Text

Application for Subsequent Renewed Operating Licenses. Part 7 of 8
	ML21158A200
Person / Time
Site:	Oconee
Issue date:	06/07/2021
From:	; Duke Energy Carolinas
To:	; Office of Nuclear Reactor Regulation
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ML21158A193	List: ML21158A195; ML21158A196; ML21158A197; ML21158A198; ML21158A199; RA-21-0132, Application for Subsequent Renewed Operating Licenses. Part 7 of 8;
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Oconee Nuclear Station Units 1, 2, and 3 Application for Subsequent License Renewal Appendix E - Applicants Environmental Report Attachment F: Other Consultation Letters

41 O S. Wilmington St

( -, DUKE NCRH15

<(; ENERGY Raleigh , NC 27601 o* 919.546.5285 Nov. 4, 2020 Fran Marshall Environmental Affairs Administrator SCDHEC 2600 Bull Street Columbia, SC 29201

Subject:

Duke Energy - Oconee Nuclear Station Units 1, 2 & 3 Subsequent License Renewal - Thermophilic Organisms

Dear Ms. Marshall:

As per your recommendation regarding DHEC's assessment of thermophilic organisms for Oconee Nuclear Station, Duke Energy had Charles W. Calmbacher, Certified Industrial Hygienist, review the information and offer his professional opinion on this matter. This summary, and Mr. Calmbacher's findings, are provided in the attached letter. We request that DHEC consider this information in support of your review and response to our request concerning any potential public health concerns associated with thermophilic organisms. The original request dated Nov 11, 2019 for Oconee Nuclear Station is also attached.

If you have any questions, please feel free to contact me at 919-793-4220 or arun .kapur@duke-energy.com .

Sincerely, Arun Kapur Lead Environmental Specialist Attachments Charles W. Calmbacher Letter Thermophilic Letter to DHEC cc: John Estridge, ONS BUILDING ASMARTER ENERGY FUTURE"'

.::I ENERCON Excel/ence- Eve,y p1ojec1. Every doy.

October 21 , 2020 Mr. Arun Kapur Duke Energy 410 S. Wilmington St, NCRH 15 Raleigh, NC 27601 RE: Impact of Thermophilic Organisms - Oconee Nuclear Station

Dear Mr. Kapur:

An updated review of the potential impact of Naegleria fowleri on Lake Keowee, and associate waterways, was performed relative to the renewal application for the Duke Energy Oconee Nuclear Power Station. A review performed during the previous licensing cycle for the plant by the State of South Carolina (Dr. Brown) concluded that the potential for increased exposure to N.

fowleri from ONS' s thermal discharge is not a concern. The conditions leading to that conclusion have not changed, and are not proposed to change, since that determination. The cooling water is discharged at temperatures below levels that promote growth of the organism. Cooling towers are not used to cool discharge water. This reduces the potential for growth of the ameba before discharge. The deep discharge of cooling water in the lake keeps water temperature below optimal levels for propagation of the ameba.

In performing this updated review, I utilized the following information and documents:

Centers for Disease Control and Prevention (CDC), Naegleria fowleri , Primary Amebic Meningoencephalitis (PAM), updated September 29, 2020.

Hains, Dr. John, Practical Limnology, " What Lurks in that Water?", The Sentinel, September-October 2016. Pp. 10-11.

Application for Renewed Operating Licenses Oconee Nuclear Station, Units 1, 2, and 3 Volume IV, June 1998. pp. 4-37-38 & Attachment I.

Based on current permit requirements, NPDES permits, discharge location, and discharge parameters, it is reasonable to assume that the potential for increasing the exposure to N. fowleri to the general public is negligible. I see no impediment to the license renewal, or continued operation, of the Oconee Nuclear Power Station based on the potential of impacting public health and safety relative to increased potential for the growth ofthermophilic microorganisms. Infection by N. fowleri is considered "rare" by the CDC. There is little reason to believe that the actions of the ONS should promote or increase the potential for elevated exposure or risk to the public at large.

Respectfully submitted, Charles W. Calmbacher, Ph.D., CIH Certified Industrial Hygienist cc: Ed Asbury Tom Slavonic 2790 Mosside Boulevard, Suite 70S Monroeville, PA 15146 Phone: 724.213.7702 enercon.com

el_~ DUKE J. Ed Burchfield, Jr.

~ ENERGY. V.ICB Pres/dBnt Occnee Nuclear Station Dub Energy ON01VP / 7800 Roch8ster Hwy Seneca, SC 29672

~ 864.873.3478

, 864.873.5791 Ed.Burchfield OdukHlle,py.com BY U.S. MAIL - RETURN RECEIPT REQUESTED November 11, 2019 Fran Marshall Environmental Affairs Administration SCDHEC 2600 Bull Street Columbia, SC 29201 RE: Duke Energy - Oconee Nuclear Station Units 1, 2, and 3 Subsequent License Renewal

Dear Ms. Marshall:

Duke Energy is seeking a response from DHEC concerning the potential existence and Perceived public health risks associated with thermophilic organisms that may be present in the portion of Lake Keowee that receives the cooling water discharge from our Oconee Nuclear Station (ONS). Information concerning the reason for this request and specific microorganisms of concern is presented below. Figures depicting the station site and the vicinity within a 6-mile radius of the station are attached.

Reason for this Request and Microorganisms of Concern Duke Energy Carolinas, LLC (Duke Energy) is preparing an application for renewing the operating licenses for Oconee Nuclear Station Units 1, 2, and 3 (ONS) for an additional 20 years (see Table 1). Duke Energy is contacting you for assistance in assessing the impacts from continued operation during this renewed license period.

Table 1. ONS Licensing Dates License Expiration Extended License Expiration ONS Unit Date Date Unit 1 February 6, 2033 February 6, 2053 Unit2 October 6, 2033 October 6, 2053 Unit3 July 19, 2034 July 19, 2054 As part of the renewal process, the U.S. Nuclear Regulatory Commission (NRC) requires that the license renewal application include an environmental report (ER) that assesses the impacts from continued operation and any refurbishment undertaken to enable the continued operation

of the units. One area of potential environmental impact concerns potential public health risks associated with microorganisms.

Information to Support Consultation on Thermophlllc Microorganisms In Regulatory Guide 1437, Supplement 1, Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GEIS), the NRC considered health impacts from thermophilic organisms posed to both the public and plant workers because ideal conditions for thennophilic bacteria can result from nuclear facility operations and discharges. The NRC designated public health impacts resulting from thermophilic organisms as a Category 2 issue requiring plant-specific analysis. Information to be considered in evaluating impacts includes thermal discharge temperature; thermal characteristics of the receiving water bodies; thermal conditions tor the enhancement of Naegleria fowleri and other pathogens; and potential impacts to public health.

The GEIS discussion of microbiological hazards focuses on the thermophilic microorganisms Legionella spp. (which can be a hazard in cooling towers) and the pathogenic amoeba, N. fowleri (which can be a hazard resulting from cooling water discharges). ONS's cooling system does not use cooling towers but does have a thermal discharge to publicly accessible water.

Naegleria spp. is ubiquitous in nature and thrives in heated water bodies at temperatures ranging from 95-106°F or higher is rarely found in water cooler than 95°F, and infection rarely occurs in water temperatures of 95°F or less (NRC 2013, Section 3.9.3). SCDHEC, South Carolina's state public health agency, characterized the risk of infection from N. fowleri 's as very rare, but warns that "recreational water users should assume that N. fowler! is present in warm freshwater across the United States and be aware that there is always a low-level risk of infection." There have been only eight cases of Primary Amebic Meningoencephalitis, the infection caused by N. fowleri, in South Carolina from 1962 to 2018.

ONS utilizes an open-cycle cooling system in which cooling water is withdrawn from Lake Keowee from its intake channel on the south side of the ONS plant, heated in the condensers, and returned to Lake Keowee through the discharge point on the northeast side of the ONS plant. ONS discharges heated cooling water at a depth of approximately 20 feet. The lake waters near the discharge area are open to the public. Activities in the area include recreational boating, fishing, and scuba diving. Lake Keowee has residential housing and public swimming areas as well.

The current NPDES permit for ONS establishes both a maximum allowable discharge temperature, and a limit for increases of water temperature between the intake and discharge.

The maximum discharge temperature is100°F as a daily average, unless critical hydrological, meteorological, and electrical demand conditions apply. In such situations, the discharge temperature shall not be allowed to exceed 103°F. The maximum temperature rise above the intake temperature is limited to 22°F when the intake temperature Is greater than 68°F. In the 2013 permit renewal application, Duke Energy requested the daily maximum value of 100°F to a 7-day average not to exceed 100°F.

As part of a CWA Section 316(a) demonstration monitoring, Duke Energy monitors water temperatures at several Lake Keowee stations. The most recent report submitted to SCOH EC is 2 of 6 I P a t'. 1'

from 2013 and covers the years 2006 - 2011. The closest station to the plant's discharge is Location 508, which is approximately 200 meters from the discharge. The annual maximum measured surface temperatures at Location 508 in the years 2006 to 2011 ranged from 92.5 °F in 2009 to 94.8°F in 2008 . The annual maximum temperatures were similar to values reported in 1995 and 2007 reports. The report also noted that no exceedances of permit thermal limits occurred over the 2006 - 2011 period.

As noted above, N. fowleri is rarely found in water cooler than 95°F, and infection rarely occurs in water temperatures of 95°F or less. While the immediate discharge area could have temperatures in the summer above 95°F, the maximum temperatures recorded 200 meters from the discharge were below 95°F, indicating lower risk. In addition, the discharge point and this monitoring point is located in an area of deep water, approximately 23 meters. The N. fowleri infection risk is higher in shallow, warm water.

The Friends of Lake Keowee published an article in their newsletter in 2016 from Dr. J. Hains of Clemson University that addressed the risk posed by ONS's heated discharge for promoting N.

fowleri. Dr. Hains wrote, "The temperature at which this organism grows best is reported to be far greater (approximately 112°F) than the ONS discharge. Moreover, that water originates in the coldest, deepest depths of Lake Keowee, not an optimal habitat. To my knowledge there have been no studies of the distribution of this organism in Lake Keowee (or in other nearby lakes in recent times)."

Additionally, for the first license renewal of ONS, Duke Energy consulted with SCDHEC to determine if the continued operation of Oconee will have public health impacts due to the enhancement of thermophilic organisms. By letter dated October 25, 1996, Dr. John F. Brown, State Toxicologist at SCDHEC, summarized the agency's position and opinion regarding the public health implications of continued operation of Oconee. Regarding the potential public health hazard from pathogenic microorganisms whose abundance might be promoted by ONS's artificial warming of recreational waters, Dr. Brown indicated that there seems to be no significant threat to off-site persons near such heated recreational waters.

As stated earlier, this letter seeks your input on any potential public health concerns associated with our proposed continued operation of ONS. We appreciate your notifying us of your comments and any information you believe Duke Energy should consider in the preparation of the ER. Duke Energy plans to include this letter and any response you provide in the ER.

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Should you or your staff have any questions or comments, please contact Mike Ruhe at (980) 373-3231 / Mike.Ruhe@duke-energy.com.

Sincerely,

>eifJ-¢111 J. Ed Burchfield, Jr Site Vice President Oconee Nuclear Station Attachments:

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cc: Myra Reece SCDHEC 2600 Bull Street Columbia, SC 29201

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January 8, 2021 Mr. Arun Kapur Duke Energy Lead Environmental Specialist 410 S. Wilmington Street NCRH 15 Raleigh, North Carolina 27601 Re: Oconee Nuclear Station Units 1,2 and 3 Subsequent License Renewal - Consultation on Thermophilic Microorganisms

Dear Mr. Kapur:

After a review of the report on the impact of thermophilic organisms associated with discharge from the Oconee Nuclear Station (ONS) prepared by Enercon, DHEC technical staff does not take any exception with the findings, including that "there is little reason to believe that the actions of the ONS should promote or increase the potential for elevated exposure or risk to the public at large."

As stated in the Duke-Energy letter dated November 11 , 2019, Naegleria spp. is ubiquitous in nature and thrives in water bodies at temperatures ranging from 95 to 106 degrees F. SCDHEC routinely warns recreational water users across the state that there is always a low risk of infection from naturally occurring organisms like N. fowleri in warm freshwater.

In our view, the Enercon consultant has met the NRC requirement of plant-specific analysis of this issue. The discharge temperature, location and demonstration monitoring all support the conclusion that an increased risk to the public to exposure to thermophilic microorganisms is not expected.

We agree with your consultant that the conditions that led the former DHEC State Toxicologist who evaluated this issue and memorialized his findings in the October 1996 letter have not substantially changed and are not expected to change. As Dr. Brown referenced, there is no ongoing monitoring program for these microorganisms in this location largely because no increased risk has been identified. That remains true today.

For all of the reasons listed in the Enercon letter/report, we concur that there is "no impediment to the license renewal or continued operation of the ONS based on the potential of impacting public health and safety relative to increased potential for growth of thermophilic microorganisms."

S.C Department of Hea lth and Environmen tal Control 2600 Bull Stree t Co lumbia. SC 29201 (803) 898 3432 www scdhec gov

If you have questions or need any additional information, please don't hesitate to contact me by phone (803.422.1805) or e-mail (marshaf2@dhec.sc.gov) .

Thank you, s/Fran W. Marshall Fran W. Marshall, JD, MSPH Director of the Office of Applied Science cc: Mike Ruhe, Duke Energy, Director, Environmental Policy and Affairs Rounette Nader, Duke Energy, Director Nuclear Engineering Myra C. Reece, DHEC Director of Environmental Affairs Bryan Rabon, DHEC Bureau of Water, Manager Aquatic Science Programs

(_~ DUKE J. Ed Burdlfleld, J r.

ENERGY. YIC8 President Oconee Nuclesr Station Duke Energy ONOIVP / 7800 Rochester Hwy Seneca, SC 29672

- 864.873.3478

' 864.873.5791 Ed.Bufthfteld Oduks-ene,gy com BY U.S. MAIL RETURN RECEIPT REQUESTED November 11, 2019 Ms. Kimberly Bose, Secretary Federal Energy Regulatory Commission 888 First Street N.E.

Washington, DC 20426 RE: Duke Energy - Oconee Nuclear Station Units 1, 2, and 3 Subsequent License Renewal

Dear Ms. Bose:

Duke Energy Carolinas, LLC (Duke Energy) is seeking to renew the operating license for Oconee Nuclear Station Units 1, 2, and 3 (ONS) for an additional 20 years (see Table 1). Duke Energy and ONS have safely and reliably provided electricity to our Carolinas customers for decades. ONS has generated clean and cost-effective power, provided thousands of well-paying jobs, and produced substantial economic benefits for the Carolinas. Renewing the licenses of ONS is important for our customers, communities and environment.

Table 1. ONS Licensing Dates Extended License Expiration ONS Unit License Expiration Date Date Unit 1 February 6, 2033 February 6, 2053 Unit2 October 6, 2033 October 6, 2053 Unit 3 July 19, 2034 July 19, 2054 Duke Energy's nuclear fleet plays an important role in the company's efforts to lower carbon emissions. In 2018, the Duke Energy nuclear fleet generated more than 72 billion kilowatt-hours of electricity and avoided the release of about 54 million tons of carbon dioxide- equivalent to keeping more than 1o million passenger cars off the road. The company has set aggressive carbon reduction goals of at least 50% by 2030 and net-zero by 2050 and keeping its nuclear fleet operating is key to achieving these goals.

Renewing the nuclear licenses will provide significant value to Duke Energy customers, as well as continue to support Carolinas communities through jobs, tax revenues and partnerships.

Duke Energy employs about 5,000 workers in its nuclear group, with additional contract workers supporting refueling outages and project work. In 2018, the Duke Energy also paid more than

$300 million in property and payroll taxes associated with the nuclear stations, benefiting local governments and school districts. In addition, nuclear employees support the communities where they live and work by donating time and funds through sponsorships and volunteer activities.

The ONS site is situated on 510 acres in eastern Oconee County, South Carolina (SC),

approximately eight miles northeast of Seneca, SC, on the southern shore of Lake Keowee.

During the license renewal term, Duke Energy proposes to continue operating the units as currently operated. There are currently no ground-disturbing activities or refurbishment anticipated at the ONS site during the subsequent license renewal period. Figures depicting the station site and the vicinity within a 6-mile radius of the station are enclosed.

Should you or your team have any questions or comments about ONS or the license renewal process, please contact Alan Stuart at (980) 373-2079 / Alan.Stuart@duke-energy.com.

Sincerely, J Cf ILJff)I/

J. Ed Burchfield, Jr Site Vice President Oconee Nuclear Station Attachments:

Figure 1. ONS Site Figure 2. ONS 6-mile Vicinity 2 of 4 I f' .i ~. ,*

Figure 1. ONS Site Legend c::IONSSite

====iMiles 0 0.25 0.5 3 of 41 I' :1 g L'

Figure 2. ONS 6-mile Vicinity Legend a Airport . . Surface Water D Heliport 0NSS1te U.S. Route i_-_i 8-Mile Radius

- - State Highway Place Local Road c:Jeounty ---==:::::,M~s 0 2

- Railroad 4of4j Pa~l'

(_~ DUKE J. Ed Burchfield, Jr.

ENERGY. \r,ce President Oconee Nuclear Station Duke Energy ONOI VP f 7800 Rochester Hwy Seneca, SC 29672 864.873.3478 f 864.873.5791 Ed.Bu11:hfie/d Oduke-ene,gy.oom evu.s. MAIL RETURN RECEIPT REQUESTED November 11, 2019 Doug Hof, President Friends of Lake Keowee Society 4065 Keowee School Rd Seneca, SC 29672 RE: Duke Energy - Oconee Nuclear Station Units 1, 2, and 3 Subsequent License Renewal

Dear Mr. Hof:

Duke Energy Carolinas, LLC (Duke Energy) is seeking to renew the operating license for Oconee Nuclear Station Units 1, 2, and 3 (ONS) for an additional 20 years (see Table 1). Duke Energy and ONS have safely and reliably provided electricity to our Carolinas customers for decades. ONS has generated clean and cost-effective power, provided thousands of well-paying jobs, and produced substantial economic benefits for the Carolinas. Renewing the licenses of ONS is important for our customers, communities and environment.

Table 1. ONS Licensing Dates Extended License Expiration ONS Unit License Expiration Date Date Unit 1 February 6, 2033 February 6, 2053 Unit2 October 6, 2033 October 6, 2053 Unit3 July 19, 2034 July 19, 2054 Duke Energy's nuclear fleet plays an important role in the company's efforts to lower carbon emissions. In 2018, the Duke Energy nuclear fleet generated more than 72 billion kilowatt-hours of electricity and avoided the release of about 54 million tons of carbon dioxide - equivalent to keeping more than 1o million passenger cars off the road. The company has set aggressive carbon reduction goals of at least 50% by 2030 and net-zero by 2050 and keeping its nuclear fleet operating is key to achieving these goals.

Renewing the nuclear licenses will provide significant value to Duke Energy customers, as well as continue to support Carolinas communities through jobs, tax revenues and partnerships.

Duke Energy employs about 5,000 workers in its nuclear group, with additional contract workers supporting refueling outages and project work. In 2018, the Duke Energy also paid more than

$300 million in property and payroll taxes associated with the nuclear stations, benefiting local governments and school districts. In addition, nuclear employees support the communities where they live and work by donating time and funds through sponsorships and volunteer activities.

The ONS site is situated on 510 acres in eastern Oconee County, South Carolina (SC),

approximately eight miles northeast of Seneca, SC, on the southern shore of Lake Keowee.

During the license renewal term, Duke Energy proposes to continue operating the units as currently operated. There are currently no ground-disturbing activities or refurbishment anticipated at the ONS site during the subsequent license renewal period. Figures depicting the station site and the vicinity within a 6-mile radius of the station are enclosed.

Should you or your team have any questions or comments about ONS or the license renewal process, please contact Mlkayla Kreuzberger at (864) 873-4204 / Mikayla.Kreuzberger@duke-energy.com or Alan Stuart at (980) 373-2079 / Alan.Stuart@duke-energy.com.

Sincerely,

)Cl~

J. Ed Burchfield, Jr Site Vice President Oconee Nuclear Station Attachments:

Figure 1. ONS Site Figure 2. ONS 6-mile Vicinity

o~ - - ~====iMles 0.25 0.5 3 Of 41 fl ,l g t'

Figure 2. ONS 6-mile Vicinity Legend a Airport . . Surface Water D Heliport 0NSS1te U.S. Route i_-_i 8-Mile Radius

- - State Highway Place Local Road c:Jeounty ---==:::::,M~s 0 2

- Railroad 4of4j Pa~l'

(_~ DUKE J. Ed Burchfield, Jr.

ENERGY. \rice President Oconee Nuclsar Station Duke Energy ONO 1VP / 78()() Rochester Hwy Seneca, SC 29672

" 864.873.3478

864.873.5791 Ed.Burchfield @dul<e-ene,r,y.com BYU.S. MAIL RETURN RECEIPT REQUESTED November 11, 2019 Rob Auhlebach Advocates for Quality Development P.O. Box 802 Seneca, SC 29679 RE: Duke Energy - Oconee Nuclear Station Units 1, 2, and 3 Subsequent Ucense Renewal

Dear Mr. Auhlebach:

Duke Energy Carolinas, LLC (Duke Energy) is seeking to renew the operating license for Oconee Nuclear Station Units 1, 2, and 3 (ONS) for an additional 20 years (see Table 1). Duke Energy and ONS have safely and reliably provided electricity to our Carolinas customers for decades. ONS has generated clean and cost-effective power, provided thousands of well-paying jobs, and produced substantial economic benefits for the Carolinas. Renewing the licenses of ONS is important for our customers, communities and environment.

Table 1. ONS Licensing Dates Extended License Expiration ONS Unit License Expiration Date Date Unit 1 February 6, 2033 February 6, 2053 Unit 2 October 6, 2033 October 6, 2053 Unit3 July 19, 2034 July 19, 2054 Duke Energy's nuclear fleet plays an Important role in the company's efforts to lower carbon emissions. In 2018, the Duke Energy nuclear fleet generated more than 72 billion kilowatt-hours of electricity and avoided the release of about 54 million tons of carbon dioxide - equivalent to keeping more than 10 million passenger cars off the road. The company has set aggressive carbon reduction goals of at least 50% by 2030 and net-zero by 2050 and keeping its nuclear fleet operating is key to achieving these goals.

Renewing the nuclear licenses will provide significant value to Duke Energy customers, as well as continue to support Carolinas communities through jobs, tax revenues and partnerships.

Duke Energy employs about 5,000 workers in its nuclear group, with additional contract workers supporting refueling outages and project work. In 2018, the Duke Energy also paid more than

$300 million in property and payroll taxes associated with the nuclear stations, benefiting local governments and school districts. In addition, nuclear employees support the communities where they live and work by donating time and funds through sponsorships and volunteer activities.

The ONS site is situated on 510 acres in eastern Oconee County, South Carolina (SC),

approximately eight miles northeast of Seneca, SC, on the southern shore of Lake Keowee.

During the license renewal term, Duke Energy proposes to continue operating the units as currently operated. There are currently no ground-disturbing activities or refurbishment anticipated at the ONS site during the subsequent license renewal period. Figures depicting the station site and the vicinity within a 6-mile radius of the station are enclosed.

Should you or your team have any questions or comments about ONS or the license renewal process, please contact Mikayla Kreuzberger at (864) 873-4204 / Mikayla.Kreuzberger@duke-energy.com or Alan Stuart at (980) 373-2079 / Alan.Stuart@duke-energy.com.

Sincerely,

)Cl~~

J. Ed Burchfield, Jr Site Vice President Oconee Nuclear Station Attachments:

Figure 1. ONS Site Figure 2. ONS 6-mile Vicinity

Legend c::J ONS Site

--~=~

0 0.25 M~es 05 3 Of 4 I J' i l )! l '

Figure 2. ONS 6-mlle Vicinity Pickens Countv Central Clemsofi Legend D Airport . . Surface Water c::J ONS Site D Heliport U.S. Route

- - State Highway

- _18-Mile Radius Place Local Road t::'J eounty

__.... Railroad 4of 4 I I' ;1 g c

/ -.. DUKE J. Ed Burchfield, Jr.

' ENERGY. Vice Pres/d6nt Oconee Nuclear Station Duke Energy ONOt VP / 7800 Roch8ster Hwy Seneca. SC 296'12 o 864.873.3478 I 884.873.5791 Ed.Burchfield OcJuke.energy.com BY U.S. MAIL RETURN RECEIPT REQUESTED November 11, 2019 Chris Starker, Land Conservation Manager Upstate Forever 507 Pettigru St Greenville, SC 29601 RE: Duke Energy - Oconee Nuclear Station Units 1, 2, and 3 Subsequent License Renewal

Dear Mr. Starker:

Duke Energy Carolinas, LLC (Duke Energy) is seeking to renew the operating license for Oconee Nuclear Station Units 1, 2, and 3 (ONS) for an additional 20 years (see Table 1). Duke Energy and ONS have safely and reliably provided electricity to our Carolinas customers for decades. ONS has generated clean and cost-effective power, provided thousands of well-paying jobs, and produced substantial economic benefits for the Carolinas. Renewing the licenses of ONS is important for our customers, communities and environment.

Table 1. ONS Licensing Dates Extended License Expiration ONS Unit License Expiration Date Date Unit 1 February 6, 2033 February 6, 2053 Unit2 October 6, 2033 October 6, 2053 Unit3 July 19, 2034 July 19, 2054 Duke Energy's nuclear fleet plays an important role In the company's efforts to lower carbon emissions. In 2018, the Duke Energy nuclear fleet generated more than 72 billion kilowatt-hours of electricity and avoided the release of about 54 million tons of carbon dioxide - equivalent to keeping more than 1O million passenger cars off the road. The company has set aggressive carbon reduction goals of at least 50% by 2030 and net-zero by 2050 and keeping its nuclear fleet operating is key to achieving these goals.

Renewing the nuclear licenses will provide significant value to Duke Energy customers, as well as continue to support Carolinas communities through jobs, tax revenues and partnerships.

Duke Energy employs about 5,000 workers in its nuclear group, with additional contract workers supporting refueling outages and project work. In 2018, the Duke Energy also paid more than

$300 million in property and payroll taxes associated with the nuclear stations, benefiting local governments and school districts. In addition, nuclear employees support the communities where they live and work by donating time and funds through sponsorships and volunteer activities.

The ONS site is situated on 510 acres In eastern Oconee County, South Carolina (SC),

approximately eight miles northeast of Seneca, SC, on the southern shore of Lake Keowee.

During the license renewal term, Duke Energy proposes to continue operating the units as currently operated. There are currently no ground-disturbing activities or refurbishment anticipated at the ONS site during the subsequent license renewal period. Figures depicting the station site and the vicinity within a 6-mile radius of the station are enclosed.

Should you or your team have any questions or comments about ONS or the license renewal process, please contact Mikayla Kreuzberger at (864) 873-4204 I Mikayla.Kreuzberger@duke-energy.com or Alan Stuart at (980) 373-2079 / Alan.Stuart@duke-enerqy.com.

Sincerely,

)UIJ..PfJJ/

J. Ed Burchfield, Jr Site Vice President Oconee Nuclear Station Attachments:

Figure 1. ONS Site Figure 2. ONS 6-mile Vicinity 2 of 4 I I'., ):.:

Figure 1. ONS Site Legend c:::JoNSSite

====::iMll 0 0.25 0.5 ea 3 of 4 I 1' :1 ~ e

Figure 2. ONS 6-mlle Vicinity legend r:I Airport Surface Water D Heliport US, Route

.. - State Highway c::JoNSSrte

- . I B-M*e Radius Place Local Road Q eounty 0

==::::,MHea 2

~ Railroad 4 Of 41 p d )' ~*

( ~ DUKE

~ ENERGY.

J. Ed Burchfltld, Jr.

V,ce Pl'9Sid9nt Oconee Nuclear Station Duke Energy ONOtVP / 7800 Rochester Hwy Sen8ca, SC 29672 Il 864.873.3478 I 864.873.5791 Ed.Burchfield @cJuke.energy.com BYU.S. MAIL RETURN RECEIPT REQUESTED November 11, 2019 Sara Green, Executive Director SC Wildlife Federation 215 Pickens Street Columbia, SC, 29205 RE: Duke Energy - Oconee Nuclear Station Units 1, 2, and 3 Subsequent License Renewal

Dear Ms. Green:

Duke Energy Carolinas, LLC (Duke Energy) is seeking to renew the operating license for Oconee Nuclear Station Units 1, 2, and 3 (ONS) for an additional 20 years (see Table 1). Duke Energy and ONS have safely and reliably provided electricity to our Carolinas customers for decades. ONS has generated clean and cost-effective power, provided thousands of well-paying jobs, and produced substantial economic benefits for the Carolinas. Renewing the licenses of ONS is important for our customers, communities and environment.

Table 1. ONS Ucensing Dates Extended License Expiration ONS Unit License Expiration Date Date Unit 1 February 6, 2033 February 6, 2053 Unit2 October 6, 2033 October 6, 2053 Unit3 July 19, 2034 July 19, 2054 Duke Energy's nuclear fleet plays an important role in the company's efforts to lower carbon emissions. In 2018, the Duke Energy nuclear fleet generated more than 72 billion kilowatt-hours of electricity and avoided the release of about 54 million tons of carbon dioxide - equivalent to keeping more than 10 million passenger cars off the road. The company has set aggressive carbon reduction goals of at least 50% by 2030 and net-zero by 2050 and keeping its nuclear fleet operating is key to achieving these goals.

Renewing the nuclear licenses will provide significant value to Duke Energy customers, as well as continue to support Carolinas communities through jobs, tax revenues and partnerships.

Duke Energy employs about 5,000 workers in its nuclear group, with additional contract workers supporting refueling outages and project work. In 2018, the Duke Energy also paid more than

$300 million in property and payroll taxes associated with the nuclear stations, benefiting local governments and school districts. In addition, nuclear employees support the communities where they live and work by donating time and funds through sponsorships and volunteer activities.

The ONS site is situated on 510 acres in eastern Oconee County, South Carolina (SC),

approximately eight miles northeast of Seneca, SC, on the southern shore of Lake Keowee.

During the license renewal term, Duke Energy proposes to continue operating the units as currently operated. There are currently no ground-disturbing activities or refurbishment anticipated at the ONS site during the subsequent license renewal period. Figures depicting the station site and the vicinity within a 6-rnile radius of the station are enclosed.

Should you or your team have any questions or comments about ONS or the license renewal process, please contact Mikayla Kreuzberger at (864) 873-4204 / Mikayla.Kreuzberger@duke-energy.com or Alan Stuart at (980) 373-2079 / Alan.Stuart@duke-energy.com .

Sincerely,

) ~ aJ/id; J. Ed Burchfield, Jr Site Vice President Oconee Nuclear Station Attachments:

Figure 1. ON$ Site Figure 2. ONS 6-mile Vicinity

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el_, DUKE J. Ed Burchfield, Jr.

~ ; ENERGY. Vk:e President Oconee Nuclear Station Duke Energy ONOIVP I7800 Rochester Hwy Sen8cs, SC 29672 864.873.3478 f 864.873.5791 Ed.Burchfield Oduk8-en8Jr,y.com BY U.S. MAIL RETURN RECEIPT REQUESTED November 11, 2019 Douglas Spencer Southeastern Power Administration 1166 Athens Tech Rd.

Elberton, GA 30635 RE: Duke Energy - Oconee Nuclear Station Units 1, 2, and 3 Subsequent License Renewal

Dear Mr. Spencer:

Duke Energy Carolinas, LLC (Duke Energy) is seeking to renew the operating license for Oconee Nuclear Station Units 1, 2, and 3 (ONS) for an additional 20 years (see Table 1). Duke Energy and ONS have safely and reliably provided electricity to our Carolinas customers for decades. ONS has generated clean and cost-effective power, provided thousands of well-paying jobs, and produced substantial economic benefits for the Carolinas. Renewing the licenses of ONS is important for our customers, communities and environment.

Table 1. ONS Licensing Dates Extended License Expiration ONS Unit License Expiration Date Date Unit 1 February 6, 2033 February 6, 2053 Unit2 October 6, 2033 October 6, 2053 Unit3 July 19, 2034 July 19, 2054 Duke Energy's nuclear fleet plays an important role in the company's efforts to lower carbon emissions. In 2018, the Duke Energy nuclear fleet generated more than 72 billion kilowatt-hours of electricity and avoided the release of about 54 million tons of carbon dioxide - equivalent to keeping more than 1O million passenger cars off the road. The company has set aggressive carbon reduction goals of at least 50% by 2030 and net-zero by 2050 and keeping its nuclear fleet operating is key to achieving these goals.

Renewing the nuclear licenses will provide significant value to Duke Energy customers, as well as continue to support Carolinas communities through jobs, tax revenues and partnerships.

Duke Energy employs about 5,000 workers in its nuclear group, with additional contract workers supporting refueling outages and project work. In 2018, the Duke Energy also paid more than

$300 million in property and payroll taxes associated with the nuclear stations, benefiting local govemments and school districts. In addition, nuclear employees support the communities where they live and work by donating time and funds through sponsorships and volunteer activities.

The ONS site is situated on 510 acres in eastern Oconee County, South Carolina (SC),

approximately eight miles northeast of Seneca, SC, on the southern shore of Lake Keowee.

During the license renewal term, Duke Energy proposes to continue operating the units as currently operated. There are currently no ground-disturbing activities or refurbishment anticipated at the ONS site during the subsequent license renewal period. Figures depicting the station site and the vicinity within a 6-mile radius of the station are enclosed.

Should you or your team have any questions or comments about ONS or the license renewal process, please contact Ed Bruce at (704) 382-5239 / Ed.Bruce@duke-enerqy.com.

Sincerely, J. Ed Burchfield, Jr Site Vice President Oconee Nuclear Station Attachments:

Figure 1. ONS Site Figure 2. ONS 6-mile Vicinity 2 of 4 I P a ~* l'

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<{; ENERGY. V-IC9 President Oconee Nuctear Station Duke Energy ONOtVP f 1800 Roch9Slflf Hwy Seneca, SC 29672

864.873 3478 I 864.873.5791 Ed.Burchfield @dukHnergy.com BY U.S. MAIL RETURN RECEIPT REQUESTED November 11, 2019 Amanda Brock, County Administrator Oconee County 415 S Pine St Walhalla, SC 29691 RE: Duke Energy - Oconee Nuclear Station Units 1, 2, and 3 Subsequent License Renewal

Dear Ms. Brock: