NCS000606_ROS request_20230814

f� DUKE Thomas P P. Haaf
Vice President
ENERGY 541Hares Nuclear Plant
3 Shearon Harris Rd
New Hill NC 27562-9300
AUG Q 9 2023
Serial: RA-23-0212
"��0l11'iU,�iG, i io9r6m
Certified Mail Number: 7014 2120 0003 3196 6821
Return Receipt Requested
Mr, Bill Denton-Engineering Supervisor
NC DEQ DEMLR
Raleigh Regional Office
3800 Barrett Drive,
Raleigh, NC 27609
Subject: Representative Outfall Status Request
Draft NPDES Stormwater Permit NCS000606
Harris Nuclear Plant(HNP)
5413 Shearon Harris Road
New Hill, NC 27562
Wake County
Dear Mr. Denton:
Enclosed are the Permit Owner Affiliation Designation Form and the Stormwater Delegation of
Signature Authority Form (DOSA) for the Harris Nuclear Plant. Please update your records as
necessary.
If you have any questions regarding this matter, please do not hesitate to contact Mr. Bob
Wilson, HNP Site Environmental Professional, at [phone].
Sincerely,
Thomas P. Haaf
Enclosure: Representative Outfall Status Request
Draft NPDES Stormwater Permit NC5000606

Representative Outfall Status Request
Draft NPDES Stormwater Permit NCS000606
Serial: RA-23-0212/page 2
CC: Certified Mail Number: 7014 2120 0003 3196 6838
Return Receipt Requested
Thad Valentine— RRO Stormwater Program
NC DEQ DEMLR
Raleigh Regional Office
3800 Barrett Drive,
Raleigh, NC 27609
Certified Mail Number: 7014 2120 0003 3196 6845
Return Receipt Requested
Brianna Young— Industrial Program Individual Permit Coordinator
DEMLR Central Office
1612 Mail Service Center
Raleigh, NC 27699-1612

Representative Outfall Status Request
Draft NPDES Stormwater Permit NCS000606
Serial: RA-23-0212
Enclosures
Representative Outfall Status Request(ROS)
Draft NPDES Stormwater Permit NCS000606
Attachment 1
(4 pages including cover)

Division of Energy, Mineral & Land Resources FOR AGENCY USE ONLY
Date Received
��'` Yegr Ivtanth Day
�::a Stormwater Program
National Pollutant Discharge Elimination System
Environmental REPRESENTATIVE OUTFALL STATUS (ROS)
Quality REQUEST FORNI
if a facility is required to sample multiple discharge locations with very similar storm water discharges, the
permittee may petition the Director for,Representative Outfall Status(ROS). DEQ may grant Representative
Outfall Status if stormwater discharges from a single outfall are representative of discharges from multiple
outfalls. Approved ROS will reduce the number of outfalls where analytical sampling requirements apply.
If Representative Outfall Status is granted, ALL outfalls are still subject to the qualitative monitoring
requirements of the facility's permit—unless otherwise allowed by the permit(such as NCG0.20000)and DEQ
approval. The approval letter from DEQ must be kept on site with the facility's Storm water Pollution
Prevention Plan, The facility must notify DEQ in writing if any changes affect representative status.
For questions, please contact the DEQ Regional Office for your area (see page 3).
(Please print or type)
1) Enter the permit number to which this ROS request applies:
Individual Permit (orl Certificate of Coverage
N I C I s0 0 06 0 6 N C G
2) Facility Information:
Owner/Facility Name Duke Energy Progress,LLC 1 Shearon Harris Nuclear Plant
Facility Contact Bob Wilson
Street Address 5413 Shearon Harris Road
City New Hill State NC ZIP Code 27562
County Wake E-mail Address [e-mail]
Telephone No. 984 229-2444 Fax:
3) List the representative outfalls) information (attach additional sheets if necessary):
Outfall(s) SW-003 is representative of Outfall(s) SW-002,SW-003,SW-004,and SW-005
Outfalls' drainage areas have the same or similar activities? a Yes ❑ No
Outfalls' drainage areas contain the same or similar materials? X Yes ❑ No
Outfalls have similar monitoring results? ❑ Yes ❑ No ® No data*
Autfall(s) SW-006 is representative of Outfall(s) SW-001,SW-008,SW-007,SW-008,SW-009,and SW-8
Outfalls' drainage areas have the same or similar activities? a Yes ❑ No
Outfalls' drainage areas contain the same or similar materials? a Yes ❑ No
Outfalis have similar monitoring results? ❑ Yes ❑ No is No data*
Outfall(s) is representative of Outfall(s)
Outfalls' drainage areas have the same or similar activities? ❑Yes ❑ No
Outfalls' drainage areas contain the same or similar materials? ❑Yes ❑ No
Outfalls have similar monitoring results? ❑ Yes ❑ No o No data*
*Non-compliance with analytical monitoring prior to this request may prevent ROS approval. Specific
circumstances will be considered by the Regional Office responsible for review.
Page 1 of 3
SWU-ROS-2009 Last revised 12/30/2009

Representative Outfall Status Request
4) Detailed explanation about why the outfalls above should be granted Representative Status:
(Or,attach a letter or narrative to discuss this information.) For example,describe how activities and/or
materials are similar.
Please see Attachment 1 for more detailed explanation.
5) Certification:
North Carolina General Statute 143-21S.6 B(i)provides that:
Any person who knowingly makes any false statement,representation,or certification in any application, record,
report,plan,or other document filed or required to be maintained under this Article or a rule implementing this
Article;or who knowingly makes a false statement of a material fact in a rulemaking proceeding or contested case
under this Article;or who falsifies,tampers with,or knowingly renders inaccurate any recording or monitoring device
or method required to be operated or maintained under this Article or rules of the[Environmental Management]
Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed
ten thousand dollars($10,000).
1 hereby request Representative Outfall Status for my NPDES Permit. I understand that ALL outfalls are still
subject to the qualitative monitoring requirements of the permit,unless otherwise allowed by the permit
and regional office approval. I must notify DEQ in writing if any changes to the facility or its operations
take place after ROS is granted that may affect this status. If ROS no longer applies, I understand I must
resume monitoring of all outfalls as specified in my NPDES permit.
I certify that I am familiar with the information contained in this application and that to the best of my
knowledge and belief such information is true, complete,and accurate.
Printed Name of Person Signing: Them-P.Haaf
Title: Vice President-Harris V ar Plant00,
9- 1.45
(Signature of Applicant) (Date Signed)
Please note: This application for Representative Outfall Status is subject to
approval by the NCDEQ Regional Office. The Regional Office may inspect your
facility for compliance with the conditions of the permit prior to that approval.
Final Checklist for ROS Request
This application should include the following items:
❑ This completed form.
❑ Letter or narrative elaborating on the reasons why specified outfalls should be granted representative
status,unless all information can be included in Question 4.
❑ Two(2)copies of a site map of the facility with the location of all outfalls clearly marked, including the
drainage areas,industrial activities,and raw materials/finished products within each drainage area.
❑ Summary of results from monitoring conducted at the outfalls listed in Question 3.
❑ Any other supporting documentation.
Page 2 of 3
SWU-ROS-2009 Last revised 12/30/2009

Representative Outfall Status Request
Mail the entire package to:
NCDEQ DEMLR at the appropriate Regional Office (See map and
addresses below)
Notes
The submission of this document does not guarantee Representative Outfall Status (ROS) will be granted as
requested. Analytical monitoring as per your current permit must be continued, at all outfalls, until written
approval of this request is granted by DEQ. Non-compliance with analytical monitoring prior to this request
may prevent ROS approval. Specific circumstances will be considered by the Regional Office responsible for
review.
For questions, please contact the DEQ Regional Office for your area.
Win da
ie r ie
y try
ngrcn
Asheville Regional Office
2090 U.S. Highway 70
Swannanaa, NC 28778 Washington Regional Office
943 Washington Square Mall
Phone [phone] Washington, NC 27889
FAX [phone]
Phone [phone]
Fayetteville Regional Office FAX [phone]
Systel Building,
225 Green St., Suite 714 Wilmington Regional Office
Fayetteville, NC 28301-5094 127 Cardinal Drive Extension
Phone [phone] Wilmington, NC 28405
FAX [phone] Phone [phone]
Mooresville Regional Office FAX {910} 350-2004
610 East Center Ave. Winston-Salem Regional Office
Mooresville, NC 28115 585 Waughtown Street
Winston-Salem, NC 27107
Phone [phone] Phone [phone]
FAX [phone] Water Quality Main FAX [phone]
Raleigh Regional Office Central Office
1628 Mail Service Center 1612 Mail Service Center
Raleigh, NC 27699-1628 Raleigh, NC 27699-1612
Phone [phone] Phone [phone]
FAX [phone] FAX [phone]
Page 3 of 3
5WU-ROS-2009 Last revised 12/30/2009

Representative Outfall Status Request
Draft NPDES Stormwater Permit NCS000606
Serial: RA-23-0212
Enclosures
Representative Outfall Status Request(ROS)
Draft NPDES Stormwater Permit NCS000606
(4 pages including cover)

Duke Energy requests that the ROS be reviewed and acted upon prior to issuance of the new permit. NC
DEQ has historically allowed ROS at SW-003 and SW-006 at the HNP for the wastewater NPDES permit
(NC0039586).
Table 1. Summary of ROS Request
Outfall Represents
SW-003 SW-002,SW-003,SW-004,SW-005
SW-006 SW-001,SW-006, SW-008,SW-009,SW-B
Figure 1. Existing Outfolls at the Harris Nuclear Plant
7-
Figure 2. Proposed ROS at the Harris Nuclear Plant
-r
a�
lof3

SW-003 Representative Status for SW-002 SW-003 SW-004 and SW-005
Duke Energy is requesting that representative outfall status where SW-003 will represent outfalls SW-
003, SW-002, SW-004, and SW-005. SW-003 was chosen for monitoring because it has the most
potential to capture pollutants from a potential release as it has the most industrial activities of all the
represented outfalls. Each industrial activity in the other drainage areas is also performed in SW-003
(see Table 2).
Table 2. Industrial Activities Performed in Each Drainage Area
industrial Activity 11 11 11' 11
Vehicle and equipment parking
Occasional non-SW discharges d d VO
Above/below ground storage and associated I
loading/unloading
-transformer operation
Cooling tower operation VO l
Sewage lift stations' V0
Indoor chemical and equipment storage i r/ I
E_aydown storage area
Note 1: Duke Energy is requesting removal of parameters associated with sewage lift stations as part of
the permit issuance as they are covered under wastewater NPDES Permit NCO039586 and HNP employs
robust spill response procedures aimed at ensuring environmental compliance and protection of
employees, public health, and the environment
Nate 2:The lay down storage area in Drainage Area S (SW-005)is temporary due to construction and
will no longer be utilized for outdoor storage when construction is completed.Construction is
scheduled to be completed by December 1, 2023.
2of3

SW-006 Representative Status for SW-001, SW-006, SW-008, SW-009, SW-B
Duke Energy is requesting that representative outfall status where SW-006 will represent outfalls SW-
006, SW-001, SW-008, SW-009, and SW-B. SW-006 was chosen for monitoring because it has the most
potential to capture pollutants from a potential release as it has the most industrial activities of all the
represented outfalls. Each industrial activity in the other drainage areas is also performed in SW-006
(see Table 3).
Table 3. Industrial Activities Performed in Each Drainage Area
Laydown storage area' YO
Occasional non-SW discharges
Indoor chemical and equipment storage VO
Transformer operation
Above/below ground j
storage/emergency power generation i V
and associated loading/unloading
Vehicle and equipment parking
Sewage lift stations' -- � - � ------..____ - _ -- .---------__--
Recycling, compacting, general refuse
handling
Fueling
Drinking water treatment i
Bulk storage of sand, gravel, and crushed
stone'
Note 1: Duke Energy is requesting removal of parameters associated with sewage lift stations as part of the
permit issuance as they are covered under wastewater NPDES Permit NCO039586 and HNP employs robust
spill response procedures aimed at ensuring environmental compliance and protection of employees,
public health, and the environment.
Note 2: Duke Energy is willing to submit a lay down area consolidation plan by March 31, 2024, to facilitate
ROS.The lay down area consolidation plan would include a proposal for consolidating outdoor storage
areas that can be moved and cover of those that cannot. Minimizing exposure of bulk storage areas will be
discussed in the lay down area consolidation plan as well.
3of3