NC0039586_Approval to Change Water Treatment Chemical Supplier_20120905

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NCDENR
North Carolina Department of Environment and Natural
Division of Water Quality
Beverly Eaves Perdue
Governor
Mr. Ernest J. Kaopopoulos, Jr.
Plant General Manager
Progress Energy Carolinas, Inc.
Harris Nuclear Plant
P.O. Box 165
New Hill, NC 27562
Charles Wakild, P. E.
Director
September 5, 2012
Subject: C P & L d/b/a Progress Energy Carolinas, Inc.
Harris Nuclear Plant
Approval to Change Water Treatment Chemical Supplier
Dear Mr. Kaopopoulos:
Resources
Dee Freeman
Secretary
In April 2012, I did discuss Progress Energy's request for authorization to precede with
conversion of certain water treatment chemicals to Nalco products from GE Water chemicals. In
error I did not follow this up with written confirmation. We have been in the process of
converting Biocide Conditions in Power Plant permits by adding the statement "Completion of
Biocide Worksheet Form 101 is not necessary for those outfalls with toxicity testing
requirements. " I apologize, for I have done several of these changes, and thought that your
permit had already been revised. The new Draft Permit renewal will have this statement. This
letter should be considered approval for making the chemical supplier change, as both Outfall
006 and 007 at younfacility do have toxicity testing requirements.
Please contact me if there are any further questions..
Sincerely,
Y ek
Jim McKay
Complex NPDES Permitting Unit
cc: Mr. Steve Cahoon - via email ([e-mail])
Central Files
Raleigh Regional Office, SWP Supervisor - via email
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet www.portal.ncdenr.org/weblwq/home
An Equal Opportunity 1 Affirmative Action Employer
NorthCarolna
;Uffrally

August 30, 2012
Serial: HNP -12-092
Mr, Jim McKay
North Carolina Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: CP&L d/b/a Progress Energy Carolinas, Inc.
Harris Nuclear Plant
NPDES Permit No. NCO039586
Chemical Change from GE Water Products to Nalco Chemicals
Dear Mr. McKay:
By letter dated February 21, 2012 (copy attached), Progress Energy Carolinas; Inc. outlined several
amendments made to our current NPDES permit application as well as the permit renewal
application submitted on January 27, 2011. One of the amendments was to identify a corporate
change from GE Water chemicals to Nalco chemicals. The change is necessary due to a change in
the corporate contract for chemical purchases of our generating facilities.
In April 2012, you had a phone conversation with Mr. Steve Cahoon, of our Environmental
Services Section, regarding authorization to proceed with the chemical change from GE Water'
chemicals to Nalco chemicals. During the conversation you indicted that you had checked with the
Environmental Sciences Section within the Division of Water Quality (DWQ) and they"had no "
issue with the change from GE Water chemicals to Nalco chemicals. They were not concerned
because the chemical transition was essentially a like for like chemical exchange.
Since our permit application is still under DWQ review, the Harris Plant is requesting that you
respond to this letter with a written response indicating that DWQ is granting permission for the
chemical exchange from GE Water chemicals to Nalco chemicals.
If you have any questions regarding this matter, please contact Steve Cahoon at [phone] or
[e-mail].
Progress Energy Carolinas, Inc.
Harris Nuclear Plant
P. 0. Box 165
New Hill, NC 27562

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Division of Water Quality
Serial: HNP -12-092
I cert, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry of the
person or persons who manage the system, or those persons directly responsible for gathering
the information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false
information, including the possibility of fines and imprisonment for knowing violations.
Sincerely,
Ernest J. Kapopoulos, Jr.
Plant General Manager
Harris Nuclear Plant
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Attachment: Letter dated February 21, 2012 (HNP -12-022)

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Progress Energy
FEB 2 1 '. SERIAL: HNP -12-022
Mr. Jeffrey O. Poupart
North Carolina Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Carolina Power & Light Company, .doing business as Progress Energy Carolinas, Inc.
Harris Nuclear Plant NPDES Permit No. NCO039586
Application Modification Request
Dear Mr. Poupart:
By submittal of this letter, Progress Energy Carolinas, Inc. is amending the subject current NPDES
permit as well as the permit application filed on January 27, 2011. This amendment has a dual
purpose: l) to include the construction of a sand filter at the sewage treatment plant (Outfall 002)
to help alleviate recent TSS issues in the plants discharge, and 2) to facilitate a corporate move
from predominately GE Water chemical products to predominately Nalco chemical products
(although we will still use some GE Water products). The replacement products contain
essentially the same chemical composition with the main difference being the vendor from which
the chemicals are purchased. The following is a list of the new chemicals and the chemicals they
are replacing.
Nalco Chemical (New)
GE Betz Chemical (Replaced)
Ouantity
Frequency
Purpose
Nalco 71 DS Plus
GE Betz FOAMTROL 1440
100 gal/yr
As Needed
Foam Control Agent
Nalco 7384
GE Betz Flogard MS6208
1800 go[/yr
As Needed
Corrosion Control
Nalco 3DT 179
GE Betz Depositrol PY5200
7000 gal/yr
As Needed
Corrosion Control
Nalco 3DT 190
GE Betz Depositrol BL 5325
8000 gal/yr
As Needed
Deposit Control
Nalco 3DT 197
GE Betz Inhibitor
AZ 8104
6000 gal/yr
As Needed
Corrosion Control
Nalco 73550 or 73551
GE Betz Spectres BD 1500
Varies
As Needed
Biodispersant
Nalco 3DT185
GE Betz Flogard MS6222 .
9000 gal/yr
As Needed
Corrosion Control
Nalco 8103 PLUS
G E Betz Klaraid PCI 192
600 gatlyr
As Needed
Settling Agent
Nalco TRAC 104
Sodium or Potassium
Molybdate
100-200 gal/yr
As Needed
Corrosion Control
Nalco TRAC 102
Sodium or Potassium Nitrate
50-100 gaVyr
As Needed
Corrosion Control
Nalco PC -33
GE Betz Kleen MCT -511
200-400 gal/yr
As Needed
System Cleaning
Naito PC -87
GE Betz Kleen MCT -103
200-400 pVyr
As Needed
System Cleaning
Progress Energy Carolinas, Inc.
Harris Nuclear Plant
P 0 Box 165
New Hill, NC 27552

Division of Water Quality
SERIAL: HNP -12-022
Nalco 7408
GE Betz DCL -32
400-800 gaVyr
As Needed
Chlorine Removal
Nalco PC -191 or PC-
191T
GE Betz Hypersperse MDC -700
200A00 gal
Daily
Membrane Deposit Control
Nalco 7390
GE Flogard POT 802 Zinc
phosphate
200400 gal
Daily
Corrosion Control
Nalco H-130
GE Betz Spectres 1300
1440 gal
As Needed
Non -oxidizing Biocide
Nalco H-550
5 gal
As Needed
Biocide
Nalco C370
16,000 gal
Daily
Chlorination Enhancement
Enclosed with this submittal is 1) an updated Attachment 4 of EPA Forth 2C reflecting the,
inclusion of the sand filter at the sewage treatment plant (Outfall 002), 2) an updated Attachment 5
of EPA Form 2C.Potential Discharges Not Covered By Analysis, and 3) the MSDS for each of
these new products_ A biocide 101 worksheet was not included for Nalco H-550, because there is
a toxicity testing requirement at Outfal1006 where the waste water that would contain these
chemicals discharges into Harris Lake. We will gladly assist should additional questions arise.
If you have further questions, please feel free to contact Steve Cahoon at [phone] or
steve.cahoon(a p-m-nail.com.
I certify, under penalty of law, that this document and all attachments were prepared under
my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry of
the person or persons who manage the system, or those persons directly responsible for
gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate, and complete. 1 am aware that there are significant penalties for
submittingfalse information, including the possibility offines and imprisonment for
knowing violations.
Sincerely,
Ernest J. Kapopoulos, Jr.'
Plant General Manager
Harris Nuclear Plant
EJK/mgw
Enclosures