NCS000590_Renewal Application Pt 1_20160606

UKPBrunswick Nuclear Plant
ENE o P.O.Box10429
Southport,NCC2846161
siAY 2 0 2016
B EP 16-0028 L
Serial: SEP
VEn
JUN 062116
Mr. Tom Belnick, Supervisor
NPDES Complex
Permitting
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NC DEQ DWRVVQ PermittingSection (
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Brunswick Steam Electric Plant, Unit Nos. 1 and 2
National Pollutant Discharge Elimination System
NPDES Permit No. NC0007064
Renewal Application
Dear Mr. Belnick:
The current NPDES permit for the Brunswick Steam Electric Plant expires on November 30,
2016. Duke Energy Progress, LLC hereby requests that the NPDES permit for the facility be
reissued. Enclosed are EPA Application Form 1 — General Information, EPA Application Form
2C—Wastewater Discharge Information and EPA Application Form 2F— Stormwater
Discharges Associated with Industrial Activity, all in triplicate.
With reissuance of the NPDES permit, Duke Energy Progress, LLC requests the following:
Corporate Name Update
The current Corporate name is Duke Energy Progress, LLC and it is requested that all permit
documents and NPDES related electronic datasets be updated to reflect this name.
Once-Through Cooling Water, Service Water- Outfall 001
Confusion has arisen with the current format and structure of the effluent table and associated
notes for A. (1) Effluent Limitations and Monitoring Requirements [001]. Please consider the
following suggested approach:
A. (I.)EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [001]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge once-through cooling and non-contact service water
through Outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:

NC DEQ/DWR/WQ Permitting Section
Page 2 of 4
Pa%ameter°= apscla"rge'Limitations, Monitoring,Requirements _- ':; " z� .
Daily Maximum Measurement Sample Type Sample
Frequency Location'
Cooling Water 1844 cubic feet per Continuous Pump Logs/
Flow December second 2'3 Recording
1 — March 31
Cooling Water 2210 cubic feet per Continuous Pump Logs/
Flow April 1 - second 2'3 Recording
June 30
Cooling Water 2335 cubic feet per Continuous Pump Logs /
Flows July 1 — second 2,3 Recording
September 30
Cooling Water 2210 cubic feet per Continuous Pump Logs /
Flow October 1 - second 2'3 Recording
November 30
pH 9.0 >_ pH >_ 6.0 Weekly Grab Effluent
Notes:
1. Unless otherwise specified, the Permittee shall sample the combined effluent from both
units. During periods of outages the Permittee may maintain minimum unit flows required
for the safe and efficient operation &maintenance of plant systems.
2. At times when the system demand is within 200 MW of available system reserves, the
Permittee may suspend flow limitations upon notice to the Regional Supervisor. Notice
shall include anticipated flow rates and an estimate of the duration of flow rates in excess
of those otherwise allowed.
3. The Daily Maximum flow limit is suspended for twenty-four hours after changing once-
though cooling water valve/pump configuration.
Confusion has also arisen with the language regarding the grab sampling for Total Residual
Chlorine for Outfall 001. The sampling point for Outfall 001 is the quiescent forebay to the
effluent pump station (Caswell Beach Pump Station) prior to the ocean outfall. The existing
language references "multiple grab samples" but should only reference a single grab sample).
Please consider the following suggested language:
CHLORINE—There shall be no discharge of Total Residual Chlorine (total residual oxidants) at
the ocean outfall. Total Residual Chlorine or total residual oxidants are to be measured monthly
at the Caswell Beach Pump Station by a grab sample.
Sanitary Waste Treatment- Outfall 004
Duke Energy Progress, LLC respectfully requests Flow be removed as a Monthly Average
Discharge Limitation. The effect of this change will be similar to other outfalls whereby flow is
not a specific limit, but will be monitored, and the performance standards for the effluent will
govern the quality of the discharge. This is consistent with 15A NCAC 02B .0508(d) and the
Federal Effluent Guidelines. These performance standards are protective of public health and
the environment.
If this approach is not possible, the Monthly Average Discharge Limitation should remain at
0.055 MGD.

NC DEQ/DWR1WQ Permitting Section
Page 3 of 4
Sanitary Waste Treatment- Sutfall 010
Duke Energy Progress, LLC respectfully requests Flow be removed as a Monthly Average
Discharge Limitation. The effect of this change will be similar to other outfalls whereby flow is
not a specific limit, but will be monitored, and the performance standards for the effluent will
govern the quality of the discharge. This is consistent with 15A NCAC 02B .0508(d) and the
Federal Effluent Guidelines. These performance standards are protective of public health and
the environment.
If this approach is not possible, the Monthly Average Discharge Limitation should be increased
from 0.036 MGD to 0.150 MGD.
St•;rrm Drain Stabilization Facility Pond - Outfall 011
Duke Energy Progress, LLC respectfully requests the Measurement Frequency for Outfall 011
parameters be modified to read "Once per Discharge Event". This treatment system operates
as a batch process (similar to Low Volume Waste - Outfall 005).
Federal Clean Water Act 316(b) Lanquage
Duke Energy Progress, LLC respectfully requests the Section 316(b) application of the Federal
Clean Water Act addressing Once Through Cooling Water Intakes be due with the next renewal
application. The alternative schedule request is provided in Addendum A.
Stormwater
Duke Energy Progress, LLC is also providing three (3) additional copies under separate cover to
the NC DEQ Division of Energy, Mineral and Land Resources (DEMLR) for their involvement
regarding Industrial Stormwater management.
If you have any questions regarding the enclosed information, please contact Mr. Don Safrit,
P.E., at [phone] or Mr. Marty McGowan at [phone].
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,
Karl Moser
Plant Manager
Brunswick Steam Electric Plant

NC DEQ/DWR/WQ Permitting Section
Page 4 of 4
Enclosure 1: EPA - Application Form 1 — General Information
Enclosure 2: EPA - Application Form 2C—Wastewater Discharge Information
Enclosure 3: EPA—Application Form 2F—Stormwater Discharge Associated With Industrial
Activity
cc: Mr. Bradley Bennett— NC DEQ DEMLR (3 copies)
Mr. Marty McGowan
Mr. Don Safrit

BSEP 16-0028
Enclosure 1
Brunswick Steam Electric Plant
Addendum A—Alternate Schedule Request 316(b) of the Clean Water Act

Duke Energy Progress, LLC
Brunswick Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0007064
ADDENDUM A
Alternate Schedule Request §316(b) of the Clean Water Act
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. Per
§125.91(a)(1)-(3) Applicability, the Brunswick Steam Electric Plant is subject to the
requirements at §125.94 through §125.99(316(b) requirements) based on the following:
— The facility is defined as an existing facility (i.e. commenced construction prior to
January 17, 2002);
— The facility is a point source discharge;
— The facility uses a cooling water intake with a design intake flow (DIF) of greater than 2
million gallons per day (MGD) to withdraw water from waters of the U.S.; and
— Twenty-five percent or more of the water withdraws on an actual intake flow basis are
exclusively used for cooling purposes.
Per §125.98(b) Permitting requirements, 316(b) requirements are implemented through the
NPDES permit. Facilities subject to the final rule are required to develop and submit application
materials identified at §122.21(r). The actual intake flow (AIF) of the facility determines which
submittals will be required. Facilities with an AIF of 125 MGD or less are required to submit
material identified at §122.21(r)(2)-(8), whereas, facilities with an AIF greater than or equal to
125 MGD are required to submit materials presented in §122.21(r)(9)-(13), in addition to
information identified at §122.21(r)(2)-(8). The AIF at Brunswick is above the 125 MGD
threshold; therefore, the following 316(b) submittals are required:
• §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
• §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
• §122.21(r)(13) Peer Review
The regulation states the owner of a facility whose current effective permit expires after July 14,
2018, must submit the above information when applying for a subsequent permit and the owner
1

Duke Energy Progress, LLC
Brunswick Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0007064
of a facility whose current effective permit expires on or before July 14, 2018 may request an
alternate schedule for the submission of the above information'. Duke Energy would like to
request the above information, with the exception of §122.21(r)(6) Chosen Method(s) of
Compliance with Impingement Mortality Standard; for Brunswick Steam Electric Plant to be
required with the subsequent permit renewal application due after July 14, 2018.
Since Brunswick Steam Electric Plant is subject to the entrainment best technology available
(BTA) determination, a compliance schedule to complete §122.21(r)(6) Chosen Method(s) of
Compliance with Impingement Mortality Standard will be requested to be included in the permit
upon issuance of the entrainment BTA determination2.
Significant work has been completed on reducing both impingement and entrainment and
ongoing entrainment and impingement studies are required to demonstrate these reductions at
Brunswick. However, the recently finalized 316(b) rule request information and evaluations that
were not previously required. Specifically, information requested in §122.21(r)(6) — r(12) are
additional reports and studies that will need to be conducted and developed. In addition, the
regulations require the §122.21(r)(10), §122.21(r)(11), and §122.21(r)(12) studies to be peer
reviewed, which will require additional time to complete upon finalizing these studies.
Additionally, the United States Environmental Protection Agency (USEPA) — Headquarters (HQ)
have indicated guidance is being prepared to assist in interpreting and implementing the rule
requirements, however, this guidance is not expected to be issued until the 316(b) litigation is
completed, which is not expected to occur until 2017. The alternate schedule, therefore, is
justified. A summary of these reasons are as follows:
• The historical entrainment data will need to be reviewed to ensure the data meets the
requirements of §122.21(r)(9) . If additional analyses are required based on this review,
it is expected that the analysis would need to be completed over a two-year period. This
review will, also, involve concurrence from both the Peer Reviewer and the state.
• Preparation of the reports to satisfy §122.21(r)(10), (11) and (12) based on guidance
expected to be provided by USEPA, which is not expected to be issued until 2017. It is
prudent to wait to develop these submittals once the guidance is issued to avoid
unnecessary re-work.
• For the §122.21(r)(13) Peer Review, Duke Energy estimates this could take up to 12
months to complete. This, also, takes into account the other six Duke Energy stations
that will be undergoing the peer review process concurrently.
' Refer to §125.95(a)(1) and (2)
2 Refer to §125.94(b)(1)
2

Duke Energy Progress, LLC
Brunswick Steam Electric Plant
National Pollutant Discharge Elimination System Permit Number NC0007064
North Carolina Department of Environmental Quality (NCDEQ) has previously determined
Brunswick fully meets the 316(b) requirements of the CWA. This is documented in the current
permit under condition A.(9), which states:
"A. (9.) 3J 6 (b) REQUIREMENTS
Impingement and entrainment studies conducted for the past 20 years indicate
that the facility's operation and maintenance of cooling water intake structure
(CWIS) is consistent with the intent of 40 CFR 401.14. The Permittee shall
continue to properly operate and maintain the CWIS."
Duke Energy intends to demonstrate through the framework established under the recently
issued regulation that the existing conditions at Brunswick continue to meet both the
impingement and entrainment BTA standards under the rule.
3

BSEP 16-0028
Enclosure 2
Brunswick Steam Electric Plant
EPA—Application Form 1 —General Information