NC0000396_Duke Energy eDMR_20170322

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Weaver, Charles
From: Weaver, Charles
Sent: Wednesday, March 22, 2017 9:05 AM
To: 'Safrit, Donald Lee'
Cc Sledge, Bob ([e-mail]); Williams, Teresa Lynne
Subject: RE: Duke Energy eDMR / NC0000396 Asheville - time of chlorine addition
That's fine by me. I'll put this email exchange in the permit file to document the decision.
CHW
From: Safrit, Donald Lee [mailto:[e-mail]]
Sent: Tuesday, March 21, 2017 5:09 PM
To: Weaver, Charles <[e-mail]>
Cc: Sledge, Bob <[e-mail]>; Williams, Teresa Lynne <[e-mail]>
Subject: RE: Duke Energy eDMR / NC0000396 Asheville - time of chlorine addition
Charles,
Thanks for the follow-up and the options offered! To provide consistency with how we have managed this aspect
historically, please go with Option 1— having two columns within the eDMR system for Chlorine Duration (Parameter
Code 78739). If the system allows, we would like the columns distinguished by "Unit 1" & "Unit 2" (to ensure no
confusion between Units for historical data purposes, if appropriate).
Please let us know if any clarifications/additional discussion is needed.
Thanks, Don
Donald (Don) Safrit, P.E.
Senior Environmental Specialist
Duke Energy I Permitting and Compliance, Carolinas
410 S. Wilmington Street I Raleigh, North Carolina 27601
Office: [phone] 1 Cell: [phone]
From: Weaver, Charlesrmailto:charles.weaver(cbncdenr.govl
Sent: Tuesday, March 21, 2017 2:10 PM
To: Safrit, Donald Lee; Williams, Teresa Lynne
Cc: Sledge, Bob
Subject: FW: Duke Energy eDMR / NC0000396 Asheville - time of chlorine addition
Don & Teresa — Sergei has two suggestions. I believe either will work, but I'd like your input.
His 1) is essentially what I was suggesting, simply adding column[s] in the eDMR report for each unit.
OR
His 2) recommends using the existing single data port in eDMR to record the longest time of chlorine addition for any
one Unit. The Unit number could be recorded in the Comments field. This fits the intent of the permit wording,
regardless of Unit.

Let me know what you think.
CHW
From: Chernikov, Sergei
Sent: Thursday, March 16, 2017 9:28 AM
To: Weaver, Charles <charles.weaver@ncdenr.g
Subject: RE: Duke Energy eDMR / Facility Permit
Charles,
I suggest 2 potential solutions:
1) Add another column for time addition
2) Report the maximum time addition for a
Thank you!
Sergei
Sergei Chernikov, Ph.D.
Environmental Engineer II
Complex NPDES Permitting Unit
Tel. [phone]
Fax: [phone]
1617 Mail Service Center, Raleigh, NC 27699-1617
Express Mail: 512 N. Salisbury St., Raleigh, NC 276(
From: Weaver, Charles
Sent: Tuesday, March 14, 2017 3:08 PM
To: Safrit, Donald Lee <Donald.Safrit@duke-enei
Cc: Sledge, Bob <[e-mail]>; Willi
Sergei <[e-mail]>
Subject: RE: Duke Energy eDMR / Facility Permit
Don —the wording in the permit is:
"Total residual chlorine shall not be
day"
Ilenges - NC0000396 Asheville
of the units in the existing column
)m>
Teresa Lynne <[e-mail]>; Chernikov,
- NC0000396 Asheville
from any single generating unit for more than two hours per
I need to speak with Sergei about this. He was out today and I'm out of the office tomorrow. I'll see what kind of fix we
can make and let you know.
The limitations in coding within BIMS may not allow me to customize this for each site.
In the interim, report the minutes for one Unit and list the Unit number in the parameter comments. Note the time
of chlorine addition for other units in the general comments field for that month's DMR.
CHW
From: Safrit, Donald Lee [mailto:Dona
Sent: Friday, March 10, 2017 4:32 PM
To: Weaver, Charles <charles.weaver(
2

Cc: Sledge, Bob <[e-mail]>; Williams, Teresa Lynne <[e-mail]>
Subject: FW: Duke Energy eDMR / Facility Permit Challenges - NC0000396 Asheville
Importance: High
Charles,
Can you review the thread below as well as attached. I was thinking we already went through this conversation
regarding Chlorine Addition but it may have been with another Duke Energy facility. Question is how do we address the
situation where two units may have chlorine addition on the same day and may cumulatively have more than 120
minutes of chlorine addition? If we put 220 on the eDMR (say 120minutes Unit 1 and 100 minutes Unit 2); would an NOV
1
be generated because we only have one column for "minutes" and a maximum limit of 120 minutes for that column.
Please explain and let us know how we should handle this situation.
Thanks, Don
Donald (Don) Safrit, P.E.
Senior Environmental Specialist
Duke Energy I Permitting and Compliance, Carolinas
410 S. Wilmington Street I Raleigh, North Carolina 27601
Office: [phone] 1 Cell: [phone]
xlft,-,DUKE
91 ENERGYr,
From: Williams, Teresa Lynne
Sent: Friday, March 10, 2017 12:27 PM
To: Safrit, Donald Lee; Woodward, Tina
Cc: Keezel, Mariea Haney; Scruggs, Don; Tyndall, Kent
Subject: RE: Duke Energy eDMR / Facility Permit Challenges
Don,
See note below. We need two columns on our e -DMR because our limit to inject chlorine is per unit. Old form had two
columns, sorry we didn't send this in with the last request
Thank you,
Teresa Williams
Lead Environmental Field specialist
Duke Energy Progress —Asheville Plant
200 CP&L Drive Arden, NC 28704
828 -687 -5240 -office 919 -417 -6417 -cell 828 -687 -5204 -fax
[e-mail]
From: Keezel, Mariea Haney
Sent: Friday, March 10, 2017 9:53 AM
To: Williams, Teresa Lynne
Subject: FW: Duke Energy eDMR / Facility Permit Challenges
Hey there,
In looking ahead to upcoming chlorine addition, I noted that although a column was added to the e -DMR for chlorine
duration, there is only one column. We inject on both units. Am I misunderstanding how the minutes are supposed to

be reported now, or do we need to have another dolumn added to account for each unit? And if another column was
added, how would we notate which column was for which unit?
Thanks!
Wariea rik"eezef
From: Safrit, Donald Lee
Sent: Thursday, December 01, 2016 9:08 AM
To: Tyndall, Kent; McGowan, Marty; Stamas, Jonathan; Graham, Mike - EHS; Lea Jr, Herbert M; Howard, Robert E;
Wilson, Bob; Williams, Teresa Lynne; Newcomb, Dana H; Hodges, Steve D; Gantt, Michael R; McCormick, Keeley Nicole;
Williamson, John C; La Sala, Joseph Scott; Massey,! Richard Scott; Wooten, Dale; Scruggs, Don; Woodward, Tina; Wylie,
Robert R; Langley, Shannon; Cahoon, Steve; Ogallo, LeToya Fields; Loveland, Brad P; Hartfield, Ross; Dishmon, Joyce
Martin; Miller, Ricky K; Walters, Macrae Burris; Nelson, Charles D; Phillips, Dulcie F; Pruett, Jeremy J.; Winston, Cynthia
C; Drensek, Daniel L.; Todd, Shannon; Fabian, Lynn; Conner, Steven B; Sarver, Amber Michelle; Bynum, Pete; Cage,
William Jeffrey; Hines, Jeffery D; Davis, Gary M; Kapke, Jeff; Hare, Thomas Arthur; Gardner, Melanie Samuels; Huang,
Bill; Wilson, Jacquelyn; Berry, Brett; Enoch, Ryan S.; Hooft, Christian Louis J; Allen, Della R; Hair, Amanda D.; Keezel,
Mariea Haney; Robertson, Crystal Raper; McFee, Jeff; Pifer, Anne H.
Subject: FW: Duke Energy eDMR / Facility Permit IChallenges
Fyi... response from DEQ DWR regarding some of the eDMR implementation challenges for a few facilities.
I apologize for any those receiving this email but find it irrelevant to your use — I grabbed the list from our recent eDMR
Training/Implementation Meetings to ensure I had all the appropriate people who may be interested in this
feedback/guidance.
Please respond to me and/or your Water SME if we need to discuss (no reply all).
Thanks, Don
Donald (Don) Safrit, P.E.
Senior Environmental Specialist
Duke Energy I Permitting and Compliance, Carolinas
410 S. Wilmington Street I Raleigh, North Carolina 27601
Office: [phone] 1 Cell: [phone]
DUPLE
ENERGY.
From: Weaver, Charles fmailto:charles.weaver@n
Sent: Wednesday, November 30, 2016 2:42 PM
To: Safrit, Donald Lee; Hennessy, John
Cc: Sledge, Bob; Scott, Michele
Subject: RE: Duke Energy eDMR / Facility Permit
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From: Safrit, Donald Lee [mailto:[e-mail]]
Sent: Thursday, November 10, 2016 8:49 AM
Subject: Duke Energy eDMR / Facility Permit Challenges
I wanted to check in regarding the status of several Duke Energy NPDES permits and previous requests to reconcile some
of the BIMS/eDMR data versus the actual NPDES permit requirements. The following permits have been sent to your
attention for reconciliation:
McGuire Nuclear— NCO024392
Outfall 001 Effluent - missing Quarterly Toxicity Sampling Acute Composite Parameter Code CER124PF
Outfall 002 - Effluent - missing Quarterly Toxicity Sampling Acute Grab Parameter Code CER148AC
Outfall 005 - Effluent - has toxicity sampling requirements as monthly Parameter Code CER7DCEV which needs to be
removed. Missing quarterly toxicity sampling 7 Day Chronic Parameter Code CER17DPF
(Resolved per Bob Sledge email of 11/30/2016)
Harris Nuclear— NCO039586
BIMS/eDMR data contains the former NPDES Permit information rather than the information associated with the
recently issued permit (effective September 1, 2016 version)
(Resolved per Bob Sledge email of 11/30/2016)
Riverbend — NC0004961
OUTFALL 002: The Parameter Codes associated with Chronic Toxicity THP3B (percent) and TGP3B (pass/fail) have a
sampling frequency of "weekly". The sampling frequency for Chronic Toxicity changes from monthly to weekly as we
transition from treating -decant water to interstitial water. Moreover, the footnote for Chronic Toxicity says "Tests shall
be conducted in January. April, July and October".
Outfall 002 has two sets of toxicity testing requirements. Prior to decanting, the tests are conducted Quarterly (January,
April, July, October) with Optional Monthly testing if a Quarterly test has failed. When decanting begins, toxicity is
tested Weekly, with Optional Weekly sampling if a test is failed. RIMS has been corrected to show both sets of test
requirements. Only the pre -decant testing requirements are now in effect.
It should be noted that the above concerns are based upon the permit anticipated to be issued soon and its anticipated
effective date of December 1, 2016.
There is no permit application currently in-house for NC0004961. The existing permit took effect on 3/1/2016.
Additionally, we have noted the below mentioned challenges and want to bring them to your attention for action as
well:
Allen — NC0004979
Outfall 002: BIMS/eDMR template has Chronic Toxicity frequency of Monthly. Current permit requires Quarterly
Toxicity. Which parameter code? Two are listed?
As Bob Sledge explained in his earlier message, the Quarterly parameter code is for the mandatory tests. The Monthly
code is for follow-up tests taken when a Quarterly test is failed. The Monthly code is optional, meaning no violations will
occur if no data is submitted.

Outfall 005: BIMS/eDMR template has Total Se
Selenium.
BIMS shows Monthly Selenium monitoring for
requirements, IT will need to resolve the discri
frequency of weekly. Current permit requires Monthly Total
11005, effective 3/1/2011. If the eDMR system has different
Rogers- NC 0005088
Outfall 002: Downstream (if required) at Gaffney Water Works limit should be 89.6 F. eDMR has limit of 95 F.
BIMS has Monthly Average limit Downstream as 89.62 F. The effluent limit is 952 F. If the eDMR system has different
requirements, IT will need to resolve the discrepancy.
Outfall 002: Parameter code difference for TSS (C0530-eDMR/00530 currently submitted), Total Nitrogen (C0600 eDMR
vs 00600 current), Total Phosphorus (C0665 eDMR vs 00665 current), Total Mercury (COMER eDMR vs 71900 current)
Outfall 004: parameter code difference for TSS (C0530 eDMR vs 00530 current)
The codes beginning with "CO" are for concentration -based limits and/or monitoring. Several permits have limits and/or
monitoring that is both concentration -based (CO) and massed -based (Q). BIMS n_ eeds different c_ odes to properly
evaluate the data. Use the codes in eDMR for those parameters.
Asheville- NC 0000396
Outfall 001: Some time back, Asheville was requ
addendum information and results forele ein a
where should this information be entered?
BIMS currently has no parameter codes for selen
the necessary codes added. Once they are in BIB
001.
Chronic Toxicity: Toxicity is listed twice.
THP313 = CHV Statre 7 Day Chronic Ceriodaphnia
THP3B has been corrected to show optional Mor
TCP313 = Pass/Fail Static Renewal 7 Day Chronic �
Solutions: This is a saltwater test and DOES NOT
from the report?
to speciate selenium. The last page of the DMR contains the
e tnie q. There are no parameter locations for these two results,
and selenite. A ticket [attached] has been submitted to IT to have
selenate and selenite effluent monitoring will be added to outfall
ily monitoring, as with NC0004979 above.
iericamysis (Mysid.) Confirmed with Environmental Testing
SHOULD NOT APPLY to the Asheville facility. Should it be removed
The parameter code is TGP3B, not TCP3B. TGP313 is the freshwater test required by section A. (6.) of NC0000396, which
includes the following text: "using the parameter code TGP313 for the pass/fail results and TBP313 for the Chronic Va_lu_e"
If the eDMR system has different requirements, IT will need to resolve the discrepancy.
NPDES is currently working on the following items related.to Duke eDMRs:
A ticket was submitted to IT requesting creation oaf a parameter code for "Duration of Chlorine Addition", which is
required in several permits. Once the code is available, that parameter will be added to the affected permits.
A ticket was submitted to IT requesting creation oaf Sutton Lake as a waterbody in BIMS for permit NC0001422. IT
replied that they did not provide that service. NPDES will contact Planning to have Sutton Lake added to BIMS.
A ticket was submitted tot IT requesting creation
replied that they did not provide that service. N
CHW
Railroad Branch as a waterbody in BIMS for permit NC0003468. IT
�.:S will contact Planning to have Railroad Branch added to BIMS.