NC0000396_Alternate Schedule Request_20150310

DUKEEnvironmental Services
ENERGY® Duke Energy
526 South Church Street
Charlotte,NC 28202
Mailing Address:
Mail Code EC13K1 P.O.Box 1006
Charlotte,NC 28201-1006
March 10,2015
North Carolina Department of
Environment and Natural Resources RECE�VED1DENRI1)WR
Division of Water Resources
NPDES Unit ;;ak . 1 201
1617 Mail Service Center
Raleigh, NC 27699-1617 Water QUS8,%'CtyV1or
PeTmWnq
Subject: 316(b)Alternate Schedule Request
Duke Energy Carolina, LLC and Duke Energy Progress, LLC
Attention Sergei Chernikov:
Final regulations to establish requirements for cooling water intake structures at existing facilities were
published in the Federal Register on August 15, 2014 (i.e. regulations implementing§316(b) of the Clean
Water Act) with an effective date of October 14, 2014. The regulation applies to stations that
commenced construction prior to or on January 17, 2002 and have a design intake flow greater than 2
million gallons per day (MGD), utilize 25% of the water withdrawn for cooling purposes and are point
sources per the NDPES program.The stations Duke Energy has identified as being subject to the rule are
provided in Table 1.
The regulation requires the submission of information listed in 40 CFR 122.21(r). The extent of the
information that is required to be submitted per station is based on the actual intake flow (AIF). For
stations that have an AIF less than or equal to 125 million gallons per day(MGD),the regulation requires
the following information to be submitted:
§122.21(r)(2)Source Water Physical Data
§122.21(r)(3)Cooling Water Intake Structure Data
§122.21(r)(4)Source Water Baseline Biological Characterization Data
§122.21(r)(5)Cooling Water System Data
§122.21(r)(6)Chosen Method(s) of Compliance with Impingement Mortality Standard
§122.21(r)(7) Entrainment Performance Studies
§122.21(r)(8)Operational Status
�r Hifi

A
For stations that have an AIF greater than 125 MGD,the regulation requires the above information to be
�I submitted and, unless waived, the following additional information:
II §122.21(r)(9) Entrainment Characterization Study
§122.21(r)(10)Comprehensive Technical Feasibility and Cost Evaluation Study
§122.21(r)(11) Benefits Valuation Study
§122.21(r)(12) Non-water Quality and Other Environmental Impacts Study
The timing of the submission of the above information is connected to the timing of the NPDES permit
renewal application for the station. The regulation states that for a station whose current effective
NPDES permit expires after July 14, 2018, information required to be submitted must be included with
the subsequent NPDES permit renewal application. For stations whose current effective permit expires
on or before July 14, 2018, the owner may submit a request to the permit Director for an alternate
schedule for the submission of the above information'.
As shown in Table 1, every Duke Energy station in North Carolina either has an effective permit that
expires prior to July 14, 2018 or has a NPDES permit that has been administratively continued while the
permit is in the renewal process. Duke Energy hereby requests an alternate schedule for each of these
stations.The requested submittal date for the 316(b) information is provided in Table 1.
As indicated in Table 1, the Duke Energy stations that have an AIF greater than 125 MGD, with the
exception of Brunswick Nuclear Station, are located on reservoirs. Under the remanded Phase II 316(b)
Rule, stations located on reservoirs were not required to conduct entrainment monitoring. These ,)
stations, therefore, will have to conduct 2-years of entrainment monitoring to complete the
§122.21(r)(9) submission. Entrainment monitoring has been conducted at the Brunswick Nuclear
Station; however, Duke Energy will need to evaluate whether the data collected is sufficient to satisfy
the requirements in the recently finalized rule. i
The data collected during the 2-years of monitoring are necessary to complete the benefits valuation
study (§122.21(r)(11)); therefore, this submittal cannot be finalized until after the entrainment
monitoring is completed and results analyzed. Furthermore, the regulations require the Comprehensive
Technical Feasibility and Cost Evaluation, Benefits Evaluation and the Non-water Quality and Other
Environmental Impacts to be peer reviewed. Duke Energy estimates that approximately five years will be
needed to complete all the necessary studies and submission, based on the following:
— 1 year for the development of the Entrainment Characterization Study plans, which includes
preparing the plans,and review and approval of the plans by NCDENR.
— 2 years to conduct the entrainment monitoring.
— 1 year to complete the Entrainment Characterization Study Report, Comprehensive Technical
Feasibility and Cost Evaluation Study, Benefits Valuation Study and Non-water Quality and Other
Environmental Impacts Study.
— 1 year to complete the Peer Review.
This timeframe is very similar to the schedule presented in the proposed rule. Upon submission of the
above information, North Carolina Department of Natural Resources (NCDENR)determines what, if any,
Refer to§125.95(a)(1)and(2)