Draft 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 Energy ’s H.B. Robinson Steam Electric Plant (HB Robinson) located in Hartsville, SC on Wednesday, October 21, 2009 to learn about the operations at the plant , specifically the operations and wastewaters generated by the nuclear electric generating unit and the ash handling system associated with the coal

- fired electric generating unit

. Table 2, located at the end of this memorandum , identifies the site visit participants. An overall water balance diagram for 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 wa s held on October 14, 2009.

Plant Overview

**•** HB Robinson operates one coal

- fired unit (Unit 1) and one nuclear 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

1 Control

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 also constructed Lake Robinson, a 1,200

- acre lake (2,250) , for the unit. The lake is used as a cooling pond for the once

through cooling water.

**•** Carolina Power & Light initially had plans to build three additional coal

- fired units, but in the late 1960s nuclear energy 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. T hese turbines are operated as swing units to provide stability to the grid and the nuclear unit. [QUESTION FOR HBPage 2

ROBINSON: Are the internal combustion turbines owned by Progress Energy?] YES

**•** HB Robinson stated that they have dry fuel 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 cooling water systems for both Units 1 and 2. The plant also has a service wat er system that is used to cool various equipment components for Unit 2.

**•** HB Robinson uses a 14% sodium hypochlorite solution for biofouling control of on both Units 1 and 2. HB Robinson stated that sponge balls are also used to mechanically clean the biof ouling of the condenser tubes. [QUESTION FOR HB ROBINSON: What ultimately happens to the sponge balls?] 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 chlo rinate the cooling water at the same time that they use the sponge balls. Additionally, the plant stated that they chlorinate more frequently in the summer (5 cleanings per week) than in the winter (3 cleanings per week).

**•** The once

- through cooling water from the plant is transferred to the discharge canal. The discharge canal (Outfall 001) is 4.2 miles long.

**•** There are two intake structures at the plant that separately serve the coal

- fired and nuclear units at the plant. In September of 2009, water usage at the plant was 836 MGD on average.

Nuclear Unit Operations and Wastewaters

**•** HB Robinson operates a 3

- loop Westinghouse pressurized water reactor. The energy from fission of uranium dioxide fuel heats the primary reactor cooling system. The primary coo ling system is pressurized to ensure that the coolant in the primary loop does not boil. Pressure, temperature, and flow rate are adjusted to enable the efficient transfer of heat from the reactor to the coolant. Typically, the temperature and pressure ins ide the primary loop are 574o F and 2,235 psi. The primary cooling system then transfers heat to the secondary system which generates steam. The steam is used to generate electricity and then HB Robinson uses water from Lake Robinson to condense the steam.

**•** HB Robinson’s reactor cooling system and radiological liquid waste processing system are designed to minimize the release of radioactive liquids to unrestricted parts of the plant.

**•** The liquid radiological wastes generated at HB Robinson include wastewat ers from equipment drains, chemical laboratory drains, shower drains, decontamination area drains, and demineralizer regeneration

. These radiologicalPage 3

wastewaters a re transferred to one of three 25,000

- gallon chemical and volume control system (CVCS) hold

- u p tanks.

**•** 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 charcoal 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 plant’s service water via Outfall 006. The service water is then commingled with the plant’s once

- through cooling water and transferred to the discharge canal. Additionally, HB Robinson monitors the radioactivity of the treated water. If the liquids do not meet NRC standards they are returned to the CVCS hold

- up tanks for reprocessing.

**•** Liquid radiological waste is discharged in batches (approximately 8,000 gallons pre discharge). HB Robinson performs calculations to determine the amou nt of waste which can be released to the discharge canal according to NRC regulations. HB Robinson personnel stated that the frequency of discharges increases towards the end of each fuel cycle. For example, at the beginning of the fuel cycle the plant m ay not discharge any radiological wastes for two or three months, but towards the end of the fuel cycle the plant may need to discharge radiological wastes every XX days/weeks

. [QUESTION FOR HB ROBINSON: How frequent is the discharge towards the end of th e fuel cycle?] An average of two batches/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 used 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 begins purging some of the boron from the system because less is needed to control the react ion. HB Robinson uses boric acid as the source of boron in the primary reactor cooling system. HB Robinson stated that the initial concentration of boron in the system at the start of the fuel cycle is 15,000

- 16,000 ppm (1,500 to 2000)

. This concentration approaches zero at the end of the fuel cycle. [QUESTION FOR HB ROBINSON: Please describe how the boron is purged from the system? Which wastewaters generated at the plant contain boron? How are these wastewaters treated?]Page 4

The borated water is purged from 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 the di scharge 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) with sodium hydroxide.

**•** HB Robinson s tated that approximately 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. The coal is stored in an outdoor coal pile.

**•** HB Robinson keeps approximately 20 days worth of coal on site at the plant.

**•** The coal pile runoff generated from stormwater that contacts the coal pile is collected in a settling area near the coal pile. The plant 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 runoff either evaporates or infiltrates to the groundwater.

**•** HB Robinson stated that they tested the use of SynFuel in the coal

- fired unit because there was a tax incentive associated with usin g the fuel. HB Robinson described SynFuel as recycled coal fines that are combined together using a binder. [QUESTION FOR HB ROBINSON: When did the plant test the SynFuel and for how long?] Plant records indicate the test burn for synfuel spanned from Ma y 30 through July 27, 2000.

Ash Handling Operations

**•** HB Robinson operates a cold

- side electrostatic precipitator (ESP) on the coal

fired unit to collect the fly ash from the flue gas.

**•** The fly ash from the ESP is collected dry in the hoppers and a hydrov eyor system pulls a vacuum to remove the fly ash from 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.Page 5

**•** 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 fly ash sluice, bottom ash sluice, metal cleaning wastes associated with the coal

- fired unit (internal Outfall 007) and stormwater from the Darlington County internal combustion turbines area of the plant. [QUESTION FOR HB ROBINSON: Are the metal cleaning wastes associated with the coal

- fired unit only or both coal

- fired and nuclear units?] Coal fired unit only.

**•** The ash pond has a footprint of approximately 55 acres.

**•** HB Robinson stated that the ash pond was designed to maintain a minimum embankment freeboard capable of preventing overflow during a 50

- year storm
event. [QUESTION FOR HB ROBINSON : What is the freeboard design basis for the pond (e.g., 50

- year storm)? ] 50 year, 24

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

**•**

**•** The height of the pond embankment has been increased three times (in 1982, 1992, and 2003). The current height of the 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. [QUESTION FOR HB ROBINSON: When was the last time the pla nt discharged from the ash pond?] 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 filled 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 monitoring wells around the ash pond. The groundwater wells were placed in order to m onitor the groundwater as it migrates away from the pond and towards Lake Robinson. Additionally, there is a “control” monitoring well located on the west side of the ash pond. There is also a monitoring well located near the retention basin.

**•** HB Robins on is required to monitor the 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, cad mium, chromium, copper, and pH. The two most recent groundwater monitoring reports are included as Attachments 2 and 3 of this memorandum.Page 6

Furnace Sorbent Injection System and Dry Fly Ash System

**•** HB Robinson does not operate a FGD system for sulfur diox ide control; however, the plant did install and operate a furnace sorbent injection (FSI) system temporarily in 2008 to test the technology. [QUESTION FOR HB ROBINSON: When and how long did the FSI system operate at the plant?] Commissioning and Equipment Testing Performance testing began in July 2008 and consisted of equipment shakedown testing in July and August, parametric testing in September and final long term operational testing October through December 2008. The FSI system consists of injecting li me into the boiler to control sulfur dioxide emissions. [NOTE TO HB ROBINSON: Please provide a copy of all FSI engineering reports and/or summary reports .] Two reports are p rovided as an attachment to this document.

**•** As part of the study, HB Robinson ins talled a dry fly ash handling system to capture the fly ash and transport 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 fly ash to the transfer hoppers. These 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 approximately 1,500 feet to the fly ash storage silo. [QUESTION FOR HB ROBINSON: In the transfer hoppers, how are the particles collected prior to falling into the hoppers below? Baghouse filters? What happens to the exhaust gas?] Baghouse filters; vented to atmosphere.

**•**

**•** 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 fl y ash. HB Robinson does not have the capability to load closed trucks with fly ash. [QUESTION FOR HB ROBINSON: What is the source of water used to condition the fly ash?] Can unload bulk transfer trailers. County
water.

**•**

**•** HB Robinson stated that the FSI system was installed only for the purposes of testing the technology; however, the plant is still considering the technology for full time operation. HB Robinson stated that they are also considering several other technologies for sulfur dioxide controls. Additionally, HB Robinson is considering operating the dry fly ash handling 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 site to dispose of the fly ash, they will continue to use the wet fly ash handling system.

**•** HB Robinson stated that the installation of the FSI system did not require any major modifications to the existing wet fly ash handling system.Page 7

**•** The major pieces of equipment included in th e FSI/dry ash handling system are: three lime storage silos, lime injection nozzles, two vacuum pumps, two blowers, two transfer hoppers, 1,500 feet of high

- pressure piping, and one fly ash storage silo. [QUESTION FOR HB ROBINSON: What was the cost for ins talling the FSI injection equipment? Actual cost for equipment and installation of the equipment for the FSI trial was $17, 259,000.00. Additionally, what was the cost of installing the dry fly ash handling equipment?] Dry fly ash handling equipment, in stallation 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. [QUESTION FOR HB ROBINSON: How much does the FSI system reduce the efficiency of the boiler?] Boiler efficiency was calculated during the FSI trial. Because of the addition of additional air into the boiler, the exit oxygen increased resulting in a boiler efficiency reduction. The results show boiler efficiency linear ly 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.

NPDES Outfalls

**•** Outfalls 008 and 009 are internal outfalls for the plants east and west retention basins, respectively. The east retention basin receives the yard drain stormwater from the coal

- fired unit (Unit 1) and the west retention basin receives the yard drain stor mwater from the nuclear unit (Unit 2). Both basins store approximately 800,000 gallons.

**•** The effluents from the two retention basins (Outfalls 008 and 009) are combined and transferred to the discharge canal. The pH of the retention basins is typically b etween 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 synthetic material lining. [QUESTION FOR HB ROBINSON: Please describe the design and any linings of the retention basins. ]Page 8

The basins were constructed for retention, settling of storm water runoff and minor flow from pl ant 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 tha t flows into Black Creek. The discharge consists of stormwater runoff from the parking lots and administration buildings.

**•** Outfall 013 discharges steam generator blowdown. HB Robinson operates three steam generators. The blowdown rate is approximately 2 5

- 50 gpm per generator, which is approximately one percent of the water volume in the steam cycle.

**•** Outfall 014 is the discharge from the discharge canal to Lake Robinson and the outfall is located at the head of the discharge canal.

**•** The on

- site sanitary treatment plant discharges 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 increase the alkalinity within the steam generators and prevent corrosion.

**•** Adding alkalinizing chemicals generates sludge piles in the heat exchanger tubes within the steam generator. During plant outages, contractors 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
wastew ater from sludge lancing (which includes 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 non

hazardous.

**•** HB Robinson per forms metal cleaning operations on the coal

- fired unit’s boiler tubes by adding several chemicals, including citric acid or EDTA.

**•** Metal cleaning on the coal

- fired unit cooling system is performed every 7

- 10 years and generates approximately 58,000 gallon s 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 generated wastes that contained 1,520 ponds 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 9

Table 2 . Site Visit Attendees

Name Organization (Representing) Telephone E

- mail

Ken Kirkland H.B. Robinson (843) 857

- 1231 kenneth.kirkland@pgnmail.com

Will ie Gilbert H.B. Robinson (843) 857

- 1371 willie.gilbert@pgnmail.com

Garrett Sanders H.B. Robinson (843) 857

- 1427 garrett.sanders@pgnmail.com

Ken Hatchel l H.B. Robinson (843) 857

- 1613 ken.hatchell@pgnmail.com
Andy C ol e H.B. Robinson (843) 857

- 5291 andy.cole@pgnmail.com

Fred Holt Progress Energy (919) 546

- 5286 fred.holt@pgnmail.com
Robin Bryson Progress Energy (919) 546

- 3962 robin.bryson@pgnmail.com

Donna Hill UWAG (205) 257

- 5234 dbhill@southernco.com

Josh Hall EPA/Office of Water (202) 566

- 1003 hall.josh@epa.gov

Jezebele Alicea EPA/Office of Water (202) 566

- 1755 alicea.jezebele@epa.gov

TJ Finseth ERG (Contractor to EPA) (703) 633

- 1698 thomas.finseth@erg.com

Kurt Blohm ERG (Contractor to EPA) (703) 633

- 1675 kurtis.blohm@erg.com

[NOTE TO HB ROBINSON: Please provide contact information for all personnel for which information is missing.]