ML20083M190

Requests That 950315 Approval Ltr from Sc Dept of Health & Environ Control,Approving Use of Listed Treatment Chemicals, Be Modified & Reissued for Listed Reasons

ML20083M190
Person / Time
Site:	Catawba
Issue date:	05/10/1995
From:	Carter J DUKE POWER CO.
To:	Eleazer T SOUTH CAROLINA, STATE OF
References
NUDOCS 9505190147
Download: ML20083M190 (6)

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f. M ," g l DukeIbwer Company DectricSrstem Support Department l GU9Hayrs ferry Rowl Hunterwille, hC207&T93 ..

1 DUKEPOWER May 10,1995 Mr. Timothy M. Eleazer Industrial and Agricultural Wastewater Division South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201

Subject:

Catawba Nuclear Station -NPDES Permit No. SC0004278 Approval for Use of Chemicals File: CN-702.13

Dear Mr. Eleazer:

Catawba Nuclear Station received approval to use the following additional treatment chemicals in a letter from DHEC dated March 15,1995 (copy attached):

1. Carbohydrazide

2. NALCO DYNACOOL 1389

3. dibromo-3-nitrilopropionamide or DBNPA

4. 3-MPA or 3-methoxypropylamine Upon review of this approval letter and the actual application of these compounds, we would -

like to request that the approval letter be modified and reissued. The reasons for this request are provided below:

. The approval to use NALCO DYNACOOL 1389, DBNPA and 3-MPA provided an actual effluent limitation value which was based upon the anticipated discharge value and not the aquatic toxicity of the compounds as provided in the MSDS sheets. The usage of these compounds is well below the aquatic toxicity values. The anticipated discharge ,

values were provided to show that the compounds would not be discharged in toxic concentrations.

. There does not exist a good analytical method to analyze for these compounds in low i concentrations in a wastewater matrix. We can analyze for the compounds and come up 9505190147 950510 r .

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'I with an actual number in a cleanwater sample and therefore know the concentrations of the chemicals which are being added to the systems. The anticipated discharge values i shown in the request were calculated values. Therefore, we will not be able. to l demonstrate by analytical means what the actual concentration of the product is at the discharge point.

For these reasons we would like to request that the letter be revised to provide a simple approval to use the compounds as described in the permit application and that a numerical effluent value not be assigned for each compound. We will discharge at or below NOEC concentrations for C. dubia. Our existing toxicity monitoring program will verify that these compounds are not being discharged in toxic concentrations. Additional toxicity testing shall ,

be performed if the NOEC limit is approached.

Upon review of the usage of the 3-MPA, we have reworked the typical discharge .

concentration range to between 1 and 5 mg/l rather than 0.1 mg/l as shown in the application submitted on February 15,1995. A revised copy of the proposed usage for this compound is attached for your review. The discharge concentration range of 1 to 5 mg/l is below the  ;'

NOEC value for this compound.

Should you have any questions concerning this letter please give John Estridge a call at (704) 875-5965.

Sincerely, f

o . Carter, Technical System Manager Environmental Division, Water Protection ,

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cc: Mr. Al Williams - Catawba EQC NRC Document Distribution List j i

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• CATAWBA NUCLEAR STATION  :

PROPOSED USAGE j May 10,1995 i NPDES PERMIT SC0004278 - i Part III Item 9 Requirements

1. NAME AND GENERAL COMPOSITION OF THE CHEMICAL 3-MPA or 3-methoxypropylamine

- Typical Manufacture Product Name: NALCO 94UF193 ,

This product will be used for pH control.

The use of MPA will help to reduce the amount of low level radioactive waste generated at the site. This product is considered an environmentally friendly substitute for ethanolamine due to the reduction in resin waste.

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2. QUANTITIES TO BE USED 3-MPA will be used in the secondary system to replace ethanolamine as the secondary -

pH control additive. This product will be used in the range of 1-10 mg/1.

3. FREQUENCY OF USE '!

continuously ,

4. TYPICAL DISCHARGE CONCENTRATION t

r 1-10 MG/L is the concentration to be used in the secondary chemistry system.

The secondary system is discharged to the conventional wastewater treatment ponds and discharged to Lake Wylie via outfall 002. The typicaldischarge concentration out  ;

outfall 002 will range between 1 md 5 mg/l based on plant operating conditions..

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5. EPA REGISTRATION NUMBER  !

MSDS sheets attached. l 1

6. AQUATIC TOXICITY INFORMATION  ;

I The 7-day Ceriodaphnia no observed effect concentration for reproduction is 9.5 mg/1.

The 7-day Ceriodaphnia no observed effect concentration for survival is 75 mg/1.  ;

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MOK 8 WATER 5X LtJTION 'TO 8 '704 875 6974- 1996 03-15 84s0GPM 8127 P.0v03 4 South Carolina  : r,w Seent: 8Weherti E,Jebbour,000. Chairman Jolin H. Sursles Robert J. Stripling, Jr.W:e C,setrmen WMom M. Hvil,Jr.Mn Depenmenief Heenih and Enutronsnentalconcret  :: ,

2000 Duti Otreet, Columbia. Sc 20201 promesap Henten, ProsaceW she sesrotunord a -

March 15,1995 Mr. John S. Carter, Technical System Manager linvironmental Division Duke Power Company 13339 Hagers Ferry Road lluntersville, N.C. 28078-7929 Re: Request Approval for Use of Chemicals  ;

Duke Power Co./ Catawba Nuclear Station l York County

Dear Mr. Carter:

l Our Office has received you'rFebruary 15, 1995 letter requesting appmval to use l additional treatment chemicals at the Duke Power Company / Catawba Nuclear Station in York -l County. Based on a review of the information provided, we approve your request to use the  !

following treatment chemicals as indicated below: l i

1) Carbohydrazide (hydrazine substitute) shall be used as a cormslon inhibitor in the nuclear service water heat exchangers during wet layup and in the station's I secondary chemistry system. The discharge of this parameter fmm Outfalls 001  ;

and 002 shall be less than the 8.1 mg/l no observed effcet concentration (NOEC) l per occurrence.  ;

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2) NALCO DYNACOOL 1389 (cooling water dispersant) shall be used to enhance the dispersion of mud and silt in the nuclear service heat exchangers during wet layup. The discharge of this parameter from Outfall 001 shall not exceed 0.3 mg/l per occurrence.

3) dibmmo-3-nitrilopmpionamide or DBNPA (microorganism control) shall be used to control microorganisms in the nuclear service water heat exchangers during l wet layup. The discharge of this parameter from Outfall 001 shall not exceed 0 l mg/l per occurrence since this pmduct decays away within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of application.

4) 3-MPA or 3-methoxypropylamine (ethanolamine replacement) shall be used as a pH control additive to reduce the amount of low level radioactive waste generated at the site. The discharge of this parameter from Outfall 002 shall not exceed 0.1 mg/l per occurrence.

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~ Duke Power Co./ Catawba Nuclear Station 2/15/95 letter

• Page 2 If you should have any questions, please call me at (803)734-5247.

Sincerely; e

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> asp.Eleazer Timothy Environmental Engineer Associate Industrial and Agricultural Wastewater Division TME/ CAT cc: Al Williams, Catawba EQC 1

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