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Home My WebLink AboutNCS000606_Modification request_20231107 DUKE " Vice President �g� Thomas P.Haaf :A/ED Harris Nuclear Plant ENERGY. 5413 Shearon Hands Rd �10V G 7 �023 New Hill NC 27562-9300 OCT 2 5 1023 'lormwaferProgram Serial: RA-23-0294 Certified Mail Number: 7014 2120 0003 3196 6890 Return Receipt Requested Ms. Brianna Young Industrial Program Individual Permit Coordinator DEMLR Central Office 1612 Mail Service Center Raleigh, NC 27699-1612 Subject: Comments -Initial NPDES Stormwater Permit NCS000606 Harris Nuclear Plant 5413 Shearon Harris Road New Hill, NC 27562 Wake County Dear Ms. Young: Duke Energy has reviewed our initial NPDES Stormwater Permit NCS000606 issued on September 27, 2023 and would like to seek further clarification on some of the permit requirements contain therein. Additionally, Duke Energy requests several corrections be made to the permit language. These questions and corrections are outlined in the enclosure. Duke Energy hopes to continue a constructive dialogue to ensure full compliance and understanding of the permit requirements. If you have any questions regarding this matter, please do not hesitate to contact Mr. Bob Wilson, HNP Site Environmental Professional, at (984) 229-2444. Sincerely, Thomas P. Haaf Enclosure: NCS000606 Initial Permit— List of Comments cc: Thad Valentine, NC DEQ DEMLR RRO Comments—NPDES Stormwater Permit NCS000606 Serial: RA-23-0294/page 2 bc: Annette Lucas Scott Brooks Joseph Francom William Gunter Dave Hoffman Don Safrit Bob Wilson Darlene Wallace Nuclear Records Comments—NPDES Stormwater Permit NCS000606 Serial: RA-23-0294 Enclosure NCS000606 Initial Permit— List of Comments (3 pages including cover) Comments—NPDES Stormwater Permit NCS000606 Serial: RA-23-0294 Enclosure QUESTIONS: • Is it possible to complete four(4)samples in a quicker timeframe for the purpose of requesting Representative Outfall Status(ROS) if those samples meet the qualifying storm event criteria and are separated by at least 30 days? RESPONSE TO COMMENTS ON DRAFT PERMIT FOR NCS000606 REQUESTED CORRECTIONS: A. In the summary of baseline sampling requirement tables throughout the permit,estimated average monthly oil usage is listed a parameter for all outfalls.Since this is average is facility wide, Duke Energy requests that this parameter be required for SW-006 only. B. Table 2, Outfall SW-005 discharges into the Main Intake Canal and is then directed to the process water for discharge through NPDES Outfalls. Duke Energy requests that the monitoring requirements for SW-005 be removed from the permit because this outfall does not discharge to the stormwater drainage system or to surface waters(reference Additional Outfalls page 19). A - 2, • ,- p 4,a•1 7 ,VY \ 6 C. Part D,Table 2,footnote 3 references a service transformer. However,there are multiple service transformers present. Duke Energy requests that footnote 3 be updated to reflect site conditions.See corrected language below: Outfall SWO02: Drainage area includes Diesel Generator Building, northern portion of the cooling tower, Major Projects Building, one (1)6,500-gallon phosphoric acid tank,three (3) 4,500-gallon water treatment chemical tanks,service transformers,sewage lift station,gravel- surfaced parking areas, rail lines, and grassed yard areas. Comments—NPDES Stormwater Permit NCS000606 Serial: RA-23-0294 Enclosure D. Part D,Table 2,footnote 3 references two Water Treatment Buildings. However,there is only one of these buildings present. Duke Energy requests that footnote 3 be updated to reflect site conditions.See corrected language below: Outfall SW006: Drainage area includes one(1)Water Treatment Building, Paint Shop, Chemical Warehouse, Mobile Equipment Area,a portion of the Service Building,a portion of the Bulk Warehouse,the Neutralization Basin,the Settling Basin,gasoline storage tanks,diesel fuel storage tanks, used oil storage tanks,oil/water separator and adjacent 1,000 gallon used oil collection tank,service transformers,three(3)sewage lift stations,one(1)8,315 gallon sulfuric acid storage tank,solid waste compactor,paved roads,gravel-surfaced areas,external storage areas, parking areas,and grassed areas. Intermittently,the auxiliary boiler heat exchanger and draining of filtered water and decriminalized water storage tanks will be pushed to the outfall. E. Part D,Table 3,footnote 3,bullet point 1 does not identify the transformers within Outfall SW-003. Duke Energy requests that this item be updated to reflect site conditions. See corrected language below: Outfall SW003: Drainage area includes the southern portion of the Cooling Tower, one(1) 5,600-gallon sodium hypochlorite tank,other small water treatment chemical storage tanks, chemical storage building,Cooling Tower circulating water pumps,transformer yard, transformers, paved parking areas, and grassed yard areas. F. Part D,Table 4,footnote 3, bullet point 1 does not identify the transformers within Outfall SW-004. Duke Energy requests that this item be updated to reflect site conditions. See corrected language below: Outfall SW004: Drainage area includes gravel-surfaced switchyard,transformers, paved roads and parking areas,and grassed yard areas. G. On page 19 under"Additional Outfalls,"SW-007 and Drainage Area 10 are said to discharge to the Emergency Service Water Intake Canal. However,SW-005 also discharges to the Main Intake Canal. Duke Energy requests that this section be updated to reflect a similar site conditions.See corrected language below: Stormwater outfalls SW005,SW007 and Drainage Area 10 discharge to the Emergency Service Water Intake Canal,which goes back into the plant.Stormwater outfall SW-A does not contain Industrial Activity.Any modifications to these outfalls that result in a potential stormwater discharge associated with past or present industrial activities will require a modification of this permit. SW005 should also be removed from Part D Table 1 since it discharges to the Emergency Service Water Intake Canal as explained above.The bulleted item in Part D Table 1 for the SW005 description should also be removed from this section. Comments—NPDES Stormwater Permit NCS000606 Serial: RA-23-0294 Enclosure H. Duke Energy understands that fecal coliform is included in the monitoring parameters for SW- 001 and SW-005 due to the presence of lift stations in those drainage areas. However,there is also an abundance of wildlife at the plant that is likely to contribute fecal coliform to stormwater. Duke Energy requests that language be added to the Tier 1 response requirements stating that if the exceedance is for fecal coliform,then Duke Energy will provide and document additional oversight of the lift station(s). If,after this effort by Duke Energy to provide additional management of the lift station(s),the fecal coliform benchmark is exceeded,then Duke Energy will be granted Tier relief rather than progressing to Tiers 2 and 3. QUESTIONS: 1. Since the permit was issued September 27,2023, Duke Energy understands and interprets observations(qualitative)and analytical (quantitative)obligations associated with NCS000606 do not go into effect until the first quarter of 2024. Please clarify if appropriate. 2. Is the average monthly usage of new motor oil and hydraulic oil a running 12-month average? 3. Part D,Table 2,footnote 3,bullet point 2 states:"Intermittently,the auxiliary boiler heat exchanger and draining of filtered water and demineralized (msp)water storage tanks will be pushed to the outfall." Duke Energy requests an explanation of how the water will be pushed to the outfall. Duke Energy believes the more appropriate language would be: ...and demineralized water storage tanks will be routed to the outfall.