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Home My WebLink AboutNC0003425_Alternate Schedule Request_20150311DUKE ►; ENERGY. March 10, 2015 North Carolina Department of Environment and Natural Resources Division of Water Resources NPPES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: 316(b) Alternate Schedule Request Duke Energy Carolina, LLC and Duke Energy Progress, LLC Attention Sergei Chernikov: Environmental Services Duke Energy 526 South Church Street Charlotte, NC 28202 Mailing Address: Mail Code EC13K/ P.O. Box 1006 Charlotte, NC 28201-1006 ,ECEtVEDiDENPJDWR t aR 11 201`j Water Q Sector. PermitttnQ Final regulations to establish requirements for cooling water intake structures at existing facilities were published in the Federal Register on August 15, 2014 (i.e. regulations implementing §316(b) of the Clean Water Act) with an effective date of October 14, 2014. The regulation applies to stations that commenced construction prior to or on January 17, 2002 and have a design intake flow greater than 2 million gallons per day (MGD), utilize 25% of the water withdrawn for cooling purposes and are point sources per the NDPES program. The stations Duke Energy has identified as being subject to the rule are provided in Table 1. The regulation requires the submission of information listed in 40 CFR 122.21(r). The extent of the information that is required to be submitted per station is based on the actual intake flow (AIF). For stations that have an AIF less than or equal to 125 million gallons per day (MGD), the regulation requires the following information to be submitted: §122.21(r)(2) Source Water Physical Data §122.21(r)(3) Cooling Water Intake Structure Data §122.21(r)(4) Source Water Baseline Biological Characterization Data §122.21(r)(5) Cooling Water System Data §122.21(r)(6) Chosen Method(s) of Compliance with Impingement Mortality Standard §122.21(r)(7) Entrainment Performance Studies §122.21(r)(8) Operational Status For stations that have an AIF greater than 125 MGD, the regulation requires the above information to be submitted and, unless waived, the following additional information: §122.21(r)(9) Entrainment Characterization Study §122.21(r)(10) Comprehensive Technical Feasibility and Cost Evaluation Study §122.21(r)(11) Benefits Valuation Study §122.21(r)(12) Non -water Quality and Other Environmental Impacts Study The timing of the submission of the above information is connected to the timing of the NPDES permit renewal application for the station. The regulation states that for a station whose current effective NPDES permit expires after July 14, 2018, information required to be submitted must be included with the subsequent NPDES permit renewal application. For stations whose current effective permit expires on or before July 14, 2018, the owner may submit a request to the permit Director for an alternate schedule for the submission of the above information'. As shown in Table 1, every Duke Energy station in North Carolina either has an effective permit that expires prior to July 14, 2018 or has a NPDES permit that has been administratively continued while the permit is in the renewal process. Duke Energy hereby requests an alternate schedule for each of these stations. The requested submittal date for the 316(b) information is provided in Table 1. As indicated in Table 1, the Duke Energy stations that have an AIF greater than 125 MGD, with the exception of Brunswick Nuclear Station, are located on reservoirs. Under the remanded Phase II 316(b) Rule, stations located on reservoirs were not required to conduct entrainment monitoring. These stations, therefore, will have to conduct 2-years of entrainment monitoring to complete the §122.21(r)(9) submission. Entrainment monitoring has been conducted at the Brunswick Nuclear Station; however, Duke Energy will need to evaluate whether the data collected is sufficient to satisfy the requirements in the recently finalized rule. The data collected during the 2-years of monitoring are necessary to complete the benefits valuation study (§122.21(r)(11)); therefore, this submittal cannot be finalized until after the entrainment monitoring is completed and results analyzed. Furthermore, the regulations require the Comprehensive Technical Feasibility and Cost Evaluation, Benefits Evaluation and the Non -water Quality and Other Environmental Impacts to be peer reviewed. Duke Energy estimates that approximately five years will be needed to complete all the necessary studies and submission, based on the following: 1 year for the development of the Entrainment Characterization Study plans, which includes preparing the plans, and review and approval of the plans by NCDENR. — 2 years to conduct the entrainment monitoring. 1 year to complete the Entrainment Characterization Study Report, Comprehensive Technical Feasibility and Cost Evaluation Study, Benefits Valuation Study and Non -water Quality and Other Environmental Impacts Study. 1 year to complete the Peer Review. This timeframe is very similar to the schedule presented in the proposed rule. Upon submission of the above information, North Carolina Department of Natural Resources (NCDENR) determines what, if any, ' Refer to § 125.95(a)(1) and (2) controls are necessary to address entrainment. Once BTA for entrainment is determined, a compliance schedule will be developed to complete §122.21(r)(6) Chosen Method(s) of Compliance with Impingement Mortality Standard. The stations with an AIF less than or equal to 125 MGD have fewer submittal requirements; however, these stations were either not subject to the remanded rule or have undergone extensive changes to the operation since they were last evaluated. As a result, Duke Energy will need to develop a new submittal for each of these stations. Duke Energy will attempt to use available historical information; however, additional field work may be needed at some sites to complete the Source Water Physical Data and Baseline Biological Characterization Data submissions. EPA concluded that 39 months will be adequate for facilities with an AIF less than 125 MGD to complete all the required submissions. Given the requirements will be implemented through the NDPES permit, Duke Energy request these submittals are due with the NPDES permit renewal applications due after July 14, 2018. If you have any questions or comments, please contact myself at 704-382-9622 or nathan.craig@duke- energy.com. Si rely, ath n Crai Senior Environmental Specialist Duke Energy Attachment Table 1: 316(b) Alternate Schedule Request Duke Energy Carolinas, LLC and Duke Energy Progress, LLC NPDES NPDES Permit Current NPDES Requested Date to Submit Anticipated Next NPDES Submittal Requirements, unless PLANT Method Actual Intake Flow Alternate Schedule Request Number Expiration Date 316(6) Information Permit Expiration Date waived Duke Energy would like to request the 316(b) submittals to be due with the subsequent NPDES r(2) -r(5), r(7)- r(13) once -through cooling (OTC) Permit application due after July 14, 2018, assuming a 5-year expiration date from the r(6) to be submitted after BTA for BRUNSWICK NC0007064 estuary AIF > 125 MGD 11/30/2016 6/2/2021 11/29/2021 expiration date of the current NPDES permit. entrainment is determined Duke Energy would like to request the 316(b) submittals to be due with the subsequent NPDES r(2) -r(5), r(7)- r(13) cooling water reservoir defined as 4.5-years from the effective Permit application, assuming a 5-year expiration date from the effective date of the renewed r(6) to be submitted after BTA for ROXBORO NC0003425 waters of the U.S. AIF from reservoir > 125 MGD 3/31/2012 date of the renewed permit TED permit. entrainment is determined Duke Energy would like to request the 316(1b) submittals to be due with the subsequent NPDES r(2) -r(S), r(7)- r(13) cooling water reservoir defined as 4.5-years from the effective Permit application, assuming a 5-year expiration date from the effective date of the renewed r(6) to be submitted after BTA for ASHEVILLE NC0000396 waters of the U.S. AIF from reservoir > 125 MGD 12/31/2010 date of the renewed permit TBD permit entrainment is determined A renewal application was submitted on Aug. 14, 2014, An alternate schedule request for the 316(b) submittals was submitted on Jan. 9, 2015. Duke Energy requested the 316(b) submittals r(2) -r(5), r(7)- r(13) cooling water reservoir defined as to be due with the subsequent NPDES Permit application due after July 14, 2018, assuming a 5- r(6) to be submitted after BTA for MCGUIRE NC0024392 waters of the U.S. AIF from reservoir> 125 MGD 2/28/2015 8/31/2019 2/27/2020 year expiration date from the expiration date of the current NPDES permit. entrainment is determined An alternate schedule request was submitted with the NPDES application renewal submitted on Oct. 9 2014. Duke Energy requested the 316(b) submittals to be due with the subsequent rQ) -r(S), r(7)- r(13) cooling water reservoir defined as NPDES permit renewal application due after July 14, 2018, assuming a 5-year expiration date r(6) to be submitted after BTA for ALLEN NC0004979 waters of the U.S. AIF from reservoir> 125 MGO 5/31/2D15 12/1/2019 5/29/2020 from the expiration date of the current permit. entrainment is determined An alternate schedule request was submitted with the NPDES application renewal submitted on Oct. 9 2014. Duke Energy requested the 316(b) submittals to be due with the subsequent r(2) -r(5), r(7)- r(13) cooling water reservoir defined as NPDES permit renewal application due after July 14, 2018, assuming a 5-year expiration date r(6) to be submitted after BTA for MARSHALL NC0004987 waters of the U.S. AIF from reservoir> 125 MGD 4/30/2015 10/31/2019 4/28/2020 from the expiration date of the current permit. entrainment is determined Duke Energy would like to request the 316(b) submittals to be due with the subsequent NPDES r(2) -r(5), r(7)- r(13) cooling water reservoir defined as Permit application due after July 14, 2018, assuming a 5-year expiration date from the r(6) to be submitted after BTA for BELEWS CREEK NC0024406 waters of the U.S. AIF from reservoir > 125 MGD 2/28/2017 8/31/2021 2/27/2022 expiration date of the current NPDES permit. entrainment is determined Duke Energy would like to request the 316(b) submittals to be due with the subsequent NPDES cooling pond (classification as AIF from cooling pond > 125 4.S-years from the effective Permit application due after July 14, 2018, assuming a 5-year expiration date from the SUTTON NC0001422 Waters of the US in review) MGD 12/31/2016• date of the permit TBD expiration date of the current NPDES permit. TBD @ a minimum r(2) - r(8) Duke Energy would like to request the 316(b) submittals to be due with the subsequent NPDES closed -cycle cooling (cooling 4.5-years from the effective Permit application, assuming a 5-year expiration date from the effective date of the renewed MAYO NC0038377 towers) AIF < 12S MGD 3/31/2012 date of the renewed permit T80 permit. r(2) -r(e) Duke Energy would like to request the 316(b) submittals to be due with the subsequent NPDES closed -cycle cooling (cooling 4.5-years from the effective Permit application, assuming a 5-year expiration date from the effective date of the renewed SHEARON HARRIS NCD039S86 towers) AIF c 125 MGD 7/31/2011 date of the renewed permit TBD permit. r(2) -r(8) Duke Energy would like to request the 316(b) submittals to be due with the subsequent NPDES closed -cycle cooling (cooling Permit application due after July 14, 2018, assuming a 5-year expiration date from the CLIFFSIDE NC0005088 towers) AIF < 125 MGD 7/31/2015 1/31/2020 7/29/2020 expiration date of the current NPDES permit. r(2) -r(8) Duke Energy would like to request the 316(b) submittals to be due within 3-years of the closed -cycle cooling (cooling effective date of the renewed NPDES permit. Assuming an effective date of 8/31/2016, this date BUCK NC0004774 towers) AIF < 125 MGD 8/31/2016 8/31/2019 8/30/2021 would be 8/31/2019. r(2) -rg) Duke Energy would like to request the 316(b) submittals to be due within 3-years of the closed -cycle cooling (cooling effective date of the renewed NPDES permit. Assuming an effective date of 4/3/2017, this date DAN RIVER NC0003468 towers) AIF a 125 MGD 4/30/2017 4/3/2020 4/29/2022 would be 4/3/2020. r(2) -r(8) Duke Energy would like to request the 316(b) submittals to be due with the subsequent NPDES closed -cycle cooling (cooling pond 4.S-years from the effective Permit application, assuming a 5-year expiration date from the effective date of the renewed H.F.LEE I NC0003417 not defined as waters of the U.S.) All < 125 MGD 5/31/2013 date of the renewed permit TBD permit. r(2) -r(8) • A NPDES application for Sutton was submitted to NCDENR on Feb. 23, 2015. Duke Energy requested the 316(b) submittals to be due with the next NPDES permit application, assuming a 5-year permit term. The Smith Energy Complex receives water from a local municipality; therefore, the station is not subject to the rule