HomeMy WebLinkAboutNC0039586_Permit Application Amendment_20120425&4? Progress Energy
APR 2 5 2012
Mr. Jeffrey O. Poupart
North Carolina Department of Environment and Natural Resources
Division of Water Quality
16.17 Mail Service Center
Raleigh, NC 27699-1617
SERIAL: HNP -12-053
Subject: Carolina Power & Light Company, doing business as Progress Energy Carolinas, Inc.
Harris Nuclear Plant NPDES Permit No. NCO039586
Permit Application Amendment
Dear Mr. Poupart:
The current NPDES permit for the Harris Nuclear Plant (HNP) located in Wake County expired on July 31,
2011, and a renewal application is now under review by your staff. HNP would like to amend the current
expired NPDES permit application as well as the NPDES permit application under review by your staff to
reflect a change occurring at the plant.
As part of HNP's re -fueling outage (RFO-17), the plant will experience a power uprate. There will be an
increase in electrical power from 900 megawatts to 979 megawatts when the plant returns to service.
Enclosed is an amended Attachment 4 — Form 2C — Item II -B Flows, Sources of Pollution and Treatment
Technologies reflecting this power change: The amendment is provided for your information. We do not
expect the change will necessitate a permit modification.
If you have any questions regarding the enclosed information, please feel free to contact Steve Cahoon at
(919) 546-7457 or steve.cahoon@ponmail.com.
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.
EJK/mgw
Enclosure
Progress Energy Carolinas, Inc.
Harris Nuclear Plant
P. 0. Box 165
New Hill, NC 27562
Sincerely,
5LO�i
rnest J. Kapopoulos, Jr.
Plant General Manager
Harris Nuclear Plant
s o�
APR 3 0 2012
Division of Water Quality
SERIAL: HNP -12-053
Enclosure
Attachment 4 - Form 2C
Progress Energy Carolinas, Inc.
Harris Nuclear Plant and Harris Energy & Environmental Center
National Pollutant Discharge Elimination System Permit Number NC0039586
Attachment 4
Form 2C --Item II -B Flows, Sources of Pollution, and Treatment Technologies
HARRIS NUCLEAR PLANT
The Harris Nuclear Plant (HNP) consists of a 979 MW generating unit and associated facilities.
The HNP systems include a Westinghouse pressurized water reactor, three re -circulating steam
generators, a turbine generator, a one -pass condenser, an open re -circulating (cooling tower)
cooling water system, and a lake to makeup water lost by evaporation. In a pressurized water
reactor design, steam .is produced in the secondary system steam generators using hot water from
the reactor core. The primary system does not normally come into contact with any other part of
the generating system, such as the steam cycle which includes the turbine and the condenser.
Outfall 006 — Combined Outfall to Harris Lake
The HNP operates on an open re -circulating cooling system using a natural draft cooling tower
and 4100 acre makeup water storage reservoir. All five major wastewater discharges at the HNP
are combined in a 36 -inch diameter common pipe which discharges to the Harris Lake 500 feet
offshore at 40 feet below the surface (Discharge Serial No. 006 in this application.) The
individual waste streams contributing to the common outfall pipe are: cooling tower blowdown,
sanitary waste treatment plant effluent, metal cleaning wastes, low-volume wastes, and radwaste
system. (These waste streams are enumerated in the present permit as Discharge Serial Numbers
001, 002, 003, 004, and 005, respectively.) Toxicity testing has been conducted on the combined
outfall line since February 1990. Each of the waste streams, as well as miscellaneous discharge
points, are described in this narrative. Also included is a list of chemicals which are expected to
be in waste streams from the HNP (Attachment 5).
Outfall 001 - HNP Cooling Tower Blowdown discharge to Outfall 006
The cooling tower provides the condenser with a supply of water for removing the heat rejected
by the condensation of steam. (The circulating water temperature rise across the condenser is
25T.) This heat is dissipated primarily by evaporation as the water falls through the tower. This
evaporation is essentially pure water vapor, with the dissolved and suspended solids remaining to
concentrate.
To prevent the solids from causing scale and corrosion problems, some of the concentrated
cooling water is discharged from the cooling tower basin, i.e., blowdown. During plant
operation, the cooling tower basin continuously discharges for optimum performance.
Blowdown currently averages approximately 6 MGD. Makeup water for cooling tower
evaporative losses and cooling tower blowdown is provided from the main reservoir. The
cooling tower also serves as a partial source of service water, which is used for non -contact
cooling of auxiliary equipment throughout the plant. The cooling tower is infrequently drained
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Progress Energy Carolinas, Inc.
Harris Nuclear Plant and Harris Energy & Environmental Center
National Pollutant Discharge Elimination System Permit Number NCO039586
for maintenance. The normal operating procedure includes draining the residual water to the
lake via Discharge Serial No. 006.
Occasionally, the condensers are drained for maintenance and repairs. When the condensers are
drained, it is necessary to route the residual water (approximately 60,000 gallons per condenser
per event) to area storm drains which discharge to the lake. This water is monitored prior to
discharge for appropriate parameters required for cooling tower blowdown in accordance with
the NPDES permit. Presently, condenser draining events are reported with relevant monitoring
data to DWQ on attachments to monthly Discharge Monitoring Reports.
Outfall 002 - HNP Sewage Treatment Facility discharge to Outfall 006
A 0.025 MGD extended aeration sewage treatment facility serves the HNP. The facility consists
of an equalization basin, aeration basin, sludge holding tanks, raw sewage holding tank,
clarifiers, and chlorine contact tanks. Disinfected effluent is pumped through a newly installed
sand filter (added to help with TSS issues) to common outfall pipe. Currently, sludge is land
applied off site by a contract disposal firm (Granville Farms, Inc., Permit No. WQ0000838).
Because the HNP sewage treatment facility receives industrial type waste as well as domestic
type waste, the land application of the mixed sludge meets the exemption conditions stipulated in
40 CFR Part 503.6.
In addition to sanitary waste, HVAC condensate is discharged to the sewage treatment facility.
Outfall 003 - HNP Metal Cleaning Wastes discharge to Outfall 006
Infrequently, cleaning of heat exchanger equipment by chemical solutions may be necessary.
Cleaning solutions would be routed to the waste neutralization basin for pH adjustment
(or other chemical neutralization) prior to discharge to the settling basin where further treatment
by sedimentation occurs. To date, the only metal cleaning which has been conducted
was a preoperational flush. If a new system is added in the future or if an existing system is
changed out, flushing could be necessary again. Also, metal cleaning may be needed in the
future for plant systems' (e.g., steam generators, auxiliary boilers, piping, etc.). Chemical
solutions used may include phosphates, organic cleaners, citric acid, or oxalic acid.
Outfall 004 - HNP Low -Volume Wastes discharge to Outfall 006
In the operation of the HNP, there are many processes which result in intermittent low volumes
of various waste streams. Low-volume waste is treated by neutralization (for pH adjustment),
sedimentation, and separation. These wastes may be treated in the oily waste separator and/or
neutralization basin as needed prior to routing to the sedimentation basin, which ultimately
discharges to the common outfall line. Annually as a maintenance practice this basin may be
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Progress Energy Carolinas, Inc.
Harris Nuclear Plant and Harris Energy & Environmental Center
National Pollutant Discharge Elimination System Permit Number NC0039586
physically cleaned using. chlorine, a bisulfate is added after cleaning to remove the chlorine
before discharge. Chemicals present in these systems may include corrosion products (such as
copper and iron) corrosion inhibitors (such as nitrites, molybdates, ammonia, hydrazine,
carbohydrazide, and ethanolamine), acids and bases from water treatment processes, and
wastewater from ion exchange processes and ammonium bisulfite from dechlorination. Low-
volume waste flow from the settling basin averages approximately 0.2 MGD. The various low-
volume waste sources are described below:
a) Water treatment system wastes from processing of demineralized water and potable
water.
(The water treatment system includes coagulation, filtration, disinfection, and ion
exchange. Wastes from treatment include filter backwash and demineralizer regeneration
wastes.)
b) Non -radioactive oily waste, floor drains, and chemical tank containment drains.
(Turbine building wastes which could contain oil are routed to the oily waste separator
for treatment prior to routing to the neutralization basin. Used oil is collected by a
contractor for reclamation.)
C) Steam generator and auxiliary boiler draining following wet layup
d) Non -radioactive secondary waste from condensate polishers
e) Miscellaneous drains/leaks from condenser, steam generator, and secondary components
f) Auxiliary boiler system blowdown
g) Miscellaneous waste streams not otherwise identified elsewhere in this application.
Outfall 005 - HNP Radwaste Treatment System discharge to Outfall 006
The radwaste system is designed to collect, store, process, and release any radioactive or
potentially radioactive liquids associated with operation of the nuclear power plant. The waste
streams are collected in tanks and sampled for conventional pollutants and radioactivity. The
specific batch treatment is selected based on these analytical results. This allows for selection of
the proper treatment processes for each individual batch. Most radwaste streams are treated by
the Modular Fluidized Transfer Demineralization System (MFTDS) that uses filtration and ion
exchange in a manner that minimizes the production of solid wastes. Boric acid is recycled. The
secondary waste system (SWS) is for treating radioactively -contaminated water from the
secondary steam cycle system; however, since that system is not normally contaminated, those
flows are routed to the normal low-volume waste treatment system after radiological monitoring.
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Progress Energy Carolinas, Inc.
Harris Nuclear Plant and Harris Energy & Environmental Center
National Pollutant Discharge Elimination System Permit Number NC0039586
After treatment, the radwaste flows are stored in one of four tanks: the secondary waste sample
tank, the treated laundry and hot shower tank, the waste monitor tank, or the waste evaporator
condensate tank. After monitoring to verify adequate treatment, the tanks are discharged to the
common outfall line.
The cooling tower bypass line provides a flow of lake water for radwaste releases, as regulated
by the NRC.
Other HNP Discharges
1. Storm Drains
Runoff from parking lots, outside storage areas, roof drains, and other areas on the plant
site are collected in storm drains and ultimately routed to release points which discharge
to Harris Lake. Flow contributed from those areas is estimated at 8.8 million gallons
per month, based on average rainfall of 43 inches per year and a runoff assumption factor
of 0.7.
In addition to stormwater, a few miscellaneous sources of water are also intermittently
routed to the storm drains. These sources that have a minor contribution to overall storm
drain flows are as follows:
a. Upflow filter clear well drains
The upflow filter clearwell stores filtered lake water which is used in the potable
water treatment system. Periodically, some of the water from this tank is drained
to the storm drains that discharge to Harris Lake. This water may contain low
concentrations of chlorine because sodium hypochlorite is added to control
biological growth in the tank prior to treatment through the upflow filter.
b. Heat exchanger on the demineralizer feedwater
It is necessary to heat the source water to the demineralized water treatment
system to achieve optimum degassification. To accomplish this, steam is used to
heat the feedwater. The condensed steam is discharged to the storm drains that
flow to Harris Lake at approximately 5 - 10 gallons per minute. This steam could
contain trace amounts of hydrazine and ammonia used for chemistry control in the
auxiliary boiler steam system. Due to the low flow rate and the long retention
time, the temperature of the condensed steam should be at ambient temperature
upon reaching the lake.
C. Condenser water box drains
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Progress Energy Carolinas, Inc.
Harris Nuclear Plant and Harris Energy & Environmental Center
National Pollutant Discharge Elimination System Permit Number NCO039586
Prior to condenser maintenance or repairs it is sometimes (approximately
twice/year) necessary to drain circulating water to the storm drains
(approximately 60;000 gallons per condenser per event) that discharge to Harris
Lake. This water is monitored for selected cooling tower blowdown parameters.
d. Filtered water stora eg tank
Water from the upflow filter clearwell is treated using a micro -filtration unit for
turbidity control and then stored in a tank prior to subsequent filtration (nano-
filtration unit) and disinfection. Occasionally, some water from this tank may be
drained to the storm drains that discharge to Harris Lake. This water may contain
trace amounts of chlorine.
Fire protection system
Approximately 5000 gallons of lake water used for annual testing of the fire
protection system is routed to most of the storm drains that discharge to Harris
Lake. In the event of a fire, additional water could be discharged to storm drains.
f. Condenser hotwell
During outages (approximately once per 18 months) it is necessary to drain the
condenser hotwell for condenser maintenance and inspection. Approxmiately
70,000 gallons of this water resulting from condensed steam is drained to storm
drains that discharge to Harris Lake. It may contain trace amounts of
ethanolamine, 100 ppb or less of boron, and 100 ppb or less ammonia.
g. Condensate storage
Infrequently it is necessary to drain the condensate storage tank for maintenance.
Approximately 400,000 gallons per event is drained to storm drains that discharge
to Harris Lake. It may contain 200 ppb or less boron, 1000 ppb or less ammonia,
and trace hydrazine.
h. Air conditioning system condensate
The condensate from various building air conditioning systems flows to various
storm drains to Harris Lake. The volume is generally low and is greatest in the
humid summer months.
i. Service water system strainers
Infrequently, when service water strainers located at the makeup pumps from the
Progress Energy Carolinas, Inc.
Harris Nuclear Plant and Harris Energy & Environmental Center
National Pollutant Discharge Elimination System Permit Number NCO039586
cooling tower basin are backwashed to remove biofouling organisms or debris, a
small volume of service water overflows the basin and runs to the adjacent storm
drain that discharge to Harris Lake.
j. Maintenance Activities
During maintenance activities at the facility it may become necessary to drain all
or some portion thereof of the following plant systems; normal service water,
emergency service water, circulating water, potable water, and demineralized
water. Maintenance activities at the facility may also require the hydrostatic
flushing of system piping with 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
2. Emergency Service Water System
This system primarily provides non -contact cooling water for nuclear safety-related
equipment systems and during emergency conditions. The emergency service water
system discharges to the auxiliary reservoir which is used as the plant's heat sink during
emergency conditions, a feature required by Nuclear Regulatory Commission regulations
to provide a reliable supply of cooling water. Under normal operating conditions, the
auxiliary and the main reservoirs are isolated from each other; however, the reservoirs
may be connected as necessary. In addition to emergency situations, this system is used
periodically for testing purposes or for containment cooling as needed. This water may
contain traces of chemicals identified for the cooling tower blowdown.
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Progress Energy Carolinas, Inc.
Harris Nuclear Plant and Harris Energy & Environmental Center
National Pollutant Discharge Elimination System Permit Number NC0039586
HARRIS ENERGY & ENVIRONMENTAL CENTER
The Harris Energy & Environmental Center (HE&EC) includes facilities that provide support
services (laboratories and training classrooms) for the HNP and other CP&L operations. The
sources of wastewater at the HE&EC are domestic waste, conventional laboratory waste, cooling
tower blowdown, and potentially radioactive liquid waste from the radiochemistry and
metallurgy laboratories. Additionally, floor drains from several shops and storage buildings are
routed to the wastewater treatment facility. All waste streams, with the exception of the
radiological wastewater, receive treatment in the 0.020 MGD wastewater facility.
Components of the treatment facility include a bar screen, submersible pump station as an
influent pump station, three treatment ponds, sand filtration, chlorination and dechlorination, as
well as the various lift stations for the HE&EC's various buildings. The pond portion of the
treatment facility consists of an aerated pond with a minimum retention time of 10 days followed
by a stabilization pond, also with a minimum retention time of 10 days. The third pond is a
polishing pond with a minimum 2 -day retention time. Effluent from the treatment facility is
discharged via the effluent discharge pipe into Harris Lake.
If necessary sludge from the treatment facility will be removed and land applied by a contractor
(a contractor for sludge disposal will be chosen when needed). Because the treatment facility
receives industrial type waste as well as domestic type waste, the land application of the mixed
sludge meets the exemption conditions stipulated in 40 CFR 503.6
Domestic Waste
The maximum domestic waste flow from the HE&EC sanitary facilities is approximately 0.014
MGD. In addition to the approximately 235 permanent employees on the site, the HE&EC,
serving as a company training facility and as a visitors' center for the nearby Harris Nuclear
Plant, accommodates a fluctuating population (ranging from 0 to 450 additional people per day).
Laboratory Waste
Laboratory waste flow, consisting primarily of rinse water from the chemical, metallurgical, and
biological laboratories, is approximately 0.001 MGD. HE&EC personnel are educated in the
proper disposal of laboratory wastes and are encouraged to minimize the use of laboratory drains
for chemical disposal. Most laboratory chemical wastes .and virtually all oily wastes are
drummed for off-site disposal. Laboratory wastes that are not drummed may go to one of two
5,000 gallon holding/neutralization tanks for visual inspection and testing before being
discharged to the influent pump station.
Cooling Tower Blowdown
Cooling tower blowdown from the HE&EC air conditioning system averages approximately
0.002 MGD. Chemical additives include an algicide (aqueous glutaraldehyde solution) and a
Progress Energy Carolinas, Inc.
Harris Nuclear Plant and Harris Energy & Environmental Center
National Pollutant Discharge Elimination System Permit Number NCO039586
suspension agent. The treatment and extended retention time in the ponds should ensure no
algicide is discharged to Harris Lake.
Radiological Wastewater
The majority of the radiological wastewater results from the cleaning of laboratory glassware. In
addition, small quantities of liquid radiochemistry laboratory samples, radioactive metallurgy
laboratory wastewater (which is prefiltered with a paper cartridge to remove particulates before
disposal), liquids generated from analyses of plant 10 CFR Part 61 samples, and reagents are
disposed via the HE&EC radiochemistry laboratory drains to a holding tank. Approximately
5,000 gallons are discharged annually from the holding tank, as allowed by the radioactive
materials License No. 092-0218-4, issued by the N.C. Division of Radiation Protection. The
effluent from the radiological holding tank combines with the effluent from the sewage treatment
plant and discharges into Harris Lake.
Radiochemical analyses are performed prior to release to calculate the total activity in the waste.
These analyses include gamma spectrum analysis using intrinsic germanium gamma
spectrometry systems, as well as direct analysis for Tritium, Iron -55, Nickel -63 and Strontium -
89/90. Individual radionuclides have different release limits, however, the total Tritium activity
discharged per calendar year shall not exceed 20 millicuries, and the total activity excluding
Tritium discharge per calendar year shall not exceed 5 millicuries.
Additionally, the pH of the wastewater is determined before release. The pH must be between
six and nine and is adjusted, if necessary, using 50% sodium hydroxide. The tank is agitated
after addition of the sodium hydroxide, and an additional sample is analyzed to verify that the
appropriate pH adjustment is achieved.
Stormwater
Stormwater runoff from the HE&EC is composed of parking lot, roof, and lawn drainage. This
non-iridustrial stormwater is not subject to the Phase I stormwater regulations of 40 CFR Part
122.