ML20247L125
| ML20247L125 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 05/19/1989 |
| From: | Bradham O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Hayes J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8906020092 | |
| Download: ML20247L125 (14) | |
Text
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. gogth C rollru Ebctric & Gas Compt.ny file B dh:m e in v le SC 29065 Nuclear Operations l
SCE&G
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l Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 Attencion: Mr. J. J. Hayes, Jr.
Subject:
Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License NPF-12 Service Water System Biocide Treatment Gentlemen:
South Carolina Electric & Gas Company (SCE&G) has been testing various products for control of corrosion and biological fouling of the Virgil C.
Summer Nuclear Station (VCSNS) Service Water (SW) System using a small side stream test stand. Although a comprehensive treatment program has not yet been defined, significant results have been obtained from this study. These results are summarized in Attachment I.
As indicated in the results summary, testing will continue in order to find methods to mitigate soft-water corrosion and silt deposition. However, SCE&G wishes to implement full scale treatment of the SW System with Betz "CT-1" to control Asiatic Clams and Microbiologically Influenced Corrosion (MIC). This action is required to maintain this safety-related cooling system.
The only alternative is to treat with continuous chlorination which although effective, has been shown to increase corrosion due to soft-water attack by the cooling water at the VCSNS.
The Betz Clam-trol CT-1 contains no heavy metals or EPA priority pollutants and has been registered by the EPA for use as a molluscicide for both once-through and reci-culating cooling systems. Another factor in favor of this biocide is that it has several characteristics which minimize its environmental impact. The active components of the biocide are neutralized (rendered non-toxic) once adsorbed to suspended material, sediment, and surfaces within a cooling system. The SW Pond silt has been shown to be capable of this. Also, the inert materials (ethylene glycol, isopropanol, and water) are non-toxic to aquatic organisms at the concentration applied.
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Document Control Desk j
May 19, 1988 l
Page 2 of 2 1
The proposed application point is at the entrance to a 12' x 15' tunnel which j
feeds the SW intake as shown by the schematic diagram on Attachment II.
Application rate will be 5 to 15 ppm for 1 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per day into the normal flow rate of 24,000 gpm. To minimize convection of the biocide to the circulating water intake (Outfall 002) via the 36 inch cross-connect pipe, application will only be made at night when Fairfield Pumped Storage Facility is either pumping up from the Broad River or sitting idle. The net result is that flow in the cross-connect pipe will be either towards the SW intake or stagnant during application. Thus, the discharge at NPDES Outfall 002, if any, will be less than the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> LC 50 for the general fish population.
SCE&G has submitted a written request, for approval, to the South Carolina Department of Health and Environmental Control for this treatment program.
SCE&G has conducted an environmental evaluation of this proposed biocide treatment and has determined it te be an unreviewed environmental question.
Therefore, in accordance with Appendix B of the Operating License (NPF-12)
Section 3.1, SCE&G herein submits a written evaluation (Attachment III) of, and requests NRC approval for the biocide treatment of the Service Water System.
For a no significant hazards determination, please refer to Attachment IV.
The proposed treatment program has been reviewed and approved by both the Plant Safety Review Committee and the Nuclear Safety Review Committee.
I declare that the statements and matters set forth herein are true and correct to the best of my knowledge, information and belief.
Should you have any questions, please call.
Very truly yours,
/N A
- 0. S. Bradham DCP/0SB: led Attachments c:
D. A. Nauman/0. W. Dixon, Jr./T. C. Nichols, Jr.
E. C. Roberts W. A. Williams, Jr.
G. O. Percival S. D. Ebneter R. L. Prevatte J. J. Hayes, Jr.
J. B. Knotts, Jr.
l General Managers NSRC C. A. Price /R. M. Campbell, Jr.
NPCF R. B. Clary RTS (EPA 870011) i K. E. Nodland File (814.07-18/14.3701 l
J. C. Snelson
Attachment I to Document Control Desk Letter Mdy 19, 1989 Page 1 of 1 SERVICE WATER TEST STAND RESULTS
SUMMARY
A test was initiated in June 1988 using different concentrations of sodium hypochlorite. From this test it was learned t~at although the hypochlorite n
is an effective biocide, it also increases corrosion due to " soft-water" attack. Another test was initiated in September 1988 to examine various corrosion inhibitors. At no time was any residual chemical detected in the SW Pond as a result of use of these chemicals in the SW test stand.
The major goal of the September test was to limit silt deposition in the piping with a high molecular weight polymer and to examine the resistance of a "High Molybdenum Stainless Steel" (AL6XN). Silt control with the polymer was unsuccessful but the stainless steel demonstrated significant resistance to both silt deposition and corrosion. Of the corrosion inhibitors tested, only the zinc sulfate demonstrated much success.
The above tests were run at an extremely low velocity, 0.3 feet per second (fps). This represents an extreme worst case condition which may never be improved upon without material replacement (e.g. stainless steel).
Future tests will be run at more moderate velocity conditions, 3.0 feet per second, which is still considered to be low flow. This flow rate is expected to give a better representation of the tested corrosion inhibitors.
Results to date from the SW Test Stand have demonstrated that four problems contribute to Service Water System degradation. They are as follows:
1.
Asiatic Clam Fouling 2.
Microbiological Influenced Corrosion (MIC) 3.
Soft-Water Corrosion 4.
Silt Deposition and Fouling Use of an organic biocide (Betz CT-1) has been proven to be effective for l
control of Asiatic Clams and possibly has merit for control of MIC. The l
problems of soft-water corrosion and silt deposition require additional testing.
L
U Attchmnnt ll to D::cumsnt Control D:sk Lott:r
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M:y 19,1.989 Page 1 of 1 System Schematic Diagram l
Monticello Reservoir n
Via Circulating Water Discharge Canal (Outfall001) '
,r Circulating Circulating Water Water (CW) <
Intake Raw Water Supply System (Outfall 002)
-+
l SW Discharge / Intake via l 36" Cross-Connect CT-1 Point Of l
Application SW Service Water 12 x is-System (SW) Intake Intake Tunnel SW Pond 456 Million Gallons
. Attachment III to Document Control Desk Letter j
Page 1 of 9 Environmental Evaluation MRF-20629, Treatment of Service Water System with Betz Clam-Trol CT-1 Summary of Proposed Treatment MRF-20629 would enable the treatment of the service Water System at V. C. Summer Nuclear Station (VCSNS) with a molluscicide (Clam-Trol CT-1) manufactured by Betz Industrial. Treatment would be accomplished by injecting the molluscicide at the trash racks located at the entrance to the intake tunnel of the Service Water intake Structure and other points as necessary. Treatment is designed to control Corbicula (asiatic clam) infestations in the Service Water System. It is expected that treatment will also help control microbiologically induced corrosion (MIC) in the Service Water System. Treatment with CT-1 is expected daily for 1 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and would be scheduled so that the potential for discharge of CT-1 to Monticello Reservoir through the Service Water intake / Circulating Water intake cross connect pipe would be limited.
Evaluation Review of the Final Environmental Statement (NUREG-0719), the Operating License Environmental Report (OLER), the Final Environmental Statement - Construction Permit (FES-CP), and the Environmental Report - Construction Permit (ER-CP) for VCSNS reveals that the use of biocides to prevent fouling or control nuisance organisms in the Service Water System was not evaluated. In fact, the statement is made repeatedly that biocides will not be used to prevent condenser fouling. Since the use of biocides in the Service Water System was not evaluated and since the use of biocides could potentially cause significant environmentalimpact, the use of Betz Clam-Trol CT-1 in the Service Water System is considered an unreviewed environmental question.
Potential for Environmental Impact Data supplied by Betz indicate that CT-1 is fairly toxic to non-target organisms. The 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> LC50 or Bluegill sunfish is given as 4.3 mg/l and the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> LC50 or Daphnia f
f maana is given as 0.41 mg/l. Betz claims that the biocide is rapidly deactivated by adsorption on suspended particles in the water. Such deactivation should greatly reduce the chance of biological effects caused by the active ingredients in CT-1. This same mode of deactivation, however, may also affect the product's effectiveness in l
controlling clams.
With the addition of CT-1 to the Service Water System as proposed, biological effects could be noted in the following areas:
1 l
- 1. Service Water Pond, l
)
l 1
l i
. Attachment III to Document Control Desk Letter 7
Page 2 of 9
- 2. Monticello Reservoir at the Circulating Water Intake,
- 3. Monticello Reservoir at the Circulating Water Discharge, and
- 4. Circulating Water System (entrainment effects).
Since the Service Water Pond is entirely under SCE&G control and is not considered public waters, any effects on organisms in this pond are of little consequence unless these effects cause problems in Monticello Reservoir. Deactivation by suspended material should preclude any significant effects in the Service Water Pond. The 36" pipe connecting the Service Water intake Structure with the Circulating Water intake structure allows exchange of water between Monticello Reservoir and the Service Water Pond. Water flows from the Service Water Pond to Monticello Reservoir only when the level of Monticello Reservoir is dropping. Since reduction of lake level occurs when Fairfield Pumped Storage Facility (FPSF) is generating, discharge of biocide from the Service Water Pond could occur only during FPSF generation. The location of the discharge point into Monticello Reservoir for water from the Service Water Pond depends on the operating status of the Circulating Water pumps. If the pumps are operating, water from the interconnecting pipe is entrained in the flow through the Circulating Water System and discharged through the Circulating Water Discharge Canal. If the Circulating Water pumps are not operating, discharge would occur through the Circulating Water intake.
9 Although deactivation of the biocide should reduce the possibility of effects, the use of biocide should be restricted to favorable lake level conditions (FPSF pumping back or idle). This would prevent the release of active components of the biocide to Monticello Reservoir. Application during " idle" periods should be delayed until the lake level and Service Water Pond level stabilize.
The bulk container of CT-1 should be diked to prevent any spills from entering the Service Water Pond. This would help prevent accidental introduction into the pond while FPSF is generating.
l Assumptions and Concerns l
The determination that the use of CT-1 in the Service Water System will have no significant adverse environmental effect is dependent upon deactivation of the active components of this biocide by adsorption onto suspended solids. If this product is not deactivated as claimed, then significant impacts could occur. Impacts which could occur include increased mortality of fish (adult, juvenile, and larval stages) and not easily quantifiable increases in entrainment losses to zooplankton and ichthyoplankton that are transported through the condensers. To ensure significant levels of biocide are not being released to Monticello Reservoir, a sampling and analysis program should be implemented to monitor the levels of biocide in the Service Water Pond. In addition to the raw water sampling proposed in the MRF, the Service Water Pond should be periodically sampled.
1
=_.
. Attachment III to Document Control Desk Letter
)
Page 3 of 9 1.evels of CT-1 in water that cause mortality in zooplankton (the 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> LC50 for Daphnia maana is 0.41 mg/l) have not been measurable with the analytical methods
~
available.. The lower limit of detection for the current analytical method is approximately 1 mg/l. New methodology proposed by Betz may allow detection of CT-1 at approximately 0.2 mg/l. A situation could occur where water might be considered free of biocide but still contain enough active ingredients to affect zooplankton. This has additional significance since ceriodaphnia dubia, an organism similar to Daphnia maana, is the test organism for combined effluent toxicity testing which is expected to be required on NPDES discharges at VCSNS beginning this year. Expected dilutions and deactivation by adsorption should-reduce possible effects.
Although not strictly an environmental issue, consideration was given to the possible repercussions of introducing the active and inert components of this biocide into the drinking water system at VCSNS via the raw water supply which is located at the Circulating Water intake Structure. The restriction of biocide use to priods of favorable lake level conditions, as described earlier, should prevent the introduction of the active components of the biocide into the raw water supply.
Inert ingredients, if not degradable, could concentrate in the Service Water System.
Ethylene glycol, a major inert component of CT-1, was viewed as a potential problem. However, available information suggests that ethylene glycol degrades in the environment and would not concentrate in the Service Water System. Inert ingredient concentrations should not increase to a point which would affect drinking water quality.
Conclusion Given the information available, the use of CT-1 to treat the Service Water System, as described in MRF-20629, should not cause any significant adverse environmental impact. There is, however, some uncertainty concerning direct or indirect effects; this would be expected with the use of any biocide. If, during the treatment of the Service Water System with CT-1, any concurrent unusual fish mortalities are noted or if levels of CT-1 as measured at the raw water intake or in the Service Water Pond significantly exceed those expected, the use of CT-1 should be re-evaluated.
Betz product information for CT-1 is attached.
l l
Stephen E. Summer, Supervisor Environmental Programs S/3/89
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BETZ CLAM TROL
- CT-1 MOLLUSCICIDE o Effectively controls all life stages of freshwater Higher temperatures and longer contact times re-Asiatic clams duce the amount of Clam-trol CT-1 that is required to achieve effective kills.
f e Controls a broad spectrum of microorganisms l
Normally, recirculating or closed systems should be e Biodegradable-low environmental Impact laid up for 24-48 hr after the system is enarged with an effective amount of product. Typical charge con-DESCRIPTION AND USE centrations are 25-50 ppm.
Clam-trol CT-1* is a unique blend of active ingredi-Once-through systems can be effectively treated by ents that controls mollusc infestations in industrial 10-30 ppm of product applied continuously over water systems. Asiatic clams, the most common 12-48 hr and repeatec two to four times a year. Or, freshwater mollusc problem, block water lines and effective control of molluscs and microorganisms damage equipment. The results can be higher pro-can also be achieved in once-through systems using duction and maintenance costs and plant shut-short-0.5-1.0 hr-daily applications of 10-30 ppm.
downs.
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,s,c A low level of Clam-trol CT-1, applied to a system for
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a short period, affects all life stages present, includ-( M,'.
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ing established adult populations. See Figure 1.
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Thereafter, periodic applications of Clam-trol CT-1
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inhibit recolonization of the system by larval and Ju-
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venile clams that are carried in with the makeup 3
water.
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Clam-trol CT 1 is registered for use against molluscs 3
as well as bacterial, fungal, and algal slimes in:
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Clam-trol CT-1 is a blend of organic biocides and
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contains no heavy metals or EPA priority pollutants.
4 ~
"' f-TREATMENT AND FEEDING REQUIREMENTS
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Adult clams should be physically removed by vacu-
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uming or dredging before the start of a Clam-trol CT-1 program so that dead clams are not carried further into the system.
Figure 1.
Asiatic clams growing on the plant Your Betz industrial representative will design a pro-side of influent screens. Clam trol gram for your system that controls the infestation CT-1, unlike halogen or screening problem while minimizing both the cost of the treat-methods, controls both !arval and ment and environmental concerns.
adult clams.
- The use of Clam-trol CT-1 for mollusc control is the subject of a pending U.S. patent appilcation.
PFP 083 8712 e 1987 BETZ LABORATORIES. INC, ALL RIGHTS RESERVED
- - - - - ~ ~ _ - -
i Segmenting plant wide application.s of Clam-trol SAFETY PRECAUTIONS j
~ CT-1 reduces the amount of product that appears in plant effluent. Clam-trol CT-1 undergoes neutraliza-A Material Safety Data Sheet containing detailed in-i tion and detoxification by natural routes. But your formation relative to this product is evailable upon j
Betz Industrial representative can provide products request.
that accelerats this process. An analytic test proce-dure is available from Betz that monitors product PACKAGING INFORMATION j
levels in plant outfall.
Clam-trol CT-1 is blended as a liquid and is supplied
)
Clam-trol CT-1 is compatible with stainless steel, in 55-gal (208-L) bung-type, nonreturnable lined copper alloys, and most common plastics and rub-steel crums. Approximate not weight is 460 lb (208 bers. Avoid the use of mild steel, low-density poly-kg) per drum, in addition. Clam-trol CT-1 is available i
ethylene, nitrile (Buna N). polyurethane, or Viton in under BETZ Point Of Feed
- and BETZ Semi-Butk
]
handling the concentrated product. A complete se-Control" programs for contracted quantities in cer-lection of compatible feed equipment is available di-tain geographic areas, rectly from Betz.
GENERAL PROPERTIES Appearancs................... colorless liquid Density at 70 'F (21 *C).
8.5 lb/ gal (1.02 kg/L)
Flash Point (closed cup )...... 2116 'F (47 'C)
Freeze Point............... < -30 ' F (-34
- C)
Initial Crystallization Point....... < 0 'F (-18 *C) pH (undiluted)
...........................5.3 (5% solution)....................... 4.9 Brookfield Viscosity at 70 'F (21 'C)..... 23 cP EPA Registration No.................. 3876-145 PFP 083 8712 Page 2
Attachment III to Document Control-Desk Letter Page,-6 of.9 BETZ LABORATORIES,INC.
4636 SOMERTON ROAD, TREVOSE, PA.,19047 BETZ MATERIAL SAFETY DATA SHEET 24 HOUR EMERGENCY TELEPHONE (HEALTH OR ACCIDENT) 215/355-3300 (PAGE 1 OF 3)
. PRODUCT :
CLAM-TROL CT EFFECTIVE DATE 09-03-87 LATEST VERSION PRODUCT APPLICATION : WATER-BASED MICROBIAL CONTROL AGENT.
SECTION 1-----------HAZARDOUS INGREDIENTS---------------
INFORMATION ON PHYSICAL HAZARDS, HEALTH HAZARDS, PEL'S AND TLV'S FOR SPECIFIC PRODUCT INGREDIENTS AS REQUIRED BY THE OSHA HAZARD COMMUNICATIONS STANDARD IS LISTED. REFER TO SECTION 4 (PAGE 2) FOR OUR ASSESSMENT OF THE POTENTIAL ACUTE i
AND CHRONIC HAZARDS OF THIS FOREJLATION.
ETHYLINE GLYCOL *** (1,2-ETHANEDIOL) ;CAS #107-21-1; POTENTIAL REPRODUCTIVE, LIVER, KIDNEY AND BLOOD TOXIN;PEL:NONE;TLV:50 PPM (CEILING).
ALKYL DIMETHYLBENZYL AMMONIUM CHLORIDE ***CAS#68424-85-1; CORROSIVE (EYES);
PEL:NONE;TLV:NONE.
ISOPROPYL ALCOHOL ***(IPA);CAS#67-63-0; FLAMMABLE' LIQUID; CHRONIC OVEREXPOSURE MAY CAUSE LIVER AND KIDNEY TOXICITY;PEL/TLV:400 PPM.
)ODECYLGUANIDINE HYDROCHLORIDE *** (DGH) ;CAS#13590-97-1; CORROSIVE;PEL:NONE; TLV:NONE.
S ECTION 2 -----------TYPICAL PHYS I CAL DATA ------------ -------------
PH: AS IS (APPROX.)
5.3 ODOR: MILD FL. PT. (DEG. F) : 116 SETA(CC)
SP.GR.(70F)OR DENSITY: 1.022 VAPOR PRESSURE (mmHG): 23 VAPOR DENSITY (AIR =1): >l VISC cps 70F: 23
% SOLUBILITY (WATER): 100 EVAP. RATE: <1 ETHER =1 APPEARANCE: COLORLESS PHYSICAL STATE: LIQUID FREEZE POINT (DEG.F):
<-30
SECTION 3-----------REACTIVITY DATA------------------------------
1 3LE l
THERMAL DECOMPOSITION (DESTRUCTIVE FIRES) YIELDS ELEMENTAL OXIDES.
-~v w a v en;sacumus aaa w PRODUSBs-CLAM-TROL CF 1
"- ---SECTION. 4-----------HEALTH HAZARD EFFECTS----------------- Document Control Dest-Letter
- ACUTE SKIN EFFECTS coo PRIMARY ROUTE OF-EXPOSURE
':ORROSIVE TO SKIN. POTENTIAL SKIN SENSITIZER Page 7 of 9
,A-
~E EYE EFFECTS ***
CORROSIVE TO THE EYES ACUTE RESPIRATORY EFFECTS *** PRIMARY ROUTE OF EXPOSURE VAPORS, GASES, MISTS AND/OR AEROSOLS CAUSE IRRITATION TO UPPER RESPIRATORY TRACT CHRONIC EFFECTS OF OVEREXPOSURE ***
PROLONGED OR REPEATED OVEREXPOSURE MAY CAUSE: TISSUE NECROSIS; BLOOD CELL DAMAGE OR IMPAIR BLOOD CELL FUNCTION; REPRODUCTIVE SYSTEM TOXICITY; SKIN SENSITIZATION.
MEDICAL CONDITIONS AGGRAVATED ***
NOT KNOWN SYMPTOMS OF EXPOSURE ***
INHALATION OF VAPORS / MISTS / AEROSOLS MAY CAUSE EYE, NOSE, THROAT AND LUNG IRRITATION; SKIN CONTACT MAY CAUSE SEVERE IRRITATION OR BURNS.
PRECAUTIONARY STATEMENT BASED ON TESTING RESULTS ***
MAY BE TOXIC IF ORALLY INGESTED.
SECTION 5------------FIRST AID INSTRUCTIONS----------------------
SKIN CONTACT ***
REMOVE CLOTHING. WASH AREA WITH LARGE AMOUNTS OF SOAP SOLUTION OR WATER FOR l'5 MIN.IMMEDIATELY CONTACT PHYSICIAN EYE CONTACT ***
IMMEDIATELY FLUSH EYES WITH WATER FOR 15 MINUTES.IMMEDIATELY CONTACT A
'HYSICIAN FOR ADDITIONAL TREATMENT IhnALATION EXPOSURE ***
REMOVE VICTIM FROM CONTAMINATED AREA. APPLY NECESSARY FIRST AID TREATMENT.IMMEDIATELY CONTACT A PHYSICIAN.
INGESTION ***
DO NOT FEED ANYTHING BY MOUTH TO AN UNCONSCIOUS OR CONVULSIVE VICTIM DO NOT INDUCE VOMITING.IMMED. CONTACT PHYSICIAN. DILUTE CONTENTS OF STOMACH USING 3-4 GLASSES MILK OR WATER
SECTION 6 ----------SPILL, DISPOSAL AND FIRE INSTRUCTIONS---------
SPILL INSTRUCTIONS ***
VENTILATE AREA,USE SPECIFIED PROTECTIVE EQUIPMENT.CONTAIN AND ABSORB ON ABSORBANT MATERIAL. PLACE IN WASTE DISPOSAL CONTAINER.THE l
CONTAMINATED ABSORBANT SHOULD BE CONSIDERED A PESTICIDE AND DISPOSED OF IN AN APPROVED PESTICIDE LANDFILL.SEE PRODUCT LABEL i
STORAGE AND DISPOSAL INSTRUCTIONS.
REMOVE IGNITION SOURCES. FLUSH AREA WITH WATER. SPREAD SAND OR GRIT.
DISPOSAL INSTRUCTIONS ***
WATER CONTAMINATED WITH THIS PRODUCT MAY BE SENT TO A SANITARY
. SEWER TREATMENT FACILITY,IN ACCORDANCE WITH ANY LOCAL AGREEMENT,A l
PERMITTED WASTE TREATMENT FACILITY OR DISCHARGED UNDER A NPDES PERMIT PRODUCT (AS IS)-
BURY IN AN APPROVED PESTICIDE FACILITY OR DISPOSE OF IN ACCORDANCE WITH LABEL INSTRUCTIONS FIRE EXTINGUISHING INSTRUCTIONS ***
'IREFIGHTERS SHOULD WEAR POSITIVE PRESSURE SELF-CONTAINED BREATHING APPARATUS (FULL FACE-PIECE TYPE).
DRY CHEMICAL, CARBON DIOXIDE, FOAM OR WATER
Atta'chment III to Qocument Control Desk EetterBETZ MATERIAL SAFETY DATA SHEET (PAGE 3 OF 3)
'Page 8'of 9-
, ppa 9UCT:
CLAM-TROL CT-1
-- :--SECTION 7-----------SPECIAL PROTECTIVE EQUIPMENT-----------------
' VENTILATION PROTECTION ***
' ADEQUATE VENTILATION TO MAINTAIN AIR CONTAMINANTS BELOW EXPOSURE LIMITS RECOMMENDED RESPIRATORY PROTECTION ***
IF VENTILATION IS-INADEQUATE OR SIGNIFICANT PRODUCT EXPOSURE IS LIKELY, i
USE A RESPIRATOR WITH ORGANIC VAPOR CARTRIDGES AND DUST / MIST PREFILTERS.
l RECOMMENDED SKIN PROTECTION ***
GAUNTLET-TYPE RUBBER GLOVES, CHEMICAL RESISTANT APRON WASH OFF AFTER EACH USE. REPLACE AS NECESSARY RECOMMENDED EYE PROTECTION ***
l SPLASH PROOF CHEMICAL GOGGLES. FACE SHIELD i
SECTION 8--------~~-STORAGE AND HANDLING PRECAUTIONS-------------
l STORAGE INSTRUCTIONS ***
' KEEP DRUMS & PAILS CLOSED WHEN NOT IN USE.
KEEP AWAY FROM FLAMES OR SPARKS. BOND CONTAINERS DURING FILLING OR DISCHARGE WHEN PERFORMED AT TEMPERATURES AT OR ABOVE THE I
PRODUCT FLASH POINT.
HANDLING INSTRUCTIONS ***
i GENERAL-IMMEDIATELY REMOVE CONTAMINATED CLOTHING, WASH BEFORE REUSE SP'CIFIC-COMBUSTIBLE. CORROSIVE TO SKIN AND/OR EYES.
SECTION 9-----------FEDERAL REGULATIONS--------------------------
FIFRA(40CFR): EPA REG.NO. 3876-145 OSHA (29CFR)-USE PROTECTIVE EQUIPMENT IN ACCORDANCE WITH 29CFR SECTIONS 1910.132-1910.134.
USE RESPIRATORS WITHIN USE LIMITATIONS OR ELSE USE SUPPLIED AIR' RESPIRATORS.
REPORTABLE QUANTITY: AS IS PRODUCT (HAZARDOUS SUBSTANCE)
NOT APPLICABLE j
RCRA (40CFR): IF DISCARDED,THIS MATERIAL BEARS HWI# D001,D002 l
DOT (49CFR) CLASSIFICATION: CORROSIVE TO SKIN. COMBUSTIBLE NFPA/HMIS : HEALTH - 3 ; FIRE - 2 ; REACTIVITY - 0 ; SPECIAL - CORR ; PE - D THIS DOCUMENT IS PROVIDED TO SUPPLY ALL THE INFORMATION NECESSARY TO COMPLY WITH OSHA HAZARD COMMUNICATIONS REGULATIONS, AND RIGHT-TO-KNOW REQUIREMENTS.
WEILE THE INFORMATION AND RECOMMENDATIONS SET FORTH H2 REIN ARE BELIEVED TO BE ACCURATE ES OF THE DATE HEREOF, BETZ LABORATORIES MAKES NO WARRANTY WITH RESPECT THERETO AND DISCLAIMS ALL LIABILITY FROM RELIANCE THEREON.
HAROLD M. HERSH ENVIRONMENTAL INFORMATION COORDINAT(,
l 1
LAttachment III to' Document Control Dask Letter
- Page. 9 of 9 Acuatic Toxicity
Adsorbed vs. Free Actives Acute toxicity-tests determining LC values for Clam-Trol CT-1 with 13% active ingredients is provided 50 follows:
Daehnia magng:
48 hr LC50 = 0. 41 mg/l (. 3 7 -.49 T.L.)
Fathead minnow 96 hr LC50 = 2. 9 mg/l ( 2. 5 - 3. 3 T. L. )
Bluegill Sunfish:
96 hr LC50 = 4. 3 mg/l (4.2 - 6. 6 T.L. )
Rainbow trout:
96 hr LC50. = 14. 7 mg/l (10 - 15. 5 T.L. )
. values represent toxicity levels for the neat The above LC for=ulation bken 100% of the " free" actives are available to the aquatic. organism (that is, no suspended solids for adsorption of the ;
actives).
i i
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i
' Attachment IV to Document Control Desk Letter 2*
j f
4ty 19,1989 Pagel1 of 1 SIGNIFICANT HAZARDS EVALUATION FOR VIRGIL C. SUMMER NUCLEAR STATION SERVICE WATER SYSTEM BIOCIDE TREATMENT Description of amendmentrequest:
1 South Carolina Electric & Gas Company (SCE&G) has been testing various products for control of corrosion and biological fouling of the Virgil C.
Summer Nuclear Station (VCSNS) Service Water (SW) system using a small side i
stream test stand. Although a comprehensive treatment program has not yet been defined, significant results have been obtained from this study.
SCE&G wishes to implement full scale treatment of the SW system with Betz "CT-1" to control Asiatic clams and microbiological 1y influenced corrosion.
This action is required to maintain this safety-related cooling system. The only alternative is to treat with continuous chlorination which, although effective, has been shown to increase corrosion due to soft-water attack by the cooling water at the VCSNS.
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Basis forproposed no significan t hazards consideration:
The proposed biocide treatment of the SW system does not involve a significant hazards consideration because the treatment would not:
1)
Involve a significant increase in the probability or consequences of an i
accident previously evaluated. This change allows control of service water system biofouling and helps assure system operability. The biocide used will not degrade system integrity or heat transfer.
Therefore, " Service Water System Failure Analysis" as discussed in FSAR Section 9.2 is not affected.
l 2)
Create the possibility of a new or different kind of accident from any accident previously evaluated.
It has been determined that the biocide used does not create any abnormal chemical or physical hazard that could affect plant operability.
3)
Involve a significant reduction in a margin of safety. The biocide used will reduce the potential for Service Water System flow blockage and does not degrade heat transfer capabilities to the ultimate helt sink.
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