NC0058297_Certification PPC_20011217

Elizabethtown/Lumberton Power, LLC
December 17, 2001
Department of Environment,
Health and Natural Resources
Fayetteville Regional Office
Wachovia Building, Suite 714
Fayetteville, North Carolina 28301
P.O. Box 1899
3100 West Broad Street j%
Elizabethtown, NC 28337-1899
[phone]
Fax [phone]
ElIVE
DEC 18 2001
P.O. Box 1063 DENR
n FCE
FAtrasfah PITT-”nAl
Lun ertgn, NC 28359
(910) 738:87..
Fax [phone]
Subject: Compliance Certification for Priority Pollutant Chemicals in Outfall 002,NC 0058297
Dear Sir:
Enclosed please find a certification from our water treatment vendor BetzDearbom. The chemical
formulations that they supply to our Elizabethtown facility, NC 0058297, do not contain any of the 126
priority pollutants as listed in 40 CFR 423 Appendix A. The chemical formulations that are currently used
in the cooling tower are Dianodic DN2104, Foamtrol AF1440 and Spectrus NX1104. The remaining
chemical formulations listed are used elsewhere in the facility mainly for boiler water treatment and waste
basin defoamers that are used as needed.
As specified in our NPDES Permit, Part III Other Requirements, (H); Elizabethtown Power wishes to
demonstrate compliance with the prohibition of discharge of toxic pollutants in detectable amounts by the
engineering calculation method. Since these chemicals are not added to our system there can be no
discharge of toxic pollutants (zero in=zero out).
As your office may be aware this facility is currently operating at a significantly reduced rate than it
historically has. Cooling tower discharge, Outfall 002 is intermittent at best in any case. It would be
extremely difficult to get a sample; much less a representative sample at this point in time. •
i
Thank you for your time. ff there are any questions or comments please do not hesitate to call me at 910-
738-8742.
Sincerely,
ifY) tuka.0-a-
Randy Musselwhite
Operations Manager
Enclosure
Cc: EHS File: 1.3.3
David Goodrich, DEHNR

• BetzDearborn
Shaping the Future of Water & Process Treatment
December 11, 2001
Mr. Randy Musselwhite-Operations Manager
Elizabethtown/Lumberton Power
Highway 87
P.O. Box 1899
Elizabethtown, NC 28337
BetzDearborn
, 4636 Somerton Road
PO Box 3002
Trevose, PA 19053-6783
215 355-3300
•
RE: Foamtrol AF1440, Spectrus NX1104, Dianodic DN2104, SteaMate NA0560, Cortrol
0S7780, Optisperse HP54414
Dear Mr. Musselwhite:
We are writing this letter in response to your request, concerning the BetzDearborn
product(s) referenced above. 1
After carefully examining the constituents of this/these product(s), we can assure you that
none of the ingredients, inert/inactive ingredients, or contaminants are listed as Priority
Pollutants as set forth in 40 CFR 423 Appendix A.
If you need any additional information concerning environmental issues and our products,
please contact your BetzDearborn representative.
Sincerely,
.(Ms.) Fran Wachowski
Environmental Information Coordinator
cc: E. A. Kozmic
A Division of Hercules Incorporated