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Home My WebLink AboutNC0007064_Comments_20230814DUKE ENERGY Via Email August 14, 2023 Dr. Sergei Chernikov NC Division of Water Resources 1617 Mail Services Center Raleigh, NC 27699-1617 Subject: Duke Energy Progress, LLC Brunswick Steam Electric Plant (BSEP) NPDES Permit No. NC0007064 Brunswick County Comments on Draft Permit & Fact Sheet Dear Dr. Chernikov: 410 S. Wilmington Street Raleigh, NC 27601 P.O. Box 1551: NCRHQ03 Raleigh, NC 27602 o: 919.546.6146 c:984.209.0940 f: 919.546.3669 Duke Energy Progress, LLC appreciates the opportunity to review the subject draft permit and fact sheet provided to us by your office. Overall, we are satisfied with the content and approach taken with the subject renewal package. We did note several aspects which we believe should be updated in the final permit and offer the following comments: Item 1- Outfall 004 Should be Removed from the Permit Page 2 of 12 — Outfall 004 is an old WWTP which has been decommissioned and removed since the previous issuance of NPDES Permit NC0007064. All sewage is now directed through BSEP's lift station system to the sanitary treatment system associated with Outfall 010. The following item (Note No. 2) should be removed from the permit: 2. to continue operating and discharging via internal Outfall 004 (see attached map), a 0.055 MGD domestic wastewater treatment plant (WWTP) consisting of influent pumps, bar screen, effluent flow v-notch weir measuring device, aeration tank, secondary clarifier and chlorination chamber; and Page 5 of 12 — Outfall 004 is an old WWTP which has been decommissioned and removed since the previous issuance of NPDES Permit NC0007064. All sewage is now directed through BSEP's lift station system to the sanitary treatment system associated with Outfall 010. The following item [A. (3)] should be removed from the permit: A. (3) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [Internal Outfall 0041 [15A NCAC 02B.0400 et seq., 15A NCAC 02B.0500 et seq.] Beginning on the effective date of this permit and lasting until expiration, the Petmittee is authorized to discharge treated domestic wastes from the onsite Wastewater Treatment Plant through Outfall 004. Such discharges shall be limited and monitored' by the Permittee as specified below: Parameter Discharge Limitations Monitoring Requirements \lonthly Average Daily \laximum Measurement Frequency Sample Type Sample Location: Flow 0.055 MGD Monthly Instantaneous Influent or Effluent BOD, 5-Day, 20 °C 30.0 mg/L 45.0 mg/L Monthly Grab Effluent Total Suspended Solids 30.0 mg/L 45.0 mg/L Monthly Grab Effluent Notes: 1. The penmittee shall submit discharge monitoring reports electronically using the NC DWR's eDMR application system [see A. (16)]. 2. To determine permit compliance, the Permittee shall sample plant effluent prior to mixing with other waste steams. Explanation: MGD = million gallons per day BOD = biochemical oxygen demand Dr. Sergei Chernikov NC Division of Water Resources Page 12 of 12 — Map contains Outfall 004 which has been decommissioned and removed since the previous issuance of NPDES Permit NC0007064. The following item (Callout for Outfall 004 and its arrow) should be removed from the permit map: Duke Energy Comment: All references to Outfall 004 should be removed from the draft and final permit. This sanitary wastewater treatment plant was decommissioned and removed from service in 2019. Attachment 1 contains a copy of the NC DEQ DWR WiRO inspection report (June 8, 2022 transmittal letter) documenting the absence/removal of the subject sanitary wastewater treatment plant associated with Outfall 004 (see item 3 on page 2 of the May 26, 2022 WiRO inspection report). Item 2 - Outfall 010 Treatment System Description Should be Updated Page 2 of 12 — This section described the previous sanitary treatment system (Extended Aeration System), and not the new sanitary treatment system (Sequencing Batch Reactor) associated with Outfall 010. �. to continue discharging via internal Outfall 010 (see attached map), and continue operating a 0.150 MGD Support Services domestic WWTP consisting of an influent duplex pump station, manually cleaned bar screen, flow EQ basin, flow splitter box; two (2) aeration basins, two (2) clarifiers, two (2) tertiary filters, aerobic sludge digester with airlift sludge pump, baffled chlorine contact chamber with one (1) tablet chlorinator, and an effluent flow `,.-notch weir measuring device; and Duke Energy Comment: The proper description for the Support Services Domestic WWTP (Outfall 010) should be revised to read: ...consisting of a sanitary collection system with twelve (12) pump stations and associated force mains, an influent self-cleaning fine screen system, four (4) sequencing batch reactor tanks each having a mixer, decanter, sludge pump and blower, two (2) sludge digestor tanks, an effluent disk filter, a UV disinfection system, an effluent flow totalizer, a standby power generator, and a PLC for plant operation and optimization; and Dr. Sergei Chernikov NC Division of Water Resources Item 3 - Outfall 012 References to Storm Drain Stabilization Pond (SDSP) Should be Updated to Reference the Drainage Holding Facility (DHF) Page 2 of 12 —The Storm Drain Stabilization Pond (SDSP) has been retired and replaced by the Drainage Holding Facility (DHF). 9. to discharge extracted groundwater and seepage water from Storm Drain Stabilization Pond from Outfall 012 to the Effluent Chamiel, and Page 8 of 12 — The Storm Drain Stabilization Pond (SDSP) has been retired and replaced by the Drainage Holding Facility (DHF). A. (8) EFFLUENT LIMITATIOI\S AND MONITORIl\G REQUIRE-NIENTS [Internal Outfall 0121 [15A NCAC 02B.0400 et seq., 15A NCAC 02B.0500 et seq] Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge extracted groundwater and seepage water from Storm Drain Stabilization Pond through Outfall 012. Such discharges shall be limited and monitored' by the Permittee as specified below: Parameter Discharge Limitations Monitoring Requirements Monthly Average Daily Maximum 1Measurement � Frequency Sample Type Sample Location Flow Weekly Instantaneous Effluent Total Suspended Solids 30.0 mg L 100.0 mg/L Monthly Grab Effluent Duke Energy Comment: The Storm Drain Stabilization Pond (SDSP) has been modified and reconstructed during the term of the previous permit and should be renamed as the Drainage Holding Facility (DHF). Item 4 -Total Beta Radiological Monitoring Should be Removed Page 3 of 12 —Total Beta radiological monitoring requirement for Outfall 001 is new. Total Beta radioactivity, Monitor and report Quarterly Grab Effluent pC'r%L Page 9 of 12 — Radiological monitoring is a Nuclear Regulatory Commission (NRC) requirement and function as evidenced by Condition A. (15) of the permit. A. (15) RADIOACTIVE MATERIAL Releases of radioactive material shall be monitored and conducted in accordance with all conditions and limitations required by the Nuclear Regulatory Commission (NRC) and as specified in the Final Safety Analysis Report, Technical Specifications, and Environs rental Statement for Brunswick Steam Electric Plant. Duke Energy Comment: The proposed monitoring for Total Beta radioactivity is unnecessary and redundant of the Nuclear Regulatory Commission's (NRC's) radiological oversight of the Brunswick Steam Electric Plant. Furthermore, the effluent levels of beta emitters do not take into consideration that these levels are typical background beta conditions (as evidenced in the Form 2C Intake analytical results) for water in the estuarine / near shore conditions associated with the Brunswick site. Such ambient and effluent beta emission data (including water) is readily available in NRC Dr. Sergei Chernikov NC Division of Water Resources annual reports and is publicly available on the NRC website. BSEP respectfully requests the Total Beta Radioactivity monitoring requirement be removed from the draft and final permit. Brunswick 1 & 2 1 NRC.gov NUCLEAR REACTORS Homer Nuclear Reactors, Operaing Reactors r Reador Safety lul'on-don Topics r Groundwater Canlamination(Tdtum)al Nuclear Planls r Rddioaclive Effluent and Environmental Rcpohs ,k Navigation Radioactive Effluent and Environmental Reports for Brunswick 1 & 2 Arkansas Nudes 0. 1&2 Beaver Valley l&2 The"Groundwater quesliannaire'desr r the stata athe gruu J-1,r vdte on program, as ul be time the ques[i r—,,was submlbed (generally 2007unless othervnse stated). Braidmod 1 &2 The-ERllent Report' lists the quantffease ies of radl or ud ides reld from Ih a sde in liquid and gaseous effluents for the calendar yea. This Bruwrs Feny 1, 2 &3 report is actually Ihe'Annual RatlioadNe EOluenl Release Repod" submitted as reouirod by Federal regulalions 110 CFR 50.38aj. The "Envirarmenlal Report' lists the measurements 1radi.-ive materials Found In the environment.-und Inq the power plairl. This mporl is actually the "Mnual Radidogical Ennomrenlal Operaling Report" su bmilled as required by Federal regulainbe Bgon Slalion 1 & 2 Gallaway Groundwater Qlestionnairesa Gahled Cliffs I & 2 • RadioaoHre E0luenl Reports: Catawba 1 &2 12022012021 p 12020a 12019 a12019 a 12317 a 120112015a 1 M14al2013 a1201212011 e l 2010BI c°dun Zoos 12908 El 12007 [91 Zoos a 126u5 21 G:lu mbi a Generaling Slaton Ermmmenlal Repods. G_nlanche Peak 1 & 2 12022E 1 20211a 1 20201812019 a 12016 a 12017 a 12016 8 1 20151a 12014 812013 a 12012 a 12011 012010131 Cooper 2009 p 120H a 12007 a 12006 a 12005 ® I Crystal R-3 Cavil -Besse PageL SRe--dlllpdaietl VredrR_ffiy, June O], 2 23 Thanks again for the opportunity to provide these comments on the draft permit and fact sheet. Please do not hesitate to contact me via email (Don.Safrit@duke-energy.com) or via my cell (984.209.0940) if you have any questions or if we need to discuss. Sincerely, Ole 1* 266;v Donald L. Safrit, P.E. Lead Environmental Specialist Environmental Ops - Water Attachment 1 - May 26, 2022, NC DEQ DWR WiRO Inspection Report cc: Mr. Tom Tharrington, NC DEQ DWR Wilmington Regional Office (via email) Mr. Drew Petrusic, Nuclear Environmental Field Support, BSEP (via email) Attachment 1 May 26, 2022, NC DEQ DWR WiRO Inspection Report DocuSign Envelope ID: C77B83C3-EBD3-4598-A331 -E5813A301 EC3 ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director John Krakuszski Duke Energy Progress LLC PO Box 10429 Southport, NC 28461 NORTH CAROLINA Environmental Quality June 08, 2022 SUBJECT: Compliance Inspection Report Brunswick Steam Electric Plant NPDES WW Permit No. NC0007064 Brunswick County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Brunswick Steam Electric Plant on 5/26/2022. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0007064. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report". There were no significant issues or findings noted during the inspection and therefore, a response to this inspection report is not required. If you should have any questions, please do not hesitate to contact Bryan Lievre with the Water Quality Regional Operations Section in the Wilmington Regional Office at 910-796-7215 or via email at bryan.lievre@ncdenr.gov. Sincerely, EW DocuSigned by: mLt a, Sad GIA�Al" EMIA14AC7DC434... Morella Sanchez -King, Regional Supervisor Water Quality Regional Operations Section Wilmington Regional Office Division of Water Resources, NCDEQ Attachment Cc: Drew Petrusic (via email at Drew.Petrusic@duke-energy,com) Laserfiche D_c Q�� North Carolina Department of Environmental Quality I Division of Water Resources Wilmington Regional Office 1 127 Cardinal Drive Extension I Wilmington, North Carolina 28405 910.796,7215 DocuSign Envelope ID: C77B83C3-EBD3-4598-A331 -E5813A301 EC3 United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 IN I 2 u 3 I NC0007064 I11 121 22/05/26 I17 18I � I 19 I s I 201 I 6 211IIIII 111111III II III III1 I I IIIII IIIIIIIII II J Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 I 72 I ni I 71 I 74 79 I I I I I I I80 701 I 71 I LL -1 I I LJ Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES Dermit Number) 08:30AM 22/05/26 18/05/01 Brunswick Steam Electric Plant 8470 River Rd SE Exit Time/Date Permit Expiration Date Southport NC 28461 02:OOPM 22/05/26 22/11/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Charles K Wilson/ORC/910-457-3687/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted John Krakuszski,PO Box 10429 Southport NC 28461/Plant Manager// No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement 0 Operations & Maintenar 0 Records/Reports Self -Monitoring Progran 0 Sludge Handling Dispo: 0 Facility Site Review 0 Compliance Schedules Effluent/Receiving Wate 0 Laboratory 0 Storm Water 0 Other Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Bryan Lievre Docusignedby- DWR/WIRO WQ/910-796-7215/ 6/8/2022 B2r�,an. �irvm� 74249ABED37443E... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date Morella Sanchez -King DWR/WIRO WQ/910-796-7218/ DocuSignedby: 6/8/2022 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. `E3ABA14Ac7DC434... Page# DocuSign Envelope ID: C77B83C3-EBD3-4598-A331 -E5813A301 EC3 NPDES yr/mo/day Inspection Type (Cont.) NC0007064 I11 12I 22/05/26 117 18 i c i Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) A compliance inspection of the Brunswick Steam Electric Plant was performed on May 26, 2022. The purpose of the inspection was to verify that the facility is operating in compliance with the conditions and limitations specified within Permit NC0007064. Present during the inspection were Don Safrit, Drew Petrusic, Charles Wilson (ORC), Eric Caison and Randy Hawkins with Progress Energy as well as Bryan Lievre with NCDEQ. The permit provides for the following outfalls: 1. Outfall 001, which is generally plant cooling water but also includes flow from Internal Outfalls 003, 005, 006, 010, 011 and 012. For Outfall 001, from December 1, 2019 through March 31, 2022, the maximum daily flows were equal to the permit limits for each period. The average daily flows for each period were very close to (i.e., within 7%) or at the maximum permitted flow, although an exceedance was not reported. During the same period, the reported pH in Outfall 001 ranged from 7 to 8.1 with an average of 7.8 which is also within the established permit limits. No detectable levels of total residual chlorine were reported at this location during this period. Thermal Reports from 11/24/2020, 2/4/2021, 11/10/2021 and 2/16/2022 were reviewed and found to be within permitted limits as described in permit condition A.(1); 2. Outfall 003 has three Radwaste Treatment Systems, although the waste from all is intermittent and eventually flows from the same discharge line. Sampling conducted in November 2020 and 2021 indicates that results for this outfall are in compliance with established permit limits; 3. Outfall 004 was for a wastewater treatment system which has been removed from the facility and the effluent line has been filled with concrete. The current permit application has requested the removal of this outfall from the future permit and the Wilmington Regional Office concurs with this request; 4. Outfall 005 is a Drain Holding Facility (DHF) which has replaced a legacy Drain Stabilization Pond. The primary input into the pond will be surface water runoff. The 4.2 acre, approximately 4 million gallon pond was under construction during the recent inspection. The pond is being constructed with various liners and will discharge into the intake canal; 5. Outfall 006 is for the discharge of treated metal cleaning wastes and has not been utilized during this permit cycle (i.e., since prior to April 6, 2018); 6. Outfall 010 is for the Support Facilities WWTF. This is a 0.150 million gallon per day (mgd) which includes 12 lift stations (only four of which pump directly to the WWTF), three fine screens, four sequencing batch reactors, an effluent flow meter, two disc filters and two UV disinfection units. The system also has two aerated sludge basins and a sludge thickening system. The average monthly flow for Outfall 010 from 12/2019 through 3/2022 was 0.012 mgd with a maximum recorded monthly flow of 0.028 mgd (permitted at 0.150 mgd). Outfall 010 had an average BOD5 of 4.76 mg/L with a maximum of 18 mg/L and an average TSS of 6.35 mg/L with a maximum of 36 mg/L over the same period; 7. Outfall 011 is for a Storm Drain Stabilization Pond (SDSP). There are eight intermittent and routine sources which are routed to this outfall. Potential discharges include those from an Auxiliary Boiler System, HVAC Cooling Towers, a Demineralized Water System, a Standby Liquid Control Test Tank, Turbine Building Closed Cooling Water, Diesel Generator Cooling Water System, Maintenance Activities and an Independent Spent Fuel Storage Installation (ISFI). Outfall 005 can receive the same inputs described above when the SDSF is not available and Outfall 012 can also be routed to the Storm Drain Stabilization Facility. Discharge from Outfall 011 is into the intake canal. From 12/2019 through 3/2022 was approximately 0.552 mgd (when discharging), total suspended solids were 7.02 mg/L on average, and sampling results for oil and grease were typically non -detectable, with a high of 5.7 mg/L; and, Page# DocuSign Envelope ID: C77B83C3-EBD3-4598-A331 -E5813A301 EC3 Permit: NC0007064 Owner -Facility: Brunswick Steam Electric Plant Inspection Date: 05/26/2022 Inspection Type: Compliance Evaluation 8. Outfall 012 is for discharge of the Groundwater Well Extraction System. This system recovers groundwater with tritium levels of concern from the area of the former Storm Drain Stabilization Pond. The outfall is typically directed to the intake canal, but can be directed to Outfall 005. A review of monitoring records indicates that the system has not had any violations since the most recent permit was issued on 4/6/2018. The staff were extremely knowledgeable of the facility and the facility seemed to be well maintained and operated. The facility is compliant with the discharge Permit NC0007064. Please review the comment sections of the inspection report for more details. Page# DocuSign Envelope ID: C77B83C3-EBD3-4598-A331 -E5813A301 EC3 Permit: NC0007064 Owner -Facility: Brunswick Steam Electric Plant Inspection Date: 05/26/2022 Inspection Type: Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new ■ ❑ ❑ ❑ application? Is the facility as described in the permit? ❑ ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ ❑ ❑ ❑ Is access to the plant site restricted to the general public? ■ ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? ■ ❑ ❑ ❑ Comment: The current permit expires 11/30/2022 and staff have submitted a renewal application A copy of the application, dated 5/23/22, was provided for WiRO during the inspection. Permit conditions include varying discarge flow limits depending upon the time of year and electrical demand, annual reports of results to minimize organism impingment and entrainment at a diversion fence, the number of fine mesh screens in place to prevent high differential pressures at the Circulating Water Intake Pumps (CWIPs), total residual chlorine at the Caswell Beach Pump Station and thermal plume monitoring. Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? ■ ❑ ❑ ❑ Is all required information readily available, complete and current? ■ ❑ ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? ■ ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? ■ ❑ ❑ ❑ Is the chain -of -custody complete? ■ ❑ ❑ ❑ Dates, times and location of sampling ■ Name of individual performing the sampling ■ Results of analysis and calibration ■ Dates of analysis ■ Name of person performing analyses ■ Transported COCs ■ Are DMRs complete: do they include all permit parameters? ■ ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ ■ ❑ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified ■ ❑ ❑ ❑ operator on each shift? Is the ORC visitation log available and current? ■ ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? ■ ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility ■ ❑ ❑ ❑ classification? Is a copy of the current NPDES permit available on site? ■ ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ ■ ❑ Page# 4 DocuSign Envelope ID: C77B83C3-EBD3-4598-A331 -E5813A301 EC3 Permit: NC0007064 Inspection Date: 05/26/2022 Record Keeping Owner -Facility: Brunswick Steam Electric Plant Inspection Type: Compliance Evaluation Yes No NA NE Comment: Greater than 10 vears worth of records are maintain on -site. The system has an ORC and three back-up operators with the appropriate certification. The system maintains lab certification number 5052 for performing field test parameters and utilize Envirochem for most other lab analyses. A recommendation was made to include additional information on COC to be sumbitted to Envirochem, including number of containers, type of containers, preservatives, etc. Compliance Schedules Is there a compliance schedule for this facility? Is the facility compliant with the permit and conditions for the review period? Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Comment: A review of monitoring records indicates that the system has not had any violations since the most recent permit was issued on 4/6/2018. Other Yes No NA NE Comment: The permit includes a diversion fence at the mouth of the intake canal as well as an intake structure which includes coarse trash racks and effluent then flowing though rotating 42 fine mesh screens and eight (8) coarse mesh screens for each of the four (4) Circulating Water Intake Pumps (CWIPs). The intake system also includes lower Pressure spray to wash organisms and higher pressure spray to wash remaining debris off the screens and back into an estuarine area of the Lower Cape Fear River by a gravity aqueduct system. The intake system appeared to be functioning properly during the inspection. Lagoons Yes No NA NE Type of lagoons? # Number of lagoons in operation at time of visit? 2 Are lagoons operated in? # Is a re -circulation line present? ❑ ❑ ❑ Is lagoon free of excessive floating materials? ❑ ❑ ■ ❑ # Are baffles between ponds or effluent baffles adjustable? ❑ ❑ ■ ❑ Are dike slopes clear of woody vegetation? 0 ❑ ❑ ❑ Are weeds controlled around the edge of the lagoon? 0 ❑ ❑ ❑ Are dikes free of seepage? ❑ ❑ ❑ ■ Are dikes free of erosion? ■ ❑ ❑ ❑ Are dikes free of burrowing animals? ❑ ❑ ❑ # Has the sludge blanket in the lagoon (s) been measured periodically in multiple ❑ ❑ ■ ❑ locations? # If excessive algae is present, has barley straw been used to help control the growth? ❑ ❑ 0 ❑ Is the lagoon surface free of weeds? ■ ❑ ❑ ❑ Page# 5 DocuSign Envelope ID: C77B83C3-EBD3-4598-A331 -E5813A301 EC3 Permit: NC0007064 Inspection Date: 05/26/2022 Lagoons Is the lagoon free of short circuiting? Owner -Facility: Brunswick Steam Electric Plant Inspection Type: Compliance Evaluation Yes No NA NE ❑ ❑ ❑ ■ Comment: The two laqoons mentioned above refer to those associated with Outfalls 005 and 011. The lagoon for Outfall 005 is called the Drain Holding Facilty (DHF) which is a low volume waste pond which has replaced the Storm Drain Stabilization Pond. The lagoon was under construction during the visit and is being constructed with liners and will be approx. 4 million gallons and discharges into the intake canal, as needed. The lagoon associated with Outfall 011 is called the Storm Drain Stabilization Facility Pond (SDSF) and is approix. 6 millions gallons and discharges on a weekly basis during normal operation to the intake canal. An average daily flow of approx. 0.552 mqd was intermittently discharged from Outfall 011 from 12/1/2019 through 3/31/2022. The SDSF is a lined pond with black plastic "balls" to prevent algal growth and inhibit evaporation. Pump Station - Influent Yes No NA NE Is the pump wet well free of bypass lines or structures? ■ ❑ ❑ ❑ Is the wet well free of excessive grease? 0 ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? 0 ❑ ❑ ❑ Are float controls operable? 0 ❑ ❑ ❑ Is SCADA telemetry available and operational? 0 ❑ ❑ ❑ Is audible and visual alarm available and operational? 0 ❑ ❑ ❑ Comment: Above information is in regards to Lift Station No 11, which was inspected during recent activities. Lift Station No. 11 is a duplex pump station that is located northwest of the WWTF and is one of 12 lift stations that serve the Support Facilities WWTF, although only four lift stations (#'s 3, 6, 11 & 16) pump directly to the WWTF. Bar Screens Type of bar screen a.Manual b.Mechanical Are the bars adequately screening debris? Is the screen free of excessive debris? Is disposal of screening in compliance? Is the unit in good condition? Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: The WWTF has three fine screen units installed in parallel with overflow to each of the subsequent SBR units. One of the screen systems was off-line awaiting replacement parts at the time of inspection. The units have internal brushes that push solids to an auger and the solids then travel to a container and are disposed of as low level radioactive waste (simply as a precaution). Page# 6 DocuSign Envelope ID: C77B83C3-EBD3-4598-A331 -E5813A301 EC3 Permit: NC0007064 Owner -Facility: Inspection Date: 05/26/2022 Inspection Type: Brunswick Steam Electric Plant Compliance Evaluation Sequencing Batch Reactors Yes No NA NE Type of operation: Duplex Is the reactor effluent free of solids? M ❑ ❑ ❑ Does minimum fill time correspond to the peak hour flow rate of the facility? ❑ ❑ ❑ Is aeration and mixing cycled on and off during fill? ❑ ❑ ❑ The operator understands and can explain the process? ❑ ❑ ❑ Comment: The WWTF has four (4) SBR units with two tvpically in operation at a time. The units typically operate with 15 minutes of aeration and 15 minutes of settling with a DO of between 8.1 to 8.8 mg/L. Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? 0 ❑ ❑ ❑ Is flow meter calibrated annually? 0 ❑ ❑ ❑ Is the flow meter operational? 0 ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ 0 ❑ Comment: The system has two influent flow meters for internal purposes and are not utilized for reporting purposes. The effluent flow meter (4" diam pipe magmeter) is located after the SBR units and is used for reporting purposes. The meter was last calibrated 11/9/2021 by C. Wright Instruments, Inc. Filtration (High Rate Tertiary) Type of operation: Is the filter media present? Is the filter surface free of clogging? Is the filter free of growth? Is the air scour operational? Is the scouring acceptable? Is the clear well free of excessive solids and filter media? Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Comment: The WWTF has two high -rate disc filters set up in parallel. The filters have a stainless steel filters and backwash is sent to Lift Station No. 11. 25% sodium hydroxide is infected into the disc filters for pH control. Disinfection - UV Are extra UV bulbs available on site? Are UV bulbs clean? Is UV intensity adequate? Is transmittance at or above designed level? Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ Page# 7 DocuSign Envelope ID: C77B83C3-EBD3-4598-A331 -E5813A301 EC3 Permit: NC0007064 Inspection Date: 05/26/2022 Disinfection - UV Is there a backup system on site? Is effluent clear and free of solids? Owner -Facility: Brunswick Steam Electric Plant Inspection Type: Compliance Evaluation Yes No NA NE ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ Comment: The WWTF has two UV units, set up in parallel, and each unit has three bulbs. The system tries to maintain 3 spare bulbs on -site. Aerobic Digester Yes No NA NE Is the capacity adequate? ❑ ❑ ❑ ■ Is the mixing adequate? 0 ❑ ❑ ❑ Is the site free of excessive foaming in the tank? 0 ❑ ❑ ❑ # Is the odor acceptable? 0 ❑ ❑ ❑ # Is tankage available for properly waste sludge? 0 ❑ ❑ ❑ Comment: The WWTF has two aerated sludqe tanks, set up in parallel. The WWTF system is also equipped with a sludge thickening system including a screw press, an electric drier unit, an auger assembly that conveys solids to a holding container. Liquids from the drying process are discharged into Lift Station 11 and solids are disposed as low-level radioactive waste (as a precaution). Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: The WWTF is checked daily for pH, DO & settleability and mixed liquor is checked weekly. Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? Yes No NA NE ❑ ❑ ■ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Comment: Composite sampling is not required for any of the outfalls for the current permit. Pump Station - Effluent Yes No NA NE Is the pump wet well free of bypass lines or structures? 0 ❑ ❑ ❑ Page# 8 DocuSign Envelope ID: C77B83C3-EBD3-4598-A331 -E5813A301 EC3 Permit: NC0007064 Inspection Date: 05/26/2022 Owner -Facility: Brunswick Steam Electric Plant Inspection Type: Compliance Evaluation Pump Station - Effluent Yes No NA NE Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? ❑ ❑ ❑ Are float controls operable? ❑ ❑ 0 ❑ Is SCADA telemetry available and operational? 0 ❑ ❑ ❑ Is audible and visual alarm available and operational? ❑ ❑ 0 ❑ Comment: The WWTF discharges into a storm drain that drains into the effluent channel at the entrance to the plant. All combined effluent then flows through a 5.4-mile long effluent channel to Caswell Beach. I siphon system allows the effluent to flow under the Intracoastal Waterway and this structure is reportedly inspected by others with the facility. The pump station at Caswell Beach is equipped with eight pumps with large trash racks to screen large debris. The pumps discharge the effluent into a submerged pipe in the Atlantic Ocean, south of the Caswell Beach pump station. The trash racks are manually cleaned and appeared in good condition during the inspection. The facility montors the level within the discharge canal. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? ■ ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ Comment: Standby Power Yes No NA NE Is automatically activated standby power available? ■ ❑ ❑ ❑ Is the generator tested by interrupting primary power source? 0 ❑ ❑ ❑ Is the generator tested under load? 0 ❑ ❑ ❑ Was generator tested & operational during the inspection? 0 ❑ ❑ ❑ Do the generator(s) have adequate capacity to operate the entire wastewater site? ■ ❑ ❑ ❑ Is there an emergency agreement with a fuel vendor for extended run on back-up 0 ❑ ❑ ❑ power? Is the generator fuel level monitored? 0❑ ❑ ❑ Comment: The emergency generator is capable of powering the WWTF as well as Lift Station 11. Page# 9