ML17146B207

Forwards Documents, Re Proposed Change to Pp&L,Inc NPDES Permit Provides Staff Info on Matters Affecting NRC Regulated Activities

ML17146B207
Person / Time
Site:	Susquehanna
Issue date:	09/10/1999
From:	Nerses V NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
NUDOCS 9909170148
Download: ML17146B207 (24)

Text

September 10, 1999 MEMORANDUMTO: Docket File FROM:

SUBJECT:

Victor Nerses, Senior Project Manage Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND2-PP8 L, INC. 'S PROPOSED NATIONALPOLLUTION DISCHARGE ELIMINATIONSYSTEM (NPDES) AMENDMENT The attached document, dated September 2, 1999, regarding a proposed change to PP8L, Inc.'s NPDES permit provides the staff information on matters affecting NRC regulated activities.

Docket Nos. 50-387/50-388 DISTRIBUTION Docket File PUBLIC SBajwa 9'P09i70i48 9909i0 PDR ADOCK 05000387 P

PDR

Thfs proposed NPDES Am ment is being submitted pursuant to Section 3.2 of the Environmental Protection Plan (Appendix B to the OL)

'erome S.

ds Sr. Envlronrnental Scientist - Nuclear PPSL, Inc.

Two North Ninth Street Allentovm, PA 181 Ot-1179 Tel. 610.774.7889 Fax 610.774.7205 jsfields@p apl.corn September 2, 1999 Mr. Paul M. Swerdon Chief, Facilities and Construction Grants Section Bureau ofWater Quality Management Pennsylvania Department ofEnvironmental Protection Two Public Square Wilkes-Barre, PA 18711-0790 SUSQUEHANNA STEAM ELECTRIC STATION USE OF DEPOSITROL PY5206 CCN 741326 FILE R9-8A PLE-

Dear Mr. Swerdon:

PP&L, Inc. is submitting information to the Pennsylvania Department ofEnvironmental Protection.(PaDEP) forthe Susquehanna Steam Electric Station (SES) to update water treatment information previously submitted forNPDES Permit No. PA 0047325.

PP&L, Inc. requests approval ofDepositrol PY5206, a scale inhibitor, for use in the Emergency Spray Pond. PP&L believes that there willbe no additional impacts to the waters ofthe Commonwealth resulting

&om use ofDepositrol PY5206.

Previously the PaDEP approved another scale inhibitor, Powerline PPL 11, however, because of the continued drought and warm weather, Powerline PPL 11 is not inhibiting scale in this pond.

Depositrol PY5206 has an active ingredient, alkyl epoxy carboxylate (AEC), a non-phosphate calcium carbonate inhibitor, while Powerline PPL 11 has an active ingredient ofhydroxy ethylidene diphosphonic acid (HEDP). A comparison ofbioassay data shows that Depositrol PY5206 is less toxic than Powerline PPL 11.

In response to the requirements of"Permitting Guidance on Conditioned Water Discharges and Use ofChemical Additives, Revised July 24, 1992," PP&L has submitted, this request for

'pproval forthe use ofDepositrol PY5206, a scale inhibitor. Attachment 1, Data for Chemical Additive Depositrol PY5206, provides information required in the PaDEP permitting guidance document. is a Material Safety Data Sheet for this product, and Attachment 3 is a Product Facts Sheet about this product's active ingredient, AEC;

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September 2, 1999 To: Mr. Paul M. Swerdon PLE-21515 We understand that the PaDEP review process takes up to 60 days; however, ifscale in this Emergency Spray Pond should impact operation ofSusquehanna SES emergency systems, we willnotifyyour ofBce and request an emergency approval. It is PP&L's understanding that Depositrol PY5206 can control scaling during extended drought conditions.

Ifyou have any questions please contact Jim Wolfer at the Susquehanna SES, (570) 542-3981 or me.

Sincerely, Jerome S. Fields Sr. Environmental Scientist-Nuclear Enclosure (in Triplicate) bc:

T. D. Belles G. W. Castleberry R. L. Doty

~ N. A. Evans R. D. Kichline

. J. L. McCormick D. J. Morgan C. H. Saxton R. S. Tombaugh J. L. Tripoli J. R. Wolfer NR File NUCSA1 NUCSA1 GENA93 GENTW8 GENA61 GENA93

'ENA63 NUCSA1 GENA63 NUCSA1 NUCSA1 GENA62 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station OP1-17 Washington, DC 20555 copy:

NRC Region I

Mr. S. Hansell, NRC Sr. Resident Inspector Mr. V. Nerses, NRC Sr. Project Manager jsf/lth5225c(26)

DATAFOR CHEMICALADDITIVEDEPOSITROL PY5206 1.

TRADENAMEOF ADDITIVE The commercial product is Depositrol PY5206 The active component is Continuum AEC (alkyl epoxy carboxylate) 2.

NAMEAND ADDRESS OF ADDITIVEMANUAFACTURER BetzDearborn Inc.

4636 Somerton Road Trevose, PA 19053 3.

MATERIAL'SAFETYDATASHEET (MSDS) OR OTHER AVAILABLE MSDS is attached and includes toxicological data.

4.

BIOASSAYDATAINCLUDINGTHE 96-HOUR LC50 ON THE WHOLE PRODUCT The 96-hour LC50 for Fathead Minnows is 1,680 mg/1 and the 48-hour LC50 for Daphnia magna is 1,635 mg/1.

5.

PROPOSED AVERAGEANDMAXIMUMADDITIVEUSAGE RATES IN LBS/DAY Average usage rate -

96 lbs./day as product Maximum usage rate - 385,1bs./da'y as product

6. '

FLOW DIAGRAMSHOWING THE POINT OF CHEMICAL ADDITIONANDAFFECTED OUTFALLS The addition point is the Spray Pond.

The Spray Pond outfall discharges into the Cooling Tower Blowdown line.

See attached line.drawing.

7.

THE EXPECTED CONCENTRATIONOF PRODUCT ATFINAL OUTFALL The expected concentration ofDepositrol PY5206 in the Emergency Spray Pond willbe 32 mg/1 as product. The expected concentration ofproduct discharged

&omthe pond through the fiaal outfall, the Cooling Tower Blowdown (Outfall 071) as product is between 0.67 tol.14 mg/l. See the response to No. 10 for additional information.

8.

THE PRODUCT. DENSITYFOR LIQUIDS(lb./gal) USED TO CONVERT USAGE RATE (gpd) TO IN-SYSTEM CONCENIRATIONS (mg/I)

The quantity ofproduct used daily is based on the average Spray Pond discharge rate of250 gpm, and a maximum pond concentration of32 mg/1 as product.

At 250 gpm, the pond daily blowdown in pounds equals:

1 250 gpm x 1440 min/day x 8.33 lbs./gal = 3.0E6 lbs./day At 32ppm, the weight ofproduct discharged per day equals:

32 mg/l x (3.0E6 lbs./day/1E6 mg/l) = 96lbs./day.

At 96 lbs./day, the daily usage rate in'gallons per day equals:

Wt/gal product = sp gr 1.27 x 8.33 lbs./gal = 10.6 lbs./gal 96 lbs./day / 10.6 lbs./gal = 9 gallons per day.

Product in-system concentration (mg/1):

The product in-system maximum concentration, as recommended by the supplier willbe a maximum of32mg/L.

9.

THE ANALYTICALTEST METHODTHATCOULD BE USED TO VERIFYFINALDISCHARGE CONCENTRATIONS WHEN THE.

PRODUCT IS IN USE ANDTHE ASSOCIATED MINIMUM ANALYTICALDETECTION LEVEL(mg/1)

The recommended analytical method is the Turbidimetric Method. The minimum analytical detection level is 12 mg/L as product.

10.

CONDITIONEDWATER DISCHARGE RATE (SLOWDOWNRATE)

ANDDURATION(HOURS)

The conditioned water discharge rate &omthe Emergency Spray Pond into Cooling Tower Blowdown (Outfall 071) willbe approximately 250 gpm, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. Cooling Tower Blowdown discharge rate for two-unit operation is between 7,000 and 12,000 gpm The as-product concentration ofDepositrol PY5206 willbe between 0.67 and 1.14 mg/1 at Outfall 071 when product is being used.

250 gpm/12,000 gpm x 32 mg/1 = 0.67 mg/1 250 gpm/7,000 gpm x 32 mg/1 = 1.14 mg/1 11.

AVAILABLEDATAON THE DEGRADATIONOR DECOMPOSITION OF THE ADDITIVEINTHE AQUATICENVIRONMENT Biodegradation data listed below can be found in Ecological Information Section 12, page 7 ofthe MSDS.

COD (mg/gm)

TOC (mg/gm)

BOD-5 (mg/gm)

BOD-28 (mg/gm) 130 70 9

9 12.

ANYOTHER DATAOR INFORMATIONTHE PERMITTEE BELIEVES WOULDBE HELPFULTO THE DEPARTMENTIN COMPLETING ITS REVIEW Depositrol PY5206 treatment ofthe Emergency Spray Pond at the Susquehanna SES is needed to eGectively control common scales such as calcium carbonate, and also fouling which occur due to iron and other suspended solids. During the present severe drought conditions, this chemical willreplace previously approved Hydroxy-Ethylidene Diphosphonic Acid (HEDP) another scale inhibitor. The active component (AEC) is more stable and has a greater protection range than HEDP.

jsf/msh5226c(26)

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BETZDEARBORN MATERIA SAFETY DATASHEET EFFECTIVE DATE: 08-IVIAR-1999 PRINTED DATE:

14-JUN-1999 8

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Pef -dearborn

1) CHEMICALPRODUCT AND COMPANYIDENTIFICATION PRODUCT NAME: DEPOSITROL PY5206 PRODUCT APPLICATIONAREA: WATER-BASED CORROSION INH)BITOR/DEPOSIT CONTROL AGENT.

COMPANYADDRESS:

BetzDearborn Inc.

4636 Somerton Road, Trevose Pa. 19053 Information phone number: (2th) -'355-3300 EMERGENCY TELEPHONE (HEALTH/ACCIDENT):(800)-877-1940 (USA)

'2) COMPOSITION / INFORMATIONON INGREDIENTS Information for specific product ingredients as required by the U.S. OSHA HAZARDCOMMUNICATIONSTANDARD is listed. Refer to additional sections of this MSDS for our assessment of the potential hazards of this formulation. This product is subject to the Pennsylvania and New Jersey Worker and Community Right to Know Law.

HAZARDOUS INGREDIENTS:

This product is not hazardous as defined by OSHA regulations.

No component is considered to be.a carcinogen by the National Toxicology Program, the International Agency for. Research on Cancer, or the Occupational Safety and Health'Administration at Pennsylvania thresholds for carcinogens.

PAGE 1

CONTINUED

" PRODUCT NAME:DEPOSITR~Y5206 EFFECTIVE DATE: 08-MAR-199M NON-HAZARDOUS INGREDIENTS:

CASg 7732-18-5

't CHEMICAL NME WATER TRADE SECRET (N320)

TSRN:

125438 6148 PAGE 2 CONTINUED

PRODUCT NAWlE 'EPOSITR Y5206 EFFECTIVE DATE: 08-MAR-1999 C

') HAZARDS IDENTIFICATION

• • • • • I A**A**AAA*AAI*A*AA*IA*A************I A*AIA*AA@A*II*AA**A**AA***i*I AIA****A*

EMERGENCY OVERVIEW CAUTION May cause slight irritation to the skin. May cause slight irritation to the eyes. Mists/aerosols may cause irritation to upper respiratory tract.

DOT hazard is not applicable Emergency Response Guide is not'applicable Odor: Mild; Appearance: Pale Yellow, Liquid Fire fighters should wear positive. pressure self-contained breathing apparatus(full face-piece type). Proper fire-extinguishing media:

dry chemical, carbon dioxide, foam or water IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIAIIIIIIAIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII POTENTIAL HEALTHEFFECTS ACUTE SKIN EFFECTS:

Prima'ry route of exposure; May cause slight irritation to the skin.

ACUTE EYE EFFECTS:

May cause slight irritation to the eyes.

ACUTE RESPIRATORY EFFECTS:

Mists/aerosols may cause irritation to upper respiratory tract.

INGESTION EFFECTS:

- May cause gastrointestinal-irritation-with-possible-nausea,--

vomiting, abdominal discomfort and diarrhea.

TARGET ORGANS:

No evidence of potential chronic effects.

MEDICALCONDITIONS AGGRAVATED:

Not known.

SYMPTOMS OF EXPOSURE'ay cause redness or itching of skin.

PAGE 3 CONTINUED

0

PRODUCT NAlNE:DEPOSITR~Y5206 EFFECTIYE DATE: 08-MAR-199&

4) FIRST AID MEASURES SKIN CONTACT:

Remove contaminated clothing. Wash exposed area with a large quantity of soap solution or water for 15 minutes.

EYE CONTACT'mmediately flush eyes with water for 15 minutes. Immediately contact a physician for additional treatment.

INHALATION:

Remove victim from contaminated area to fresh air. Apply

'ppropriate first aid treatment as necessary.

INGESTION:

Do not feed anything by mouth.to an unconscious or convulsive victim. Do not induce vomiting. Immediately contact physician.

Dilute contents of stomach using 3-4 glasses milk or water.

5) FIRE FIGHTING MEASURES FIRE FIGHTING INSTRUCTIONS:

Fire fighters should wear positive pressure self-contained breathing apparatus (fullface-piece type):

EXTINGUISHINGMEDIA:

dry chemical, carbon dioxide, foam or water

'AZARDOUS DECOMPOSITION PRODUCTS:

Thermal decomposition {destructive fires) yields elemental oxides.

FLASH POINT:

) 200F

> 93C P-M(CC)

6) ACCIDENTALRELEASE MEASURES PROTECTION AND SPILL CONTAINMENT:

Ventilate area. Use specified protective equipment. Contain and absorb on absorbent material. Place in waste disposal container.

Flush area with water. Wet area may be slippery. Spread sand/grit.

DISPOSAL INSTRUCTIONS:

Water contaminated with this product may be sent to a sanitary sewer treatment facility,in accordance with any local agreement,a'permitted waste treatment facility or discharged under a permit. Product as is - Incinerate or land dispose in an approved landfill.

7) HANDLINGANDSTORAGE HANDLING:

Alkaline. Do not mix with acidic material.

STORAGE:

Keep containers closed when not in use. Protect from freezing. Do not store at elevated temperatures.

PAGE 4 CONTINUED

4 PRODUCT NAME: DEPOSJTR~Y5206 EF FECTIVE DATE: 08-MAR-199&

8) EXPOSURE CONTROLS/PERSONAL PROTECTION EXPOSURE LIMITS This product is not hazardous as defined by OSHA regulations.

ENGINEERING CONTROLS:

adequate ventilation PERSONAL PROTECTIVE EQUIPMENT:

Use protective equipment in accordance with 29CFR 1910 Subpart I

RESPIRATORY PROTECTION:

RESPIRATORY PROTECTJON PROGRAM THATMEETS OSHA'S 29 CFR 1910.134 AND ANSI Z88.2 REQUIREMENTS MUST BE FOLLOWED WHENEVER WORKPLACE CONDITIONS WARRANTA RESPIRATOR'S USE.

USE AIR PURIFYING RESPIRATORS WITHINUSE LIMITATIONSASSOCIATED WITHTHE EQUIPMENT OR ELSE USE SUPPLIED AIR-RESPIRATORS.

lfair-purifying respirator use is appropriate, use a respirator with dust/mist filters.

SKIN PROTECTION:

neoprene gloves-Wash offafter each use. Replace as necessary.

'YE PROTECTION:

splash proof chemical goggles Vapor Piessure (mmHG)

- 18.0 Vapor Density (air=1)

< 1.00 k.-solubility (water) 100.0 S) PHYSICALAND CHEMICALPROPERTIES Specific Grav. (70F, 21C)

1. 270

'eeze Point (F) 27

.reeze Point (C)

-3 Viscosity-(cps"-70F., 21C)...

-...,.22 Odor

.= Appearance

,Physical State Flash Point pH As Is (approx.)

Evaporation Rate (Ether=l)

P-M (CC)

NA = not applicable ND = not determined Mild Pale Yellow Liquid

> 200F

> 93C 13.1

< 1.00 PAGE 5 CONTINUED

PRODUCT NAME: DEPOSITROJ~PY5206 EFFECTIVE DATE: 08-MAR-199~

10) STABILITYAND REACTIVITY STABILITY:

Stable under normal storage conditions.

HAZARDOUS POLYMERIZATION:

Willnot occur.

INCOMPATIBILITIES:

May react with strong oxidizers.

DECOMPOSITION PRODUCTS:

Thermal decomposition (destructive fires) yields elemental oxides.

BETZDEARBORN INTERNALP UMPOUT/CLEANOUTCATEGORIES:

IIBII

11) TOXICOLOGICALINFORMATION

'ral LD50 RAT:

3,050 mg/kg 28 Day Oral RAT:

1,000 mg/kg/day NOTE No clear indications of treatment related toxicity(dose adjusted to 100% active)

Dermal LD50 RABBIT:

)1, 000 mg/kg NOTE Estimated value Skin Irritation Score RABBIT:

0.3 NOTE DOT HM181: noncorrosive Eye Irritation Score RABBIT:.

3.3 NOTE Maximum score at 48 hrs; completely reversible by day 4

Non-Ames Mutagenicity MOUSE:

NEGATIVE NOTE In Vivo Bone Marrow Micronucleus Assay PAGE 6 CONTINUED

'RODUCT NAME:DEPOSITR~Y5206 EFFECTIVE DATE:-08-MAR-199&

42) ECOLOGICAL INFORMATION AQUATICTOXICOLOGY Fathead Minnow 96 Hour'Static Acute Bioassay LC50:,1 680 mg/L No Effect Level: 1350 mg/L Daphnia magna 48 Hour Static Acute Bioassay LC50: 1635 mg/L No Effect Level: 870 mg/L Mysid Shrimp 48 Hour Static Renewal Bioassay LC50: 9900 mg/L 5% Mortality: 4000 mg/L Sheepshead Minnow 96 Hour Static Renewal Bioassay LC50: 28300 mg/L No Effect Level: 20000 mg/L BIODEGRADATION COD (mg/gm):

130 TOC (mg/gm):

70 BOD-5 (mg/gm):

9 BOD-28 (mg/gm):

9

53) DISPOSAL CONSIDERATIONS Ifthis undiluted product is discarded as a waste, the US RCRA hazardous waste identification number is:

D002=Corrosive(pH).

Please be advised; however, that state and local requirements for waste disposal may be more restrictive or otherwise different from federal regulations. Consult state and local regulations regarding the proper disposal of this material.

14) TRANSPORT INFORMATION DOT HAZARD:

Not Applicable UN / NA NUMBER:

Not applicable DOT EMERGENCY RESPONSE GUIDE 8: Not applicable PAGE 7 C'ONTINUED

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PRODUCT NAME: DEPOSITR~Y5206 EFFECTIVE DATE: 08-MAR-199&

'6)

REGULATORYINFORMATION TSCA:

Allcomponents of this product are listed'in the TSCA inventory.

CERCLA AND/OR SARA REPORTABLE QUANTITY(RQ):

No regulated constituent present at OSHA thresholds SARA SECTION 312 HAZARDCLASS:

Product is non-hazardous under Section 311/312 SARA SECTION 302 CHEMICALS:

No regulated constituent present at OSHA thresholds SARA SECTION 313 CHEMICALS:

No regulated constituent present at OSHA'thresholds CALIFORNIAREGULATORY INFORMATION CALIFORNIASAFE DRINKINGWATER AND TOXIC ENFORCEMENT ACT (PROPOSITION 65) CHEMICALS PRESENT:

No regulated constituent present at OSHA thresholds MICHIGANREGULATORYINFORMATION No regulated constituent present at OSHA thresholds

16) OTHER INFORMATION NFPA/HMIS CODE TRANSLATION Health Fire Reactivity Special (1) Protective Equipment' 1

0 ALK 8

Slight Hazard Slight Hazard Minimal Hazard pH above 12.0 Goggles, Gloves (1) refer to section 8 of IVISDS for additional protective equipment recommendations.

CHANGE LOG REVISIONS TO SECTION:

E FFEC TIVE DATE MSDS status:

21-MAY-1997 08-MAR-1999 12 SUPERCEDES

• • NE'g **

21-MAY-19 97 PAGE 8

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PrOduCt FaCtS HE~I-/QQD JUL 19 ~ggg ENVIRONMENTAL SERVICES CONTlNUUM AEC Alkaline Cooling Water Treatment

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Controls deposition and scale with patented AEC non-phosphonate technology

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Maximizes corrosion protection without heavy metals

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Minimizes or eliminates acid feed

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Stable in presence of halogens DESCRIPTION AND USE Contlnuume AEC products are custom designed

. blends containing alkyl epoxy carboxylate (AEC).

AEC, a non-phosphonate calcium carbonate inhibitor, is the primary ingredient used for patented deposit control technology.

These Continuum products control corrosion and scale formation ln open recirculating cooling water systems over the alkaline pH range of 7.8 to 9.0.

'Continuum products with AEC are versatile'and have been successfully used in a broad range of systems operating under varying conditions.

TYPICALAPPLICATIONS Coritinuum AEC programs are designed for coo)ing water systems operating at alkaline pH, typically 7.8 or above. This means that acid feed and the costs and concerns associated with it may be reduced or eliminated.

Continuum products with AEC effectively control com-mon scales, such as calcium carbonate, and fouling which occur due to iron and other suspended solids.

AEC technology is a major breakthrough in calcium carbonate scale control. Figure 1 demonstrates the ability of AEC to inhibit calcium carbonate scale com-pared to other conventional inhibitors.

Organic phosphate inhibitors are susceptible to breakdown or reversion in the presence of chlorine.

Figure 2 demonstrates that there is no loss of cal-cium carbonate scale inhibition by AEC in the pres-ence of chlorine.

Continuum AEC programs'inhibit the corrosion of mild steel, copper, and copper alloys.

THE BETZDEARBORN ENVIRO-GUARD COMMITMENT BetzDearborn is committed to the preservation and enhancement of our global environment, improving health and safety, and fostering environmental awareness.

We pledge to provide a Return on Environment (ROEG) to our customers, employees, neighbors, and the public by holding ourselves accountable to the highest standards of environ-mental responsibility.

Continuum AEC programs were designed to enhance workplace safetyand minimizeimpact on the environment.

$00 L

O

~ 75 Z,

'C

~O 50 AEC PBTC HEDP HPA Figure 1: Calcium Carbonate Inhibition with Equal Actives Concentration in a High LSI System.

++ BetzDearborn IVater Management Group TREATMENTAND FEEDING REQUIREMENTS The particular combination of active, ingredients required to give the best results depends on the sys-tem metallurgy, temperature, water chemistry, and other system characteristics.

Your Betzoearborn sales representative will recommend the most effec-tive treatment for your system.

PFC 706 9708 01997, BetzDoarbom Water Management Group. Allrtghts reserved.

100 CI 50 ZC

<o'5 0

2 5

10 Free Chtorfne (ppm fmg/LII Figure 2: Stability of 10 ppm (mg/L) AEC at High LSI ln the Presence of Chlorine.

Dosage - The proper treatment level of Continuum AEC products depends on the needs of your system and the product selected. The product should be fed in accordance with control parameters that BetzDearborn Water Management establishes for your particular application. For consistent protection, continuous feed is recommended.

Feed point - Continuum AEC should be fed to a point

'in the cooling system where it rapidly mixes with the bulk cooling water.

Dilution-For best results, Continuum AEC products should be fed neat. Dilutions, if necessary, can only be made with low hardness water.

Feed Equipment - Tanks, pumps, piping, and.

valves should be made of stainless steel, polyethyl-ene, or PVC. Equipment recommendations for spe-cificblends are available upon request.

ENVIRONMENTALINFORMATION Aquatic toxicology data and regulatory information is available for each Continuum AEC program. Contact your BetzDearborn Water Management Group sales representative for detailed information about a spe-cificproduct.

PACKAGING INFORMATION Continuum AEC products are liquid blends, available in a wide variety of customized containers and deliv-ery methods. Contact your BetzDearbom sales rep-resentative for details.

SAFETY PRECAUTIONS

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Material Safety Data Sheets containing detailed informatioh about products in this series are avail-able upon request.

hCNA p PFC 706 9708

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