NC0003425_Draft Permit_20200212

(� DUKE.
�t ENERGY.
Roxboro Steam Electric Plant
17o0 6unnaway Road
Semora, NC 27343
February 12, 2020 RECEIVED
Sergei Chernikov, Ph.D- FEB IS 2020.
North Carolina Department of Environmental Quality NOEWWRIN ES
1617 Mail Service Center
Raleigh NC 27699-1617
RE: Duke Energy Progress, LLC — Roxboro Plant
Comments on DRAFT NPDES Perrriit
NPDES Permit.Number NC0003425
Dear Dr. Chernikov:
Duke Energy. Progress, LLC (hereinafter Duke Energy) staff have reviewed the draft National
Pollutant Discharge Elimination System Permit for Roxboro Steam Electric plant, issued for
public comment by the North Carolina Department of Environmental Quality on January 15,
2020. We appreciate the efforts undertaken to finalize this permit to allow needed activities.
related to station operations and ultimate closure activities at the site. We have divided
comments into two categories in this response: 1.) Substantive comments and I) .
Clarification/typo corrections.
Substantive comments
1. Duke Energy requests that clarification be made that the 2.0 MGD flow limit during
dewatering is related to interstitial water only: Additionally, Duke Energy requests that
the footnote requirement related. to, continuous pH and=TSS monitoring on;pages 5 and 7
be clarified to be applicable to the decanting/dewatering pumps and not the Outfall- 002
location. Continuous monitoring is related to. the pumps and not the Outfall 002 location
where other waste streams commingle.
2. Duke Energy requests clarifying the footnote language on page 9 of 28 to read "Total
residual Chlorine monitoring is required only if chlorine or chlorine derivative is added
to the cooling water." No chlorine is added and this, clarifies that monitoring is not
necessary in this case.
3. It appears that an oversight was made in requiring BOD and Fecal coliform:monitoring at
Outfall 012B on page 18 and 012C on page 19. BOD.and fecal monitoring and
compliance are required at the domestic package plant (Outfall 008). This is the- only
source of BOD and/or fecal coliform, therefore it is requested that BOD and fecal
monitoring be removed from Outfalls 012B and 012C.

Mr. Sergei Chernikov
Roxboro Draft NPDES Permit Comments
February 12, 2020
4: On page 4 of 28, Duke Energy requests removal of language in A.(1) related to the date
of December 31, 2021 for removal of all CCR material in the Eastern Extension
Impoundment. Closure plans outside the permit are being submitted that will drive these
activities. This permit language pre -dated those processes and should be removed as it is
no longer applicable. This was discussed in our meeting on December 6, 2019.
5. On page 9 of 28, Duke Energy requests the removal of hardness sampling at 4C4D
temperature buoy.
6. On page .14 of 28, the footnote that reads "For the purposes of this permit, the term "once
per discharge event" shall mean the discharge from Outfall 002 that occurs within 30
minutes from the time the fly ash containing the metal cleaning waste is discharged into
the ash pond plus the calculated detention time of the ash pond;" is no longer applicable
and should be removed. Chemical metal cleaning waste can no longer be sent to the ash
pond. These wastewaters are now routed to the LRB when generated so sampling should
occur at the LRB.
Clarifications and typo corrections
Numerous changes have been made at the station since the permit was first drafted. The
following items were at one time correct, but flow modifications and other changes have made
them inaccurate.
1. Throughout the permit, clarify that the lined retention basin (LRB) is constructed and in
service as opposed to "proposed". Examples include references in conditions for Outfall
005, 008 and 009.
2. Clarify that wastewater is no longer directed to the ash basin throughout the permit.
Wastewater associated with closure activities will be removed from the ash basins, but no.
operational wastewaters are sent to the ash basins.
3. Clarify Outfall 008 special condition should be A.(22);.
4. Clarify special condition A.(14) which states "These months signify the first month of
each three month of each three month toxicity testing quarter". The designated months
are the last month of each quarter.
Thank you.for your time and attention to this request. If there are any questions, please contact
Lori Tollie at 336.854.4916 or at [e-mail].
Sincerely,
Tom Copolo
Roxboro Station Manager