HomeMy WebLinkAboutNC0004987_Permit App. Amendment_20160617�L
t , DUKE /� ,—�� Larry E. Hatchet
(�{'- 11 � Vice President
NE"ENERGY,
Environmental Services
CAROLINAS 526 South Church Street, EC13X
Charlotte, NC 28201
o: 704.382.0298
f.• 704.382.0249
June 17, 2016 larry.hatcher@duke-energV•com
Mr. Tom Belnick
Division of Water Resources .
WQ Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: AnodamineTM Use at NC Facilities
NPDES Permit application amendment
Dear Mr. Belnick:
RECEIVED/NCDEQ/DWR
JUN 2 4 2016
Writer Quality
Pertnitting Section
Duke Energy Carolinas, LLC and Duke Energy Progress, LLC (collectively, "Duke Energy") are
seeking your concurrence in the use of AnodamineTM for equipment maintenance at the stations
listed below, under existing NPDES permits. The use of AnodamineTM is not anticipated to be a
material or substantial alteration or addition that requires a permit modification under 40 C.F.R.
122.62 or a change in condition that requires a limitation of the permitted discharge under 15A
N.C.A.C. 021-1.0114.
Duke Energy routinely uses water chemistry products for the maintenance of equipment
components at our generation sites. Facilities require scheduled maintenance at routine
intervals (outages). During outage maintenance activities or extended periods where units are
not in demand, boilers are placed in a layup mode. In order to protect the internal metal
surfaces, AnodamineTM will be introduced to establish a protective coating or barrier, which in
turn reduces corrosion during startup. While most of the AnodamineTM will be consumed in the
process, there may be trace amounts remaining in the boiler and associated blowdown water as
the boiler unit starts up and comes online. The Safety Data Sheet for AnodamineTM is attached.
Note that Section 12 - Ecological Information, indicates that the LC50 for the most sensitive
organism tested (Pimephales) is 49,210 mg/I. At Duke Energy plants, AnodamineTM will be
introduced into the boiler chemistry cycle at an initial concentration of 1.0 mg/l, and the
concentrations in effluent (if any) will be lower. Thus, to the extent AnodamineTM is found in
effluent, it is not expected to have any impact on receiving waters.
Duke Energy further requests that the Division accept this letter as a modification to all pending
NPDES permit applications; specifically, we request that AnodamineTM be added to our EPA
Form 3510-2C Section VI: "Potential Discharges not covered by Analysis". Future NPDES
renewal applications will explicitly include this maintenance product, if its use is still anticipated.
This communication covers use at the following stations:
IL;_
Duke Station
NPDES Permit Number
Belews Creek
NCO024406
Buck CC
NC0004774
Dan River CC
NCO03468
H. F. Lee CC
NC0003417
Mao
NCO 038377
Roxboro
NC0003425
Smith Energy
NCG500594
Sutton CC
NC0001422
Allen
NC0004979
Asheville
NC0000396
Rogers Energy
NCO05088
W. S. Lee
SC0002291
Marshall Steam
NC0004987
If you have any questions regarding the use of this product, please do not.hesitate to contact
Ms. Cyndi Winston, P.E., Manager of the Carolinas Permitting and Compliance Group at (919)
546-5538 or via email at Cynthia.Winston @ Duke- Energy. com.
Sincerely,
Mr. Larry E. Hatcher
Vice President Environmental Services
Environmental, Health & Safety .
cc: Belews Creek Steam- Electric Station (SES) NPDES File, Buck SES NPDES File, Dan
River SES NPDES File, H.F. Lee SES NPDES File, Mayo SES NPDES File, Roxboro
SES NPDES File, Smith Energy Center SES NPDES File, Sutton SES NPDES File,
Allen SES NPDES File, Asheville SES NPDES File, Rogers SES NPDES File, and
Marshall SES NPDES File
Jeremy Pruett
Don Safrit
Shannon Langley
Cynthia Winston
SAFETY DATA SHEET I RN®ORM NE
According to Federal register/Vol. 77, No 58, March 26, 2012 /rules ®ulations O
Safety Data Sheet compliant with OSHA Hazardous Communication Standard, 2012 (OSHA -HCS)
1.1 Product identifier
Trade name AnodamineTM HPFG
Alternative Names Surface-active polyamines.
1.2 Relevant Identified uses of the substance / mixture and uses advised against
Identified Uses High-pressure boiler metal passivation scale and corrosion
inhibition for industrial water treatment.'
1.3 Details of the supplier of the safety data sheet
Supplier Anodamine Inc, 2590 Oakmont Drive, Building 300, Round
Rock, Texas, USA 78665
Telephone and Fax Tel: + 1 (512) 244 2318
Contact details of person Technical Support Services contact (info cpanodamine.coml
responsible for SDS Tel: + 1 (512) 244 2318
1.4 Emergency telephone number
For USA: Chemtrec: +1-800-424-9300
Canada: CanuTec: 6137996-6666
For
e-mail: ers(cr)chemtelinc.com
Opening Hours
24 hours
Other Comments (e.g. Language of
English
the phone service)
2.1 Classification of tile ance or mixture
GHS -US cassification Not classified
Additional Information
For full text of Hazard statements: See Section 16 -
2.2 Label elements
GHS -US labelling:
Hazard Pictogram
No hazard pictograms required
Signal Word
No signal word required
Hazard Statements
No hazard phrases required
Precautionary Statements
Response: None
Storage: None
Disposal: None
Supplemental Hazard Information
None
Not a PBT or vPvB
2.8 Other Hazards
2.4 Unknown Acute toxicity (GHS -US) No data available
3.2 Mixture:
sation: Surface active Polyamines
Chemical Characteri
Remarks: No hazardous ingredients resent according to OSHA; -GHS 2012-
4.1 Description of first aid measures
General Notes Immediately call doctor/ physician if required.
Inhalation No effects or symptoms are expected when handling the product. No respiratory
PPE is required. Remove to fresh air if irritation occurs get medical attention.
Skin Contact Remove contaminated clothing and shoes and immediately wash affected area
with plenty of soap and rinse area with large amounts of water. Get medical aid if
required.
contact lenses and continue flushing eyes with plenty of soap and
Eye Contact Remove any
water for at least 15 minutes, occasionally lifting the upper and lower lids. Get
medical aid immediately. Do NOT allow victim to rub or keep eyes closed.
Ingestion Do NOT induce vomiting. If victim is conscious and alert, wash out mouth with
water, give several glasses of water. Get medical aid immediately if necessary.
4.2 Most important symptoms and effects, both acute and delayed
Refer to section 11 for more information on health effects and symptoms.
SAFETY DATA SHEET ^ �w
According to Federal registerNol. 77, No 58, March 26, 2012 holes & regulations ° R I w' � O D R M S I �p�
E
4.3 Indication of immediate medical attention and special treatment needed: None specific
SECTION
5.1 Extinguishing media:
Suitable extinguishing media: Use water fog or spray, dry chemical foam or carbon dioxide
Unsuitable extinguishing media: None known
5.2 Special Hazards arising from the substance / mixture: Under fire conditions it may produce irritating
fumes and/or gases if heated to 600 OC (1112 OF) or above.
Hazardous Combustion Product: Thermal decomposition products may release toxic and/or
hazardous fumes or gases including carbon oxides (CO & CO2),
amine.
5.3 Advise for fire fighters: Wear self-contained breathing apparatus and acid resistant
clothing
SECTION
6.1 Personal precautions, protective equipment and emergency procedures
For non emergency personnel:
Protective Equipment Use personal protection recommended in section 8
Emergency Procedures Evacuate the spill area safely to permit authorised personnel to
handle the spill.
For Emergency Responders Emergency responders must wear the proper personal protective
equipment (and have appropriate fire -suppression equipment)
suitable for the situation to which they are responding.
6.2 Environmental precautions:
Avoid release to the environment. Collect leaking substance with suited acid proof containers. Do not
allow to enter into drain or surface waters. Collect contaminated material in suited acid- proof
containers. Dispose of contaminated material and its container as waste according to local
regulations.
Water Spill: The material will not cause any adverse environmental impact if it riches waterways
however avoid release in to waterways. The products considered non -hazardous to aquatic
environment based on third -party test results.
Land spill: None
Air Spill: None known
6.3 Methods and material for containment and cleaning up:
Contain large spills with containment walls and transfer the material to appropriate containers for
reclamation or disposal. Collect by sweep, scoop or vacuum and remove. Flush spill area with water.
The spill area may be slippery. Soak up liquid residue with suitable absorbent such as clay or saw
dusts
6.4 References to other sections: Refer section 13 for disposal consideration
Additional information: Avoid contact with skin and eyes as part of safe handling. If spillage occurs on the
public highway, indicate the danger and notify the authorities (police, fire brigade).
SECTION
7.1 Precautions for safe handling:
Protective measures Avoid repeated contact with skin and eyes. Avoid inhalation of vapours
or fumes.
Do not open the containers until ready for use. Close the containers
properly.
Handle in accordance with good industrial hygiene and safety practices
as mentioned in section 8.2. These practices include using appropriate
personal protection, avoiding unnecessary exposure and removal of
material from eyes, skin and clothing. Do not eat, drink or smoke when
handling this product.
Observe all recommended safety precautions until container is cleaned,
SAFETY DATA SHEET . I�NO��NIiNE
According to Federal registerNol. 77, No 58, March 26, 2012 /rules & regulations
reconditioned or destroyed. The reuse of this material's container for
non -industrial purposes is prohibited and any reuse must be in'
consideration of the data provided in this material safety data sheet.
Advice on general Keep personal protective equipment in a clean place, away from the
occupational Hygiene work area. Use clean and correctly maintained personal protective
equipment. Always wash your hands after handling the product.
Do NOT eat or drink in the workplace..
7.2 Conditions for safe storage including any incompatibilities:
Technical measures and Take all necessary precautions to avoid the accidental release of the
storage conditions product outside due to the rupture of containers or transfer systems.
Ensure there is a suitable retention system. Storage facilities should be
dry.
Packing Material:
Suitable packing and
storage material
Unsuitable. "packing and.
storage material
Requirements for storage
rooms and vessels
Advice on common storage
Storage Class
Further information on.
storage conditions
7.3 Specific end Use(s)
SS 316 (only for transportation purpose), original containers or metal
containers with glass, PVC, PP, PE or GRP lining
Avoid contact with aluminium, copper, copper alloys, nickel and zinc.
Storage should be done in original containers. Store the containers in
cool and dry place'at ambient temperature at temperature > 37 OF
(freezing protection) or < 180 of typically ensure a useable shelf life of
3-5 years. Even after freezing, thawing allows re -use of the product
without limitations
No special restriction on storage with other products
12
Shelf life: 3-5 years
Refer section 1.2
8.1 Control Parameters
No specific occupational exposure limit is known or established on components present in the
product.
8.2 Exposure controls
Appropriate engineering controls
Personal Protection equipment
Eye / face protection
Skin protection
Hand Protection:
Other skin protection:
Respiratory protection
Environmental Protection Control
No specific additional engineering controls are required. Provide
good natural or artificial ventilation.
Use face shield and/or chemical goggles. Have eye wash
facilities immediately available at any location where eye contact
can occur.
Wear gloves of suitable material. Wear suitable protective
clothing including aprons, boots, or a suitable acid resistant
chemical suit. Wash thoroughly after handling. Although this
product does not present a significant skin concern, minimize
skin contamination by following good industrial practice.
Avoid breathing vapour / mist. Use approved respiratory
protection equipment when air borne exposure is excessive.
Consult respirator manufacturer to determine the appropriate
type of equipment for a given application. Observe respirator use
limitations specified by the manufacturer. In case of 'insufficient
ventilation, wear suitable respiratory equipment
Avoid direct discharge into drains
9.1 Information on basic physical and chemical properties
Appearance Liquid
Colour Clear liquid to light straw colour
Odour Characteristic or limited
Odour Threshold Not available
pH -6.0 of 1% solution at 25 OC
SAFETY DATA SHEET ��®�f�MetVE
According to Federal registerNol. 77, No 58, March 26, 2012 /rules & regulations0
Freezing point / range
Initial boiling point / range
Flash point
Evaporation rate
Flammability (solid, gas)
Upper/lower flammability or
explosive limit
Vapour Pressure
Vapour Density
VoC content
Specific gravity@ 25C
Solubility(ies)
Partition coefficient (N-Octanol /
Water)
Auto ignition temperature
Decomposition temperature
Viscosity
Explosive Properties
Oxidising Properties
Percentage of Volatile components
9.2 Other information
< 37 OF
>I 00 OC (Similar to water)
Not available
Not determined
Not flammable or combustible
Not applicable
Same as water
Not available
No data available
0.98
Miscible in water
No data available
Not applicable
Not available
No data available
No data available
No data available
1% of non -hazardous active in water steam phase at > 250 OC
Please refer technical datasheet
Acute inhalation toxicity No test data available
Acute dermal toxicity Species: rat
Route of administration: Dermal
LD50: >5000 mg/kg
Not classified for acute dermal toxicity as per OSHA -GHS
regulation
Skin irritation Species: Rabbit
Exposure: 4 hour
Result: Not irritating
Not classified for skin irritation as per OSHA -GHS regulation
Serious eye damage / irritation Species: Rabbit
Result: Not irritating
Not classified for Eye irritation/ damage as per GHS regulation
Respiratory irritation No data available
• o
10.1
Reactivity
Reacts vigorously with acids, metals and oxidising agents
Hazardous polymerisation
None
10.2
Chemical Stability
Stable under recommended storage and handling conditions.
10.3
Possibility of hazardous reactions
Hazardous polymerization -is not expected to occur under
normal temperature and pressure.
10.4
Conditions to avoid
Avoid contact with aluminium, nickel, zinc, copper and copper
alloys.
10.5
Incompatible materials
Acidic and Strong oxidizers
10.6
Hazardous decomposition
Carbon oxide fumes (CO, CO2)
products
SECTION
11.1
Information on toxicological effects
Acute oral toxicity
Species: rat
Route of administration: oral
LD50: >5000 mg/kg
Not classified for acute oral toxicity as per OSHA -GHS
regulation
Acute inhalation toxicity No test data available
Acute dermal toxicity Species: rat
Route of administration: Dermal
LD50: >5000 mg/kg
Not classified for acute dermal toxicity as per OSHA -GHS
regulation
Skin irritation Species: Rabbit
Exposure: 4 hour
Result: Not irritating
Not classified for skin irritation as per OSHA -GHS regulation
Serious eye damage / irritation Species: Rabbit
Result: Not irritating
Not classified for Eye irritation/ damage as per GHS regulation
Respiratory irritation No data available
SAFETY DATA SHEET Pa N O til M I N E
According to Federal registerNol. 77, No 58, March 26, 2012 /rules & regulations
Sensitisation Species: Guinea Pig
Result: Not sensitizing
Not classified for skin/ respiratory sensitization as per OSHA -
GHS regulation
Repeated dose toxicity No classification is required for Repeated. dose toxicity
Germ cell mutagen city Negative results obtained in Ames, CHO HGPRT forward
mutation and micronucleus tests.
Carcinogenicity Not expected to be a carcinogen
Reproductive toxicity No classification is required for Reproductive toxicity
Specific target organ toxicity — No data available
single exposure (STOT SE)
Specific target organ toxicity — No data available
repeated exposure (STOT RE)
Aspiration hazard No data available
SECTION
w 12.1 Toxicity Toxicity on Fish:
Species: Pimephales promelas
Duration: 96 h
LC50: > 100mg/l
Toxicity. on Invertebrates:
Species: Daphnia magna
Duration: 48 h
EC50: >100 mg/l
Toxicity on Algae:
Species: Algae
Duration: 72 h
EC50: >100 mg/1
(Data extrapolated from similar products or equivalent
analogues)
12.2 Persistence and degradability Test Method Degree of
Removal
OECD 301D (Ready Biodegradability: 91%
Closed Bottle Test) 28 d
12.3 Bio accumulative potential No data available
12:4 Mobility in Soil No data available
12.5 Results of PBT and vPvB This substance does not fulfil the criteria for PBT or vPvB
assessment
12.6 Other adverse effects No information available
13. Disposal considerations
13.1 Waste treatment methods All local and national regulations should be followed. Consult
regulatory officials for disposal requirement. For small quantities flush
away with plenty of water. For large quantities send to special waste
disposal system and burn in proper incinerator. This product should
not be dumped in public storage and sewers / waterways.
13.2 US EPA RCRA Status This material when discarded is not a hazardous waste as that term is
defined by the Resource, Conservation and Recovery Act (RCRA), 40
CFR 261.
SAFETY DATA SHEET
According to Federal register/Vol. 77, No 58, March 26, 2012 /rules & regulations
13.2.1 US EPA RCRA
Not applicable
hazardous waste number
(IMDG-
13.2.2 Compound/ Characteristic
Not applicable
13.3 Disposal considerations
Incineration
IV RNM3RMINES
SkCTION
The Product does not meet for classification as dangerous good according to local or International transport
reanlatinnc ThP nmrinrrt is rrlaaeii evi ns not eine—rnna a—1 o
15. Regulatory information I
Inventory status All components are on the following inventories:
US TSCA, Canadian DSL, EU EINECS
US federal regulations
US TSCA (12b) This product does not contain sny chemical substances subjected
to the US Toxic Substance Control Act (TSCA) 12 (b) export
reporting requirements.
Product is compliance with TSCA regulation.
SARA Hazard Notification:
Hazard Categories Under Title Not applicable
III Rules (40 CFR 370)
SARA Section 311/312 Not applicable
Hazard Categories
SARA Title III Section 302 None
Extremely Hazardous
Substances
SARA Title III Section 313 This product does not contain any chemical with known CAS
Toxic Chemicals numbers that exceeds the threshold (De Minimis) reporting levels
established SARA Title III, Section 313.
US EPA CERCLA None
Hazardous Substances (40
CFR 302)
OSHA Process Safety Not applicable
Management, 29 CFR 1910.119
CERCLA Reportable Quantity Not applieble
California proposition 65 To the best of our knowledge, this product does not contain any of
US DOT (Road & Air)
Mexican regulation
(IMDG-
ICAO-IATA/DGR
ADR/RID/GGVSE
for Land transport
Code/GGVSee
Canada TDG
of Hazardous
materials and
wastes
14.1 UN
Number
14.2 UN
Not applicable
Not applicable
Not applicable
Not applicable
Proper Shipping
Name
14.3
Not applicable
Not applicable
Not applicable
Not applicable
Transport
Hazard Class
14.4 Packing
Group
14.5
No
No
No
No
Environmental
hazards
14.6 Special
precautions for
user
14.7 Transport in bulk according to Annex II of MARPOL 73/78 and the IBC Code: Not available
15. Regulatory information I
Inventory status All components are on the following inventories:
US TSCA, Canadian DSL, EU EINECS
US federal regulations
US TSCA (12b) This product does not contain sny chemical substances subjected
to the US Toxic Substance Control Act (TSCA) 12 (b) export
reporting requirements.
Product is compliance with TSCA regulation.
SARA Hazard Notification:
Hazard Categories Under Title Not applicable
III Rules (40 CFR 370)
SARA Section 311/312 Not applicable
Hazard Categories
SARA Title III Section 302 None
Extremely Hazardous
Substances
SARA Title III Section 313 This product does not contain any chemical with known CAS
Toxic Chemicals numbers that exceeds the threshold (De Minimis) reporting levels
established SARA Title III, Section 313.
US EPA CERCLA None
Hazardous Substances (40
CFR 302)
OSHA Process Safety Not applicable
Management, 29 CFR 1910.119
CERCLA Reportable Quantity Not applieble
California proposition 65 To the best of our knowledge, this product does not contain any of
SAFETY DATA SHEET N O �7 I� M I N E
According to Federal register/Vol. 77, No 58, March 26, 2012 /rules & regulations o
the listed chemicals, which the state of California has found to
cause cancer, birth defects or other reproductive harm.
Hazardous air pollutants (Clean The product does not contain any hazardous air pollutants as
Air Act) listed under section 112 of the Clean Air Act
Clean water act (CWA) None listed
The product does not contains any chemicals which are listed as a carcinogen by IARA, NTP & OSHA
NEPA Rating
NA .',
HMIS Health: 1
Flammability:0
Physical hazards:0
Special Hazard: NA
HAZCOM Standard Status This material is not considered to be hazardous by the OSHA
Hazard Communication Standard (29 CFR 1910.1200).
other International regulations
Canada:
Canadian WHMIS classification
National Pollutants Release
Inventory (NPRI)
Priority Substances List 1 and
Priority Substances List 2 (PSL
1 and PSL2)
Not regulated or classified
The product does not contain any components listed on
Environment Canada's NPRI
The product does not contain any components listed on
Environment Canada's PSL/ and'PSL2
EU regulations
Classification according to Not a hazardous substance or mixture according Regulation (EC)
Regulation (EC) No. 1272/2008 No. 1272/2008
[CLP)
Classification according to Not classified
Directive 67/548/EEC
SVHC or restricted substances No substances on this list have been intentionally added to the
list as per REACH regulation product. Concentration of impurities, if any, is expected to be
below 0.1%.
Water Hazard Class (Germany) WGK: Slightly water endangering.
SECTIONother
Indication of changes All sections revised to meet OSHA -GHS requirements
Last revision date -
Procedure used to derive the classification according -GHS Revision no:3 (adopted guidance by OSHA)
Classification Judgement
Not classified On basis of weight of evidence
i
Abbreviations and acronyms CSR = Chemical Safety Report
DNEL = Derived No Effect Level
LD50 = Median lethal dose
SAFETY DATA SKEET
According to Federal registerNol. 77, No 58, March 26, 2012 /rules & regulations ®® R N O O R M B N E
PNEC = Predicted No Effect Concentration
STEL = Short term exposure limit
TLV = Threshold limits
TWA = time weighted average
IATA = International Air Transport Association
IMDG = International Maritime Dangerous Goods Code
PBT = Persistent Bioaccumulative Toxic
vPvB = very Persistent and very Bioaccumulative
GHS =
OSHA = Occupational Safety and Health Administration
IARC = International Agency for Research
NTP = The National Toxicology program
TSCA = US Toxic Substance Control Act
Key literature references for data Environmental Properties and Safety Assessment of Organic
used for Surface-active Polyamines Detergent and Water
Treatment Applications----W.E. Gledhill and T.C.J. Feijtel
Relevant Risk Phrases (in full) Not applicable
Relevant H Statements (in full) Not applicable
Further information -
Although the information and recommendations are presented in good faith and believed to be correct as of
the date hereof, Anodamine Inc. makes no representations as to the completeness or accuracy thereof.
Information is supplied upon the condition that the persons receiving same will make their own
determination as to its. suitability for their purposes prior to use. In no event will Anodamine Inc,. be
responsible for damages, of any nature whatsoever resulting from the use of or reliance upon this
information. No representations or warranties, either expressed or implied, of merchantability, fitness for a
particular purpose or of any other nature are made hereunder with respect to information or the product to
which this information refers. The data here is based on literature information.
For all purpose the English version is final Version No: 1 US -GHS 2014