time based on mass balance calculations, (2) the maximum quantity of the active ingredients used shall not exceed 50 lbs per day for all three injection points, and (3) treatment durations shall not exceed 30 minutes at 2-3 times per week into ERCW Train A, ERCW Train B and RCW systems.

Chemical Name: NALCO Towerbrom 960 Primary Ingredient: Sodium Dichloroisocyanurate CAS Nos. 2893-78-9 Secondary Ingredient: Sodium Bromide CAS Nos. 7647-15-6 This chemical mixture is an oxidizing (chlorinating/brominating) biocide used for control of slime producing organisms, i.e., Asiatic clams and zebra mussels. The chemical mixture contains 85% to 95% sodium dichloroisocyanurnate and 5% to 10% sodium bromide. This chemical was previously approved by the Division, at WBN for non-discharge use in biological control of the cooling towers (see Thomas E. Roehm letter to Odis E. Hickman of September 6,1996).

TVA is requesting to be allowed to increase the chlorine discharge limit at Outfall 101 when using Towerbrom 960 to a maximum discharge concentration of TRO of 0.10 mg/L from the current maximum of 0.058 mg/L. The increase in the maximum limit is based on the following statement from TVA.

"The application period of Towerbrom must be increased in order to ensure growth of Asiatic clams and zebra mussels entering the plant system is limited to a size that will not restrict flow to equipment essential for the safe shutdown of the nuclear plant. During spring of 2004, SQN's ability to safely shutdown was threatened due to infestation of Asiatic clams with sizes up to 3/8" inch. The non-oxidizing biocide kills Asiatic clams and zebra mussels only when the river temperature is above 60 degrees F. TVAN monitoring has shown that veligers are present at river temperatures as low as 46 degrees F.

Previously, spawning was believed to stop at 55 degrees F. For that reason, the 2003 request to TDEC, asked for continuous Towerbrom treatment when the river temperature was >55 degrees F until such time as non-oxidizing biocide was administered. With current data proving present of veligers at river temperatures as low as 45 degrees F, the ability to use continuous Towerbrom for a period long enough to protect the system from infestation whenever veligers are detected is necessary. The 24-hour application of continuous Towerbrom treatment following nonoxidizing biocide treatments is necessary to have a synergistic effect for mollusk eradication in the systems. Likewise the number of treatments must be increased in order to limit the size of clams to 1/8 inch. Shells larger than 1/8 inch could cause failure of critical components required for safe shutdown.

Growth data obtained indicates that a clam can reach 1/4 inch in 8 to 12 weeks. Again, the ability to control the size of these mollusks is necessary to ensure safe shutdown capability. The same treatment program is also being used at TVAN's Watts Bar plant in order to ensure safe shutdown capability."

From "An Overview of Raw Water Chemical Additives", included in the letter of March 7, 2005 requesting authorization to implement changes to the raw water treatment plan at the Sequoyah Nuclear Plant (SQN):

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

Stephanie A. Howard Page 5 of 10

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. SQN 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."

Sodium dichloroisocyanurnate is acutely toxic to D. magna with reported EC50 in the range of 0.093 mg/I to 0.36 mg/I and LC50 of 0.15 mg/I. The sodium bromide is less toxic with D. magna LC50s in the range of 1.3 to 20,000 mg/I. TVA reported data for the Towerbrom 960 mixture, which shows D. magna 48' hr LC50 of 2.43 mg/I and P.

promelas48 hr LC50 of 0.679 mg/I.

The active ingredients in Towerbrom 960 produce 57% free halogen (chlorine and bromine) in solution. TVA is proposing to control the effluent concentration of Towerbrom-960 by controlling effluent Total Residual Oxidants to 0.10 mg/I in the plant effluent (TROs is defined for purposes of this plan to include residual chlorine and bromine and is to be quantified using the Total Residual Chlorine [TRC] test). Water quality criteria for TRC are 0.019 mg/I as the CMC and 0.011 mg/I as the CCC.

Although the 0.1 mg/I effluent limit will exceed the CMC, it is recognized that TRC reacts and dissipates rapidly between the point of measurement and the point of discharge at the receiving stream. Therefore it is anticipated that an effluent limit of 0.10 mg/I for TRC will comply with water quality criteria.

Based on the data available, the conditions for approval of use of this chemical shall be strictly adhered to and are: (1) the maximum concentration of TROs (including chlorine and bromine) shall not exceed 0.10 mg/I in Outfall 101, (2) the total quantity of active ingredient use shall not exceed 1425 lbs/day, (3) discharge limits compliance will be determined by mass balance calculation, (4) increased periods of application is approved based on described items 1. through 3. above (from the March 7, 2005 request letter's "An Overview of Raw Water Chemical Additives"), (5) oxidizing biocide treatments using Towerbrom 960 shall not be conducted simultaneous per system train with non-oxidizing biocide chemical treatments.

Chemical Name: NALCO H-130M Primary Ingredient: Didecyldimethylammonium Chloride CAS No.: 7173-51-5 This chemical is a non-oxidizing biocide used to control mollusks. The primary ingredient, didecyldimethylammonium chloride, is a specific biocide in the family of quaternary ammonium compounds. These compounds are generally structured to contain four organic radicals attached to a nitrogen molecule. Ethanol may be added to enhance solubility.

Stephanie A. Howard Page 6 of 10 TVA is proposing to increase the use of H-130M and to provide detoxification treatment using Nalco Coagulant Aid 35 active ingredient: Quartz, crystalline silica. (See separate discussion below).

Nalco H-130M is acutely toxic to D.magna in the range of 0.019 mg/I to >1.0 mg/I based on data from the EPA EcoTox database. The Nalco MSDS reports D.magna acute toxicity at 0.19 mg/I and TVA reports chronic toxicity for C. dubia at 0.139 mg/I and for P.

promelas at 0.104 mg/I. Based on these data, an acute criteria (CMC) of 0.05 mg/I and a chronic criteria (CCC) of 0.01 mg/I are established for this compound.

Treatment of Outfalls 101 and 110 with sodium bentonite shall be undertaken any time mass balance calculations indicate that an exceedance of the effluent concentration limits for H-1 30M will occur. TVA-SQN will also use grab samples analyzed with a low-level detection test method (using methylene chloride extraction), which has an MDL of 0.02 mg/I, in conjunction with those calculations to demonstrate protection of the receiving stream. TVA may use a colorimetric method for detection of quaternary ammonium compounds suitable for field use to a detectable limit (MDL) of 0.05 mg/I for operational use. TVA may send samples to Nalco or other qualified laboratories for comparative sample analysis.

The conditions for approval of the use of this compound are (1) the concentration of the active ingredients in the plant effluents shall not exceed 0.05 mg/I, (2) when treatment is underway, routine sampling of the effluents shall be undertaken once each four hours during daylight hours and once during nighttime hours, (or a composite sampler may be used), and the grab samples shall be analyzed for quaternary ammonium compounds using methylene chloride extraction, and (3) the total use of Nalco H-130M shall not exceed 855 lbs/day of active ingredients, and (4) treatment using sodium bentonite shall be applied to Outfalls 101 and 110 any time that calculations show that an exceedance of condition (1) or (3) may occur. TVA-SQN will use grab samples analyzed with a low-level detection test method (using methylene chloride extraction), which has an MDL of 0.02 mg/I, in conjunction with those calculations to demonstrate protection of the receiving stream. TVA may send samples to Nalco or other qualified laboratories for comparative sample analysis.

Chemical Name: Lonza Barquat 4250-Z, a.k.a. Nalco H-150M Primary Ingredient: N-alkyl (C 14 60%, C1 6 30%, C 12 5%, C 18 5%)-N, N-dimethyl-N-Benzylammonium Chloride CAS No.: 68391-01-5 Secondary Ingredient: N-Dodecyl-N,N-dimethyl-N-ethylbenzylammonium CAS No.: 27479-28-3 Chloride This chemical is a "second" generation quaternary ammonium compound used as a hard surface disinfectant and/or water treatment to provide biocidal action against a broad

Stephanie A. Howard Page 7 of 10 spectrum of microbial organisms such as: bacteria, funji, viruses, and algae. This product is new to this program and has not been previously approved for use. TVA stated in their request for approval to use that "Toxicity testing of Barquat is (was) currently underway (3/1/05) at Environmental Testing Solutions, Inc., Asheville, NC."

Testing was completed on, or about March 15 2005. Completed test results were presented in a report to the division March 30, 2005.

Barquat 4250-Z is acutely toxic to C. dubia in the range of 48-hour LC50 of 0.053 mg/I to 24-hour LC50 of 0.083 mg/I based on data from the recently completed toxicity testing.

The toxicity tests also reports acute toxicity for P. promelas between 0.283 mg/I for a 96-hour LC50 to 0.386 mg/I for a 24-hour LC50 . Based on these data, an acute criteria (CMC) of 0.05 mg/I and a chronic criteria (CCC) of 0.01 mg/I are established for this compound.

Treatment of Outfalls 101 and 110 with sodium bentonite shall be undertaken any time mass balance calculations indicate that an exceedance of the effluent concentration limits for Lonza Barquat 4250-Z, a.k.a. Nalco H-150M will occur. TVA-SQN will also use grab samples analyzed with a low-level detection test method (using methylene chloride extraction), which has an MDL of 0.02 mg/I, in conjunction with those calculations to demonstrate protection of the receiving stream. TVA may use a colorimetric method for detection of quaternary ammonium compounds suitable for field use to a detectable limit (MDL) of 0.05 mg/I for operational use. TVA may send samples to Nalco or other qualified laboratories for comparative sample analysis.

The conditions for approval of-the use of this compound are (1) the concentration of the active ingredients in the plant effluents shall not exceed 0.05 mg/I, (2) the effluents shall be sampled and analyzed for quaternary ammonium compounds once each 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during daylight hours and once per nighttime hours, (or a composite sampler may be used), in periods when treatment is underway, (3) the total use of Barquat 4250-Z (or Nalco H-150M) shall not exceed 855 lbs/day of active ingredients, and (4) treatment using sodium bentonite shall be applied to Outfalls 101 and 110 any time that calculations show that an exceedance of condition (1) or (3) may occur, (5) TVA-SQN will also use grab samples analyzed with a low-level detection test method (using methylene chloride extraction), which has an MDL of 0.02 mg/I, in conjunction with those calculations to demonstrate protection of the receiving stream. TVA may send samples to Nalco or other qualified laboratories for comparative sample analysis.

Stephanie A. Howard Page 8 of 10 Chemical Name: Betz Dearborn Spectrus CT1 300 Primary Ingredient: (C12-C16) Dimethylbenzylammonium Chloride CAS No.: 68424-85-1 Secondary Ingredient: Ethyl Alcohol CAS No. 64-17-5 This chemical is a non-oxidizing biocide used for mollusk control. It contains a primary ingredient, (C12-C16) dimethylbenzylammonium chloride (50%), which is a quaternary ammonium compound. A secondary ingredient is ethyl alcohol. This product is approved by the Division with the condition that the concentration of the active ingredients does not exceed 0.05 mg/I in the plant effluents. TVA is requesting that the number of injections and durations be adjusted, but that the current maximum allowable discharge concentration of 0.05 mg/L remains unchanged. Under these conditions, detoxification of the chemicals will be undertaken using sodium bentonite (see discussion below).

Dimethylbenzyl ammonium chloride has been found to be acutely toxic to D. magna at concentrations ranging from .00028 to .09 mg/I and to P. promelas in concentrations ranging from 0.23 to 1.8 mg/I based on limited data in the EPA EcoTox database. The Betz Dearborn MSDS reports acute toxicity for D. magna of 0.16 mg/I and P. promelas of 2.9 mg/l. TVA reports chronic toxicity to C. dubia of 0.18 mg/I and to P. promelas of 0.36 mg/I. Based on these data, a CMC of 0.050 mg/I and a CCC of 0.010 mg/I are selected to protect the stream.

Treatment of Outfalls 101 and 110 with sodium bentonite shall be undertaken any time mass balance calculations indicate that an exceedance of the effluent concentration limits for Betz Dearborn Spectrus CT1300 will occur. TVA-SQN will also use grab samples analyzed with a low-level detection test method (using methylene chloride extraction), which has an MDL of 0.02 mg/I, in conjunction with those calculations to demonstrate protection of the receiving stream. TVA may use a colorimetric method for detection of quaternary ammonium compounds suitable for field use to a detectable limit (MDL) of 0.05 mg/I for operational use. TVA may send samples to Nalco or other qualified laboratories for comparative sample analysis.

The use of Betz Dearborn Spectrus CT1300 is approved for use with the following conditions (1) the concentration of the quaternary ammonium compounds in the chemical shall not exceed 0.05 mg/I, (2) the total use of all active ingredients in Spectrus CT1 300 shall not exceed 855 lbs/day, (3) treatment of Outfalls 101 and 110 with sodium bentonite shall be undertaken any time mass balance calculations indicate that an exceedance of condition (1) and (2) may occur, (4) when treatment is underway, routine sampling of the effluents shall be undertaken once each four hours during daylight hours and once during nighttime hours, (or a composite sampler may be used), and the grab samples shall be analyzed for quaternary ammonium compounds with a low-level detection test method (using methylene chloride extraction), which has an MDL of 0.02 mg/I, in conjunction with those calculations to demonstrate protection of the receiving stream. TVA may send samples to Nalco or other qualified laboratories for comparative sample analysis.

Stephanie A. Howard Page 9 of 10 Chemical Name: Nalco Coagulant Aid-35 Active Ingredient: Quartz, crystalline silica (aluminum silicate)

CAS No.: 14808-60-7 This chemical is sodium bentonite clay, which is composed primarily of sodium and aluminum silicates. The clay is used to detoxify (adsorb and bind) the toxic constituents in H-130M, Barquat 4250-Z, (also known as H-150M), and Spectrus CT1300. This treatment proposal is new and has not been approved in the past. Treatment is to occur approximately 24 times per year for about a 3.5-5.5-day period, for a maximum period of 132 days per year. Special trailers have been constructed to house the chemical feed equipment to be used during the treatment operation. Both Outfalls 101 and 110 will be treated as needed. Proposed feed rate is up to 8,520 lbs/day and proposed maximum concentration in the effluents is 10 mg/l.

The sodium and aluminum silicate clays are generally non-toxic and should not pose a problem for the receiving stream. Nalco Coagulant Aid-35 is approved for use with the conditions (1) the maximum concentration in the effluents is less than1o mg/I based on mass balance calculations, (2) the total use of sodium bentonite shall not exceed 8,520 lbs/day, and (3) treatment of Outfalls 101 and 110 with sodium bentonite shall be undertaken any time mass balance calculations indicate that an exceedance of the effluent concentration limits for Nalco H-130M, Barquat 4250-Z, or Betz Dearborn Spectrus CT1300 will occur. TVA-SQN will also use daily grab samples analyzed with a low-level detection test method (using methylene chloride extraction), which has an MDL of 0.02 mg/I, in conjunction with those calculations to demonstrate protection of the receiving stream.

General Requirements In addition to the chemical specific requirements above, the approval of the use of these chemicals is also conditioned upon the following:

1. Oxidizing and non-oxidizing biocides are not to be used at the same time, in each system Train, (e.g., ERCW Train A, Train B, or RCW),

2. Whole effluent toxicity testing (biomonitoring) of Outfall 101 shall be undertaken once per year when oxidizing biocides are being used and once per year when non-oxidizing biocides are being used,

3. Whole effluent toxicity testing (biomonitoring) of Outfall 110 shall be undertaken -once per year when oxidizing biocides are being used and once per year when non-oxidizing biocides are being used,

4. Whole effluent toxicity testing performed under requirements of the NPDES permit may be coordinated with the requirements of (2) and (3) above.

5. The sampling and test procedures used for biomonitoring shall be the same as those described in the NPDES permit, analysis of the samples shall be performed the same regardless of how the sample is collected, e.g., if composite sample collection is used the test method for the sample shall be the same as if the sample was collected by grab sample.

6. The acceptable methods for detection of TRO shall be the same as those specified in the NPDES permit for TRC,

Stephanie A. Howard Page 10 of 10

7. Annually, a report shall be submitted to the Division presenting the biomonitoring data for tests conducted during treatments, a summary of all analytical results (daily maximum, daily average, number of samples), the approximate duration in hours of each chemical used, quantity in pounds of each chemical used, and any minor changes that have occurred to the plan. The report shall be submitted to the Enforcement and Compliance Section in Nashville and to the Chattanooga field office by February 15 of the year following the reporting year. Significant changes to the plan must be submitted for Division for approval prior to their initiation. Minor changes (e.g. chemical names or vendor changes of essentially the same chemical) do not require pre-approval, but shall be indicated in the annual report or when the plan is revised,

8. In order to compare reliability of the mass-balance calculations with the methylene chloride extraction method, SQN shall compare both methods used for the analyses of the effluent and report to the Division. This is especially important during the first six treatments using detoxification. When the division includes "...other qualified laboratories..." the intent is that a laboratory will be selected based on its ability to accurately run the specified test. TVA should base their selection of the laboratory on the highest of industry standards. The results of these comparisons will be submitted in the first annual report to TDEC on February 15, 2006, and

9. TVA-SQN is required to maintain all records on file of sampling and analytical data, toxicity test results, records of quantities fed per day of each chemical, and mass balance calculations. These records shall be maintained on site for a period of at least three years.

If you have any questions or comments, please don't hesitate to contact me at (615) 532-1178, or at edward.polk@state.tn.us.

Sincerely, Edward M. Polk, Jr., P.E.

Manager, Permit Section Water Pollution Control EMP/prm Attachments Cc: Saya A. Quails, P.E., WPC-Chief Engineer Pamala Myers, Permit Section Terry Whalen, Chattanooga EFO

Table 1 TVA Sequaoyah Nuclear Plant Raw Water Treatment Plant Chemicals Toxicity Data from EPA EcoTox Database Supplier Name and CASNo. IAquatic Species EndPoint' Concentration, uiqIA . Reference Chemical Name I I Min I Average Max No.

Corbicula EC50 600 14413 Nalco Towerbrom 960 Daphnia maona EC50 93 360 344 Prmary active ingredient:

1,3-DichlorO-1,3,5-triazine-2,4,6 (1H,3H,5H)-trione, 2893789 Daphnia manna EC50 150 14413 Sodium salt. Bluegill LC50 250 3200 344 90% active ingredient in Towerbrom 960 Rainbow trout LC50 290 14413 Rainbow trout LC50 130 900 344 Daphniamagna ECO 5,171,000 6628 Secondary active ingredient: Dahnia manna EC50 7,219,000( 6628 Sodium bromide 7647156 Daphnia magna NOEC 91,000 1 6628 10% active ingredient in Towerbrom 960 Daphnia ma.na EC10 43,000 12872 Oaphnia magna ECSO 6,820,000 10203 Daphnia mag:na EC50 17,219,000 847 Saphnia magna EC50 1300 1400 1600 7054 Daphnia magna EC50 6,700.000 9,300,000 2493 Daphnia magna EC50 5,700,000 10,800,000 6556 Daphnia magna EC5O >1,000,000 344 naphnia madena ECSO 5 5.8004000 1060 Daphnia magna* EC50 20,800 30,400 20061 Daphnia magna EC50 23,000 5675 Daphnia magqna EC50 123,000 10600 Daphnia magna EC50 5870 14,170 3949 Daphnia magna LC50 500,000 5718 Daphnia magna LC50 1 11,000,000 10600 Daphnia magna LC50 149794 Daphnia magna LCS0 1i0,500,000 5675 Daphnia magna LC50 110.000.000 20,000,000 7054 Daphnia magqna LC50 18,900,000 ... 1,0203 Daphnia magna LC50 1 <38 76 6320 Daphnia manna "'"LC.50 1 7394 7508 49794 Daphnia magna ... LOEC 19.000 120061 Daphnia magna LOEC 19,000 4464 Daphnia magqna LOEC 1 3000 47,000 5857 Daphnia magqna NOEC 12800 -,12872 Daphnia magna NOEC 3,100,000 7,800,0(00 10600 Daphnia magna NOEC 7500 20061 Daphnia magna ,,NOEC 91,000 847 Daphnia, magna NOEC ,7800 16.000 10600 Daphnia magna ... NOEC <3000 19,000 ,5,857

Scud LC50 <32 333,O 407 6320 Blueclill LC50 >I000344 Inland silverside LC50 50 410 62.30 Golden shiner LC50 236 288 353 6230 Nalco H-130 M Cenodarohnna dubia LC50 Daphnia magna I EC50 Active ingredient Danhnia maana I FC50 N-DecyIl-N,N'-dimethyl-l-decanaminium chlodde 7173515 >1000 5333, 28 37 48 18386 P. promelas LCS0 450 470 500 17880 P. promelas LC50 200 330 500 18386 White sturgeon LC50 0.006 10 20400 Opossum shrimp LC50 1 39 110O0 1B386 Opossum shrimp LC50 52 69 84 344 Virginia oyster LC50 17 94 210 344 Sheephead minnow LC50 770 960 1170 344 Zebra mussel LC50o 30 >.10,000 14064 Mayfly LC50 4200 6900 17880 Scud LC50 90 110 120 18386 Channel Catfish LC50 690 710 730 344 Bluegll LC50 350 590 830 344 3-Horned Wartytack LC50 4850 6120 7730 4175 Rainbow Trout LC50 373 773 20361 Rainbow Trout LC50 970 1240 344 IIII Daphnia magna LC50 83,000 300,000 10117 Nalco Biodetergent 73551 150,000 10117 P. promelas LC50 63,000 Ethylene Oxide 75218 Goldfish LC50 17-0,000 -623 Propylene oxide 75569 W. mosquitofish ýLCJ50 141,000 . 840 ..

Bluegi~ll LC50 215,000)

Table 1 continued Supplier Name and CAS No. Aquatic Species EndPoint*C ntration Reference Chemical Name Min Average Max No.

Betz Deartbon Spectrus CT1300 Daphnia magna EC50 3.6 ppm 5.9 ppm 7.5 ppm 344 P. promelas LC50 .7 ppm .83 ppm .90 gpm 344 Primary Active ingredent Brown Bullhead LC50 1.48 ppm 1.59 gpm 1.70 ppm 344 Goldfish LC50 1.16 ppm 1.49 ppm 1.91 gpm 344 (12-16) AJkyl dimethy! benzyl ammonium cahoide 68424851 Smallmouth bass LC50 1.29 gn 1.37 ppm 1.45 ppm 344 Charnel catfish LC50 .88 ppm .98 Dom 1.09 ppm 344 Green sunfish LCS0 2.04 ppm 2.25 ppm 2.48 gem 344 Blueill LC50 2.36 ,ppm 2.71 ppm 3.03 ppm 344 Redear sunfish LC50 0.56 ppm .74 ppm .98 ppm 344 Largemouth bass LC50 1.07 ppm 1.13ppm 1.20 ppm. 344 Striped bass LCS0 10400 14100 19100 2468 Rainbow trout LC50 2.19 ppm 2.45 ppm 2.74 ppm 344

64175 Daphnia magrna LC50 >100000 11951 Daphnia magna NOEC <6300 14533 ethyl alcohol (Ethanol) C. daphnia dubia LC50 7200000 8808000 12000000 212 Carp LC50 8140 547 Nalco PCL-401 Primary Active ingredient. Rainbow trout LC50 4900 ppm Ingredients rot provided from MSDS information submitted. N/A Daphnia magna LCS0 2800 ppem Bueill LC50 >5000 ppm Nalco Coagulant Aid 35 Primary Active ingredient: Ranbow trout LC50 120 14405 Quart, crystalline silica 14808607 Ridged-beak Pea dan LC50 >0.40 ppm 19974

- - ,P vi; 4-2*.1'*., ,'ýIl' 41ý.P, Concenration, rno Concentration m.

$0 14.. CASNo Aquatic Species EndPoint Gr6owtRepF c Nalco PC.-22** Mix~

/J 7-day uiction 96-hr 4ý P. promelas NOEC 625 625 1,250 Primary Active ingredient: LOEC 1,250 1.250 2,500 LCS0 1,853"_._

Sodium bisuffate, 7631-90-5 LC25 _____ 1,530 Sodium pofyphosphate 68915-31-1 LC10 1,336 .,_____

____~~8 __ _4-hr C. dubia NOEC 625 313 ,,*..".. 1250 Monopotassium phosphate 7778-77-0 LOEC 1,250 625 . 2,500 Dipotassium phosphate 7758-11-4 EC50...:,__.-,. -' .. 1,765 EC25 ______ ¢ 1397 ECIO 14 Lonza Barquat 4250-Z __ _

Primary Active ingredient: 68391-01-5 P. promesas EC504e .3295 ppm .3694 ppm .4225 ppm _

N-AJky! (C12-18) -N,N-dimethyl-N-benzy1ammonium chlori 27479-28-3 P. promelas EC50ir .2054 ppm .3468 ppm 64.449 ppm N-Dodecyf -N, N-dimethyl-N-ethylberanyam norium chloride 27479-29-4 P. promelas EC50% 0.3003 ppm N-TetradecyI-N, N- methyl-N-ethylbenzylammonium chloride Naloo H150-M' P. promelas LC509 0.283 pprm (Note: this product has the same chemical characteristics as P. promelas NOEC 0.05 ppem "Lonm Barquat 4250-7-) P. promelas NOEC 0.1 ppem C. dubia LC50*8 *,*:'"*Z.*..*..;,. "w_,7 ., ":. O.0053ppm NOEC-C. dubia 3 Brood 1 0.02 ppm LOEC -

C. dubia 3 Brood 0.04 ppm "Benzotraarles Category Justifcation and Testing Rationale, Benrzttiazcdes Coaldion, Synthetic Organic Chemical Manufactures Assodation, December 2001 Data provided from TVA and AScttesting performed March 5-12, 205.

Data provided from TVA and Environmental Testing Solutions. Inr. laboratory report.

Test duratons vary from 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months 2 Data source is TVA or Manufacturer.

Subscripts for end points for Barquat 4250-Z are for test data at 72-hr, 48-hr, and 96-hr test at 95% FRdudal ULnits.

Some data duplicated form TVA WEN raw water treatrnent plan.

TABLE 2 Maximum Instream Concentration of Raw Water Treatment Chemical versus Calculated Water Quality Criteria TVA Sequoyah Nuclear Plant

%Active Max Daily Mnimum Max Conc. Active ingred. Active Ingred.

Active Ingredient Ingredient Active Ingred. Stream Active Ingred. Acute Chronic CN1Ze CCC7 2 4 Chemial (or ingredient of Concer) In Disc.harge FOW insrtrean Toxicty Toxicty (1(2 Acute) (1(10 Acute)

_ _ _ _ _ _ _ _ _ Chemnical' lb MGD uy U91 Lrj 1.01 Nalco PCL-401 Anionic Colyner 28.50% 1480 1893 93.74 798,000 399,000 79,800 Nalco PCL-222 Anionic Copolymer 8.88% 760 1893 48.14 1.853.0001 926,500 185.300 Phcspthate 32.30% 2280 1893 144.42 Nalco 73551 Ethyfleuclene oxide 20.00% 50 1893 3.17 200 28,§ 100T 28, Nalco Towedbromn 960 Sodumw Dichloroisocyanurate 90.00% 1425 1893 90.26 150 75= 1.7 SodLum Bromide 10.00% 1425 18903 90.26 60, _ _ 30000 6, TRIO 54.70%/o 1425 1893 90.26 19_ 11 Barquast 4250-Z alkyt dimethytl benzyl 25.00% 855 1893 54.16 300 150 3C

-ammonium chloride I alkyl dimethylethybenzy - 25.00% 855 1893 54.16 ammonium chloride I NalcoH-130M N-decy4-N, N-dimethyf-l- 50.00/% 855 1893 54.16 100 104 50 10.C

_ ecanaminium

_ chloride Betz-Dearoon- (C12-16) alky dime"t benzyl 50.001% .855 1893 54.16 100 104 50 10.0 Spectrus CT 1300 ammoniun chloride Nalco Coagulant Aid 35 Aluminum 10.60%1 8520 1893 540 i1 750 87 1 Data obtained from MSDS, chemical vendor, or TVA.

2 TVA data from Raw Water Chemical Application Guide, Tables 2 and 3.

3 Concentration calculated based on mass balance using minimum stream flow and assuming zero background concentration i stream. Values shown in bold have the potential to exceed the CMC and/or the CCC.

4 Concentration selected based on best professional judgement using data from the EPA ECOTOX database, toxicity information from the MSDS for the chemical, or data presented by 5 Chronic toxicity data from MSDS or TVA data 6 CC is published criteria for TRC and aluminum. For oiher active ingredients, CMC calculated to be 1(2 of the acute toxicity in accordance with EPA procedures.

7 CCC value is equal to the measured chronic toxicity value or 1/10 of acute toxicity value (where measured chronic toxicity data is absent.)

8 Because the source of the aluminum is day, anaturally ccuring material in the Tennessee Valley, and because the aluminum silicate is not soluble, the CMtC and CCC are not considered applicable to this material.

9 Minimum stream flow is the 1010 of 3491 MGD minus the discharge flow (which accounts as the intake volume).

Table 3 Maximum Anticipated Discharge Concentrations Versus CMC Max Daily Avg. Plant Caic. Max. Discharge A Max Anticipated 2

Active Ingredient Active Ingred. Discharge Concentration Act. Ingred.3 CMC 3

Chemical .(or Ingredient of Concern) % Active Discharge4 101 + 1101 Chemical Active Ingred. Disch. Conc.

Ingredient lbs MGD u ugA u/IA uq/I Nalco PCL-401 Anionic Cooolymer 100.00% 1480 1598 ll 111i 200 399.000 Nalco PCL-222 Anionic Copolymer 50.00% 760 1598 57 29 200 926,500 Phosphate 50.00% 2280 1598 171 86 Nalco 73551 Ethylene/Propolyene oxide 100.00% 50 1598 4 4 2000 100,000 Nalco Towerbrom 960 Sodium Dichloroisocyanurate 96.00% 1425 1598 107 103 100 TRC 75 Sodium Bromide 10.00% 1598 100 TRC 30.000 TRO 54.70% 1425 1598 107 TRC O100 19 Barquat 4250-Z alkyl dimethyl benzyl 25.00% 855 1598 64 16 50 150

-ammonium chloride alkyl dimethylethylbenzyl - 25.00% 855 1598 64 16 ammonium chloride I Nalco H-130M N-decyl-N, N-dimethyl 50.00% 855 1598 64 32 50 50 clecanaminium chloride Betz-Dearborn- (C12-16) alkyl dimethyl benzyl 50.00% 855 1598 64 32 50 50 Spectrus CT 1300 ammonium chloride Nalco Coagulant Aid 35 Aluminum 10.60% 8520 1598 639 68 10600 750 1 Average flow reported In June 2003 NPDES permit application 2 Concentration value assumes no treatment for TRO or detoxification of quaternary ammonium compounds 3 The maximum anticipated concentration presented by TVA in the Raw Water Chemical Additives table in the Raw Water Treatment Plan 4 TVA data from Raw Water Chemical Application Guide, Tables 2 and 3.

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 & C Annex 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-1 30M, Barquat 4250-Z (also known as H-1 50M), and/or Spectrus CT1 300 for mollusk control.

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

3. 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.

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-1 30M, Barquat 4250-Z (also known as H-150M), and/or Spectrus CT1 300 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 SQN has conducted and passed quarterly toxicity testing in conjunction with non-oxidizing biocide treatments with H-1 30M during the current permit term.

Printedon recycledpaper

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).

/ certify underpenalty of law that this document and all of its attachments were prepared under my direction or my supervisorin accordancewith a system designed to assurequalified personnel properly gatheredand evaluatedthe information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gatheringthe information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significantpenalties 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 Addiuves at Sequoyah Nuclear Plant PRODUCT PURPOSE FREQUENCY ACTIVE INGREDIENTS REPRESENTATIVE AQUATIC TOXICITY DISCHARGE OF /DESCRIPTOR CONCENTRATION1 DISCHARGE (ppm active ingredients) (ppm active ingredients)

PCL-401 Dispersant to Continuous Anionic Copolymer 48-h LC50=798 (D. magna) < 0.2 facilitate iron during cool 96-h LC50=>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 Biodetergent Surfactant to Periodic Ethylene Oxide - Propylene 3 brood IC 25=28 (C. dubia) < 2.0 73551 facilitate oxidizing Oxide copolymer 7-d NOEC= 105.4 (P. promelas) biocides (EO/PO copolymer)

Towerbrom 960 Oxidizing Biocide Periodic Sodium Bromide & Sodium 48-h LC50=2.43 (D. magna) < 0.10 Chlorine (Chlorination) Dichloroisocyanurate 48-h LC50=0.679 (P. promelas) (Total Residual)

H-130M 4 Non Oxidizing Periodic Didecyldimethylammonium 3 brood IC 2 5=0.139 (C. dubia) < 0.05 Biocide Chloride (DDAMC) 7-d IC 25=0. 104 (P. promelas)

(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 LC 50=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 to be 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 GuideI Product Injection Points Max Feed In Plant Frequency of Average Estimated Maximum Daily2 (ppm) Target Application Duration of Max Days Usage (lbs/day)

(ppm) Application. per Year PCL-4013 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 Copolymer 3 ERCW 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 3 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 960 4 ERCW Train A & B 1.5 1.5 312 days 4-12 hours 312 1425 and RCW per year per day H-130M' 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 daily usage (bs/day) is higher than the 4-12 hours per day usage 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 lbs)

PCL-401 2.6 mg 1 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 1 lb 71,800 gal 3.785 L 60 min 24 hr 1.10 760 lbs/day PCL-222 copolymer 0.8 ppm active L 454,000mg min, gal 1 hr 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 mrin gal 1 hr day BioDet 73551 2.5 mg 1 lb 71,800 gal 3.785 L 60 mrin 0.5 hr 1.10 = 50 lbs/day BioDetergent 73551 2.5 ppm active L 454,000 mg nmin gal 1 hr day TB-960 1.5 mg I 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 mmin al 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 mrin 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 nin gal I hr day Spectrus CT1300 3 mg I lb 21,500 gal 3.785 L 60 miin 24 hr 1.10 = 855 lbs/day Spectrus CT1300 3 ppm active L 454,000 mg min gal 1 hr day CA-35' 30 mg I lb 21,500 gal 3.785L 60 min 24 hr 1.10 = 8520 lbs/day CA-35 30 ppm active L 454,000 mg min gal I hr day

1. Coagulant Aid-35 is fed at 5x product dose (or 1Ox active dose) for quaternary amines.

It may be applied to the ERCWA & B Train and RCW when required.

Max ppm feed dose of 30 ppm is based on theworst case scenario of 3 ppm active H-130M, Barquat 4250-Z (also known as H-150M), 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 calculationl 3/7/2005 SQN Biocide/Corrosion Treatment Plan Rationale 4

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

Plan Overview This document describes the process for detoxifying SQN's effluents from the application of quaternary amines as a molluscicide. The Detoxification process references H-1 30M but is applicable to Barquat 4250-Z (also known as H-1 50M) and Spectrus CT1 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.

Results from these studies are incorporated into the attached summary of toxicity endpoints compared with projected instream product Toxicity Assessment 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 quaternary amines work.

Quaternary Arrines 3/7/2005 SQN Biocide/Corrosion Treatment Plan Rationale 5

TN0026450 Ra Water Chemical Additives for (RATIONALE SQN PCL-401 (Anionic Copolymer)I 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 TMaterial Safety Data Sheet.

PCL-401 MSDS.pdf S 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 f.7 Material Safety Data Sheet.

PCL-222 MSDS 1Product Bulletin PCL-222 PB Biodetergent 73551 (Ethylene Oxide/Propylene Oxide Copolymer)

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 oroduct has a low toxicity and will be dischared at low concentrations.

Document Summary Material Safety Data Sheet.

Biodetergent 73551 MSDS.pdf 9"IM' 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 discharae limitations are met.

Document Summary Material Safety Data Sheet.

Towerbrom 960 MSDS. pdf XProduct Bulletin Towerbrom 960 PB. pdf H-130M (Didecyldimethylammonium Chloride)

H-130M is a quaternary 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 ?

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 quaternary 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 IA Material Safety Data Sheet.

Barquat 4250-Z MSDS EProduct Bulletin Barquat 4250-Z PB Spectrus CT1300 Spectrus CT1300 is a quaternary 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 CT1300 MSDS Product Bulletin SpecW-us CT1300 PB 3/7/2005 SQN Biocide/Corrosion Treatment Plan Rationale 8

TN0026450 RATIONALE for Ra Water Chemical Additivest 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 Material Safety Data Sheet.

CA-35 MSDS.pdf Iq Product Bulletin CA-35 PB. pdf

/,

3/7/2005 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 (RCW) pump suction header for RCWto ensure these raw water systems are protected. These systems, the ERCW and RCW, are essential for the safe and reliable operation of the plant. SQN 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. SQN 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) recquires 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. SQN 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. SQN 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. SQN 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-130M, 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 quaternary amines as a molluscicide. The process references H-130M but is applicable to Barquat 4250-Z (also known as H-1 50M) and Spectrus CT1 300 as well.

Back-ground H-130M is a non-oxidizing liquid organic molluscicide containing a quaternary 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 quaternary 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-1 30M required or the length of treatment is greater for the same mortality rate. Below 60 OF, the effectiveness of H-1 30M drops off quickly and dramatically due to lower mollusk metabolism rates and slower chemical reactions.

Generally, 70-72 OF 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.

~~.. ,.

ERCW/ H-130M with 60-85 6.0 3.0 24-120 RCW CA-35 clay detox at 5:1 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 ERCW A 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.

Application/Equipment 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 lbs/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 quaternary 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-130M 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 21,500 288 6.0 35 10,080 1st Veliger Peak 21,500 90 6.0 35 3,150 Treatment 2 nd Veliger Peak 21,500 90 6.0 35 3,150 Treatment 3rd Veliger Peak 21,500 90 6.0 35 3,150 th Treatment 4 Veliger Peak 4th 21,500 90 6.0 35 3,150 Treatment 5th Veliger Peak 21,500 90 6.0 35 3,150 Treatment 6tIh Veliger Peak 21,500 90 6.0 35 3,150 TreatmentIIIII Fall Treatment 21,500 288 6.0 35 10,080 Total Annual Usage (Ibs) 39,060 Table 3: Expected CA-35 Chemical Usage T eatm en .......... ..................21 i................

.Spr.ing. 180 52

.k .e a 2 1 ,5 00 9 4' 18 0 L 1 6 ,92........

1s Veigr ea Teamet 1,0 94at3 18d 1692 3Vd Veliger Peak Treatment 21,500 94 180 16,920 4 th Veliger Peak Treatment 21,500 94 180 16,920 5 th Veliger Peak Treatment 21,500 94 180 16,920 6 th Veliger Peak Treatment 21,500 94 180 16,920

.iiiii:.;:* Fall 'Th~

Treatment AUiII,~ ~ Usaiei 21,500 (I ~jj..j292 .. 180 52,560 206*ji ,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 Cone.

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

(< Acute endpoints) 101 -1532 MGD

(< Chronic endpoints))

48-h LC5 o L 96-h LC5 o NOEC IC25 (ppm as active) (ppm as active)

PCL-401 D. magna 798 _

Bluegill - >2,850 0.2 0.088 Rainbow Trout >-1,397 PCL-222 2 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 3 - 0.172 - 0.139 D. magna 0.094 - -

P. promelas3 - 0.172 - 0.104 Bluegill - 0.46 -

Rainbow Trout - 1.10 - - 0.05 0.022 H. azteca 3 - - - 0.144 C. tentans3 - >1.50 U. imbecillis 3 - 0.159 w/o 9-day LCs 0 silt; w/silt w/o

>0.300 silt=0.047; I I w/silt>1.50

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

(ppm as active) (ppm as active) Discharge Cone. iQ1o -3491 MGD

(< Acute endpoints) 101 -1532 MGD

(< Chronic endpoints) 48-h LC5 o 96-h LC50 NOEC I IC2 5 (ppre 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 -

NOEC 0.07 G. - 0.04 ,

pseutolimnaeus Notes:

1. Data Source: Manufacturer unless otherwise noted.

2. Toxicity of PCL-222 assumed to be 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. 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. ii 5.24

-emalared in ww 00 Zebra Maud Caftil Applicadm at Isndaal Fadc'e C Ai M* ugh, P. 1L Gil and R. A. Muia Calgin Cobamain P.O. Box 1346 PlasburghPA 15230 Absta~

Sincltlr introdction into US watuways Zda M*els (Drdmw pofymuphe) have

-ra nody *mrugh otth Grea Labs and Mksidjq# egma.& ies muuela haw cotinuod to colonize the intake ppe. of ha al wotr sM ies ad water dgtributln s,3egmsthrmou the affectd atom Thni collonliziltioa has compromised pllit mbty and pubaioa eficmacy, and eam*l iwu- coost to ~wain users.

The dmign ofea: icuhdusia plan water "dl ti MM Is unique. A comprehetsive zera mued control c utmgousdig the best vila olpim mus be considered in each Vecific satuation. Thi ~pq dismis.. the .azzail =s aof on tratg ( a qucparinazy ammonia-based moiuscicke) in the bmle agsinet zdn munelL IU conmmercal lIfe cyce olan induial molucidde bepan with initial uoiy Keeaig in the lbaratory. The mvahtion ontinued at M=uz= th r fied ,g r and

, o&d= L uoa lammed frthse expereum . -

direct mor F M- toward the developmet of a woond generation pmopam.

Kpyword& Zdma mussielm*oolaicidc, intake Wucu*r, nmacoulng -mli- sat cendodmfl and qua*ernary ammocium comomzmg INTRODUM"lON Zeraa modek hawv been kund = far south u New Orleans, and.= far vm, as Oklahoma.

(Frigur 1)' Addi*ioal infiectafim of this m ipnin is emxed to cwtimae at a Nay dow riat As an tmp. Corblcu/av (Asian Cla) vme &Afiahd in the sta of Washington and ca nw be found in most fresh water uytm na the US. Th qxead of Asian dlams took nemily twenty yews from the time of tbr introduction.

Becauc of zcba mases reoent introduction into the North Amencian watterway (with the ladI ten ywvu)ý plants and nauxk ial frilkie not prepaedu to handle the problems nociated with their infetattion. In Europe, inuausticm hadoulpted moodified design, *At minimizes the coloization pdftlms of zdxa mmseL Due to the aphitl expeiditure; ivolved most North Amerca cunpime.i an not Able to modify' exumisigItalm atructures at all plan faclitie.

Copyright 01995 byNACE InternationaL Requests for perrnission to pubrish this manuscript In any forn. in part or in whole must be made in writing to NACE Internationaj. Conferences Division, P.O. Box 218340, Houston, Texas 77218-8340. The material presented and the views expressed in this paper are solely those of the author(s) and are not necessarily endorsed by the Association. Printed in the U.S.A.

Genal, such deign chans are mow com effcenty lmplemed during new constnom This is a real dilemma fir facitics.

As reported in a xum conducted by the New York Sea Grant publication DiUMaI 2,m Musl rn.ma louz*lding=. mLwpmes rewblated to zdxu mU selst 339 facilities totaled

$69,070,78o. In addition to the millio of dollUas spent onminin,,izipz, musmeliistation, plnt " dered the additional risk of pluged safy related equipment, valve seas, and ftir war,5Ymms. 'r mmn expedi*r per aility was $205,5V0. In some c . tlwy al incurred the additional eqxupess Mead to lost produ&con due to plugged mc'ms and beat ,xh.ang equipmeu. Ze mussel infsatio as o ha moused nmipl water suppli great difficulties in maintning sufficent wa= supplies to thar csmmnes.

Chmcal contro of mollusk colonization has .cthe mit accpted method of atanenL Of these chlorine is the moot mommoly used mo iide. Howver, regulamoy awecie and x ics .bave mxprmssed increased concerns over chlorinated orpnic compounds, fi= oxidants and indirect trihalosrnnes ' These chemicals can Pesid in the envirnmmet. Storwa and handln-of large quantities of chlorine art regulated ud SARA Title II. DCtoxication of chlorine is needed prior to discharg. Chloination can also inc*r* the cormsion potential. All of these fxtms could lead to the emraabandonment of chlorine as an %tiono A im of chmial mon mquaternary mmomum commoud (Quts) is now being used as an altaMave to chlm for controf c &Crioun&Quas function bY Interferiunm th oxyscn trunf acM the gSll meMbrMme cithe zof a musseL. NormOy an 9-24 bou continuous aplicatio of Quits is med to disinfec distrbadin, systern piping several tinme during the mollusk breding sea . Cotol s maintained

keepin the se ofthe abimusl popuution auh that they wil noet interfere with the heatechange equipment. Quts may need to be deactivated prior to discbar, pardailarly In once through cooling system.

LA"ORATORY VEMIFICATION OF QUATS AS A MOLLUSOCIDE In 199, a compreaesiv research pmjoct was began to develop a mlmauicidf for industrial use. A litertum searchof the physiology and biologil qC~so DAknap*oftm'a -t was initiated. A ba musmel farm vsm d lPe4, to bwv muwel speimms and twst various potential an them. (See Figure 2)5.

oolluaicides Screeni Ct quatmmary ,ammniu, ompounds and ot po**,l cemcal by Static Renwal StudiMS w, the fa step in the vesificatin procw, Became of the smccm of quaternary arn mma co mpd agant Asian dams, C*rblkuaý,a itrnasy amnmium ompound was

-valuMtd at an industrialbfAity along Lake Ere. A field trial U demwid that the quaslm y amnodu= Compounds wm efrecti at the I d concetration rang (0.50 - 2.50 mgl active) achieving 100% mortality. Bkomanx mmntilid at this facility with z*a mums acclinmatd to the plat int h w&.

a The wat temperaur during tbe screis oftm was Z2t. A second scrims atests were pua rumad in the late f&U wha the wer npu ad dropped. During this seies Of tesis m* chemikal was naedod to kill the musse than in the *t &r series t*ts.' DuI to the varying rmits in the field, it was decided to verify and allmpt to dupicae the reults uiter controllkd laboramy coDitions This dosion was mad with the iuniion of registeng the quaternary armmnomn COMPOUnd a a mo~uadciW The laboratOry phass invoved the conastn of the flaw-hrough tet chankc (Figure 3).7 Testing Of mUssl in a dynamic rsytm like &lowtMh test dhab= hel*p stmula biologica activitim in the muns. In mtdis puermed both in boratry and fkid appUlWcgao, a constant flow af fresh watr over the mnmels curagd activ filbtioa-Theatig oflb m==es at various cwf os and temperature helps optimIz the tetmeU sgrafe s and nm im the amou of preduct und In the applicto Qmn dDage fur zeb-a xmuel control is a fincti i war mperature. As th water uaupeuture decrass, 524/2

the anwnt of Quats required tot cmtrol the zbra mussels his gh. At 22M 0.25 mg& active conmxution of didcyl di&mhyl ami nm chloride achieved 100% Muulity in 120 heDu While at 18IC the u dmWacheved 100% morality in 240 b s. By increasing the concralon tD 0.50 mg.L activ couation of dudecyl dimotl arutmoum chloide, the time required to achieve 100% morality at 20C wu 72 -ours.

Using the* n don and lwering the wantempture to j°c,restated in an increase from 72 houm to 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months in ordir to achieve 100% moftlity (FW 4).

BfEr the product could be use in the field, an effctive means of deactivatin the product had to be addrmed. TJU un otban'jti clay had demoetratwd its ability to dacivat the quamnary ammoniu mpoun. In studies pmerme in lboratmy using deonized water. 9 mg/&4 ob nitD layw needed to deactivit 5 mg/i of the Quats pmduct( Figure 5).'

In the fd, wtr the sysam wan hu vawyg concentratmof ctmmi charge particles, amounts afbentonite clay aeeded to deactivate the Quals is lwer.

A Zdra Mond Detoxification Tail was cnucWd (ig 6).'OTe trailer was designed to be portabaud aslf'conmied. M tier operat at remote sit ung enrgy from an atthed electrical geeratr unit. Betoite clay is delivered thromh a hopper to au which the cay disprme into an eductor that WNiliz 273 ma/day water flow. Th clay Au is then introdued to the discharge at this point.

Aftr investiagti sgvren diffeawt snarios in the laboratory, the product was taken to the field for cffic studiMs at industrial sites.

LESSONS LEARNED No two indutnal waer distrAmbion systems are alirk XtIt ICitiC1l to irveati the enti sytm. Input *should be gat by all operati gnPsivoe Mollusk orO mes qpevon safety.

evirmnnamlm commomly invclve smaiaten a maapgea personn l.

FAAh goup we& to be co tad and be in agrement

n the =emtin Pla MUny fahcs amr ivv in the deiom to use a cheical for mollusk control. The four main facWors are the physical charctestics oftbC plant, the nature of the chemical to be applied, ewonomics and the frtqency of applicatioI" Aftr thb criscria for zebra musn cointrol trate had be=n considr, the moluscicide was aplie at sv=a industrial faiiti At eac facilhty trested, mom acmate bkwledg of xisti intk structures, as wUlla inasaue undmiuading of biology of thbe =bra mussels as it hor adapted to the North America we*r acquirod. Te str was modified accordingly at each site.

CMemical icadm ad Plant DistribRtmM Systm Csmaldert As pmviosy meibonod it is Umporan to thorugy undentand the system to be treated. A sudy of dim m sylm r &ndWaam. wil hanp detjerin w the grcau:a hmat of mouusk ifsatioa Odsts. But do am rely on p*ant bkqudns fr the whoa picture LUpda and mdicai to iing intake strcum are not algwqs depicted on the bluepui Opetors nd matnn peVrn may have the beat knowlg of crm cnec or dviatios frnn the ccm*sysem.

potabl wager sysems, yc wuh MsaioM a shows ould be circumvented duin appliatio of a cemical mollusk tbeatment. In ase c&= it is noaauy to dille time the UWemnt with ou s,"weMds, or durin me ing hours to vd conflicts with the opration or avaiabgiity oaother sytems in the plaaL i 524/3

It has also been observed that mollusk infiestation within a ddnmistiuto aystem pimaril affkt the firt oWe Imgth of piP In =r experiece, vve hav never se or hiard of a discharg ystem had a plugging problens de to mollusks Where cooling towen ae integral to the operation of an industrial water distnrbution sysen, it isa good pactice to blow dowa the towv and minimi cycles ofconcm tration the day pir to applicatim of a mUolusk Control program. Whm bUtmn t isstarted, the coing twer blowdown should be hut off and the vitm dosed with the Qus at the dedsrd cocentration based on rystom volme. latural deactivation wil ocur due to solids i the s*ysem and contac with di.sibton ssem Pfacc Wh= dcsuial kvds meet dicharg level, the b1odown valve is opened and nonnal operation is reumed. Some Quaft tend to cam foam in ooling tom It is important to choose a doage rate that will be effective *ut minimie the amount offoam gcnerated.

It may be accessary to han uatifosm available at kast the firat time a cooling towu is tcuted in canexu ilamounts of foam are nerated.

Firewater systcs had bo taWd usinig a treat and soak mchd. The fartht ed of the qsym wa flushed while Quats was being added to the s=ince water system. A rnda of Quats was measued using an Cokimeic Dciezniaatin ofDidveqydiznthyammokn um Chloride method.' 2 Whm a residual was ftud, the hydra i shut off and difflert laterals wue operated.

This cuatimud until the etio fire water stams contained treatd water. T syste is then allowed to si for twMnty-four hours and thea fushd.

The key to dEctiw truatcmat is to maintin an active residual of Quats during the presrbed treatmen pedod while achivig the deied motact time. In the cae offlowing water, the hmical must be continually added to keep the residual at the desired lvel. In the can of the fiv-waer system, oace the residual k-ve is readmd, the ystem is simply bettled up and maintained without the need for additional chemical.

Another leo lssonard was how to start up a Utatment to get quick reslts with the optimum amount of chemical. Many plants have surp tanks or toagp tanks in varow jmrt of the system.

If the tanks ontamin amoun of water that will trn ovr sVly, it is important to dose these a=ea with dweical on the day oftratint a the rw of the qcsysm is tea In this manner the eatire distribution is treatedat the iame time. Althogh it may sound insVificant, 3 or failue of an applcafion depends on reaching the effective residual as quickly as possible.

A treatment acbedul is wbied to prferecn=e and the potentia rsk thAt the plat is willing to endur Some fadlites c:oose to trad oS per year at th end of the breeding saam, which is nmnay miSeptmber. Othes dp the sqping trctment, but trea tw=ila in the year. First treatmmt is right deer the peak ve r rems during the sum , and the second treatment is in the fJ aftr veligr numbers dimnWish It is impotaut to momito both the adult and veliW population In t source; water. Tis should be done continuoWy when water tesoprature is abov 3C. T1wprn o cither f stlng adults or a igh denity otve rs will Indicate the need fbr a treatment. Qwnw industry procedures outline both mouitorix% protocol and sampling protocol. Moitoring for juvenl or adult munds on artificial svbatrat (coertc blodw, PVC) should be located a& critical intakc structur mm than ow monioring site a rocoms eadod duo to the variabilty ofttlling mussed Monitoring foir vdi in t u= water custs oflpaming a known am t of pant water throgh at Imast a 40 micron plankton ne w~th a spedie cup On the end. Microswci observation Of the residual material wili allow detnninaboo of the number of velipm per unit volume of water. Trackng this data will reval the trends in breeding activity that will be usful in timing zebra mussl trestment aplicadtai 524/4

In oWplant, zebra muMsIC Slfls were AmW in heat xcbazg tubes when mainenance persoand were woddag on the exchaqczuL Muzinu~man personnel fluysbad the akeilas ot of the symn When the qappcaw = ofacbra mium shells bepan to increa at this plant the plant persorad decided to dos a aoomcidt One day aft dr bhasnnat was aqppidt plant pevnuanel were muuam~d when a &4u of whm mul time Wainud up cratial beg exchanger i the plant and Axced an egmrpq outq. The mwa al was cleane up and the pla was put back&on Within moe.r 24-hwur period. the heat owlangerswen onc agamn *ed, but this time by whra mum! ahels The two contag canned the plai to loge appwximately one millon d&ra in IoM prodxata time and amso ed dcan up coM.

7he tboory belzizd ~ecziw periodic (Mt treatmes ii that anna digrbtut= s)Uem is dixinfiomd or mldfins it is kzq%ckn by kiling off molUt colornes beft they grow to popoaitio that would plug critical equipami in a wator diaiulm 3s 1, Owc a srmn is dean coly vcllga wec Introducd lInt the plant an acotnal basi during te brooding scas.

Wdl-ded Ireatments will kill the ve sid m insur a cdean om.

Monitrin the =bra mumcl papilazo Isthe key for the initial ftratm= Immediate zoactions to the prucamo of the oranism can help elimiznte infestafion prebkema Tmesuh*we As a put ofthe monitoring proxtcl. a log of the auent source wat temperatute should be maina/id It has been exouerc that wear temnpcsto is an imptat cAerion for efficacy of a chemical Lztecot p*mram. Zetba mussels aiM be acvey siphoning in order for the chemkal to do Its job. At weter tempambm below 16 "C, the aiity c*fzebra mumek slowis dzamabc'y.14 Althoug*hmkal tm at a stil mplis the dewind affct zebr mussel cntrol will acquire mde emi ndA "lla w te ment The aun application that would lake 24 houn at tempertur above 16 -C might take as long as 3 days to yield the saw reults below 16 *C wa tenpeiue. Is5Ti exitded u'eztme timn wMl iacreas the Cm OfUeaMMn Water Velcity In additiWo to tempm t watw veocity aMocms zuira mumse w*ationz Zbra muumels pmfor wat kow ratc of 1.5 m/c or lows Coouizaekm of wak msyAM with-a water velocity over 1.5 m/i are rame.

Intak Ane&ay area ad stms with Waler V cti bm than 1.5 MI/Nec aM high rifk W=L 16 It has been obarved tha zebra mansehs ohe tond to cokonize &dr Uyaton to a eaier degpe than Cho W udig ai xav firm%,ad h1m A Gotait wai DOW along with he nutrim load waumarated in a mall arapFwvd the zeIn G usse with a Pedhet breein 17 Thc main circulating water in C"=u Is nota2 ocemnbau the wUte Velocity is high cnough to discoura zebr umume! attacbmant For czeniple consider a wafte flow raft in tbe Pama srvc water loop at l09,02o m'/day whl the main ciculatiqg water flow raft is 2,725.500 M3/Iday. In thmas ailamu anadeuat anriecwater teactmightbe Quacmodinwudy aplnied at 1.5 mg/ active for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . No &deativ of the cmial waseded due to the msfficmt dilution with the main c.latiU water W=M The re udal Value Of tne Qut in the disdharge was well below watm quality eflumataInacbr ZarOimMaO Fate Mad Deacitvatkm Suim. Qualm hav a catoknic dmbAre it is generally mcepnd tha their molluscadal mode of action invelves coagukaton of muous on the zebra mosel giLl The binding of the Quaft to the 524/5

gill will Wat down atain biochmicl radion in the zeba miuel (extjrnal memibram bound c-cnzym and zupnsion).

The affinity for Quats to adhem to the maucas of gils is the pumuy concea m efflue wutess. In order M pmvt thin mode of adi In non-tareted orpnisms, bntonite cay is added to the dchae war. T7U day hisaaslihty aonic hap on the swurim and t -datomml.

wh addedn twt. The clay acts like a qx and adI I -any naing Quamts. The adsorpio onto tme clay rumks the Quats unavailable to aftach to the gils afnon-targted S Exrsive studie we coadctd on the clay and Qum complmx. Admorp and desompon studls showed that the Qumm nmmmned cwwkd to the day Ae di=a into the benthc envirommmn Bimailabift and dendati with acdimated and mmclinuktod bacteria have shown tha the Quats were sti availbe fwr biodegadatim but at a rtedud klteL Other shidies Incudng ss"m valmtlo6 ris auuw and degradato using natural idneiWt cownhlded that the clay-Qumn compkx was stable and had no advere effect an the enviromnent in amo to tese temt ma toidd work ws take duig ttmenapc ation. Results fbon all facilitis tmted showed no residual toxicity 0a daphai and fathead mim in efther acute or chnic tesft

-- DeactivaiDon of the chanical is a majo pt of the treatmiL. Specialized day foed equipment is used to ddiv a prcscri d amoemt of dxy slurry to the discharge strm Cons*amt monitrg of the clay faed is needed to imamr continuous feod of the, dlay to the,discarg sstem. Clay feedmr ane St each om"l a&4 Cosmind with the curret analtica psoociwe make the Quats treaunent program equipreeat and labor intomhm In additio to the ct relMatd to dW a of the Q*ui, conMS ae 9i unonfolabe with the idea afadding day to deactivate the cbanicuL In order to eliminate the use of clay in th proces, a search for an alterative Utmeneat wa ingitued A SECOND GENERATION CHEMICAL APPROACH Qufts were Efit used to control Atian dlams (CombIcmWa) and m Icrooansms within coolin towcr systems.' It was logical that the use of Quats could be cxtended to control of the zeba mscti. Even though Quat cheimsyry bat been shown to biodegrde in the envument and not acm=Iaw many mms would lue to avoid the use of bDoUnoiitc ayr deactmyou" Industiy has calld fDr a more OaiUve Utatmn pro0co for vdig tro tan the cu.rra periodic treatmnot process Conmtin suineerch into altenate ctemistries has resulted in the &delopment of a new che arwil With a numh largerned for zbra mumel Wont and the desire for almt %poacke for ontrol the search began for a gmration MOUsciaci Seond A amibinfon endotball and filmiln amimne unNdaly w as EVACrMC) (amine mlt ofendotha was ideifed as an altratv to existing chemisies. The amine mIt of edor1h has several advantaes that positon it as a second genrCaMi a -Oht0 mollusk cmnmol. Listed below amc the inqor dilkrencm between the ami ast c*endatafl and Quat che-m y-

, The amie alt of endothall cn be appled without the need for de:activ with bentomite claL e Plriodic trmatm s of only 8 hlmt for tbe amine salt af edoh*all ompai wll with.

10- to 24-hir aplikatIoms for Quats Ci) Re*gister Trademark of lf Atchi North America lime. EVACnTM Is M QI,N-diimethylalkyil&min lt of endothda

Ipmib

t inAa W 524/6

7U h amnalt cmdoda caln be qied on a raauim whedue throuhbowit bebreai* g

-as for control afw'legeru The cavimsmentul &eWof doh-fainoff~odotal!i ci s better than Quints, simo its half-life is only 24 bow%, while the MY-NoIif of Quwtis.29 days.

In recen iched application, the amine aft of eadatball prformed effwftivdy Aga, zebra mMdl& Throbo awmation l eviinn We* td. Effia.y

m* mam dmwn i.igure 7. In the firt aerics ofteis I nIr active amie salt of oadotha5l *ctivdy killd all the mua in a 24-bour expoam The w, am were performed udng 2 m&/ acive amdiie salt of ondothu.

Within S hos of ckeical feed, 90% of tbe munch wen dead or no raomiin. Tlhe cbcaucal feed was dismtindud. A onant flow otmvcre water was ntaied oam the tefted mussels withomtEndialL After10bom, allmu m vlsu deirdadorrnotqosv.

Th but scras of tuts wer done at 5 mn/4 activ amine .11t ofendo&Al. Within 4 hourns the s=t of chemical fod 85% of fthmnxs %wedead or not respondin. MChmical fbed continued until all rereals we-dead or not responding (Fig 8). 2 Th" indw a- k of odotMhil cheiy rqrtscnha the flat FVRA opprWd prodwt to tke moUmk coowd to the not level. The moUmdkal mode of acto of Whis product is ad comiletely understod. Th produ aems to coat the ill mmanI ofthe moIua1z which inteiteres with oxy.li ba *er. T1h mim alt also a.s a hish affity withsufc. It adhers Wtoppag walls ad minepeod olds Inwow dlruhtion quemL At nomal we concdratosK the prodit d=o not exit in discharge wter in sailfiemaantL Conrol of v*ligmrs as poamible witouat th urn ofoxidizig mou ide and the h rds amnociad with oxidam. In a Utdy conducted by a power Fgc-ft cMnPAnY. aeaement of idigus decre by 6M%211U elsizminato of ft need for deMficab= by baontaift Clay pli~fi the Wbcoti:on ofbe amine alt of endotal This is a itep in the rih direction ad builds on kon karned frm epeiences pine with Qua opplicatim CONCLUSION Ziramaus como coaidcrauou arwe h to my. New coanstnicti will hav to tda molusk fmling iwo accont in th dsin ofwaler distibtiWo sydtans. E syatas will comutino orqwrcaoih* abatementxmetods, psaticlady asthemiummuse rngeepands A comprehenafre contro WaftVumst be devepdý tha anetg fthqczulos and sakey goals of p-a ow*ns ad opeMtM. lh mrcb for samnaweot methodsconms. Whil =rwt auenmm inholvd Qwn a, chlorinme a new moflu ide has been develope 11e deelopmen of "hinew molhaucicide was bowed on field expeeCfkG and W=oifcasi uniq to zebra nUese contol in industial application.

524/7

V.

Figur 1 - Dishriution map of zebmram-swl oolomizetion Average pH 7.85 Chlorine Residual 0 m-gL Dissolved Oxygen >6 mg/L Total Solids 170-39%mg/L Calcium 30.50 mgfL Potassium <0.50 Mg/L HOW' 10Ž Tankk m~akeup Tank Figre2- ZdraMumd HolIwng Tank 524/8

W F],*

!.Fo. . J*¸ L.... l* Feed Tanik

[ *Pur ,

s Opp ly

0. Qa Tak 300 150 I

0.5 MBIL 1.00 MVL 2-00 M&41 5.00 Mg/I Dom lad ofQoatuC =$L)

Figui 4 -Dosag level o(Qiuma wed to obtiWn 100% asoillity ut varnour tempamnru 52419

FWMv 5- AmmWountcIntonite clay wed to~decvWe aoUMM ofQuatg prqmhld in didmized wuar Figure 6 - Deactivation Trailer for ihe Quat 524/10

Piar~ 7- kamuJk cOlw4 A*mdl.ups'Soiim.i in tbhc~d Mmod 524/11

MATERIAL SAFETY DATA SHEET PRODUCT

~NALCO.

PCL-401 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC

11. I CHEMICAL PRODUCT AND COMPANY IDENTIFICATION I.

R PRODUCT NAME: PCL-401 APPLICATION: WATER TREATMENT 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 1 = Slight 2 = Moderate 3 = High 4 = Extreme

12. 1 COMPOSITION/INFORMATION ON INGREDIENTS Based on our hazard evaluation, none of the substances in this product are hazardous.

3. HAZARDS IDENTIFICATION

- 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 IN'A **PRODUCT

~NALCOjc PCL-401 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.

14. 1 FIRST AID MEASURES EYE CONTACT:

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

SKIN CONTACT:

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

INGESTION:

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

INHALATION:

Remove to fresh air, treat symptomatically. 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.

15. 1 FIRE FIGHTING MEASURES FLASH POINT: None EXTINGUISHING MEDIA:

This product would not be expected to burn 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 Roads Naperville, Illinois 60563-1198 (630)305-1000 2/9

MATERIAL SAFETY DATA SHEET I PRODUCT NALCOL PCL-401 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC

16. 1ACCIDENTAL RELEASE MEASURES PERSONAL PRECAUTIONS:

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

METHODS FOR CLEANING UP:

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

ENVIRONMENTAL PRECAUTIONS:

Do not contaminate surface water.

17. 1 HANDLING AND STORAGE HANDLING:

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

STORAGE CONDITIONS:

Store the containers tightly closed.

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

18. 1EXPOSURE 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 3/9

MATERIAL SAFETY DATA SHEET PRODUCT

.rNALCO. 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.

19. . PHYSICAL AND CHEMICAL PROPERTIES PHYSICAL STATE Liquid APPEARANCE Light yellow ODOR None SPECIFIC GRAVITY 1.16- 1.20 SOLUBILITY IN WATER Complete pH 0 4.2 - 5.0 VISCOSITY 20- 160 cps FREEZING POINT 25 OF /

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. 1 STABILITY AND REACTIVITY STABILITY:

Stable under normal conditions.

HAZARDOUS POLYMERIZATION:

Hazardous polymerization will 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 4/9

MATERIAL SAFETY DATA SHEET P4'NALCO, Ask,..:.. ý

~ ~ ~ ~

.~ .Aft..:

'd .. . :

f loft.

, .. . PRODUCT 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 mg/I Product Bluegill Sunfish 96 hrs > 5,000 mg/1I Product Rating : Essentially non-toxic ACUTE INVERTEBRATE RESULTS:

I Species I Exposure I LC50 IEC50 I Test Descriptor Daphnia magna 48 hrs 2,800 mg/l Product Rating : Essentially non-toxic MOBILITY:

The environmental fate was estimated using a level Ill 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; Il Air Water I Soil/Sediment I

<5% 30-50% 50-70%

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

Nalco Company 1601 W. Diehl Road - Naperville, Illinois 60563-1198 (630)305-1000 5/9

MATERIAL SAFETY DATA SHEET P'NALco I PCL-401 PRODUCT 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.

m 1 13. I 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. TRANSPORT INFORMATION The information in this section is for reference only and should not take the place of a shipping paper (bill of lading) specific to an order. Please note that the proper Shipping Name / Hazard Class may vary by packaging, properties, and mode of transportation. Typical Proper Shipping Names for this product are 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 115. 1REGULATORY INFORMATION NATIONAL REGULATIONS, USA:

OSHA HAZARD COMMUNICATION RULE, 29 CFR 1910.1200:

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

CERCLA/SUPERFUND, 40 CFR 117, 302:

Notification of spills of this product is not required.

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

MATERIAL SAFETY DATA SHEET

'...NALLO 1

. -. .. . - ./ . . ". i *.. .'i. ,....

I PCL-401 PRODUCT EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC SARA/SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986 (TITLE III) - SECTIONS 302, 311, 312, AND 313:

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

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

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

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

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

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

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

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

TOXIC SUBSTANCES CONTROL ACT (TSCA):

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

FEDERAL WATER POLLUTION CONTROL ACT, CLEAN WATER ACT, 40 CFR 401.15 / formerly Sec. 307,40 CFR 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 a la& ar PRODUCT

~NALCO 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. 1 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., (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), (Adel 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

MATERIAL SAFETY DATA SHEET PRODUCT

.NALCO.... PCL-401 K

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, Westem 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

)PL WD LEADER- ON-SITE EXPERT

.4 :S PRODUCT BULLETIN PCL-401 Scale Inhibitor PRODUCT BENEFITS " Stable In Chlorinated Water - There is no need to increase dosage during periods of chlorination. 0 9 Prevents the Formation of Calcium Phosphate r-

-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 excessive blowdown. GENERAL DESCRIPTION

Inhibits Scale Formation in High pHlAlkalinity 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 (Confinued 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, IIitnois 60563-1198

)Registered

.*'a Trademarks of Nalco Chemical Company @2000 Nalco Chemical Company AM? Rights Reserved pHreeGUARD and TRC-233 are Registered Trademarks of Calgon Corporation Printed in U.S.A. 11-00 A4.I

NALCO MATERIALS COMPATIBILITY STORAGE AND HANDLING Compatible materials of construction for bulk storage The recommended minimum 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 12 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 UN Number Not Applicable 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.

PCL-401 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 NDEO Nalco PCL-222 m

PRODUCT EMERGENCY TELEPHONE NUMBER j

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

11. I CHEMICAL PRODUCT AND COMPANY IDENTIFICATION I 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: 01i FLAMMABILITY: 1 /1 REACTIVITY: 0/ 0 OTHER:

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

12. 1 COMPOSITION/INFORMATION ON INGREDIENTS Based on our hazard evaluation, none of the substances in this product are hazardous.

13. 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 PRODUCT

.NHaco 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.

14. 1 FIRST AID MEASURES EYE CONTACT:

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

SKIN CONTACT:

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

INGESTION:

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.

15. 1 FIRE FIGHTING MEASURES FLASH POINT: >200°F/>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

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

16. 1ACCIDENTAL RELEASE MEASURES PERSONAL PRECAUTIONS:

Restrict access to area as appropriate until clean-up operations are comp!ete. 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.

17. 1 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.

18. 1 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:

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 Q ONDJEO 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.

19. 1 PHYSICAL AND CHEMICAL PROPERTIES PHYSICAL STATE Liquid APPEARANCE Clear ODOR Sharp SPECIFIC GRAVITY 1.3 @ 77 -F 25 -C DENSITY 10.8 lb/gal SOLUBILITY IN WATER Complete pH (100 %) 4-5 VAPOR PRESSURE Same as water EVAPORATION RATE Same as water 110. 1STABILITY AND REACTIVITY STABILITY:

Stable under normal conditions.

HAZARDOUS POLYMERIZATION:

Hazardous polymerization will not occur.

CONDITIONS TO AVOID:

Freezing temperatures.

MATERIALS TO AVOID:

Contact with strong 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

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

CARCINOGENICITY:

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

ONDEO Nalco Company ONDEO Nalco Center - Naperville, Illinois 60563-1198 (630)305-1000 4/8

MATERIAL SAFETY DATA SHEET 0DE PRODUCT

~Nalco PCL-222 EMERGENCY TELEPHONE NUMBER (800) 424-9300 (24 Hours) CHEMTREC 112. 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 CERCLA/SUPERFUND in Section 15.

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

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

114. 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 / 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: III 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

0 OO~Nalc~o

N E 'IPRODUCT MATERIAL SAFETY DATA SHEET PCL-222 I

- -.- - --- -..- I EMERGENCY TELEPHONE NUMBER (800) 424-9300 (24 Hours) CHEMTREC Packing Group: III 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 115. I 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.

CERCLA/SUPERFUND, 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. (1-800-424-8802).

RQ 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 1910.1200.

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 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 6/8

0" : MATERIAL SAFETY DATA SHEET Nalco PCL-222 EMERGENCY TELEPHONE NUMBER (800) 424-9300 (24 Hours) 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 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.

116. 1OTHER 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., (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.

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

MATERIAL SAFETY DATA SHEET NDEO

~ N alco I PCL-222 PRODUCT EMERGENCY TELEPHONE NUMBER (800) 424-9300 (24 Hours) 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 06/05/2000 Replaces: 04/12/1999 ONDEO Nalco Company ONDEO Nalco Center Naperville, Illinois 60563-1198 (630)305-1000 8/8

Nalco Company 1601 W. Diehl Rd.

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 (WO)

Sodium bisulfite 7631-90-5 0.2649 Sodium polyphosphate 68915-31-1 13.88 Sodium sulfate 7757-82-6 0.042 Water 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

I .. .NALCO. MATERIAL SAFETY DATA SHEET PRODUCT H-130M EMERGENCY TELEPHONE NUMBER(S)

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

11. 1 CHEMICAL PRODUCT AND COMPANY IDENTIFICATION PRODUCT NAME: H-130M 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: 2/2 INSTABILITY: 0/0 OTHER:

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

12. 1 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)

Didecyl-Dimethyl-Ammonium chloride 7173-51-5 50.0 Ethanol 64-17-5 5- 10

13. 1 HAZARDS IDENTIFICATION

- EMERGENCY OVERVIEW**

DANGER CORROSIVE. Causes severe eye and skin damage. Harmful or fatal if swallowed. Do not get in eyes, on skin, or on clothing. Wears goggles or face shield and rubber gloves when handling. Avoid contamination of food. Remove contaminated clothing and wash before reuse.

Do not get in eyes, on skin, on clothing. Do not take internally. Keep away from heat. Keep away from sources of ignition - No smoking. Use with adequate ventilation. Keep container tightly closed and in a well-ventilated place.

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 chemical resistant apron, chemical splash goggles, impervious gloves and boots.

Combustible Liquid; may form combustible mixtures at or above the flash point. Empty product containers may contain product residue. Do not pressurize, cut, heat, weld, or expose containers to flame or other sources of ignition. May evolve oxides of carbon (COx) under fire conditions. May evolve oxides of nitrogen (NOx) under fire conditions. May evolve HCI under fire conditions. May evolve ammonia (NH4) under fire conditions.

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

,~~~~~~ !:i iil!~

ii~~i ~ .~~ ili:ii

...... -130M

.. EMERGENCY TELEPHONE NUMBER(S)

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

EYE CONTACT:

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

SKIN CONTACT:

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

INGESTION:

May cause burns to mouth and gastro-intestinal tract.

INHALATION:

Repeated or prolonged exposure may irritate the respiratory tract. Can cause central nervous system depression.

SYMPTOMS OF EXPOSURE:

Acute:

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

Chronic:

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

AGGRAVATION OF EXISTING CONDITIONS:

kreview of available data does not identify any worsening of existing conditions.

14. 1 FIRST AID MEASURES For Eyes and Skin: Flush with plenty of water for at least 15 minutes. (Eyelids must be held open). Call a physician immediately. Remove contaminated clothing and wash before reuse.

If swallowed: Immediately give 3-4 glasses of milk; if unavailable, give water. Do not induce vomiting. Call a physician.

NOTE TO PHYSICIAN: Probable mucosal damage may contraindicate the use of gastric lavage.

NOTE TO PHYSICIAN:

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

15. IFIRE FIGHTING MEASURES FLASH POINT: 109 °F /43 -C ( SETAFLASH)

EXTINGUISHING MEDIA:

Foam, Carbon dioxide, Dry powder, Other extinguishing agent suitable for Class B fires, For large fires, use water spray or fog, thoroughly drenching the burning material.

Water mist may be used to cool closed containers.

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

N.NALCO:: . .*:, ... MATERIAL SAFETY DATA SHEET I H-130M PRODUCT EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC FIRE AND EXPLOSION HAZARD:

Combustible Liquid; may form combustible mixtures at or above the flash point. Empty product containers may contain product residue. Do not pressurize, cut, heat, weld, or expose containers to flame or other sources of ignition. May evolve oxides of carbon (COx) under fire conditions. May evolve oxides of nitrogen (NOx) under fire conditions. May evolve HCI under fire conditions. May evolve ammonia (NH4) under fire conditions.

SPECIAL PROTECTIVE EQUIPMENT FOR FIRE FIGHTING:

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

16. 1ACCIDENTAL RELEASE MEASURES PERSONAL PRECAUTIONS:

Notify appropriate government, occupational health and safety and environmental authorities. Restrict access to area as appropriate until clean-up operations are complete. Ensure clean-up is conducted by trained personnel only. Ventilate spill area if possible. Do not touch spilled material. Eliminate ignition sources. Stop or reduce any leaks if it is safe to do so. Use personal protective equipment recommended in Section 8 (Exposure Controls/Personal Protection).

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. Wash site of spillage thoroughly vith water. 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:

This product is toxic to fish and other water organisms. Do not discharge directly into lakes, ponds, streams, waterways or public water supplies.

17. 1 HANDLING AND STORAGE HANDLING:

Do not get in eyes, on skin, on clothing. Do not take intemally. Use with adequate ventilation. Avoid release of vapors or mists into workplace air. Keep the containers closed when not in use. Do not use in locations where vapor is likely to travel to welding flames or arcs or to other hot surfaces. Vapors are much heavier than air, this can result in uneven distribution. Have emergency equipment (for fires, spills, leaks, etc.) readily available.

STORAGE CONDITIONS:

Store away from heat and sources of ignition. Connections must be grounded to avoid electrical charges. Store the containers tightly closed. Store separately from oxidizers. Store in suitable labelled containers.

8. IEXPOSURE 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.

ACGIH/TLV:

Nalco Company 1601 W. Diehl Road

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

MATERIAL SAFETY DATA SHEET N-ALCO PRODUCT H-130M EMERGENCY TELEPHONE NUMBER(S)

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

Ethanol TWA: 1,000 ppm, 1,880 mg/m3 OSHNPEL:

Substance(s)

Ethanol TWA: 1,000 ppm, 1,900 mg/m3 ENGINEERING MEASURES:

Use general ventilation with local exhaust ventilation.

RESPIRATORY PROTECTION:

Ifsignificant mists, vapors or aerosols are generated an approved respirator is recommended. An organic vapor 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, Viton# gloves SKIN PROTECTION:

Wear impervious apron and boots. A full slicker suit is recommended if gross exposure is possible.

.YE PROTECTION:

Wear 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. Use good work and personal hygiene practices to avoid exposure.

19. 1 PHYSICAL AND CHEMICAL PROPERTIES PHYSICAL STATE Liquid APPEARANCE Light yellow ODOR Alcoholic SPECIFIC GRAVITY 0.93 @ 77 OF /25 -C DENSITY 7.7 lb/gal SOLUBILITY IN WATER Complete pH (1 %) 7.0- 8.0 VISCOSITY < 100 cps @ 77 *F/25 °C FREEZING POINT 12 OF /

VOC CONTENT 10%

Note: These physical properties are typical values for this product and are subject to change.

Nalco Company 1601 W. Diehl Road

Naperville, Illinois 60563-1198 (630)305-1000 4/9

MATERIAL SAFETY DATA SHEET NALCO PRODUCT H-130M

..... EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC

10. STABILITY AND REACTIVITY STABILITY:

Stable under normal conditions.

HAZARDOUS POLYMERIZATION:

Hazardous polymerization will not occur.

CONDITIONS TO AVOID:

Heat and sources of ignition including static discharges.

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 withreducing agents (e.g.

hydrazine, sulfites, sulfide, aluminum or magnesium dust) may generate heat, fires, explosions and toxic vapors.

HAZARDOUS DECOMPOSITION PRODUCTS:

Under fire conditions: Oxides of carbon, Oxides of nitrogen, HCI I'11. I TOXICOLOGICAL INFORMATION _

The following results are for the product.

ACUTE DERMAL TOXICITY:

Species LD50 Test Descriptor Rabbit > 4 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).

112. 1 ECOLOGICAL INFORMATION ECOTOXICOLOGICAL EFFECTS:

The following results are for the product.

ACUTE FISH RESULTS:

Species Exposure LC50 Test Descriptor Rainbow Trout 96 hrs 2.2 mg/I Bluegill Sunfish 96 hrs 0.92 mg/I Rating: Very toxic Nalco Company 1601 W. Diehl Road

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

MATERIAL SAFETY DATA SHEET

~NALCO PRODUCT H-130M EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC ACUTE INVERTEBRATE RESULTS:

Species Exposure LC50 EC50 Test Descriptor Daphnia magna 48 hrs 0.19 mg/I Mysid Shrimp (Mysidopsis 96 hrs 0.14 mg/I bahia)

Rating: Very toxic If released into the environment, see CERCLAISUPERFUND in Section 15.

13. 1 DISPOSAL CONSIDERATIONS Ifthis 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 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.

( 14. 1 TRANSPORT INFORMATION The information in this section is for reference only and should not take the place of a shipping paper (bill of lading) specific to an order. Please note that the proper Shipping Name / Hazard Class may vary by packaging, properties, and mode of transportation. Typical Proper Shipping Names for this product are as follows-LAND TRANSPORT:

Proper Shipping Name: CORROSIVE LIQUID, FLAMMABLE, N.O.S.

Technical Name(s) DIDECYLDIMETHYLAMMONIUM CHLORIDE, ETHANOL UN/ID No: UN 2920 Hazard Class - Primary: 8 Hazard Class - Secondary: 3 Packing Group : II Flash Point: 43 'C / 109 OF AIR TRANSPORT (ICAO/IATA):

Proper Shipping Name: CORROSIVE LIQUID, FLAMMABLE, N.O.S.

Technical Name(s) DIDECYLDIMETHYLAMMONIUM CHLORIDE, ETHANOL UN/ID No: UN 2920 Hazard Class - Primary: 8 Hazard Class - Secondary: 3 Packing Group: II IATA Cargo Packing Instructions:

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

MATERIAL SAFETY DATA SHEET tdNALCO PRODUCT H-130M EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC IATA Cargo Aircraft Limit: (Max net quantity per package)

MARINE TRANSPORT (IMDG/IMO):

Proper Shipping Name: CORROSIVE LIQUID, FLAMMABLE, N.O.S.

Technical Name(s): DIDECYLDIMETHYLAMMONIUM CHLORIDE, ETHANOL UN/ID No: UN 2920 Hazard Class - Primary: 8 Hazard Class - Secondary: 3 Packing Group: II 115. 1 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.

Didecyl-Dimethyl-Ammonium chloride: Corrosive Ethanol: Flammable

-ERCLA/SUPERFUND, 40 CFR 117, 302:

r'his 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. (1-800-424-8802).

RQ Substance RQ Ethanol 1,000 lbs SARA/SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986 (TITLE Ill) - SECTIONS 302, 311, 312, AND 3,13:

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 Delayed (Chronic) Health Hazard X Fire Hazard Sudden Release of Pressure Hazard 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.

Nalco Company 1601 W. Diehl Road

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

MATERIAL SAFETY DATA SHEET

"A:CO: PRODUCT H-130M EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC SECTION 313 - LIST OF TOXIC CHEMICALS (40 CFR 372):

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

TOXIC SUBSTANCES CONTROL ACT (TSCA):

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

FEDERAL INSECTICIDE, FUNGICIDE AND RODENTICIDE ACT (FIFRA):

EPA Reg. No. 6836-203-1706 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 IIOzone Depleting Substances):

This product contains the following substances listed in the regulation:

I Substance(s) Citations

. Ethanol Sec. 111 1~

.;ALIFORNIA 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.

WHMIS CLASSIFICATION:

Pesticide controlled products are not regulated under WHMIS.

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 Nalco Company 1601 W. Diehl Road

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

MATERIAL SAFETY DATA SHEET NAL~OPRODUCT 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, Dublic 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 : 03/04/2004 Version Number: 1.5 Nalco Company 1601 W. Diehl Road ° Naperville, Illinois 60563-1198 (630)305-1000 9/9

7 FF WORLDWIDE LEADr=R 3 S~~O TE- IT X EXP

- ERT A

PRODUCT BULLETIN H-=130MO Molluscicide PRODUCT BENEFITS DIRECTIONS FOR USE

Achieves a 100% kill rate of adult, juvenile, and H-130M molluscicide is only sold as part of a com- CJ) veliger forms of zebra mussels and Asiatic clams 0O:

plete Nalco mollusk treatment application service.

usually within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of the start of a treatment This product is safe to the aquatic environment only if program. the treated water is properly deactivated prior to

One to three 24-hour treatments per year are discharge. The method for using this product is usually sufficient to avoid the problems associated restricted by environmental regulations. This product with an uncontrolled mollusk infestation. is not to be used without'supervision from a Nalco representative.

Treatment of a plant's discharge with CA-35, a bentonite clay, effectively complexes with H-130M to eliminate toxicity to non-target organisms. The MATERIALS COMPATIBILITY combined complex is not harmful to aquatic Compatible materials of construction for pump and species or benthic organisms.

piping include polypropylene, polyethylene, Hypalon,

Biodegradable at use concentrations, providing an stainless steel, epoxy phenolic-lined steel, or environmentally acceptable treatment. isophthalic polyester resins.

" Treatment dosages as low as 0.5-2.0 ppm of H-130M are sufficient for an effective treatment.

CONTROL TESTING AND EFFLUENT

" H-130M is a non-oxidizing molluscicide meaning TOXICITY TESTING that H-130M is available for mollusk control rather than being consumed by organic or inorganic H-130M residual is monitored throughout a plant reducing substances in the cooling water. system and prior to discharge using a test procedure sensitive down to 20 ppb. The biological toxicity of the

" Addition to the cooling water does not depress the effluent water generated during the treatment is veri-pH of the bulk water and does not form corrosive fied to be safe through a composite water sample sent by-products as found with chlorination or to an outside laboratory. Results of this testing are bromination. provided to the customer.

" Corrosion of metal surfaces is not accelerated by biocide treatment.

(Continued on Reverse Side)

EPA REGISTRATION Molluscicide H-130M is registered by the Environ-mental Protection Agency (EPA Registration No.

6836-203-1706) as a slug feed molluscicide for industrial cooling water systems.

NALCO CHEMICAL COMPANY One Nalco Center- Naperville, Illinois 60563-1198 p,

NALU=

'A

Pd T*JALCO FEEDING AND DOSAGE DISPOSAL H-130M is fed as close to the raw water inlet as Prohibitions - Do not contaminate water, food or possible without risking the release of the chemical feed by storage or disposal.

into the environment. Treatment of a system with Pesticide Control - Pesticide wastes are acutely H-130M molluscicide typically includes a 24-hour hazardous. Improper disposal of excess pesticide, feed period at 1.5 ppm to the inlet of the plant, spray mixture, or rins ate is a violation of Federal Law.

maintaining a residual at the discharge of 0.5 ppm.

If these wastes cannot be disposed of by use accord-The rate of adsorption of the biocide on the target ing to label instructions, contact your State Pesticide mollusks and thus, the kill rate, is temperature-or Environmental Control Agency, or the Hazardous dependent. Actual treatment durations may vary from Waste representative at the nearest EPA Regional site to site dependent on water temperature and other Office for guidance.

site specific conditions.

Metal Containers - Triple rinse (or equivalent).

Then offer for recycling or reconditioning, or punc-DEACTIVATION REQUIREMENTS ture and dispose of in a sanitary landfill, by incinera-tion or as allowed by state and local procedures.

CA-35 is used to deactivate H-130M molluscicide in the plant water prior to discharge to the environment. Plastic Containers - Triple rinse (or equivalent).

The feed rate of the CA-35 is typically 5 ppm of Then offer for recycling or reconditioning, or punc-CA-35 for every 1 ppm of H-130M molluscicide fed ture and dispose of in a sanitary landfill, by incinera-to the inlet water. CA-35 feed continues for at least tion or, if allowed by state and local authorities, by 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months past the time when the H-130M molluscicide burning. If burned, stay out of smoke.

feed is discontinued to assure complete deactivation Tank Cleaning - Transport tanks and equipment of biocide remaining in the system. should be thoroughly drained and flushed with water to properly remove all traces of product. Dispose of washings as indicated above. Liquid and solid resi-HANDLING AND STORAGE dues are hazardous.

Do not use or store near heat sources or open flame.

H-130M is stable at room temperature. A slight haziness occurs as the product approaches its freezing REMARKS point. Warming will return it to original condition If you need assistance or information, please call your with molluscicidal properties unimpaired. nearest Nalco representative, or our Naperville office Best if used within six months from the time of at 630-305-1000. For more news about Nalco, visit receipt. our website at www.nalco.com.

For Medical and Transportation Emergencies involving Nalco products, call (24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months response):

SHIPPING (800) I-M- ALERT or (800) 462-5378.

H-130M molluscicide is shipped in 5 gal pails and 55 gal drums.

DOT Hazard Class Combustible liquid DOT Proper Shipping Name Combustible liquid, N.O.S. (isopropanol)

UN# 1993

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nna-m-r ROUTEtS Or srrn - ,Sirs CONTACT X EYE COITACT X INHAL:TION' IK TTADTI0Q ETCSOF OVEREXPOSURE Ra-ped on. the av.A ilable animal toicity informato fot hi and 'clogeliy rel~ate mateil t Is antticip ted that dntiret kn r y contact may produce 'se-vere I -iatat Q adt/or b..unsre with posibie irreversible damfl age. M4ay be fat.al. it ling es*ea.

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an:can als r5 in nUs:cta1 par ffecting the ability to breathe; causing .circulaty s.hck.

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.'yea: Flush ... es With. Larg. m .. o unni.n .

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ten m.:ritesan rasntt ~himto. ae~dica~l c.are.

skin:; wah with la4rge amounts of running-n wate., and- s!oap :if 4yiab& 15 for

.m~iintes~. Remoýve6 contAmiriated clothingq and shoes.; Get i'm Ldate medical at tent ion.

Wahclting and. dec~ontaminate shoe~s before reus~e.

Ingstin: If wloeirett~ givel .3ý-c 0lase Of water bdO6 Id'ude nO vohtlti,. If n. ccus give f.ids fvii .agai e .t i diate edici atten ion.

Have. vhysicI'a n determ~ine lit rie t 'S coditioý n allowsor ilnducti lOf ct omt.ng .1 e'vacuation o f the- s~tomach. Dob.6t iqivi -anything by motho a cotulinr o Unconsci~ous p)earso.n.

Inh Jial'atiLon:. R~emo.ve f rom ar~ea to friesh air.. Itr no.t. breiathing cleatý aijntav ajjd: t artifcial espirtion. If victim Is9 hat-'ing-trotible bre6atbiag. gv upen The ird~wnzlon rniA.Wcd hris; couWie ff~mi6 idntecka ftpoasn Ibrm data0i~ aicWmal pub~icatian -tis FUNSmb WITHUT WA.PRAN~y:

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.0pCWprR13 ddo~as.iiisin e4W4e iAgtc smatg.i &4 5g., 14 nw 9U~lWtt1kltifllY fla fRml dierotttl. i*11mpkýememioo of safrty I nd~~cdft~..

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and loct uthrnzea I inlnatd avoid 'smo'ke.

R1OGNERRING. CONTROLS In proceases~ where Aists. or vaosmay be' geaneratekd, proper ventilation mus t bte ttviedinacordaufce wi th -4ood vent-ilationa prAcices, In*.protese .rehsre maiatsa nr vahport' may sexqeeratet- l /~R o ityaooe reznr rato:r iý4s-adri~snd -theb abnence of ntcer. emiv~ronZX~wta1 contrclsý.

flROfT30iVE rra Weaýýr chdmical' spiass 6ogls

.whoere there. Is .a .p~t~nt is. for cqeye cotmantt Mae safety,:

gl'asses with sn651_41. use..i.i Man~1 PRCThCT-TNT Rxrs.rr W-7 ippopr ro .. .... .. ~ arta t 7111 - STORAGE AMD &MuwLZ)G****4tn***4**dw

~R~A~TCKSrOR STORAMR LlAn:DLQf Storeatner tcroc temeratre. ea eo~t:ainters tightly. closed iiirctlt i.

Do no~t ;e-rt4r ab~ove 1-106C

- - r**t**4c***t* x TXICOLOGY

- & WCTOXIOLOGY NFlDIYOXTIO **f*******t*

thetcxf:i;y .Infoz ~Aao< hvec O5IO'w ?i:htti -. t"5o ra mtral ,j >f)tekg Darrca.~ever (xitit . . . ... 340 m/k . 1.,, . . . .:<.,.* t*

tna.,..*.....,.... *; - *- --. -- "

drvcissnman ed.ime.cntaiori,&f ad.pw.e.nre. ,*.y.,san',.h.

-De'rna.i rn-tatiort '(rabbit : Severeiria.

D-_rwalI ccnzoui.vity (rlabbit - DOI) Co-rresive-.

or ANuy gt upc iPm SflO sr.i hitne nns4f ei hiyi!p crute nfth-rnawrds in mnifitxhtrfr and Wn

MATERALSFETY ATA H-EET-EMERENCYTELEHONE SO-24-93O~1hmrc 90.B0,6ohti.. RoW.: -All idtc,.NJ'O?40

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d-iaty-N-enya'oiu

-Photosensitiza ion (gjuineat Pig): -Nt;a. coatact 6ensitizi-r or-.phqt<osenjsitizr K.. IRat; dertual; 20 q4/k91day: fqr 90 days

.... ~ irrit...n.fo N-Alk:ý1-:N*, Mdimethy1--bny m on\m ~oidie Coeponentn ysei toxic effect's*.

.a..i ...

....... y ~O,,1GO :~ o 0~atv prod u.ed mild, reftesit &nd

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Defnitve~tfct at40 OM , n Poib .00 ppm Arhnon ahi to0 Nnprn tN u.~~~ ~ ~0 .......

TOXI-C SUOrANCE aOTRI aCT: (T.SCA IVWTORT) 0'~

'I'le cotnpouent~ iýthis produc .q:t arecurrenl it~ on. the gvTSA tsk' b TStCA Section 12(b) Exp~tNtfcto Comona~t vreaeut i hsprod~c whith, if p~c~td ou;d requir either nna or One'-tie #g:..i~ju4der thio:6 regm.atiou: arti 8a follows;-

Typical MAxiinum None,known RPX 980MA-TI-ON OI PESTICIDES This-poutisa P FIFRA xe-,istejred pted.ýi~t Eq:j PA-Re iatr-atlonN.S3-~

It-c-A-D onWb C:i1emiercMi~aly -in t4eUntdstates frePý mMregiAst re app!i~ios on the pr u1~S~ael O~ANX iN~ O~ TP~ I. IT.ijs fl1the~~ ~nt~n ~ ~roeura i~ t~te~ ~ Itbtyai~ proper~~em orh intealihitorcn

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.LOfZO MATERIAL

S*AFETYDATASHEET**--,T D AS ,

Lornt4 Jut.

S~) £4ou4rae Rosi~ AMtok$~, Ni 07404 STh Svra) 309..697..7200 fAf&+/-r5pnt) Page 6 ctS C~~~~flCL......

10.004 irhzseRvtom ta tPf v o pnaiOP.And-:L1AbilityvAct Of (Tle~fon80-24fl2)in' the a.en-farlaeo quiantteo h t.ri.l. cotie6nti.olwa

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.. rodct=. if the re~leas8e i6 equal to- or. qrste0kt* - tha the :Rootal gunities (20a)litdn 40'Ot3~4 Typt eel Wazimum

%S Rusher Concentration None 100w31:

EAfl. Title I1Iý Sectionso 3ý0a/304 wuefn aedetsadRaautihorLizatIion act ofI I.S9A0. - This actrqie mrec lnig icuigaec oiiain for

-possible rees fteftoi~cwcre fthi -aeil bse upon: th*

ThrshldPlnnngQunttisPe)aandi reletase koportable Qatite (POO) listed fo th omoetsi 0 :.3S, Tlypica1 KarLu ne matrxKL r n oreofthefie hzad caeore lised in: 4.0 tA 110-i N-Dodcvl-l~ ?Idim 1hyIv-ethyvlbenz lanimonium 77283A

......... five'kbz fe hanr at'e'orita are a ofoa *Tr~RIRE ARni> 8; sunnxw nznnS OF flRSU* IacltfVR UR~ff {AUT)"ERALTE ... lZRI CwI)SX&YED (me~xrce)

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Typical )Csxinumt

!CP m i-cgLI 4a-"

fl CAS Nuntet Concentration Nomte k~

The nrcctkuisctyitd rnm ~tm~d to~nhcn~ tpars edsitsfmm~~tnirnI ~icees.....sRh.......WITC...WA..

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'*,~~ ~ - ~~c~LJ~NEUs 'AMf R RYA~Ol fl407MATION (cottiri~)~~*w STATE, RIGmrt-T04*5OU RGULATTOGM:

CALIPORNXA -jRP68tTSTIOW.$5 -Compbn~ita provent 14 thi Wla teO wiht taeo californiag hasfotn toiue ~ner~,brh-eet or other repro utve hr are a's.~~Qu AS A CANCO F HZ A. Typical Naximium Chemical XA CAS Numaber.,ee~t~1 Benele 71-4 3-2 2:00 pmo 5.ebzy1 Ohloride 100-44-7 200 p x.:

~-~icod~nehyiuiin 6275- 1.ppm:

Propyiene oxide Q5~91 PPM AS RPROROCTZVZ 2.MAZA1 TypiCal Maximm~

Chemical same ~A. Nw~ber 71-43-2 "200 ppa-108-88-3 30 0 pp%

MkSSACH7S~r~tT Rigrh to-s:qnow - The: followium compon~ents of this material.ar~e :~included in: the.MassachUsettv dubisance List amd.are pxeaftn1t at or above- reportab1I Ievl cAS Vimber 71-43-2 B.enzene 100-44-7 62-75-9 i 0 ppm

.Propylaene oxide 75-56-9 xMf~atGAN (Criti6;kl Matfiials. - the fc61lbvin* opnnso thisiatexarllare -included ift the lkichigan -Critical Umateials Zlistia Typicdal X.Ut41MUk Chemical Maine CAS Run~ber concentration bloije kno~ti NE~W %MPSS~Y RgIxt-to-kx20w -Tbe -following compqonents of this %aterial ara inlixdeced in the New ilersey Hlazardous Substance. Liat and.-are px~eveut at or above -repartabJe I-evels; Typical N~arIum Chemicdal xame 25%

N-DoitdeylN-N-IN.i dt hl-IN-etblb;O.-~ ni~ 274-79.-28-;3 N-Tetradecy1-I& ,N-dimethy-#j je-h'bezanoiu

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Lonza.. Awam MATERIAL SAFETY DATA SHEET

.MERtRG EN( . TELEPHONE- 8,00424ý93O) (CUh*ettr) 90 ~u~in R~~i Alimmia) NJ 0740V.

(~n~- 5n, -30.9-697-4300 (After-5fpnO 0-77-~~~ page8 oC8 1DREG=T~QRY flNFOM~ATIN(o~i~e) -***

PMMSYLVANTA h 41~igcno44pAnuso this 3nateriti1 j :--nv- are: ixii1uded

-xin the Pen IV' Hazrdoua 8btan.a

na Li m ý'dare. pr~ t at.~

~epoz......

& s .....

Ch~mi%~a1 ILime CM.- klwnbqeX-1a~e.ne 71tý43-2 20~ppm.

The P-. .4 i WO4k46rýiim r~w UNA1 pfRsfNns. pGai. isuisixW!rfxrWA 19

LOlZOa BARQUAT 4250Z BAR QUAT 4280Z Quatermary Ammoium Comp0unds EPARegistered:.

CH 3 H 1H 3 / f R---H Barquat 42250Z and B-wq 280Z a&re blnds of alkyl dimeohyt behzyf ammonium chlotides and:

1 alkyl dirmety,l i~e~t~hylb ammoniumfchfoides. When used as .an: aive i*gredient in F:FRA reg~is-tere~frmulaons.Sucha.s har.d .surface diSinfectants, sanitizers andorb ceitain types of Water treme nt fomulations, these.. pro.ducts haýe..be: found to provide superi:r biocida aton against A: broad 00pctrum of tncrobial oranisms.-such -as: baceifndvrss and alga~e:: .his1'seo"dgeneraion quatem... ammonium:.compund defivers potent germicidal cti*n evenr:in hea~~yorganic soi. loads.

ai :Com iasition :. '

T y" alw l.C. h BArquat 428OZ MActv thwteAfIemnt Alkyl 0,C 30%C 3Q 2 , 0 s5)

Dimoethyt*8Ethybzy! A~mm6 orkn Chioridq 5 e~thyl alcoolli Water 10%

50%

FIFRA - Faderat lns~cticide. Fung~de and R~er~c~ie Act s~r...e ...Th*0e~s~

s~rI,~ ,~wet ~en~r ~0ac~cy 0( g~ !14,OASct~rV~4ee %en ~~Tb1'j&k~&~6t ly~rwd~i~be~ f~~ U ~'s. f5 fuea~' ~~

nm~a~it n.awcr tx 6Cd cOL~ rip~~.9w .~90. . .

oa...2 LO.OnO 1nI!,. Te06 2+013 2-O

0. J00116.6~ R.a Fax 201 igssqeo$

USFL-16739 ARlandale, NJ 07401, LISA, ~~~z~~

Lonza Tvtica Lrf~4f Barquat. 42ft0Z Appaar&oce Clear,: paLe lw:

Mrtaw titpd41 C4Aor~ ~AP14AI 125 Max. 200 Max, ph, (10% act'e saW~itrb)

Flat Point, ~Se sIt. -00 Averae MoS3/4Wit~~t V77 Soecii~ Gravity 4 ~YCi:::KI -* 8.. 00 .-

'.14

-":*./. 7.84 Dansii9 in 'b's st~aI 14.

PhYSiCW State, Refer to Lo*loza. IXAla

,triaii S.faly She- fTof tir:x:s.

R.guIatGry Bsrnuaf 4250Z Barquat 42~02 EPA Rogistratkni No.~ *383*3-23 Can~atian Pesticide Contrnt No: 21904 Q749.$2 3 Ž1 90~*

GAS No.: 68s$g1-t I-s &

274.*22 68391-01-5 &

274 TP-2&3.&

27470.~V4 CaliThrnia Re9iMerect: Y.e~

iiarqwst

.an!itzersC"atOZ. aIr'rd Rsrc*.5;t n'o-more 421), ?wactiVe, that200-p; potleto.FDA~k POOIMe" as net.i-2i GFRpt tri;Ig,. 7 10r CE. ~ .*

The components of aarqluat 4250Z anid Baratat 42280Zware istced inthe Unite~d St a-te

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.;.'*Oa" '"e;: '

EPA reip.sterd tommu',atns' Th*s* for.uaticn nr ie

~atvth35Tc Service ~ ~

52) m Hoin Page2 of 2 Loi i-in; Tt$ Z~4 115 ma sea m&Re*d fli~ 201 755 USFL-1$739 AUensAelo* ttJ 0?4~1, liSA ;~&ndts.t~rn

SpectrusT M ICTi300 i i ~: : ii:i!

Mollusk Control Ageinit .....

Controls I ommro fouling mollusks at.a I life S::sta ge~s: us~in~g b:riefi (6: toi24 :hr) :seasonal!

applications .

Effective o all t*1pes of fresh 6 and salt water clams, mussels, and oysters:

Certififed- by th!eNational: -Sanitation roundation

(NSF) for usein' potable water systemrs, includihg in.flent water systems and desalination systems

. Ca.n:-'..-. erapidly 'de*tox*ied. anm-is.

d readi~y bioqdegradable6

Fiel test methds .forav.ai able determining Figure 1: zebra Mussel ACcumulation.zafter 3 .Moltfs product:6oncehtrations: .:In, a 6-n. .1 5.2 cm)Diameter Discharge Line,

.i ' -" 'i *.. .' ' i ..

." .. ... . .' . . - -i . * - . *. i . . .

DESCRIPTIONAND USE.

Control of.m.acr.fouli.. . oganim . suh as. mollusksl SpectrUST M CT:1300: is :an:::ennvironmeitally frienfdly:, is fl*eededit0 prevent: b!ockedJ !water !ilnes and idam-

aged equipme~nt. :Uncontrole Idgrowth o0f macrofouling bioncontrol a*gent that can be used to control mollusks organismrMs c*n lead to higher mraint~ernace d in a variety. of industrial water-based: syste ms; Spectrus CT1300 can. also be us!ed for control of production coSts, reduced plant'safety, and even algae,: baateria and funga :s!imes in these isaime plant outages:. Therefore, a.effective macrofouling tontrol is.necessary: fo:r operating:uni~ts to achie.ve water systems. Spectrus: CT1300 is :o0ncentrated.It

contains 50% .of quaternary .ammrn~rium hydrochlorid~e profitability q.oals;. More im(portantlyi ;effecive: mlacrow

fouling control is eissential to einlsre availability offiie (QUat) as active ingredient:

protet:on0 systefmsand ther :sa fty-related

Spectrus: CTI300;:applied in brief (6 to :24 hr), seaQ- equipMent.

Son!al applications, lý effective aga.nst a mollusksat

.alll:ife stages. SpectrusCT1 3300 is effective against POTABLE APPLICATIONS*

adult organismsh and will prevent immature forms from When. used in.:des~alinati.on:s§ystems producing potable water:the NS:F has certified Spectrus

-CTi3'00. based on a mraaximumr dosage of010 ppM Spectrus C1 300: _is EPA-approved for. .UIse in recircu- (mg/Li). :wfhen. use~d in :general in~fluenitsystems:plro-latwingcoolafingsytems, heat e . .h::esys 6fmi and ducing. po*t*b* :water, NSF..: has:eortified Spectrus

evvaporative condensersm. :Thi* pr§duqct: is. alls CTI 300 at a maximum dolsage of 3,$ ppm (mg'Li).i '

a~pproved for use in: ondethrough coo.ing systems, service wAtOr, auxiliary water;: and fire :protection sysg tems, as well as:'influent and wastewater systemrs.

see ithe Spectrus.CT1300 :ptoduct ilabel for co0* oa plete.listng of approVed.end-uses..

www.gebetz.com PFC,72FI0211 :m. APrightsreserved.

02002.,GEBev7,

ENVIRONMENTAL BENEFITS--.... Feed:EqUipmert - SpeotruS CT1300is compatible Thol activeh inredient in S rs. C T-1300 (ut s With theJfollowing mater:also*f.6onstruction;: Ha sti0y short-lived in the environment. Quat are cationic 'and :.l~¢;. PVC High

.".:.25. Neopriene:; Densit Buna Cross-lin.kedN;i:Bu~na 5S; :Lit~h~arge .yethyle.e; *Teflo.

V*ito~n; rapidly~adisorb ed by. natui~aI, anio nics~u~bstrates and, sediments. Adsrponmeffetively detoiisQut n -:i.Ethylene.Propylen:e Resin; 1-lypalo0ni ::.i-:::i.)i:.-

Av:id use *.f. 3'04 and 316:Stainless. -Steels:(*e0peciaIly in thin :all*e f6ed :ines);:High Density Polyropylen&

adequae to omplywith atet ualtctriteria.nce :unearHighDensityPolyeihylene;.Nylon.:- :-

those..foUnd:in Spectus.s:DTI400:.or DT.!40I. :TheSe! T-t..his fedsing:the*Paesetterm

.po....t.m..yb Productsnay be usedwha ere natural adsorpio b is not cobntrol: sys*temn.

- ,* s.e

.~:GENERL .. : . :.:*

PROPE*RTIESi:: :.... ...... ! ....*: .: :::* *:*::: :*ii * .:

"ds.ibe, Qouats:are readily bio*de~ia.ded to cabon:

dioxide and w ater-*.:-::: .. .: :.-- :..::..-.:.::.::.:: Physical pro peies.. of..S.pect .. 1T*300 are: shoWn on.......

.-ch'the :.Mate6rial:Safety a.lb ~ - .. ,0!: i * : - . .: ..: . -:: !1.a-*c'opy Daita Sh'eet, ...--i!: ofwhch,0:.:::::::::: ::-Is

~ , ......,..~ ~-,on

..available

~ '" euet

!control ini just a. few hou~rs:, it !reduces chemical :con-:

sump~tion,I envli0ronmental i mpact ianid treatmenet .costs. -:PACKAOIN0 INFORMATION compared:.to hailogen~bas*ed racrofouling treatments. Specitus: CT:1.300 :isa liquid:anid is.available. in a wide Wrhen halogens a reu&sed..for molusk:controthey.

varetyof ontines ad dlivry mthods, icluding must. be applied .continu~ousliy for:"sev~elr~alweeks iifi GE Betz:s ChemSureT Dum.ess .Delivery Setrvics.

.they:are to' be. effective, anidthey: mu*stbe :deha~lo.-..

STORAQE ...

pirmotes follrmatonof un.desirable byproducts suc

~ ~. ..~.

.Protectfromextreme-temperatures.-Protect . . . . . . :from as trihalometh6anes(T: s), Atotal organi-c.ihalides . . . . . ....

(TOX),and adsrba ble halgen.atedI,organics(AO). ::X: freezing. Keep :6ontaine-rsc closed*hen. not:inus.e.

from . flames or sparks .:.. .....

since .Sectrus.13.00 is. noht anoxi.dizetrit does not: ~~~~. . away Keep . . .-. . . ..... . . . - . . . . . . . . ..... . ... - . ,

produe f secmpoundst S ..D1.0-f:. D ::401-ý Th:i.. SAFETY PRECAUTIONSýý

:Use::of eye protection. oggles. an*dface shield):and

.gau.nt.t-ypnhe*r6eh:e gl**ves "irequired when han-correct, tratmentl:eels ::;andt: freq.uency: of spnectr:us.:

Ti 300 oadditi . dep:enad. on.m any fa.tors. These dlinhg this: pro.duct :Se-e section ::7 ofthe:MSDS:fr niclude, h.. . . ..

but are:dntt: " ' -"

mite'dto, degree0f c "ti...... " .

ifestation,

. .'. . .. i- . additionalinfolrmanain on recommnneded personal pro-tective equipme*nt. .

tyipe of:.mollusk, environme~nt.Heavy.

and dischargei temperatur'e, system- infe.statin retention :time, of.

from triIhe storagecothainer.(Hs'ttl _:"GENERAL.]NFORMATION :

mollusksesould betphysically removed o' by vacuum- dS:

ing, dredging,-:or sicrping priortotrepatment Caonsult EPA Registrationr Nunber.::......3876-:149:..:: b

.your GE !Betz ;repr~esentative for ~tech~nicaladiaclie :n: Purchase -of e r"s...CT 300.from GE..Betz includes - "

yo.ur specific application:!:::.:!::::.:."::i.:i!:::::: : . ' is. to pace. .

te.pro e.

overe.d.by U.....

Feed.point -:Apply.Spectrus CT!3.00to a .pointinth:e 4.Pate'nt, 4857 209'.'

psystem:where -turbulence and flow patterns assure -:.

good mixing with the waterbeing treated' . -:-.

Dilution. -uThis p*ructr. is..biet n (t ::un:diut *. . ....:.:. . ...: .-: : . . .. . . . . . .. * . .... .. ,

,ww.gebetz.com

,*C 7280J211 @20C2,GEBoL irc. AJ!6ghttsresmwd.

MATERIAL SAFETY DATA SHEET

,NA. .AL COO& .

I COAGULANT PRODUCT AID 35 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC

11. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION PRODUCT NAME: COAGULANT AID 35 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 1 = Slight 2 = Moderate 3 = High 4 = Extreme

12. 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)

Quartz, crystalline silica 14808-60-7 1.0- 5.0

(

13. 1 HAZARDS IDENTIFICATION

- EMERGENCY OVERVIEW"*

CAUTION May cause irritation with prolonged contact. Inhalation of crystalline silica can cause silicosis.

Do not get in eyes, on skin, on clothing. Do not take internally. Do not breathe dust. Wear suitable protective clothing. 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 soap and water.

Not flammable or combustible. Water in contact with the product will cause slippery floor conditions.

PRIMARY ROUTES OF EXPOSURE:

Eye, Skin HUMAN HEALTH HAZARDS - ACUTE:

EYE CONTACT:

Particles may scratch eye surfaces or cause mechanical irritation.

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 1/8

MATERIAL SAFETY DATA SHEET

.N.ALCO' A4 PRODUCT

.... ... COAGULANT AID 35

.. ""EMERGENCY TELEPHONE NUMBER(S)

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

Repeated or prolonged exposure may irritate the respiratory tract. May cause irritation of mucous membranes.

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:

Prolonged inhalation of product can increase lung injury in persons with emphysema, asthma, or other lung disorders.

14. 1 FIRST AID MEASURES EYE CONTACT:

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

SKIN CONTACT:

First aid is normally not required. 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.

15. J FIRE FIGHTING MEASURES FLASH POINT: None EXTINGUISHING MEDIA:

Not expected to burn. Use extinguishing media appropriate for surrounding fire.

FIRE AND EXPLOSION HAZARD:

Not flammable or combustible. Water in contact with the product will cause slippery floor 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 2/8

MATERIAL SAFETY DATA SHEET

.,.'.-*NALCO

[ COAGULANT PRODUCT AID 35 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC

16. 1ACCIDENTAL RELEASE MEASURES PERSONAL PRECAUTIONS:

Notify appropriate government, occupational health and safety and environmental authorities. Use personal protective equipment recommended in Section 8 (Exposure Controls/Personal Protection).

METHODS FOR CLEANING UP:

Sweep up and shovel. Reclaim into recovery or salvage drums. Dispose of material in compliance with regulations indicated in Section 13 (Disposal Considerations). Water in contact with the product will cause slippery floor conditions.

ENVIRONMENTAL PRECAUTIONS:

Do not contaminate surface water.

17. 1HANDLING AND STORAGE HANDLING:

Do not take internally. Ensure all containers are labelled. Avoid eye and skin contact. Avoid generating dusts.

STORAGE CONDITIONS:

Keep in dry place.

8. EXPOSURE CONTROLS/PERSONAL PROTECTION OCCUPATIONAL EXPOSURE LIMITS:

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

ACGIH/TLV:

Substance(s)

Respirable Nuisance TWA: 3 mg/m3*

Particulates Inhalable (Total) Nuisance TWA: 10 mg/m3 Particulates Quartz, crystalline silica TWA: 0.1 mg/m3 0.1 mg/m3 OSHA/PEL :

Substance(s)

Respirable Nuisance TWA: 5 mg/m3 Particulates Inhalable (Total) TWA: 15 mg/m3 (total dust)

Nuisance Particulates Quartz, crystalline silica TWA: 0.1 mg/m3 ENGINEERING MEASURES:

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

Nalco Company 1601 W. Diehl Roads Naperville, Illinois 60563-1198 (630)305-1000 3/8

MATERIAL SAFETY DATA SHEET lop *ALCO.

I COAGULANT PRODUCT AID 35 EMERGENCY TELEPHONE NUMBER(S)

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

An approved respirator must be worn if the occupational exposure limit is likely to be exceeded. If dusts are generated, use an approved air-purifying respirator. A dust, mist, fume cartridge may be used. If respiratory protection is required, institute a complete respiratory protection program including selection, fit testing, training, maintenance and inspection.

HAND PROTECTION:

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

Wear standard protective clothing.

EYE PROTECTION:

Wear safety glasses with side-shields.

HYGIENE RECOMMENDATIONS:

Keep an eye wash fountain available. Keep a safety shower available.

19. 1PHYSICAL AND CHEMICAL PROPERTIES PHYSICAL STATE Powder APPEARANCE Light grey ODOR None SOLUBILITY IN WATER Insoluble pH (5 %) 8.5-10.5 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 will not occur.

CONDITIONS TO AVOID:

Moisture MATERIALS TO AVOID:

None known HAZARDOUS DECOMPOSITION PRODUCTS:

Under fire conditions: None known Nalco Company 1601 W. Diehl Road . Naperville, Illinois 60563-1198 (630)305-1000 4/8

MATERIAL SAFETY DATA SHEET JiA4 NALCU, .PRODUCT

. COAGULANT AID 35

.... EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC

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

CARCINOGENICITY:

Contains crystalline silica (quartz or cristobalite). The International Agency for Research on Cancer (IARC) has evaluated crystalline silica (inhaled in the form of quartz or cristobalite from occupational sources) and found it to be a human carcinogen (Group 1) based on sufficient animal data and sufficent human evidence. The National Toxicology Program (NTP) has evaluated crystalline silica and found it may be reasonably anticipated to be a human carcinogen. Overexposure to the respirable dust (less than or equal to 5 microns in size) may lead to silicosis, which is a progressive and irreversible lung disease.

12. 1 ECOLOGICAL INFORMATION ECOTOXICOLOGICAL EFFECTS:

No toxicity studies have been conducted on this product.

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

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

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

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

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

MATERIAL SAFETY DATA SHEET deALC-COAGULANT PRODUCT AID 35 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC Proper Shipping Name: PRODUCT IS NOT REGULATED DURING TRANSPORTATION 115. 1REGULATORY 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.

Quartz, crystalline silica : Cancer suspect agent (refer to Section 3)

CERCLA/SUPERFUND, 40 CFR 117, 302:

Notification of spills of this product is not required.

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

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

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

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

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

X Immediate (Acute) Health Hazard X Delayed (Chronic) Health Hazard Fire Hazard Sudden Release of Pressure Hazard 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)

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 173.310 Boiler Water Additives, 21 CFR 176.170 Components of paper and paperboard in contact with aqueous and fatty foods and 21 CFR 176.180 Components of paper and paperboard in contact with dry foods.

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.

Nalco Company 1601 W. Diehl Road Naperville, Illinois 60563-1198 (630)305-1000 6/8

MATERIAL SAFETY DATA SHEET PRODUCT S.ALCO COAGULANT AID 35 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) 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 II Ozone Depleting Substances):

None of the substances are specifically listed in the regulation.

CALIFORNIA PROPOSITION 65:

This product contains the following substances which require warning under California Proposition 65.

Substance(s) Concentration EFFECTS

Quartz, crystalline silica 5% Causes Cancer 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:

Quartz, crystalline silica 14808-60-7 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:

D2A - Materials Causing Other Toxic Effects - Very Toxic Material CANADIAN ENVIRONMENTAL PROTECTION ACT (CEPA):

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

116. 1 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., (Ariel Insight# CD-ROM Version), Ariel Research Corp.,

Bethesda, MD.

Nalco Company 1601 W. Diehl Road - Naperville, Illinois 60563-1198 (630)305-1000 7/8

MATERIAL SAFETY DATA SHEET

.A4 PRODUCT

........... COAGULANT AID 35 EMERGENCY TELEPHONE NUMBER(S)

(800) 424-9300 (24 Hours) CHEMTREC Hazardous Substances Data Bank, National Library of Medicine, Bethesda, Maryland (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.