NC0039586_Outfall 0006_20191115

(•, DUKE Tanya M. Hamilton
Vice President
ENERGY. Harris Nuclear Plant
�( 5413 Shearon Harris Rd
New Hill, NC 27562-9300
NOV 152019
Serial: RA-19-0430 31ECEDWIE —;\
Certified Mail Number: 7014 2120 0003 3196 5893 NOV 1 9 2019
Return Receipt Requested
Ms. Linda Culpepper, Director DIVISION OF WATER RESOURCES
NC DEQ Division of Water Resources __, D!Rr C oR S OFFICE_
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Duke Energy Progress, LLC - Shearon Harris Nuclear Power Plant (HNP)
NPDES Permit No. NC0039586
Part I (A)(9) - Schedule of Compliance (Outfall 006), Wake County
Dear Ms. Culpepper:
On August 29, 2016, NC DEQ DWR issued NPDES Permit NC0039586 with an effective date
of September 1, 2016. Contained within this permit were new effluent limit requirements for
Copper and Zinc for Outfall 006 (Combined Outfall for Internal Outfalls 001-005) serving HNP.
Part I (A)(9) of the permit requires Duke Energy Progress, LLC (Duke Energy), submit to the
Division of Water Resources (DWR) a Corrective Action Plan (CAP) which summarizes the
actions to be taken to achieve the total copper and total zinc limits at Outfall 006 and a
schedule of actions to be taken to implement the Plan. The CAP was submitted to the DWR on
September 1, 2017. Duke Energy is proceeding with the strategy recommended in the CAP.
Duke Energy is proceeding with a strategy to achieve compliance by determining site-specific
water quality criteria. A Water Effects Ratio (WER) study for both copper and zinc for HNP
Outfall 006 was performed and results were submitted to DWR on May 9, 2019. This Method 1
WER study was conducted using 100 percent effluent and Duke Energy then conservatively
used the lowest of the three tests in its recommendation to DWR. DWR sent a response letter
on July 10, 2019 requesting that dilution be taken into consideration when determining the
WER. DWR also requested in the letter that the WER study be performed again with the
fathead minnow used as the primary organism.
Duke Energy believes the May 2019 submittal of WER results, using the lowest WER of the
three tests using 100 percent effluent, was a conservative recommendation protective of water
quality in Harris Lake. Although Duke Energy interprets the application of Appendix F of EPA's
1994 Interim Guidance differently, for the sake of moving forward while still preserving our right
to further discuss such differences of opinion, Duke Energy is submitting work plans for a
mixing zone evaluation using a dilution model, CORMIX, and a workplan for a WER using
fathead minnow as the primary species. This dilution analysis will be conducted first, and the
results presented to DWR so that we can reach agreement on the appropriate dilutions for
further WER testing, if necessary.

Division of Water Resources
Serial: RA-19-0430 / Page 12
While we are submitting work plans for both a mixing zone evaluation and additional WER
testing using fathead minnows as the primary species, we believe DWR is misapplying some
aspects of EPA's 1994 Interim Guidance. One is the decision to use fathead minnows as the
primary test species for WER testing. The guidance indicates on page 21 —"The primary
toxicity test used in the determination of a WER should have an endpoint in laboratory dilution
water that is close to, but not lower than, the CMC and/or CCC to which the WER is to be
applied." The acute end point for Ceriodaphnia in laboratory water for our three tests ranged
from 48-hour LC50 values for dissolved copper of 9.4 ug/L to 21.1 ug/L at a hardness of 50
mg/L. The 48-hour LC50 value for fathead minnows in our secondary test was a dissolved
copper of 157.9 ug/L. The CMC endpoint from the equations in the standards rules for the
hardness of the toxicity tests (-50 mg/L) ranged from 7.5 to 8.0 depending on the effluent
hardness. Therefore, the end point for Ceriodaphnia"is close to, but not lower than, the CMC" —
where the same cannot be said for fathead minnows. There are also other references in the
guidance indicating that the primary species should be an appropriate sensitive species.
As discussed at the June meeting between Duke Energy, our consultants, and DWR, the 1994
Interim Guidance is a very difficult document to interpret. Most people involved with the
guidance at both state levels and EPA have retired. To that end, Duke Energy has added to our
consulting team Charles Delos, Senior Research Scientist at the Great Lakes Environmental
Center, Inc. (GLEC). Prior to joining GLEC in 2014, Mr. Delos worked for EPA in the water
program for 45 years and was extensively involved with various copper criteria documents and
development and applications of the 1994 Interim Guidance. Mr. Delos will be available to
discuss historical aspects of the WER and/or copper criteria with NC DEQ DWR staff and will
be providing valuable input to our path forward.
As indicated above, additional WER testing is dependent on completion of the dilution
modeling. We will be preparing a report of the mixing zone analysis and make
recommendations for the specific use of these results in calculating potential effluent limits and
for selecting dilutions for subsequent WER testing. If you have any questions regarding this
matter or wish to discuss in further detail via a conference call or in-person meeting, please do
not hesitate to contact Mr. Bob Wilson, HNP Site Environmental Professional, at (919) 362-
2444 or Mr. Don Safrit, Senior Environmental Specialist, at [phone].
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. I am aware that there are significant penalties for submitting false
information, including the possibility of fines and imprisonment for knowing violations.
Sincerely,
diATt /14Q1/11`----
Tanya M. Hamilton

Division of Water Resources
Serial: RA-19-0430 / Page 13
Enclosures:
STUDY PLAN: Water Effect Ratio - Site Specific Study (wi Pimephales promelas as
Primary Species) Duke Energy - Shearon Harris Nuclear Station
Mixing Zone Study Work Plan
cc: Ms. Julie Grzyb, Supervisor, NPDES Complex Permitting Supervisor,
Certified Mail Number: 7014 2120 0003 3196 5916
Return Receipt Requested
Mr. Rick Bolich, Interim Water Resources Regional Supervisor,
NC DEQ DWR Raleigh Regional Office
Certified Mail Number: 7014 2120 0003 3196 5923
Return Receipt Requested
Ms. Cyndi Karoly, Chief, Water Sciences Section, NC DEQ DWR
Certified Mail Number: 7014 2120 0003 3196 5909
Return Receipt Requested
NC DEQ DWR Central Files
Certified Mail Number: 7014 2120 0003 3196 5824
Return Receipt Requested

Division of Water Resources
Serial: RA-19-0430
Enclosure 2
Harris Nuclear Plant and Harris Energy and Environmental Center
NPDES Permit Number NC0039586
STUDY PLAN
Water Effect Ratio - Site Specific Study (w/ Pimephales promelas as Primary Species)
Duke Energy - Shearon Harris Nuclear Station
(5 pages including cover)
new

EJmjc. [phone] . FAX[phone]
P.O. Box 16414, Greenville, SC 29606 4 Craftsman Court, Greer, SC 29650
STUDY PLAN
Water Effect Ratio-Site Specific Study (wi Pimephales promelas as Primary Species)
Duke Energy-Shearon Harris Nuclear Station
It is proposed that a Site Specific Study be conducted as a Water Effect Ratio per the EPA document Interim
Guidance on Determination and Use of Water-Effect Ratios for Metals (1994). The study will be
conducted by ETT Environmental, Inc. of Greenville, SC. The Scope of Work to be used is as delineated
below.
The full WER procedure involves three rounds of parallel testing with the primary species and a round of
testing with the secondary species. The primary species will be the Fathead Minnow (Pimephales
promelas)and the secondary species will be the daphnid Ceriodaphnia dubia.
Each round of testing will be conducted with simulated lake water prepared at the
proportion of lake water versus effluent flow using results of the dilution model evaluation. The amount
of lake water used for dilutions will be based on dilution model studies as agreed upon
by NC DEQ personnel. Effluent flow will be obtained from the Shearon Harris Nuclear Station.
The second and third rounds of testing will be conducted at least three weeks after the previous round
of testing. Based on guidance, two of the three rounds will be conducted using low dilutions (Type
I) conditions and one test using higher dilution (Type II) conditions. As indicated above, dilutions
for Type I and Type II conditions will be based on dilution modeling results as agreed upon by NC
DEQ. The testing for the secondary species, Ceriodaphnia dubia, will be conducted under Type II
conditions so that results could be utilized with previously conducted WER studies. Thus, the
timing of the sampling and testing may have to be adjusted based upon flow conditions.
Grab samples of upstream lake water will be collected from the intake point, for use in the WER testing.
The lake water will be refrigerated during a maximum 14 day holding period. Aliquots of lake water
will be set aside for analysis of TOC,Conductivity,Alkalinity, Hardness,TSS,and total and dissolved
copper. Effluent samples will be collected at the time of lake water collection and these will be

sampled by Shearon Harris Nuclear Station personnel and provided to ETT. ETT will need
station personnel to provide flow data for the effluent discharge for the day when the first effluent
sample is collected.
For each round of testing lake water and effluent will be mixed to match the results of the
dilution model evaluation. As indicated above, dilutions will be based on dilution modeling results as
agreed upon by NC DEQ.
Laboratory water will be prepared by adding mineral water (Perrier) to ultra-pure (Type I) water in
sufficient volume to achieve the desired hardness (50 mg/L as CaCO3 - as specified by SCDHEC).
Laboratory water will be maintained a maximum of two weeks. Aliquots of laboratory water will be
set aside for analysis of TOC,Alkalinity,Hardness,TSS, and total and dissolved copper.
Once simulated water based on the dilution study is ready for use, six or more aliquots of the
simulated water will be prepared. A stock solution of copper (typically 50 mg/L of the metal salt) will be
prepared by adding the metal salt to deionized water. Copper will be added as copper sulfate, according
to Appendix J of the Interim Guidance Document. One aliquot of the simulated water will be a
control, with no aqueous metal added. Five or more concentrations of the aqueous metal in simulated
water will be prepared, using a dilution factor of no greater than 0.7. Concentrations will be set
so that the middle concentration will be close to the expected threshold toxicity value, with
two concentrations at a higher concentration and two concentrations at a lower concentration. A typical
series for copper in simulated water for fathead minnow testing would be 0, 50, 71, 102, 146, 208,
297, 425 ug/L. For acute toxicity tests only enough solution will be prepared for test initiation, as there
will be no renewal. A sample of each metal concentration in simulated water will be set aside
for total and dissolved metal at test initiation. Total metal samples will be preserved immediately
with nitric acid. Dissolved metal samples will be filtered within 15 minutes and then preserved with nitric
acid.
In a similar manner, laboratory water(diluted mineral water)is prepared, with six or more aliquots set out.
A stock solution of copper (typically 50 mg/L of the metal salt)will be prepared by adding the metal salt
to deionized water. Copper will be added as copper sulfate, according to Appendix J of the
Interim Guidance Document. One aliquot of the simulated water will be a control, with no aqueous
metal added. Five or more concentrations of the aqueous metal in laboratory water will be
prepared, using a dilution factor of no greater than 0.7. Concentrations will be set so that the middle
will beclose to theexpected threshold toxicityvalue, with two concentrations at a higher
concentration pg
concentration and two concentrations at a lower concentration. A typical series for copper in laboratory

water would be 0,35, 50, 71, 102, 146,208,297 ug/L.For acute toxicity tests only enough solution will be
prepared for test initiation,as there will be no renewal.A sample of each metal concentration in laboratory
water will be set aside for total and dissolved copper at test initiation.Total metal samples will be
preserved immediately with nitric acid. Dissolved metal samples will be filtered within 15 minutes and
then preserved with nitric acid.
The primary species tested will be the Fathead Minnow (Pimephales promelas). Acute toxicity tests
will be conducted for this species. Laboratory will be prepared in the same manner as noted for the
primary species. Tests using laboratory water and tests using simulated water will be run in parallel,
starting and ending on the same day, using test organisms from the batch of fish. Fish to be used in
the simulated water test will be hatched in the simulated water for acclimation, and used to start the test
no more than 24 hours after hatching. Fish to be used in the laboratory water test will be hatched in
the laboratory water for acclimation, and used to start the test no more than 24 hours after hatching.
Acute toxicity tests will be 48 hours in length and use two replicates of ten test
organisms at each test concentration. Test organisms are not fed during acute tests but are fed during the
holding period prior to the test. Measured concentrations of total and dissolved metal are conducted on
each test concentration at the beginning and end of the test and are preserved/filtered as noted above.
Tests for the secondary species will be conducted using the test organism Ceriodaphnia dubia. Tests using
laboratory water and tests using simulated water will be run in parallel, starting and ending on the same
day,using test organisms from the same rows of stocks.Acute toxicity tests will be 48 hours in length and
use fours replicate of five test organisms at each test concentration.Test organisms are not fed during acute
tests but are fed during the holding period prior to the test. Measured concentrations of total and dissolved
metal are conducted on each test concentration again at the end of test and are preserved/
filtered as noted above.
Once all three rounds of testing with the primary species and the single round with the secondary species
are completed and metal data are available, a water effect ratio will be calculated using both total
and dissolved copper concentrations. For acute tests a 48 Hour LC50 will be determined for both the
laboratory water and the simulated water. If there are at least two concentrations with partial
mortality the probit method will be used, otherwise a non-linear regression model will be used to
interpolate the EC50. If the highest concentration in either test shows less than 50% mortality, the
tests will need to be repeated using higher test concentrations. Each 48 Hour LC50 value for the
laboratory will be adjusted(normalized)to the same hardness as the simulated water.For chronic tests

with the primary species, an EC50 value will be calculated. The EC50 is the standard test endpoint
used by SCDHEC for WERs, however, alternatives such as an IC25 might be considered. EC50 values
will be based on reproduction and will be calculated using a non-linear regression model as specified in
SCDHEC methodology.
The individual water effect ratio for each round of testing will be calculated as the ratio of the EC50
in simulated water / the EC50 in laboratory water. The final WER will be calculated according to the
guidelines and formulas in the EPA Interim Procedure Document. The final WER is calculated using only
the three individual WERs from the primary species. The WER from the secondary species is not used
but is merely checked to verify that it differs by no more than a factor of 5 from the primary species
WERs. If two Type I WERs are conducted and a single Type II WER is conducted, the final WER will be
the lowest of the adjusted geometric mean of the Type I WERs and the lowest hWER.

Division of Water Resources
Serial: RA-19-0430
Enclosure 2
Harris Nuclear Plant and Harris Energy and Environmental Center
NPDES Permit Number NC0039586
Mixing Zone Study Work Plan
(8 pages including cover)
new

JACOBS Draft Memorandum
111 Corning Road,Suite 200
Cary,North Carolina 27518
United States
T+1.919.859.5000
F+1.919.859.5151
www.jacobs.com
Subject Mixing Zone Study Work Plan
Prepared for: Shearon Harris Nuclear Plant(HNP)
Duke Energy-Progress LLC(Duke Energy)
Copy to: Bob Wilson/Duke Energy—HNP
Don Safrit, PE/Duke Energy
From CH2M HILL North Carolina, Inc.(a wholly owned subsidiary of Jacobs Engineering)
Date October 10,2019
Introduction and Background
This technical memorandum presents the work plan for performing a mixing zone study evaluating the
dilution for use in subsequent toxicity testing and/or for calculations for allowable outfall dilution for
application of dissolved water quality criteria for metals from Shearon Harris Nuclear Plant(HNP) into
Shearon Harris Reservoir under NPDES Permit No. NC0039586, effective September 1, 2016.
Conditions of the permit require compliance with total copper and total zinc limits by September 30, 2021.
This work plan has been developed by CH2M HILL North Carolina, Inc. (a wholly owned subsidiary of
Jacobs Engineering)in response to the comments on the 2018 Water Effects Ratio (WER)Study
received from the North Carolina Division of Water Resources (DWR)on July 16, 2019. In the letter DWR
requests that a dye dispersion study or dilution modeling study be conducted so that the WER Study can
be conducted in accordance with the Special Flowing-Water Situations described in Appendix F of the
1994 United States Environmental Protection Agency(EPA)Interim Guidance on Determination and Use
of Water-Effect Ratios for Metals(EPA, 1994).
The NPDES Permit requires toxicity testing and other effluent limits for Outfall 006 using a Chronic Test
Concentration (CTC)of 100%, which does not incorporate any dilution within the Shearon Harris
Reservoir. DWR has indicated that WER testing should have been conducted using some dilution with
the receiving water and that a dilution model could be used to select appropriate dilutions. Duke Energy
has agreed to conduct dilution studies for use in subsequent WER testing but also proposes that mixing
zone study results can also be used to determine more appropriate CTCs for Outfall 006.
The mixing zone study's analytical approach will rely on modeling the outfall and reservoir characteristics
using the Cornell Mixing Zone Expert System (CORMIX)(Doneker and Jirka, 2007).
Outfall Characteristics
The NPDES Permit authorizes discharges from seven outfalls with designations from 001 through 007.
Outfalls 001 to 005 are internal outfalls, which then combine as Outfall 006, which then discharges into
the receiving water, Shearon Harris Reservoir. Outfall 007 is a discharge to Shearon Harris Reservoir
from a wastewater facility serving the Harris Energy&Environmental Center.
The proposed mixing study will focus on Outfall 006, which combines internal outfalls from cooling tower
blowdown and the HNP radwaste treatment system. Outfall 006 is located towards the south end of
Shearon Harris Reservoir near the point at the end of Bartley Holleman Road, as shown in Figure 1. The

outfall structure is a single, 48-inch reinforced plastic pipe with head wall and riprap bed. A drawing
showing the outfall structure is included as Attachment 1. The most recent effluent characterization
results through June 2019 are documented in the Corrective Action Plan for Copper and Zinc for Harris
Nuclear Plant NPDES Permit, Year 3 Activities Report(Duke Energy, 2019).
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006
Methodology
Based on the understanding of the request from DWR,the objective is to develop a Mixing Zone Study 1
technical report of the existing Duke Energy HNP wastewater discharge system for Outfall 006, determine
the dilutions achieved by the discharge based on effluent flow records and the existing outfall
configuration, assess dilution requirements for compliance with the permit conditions by September 30,
2021, confirm mixing zone boundaries for Outfall 006, and determine if there is a need for additional WER
testing using the dilution suggested by the model. Analyses will be performed to document the dilution
performance and mixing provided by the existing Duke Energy Outfall 006 for site-specific receiving water
conditions.
This discharge evaluation will be developed based on wastewater flow and chemistry data collected by
Duke Energy since April 2017 and existing data sources for the Outfall 006 discharge site. No site-
specific receiving water data will be collected as part of this mixing zone study. The available receiving
water data (current velocities,water temperature and chemistry, and depth of discharge)will be used as
inputs for the dilution modeling. The outfall dilution will be evaluated using an appropriate and
representative model (CORMIX). Dilutions will be predicted for monthly average, maximum daily, and
peak effluent flows and with seasonal receiving water conditions.

Modeling Application
The model that will be used for the mixing zone study is CORMIX v11.0. The CORMIX modeling system
is detailed in the 2007 CORMIX User Manual, A Hydrodynamic Mixing Zone Model and Decision Support
System for Pollutant Discharges into Surface Waters, developed for the EPA(Doneker and Jirka, 2007).
It is a rule-based system that classifies the interaction of discharges and the receiving water. The
CORMIX models use empirically-derived curve fit equations to make dilution predictions. These equations
are selected from length scales determined from input parameters that are input by the user. The
program makes many of the decisions for the model user based on the input parameters that are
provided. It can simulate a variety of discharge conditions, including boundary interactions, such as
bottom attachment and shoreline contact.
The CORMIX modeling system consists of three models or modules: CORMIX 1,which is designed for
submerged single port outfalls; CORMIX 2, which is designed for submerged multiport line diffusers; and
CORMIX 3, which is designed for surface discharges. CORMIX 1 is the most appropriate selection for this
application given the outfall configuration (Attachment 1). The model that best represents the existing
outfall configuration will be selected to predict dilutions for the facility's discharge to the receiving water.
Data for the model is input for four topics listed below. The checklist for data preparation included in the
CORMIX User Manual will be used to gather the applicable variables:
1. Effluent properties
2. Ambient conditions
3. Discharge conditions
4. Mixing zone definitions
The model output includes both qualitative and quantitative data. Qualitative output includes the
processing record, length scale calculations, flow class description, and design recommendations. The
quantitative output includes numerical flow predictions in a session summary report and a detailed
prediction file.
Reporting
A Mixing Zone Study technical report will be prepared from the Outfall 006 discharge evaluation and
mixing zone analyses, and it will include:
• Discharge characteristics from the available effluent data
• Modeling approach and assumptions
• Modeling results, including outputs for all discharge scenarios
• Evaluation of dilutions and recommendation for acute and chronic mixing zone boundaries
• Recommendations for the application of these results with additional WER testing
A meeting or a conference call will be held with Duke Energy and DWR to review the findings of the
technical report, if needed.
Schedule
The estimated timeframe to complete the Mixing Zone Study is eight weeks, as shown in Figure 2.
Week
Task 1 2 3 4 5 6 7 8
Data Collection
Modeling
Report Development
Figure 2. Shearon Harris Nuclear Plant Mixing Zone Study Work Plan Schedule

References
Doneker, R.L. and G.H. Jirka. 2007. CORMIX User Manual: A Hydrodynamic Mixing Zone Model and
Decision Support System for Pollutant Discharges into Surface Waters", EPA-823-K-07-001, Dec. 2007.
http://www.mixzon.com/downloads/.
Duke Energy. 2019. Corrective Action Plan for Copper and Zinc for Harris Nuclear Plant NPDES Permit,
Year 3 Activities Report. Submitted to North Carolina Department of Environmental Quality on August 29,
2019.
United States Environmental Protection Agency(EPA). 1994. Interim Guidance on Determination and
Use of Water-Effect Ratios for Metals. Prepared by Office of Water. February 1994.

Attachment 1
Outfall 006 Drawing

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