NC0005088_NOVNOI2023LV0887_RESP_20231212

(> DUKE
ENERGY
December 12, 2023
North Carolina Department of Environmental Quality
Division of Water Resources
Daniel Boss
2090 US Highway 70
Swannanoa, NC 28778
Subject:
Rogers Energy Complex
Permit # NC0005088
Notice of Violation & Intent to Assess Civil Penalty
NOV-2023-LV-0887
Mr. Boss,
Rogers Energy Complex
Cliffside Steam Station
573 Duke Power Road
Mooresboro,
North Carolina 28114
Roger's Energy Complex received your letter December 6, 2023, transmitting a Notice of Violation
(NOV-2023-LV-0887) for North Carolina General Statute (G.S.) 143-215.1and the facility's NPDES
permit. For the October Discharge Monitoring Report, Duke Energy reported one monthly average Se
permit exceedance for internal outfall 004, the station's Flue Gas Desulfurization system. In
response, Duke Energy offers the following information for further consideration.
Outfall 004 was sampled at the end of the month of October during a period of inefficient operations.
Sulfide and ORP levels indicated additional nutrients should be added to the system to optimize the
reduction of Se. The non -compliant sample was taken before this process control data had been
reviewed. Once Duke Energy's investigation was complete into this matter an additional compliance
sample was taken on November 14 with Se being back in compliance.
The following have been implemented to prevent a similar occurrence:
• Samples will be taken after thorough review of all pertinent process control data.
• The operating parameters have been reviewed with all operators.
• Revision of the performance sampling procedure will be made requiring additional parameters
for operation personnel to evaluate the health of the microorganisms within the bio reactor.
• Define a repository for FGD WWT bioreactor performance results to combine all field/lab into
one central place so all departments can easily review.
• Add additional alarms for ORP into DCS (controls system).
Please direct any correspondence or questions concerning the subject facility NPDES Programs to Steve
Hodges at [phone].

(> DUKE
ENERGY
Rogers Energy Complex
Cliffside Steam Station
573 Duke Power Road
Mooresboro,
North Carolina 28114
"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. 1 am aware that there are significant penalties for submitting false
information, including the possibility of fines and imprisonment for knowing violations."
Sincerely,
-" e� /- ' '
Brandon K. Sipe
General Manager III, Rogers Ene gy Complex
Regulated and Renewable Energy - Carolina Dispatchable Generation
bc: Steve Hodges
Lori Tollie
Record Type Code
ENV-30-32