NC0007064_Comments on Draft Permit_20180316

t DUKE Brunswick Nuclear Plant
P o Box 10429
ENERGY® Southport,NC 28461
MAR 1 6 2018
Serial: BSEP 18-0037
Mr. Bing Bai, Engineer
NPDES Complex Permitting Unit RECEIVED/pENR/pWR
NC DEQ Division of Water Resources
1617 Mail Service Center MAR 2 2 2015
Raleigh, North Carolina 27699-1617 Water Resources
Permitting Section
Subject: Brunswick Steam Electric Plant, Unit Nos. 1 and 2
Comments Regarding Draft NPDES Permit No. NC0007064
Brunswick County
Dear Mr. Bai:
In accordance with your letter dated February 20, 2018, Duke Energy staff have reviewed the
proposed draft permit and the accompanying Fact Sheet and offer the following comments in
response to your bulleted draft permit proposals:
Draft Permit Proposal:
• Flow limits for Outfall 010 has been increased from 0 036 MGD to 0.150 MGD to
accommodate consolidation of the two existing sanitary plants into one new larger
sanitary plant as requested by the Permittee [See A. (6)].
Comment:
Duke Energy agrees with this approach.
Draft Permit Proposal:
• Special Condition A.(9) 316 (b) Requirements has been revised. Additionally,
language for Fine Mesh Screens Condition has been moved from A.(1) Effluent
Limitations and Monitoring Requirements (Outfall 001) to Special Condition
A.(9).
Comment:
Duke Energy agrees with this approach.
Draft Permit Proposal:
• Special Condition A.(10) Biocides has been added to the permit. Please review it
carefully.
Comment:

NPDES Complex Permitting Unit
Page 2 of 5
Duke Energy agrees with this approach.
Draft Permit Proposal:
• Special Condition A.(11) Chemical Metal Cleaning Wastes has been added to the
permit. Please review it carefully.
Comment:
Duke Energy agrees with this approach.
Draft Permit Proposal:
• Special Condition A.(12) Combined Waste Streams has been added to the
permit. Please review it carefully.
Comment:
Duke Energy agrees with this approach.
Draft Permit Proposal:
• Special Condition A.(13) Federal Insecticide, Fungicide, and Rodenticide Act
has been added to the permit. Please review it carefully.
Comment:
Duke Energy agrees with this approach.
Draft Permit Proposal:
• Special Condition A.(14) Polychlorinated Biphenyl Compounds has been added to
the permit, accordingly the language for polychlorinated biphenyl compounds in
Section A.(1) Effluent Limitations and Monitoring Requirements (Outfall 001) has
been removed.
Comments:
Duke Energy agrees with this approach.
Draft Permit Proposal:
• One effluent sample reported for mercury was less than detection, at a detection
level of less than 0.2 µg/L. In accordance with the implementation of 2012
Statewide Mercury TMDL, future sampling for mercury should employ EPA method
1631E and analyze mercury down to the lower reporting level of 1 ng/L. No limits or
additional monitoring requirements for mercury were added to the permit at this time.
Comment:
Duke Energy agrees with this approach.
Draft Permit Proposal:

NPDES Complex Permitting Unit
Page 3 of 5
• Federal regulations require electronic submittal of all discharge monitoring reports
(DMRs)and program reports. The requirement to continue reporting discharge
monitoring data electronically using the NC DWR's Electronic Discharge Monitoring.
Report (eDMR) internet application has been updated in the permit. [See Special
Condition A. (16)].
Comment:
Duke Energy agrees with this approach.
Draft Permit Proposal:
• Regulatory citations have been added to the permit.
Comment:
Duke Energy agrees with this approach.
As a result of our review, Duke Energy also provides the following comments:
1. Outfall 001 [Part I(A)(1)] has been clarified to address the various permitting flow regimes as
requested. This approach will eliminate confusion associated with the complexity of cooling
water discharges.
Include in section A.(1) the following as in the previous issued permit:
FINE MESH SCREENS - Continue to operate the plant with 42 fine mesh screen panels for
each of the 4 Circulating Water Intake Pumps (CWIPs) for each unit and eight (8) coarse
mesh screen panels for each of the 4 CWIPs for each unit for a total of 50 screens for each
CWIP per unit.
If the CWIPs are in jeopardy of tripping as a result of high differential pressure across the
traveling screens, the fine mesh screens may be temporarily removed to prevent or mitigate
unplanned decreases in power or plant trips. The fine mesh screens will be reinstalled
when conditions permit the CWIPs to sustain continuous operation. Should flow through a
traveling screen with more than eight (8) coarse mesh panels be necessary for any reason
the Permittee shall provide explanation in the monthly report stating the cause(s), duration
and corrective action(s) taken by the plant.
2. While reviewing the Fact Sheet and effluent limitations for Internal Outfall 005 [Part I(A)(4)],
it was noted the daily maximum discharge limitation for Total Suspended Solids was
decreased from 100.0 mg/I in the previous NPDES Permit to 45.0 mg/I in the draft permit
and the daily maximum discharge limitation for Oil and Grease was increased from 20.0 mg/I
in the previous NPDES Permit to 45.0 mg/I in the draft permit. 40 CFR 423.12(b)(3) has
these daily maximums as 100.0 mg/I for Total Suspended Solids and 20.0 mg/I for Oil and
Grease. The Fact Sheet is correct. The draft permit should reflect the daily maximum limits
as prescribed by 40 CFR 423.12(b)(3) and consistent with the previous NPDES Permit.
The narrative description of Internal Outfall 005 has a qualifier"(if installed)"for cooling
tower blowdown. This cooling tower blowdown has been install as part of Internal Outfall
005 so the qualifier"(if installed)" can be removed from the narrative description.

NPDES Complex Permitting Unit
Page 4 of 5
3. While reviewing the Fact Sheet and effluent limitations for Internal Outfall 006 [Part I(A)(5)],
it was noted the daily maximum discharge limitation for Oil and Grease was increased from
20.0 mg/I in the previous NPDES Permit to 30.0 mg/I in the draft permit. 40 CFR
423.12(b)(5) has this daily maximum as 20.0 mg/I for Oil and Grease. The Fact Sheet is
correct. The draft permit should reflect the daily maximum limits as prescribed by 40 CFR
423.12(b)(5) and consistent with the previous NPDES Permit.
4. The Support Facilities Wastewater Treatment Plant is currently under construction and
should be operational by the end of 2018 or early 2019. The monthly average flow increase
from 0.036 to 0.150 mgd and associated effluent limitations for sanitary plant (Internal
Outfall 010) [Part I(A)(6)] are acceptable.
In accordance with Part III Section D— Facility Closure Requirements, Duke Energy will
provide, at the required ninety (90) days, notification of the deactivation of the Onsite
Wastewater Treatment Plant associated with Internal Outfall 004 [Part I(A)(3)].
5. Internal Outfall 011 [Part I(A)(7)], narrative description has a qualifier"(if installed)" for
cooling tower blowdown. This cooling tower blowdown has been install as part of Internal
Outfall 005 so the qualifier"(if installed)" can be removed from the narrative description.
6. Internal Outfall 012 [Part I(A)(8)], Notes section starts with No.#2. This note should be
corrected to be "No. 1" unless there is a missing note. If there is a missing note, Duke
Energy request the opportunity to review and provide comment.
7. [Part I(A)(15)] — Radioactive Material —condition incorrectly references "McGuire Nuclear
Station" and should be corrected to read `Brunswick Steam Electric Plant".
If you have any questions or wish to discuss this matter further, contact Mr. Marty McGowan,
Brunswick Steam Electric Plant Environmental Coordinator, at 910-832-2538.
I certify, under penalty of law, that this document and all attachments were prepared under my
direct supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based upon 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,
//y/ -Iwo"
Karl Moser
Plant Manager
Brunswick Steam Electric Plant

NPDES Complex Permitting Unit
Page 5 of 5
cc: Mr. Jim Gregson, NC DEQ DWR Wilmington Regional Office
Mr. Marty McGowan, Site Environmental Coordinator, Brunswick Steam Electric Plant
Mr. Don Safrit, Senior Environmental Specialist, Permitting and Compliance, Carolinas