NC0039586_Water Treatment Facility Upgrade_20041108

&4? Progress Energy
NOV 0 8 -2004
Mr. Mark McIntire
NCDENR — Division of Water Quality, NPDES Unit
1617 Mail Service Center
Raleigh; -North Carolina 27699-1617
Subject:
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Harris Nuclear Plant POINT SOURCE BRANCH
NPDES Permit Number NCO039586 *� 1
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Water Treatment Facility UpgradeM
Notification of Minor Changes in Waste Discharge to Outfall 004
Dear Mr. McIntire:
Thank you for meeting with Bob Wilson and Steve Cahoon of our staff and Kevin Eberle of
McKim & Creed, P.A. on July 15, 2004, to review Progress Energy's on-going efforts to upgrade
the Harris Nuclear Plant's (HNP) potable water and demineralized make-up water treatment
systems. As was discussed during the meeting, Progress Energy has signed a contract with GE
Osmonics to provide a new membrane water treatment process at the HNP in New Hill, NC. The
new water treatment system will replace the existing potable water and demineralized make-up
water treatment processes at the site. The changes are required in order to comply with
regulatory requirements as defined in the USEPA Long -Term Enhanced Surface Water
Treatment Rule and the Stage 2 Disinfectants and Disinfection Byproducts Rule.
Enclosed is a simplified description of the new system, an updated NPDES Permit NCO039586
Outfall 004 as discussed and the Material Safety Data Sheets (MSDSs) for all of the monitoring
equipment chemical (Hach) tests and process chemicals used with the new drinking water
system.
I trust that this letter is sufficient to allow you to modify our existing NPDES permit and give us
permission to use these chemicals during the testing of the new drinking water system.
If you have any questions or comments concerning this information, please contact Mr. R. T.
Wilson at [phone] or Mr. S. G. Cahoon at [phone].
Progress Energy Carolinas, Inc.
Harris Nuclear Plant
P.O. Box 165
New Hill, NC 27562

Mr. Mark McIntire
Page 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,
B.C. Waldrep
Plant General Manager
Harris Nuclear Plant
MGW
Enclosures

Mr. Mark McIntire
Page 3
Mr. S. G. Cahoon
Mr. M. Hardy
Mr. K. C. Eberle, P.E., McKim & Creed
Mr. B. White, McKim & Creed
Mr. R. T. Wilson
USNRC
Nuclear Records
HNP Licensing File: H -X-230

Mr. Mark McIntire
Page 4
Attachment 1
DESCRIPTION OF PROPOSED WATER TREATMENT SYSTEM IMPROVEMENTS
The proposed new water treatment system consists of a dual -train, dual -barrier membrane
treatment process with pretreatment consisting of screening and chemical pre -oxidation of iron
and manganese. The new system will also include a new 30,000 gallon fiberglass reinforced
plastic _(FRP) potable water clearwell, hydropneumatic pressure distribution system and
disinfection using sodium hypochlorite to maintain free chlorine residual in the distribution
system.
Similarly to the current Harris Water Treatment Systems, the new process will be designed to
produce water for both potable use as well as to produce highly treated make-up water for the
existing Demineralization Process. Potable water is utilized throughout the main facility and is
also used for seasonal cooling at the Harris Energy & Environmental Center. Demineralized
water is used extensively at the facility for process cooling and boiler make-up.
Raw water is,currently withdrawn from Harris Lake using two low lift pumps located in a pump
house on the lake shore. These pumps supply surface water to the cooling tower and also supply
make-up water to the water treatment building. This water is high-quality surface water with
relatively low levels of turbidity and other organics. It is anticipated, that as the lake ages the
turbidity levels and organic loading levels in the lake will increase as result of natural
eutrophication.
Raw water enters the water treatment building through a 10" welded steel pipe at a residual
pressure of 40-45 psi. New potassium permanganate and sodium hypochlorite chemical feed
systems will inject oxidant immediately upstream of a new 100 micron automatically
backwashing strainer (upstream of the microfiltration process) to oxidize and precipitate
naturally occurring soluble iron and manganese in the raw water. The pretreated water will then
pass through the 100 micron automatic backwashing strainer for removal of suspended solids
prior to microfiltration via 0.1 micron PVDF (polyvinylidenefluoride) hollow filter membranes.
A new 6" tapping saddle and valve will be installed directly following the strainers to convey raw
water to the new microfiltration process via a new 6" welded steel pipe using residual pressure
from the low lift pumps.
Two parallel -train, 100 gpm Pall Aria Microfiltration systems and ancillary equipment will
receive pretreated raw water via the new 6" steel piping. The dual train microfiltration process
will be designed to produce 200 gpm of filtered water (100 gpm per train) for potable use and
demineralized supply makeup water. The Pall Microza Microfiltration modules are specially
designed for water processing applications. These modules use proprietary; 0.1 micron rated
PVDF hollow fiber membrane technology with high and stable flux rates and advanced bonding
techniques for an exceptionally strong module design.

Mr. Mark McIntire
Page 5
The Microza Microfilters operate in an outside -in mode with a small amount of recirculation.
Unlike conventional filtration or single pass filtration, where the membrane filter is
perpendicular to feed flow direction and solids are dead end filtered by the media, Microza
microfiltration membranes are placed parallel to the feed direction and only clean liquid passes
through the membrane. Two exit streams are produced during filtration:
• Filtrate (or permeate), which passes through the process and into a downstream holding
tank (called "Filtrate Break Tank on the P&ID Drawing);
• Recirculated raw water consisting of approximately 10% of the forward flow. This raw
water is returned to the feed stream from the top of the module and ensures complete
utilization of the available filter area by increasing the velocities in the upper end of the
module and removing any air that might get trapped at the top of the housing. Solids
retained on the filter are removed via periodic backwashing, air scrubbing, chemically
enhanced backwashing, and periodic chemical clean -in-place (monthly basis).
When the flux, is reduced, as evidenced by a transmembrane pressure drop, then the
microfiltration system programmable logic controller (PLC) will signal the individual Microza
train to initiate a backwash procedure. Each train will intermittently backwash, (typically once
every 20 minutes for approximately 1.5 minutes); however, time between backwashes varies
depending upon the quality of the raw water being fed to the microfiltration trains.
In addition to the PLC -initiated backwash cycle, the microfiltration skids will also be equipped
with an operator initiated clean -in-place (CIP) process which the operator will schedule regularly
(typically once every 20 days or less frequently if transmembrane pressure returns to normal after
backwash cycles) to extend membrane life. The CIP process removes embedded matter from the
membrane, and will restore the membrane flux and transmembrane pressure back into the
original design range. The CIP process is a two step sequence consisting of a citric acid cycle
and a sodium hypochlorite/sodium hydroxide cycle. These two cycles will consist of 20 minutes
of circulation, 20 minutes of soaking, and a 20 minute flush period. The CEP will restore the
membranes to their design flux level and transmembrane pressure.
The filtrate from the microfiltration process will discharge, under pressure, into a 2,500 gallon
high density polyethylene (HDPE) break tank that will serve as supply reservoir for the
downstream nanofiltration system. This tank will be equipped with an ultrasonic level sensor that
will communicate continuously with the system master PLC. This PLC will continuously
monitor liquid level in the break tank and will automatically pace the microfiltration feed pump
variable frequency drives (VFD) to maintain the pre -established set point -level in the tank.
However, if levels increase to the Operator -selected "high water" set point elevation, then the
master PLC will take both microfiltration trains off line. The master PLC will restore
microfiltration operation once water level in the break tank falls below the Operator -selected
"system restore" water level in the tank. Likewise if water levels fall below the "minimum level"
setpoint water elevation, then the PLC will send a "system failure" to the Harris Supervisory
Control and Data Acquisition (SCADA) system.

Mr. Mark McIntire
Page 6
Two new GE Osmonics nanofiltration trains will be installed in parallel, directly downstream of
the microfiltration process and will take suction from the new HDPE break tank. The
nanofiltration trains will be designed to produce finish water with total organic carbon (TOC)
concentrations of less than 1.5 ppm based on a maximum raw water TOC concentration of 10
ppm or less. This TOC reduction will minimize disinfection byproduct formation in the
distribution system and allow Harris to maintain their use of free -chlorine disinfection. The two
parallel nanofiltration trains have each been designed for an average flow of 100 gpm (125 gpm
peak flow) in order to meet Harris Nuclear Plant's maximum daily demand for potable water and
demineralizer makeup.
The nanofiltration system will be fed by VFD-controlled pumps that will draw pretreated water
from the microfiltration break tank. Water will flow, under 100 psi pressure through the
nanofiltration membranes and colloidal particles, soluble organic molecules, and soluble cationic
metals (calcium, magnesium, iron, manganese and aluminum) will be concentrated on the
upstream side of the membranes and the finish water will pass through the membranes into either
the potable water clearwell or the demineralizer make-up "finish water storage tank".
Nanofiltration technology utilizes semi -permeable membranes to perform the function of
removing dissolved organic molecules and large ions in solution. The technology functions on
the basis of diffusion. In the diffusion process water moves from an area with high concentration
of organic molecules (or inorganic ions) through a semi -permeable membrane to an area of lower
concentration in an attempt to maintain chemical equilibrium on both sides of the membrane.
Nanofiltration utilizes diffusion -under -pressure to cause water to diffuse through a semi-
permeable membrane in a "reverse flow" direction in order to concentrate contaminants (i.e.
organic molecules and inorganic cations) on one side of the membrane while allowing water
molecules to pass through the' membrane to produce a high-quality product water. The
concentrated contaminants are said- to be "rejected" by the' membrane and are continuously
wasted from the process to optimize membrane performance.
Nanofiltration uses a forward flow "flushing" process as opposed to the "backwash procedure"
typical of microfiltration. In addition to continuous flushing, nanofiltration (NF) treatment
technologies require regular cleaning via chemically enhanced flushing and periodic CIF's to
maintain their capacity to produce finish water at the desired flux rate. During normal operation,
the NF system will gradually see reduced throughput of water and increased transmembrane
pressure as the membrane becomes fouled with contaminants. Since the system PLC
continuously monitors transmembrane pressure (TMP), it automatically triggers a chemically -
enhanced cleaning cycle whenever the TMP exceeds the pre -established "maximum" pressure.
During the chemically -enhanced cleaning process one entire nanofiltration train will be
temporarily taken off-line until the cycle has completed. However, the PLC will ensure that the
cleaning cycles are staggered between the two trains to ensure a minimum production of 100 gpm
at all times.

Mr. Mark McIntire
Page 7
Finish water from the nanofiltration system will flow into either the 0.5 million gallon
demineralized makeup "Filtered Water Storage Tank" (FWST) or the new FRP "Potable Water
Clearwell" (PWC) depending on automatic valve sequences. Finish water will normally flow to
the 0.5 MG FWST (to serve as makeup for the demineralized water process) but will
automatically be diverted, (via motorized butterfly valves) to the potable water clearwell
whenever liquid level falls below the established "minimum" liquid level setpoint. When the
potable water clearwell level reaches the "maximum" set point elevation, flow will automatically
be restored to the FWST. If both the FWST and the potable water clearwell reach their
respective "maximum" levels, the system master PLC will automatically shut down both the
nanofiltration and microfiltration processes. Flow will be automatically restarted whenever
liquid levels in either tank fall to the pre -selected "system restore" elevations.
Each of the tanks will be equipped with new ultrasonic level sensors that measure the level of
water in each tank and transmit a 4-20 mA analog signal that is proportional to the level (in feet)
to the system master PLC. The master PLC will automatically open or close the two motorized
butterfly valves located on the supply lines feeding the FWST and the new 30,000 gallon potable
water clearwell in response to the actual water elevations in each tank. The potable water
clearwell will have precedence over the FWST and will be filled preferentially.
After the dual barrier microfiltration -nanofiltration process, the finished water will contain only
soluble anions and low -molecular weight organics. Therefore, since precursors to disinfection -
by -products will be removed, the potable water can be safely disinfected via injection of sodium
hypochlorite prior to the Potable Water Clearwell. A continuous on-line total chlorine residual
monitor will measure free chlorine concentrations in the finish potable water prior to distribution
and will report the results via a proportional 4-20 mA signal to the system PLC. The PLC will
automatically adjust the sodium hypochlorite feed in order to maintain chlorine residual levels in
the distribution system at 1.5 to 2.5 ppm. Sodium hydroxide (for alkalinity and pH adjustment)
and zinc polyphosphate (fof metallic pipe protection) -will be added to the finish water in order to
reduce the corrosivity of the potable water prior to distribution. A new inline mixer will be
installed downstream of the two chemical injection points in order to ensure that the chemicals
are fully blended in the treated water.
A new hydropneumatic system consisting of (3) pumps, (2) bladder -type hydropneumatic tanks
and associated pressure switches and controls will be installed as part of the potable water system
upgrade. The pumps will draw suction from the potable water clearwell in response to system
pressure and will fill the two new hydropneumatic tanks by compressing the air bladder to
maintain system pressures between 50 and 70 psi. At start-up, potable water will be pumped into
the two new hydropneumatic tanks filling them to capacity. The air bladders in each tank will
then be pressurized to 70 psi to create pressure for distribution into the Harris plant system. Two
of the hydropneumatic pumps will operate in a lead -lag mode of operation, with the lead pump
automatically activating (via pressure switches) whenever the system pressure falls below 50 psi
and automatically deactivating upon reaching 70 psi. The third pump will serve as a pressure
maintenance (or jockey) pump for low flow periods and will be automatically activated (via a

Mr. Mark McIntire
Page 8
separate pressure switch) whenever system pressure drops below 65 psi. and deactivating upon
reaching the setpoint pressure of 70 psi.
A new totalizing flow meter will be installed downstream of the bladder tank that will measure
and totalize the potable water flow into the distribution system.
ESTIMATES OF WASTE PRODUCTION:
Following is a listing of all the wastewater producing processes in the new Harris Water
Treatment Plant membrane facility. The volume of wastewater produced, along with the
contaminants in that water is each detailed below by processes.
Automatic Backwash Strainer
• Waste Volume: 20 gallons per backflush, typically once per hour = 480 gal/d
• Auto Backwash unit is a 400 micron screen that will remove a portion of precipitated Fe
and Mn and the majority of large, insoluble inorganics and organics prior to
microfiltration.
• The unit will be PLC controlled and programmed to backwash at operator selected time
intervals.
• Waste stream will consist of raw lake water containing screen reject (organic debris such
as leaves, sticks, sand & gravel). The stream may also contain residual oxidants (up to 1
ppm of potassium permanganate and up to 2 ppm of total residual chlorine), although any
residual oxidant will rapidly react with soluble Fe, Mn, and organics and will not be
reactive by the time it enters the waste neutralization basin.
Microfiltration Units
Waste Volume: 160 gallons every 20 minutes (each train will function in this manner) for
90 seconds @ 107 gpm. Maximum discharge in a 24 hour period assuming dual train
operation and continuous production is 1440 min/20 min per cycle = 72 waste cycles per
day x 1.5 minutes/cycle = 108 minutes per day x 107 gpm = 11,556 gallons per day x 2
units = 23,112 gpd (maximum)
Waste stream will contain suspended and colloidal particles larger than 0.1 micron,
specifically inorganics, organic particles, precipitated iron and manganese and color
causing agents. May also contain residual oxidants (up to 1 ppm of potassium
permanganate and up to 2 ppm of total residual chlorine) although any residual oxidant
will rapidly react with soluble Fe, Mn, and organics.
Clean in Place Procedure
o Waste volume: each skid will generate approximately 800 gallons of waste during
the clean in place procedure (1600 gallons total).
o Waste stream will contain: a 2% citric acid solution, followed by flushing water
(potable), a 0.4% NaOH solution with 300 ppm chlorine solution, followed by 5-
10 minute potable water flush.

Mr. Mark McIntire
Page 9
Nanofiltration Units
• Waste Volume: 25 gpm continuous flow per train as long as the system is in operation.
Maximum discharge in a 24 hour period assuming dual train operation and'continuous
production is 25 gpm x 1440 min/day x 2 trains = 72,000 gpd (maximum).
• Waste stream will contain naturally occurring soluble organic molecules (i.e. large
molecular weigh soluble molecules such as tanins) and removes tri- and di -valent cations
(hardness). Additionally the wastestream could contain 0-1 ppm of sodium bisulfite (to
remove chlorine) and low levels (>0.5 ppm) of antiscalant. NOTE: The character of this
wastestream is no different than the wastestream currently being produced by the existing
demineralization process at the Harris Plant.
• Clean in Place Procedure
o Waste Volume: Each skid will produce 720 gallons of wastewater during the CIP
procedure (1440 gallons total)
o Waste Stream will contain: a 2% citric acid solution, followed by flushing water
(potable), a 0.4% NaOH solution followed by 5-10 minute potable water flush.
Potable Water Clearwell Overflow and Drain
The water from this source will be potable water. As such the only contaminants will be
residual chlorine at a maximum concentration of 2.0 ppm.
Waste volume: tank will be infrequently drained resulting in 30,000 gallons of water to
the waste neutralization basin. Additionally, the tank is equipped with an overflow pipe
that will only send flow to the waste neutralization basin in the event of a failure in the
level sensors.
NPDES PERMIT MODIFICATIONS
Outfall 004 - HNP Low -Volume Wastes discharge to Outfall 006
Progress Energy is permitted to discharge intermittent, low volume waste streams generated
during the production of potable water and demineralized make-up water needed for operation of
the HNP. Low-volume waste is treated by neutralization (for pH adjustment), sedimentation, and
separation. These wastes are pre-treated in the neutralization basins (as needed) prior to routing
to the sedimentation basin (for particulate removal), prior to ultimate discharge to the common
outfall line. Low-volume waste flow from the settling basin averages approximately 0.2 MGD.
The various low-volume waste sources are permitted for discharge to Harris Lake in accordance
with NPDES Permit #NC0039586 via Outfall 004 and Combined Outfall 006.

Mr. Mark McIntire
Page 10
Attachment 2
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. 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 potable water and demineralized
water.
The water treatment systems include the following unit processes:
1.Iron and manganese oxidation with sodium hypochlorite and potassium
permanganate to create a precipitate that can be removed via filtration;
2. Microfiltration to remove suspended solids and colloidal particles down to 0.1
micron in size;
3. Nanofiltration to remove naturally occurring organic molecules (to prevent THM
formation after chlorine disinfection in public water supplies);
4. Disinfection of potable water supplies with sodium hypochlorite;
5. Ion exchange for production of demineralized water for process requirements on site.
(Wastes from the treatment processes include microfiltration and nanofiltration
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

3
Mr. Mark McIntire
Page 11
f) Auxiliary boiler system blowdown
g) Miscellaneous waste streams not otherwise identified elsewhere in this application.