Notes from Site Visit at Progress Energy's H.B. Robinson Steam Electric Plant on October 21, 2009

EPA conducted a site visit at Progress Ener gy’s H.B. Robinson Steam Electric Plant (HB Robinson) located in Hartsville, SC on We dnesday, October 21, 2009 to learn about the operations at the plant, specifically the opera tions and wastewaters ge nerated by the nuclear electric generating unit and the ash handling syst em associated with the coal-fired electric generating unit. Table 2, located at the end of this memora ndum, identifies the site visit participants. An overall water balance diagram fo r the plant is provided as Attachment 1.

This memorandum describes the information collected during the site visit and the pre-site visit phone call, which was held on October 14, 2009.

Plant Overview

 HB Robinson operates one coal-fired unit (Unit 1) and one nucl ear unit (Unit 2). The table below contains some general information for the two units.

Table 1. HB Robinson Units Description

Unit Type of

Fuel Installation

Date Capacity (MW) Particulate

Control NOx

Control SO 2 Control

1 Bituminous

Coal 1960 174 Cold-side

ESP Low-NOx burner;

Overfire air

separator None

2 Nuclear (Uranium) 1971 710 N/A (no air emissions) N/A (no air emissions) N/A (no air emissions)

 Unit 1 was installed in 1960 by Carolina Power & Light. The unit has a capacity of 174 MW. Carolina Power & Light al so constructed Lake Robinson, a 2,250- acre lake, for the unit. The lake is used as a cooling pond for the once-through cooling water.

 Carolina Power & Light initially had plan s to build three a dditional coal-fired units, but in the late 1960s nuclear en ergy became available and the company

decided to build a nuclear unit instead.

 Unit 2 began operation on March 7, 1971. The unit has a capacity of 710 MW.

 HB Robinson was the first nuclear plant built in the southeastern United States.

 HB Robinson stated that the plant also has 13 internal combustion turbines on site with a combined capacity of 812 MW. Thes e turbines are operated as swing units to provide stability to the grid and th e nuclear unit. The internal combustionPage 2

turbines are owned by Progress Energy.

 HB Robinson stated that they have dry fu el storage on site (i.e., spent fuel). The fuel is initially stored in a spent fuel pool and is then transferred to a storage area

outside of the containment area.

 HB Robinson operates once-through cooli ng water systems for both Units 1 and 2. The plant also has a service water sy stem that is used to cool various equipment components for Unit 2.

 HB Robinson uses a 14% sodium hypochl orite solution for bi ofouling control of

on both Units 1 and 2. HB Robinson stated that sponge balls are also used to mechanically clean the biofouling of th e condenser tubes. The sponge balls are collected within the system and re-used. They are collected and disposed of, as

needed.

 HB Robinson stated that they usually ch lorinate the cooling water at the same time that they use the sponge balls. A dditionally, the plant stated that they chlorinate more frequently in the summe r (5 cleanings per week) than in the winter (3 cleanings per week).

 The once-through cooling water from the pl ant is transferred to the discharge canal. The discharge canal (O utfall 001) is 4.2 miles long.

 There are two intake structures at the plan t that separately serve the coal-fired and nuclear units at the plant. In Septembe r of 2009, water usage at the plant was 836 MGD on average.

Nuclear Unit Operations and Wastewaters

 HB Robinson operates a 3-loop Westi nghouse pressurized water reactor. The energy from fission of uranium dioxide fu el heats the primary reactor cooling system. The primary cooling system is pre ssurized to ensure that the coolant in the primary loop does not boil. Pressure, te mperature, and flow rate are adjusted

to enable the efficient transfer of heat from the reactor to the coolant. Typically, the temperature and pressure inside the primary loop are 574o F and 2,235 psi. The primary cooling system then transfer s heat to the secondary system which generates steam. The steam is used to ge nerate electricity and then HB Robinson

uses water from Lake Robinson to condense the steam.

 HB Robinson’s reactor cooling system and radiological liqui d waste processing system are designed to minimize the releas e of radioactive liquids to unrestricted parts of the plant.

 The liquid radiological wa stes generated at HB R obinson include wastewaters from equipment drains, chemical laboratory drains, shower drains, decontamination area drains, a nd demineralizer regeneration

. These radiological

wastewaters are transferred to one of three 25,000-gallon chemical and volume control system (CVCS) hold-up tanks.Page 3

 HB Robinson monitors the radioactivity of the liquids in the CVCS hold-up tanks and will hold liquids in the tanks for as long as possible to allow short-lived radiological isotopes to decay.

 HB Robinson transfers the liquids in the CVCS hold-up tanks to the demineralizer system for treatment.

 The demineralizer system consists of filtration and treatment by ion exchange. The ion-exchange resins consist of char coal and anion/cation resins, which are specialized to remove radionuclides. HB Robinson sends spent ion exchange resins to an off-site disposal facility.

 The effluent from the demineralizer system is sent to waste monitoring tanks. HB Robinson tests for pH, TSS, and oil and grease in the waste monitoring prior to diluting the wastewater with the plan t’s service water vi a Outfall 006. The service water is then commingled with th e plant’s once-throu gh cooling water and transferred to the discharge canal. Additionally, HB Robinson monitors the radioactivity of the treated water. If th e liquids do not meet NRC standards they

are returned to the CVCS hol d-up tanks for reprocessing.

 Liquid radiological waste is discharged in batches (approximately 8,000 gallons pre discharge). HB Robinson performs cal culations to determine the amount of

waste which can be released to the disc harge canal according to NRC regulations. HB Robinson personnel stated that the fr equency of discharges increases towards the end of each fuel cycle. For exampl e, at the beginning of the fuel cycle the plant may not discharge any radiological wastes for two or three months, but towards the end of the fuel cycle the pl ant discharges on average two batches of radiological wastes per week.

 HB Robinson stated that the reactor is refueled approximately every 18 months. The plant was last refueled in October 2008 and is scheduled to refuel again in April 2010.

 Boron is a neutron moderator and is us ed in the primary cooling system to

maintain the desired rate of fission within the reactors. As the uranium fuel starts slowly losing its reactivity, the plant be gins purging some of the boron from the system because less is needed to contro l the reaction. HB Robinson uses boric acid as the source of boron in the primar y reactor cooling system. HB Robinson stated that the initial concentration of boron in the system at the start of the fuel cycle is 1,500 to 2,000 ppm. This concentra tion approaches zero at the end of the fuel cycle. The borated water is purged fr om the reactor coolant system in a “feed and bleed” process to holdup tanks where it is held for waste processing. The water is processed through filters and demineralizers in the liquid waste processing system and is released to th e discharge canal. The wastewater from the Liquid Radwaste System contains boron. The wastewater has NPDES Permit limits for pH, TSS, and Oil & Grease. If the wastewater pH is below 6.00, it is treated (neutralized) wi th sodium hydroxidePage 4

 HB Robinson stated that approximate ly 10,000 kg of boric acid were used by plant in 2008.

Coal-Fired Unit Operations and Wastewaters

 HB Robinson receives its coal via rail. Th e coal is stored in an outdoor coal pile.

 HB Robinson keeps approximately 20 days worth of coal on s ite at the plant.

 The coal pile runoff generated from stor mwater that contacts the coal pile is collected in a settling area near the coal pile. The pl ant does not have a discharge from the coal pile runoff collection area because the soil in the area is sandy and drains easily; therefore, the coal pile runo ff either evaporates or infiltrates to the groundwater.

 HB Robinson stated that they tested th e use of SynFuel in the coal-fired unit

because there was a tax incentive associat ed with using the fuel. HB Robinson described SynFuel as recycled coal fines that are combined together using a

binder. Plant records indicate the test burn for SynFuel spanned from May 30 through July 27, 2000.

Ash Handling Operations

 HB Robinson operates a cold-side electr ostatic precipitator (ESP) on the coalfired unit to collect the fl y ash from the flue gas.

 The fly ash from the ESP is collected dr y in the hoppers and a hydroveyor system pulls a vacuum to remove the fly ash fr om the hopper. The fly ash is pulled by vacuum to the hydroveyor junction where the fly ash is mixed with the sluice water. The fly ash sluice is then sent through an air separator to remove and vent the air present in the fly ash sluice.

 HB Robinson operates a wet bottom ash handling system.

 The bottom ash sluice and the fly ash sluice waters are combined together and pumped to the plant’s ash pond.

 HB Robinson stated that they usually sluice the fly ash and the bottom ash once per shift. The combined ash sluice flow rate is approximately 2 MGD.

Ash Pond

 The ash pond at HB Robinson receives fl y ash sluice, bottom ash sluice, metal cleaning wastes associated with only the co al-fired unit (internal Outfall 007) and stormwater from the Darlington County in ternal combustion turbines area of the plant.

 The ash pond has a footprint of approximately 55 acres.Page 5

 HB Robinson stated that the ash pond was designed to maintain a minimum embankment freeboard capable of prev enting overflow during a 50 year, 24-hour

storm of 7.5 inches of rain with normal pool at elevation 269.5 feet.

 The height of the pond embankment has been increased th ree times (in 1982, 1992, and 2003). The current height of th e pond embankment is approximately 31

feet.

 The ash pond has an outfall pipe (internal Outfall 005) into the discharge canal. However, the plant does not typically discharge from the ash pond. The last time the plant discharged from the ash pond was February 2002.

 HB Robinson stated that the pond is not lined and that the soil below the pond is sandy and drains easily.

 Portions of the ash pond are completely fill ed with ash and the ash appears to be completely dried out. HB Robinson operates a sprinkler system on the pond for dust control. The sprinkler system is used 2-3 times per week on average.

 HB Robinson has three groundwater m onitoring wells around the ash pond. The groundwater wells were placed in order to monitor the groundwater as it migrates away from the pond and towards Lake Robinson. Additionally, there is a “control” monitoring well locat ed on the west side of the ash pond. There is also a monitoring well located n ear the retention basin.

 HB Robinson is required to monitor th e groundwater semi-annually at all four of its wells. HB Robinson monitors for the following parameters: water level, turbidity, acid digestion (liquids), arsenic, zinc, sulfate, specific conductance, total dissolved solids, cadmium, chromium, copper, and pH. The two most recent groundwater monitoring reports are included as Attachments 2 and 3.

Furnace Sorbent Injection System and Dry Fly Ash System

 HB Robinson does not operate a FGD system for sulfur dioxid e control; however, the plant did install and operate a fu rnace sorbent injection (FSI) system temporarily in 2008 to test the tec hnology. Commissioning and Equipment Testing Performance testing began in July 2008 and consisted of equipment shakedown testing in July and August, pa rametric testing in September and final long term operational testing Octobe r through December 2008. The FSI system consists of injecting lime into the boiler to control sulfur dioxide emissions. The final report summarizing the FSI project at HB Robinson is provided in Attachment 4 and a report evaluati ng the FSI technology is provided in

Attachment 5.

 As part of the study, HB Robinson instal led a dry fly ash handling system to capture the fly ash and tran sport it to a storage silo.

 The dry fly ash handling system uses vacuum pumps that were installed that pull a vacuum on the ESP hoppers and pull the fl y ash to the transfer hoppers. ThesePage 6

transfer hoppers are needed to move from a vacuum system to a pressure blower system. From the transfer hoppers, the fly ash falls by gravity to another hopper where the blowers push the fly ash approxi mately 1,500 feet to the fly ash storage silo. The exhaust gas from the transfer hoppers is vented to the atmosphere, but first passes through baghouse filters to rem ove particulates from the vented gas.

 The fly ash storage silo has enough capacity to store approximately five days worth of ash when operating at full load. The plant has the capability to load open trucks with fly ash. Additionally, they have the capability to add water to condition the fly ash. The plant uses county water to condition the fly ash. HB Robinson does not have the capability to load closed trucks with fly ash, but it can

unload bulk transfer trailers.

 HB Robinson stated that the FSI system was installed only for the purposes of testing the technology; however, the plant is still consideri ng the technology for full time operation. HB Robinson stated th at they are also considering several other technologies for sulfur dioxide c ontrols. Additionally, HB Robinson is considering operating the dry fly ash ha ndling system full time. However, because the plant does not currently have a contract set up to market the fly ash and the plant does not have a landfill on s ite to dispose of the fly ash, they will continue to use the wet fly ash handling system.

 HB Robinson stated that the installati on of the FSI system did not require any major modifications to the exis ting wet fly ash handling system.

 The major pieces of equipment included in the FSI/dry ash handling system are: three lime storage silos, lime injection nozzles, two vacuum pumps, two blowers, two transfer hoppers, 1,500 f eet of high-pressure pipi ng, and one fly ash storage silo. Actual cost for equipment and instal lation of the equipment for the FSI trial was $17,259,000.00. Dry fly ash handling equipment, installation of equipment

and road construction for trucks to enter and exit the property totaled $7,668,291.00.

 HB Robinson stated that the FSI system reduces the efficiency of the boiler. Boiler efficiency was calculated during the FSI trial. Because of the addition of additional air into the boiler, the ex it oxygen increased resulting in a boiler efficiency reduction. The results show bo iler efficiency linearly decreases with the increase of exit oxygen over the load range. For the same load tests, the boiler efficiency dropped about 0.1% to 0.8% during sorbent injection.Page 7

NPDES Outfalls

 Outfalls 008 and 009 are internal outfalls for the plants east and west retention basins, respectively. The east retention ba sin receives the yard drain stormwater from the coal-fired unit (Un it 1) and the west retention basin receives the yard drain stormwater from the nuclear unit (U nit 2). Both basins store approximately 800,000 gallons.

 The effluents from the two retention ba sins (Outfalls 008 and 009) are combined and transferred to the discharge canal. Th e pH of the retention basins is typically between 4.5 and 5.2 S.U.; therefore, the plant has an automated neutralization system which controls the pH by adding sodium hydroxide prior to water entering the discharge canal.

 The retention basins do not have a synt hetic material lini ng. The basins were constructed for retention, settling of st orm water runoff and minor flow from plant systems. The basins were designed with rip-rap along the side walls. The basins have an overflow weir with a skimmer baffle to prevent release of floating solids and rope-type oil and grease skimmers.

 Outfall 011 is the discharge from a ditch that flows into Black Creek. The discharge consists of stor mwater runoff from the park ing lots and administration buildings.

 Outfall 013 discharges steam generato r blowdown. HB Robinson operates three steam generators. The blowdown rate is approximately 25-50 gpm per generator, which is approximately one percent of the water volume in the steam cycle.

 Outfall 014 is the discharge from the di scharge canal to Lake Robinson and the

outfall is located at the head of the discharge canal.

 The on-site sanitary treatment plant discha rges to the discharge canal via Outfall 003. Sludge from the sanitary plant is sent off site by a waste disposal company.

Metal Cleaning

 Metal cleaning of the nuclear unit’s steam generators consists of adding chemicals to the steam generators to maintain a pH of 9.8 to 10.1. HB Robinson adds ETA (ethanolamine) and hydrazine to incr ease the alkalinity within the steam generators and prevent corrosion.

 Adding alkalinizing chemicals generates sl udge piles in the h eat exchanger tubes within the steam generator. During plan t outages, contract ors perform sludge lancing to remove the accumulated sludge. Sludge lancing consists of using a high pressure water wash to remove sludge deposits. HB Robinson stores the wastewater from sludge lancing (which in cludes the sludge and the water used in lancing) in frac tanks. A waste disposal vendor ships the wastewater off site. HB Robinson stated that they must prove to the vendor that the waste is nonhazardous.Page 8

 HB Robinson performs metal cleaning ope rations on the coal-f ired unit’s boiler tubes by adding several chemicals, including citric acid or EDTA.

 Metal cleaning on the coal-f ired unit cooling system is performed every 7-10 years and generates approximately 58,000 ga llons of wastewater. The last two metal cleaning operations occurred in 1998 and 2007. In both cases, the metal cleaning wastes were sent to the ash pond.

 In 2007, the metal cleaning operation ge nerated wastes that contained 1,520 pounds of iron, 239 pounds of copper, and 2,110 pounds of iron oxide.

 HB Robinson does not perform washes on the fire side of the boiler.Page 9Table 2. Site Visit AttendeesNameOrganization (Representing)TelephoneE-mailKen KirklandH.B. Robinson(843) 857-1231kenneth.kirkland@pgnmail.comWillie GilbertH.B. Robinson(843) 857-1371willie.gilbert@pgnmail.comGarrett SandersH.B. Robinson(843) 857-1427garrett.sanders@pgnmail.comKen HatchellH.B. Robinson(843) 857-1613ken.hatchell@pgnmail.comAndy ColeH.B. Robinson(843) 857-5291andy.cole@pgnmail.comFred HoltProgress Energy(919) 546-5286fred.holt@pgnmail.comRobin BrysonProgress Energy (919) 546-3962robin.bryson@pgnmail.comDonna HillUWAG(205) 257-5234 dbhill@southernco.comJosh Hall EPA/Office of Water (202) 566-1003 hall.josh@epa.govJezebele Alicea EPA/Office of Water(202) 566-1755 alicea.jezebele@epa.govTJ Finseth ERG (Contractorto EPA) (703) 633-1698 thomas.finseth@erg.comKurt Blohm ERG (Contractor to EPA)(703) 633-1675 kurtis.blohm@erg.com