NC0003425_Correspondence_20200608 (5)

(' DUKE
ENERGY
March 29, 2019
Ms. Julie Grzyb, Supervisor
NPDES Complex Wastewater Permitting
NC DEQ/DWR/WQ Permitting Section
1617 Mail Service Center
Raleigh NC 27699-1617
RE: Roxboro Steam Electric Plant, NPDES Permit NC0003425
Request for Designation as Closed -Cycle Recirculating System
Dear Ms. Grzyb,
Duke Energy
411 Fayetteville Street
Mail Code: NC15
Raleigh, NC 27601
This letter is to request that the Duke Energy Progress, LLC (Duke Energy) Roxboro Steam
Electric Plant be designated a closed cycle recirculating system (CCRS) pursuant to the United
States Environmental Protection Agency's Final Regulations to Establish Requirements for
Cooling Water Intake Structures at Existing Facilities and Amend Requirements at Phase I
Facilities, 79 Fed. Reg. 48,299 (August 15, 2014) as codified at 40 CFR §§ 122 and 125 (the
Cooling Water Intake Rule).
The NPDES permit renewal application for the Roxboro Steam Electric Plant (Roxboro),
submitted on September 28, 2011, is currently under review by the Department. Pursuant to 40
CFR § 125.95(a)(2), Duke Energy requested, and the Department established, an alternate
schedule for the submission of application materials described in 40 CFR § 122.21(r). Until that
information is submitted, the Department can establish an interim Best Technology Available
(BTA) for this facility, per the Rule. A designation of BTA and identification of the Roxboro
system as CCRS for the purpose of the pending permit would allow Duke Energy additional time
to complete certain ongoing studies and provide the Department with additional time to review
entrainment and impingement at the facility. As stated in the preamble to the Cooling Water
Intake Rule, when cooling systems involving impoundments meeting the definition of CCRS, the
permitting authority can consider whether additional controls are warranted to protect against
adverse impacts due to entrainment or impingement (79 Fed. Reg. 48,348). To facility further
review, Duke Energy will submit the application information required by the Cooling Water
Intake Rule as set out in the alternate schedule in I(A.)(28.) of the January 21, 2017 Public
Notice draft (a requirement that Duke Energy expects in the final permit).
Basis for Designation as a CCRS
A "closed -cycle recirculating system" is defined at 40 CFR 125.92 (c). The definition addresses
facilities with CCRS that withdraw from waters of the United States where the impoundment
was constructed for the purpose of providing cooling water for the facility:

Ms. Julie Grzyb, Supervisor
March 29, 2019
Page 2
"Closed -cycle recirculating system also includes a system with impoundments
of waters of the U.S. where the impoundment was constructed prior to October
14, 2014 and created for the purpose of serving as part of the cooling water
system as documented in the project purpose statement for any required Clean
Water Act section 404 permit obtained to construct the impoundment. In the
case of an impoundment whose construction pre -dated the CWA requirement
to obtain a section 404 permit, documentation of the project's purpose must be
demonstrated to the satisfaction of the Director. This documentation could be
some other license or permit obtained to lawfully construct the impoundment
for the purposes of a cooling water system, or other such evidence as the
Director finds necessary." 40 CFR 125.92 (c)(2).
Impoundments are further defined and discussed as a closed -cycle cooling system in the rule's
preamble, stating that:
"Impoundments are surface waterbodies that serve as both a source of cooling water
and a heat sink. As with cooling towers, impoundments rely on evaporative cooling
to dissipate the waste heat; a facility withdraws water from one part of the
impoundment and then discharges the heated effluent back to the impoundment,
usually in another location to allow the heated water time to cool. Depending on
local hydrology, impoundments may also require makeup water from another
waterbody. Impoundments can be man-made or natural, and can be offset from
other water bodies or as part of a "run of the river" system (the latter are sometimes
referred to as cooling lakes)." 79 Fed. Reg. 48,334 (August 15, 2014)
The system at Roxboro meets the criteria for classification as a CCRS. Roxboro withdraws
cooling water from Hyco Lake which was constructed in a water of the United States for the
purpose of providing cooling water for the Carolina Power & Light Company (now Duke
Progress, LLC) Roxboro Steam Electric Plant prior to the Clean Water Act 404 permitting
program. As demonstrated in the attached documents, the Carolina Power & Light Company
received authorization for the creation of Hyco Lake in April 1964 for the Roxboro facility.
Several references, including those listed below provided as an enclosure to this letter, contain
several statements and commensurate justification that the purpose of Hyco Lake was to be
"operated ... to reduce pollution [via condenser cooling water recirculation] in the Hyco River"
and is a "cooling pond":
• State of North Carolina Department of Water and Air Resources Permit 522 issued May
4, 1964
• Carolina Power & Light Company, North Carolina State Stream Sanitation Committee
"Application for Approval of Plans" dated April 13, 1964
• North Carolina Board of Water and Air Resources Permit 522 Certification dated October
1, 1971
• North Carolina Environmental Management Commission Permit 2523 issued July 22,
1974

Ms. Julie Grzyb, Supervisor
March 29, 2019
Page 3
The permit issued by the State of North Carolina Department of Water and Air Resources (the
predecessor Agency to the North Carolina Department of Environmental Quality) authorized
"...operation of a 3,800 acre cooling lake for a design flow of 2,400,000,000 G.P.D., and the
discharge of the effluent into the Hyco River, a tributary in the Roanoke River Basin". The dam
was completed in 1964 and Hyco Lake reached full pool elevation in 1965.
As also required by the definition, make-up water withdrawals attributable to the cooling portion
of the Roxboro cooling system have been minimized. The source of all makeup water is the
approximately 300 square mile Hyco Lake watershed. No other sources of makeup water are
currently available and none are planned.
In addition to minimizing withdrawals for make up water to Hyco Lake, Roxboro also minimizes
cooling water withdrawals from Hyco Lake in multiple ways. First, Unit 4 operates on
recirculating cooling towers that require only small volumes of makeup waters. Those make up
waters are taken from internal process areas consisting of Unit 1-3 cooling water discharge and
the ash basin discharge flows. Second, the cooling water system for Units 1-3 has several design
features that increase their efficiency, including (a) directing deeper, cooler water to the intake as
needed to maintain efficiency by using cooler water from deeper in the reservoir; (b) routing of
cooling water discharges as far as possible upstream from the cooling water intake (subject to
constraints imposed by the Department for thermal impact reasons); and (c) utilization on Unit 3
of a helper cooling tower seasonally which reduces the thermal discharge load to the lake and
allows for more efficient cooling during the summer months. Third, as reflected in the
company's Integrated Resources Plans, filed with the North Carolina Utilities Commission,
Roxboro has operated since 2016 as an "Intermediate" rather than `Baseload" generation
source. The reduction in operating time has resulted in a reduction of average daily withdrawals
from greater than 800 MGD when the plant operated as Baseload to 592 MGD in 2018, as
reported in the station's annual water withdrawal reports.
Consistent with the purpose of its creation as a CCRS and the fact that there is no additional
makeup flow to the CCRS, make-up water withdrawals to the CCRS attributed specifically to the
cooling portion of the cooling system have been minimized.
If there are any questions, please contact me or Lori Tollie at [e-mail] or
336-854-4916. Duke Energy sincerely appreciates your assistance with this matter.
Sincerely,
E. Shannon Langley
Principal Environmental Specialist
Enclosures

Ms. Julie Grzyb, Supervisor
March 29, 2019
Page 4
Cc: Tom Copolo — Station Manager (w/attachments)
Robert Howard (w/attachments) — via email
Lori Tollie/FileNet (w/attachments) — via email
Stephen Conner (w/ attachments) — via email
Richard Baker (w/attachments) — via email
Michael Smallwood (w/attachments) — via email
Reid Garrett (w/attachments) — via email

March 29, 2019 Submittal
Roxboro Steam Electric Plant, NPDES Permit
NC0003425
Request for Designation as Closed -Cycle
Recirculating System
Enclosures

NORTH CAROLINA
STATE STRE101 SANITATION' C0;.111) 1 i tE
STATE DEPART:4ENT OF WATER RESOURCES
P. 0. BOX 9392
RALEIGH
ML EXHIBIT NO. 1
APPLICATION FOR APPROVAL OF PLARS AND ISSUANCE OF FIL
"C.ERTIFICATF OF APPROVAL" OR "PERMIT" co/
TO Y
DISCHARCE SEYIAGE, INDUSTRIAL VASTES OR MEAT!'E`aT PLANT S�
EFFLUENTS INTO T11E WATERS OF THE STATE
.......
ktj it 13 19i>4-
To: The State Stream Sanitation Committee
Raleigh, North Carolina
Gentltmen:
In accordance with Lite provisions of Article 21 of Chapter 143, General Statutes
of North Carolina (Chapttr (.06, Session Laws of )9S)), application i:, hrrel.y made
by r•1 uffi_-.r of Liar f 'u •t`si`di� f' ,ir.`�iS. ytltx
(Name of board, individual or others) (Name of cit2 village, town,
in the county of t,ai:a , to the State
sanitary dislriet or estab)ishment) (Narnc of county)
St.reem Sanitation Committee for approval of the atrnmpunying pl,.ns, specifications and
other Joan subeitted herewith covering n eoOJPJ)j ail n,'`cxf<al::r7y JLC'J t2_res
ti—all till f.,.L'Y r'1 t.1L1,:r.r,(;3 CF1)? .ftV of wJ'.) io'I r.t.. 0iG C;,;, %anytc 11::!
ltu::t,uru 11:t:)i: ir. I'.^rcnn C„ant
and for a "Certificate of Approve)" and/or "Permit" for Lite discharge of
c_ Iletld r® (sera fr,
from the —�-- serving
indus,:ir.l waste or combinnU.-its) (sewers or treatm,nt plant)
_ w . .:,-c- o . :ta tltu cttrface
_ into _
(Name of utinn or indu::tty, etr.) (nrface or ground waters)
w0n
aters of t"nt:.; :tiii•j ;r.: _ ._..c:I by A max': � LLO liyco lay?r
(Name of water cnur,:c if surfr.,e vrters; if prnund watr.rs. state rater
course to whrrh they are tribuLary) (exact location of point of disrIarrr.)
■ The plans for Lite proposed wt•rks have been prepared by rbor o neryi_us Inc.
• (Enptncering Firm)
ofy li.i. Zt_'0SL is esti.,ated that lreotmcnt weal - rill provide
(Address)
adequate capacity to serve the Ro-:`oro Stemma LIvictric 111a]t: for art indeitnite
(City, town, seuitLry district or estab)inl, ent)
perind�f''''^r'�tYr al y(,tch time it is estimate/ the average dailyb7tJ::aY2i5,1t>re
flow will not. exceedL•r{ i a'•(1
� gallons. It is further expected that the treatment
works will effect overall reductions in pollutinn as followe.: n.0.1). (S-day
IL
200C t_ ,— suspended rnlids t"L total solids" i, coliform bacteria 1`1
;•,.
end toxic ritcrials ' ` '�. The cost of Lite proposed works is estimated to he:
sewers f• _.�� pumping stations f—'i� treatment plant > '11
• eOOlict;g pon(Ly. The.. works will be con.pleted and in operation on or before
attached
The applicant hereby agrees that Lite proposed works will be constructed in strict
accordance with Lite approved plot,, and specificaLions or subsequently approved changes
therein and further agrees to place its operation nr.der the care of a competent person
and to mnintein end op�rnt, the plant according to the best accepted practice and in
accordance wiLh Lite plans and specifications approved by the Committee.
7� l• 1 �i
Signature
Title l'Lce•F'rr:r'.dc : _ C.�-.rulina 1'c.:ur & Ll;,ht Cctrpriay
ra1c:.;;lla North Carolina
Mailing Address _
• Specify percentage reducLion for each toxic substnare, uving additional sleet, if
near scary.
(See Instructions on revers- side)
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NO3TIi C AROLINTA
FIr 6-LATE STR„A 1 SANITATION C011%Iit 1•EVE
LE
Copy RALMGH
3- -/a- 3 PERMIT
For the Discharge of Sewage, LTdustrial Wastes, or Other Wastes
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Caro-
lina as amended, and other applicable Laws, Rules and Fe--ulations,
PERAIISSION IS HEREDY GRANTED TO
Carolina Po:r,:r & L �_;E;r. Co;11pany
Roxboro Stea:z lec+ric Plant
Person Cou- ty, :;Ortz Carolina
FOR T::E
operation of a 3,800 acre cooling pond for a desi-q flo?-r
of 22400,000,000 G.P.D., and the discharge of the efflu-
ent into the 1�rco P,iver, a tributary in the 2'oanoke 3ire�
Basin,
in accordance tivit`t tI:e application dated ------ _--- 0:--1-15 ---__ 19-64L, and in conformity with
the plans. specifications, and other supporting data, all of which are filed with the State Stream San,
tation Committee and are considered a part of this Permit.
This Permit shall be effective from the date of its issuance until _p'?lTied o==escide�and
shall be subject to the following specified conditions and limitations:
1. This Peru shall beco-e void unless the facilities awe :on-
st-z".cted in accord=ca with the arvroved plans, SpeClf1C' _ ._:S
and other supporting data a _d are co:a_ leted and p '
tion on or before 1:a-- 1. 1 laced i:. O_
r 9c6 , or ws this data may be ar:e-:ded
by the State Stream Sanitation CouTll+tee.
2. This Pe=. it is effective only with respect to the nature of the
operations described in the application and ot:.er supporting data.
3. The Cooling pond shall be operated in such a raruner as to pro-
vide a Mni'T=-- disCharga of 7.0 cf s, or other:•r_se in lceening withthe discharge schedules set forth in the applica+ion and otl'.e=
supporting data.
4. The operation of the coolies pond shall result in the temuera-
ture of the lane discharge being; substantially in 'teeping ,.jit +nose
Set forth In the af�pllCaU.L �71d Oth er s;�pportL�lb da�,a, or x-rise as to 2intai-� applicable assi&zed water cuality standards.
Permit issued this the---�----- day of-----_'� �------,
Per:rit No.
10.16.6: 4M
Sionad�-.:1.ws
1----------
. C. ?ubb�rd, Sccretary
State Stream Sanitation Committee

1 �1
Copy
Sf) - l�
NORTH CAROLINA
BOARD OF WATER AND AIR RESOURCES
RALEIGH
C E R T I F I C A T I O N
(Covering the issuance of "Certificate of Approval" or "Permit")
In accordance with the provisions of the General Statutes of North Carolina
(G.S. 105-122, 105-147, 105-294, 105--29G, and 105-297), this is to certify
that:
Carolina Power and Light Company
Roxboro Steam Electric Plant
Person County, North Carolina
has been issued "Permit" No. 522 covering the construction and operation of
waste treatment facilities, and the discharge of the effluent into H co
River. a tributary in the Roanoke River basin, in accordance with the applica—
tion filed on April 13, 1964. in the office of the Board of Water and Air
Resources and in conformity with the plans, specifications, and other data sub—
mitted in support of said application.
It is further certified that the following conditions have been met:
1. The facilities referred to above have been constructed and
placed into operation.
2. The facilities comply with the requirements of the Board of
Water and Air Resources with respect to such facilities, and
are being effectively operated in accordance with the terms
and conditions set forth in the "Permitil.
3. The primary purpose of said facilities is to reduce pollution
in the Roanoke, resulting from the discharge of wastes.
Issued at Raleigh, North Carolina, this lst day of October. 1971.
Signed ,,�_,._
E. C. Hubbard, Assistan Director
Department of Water & Air Resources

S T'1; S'1'l�I:APl SANITATION COMM,. .I:i: CP&L EXI11111T NO. 2
JILE
RALL•'1GH
COPY� P E R M z T .
For the Diselwirge of Scwa c, Industri.11 `raster',, or Other Wastes
In accordance mith the provisions of Article 21. of Chapter 143, General Statutes of North Caro-
lina as amended, and other applicable Laws, Rules and P'Legulations,
PERIti'IMSION IS IiEI:E1�Y GRANTED TO
Carolina Power & bight Company
Roxboro Stem Electric Pl::nt
Person County, North Carolina
FOR THE
operation of a 3,800 acre cooling pond for a desirn flog
of 2,400,000,000 G.P.D., and the discharSe of the efflu-
ent into the llvrco River, a tributary in the P.owiokc River
Basin,
a
In accordance with the application dated ------ ___--- 1964 and in cmnformity v:ith
the plans, specifications, and other supporting data, all of which are filed with the State: Stream Sani-
tation Committee and are considered a part of this Permit.
This Permit shall be effective from the date of its issuance until _ oclifi.ed or_re_ cin ed, al,d
-• shall be subject to the follonving specified conditions and limitation :
J
1. This Perrot shall beco;ae void .unless the facilities are con-
structed in accordance with the approved plans, specifications,
and other supporting data and are completed and placed in opera-
tion on or before May 11 1966 , or as this date mwy be amended
• by the State Stream Sanitation Committee.
2. This Pe .sit is effective only with respect to the nature of the
operation-- described in the application and other supporting data.
3. The cooling pond shall be operated in such a manner as to pro-
vide a minimum discharge of 7.0 efs, or otherwise in keeping with
the discharge schedules set forth in the application and other
supporting data.
4. The operation of the cooling pond shall result in the tempera-
ture of the lance discharge being substpuntially in keeping with those
set forth in the application and other supporting; data, or other-
wise as to maintain applicable assiGned water quality standards.
Permit issued this the __A _
Permit No.
10.15.r,�. f hl
day of ----- 21ay------ I9 -1-1:_
Signed
E. C. Hubbard, Sccrclary
Statc Stream Sanitation Committee

Ir
NORTH CAROLIK& /
MW]RONMENTAL MMUMD= CMNISSION
RALEIGH
CERTIFICATION
(Covering the issuance of a Permit)
In accordance with the provisions of the General Statutes of North Carolina
(G.S. 105-275), this is to certify that:
Carolina Power and Light Company
Roxboro Steam Electric Plant
Person County
has been issued Permit Number 2523 for the construction and operation of a 650 acre
afterbay reservoir below Roxboro Cooling Lake (Hyco Lake) with a final discharge
into Hyco River (Roanoke River Basin) at not less than a Flow rate of 10 efs and
the temperature at no time to exceed the allowable stream temperature limits for
Hyco River at this location.
it is further certified that the following conditions have been meta
1. the facilities reffered to above have been constructed and placed into
operation.
she facilities comply with the requirements of the Environmental Management
Commission with respect to such facilities, and are being effectively opera-
ted in accordance with the terms and conditions set forth in the Permit.
The primary purpose of said facilities is to reduce pollution in the Hyco
River, resulting from the discharge of wastewater.
0Issued at Raleigh, North Carolina, this off/ day of , 1974.
Signed i6
E. C. Hubbard, Director
Division of Environmental Management
TC-F-34