HomeMy WebLinkAboutNC0007064_Application Attachment_20230417DUKE
ENERGY
APR 1 2 1013
Serial: RA-23-0062
Mr. Doug Dowden, Supervisor
NPDES Industrial Permitting
NC DEQ/DWR/WQ Permitting Section
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Brunswick Steam Electric Plant, Unit Nos. 1 and 2
National Pollutant Discharge Elimination System
NPDES Permit No. NC0007064
Renewal Application Addendum
Dear Mr. Dowden:
Brunswick Nuclear Plant
8470 River Road SE
Southport, NC 28461
Duke Energy Progress, LLC submitted the permit renewal application via a package dated May
23, 2022 and acknowledged as received by your office on May 31, 2022. During recent reviews
of facility improvements (Drainage Holding Facility [DHF]) and vendor supplied products, it was
noted that several aspects of the previous application package (Attachments to Enclosure 2 US
EPA Form 2C) need to be updated. Please accept and integrate the following information into
the current renewal package and process:
Attachment 3 - Form 2C — Section 2 — Line Drawing & Flow Balance (updates in red)
Attachment 4 - Form 2C — Section 3 — Outfall Flows, Contributing Operations and Treatment
Technologies (updates in red)
Attachment 5 - Form 2C — Section 8 — Used or Manufactured Toxics (Potential Discharges
Not Covered by Analysis) (updates in red)
Routine operation of the DHF is to route flows to the Storm Drain Stabilization Facility (SDSF)
and subsequent discharge via Outfall 011. During extreme weather conditions, DHF flows
would discharge via Outfall 005 as opposed to Outfall 011. We do not believe these
clarifications will have any substantive changes to how the NPDES permit was previously
developed but may affect how permit narratives are written in the permit renewal. We are
enclosing the original and two copies of these attachments to include in your review package.
If you have any questions regarding the enclosed information, please contact Mr. Don Safrit,
P.E., at (984) 209-0940 or Mr. Drew Petrusic at (910) 832-2728.
NC DEQ/DWR/WQ Permitting Section
Page 2 of 2
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,
Jay Ratliff
Plant Manager
Brunswick Steam Electric Plant
Enclosures
Attachment 3 - Form 2C — Section 2 — Line Drawing & Flow Balance (updates in red)
Attachment 4 - Form 2C — Section 3 — Outfall Flows, Contributing Operations and Treatment
Technologies (updates in red)
Attachment 5 - Form 2C — Section 8 — Used or Manufactured Toxics (Potential Discharges
Not Covered by Analysis) (updates in red)
cc: Mr. Thomas Tharrington, Wilmington Regional Office
Mr. Drew Petrusic
Mr. Don Safrit, P.E.
Attachment 3
Form 2C — Section 2 — Line Drawing & Flow Balance (updates in red)
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Attachment 4
Form 2C — Section 3 — Outfall Flows, Contributing Operations and Treatment
Technologies (updates in red)
Duke Energy Progress, LLC
Brunswick Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0007064
Attachment 4
Form 2C - Section 3 — Outfall Flows, Contributing Operations and Treatment
Technologies
A
010
0.150
3A,54PB &
Design capacity
B
0.120
Estimated flow
C
006
5,000 gals/event
4B
Estimated flow
D
005
1.44
3G & 4B
Estimated flow
E
003
0.020
1 O& S, 4B
Estimated flow
Maximum flow- totals for Units 1 & 2 Once
F
001
1,625
4B
through cooling water (1509 MGD
maximum) and Service Water (116 MGD
maximum)
G
0.201
Brunswick County Utilities Account Report
H
0.255
Estimated flow
I
1,625
Maximum intake
J
011
5.9
3G & 4B
Estimated flow per event
K
012
0.022
3G & 4B
Estimated Average flow per day
L
0.030
Estimated Average flow per day
Notes:
* - Radwaste is disposal at a licensed disposal facility
1
Duke Energy Progress, LLC
Brunswick Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0007064
The Brunswick Steam Electric Plant (BSEP), located approximately 2.5 miles north of
Southport, North Carolina, consists of two General Electric boiling water nuclear reactors
with a combined maximum dependable capacity of 1,870 MW. Cooling water for the plant
is drawn from the Cape Fear River and discharges into the Atlantic Ocean approximately
2,000 feet off -shore. In addition to cooling water, all other waste streams at the plant
ultimately discharge to the Atlantic Ocean.
Chemical constituents contained in this discharge will, in part, be representative of
the naturally occurring chemical quality and quantity of the intake water and will
also have chemical constituents of such quality associated with similar discharges
for nuclear generating facilities of this size, type, and in this geographical location.
Either all or part of the elements in the Periodic Table, either singularly or in any
combination, may from time to time be contained in the discharge.
Each component of the discharge is described below.
Once -Through Cooling Water, Service Water (Outfall 001)
Cooling water is withdrawn from the Cape Fear River via an intake canal. At the point
where the intake canal intersects the river, a diversion fence screens out larger organisms.
The intake structure for once -through cooling water has 42 fine mesh screen panels and 8
coarse mesh screen panels rotating in front of all four pump bays for each unit. Normal
operating configuration is for 3 CWIPs to be in service at all times for each unit, for a total
of 126 fine mesh screen panels and 24 coarse mesh screen panels in service per unit.
The 4th pump bay for each unit will be maintained with the with the same number of fine
mesh and coarse mesh screen panels as the other three pump bays, such that if the 4th
pump is put into service, there will be no impact to the number of fine or coarse mesh
screen panels in operation. Aquatic organisms impinged on the traveling screens are
washed off and returned to the estuary. The once -through cooling water discharge
consists of water that has circulated through the condensers of Units 1 and 2. The
temperature rise over the condenser is approximately 150 - 300 Fahrenheit. The service
water is used to cool heat exchangers associated with the turbine and reactor closed
cooling water systems. The temperature rise of the service water is approximately 101
Fahrenheit. Both of these systems discharge to the Atlantic Ocean via the 5.4-mile
effluent channel and pumping station at Caswell Beach. Prior to entering the plant, both
cooling water and service water are chlorinated to minimize bio-fouling in the piping, heat
exchangers, and other plant components.
The once -through cooling water pump flows will be verified periodically during the
operating cycle. If a significant difference is found between the flow rates, the once -
through cooling water pumps/valves will be adjusted during upcoming maintenance or
refueling outages to reflect the appropriate flow rate. In addition, flow will be verified after
changing pump/valve configurations if needed.
0
Duke Energy Progress, LLC
Brunswick Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0007064
Since the source of the cooling water and service water is near the mouth of the Cape
Fear River, the chemical constituents of the discharge are representative of the water in
the river. The chemical constituents, in quality and quantity, are subject to many variables
such as tides, rainfall, and other discharges to the river.
Radwaste Treatment (Outfall 003)
The radwaste treatment system is designed to collect, store, and process any radioactive
(or potentially radioactive) liquids associated with operation of the nuclear power plant.
These low volume waste streams are collected in tanks and sampled for radioactivity prior
to discharging to the effluent channel. A representative tank is also sampled for TSS and
oil and grease in accordance with the NPDES permit. The tanks are discharged
intermittently, one at a time, at a rate of up to 200 gpm. Flow rates are identified on EPA
Form 2C Section 3. Radioactive components of releases are regulated by the Nuclear
Regulatory Commission. These tanks are described below:
Floor Drain Sample Tanks and Waste Sample Tanks (23,000 gal. capacity each)
These tanks receive the majority of the radwaste, primarily from in -plant drains
and sumps, which contain high purity water. After the water is treated by
demineralization and filtration, it is either recycled back into the plant or released.
Detergent Drain Tanks (1,200 gal. capacity) - This tank receives water from
showers and other in -plant drains that may collect water used for general
cleaning purposes and is treated by filtration prior to release.
Salt Water Release Tank (34,250 gal. capacity) - This tank receives water used
for general cleaning purposes and water that leaks into the plant from the cooling
and service water systems, as well as waste water from the turbine building air
wash system which cools and removes humidity from the air that is re -circulated
through the turbine buildings. The water is treated by filtration prior to release.
Drainage Holding Facility Pond (Outfall 005)
A Drainage Holding Facility (low volume waste pond acronym DHF) has replaced the
Storm Drain Stabilization Pond with its primary input being sheet flow from the legacy pond
area. The DHF is approximately 4.2 acres and holds approximately 4 million gallons.
Discharge frequencies can vary depending upon stormwater inputs.
Routine volume control of the DHF is to gravity drain contents to the Storm Drain
Stabilization Facility (Outfall 011). During extreme weather or for severe weather
preparations GeRditinnc WheR SUffinient w ateF has aGGW , Wlated OR the DHF is released
through an underflow/overflow standpipe and valve at the rate of up to 1,000 gpm. This
released water flows into the intake canal at a point approximately 500 yards from the
3
Duke Energy Progress, LLC
Brunswick Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0007064
intake pumps, where it is drawn into the plant circulating and service water system, and
eventually released into the effluent channel.
The DHF has a Parshall flume weir and sampling station located downstream of the outfall
riser structure. The DHF can be used as an alternate collection point for the same inputs
described in Outfall 011.
Sanitary Waste Treatment (Outfalls 010
The BSEP is served by a 0.150 million gallons per day (MGD) sequencing batch reactor
(SBR) sanitary treatment plant. The SBR is a fill -and -draw activated sludge system for
wastewater treatment. In this system, wastewater is added to a single "batch" reactor,
treated to remove undesirable components, and then discharged. Equalization, aeration,
and clarification can all be achieved using a single batch reactor. To optimize
performance of the system, two or more batch reactors are used in a predetermined
sequence of operations. They are uniquely suited for wastewater treatment applications
characterized by low or intermittent flow conditions.
Storm Drain Stabilization Facility Pond (Outfall 011)
The Storm Drain Stabilization Facility (low volume waste pond acronym SDSF) is
approximately 3.7 acres, holds approximately 6 million gallons of water, and discharges on
a weekly basis during normal operation. Discharge frequencies can vary depending upon
storm water input. When sufficient water has accumulated in the SDSF, it is released
through an underflow/overflow standpipe and valve at the rate of up to 1,000 gpm for
approximately one week, or as needed. The SDSF has a graded native soil berm with a
geotextile liner, a lower HDPE liner, Geonet drainage layer and detection/collection sumps,
leak detection layer and an upper HDPE liner. The SDSF has a Parshall flume weir and
sampling station located downstream of the outfall riser structure.
Low volume sources and storm water from the plant yard discharges into the Storm Drain
Collector Basin (SDCB) prior to being routed to the SDSF (Outfall 011). The SDCB is
equipped with an oil skimmer for treatment of the effluent prior to discharge to the SDSF.
Although chemical treatment of the waste is not a general practice, there are provisions for
neutralizing the waste in the collection basin, if necessary, using caustic or acid.
There are eight sources, which are routed to the low volume waste system (Outfall 011),
including both intermittent and routine flows. These sources are described below.
Auxiliary Boiler Systems
The plant operates one auxiliary boiler to generate steam as necessary for
various plant systems. Less than 50 gallons/week are discharged from this
system as routine blowdown. About once a year, the boiler is drained and
inspected, resulting in approximately 3,500 gallons of wastewater per event.
4
Duke Energy Progress, LLC
Brunswick Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0007064
2. HVAC Cooling Towers
An HVAC cooling tower is used to cool each of the two Turbine Buildings.
The towers blow down approximately 6.4 gpm to the Storm Drain Collector
Basin.
3. Demineralized Water System
The purpose of the Mobile Make Up Water Treatment Unit (MMWTU) is to
provide ultra pure demineralized water for the BSEP. Demineralized water
is used throughout the BSEP for many purposes. Some of which include the
Fuel Pool make up, precoat tank fill, and cooling for pump bearings. The
MMWTU system is also the primary supply to the Condensate Storage
Tanks. The demineralized system is a reverse osmosis (RO) based system
with demineralizers for final polishing, using county water as the raw influent
water. The truck -mounted system takes county water from the site potable
water system after passing through the charcoal bed. The demineralized
system produces product water along with a brine concentrate that is
drained to the storm drain system at a pH of 6.0-8.0. Amount of usage for
product water, not including brine and rinse water, is 11 million gallons per
year at normal flow and 12 million gallons at high flow. This creates a brine
solution of 5.7 million gallons a year. Brine water consists of concentrated
contaminants of the county water system. Some additives are used to
enhance the system performance. Approximately 450 lbs of sodium
hydroxide per year is used for Chlorine destruction, and approximately 50
Ibs per year of polyaluminum chloride and 50 gallons per year of
Hypersperse MDC 150 are used as an antifoulant. Rinses are done when
the system is started up, this is done by dumping product water and brine
water together until product water reaches certain parameters. Rinses are
approximately 225,000 gallons per year. There is approximately one
chemical cleaning a year for the RO membranes. The rinse consists of 70
Ibs/yr of GE Water Kleen MCT 103, and 70 Ibs/yr of GE Water Kleen MCT
511. The rinses are drained to the storm drain system at a pH of 8.0-9.0.
4. Standby Liquid Control Test Tank
This 210 gallon tank contains demineralized water and occasionally, Borax
and boric acid. The tank is released quarterly, if the Boron levels exceed 10
ppm.
5. Turbine Building Closed Cooling Water
During each refueling cycle, (approximately once every 24 months), one
heat exchanger containing approximately 2,100 gallons of water may be
drained. Occasionally, a system feed and bleed is required to maintain
Chemistry control. This process may release up to 4,500 gallons.
5
Duke Energy Progress, LLC
Brunswick Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0007064
6. Diesel Generator Cooling Water System
Minor sources of non -potable water leaks from this generator system (four
diesel generators) and drains into the collection basin. Additionally, the
cooling water system is drained periodically for maintenance (Approximately
900 to1,000 gallons).
7. Maintenance Activities
During maintenance activities at the facility it may become necessary to
drain all or some portion thereof of the following plant systems; service
water, circulating water, potable water, and demineralized water.
Maintenance activities at the facility may also require flushing of system
piping with the discharge to the storm drain system. In addition, the facility
may find it necessary to wash equipment with demineralized water with
the discharge to storm drains.
8. Independent Spent Fuel Storage Installation (ISFSI)
An ISFSI vault was installed at the facility in 2009. Storm water runoff
from the concrete surface and concrete vault will be collected and pumped
to either of the active storm drain stabilization ponds. None of the spent
fuel rods housed in the vault will come in contact with the storm water
runoff, the runoff is expected to have characteristics similar to that of any
other impervious surface (concrete) runoff.
9. Drainage Holding Facility (DHF)
The DHF was placed in service in 2023 and replaced the site's retired
stormwater collection pond. Routine volume control of the DHF is through
gravity draining to the SDSF.
10. Groundwater Well Extraction System (GWE)
Remediation well system utilized to remove groundwater with tritium levels
of concern from the site.
The DHF (Outfall 005) can receive the same inputs described above when the SDSF is
not available for use.
Ground Water Well Extraction System (Outfall 012)
In March of 2011, 92 ground water extraction wells onsite began operating to remove
approximately 22,000 gpd of groundwater with tritium levels of concern from the site. The
wells discharge primarily into the intake canal through the Storm Drain Stabilization Facility
(SDSF, Outfall 011) with the option of using Outfall 012. The discharge will consist of the
extracted groundwater and approximately 30,000 gpd of seepage water from a sock drain
system.
2
Duke Energy Progress, LLC
Brunswick Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0007064
Other Miscellaneous Discharges
In addition to cooling water, service water, sanitary waste, low volume waste, and
radwaste, there are other miscellaneous discharges (or potential discharges) at the BSEP:
Emergency storm drain collection basin overflow to the effluent channel used as
necessary to prevent flooding in the plant area.
Intake screen backwash, as required, to operate the cooling water system.
7
Duke Energy Progress, LLC
Brunswick Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0007064
Emergency storm drain collection basin overflow to the effluent channel used as
necessary to prevent flooding in the plant area.
Intake screen backwash, as required, to operate the cooling water system.
7
Attachment 5
Form 2C — Section 8 — Used or Manufactured Toxics (Potential Discharges Not
Covered by Analysis) (updates in red)
Duke Energy Progress, LLC
Brunswick Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0007064
Attachment 5
Form 2C - Section 8 — Used or Manufactured Toxics (Potential Discharges Not Covered
by Analysis)
Although not added or produced, the following elements could potentially be present in the
discharge due to normal pipe erosion/corrosion:
Copper Iron Silver Nickel
Zinc
The following elements could be present in oil which is used to fuel auxiliary boilers:
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
The following chemicals are used at the plant site and may be present within the waste
treatment system:
Sodium Hypochlorite
2gals/yr
As Needed
Sewage Plant Biocide Treatment
12 - 15%
,000
& Cooling Tower Treatment
Sodium Hypochlorite
1.75 million
Daily
Circ & Service Water Antifouling
12 - 15%
gallons per year
Treatment
Nalco CAT -FLOC
Sewage Plant Solids Treatment
1,500 Ibs/yr
As Needed
8103 Plus
Sodium Hydroxide
4,420 gals/yr
As Needed
Sewage Plant & Air Wash
(4-50 /o)
pH control
Lime
100 Ibs/yr
As Needed
Sewage Plant Sludge pH
Treatment
Nalco 7346 Cooling Towers Biocide &
(Bromine powder 1,600 Ibs/yr Daily
Wastewater Systems
and tablet form)
1
Duke Energy Progress, LLC
Brunswick Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0007064
Chemical
Quantity
(used per year,
estimate
Frequency
Purpose
Nalco 19PULV
100 Ibs/yr
As Needed
Aux Boiler Chemicals
Sodium Nitrite
96 Ibs/yr
As Needed
Diesel Generator Chemicals
Nalco 3D Trasar
3DT198
1,200 Ibs/yr
As Needed
Cooling Towers & Diesel
Generators
Nalco 3D Trasar
�94 3DT494
6,700 Ibs/yr
As Needed
Cooling Tower & Diesel
Generators
GE Water
Biomate MBC 2881
Variable
As Needed
Biocide
HydroxideSodium
4-50 lbs�r
nl s ,
5
Ghlerlde
As nl
GE ,nersperse
460 lb&/-Yf
As Need
M ID S-a 59
GE Kleen MGTI03
�
As Needed
Membrane Cleaner
Kleen MGT 51-1
7G4b&/yr
As Needed
Membrane (leaner
,
Veolia
MCT 714
160 Ibs/yr
As Needed
Make Up Water RO Products
Veolia
MCT 403
120 Ibs/yr
As Needed
Membrane Cleaner
Veolia
MCT 411
120 Ibs/yr
As Needed
Membrane Cleaner
Sodium Borate
50 Ibs/yr
As Needed
Diesel Generator Chemicals
Disodium Phosphate
50 Ibs/yr
As Needed
Aux Boiler
Trisodium Phosphate
50 Ibs/yr
As Needed
Aux Boiler
Nalco Towerbrom
991
as
1,000 Ibs/yr
As Needed
Cooling towers
Duke Energy Progress, LLC
Brunswick Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0007064
Quantity
Chemical
(used per year,
Frequency
Purpose
estimate
Nalco 73310
1,889 y
As Needed
Closed Cooling Water System
Sodium Nitrite
3,600 lbs/yr
Stabrex ST70 —
4,300 Ibs/yr
As Needed
Air Washes
Liquid Bromine
Redux 515 Acid
Approximately 2
Pellets (80%
pounds per
week per
As Needed
Pump and piping maintenance
Sulfamic Acid, 20%
groundwater
Boric Acid)
extraction well
Approximately 5
Redux 500
gallons per
As Needed
Pipe cleaning
oLiquid
Descaler (10 /o HCL)
month or 60
gallons per year
Approximately 1
Aqua -Clear AE (60-
gallon per
100% Hydroxyacetic
quarter per
As Needed
Well cleaning and maintenance
Acid)
groundwater
extraction well.
Approximately 1
Aqua -Clear MGA
pound per
(60-100% Sulfamic
quarter per
As Needed
Well cleaning and maintenance
Acid)
groundwater
extraction well
Aqua -Clear PFD (30-
Approximately 1
60% Anionic
cup per quarter
As Needed
Well cleaning and maintenance
polyacrylamide)
per groundwater
extraction well
NALGO 3DT
TD A C O D 4 /1i1
4c nloe.Jo�•!
r�--r�cca�
Used in fliocol (_'onor�+�n re•
in Diesel Gencrccccro,
vied
TBA
�
NALCO 3DT
61,000 Ibs/yr
As Needed
Condenser Cleaning; Silt
TRASAR 121
Dispersant
Condenser Cleaning;
NALCO 73551
54,000 Ibs/yr
As Needed
Bio-detergent
NALCO 90005
500 Ibs/yr
As Needed
Cooling Tower Treatment
Duke Energy Progress, LLC
Brunswick Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0007064
Quantity
Chemical
Used per year,
Frequency
Purpose
estimate
NALCO Actibrom
2,000,000 Ibs/yr
As Needed
Bromine Biocide; Circulation
1338
Water Bio-detergent
NALCO Actibrom
Alternate
product for
Only when 1338 is
Bromine Biocide; Circulation
1318
Actibrom 1338
not available
Water Bio-detergent
Cellulose (Wood
Approximately
Flour)
500 Ibs per
As Needed
Mitigate Condenser Tube Leaks
treatment
ScintLogic LB
3 gallons/yr
As Needed
Online Groundwater Analysis