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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 &regulations 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