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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) a p wN Wok LLoto a A d N d C ID y c. 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I U NC G L O U- p N Y c 0 N O m LL On U«� YpCC ` C 9 V w r R 7 O y N LL -------------------------------------' o i 7 V r H c W m G A 1i N p CL 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