NC0003425_Historical_2009

Attachment E
Analytical Sampling Results
(Attached Compact Disk)

P received
p-oy
Progress Energy
Application for Special Order of Consent
Attachments
Roxboro Steam Electric Plant
Person County
Permit Number: NC0003425
March 30, 2009

Attachment A
Root Cause Investigation Report

Golder Associates NC, Inc.
4900 Koger Boulevard, Suite 140
Greensboro, North Carolina 27407
Telephone [phone]
Fax [phone]
May 1, 2008
Progress Energy Carolinas, Inc
P.O. Box 1551, PEB 17
Raleigh, North Carolina 27602
Attn: Mr. Charlie Madison
RE: FAILURE EVALUATION
ROXBORO PLANT FGD WASTEWATER and
FLUSH POND
Dear Mr. Madison:
A 1
Project No. 073-96258
As requested, Golder is providing this evaluation to summarize our current understanding
of the pond design, relevant field observations, engineering evaluations, an evaluation of
potential causes of the performance problems observed to date, and recommendations as
verbally requested by Progress Energy
Pond Design
Progress Energy recently completed construction of new wastewater settling and flush
ponds in conjunction with the start-up of a new flue -gas desulfurization (FGD) system at
their Roxboro Plant. The ponds were constructed on top of the existing ash pond by first
constructing a working pad of either bottom ash or blast/partially weathered rock. The
pond embankments were then constructed above the working pad using either fly ash or a
mixture of bottom ash and fly ash. Project specifications required the embankment fill to
be placed in maximum 12-inch loose lifts and compacted to a minimum of 95 percent of
the maximum dry density as determined by a standard Proctor. The moisture content at
the time of compaction was to be within plus or minus three percent of the optimum
moisture content.
The pond sidewalls have interior 3H:1 V slopes rising approximately 35 feet above the
surrounding grade. The interior of the pond is lined with a Bentomat CLDN geosynthetic
clay liner (GCL). The GCL on the embankment slopes and pond bottom is supported by
compacted fly ash. The GCL is overlain by two feet of fly ash, a Typar 3801g geotextile,
and then 18 inches of Class B riprap.
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Progress Energy 2 Roxboro FGD Wastewater Settling Pond
Attn: Mr. Charlie Madison May 12008
The exterior sideslopes are generally 3H:1 V except along the western sideslope, which is
approximately 2.75H:1 V. A vegetated, two foot thick layer of compacted soil covers the
fly ash embankment fill on the exterior sideslopes and a gravel road is atop the
embankment.
Project Documentation
The following documents prepared during design or construction of the Roxboro FGD
Wastewater and Flush Ponds were reviewed as part of this evaluation:
FGD Wastewater Treatment System Design Calculations, prepared by Parsons
E&S, last revised March 2006
Specification for Wastewater Settling Ponds (ROXO-O-SP-535001-RA), prepared
by Worley -Parsons, January 2006
Specification for Wastewater Settling Ponds (ROXO-O-TS-02750-RA), prepared by
Worley -Parsons, August 2005
Specification PGNC-0-TS-02200, Revision S, For Earthwork; prepared by
Worley -Parsons, September 2006
Technical Specification, for Geosynthetic Clay Liner (PGNC-0-TS-02210-R6),
prepared by Worley -Parsons, April 2006
Specification for Soil Testing and Inspection (PGNC-0-TS-02246-R3) prepared
by Worley -Parsons, August 2006.
Progress Energy Roxboro FGD Project Wastewater Settling and Flush Ponds
Logbook, prepared by Michael Fussell (Progress Energy)
Record of Daily Activities and Field Density Test Results, MACTEC Engineering
and Consulting, Inc., for the period June 6, 2006 — May 29, 2007
Project Chronology
Construction of the ponds was completed in May 2007. During a routine inspection by
Progress Energy personnel on October 25, 2007, several localized failures of the interior
sideslopes were noted. Inspections of the sideslopes indicate that in several areas the fly
ash between the GCL and riprap had been displaced and the overlying riprap was also
displaced. In many areas small tears in the Typar were observed and in several areas the
Typar had been ripped or torn. In addition, in one small area the membrane on one face
of the GCL was tom, but otherwise the GCL liner appeared to be intact in areas that
could be observed. In the area of tom GCL the liner was repaired by placing a new GCL
panel over the existing GCL, placing 2 ft of structural fill over the GCL, placing a 16-oz
geotextile over the soil cover, and placing 18 inches of riprap over the geotextile.
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Progress Energy 3 Roxboro FGD Wastewater Settling Pond
Attn: Mr. Charlie Madison May 1 2008
Later inspections have revealed many additional veneer failures. In December 2007,
Progress Energy released an RFP to
• Identify the root causes of the slope failure(s);
• Determine the impact of the slope failures on the GCL liner integrity;
• Review the original design for potential errors;
• Identify potential impacts of the failures to stability of the pond's fly ash embankments;
• Develop corrective action alternatives to address issues associated with the interior slope
failures;
• Develop cost estimates for each alternative to repair the slopes;
• Develop a list of risks (regulatory/performance/schedule) with each remedial alternative,
and;
• Prepare a formal report detailing the findings and evaluation of potential remedial
actions.
Progress Energy commissioned Golder to evaluate site conditions and prepare a report
addressing the internal slope failures identified in the RFP on January 27, 2008.
As requested by Progress Energy, Golder personnel visited the site on January 29, 2008,
to view a seep that developed along the northwestern perimeter berm of the FGD
Wastewater Pond. Results of chemical analytical testing of water collected fiom the seep
(completed by Progress) indicated that the water had an elevated chloride concentration
consistent with FGD wastewater. During our site visit, Golder walked the entire exterior
sideslopes of the pond and observed that the southwestem portion of the embankment
was soft and wet.
Again, at Progress Energy's request, Golder personnel returned to the site on February 7
to complete hand auger borings in the southwestern portion of the embankment and
further examined conditions in the southwestem and northwestern portions of the
embankment. Golder completed 8 hand auger borings and installed slotted 2" PVC pipe
in six of those borings to collect static water level data. Measured static water levels
ranged from 0.31 ft above ground surface, approximately one-third the way up the slope,
to 6.92 feet below the ground surface approximately midway up the slope.
During the week of February 18, Progress Energy personnel observed seeps developing
on the western sideslope and in the channel bordering the western portion of the pond.
At the request of Progress Energy, Golder personnel visited the site on February 22. Two
seeps were noted approximately one-third up the sideslope which were transporting fly
ash. In addition, fly ash was observed being discharged via seeps into the ditch along the
western perimeter at several locations. Seepage rates have not been measured, but were
observed to be greatest in the ditch surrounding the embankment on the west and
decreased as the seep locations rose up the sideslope; in all cases, seepage rates visually
appear to be less than one gallon per minute. In addition, a possible tension crack was
observed on the exteriar pond sideslope in the southwestern portion of the pond
embankment approximately one-third of the way up the slope.
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Progress Energy 4 Roxboro FGD Wastewater Settling Pond
Attn: Mr. Charlie Madison May 1 2008
Piping failure through the embankment of the flush pond occurred on February 26, 2008.
At the request of Progress Energy, Golder personnel visited the site on February 27. At
that time, water was discharged into the ash pond through the sideslope of the working
pad upon which the flush pond was constructed. Visual inspection of the failure indicates
that a preferential pathway for water transport developed immediately above the blast
rock used to construct portions of the working pad. Piping extended from the working
platform sideslope beneath the southwestem comer of the flush pond and resulted in
partial collapse of the toe of the embankment. A "sinkhole" located approximately in the
middle of the ulterior toe of the southern embankment appears to be the other end of the
piping failure.
Progress Energy began lowering the water level in the wastewater pond on or about
February 27. Water was pumped from the wastewater pond into the existing ash pond
using portable pumps. By March 24 water levels had been lowered to approximately
elevation 482 (12 ft of water), which is the approximate minimum required to operate the
biological wastewater treatment system and maintain plant operations.
At the request of Progress Energy, nine (9) additional hand auger borings were completed
around the perimeter of the waste water pond on March 12, 2008, and seven borings
were completed using a hollow stem auger (HSA) drill rig down the centerline of the
wastewater and flush ponds between April 7 and April 14, 2008. Slotted 2" PVC pipe
was installed in four of the hand auger borings and six of the HSA borings to collect
additional static water level data and better define the phreatic surfaces developing within
the pond sidewalls. Water levels measured in piezometers installed in the southwestern
portion of the wastewater pond had been observed to drop approximately one foot in
response to lowering the water levels in the pond between February 15 and March 17,
2008.
A large areal veneer failure occurred in the northwestem comer of the wastewater pond
on March 16, 2008, which partially exposed several GCL panels. Golder's visual
inspection of the GCL did not reveal any damage to the GCL nor did the GCL appear to
be in tension. However, when the lap joints were examined, the seams were not intact;
the bentonite powder (continuous bead) used in overlaps was not present in 5 of the 9
seams examined.
On April 7, Taylor and Murphy (General Contractor retained by Progress Energy to build
the ponds) removed cover materials from the GCL in the flush pond in the area of
"sinkhole" at the toe of the southern interior sidewall. Once the overlying fly ash was
removed, a gap between the GCL panels and a large void beneath the GCL was observed.
The void was at the edge of the underlying rock working pad, which was approximately 6
feet from the toe of the interior berm sidewall. Rock observed in the working pad was
coarse graded and ranged from boulder sized to approximate 3-inch cobbles.
Subsurface Investigations
Seventeen hand auger borings were completed by Golder personnel around the exterior
sideslope of the FGD Wastewater Settling pond on February 15 and March 12, 2008.
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Progress Energy 5 Roxboro FGD Wastewater Settling Pond
Attn: Mr. Charlie Madison May 1 2008
Approximate locations of the hand auger borings are shown on Drawing No. 1.
Piezometers were installed in twelve of those borings. The depths to which hand auger
borings were advanced, piezometer construction data (if applicable), and comments
regarding subsurface conditions encountered are summarized in Table 1. In general,
hand auger borings encountered between 2.5 and 3.0 ft of soil cover overlying flylbottom
ash used to construct the pond embankment.
Six piezometers were installed along the centerline of the wastewater settling pond berm
and one boring was completed along the centerline of the flush pond berm between April
7 and April 14, 2008. Geologic Exploration of Statesville, North Carolina, performed all
drilling and well installation activities. The drilling equipment consisted of a Diedrich
D-50 Turbo Track Mounted rig equipped with 4.25-inch inner diameter (ID) hollow -stem
augers. An experienced Golder geologist was present to observe the drilling and
supervise the piezometer construction. Split -spoon samples were logged by the geologist
for all of the boreholes. The boring logs and piezometer construction records are
included in Appendix 1. The piezometer/boring locations are provided on Drawing No.
1.
The six piezometers were installed with screened intervals targeting the base of the
wastewater pond (i.e., between 30 and 40 ft below existing ground surface). All
piezometers were constructed with a 10-ft screen interval surrounded by a sand filter,
were grouted to the surface, and received a flush mount surface completion.
The borings completed down the centerline of the pond embankments were advanced to a
maximum of 50 ft below the existing ground surface (BGS) or auger refusal.
Undisturbed soils/weathered bedrock were encountered in five (5) of the borings at depth
between 29.9 and 48.5 ft BGS. Generally, CCP materials were dry until the phreatic
surface within the embankment was encountered, but, in two locations (HA-10, B-4),
interbedded layers of wet and dry materials were encountered. Water was encountered at
depths of between 26.1 and 37 feet below ground surface in the borings drilled down the
centerline of the embankment. At the time of drilling, water levels were highest in the
borings completed in the western side of the wastewater pond embankment; however,
water levels encountered during HAS drilling are likely below those that existed before
the pond water level was lowered.
Stability Analyses
Stability analyses have been completed to evaluate the potential rotational failures of the
southwestem portion of the wastewater pond exterior sideslopes. This area was modeled
since it has the steepest exterior sideslope and represents conditions where the worst
seepage was observed. Results of these analyses are attached as Appendix 2.
Unless noted otherwise2site geometry, subsurface stratigraphy/nomenclature, and
material properties used in the stability analyses match those used during the design of
the waste water pond by Worley -Parsons. Six series of stability analyses were completed
as described below:
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Attn: Mr. Charlie Madison _ May 1 2008
GCL Breach Low Compacted Ash Density: This scenario assumes that the GCL
liner has breached, the pond has been filled to capacity with water, and a fully
developed theoretical phreatic surface is present within the embankment. This
analysis is consistent with that completed during the design of the pond, assumes
an in -place ash density of 90 pcf an internal material friction angle of 30 degrees,
and resulted in a factor of safety of 1.3 under static conditions. This analysis is
similar to the result of stability analyses completed by Parsons E&C (attached).
Subsurface stratigraphy, nomenclature and material properties used by Parsons
were, with the exception of phreatic surfaces and ash density/material strength for
embankment fill as noted, used in this analysis and the following analyses for ease
of comparison.
2. GCL Breach Observed Ash Densities: This scenario assumes that the GCL liner
has breached, the pond has been filled to capacity, and a fully developed
theoretical phreatic surface is present within the embankment. The in -place
density of fly ash was assumed to be 85 pcf (based on the results of field density
testing completed during construction of the embankment) and an internal
material friction angle of 27 degrees (based on testing completed on fly ash
samples collected at the Progress Energy Asheville Plant). The stability analyses
resulted in a factor of safety of 1.2 under static conditions.
GCL Breach Observed Phreatic Surface: This scenario assumes that the GCL
liner has breached, the pond has been filled to capacity, and a phreatic surface
consistent with field observations is present within the embankment. The in -place
density of fly ash was assumed to be 85 pcf, and an internal friction angle of 27
degrees was used in the stability analyses. The stability analyses resulted in a
factor of safety of 0.7 under static conditions. Since failure of the embankment
did not occur, the results may be indicative of the observed seeps being due to
perched water/preferential flow through the embankment or in place material
strength being greater than that used to model slope stability.
4. Twelve Foot Pond Level: This scenario assumes that the GCL liner has breached,
the pond has been filled to approximately 12 ft, and a phreatic surface develops to
the exterior toe of the embankment. The in -place density of fly ash was assumed
to be 85 pcf, and an internal friction angle of 27 degrees was used in the stability
analyses. The stability analyses resulted in a factor of safety of 1.5 under static
conditions.
Twelve Foot Pond Level, Total Liner Breach: This scenario assumes that the
GCL liner is totally ineffective, the pond has been filled to approximately 12 ft,
and a phreatic surface typical of a homogenous embankment develops (i.e., the
phreatic surface intersects the exterior sideslope at approximately 1/3 of the pond
height). The in- lace density of fly ash was assumed to be 85 pcf, and an internal
friction angle of 27 degrees was used in the stability analyses. The stability
analyses resulted in a factor of safety of 1.2 under static conditions.
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Progress Energy 7 Roxboro FGD Wastewater Settling Pond
Attn: Mr. Charlie Madison May 12008
6. Toe Drain: This scenario assumes that the GCL liner has breached, the pond has
been filled to capacity, and a phmatic surface c develops to the interior of a
hypothetical nine foot wide toe drain. The in -place density of fly ash was
assumed to be 85 pcf, and an internal friction angle of 27 degrees was used in the
stability analyses. The results of the stability analyses resulted in a factor of
safety of 1.6 under static conditions.
The slope stability analyses completed to date indicate that the embankment stability is
dependent upon material properties (i.e., the unit weight and friction angle of the fly ash)
and the phreatic surface. Review of CQA documentation collected during berm
construction indicates that there is significant material variation within the berms with the
berms being constructed primarily of fly ash, bottom ash, or a mixture of the two
materials.
Based on the material properties assumed above and the phreatic surfaces observed to
date, the existing embankment is expected to be stable under static conditions with twelve
feet of water stored within the wastewater pond. Currently, the GCL liner is assumed to
be ineffective and the embankment in its current condition is not expected to be stable
should the pond be filled to design height.
Should the FGD Wastewater pond be retained for long term use, it is assumed that the
pond will be relined with an FML liner. Golder anticipates that the pond will have a 30-
year design life. Even with an FML liner, rehabilitation of the pond should assume that
at some point the liner will be ineffective. The stability analyses completed to date
suggest that the stability of the embankment is highly sensitive to the phreatic surface
which develops within the embankment. Therefore, we recommend, should the pond be
rehabilitated, that the stability of the embankment be evaluated assuming an ineffective
liner and that a toe/blanket drain or alternate method of enhancing embankment stability
be designed and installed.
Although outside the scope of this study, Progress may wish to further evaluate the risk
associated with a seismic event (earthquake). The site is not located within a seismic
impact zone with the maximum horizontal acceleration in bedrock (90% probability of
not being exceeded in 250 years) estimated to be 0.08 g. However, the ash upon which
the embankments rest may liquefy during an earthquake, potentially resulting in large
scale settlement and potential catastrophic failure of the pond embankments.
Review of CQA Documentation
Review of CQA documentation included review of reports completed by MACTEC and
the project log book completed by Mike Fussell of Progress Energy.
Review of the soil density testing completed by MACTEC indicated that the materials
used to construct the embankment were placed in approximate 12-inch lifts and
compacted with a sheepsfoot roller. Water was sprayed on the materials as they were
being compacted to condition the materials and minimize dust. Soils density testing was
completed using either a nuclear density gage or a sand cone.
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Attn: Mr. Charlie Madison May 1 2008
Ten Proctors were completed during the project; maximum dry densities as determined
by a standard Proctor ranged from 60.5 pcf to 76.8 pcf and optimum moisture contents
ranged from 26.2% to 44.7%. This range in dry densities and optimum moisture contents
suggest significant material variability. Review of the log book indicates that materials
used to construct the pond embankments came from the on -site ash landfill, on -site silos,
and the existing ash pond. Review of the CQA documentation and the log book therefore
indicate that materials used to construct the pond embankments consist of fly ash, bottom
ash, and a mixture of the two materials.
Results of the soil testing generally indicated that the materials were compacted to a
minimum of 95% of the dry density as determined by a standard Proctor. Moisture
contents were generally within +/- 3% of optimum as required by project specifications,
although they were frequently placed dry of optimum, Upon occasion, materials were
also placed wet of optimum, The location of completed field density tests is problematic,
only a hand sketch of the approximate location of reference stakes is available. However,
review of the CQA data does not indicate any correlation between the materials placed
wet/dry of optimum and the observed seepages.
MACTEC representatives also observed placement of the GCL. Review of daily field
reports suggests that the bentonite bead was placed in the panel lap as required. No
significant difficulties associated with placement of GCL were noted in field reports.
Observations and Comments for FGD Wastewater Settling Pond
Several localized failures of the FGD wastewater pond's interior sideslopes have
occurred. Inspections of the sideslopes indicate that in several areas the fly ash between
the GCL and riprap had been displaced and the overlying riprap was also displaced. In
many areas small tears in the Typar were observed and, in some areas, the Typar had
been ripped or torn. In addition, in one small area the membrane on one face of the GCL
was torn, but otherwise the GCL liner appeared to be intact in areas that could be
observed. In the area of tom GCL, Progress repaired the liner by placing a new GCL
panel over the existing GCL, placing 2 ft of structural fill over the GCL, placing a 16-oz
geotextile over the soil cover, and placing 18 inches of riprap over the geotextile.
Veneer failures observed in the interior of the ponds are likely caused by material (fly
ash) failure and displacement. Compacting the fly ash as it was being placed on a 3H:1 V
sideslope would be difficult. In addition, there was little confinement of the material;
there was no toe berm to buttress the cover material and the Typar placed over the
material was punctured during placement of riprap. The ash will become unstable and
"flow" if it becomes saturated and is not confined. Since the fly ash was not effectively
confined where tears occurred in the Typar and at the toe of the slope, once the fly ash
became saturated, it failed locally and is considered to be the cause of the observed
interior veneer failures.
On the exterior, seeps transporting fly ash have been observed on the sideslope and along
the toe of the pond embankment in the southwestern and northern portions of the pond.
In addition, apparent tension cracks have been observed in the southwestern area of the
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Progress Energy 9 Roxboro FGD Wastewater Settling Pond
Attn:_ Mr. Charlie Madison Mav 1.2008
embankment. When these conditions were observed on February 22, 2008, Progress
initiated efforts to lower the water level in the pond and through March 12, it had been
lowered by approximately 10 feet.
Hand auger borings completed in the embankment typically found two feet of soil cover
overlying fly ash fill. In some areas, the fly ash was dry to depths of 5 feet or more
below the existing embankment surface. In other areas, predominantly in the
southwestern portion of the pond embankment, the fly ash was saturated immediately
below the soil cover. In one boring, interbedded layers of soft saturated fly ash and
competent dry fly ash were encountered. Piezometers installed on the sideslope indicate
that the phreatic surface is as high as ten feet in elevation above the toe of the slope.
Since the water level in the pond has been lowered over a two week period, water levels
in the piezometers have dropped slightly.
Bentonite, used in the GCL liner and its lap seams, is expected to be incompatible with
the wastewater. Chemical analytical testing of water samples collected from seeps by
Progress Energy indicate that the samples have a high chloride content, consistent with
FGD wastewater. The chemical composition of seep water and rapid development of an
elevated phreatic surface within the wastewater pond embankment indicate the liner has
been ineffective, at least in some locations. Since no displacement of the GCL was
observed in areas where the GCL was exposed due to failure of the overlying fly ash and
riprap, seepage through the liner is expected to be concentrated along the joints of the
GCL panels.
A large areal veneer failure in the (location) of the wastewater pond provide an
opportunity to further examine the condition of the GCL joints. The GCL appeared
intact; no punctures of the GCL were observed and there was no evidence that the GCL
was under tension or had been pulled during the failure. From the exterior, the joint
overlap appeared intact. However, when the seams were pulled apart, no evidence of
beaded bentonite which was to be placed in the joint lap was observed in 5 of 9 seams
examined. Review of CQA documentation suggests that the bentonite bead was placed
as required by the project specifications. However, there is no evidence of mechanical
intervention or water transport which could have removed the bentonite bead in some lap
joints but not in adjacent joints. Therefore, in spite of available CQA documentation, we
believe that the absence of a bentonite bead in some lap joints is due to a failure to place
bentonite during seaming.
Materials used to construct the embankment are not expected to have achieved design
density or strength in isolated areas. The strength of the fly ash is directly related to its
confining pressure, moisture content, and density. Based on preliminary review of
portions of the available CQA documentation, the embankment fill (fly ash) was placed
in 12 to 18 inch loose lifts and compacted using a sheepsfoot roller. Field density testing
was completed at time using the sand cone method, which only measures the in -place
density of the uppermost two to three inches of a compacted lift. In addition, material
was in some instances, placed significantly dry or wet of optimum. Construction
techniques, both in conformance and out of conformance with the project specifications,
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Attn: Mr. Charlie Madison May 1 2008
are expected to have resulted in preferential horizontal pathways for water migration and
contributed to the observed seeps.
The isolated areas where material used to construct the embankment did not achieve
design density or strength only contributed to the rapidity to which seeps developed on
the exterior sideslope of the FGD wastewater pond. The root cause of the failures
observed to date is considered to be the failure of the GCL panel seams. Whether or not
the bentonite bead had been properly placed on the GCL panel seam, bentonite
incompatibility with the FGD wastewater as discussed in the design report (FGD
Wastewater Treatment System Design Calculations, prepared by Parsons E&C dated
March 16, 2006) would have eventually resulted in failure of the seam and resultant
failure of the GCL liner to perform as designed.
Observations and Comments for Flush Pond
Similar to the FGD wastewater pond, several small veneer failures were observed in the
interior sideslope of the flush pond, none of which have been repaired as of this date.
Piping failure through the embankment of the flush pond occurred on February 27, 2008.
Water was discharged into the ash pond through the sideslope of the working pad upon
which the flush pond was constructed. Visual inspection of the failure indicates that a
pathway developed immediately above the blast rock used to construct portions of the
working pad. Piping extended from the working platform sideslope beneath the
southwestern corner of the flush pond and resulted in partial collapse of the toe of the
embankment. A "sinkhole" located approximately in the middle of the interior toe of the
southern embankment appears to be the other end of the piping failure. Before the
failure, there was approximately six to eight feet of water in the pond; the pond is
currently dry.
The "sinkhole" located at the interior toe of the pond sidewall began at the edge of the
rock working pad and extended several feet into the pond interior. It is likely that the
working pad acted as a drain for water dissipating from the subgrade as the pond
embankments were built and settled. Migration of fines likely began at this time and
continued following placement of GCL liner. As fines were transported and a void
developed beneath the GCL, the GCL panels pulled apart putting increased hydraulic
head on water flowing through the working pad. Ultimately a preferential pathway
developed along the surface of the working pad which began to undermine the exterior
sideslope of the flush pond. As water transport increased, so did the transport of fines
(e.g., base and embankment material). Once breakthrough occurred, the sideslope
became undermined at an increasingly rapid pace and the "sinkhole" at the base of the
interior sideslope enlarged until the pond emptied.
The root cause of the flush pond failure is considered to be the migration of ash into the
working pad. In the area of the failure, the blast rock used to construct the working pad
was coarse and open graded. Based on our visual inspection of the failure, fly ash placed
above the working pad appears to have migrated into the rock fill creating a preferential
pathway for water movement and undermining the GCL liner. The working pad should
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Progress
11 Roxboro FGD Wastewater Settling Pond
have been choked off with finer aggregates/sands or geotextile fabric to protect against
the migration of the overlying ash into the working pad.
Recommendations
At this time, if Progress Energy plans to continue to use the wastewater pond, Golder
recommends relining the wastewater and flush ponds with an HDPE flexible membrane
liner (FML). The existing seams of the GCL liner are assumed to have failed due to
either material incompatibility or improper seam construction. We also recommend,
should the pond be rehabilitated, that the stability of the embankment be evaluated
assuming an ineffective liner and that a toe/blanket drain or alternate method of
enhancing embankment stability be designed and installed
If the flush pond is to be reconstructed, Golder recommends that the fly ash placed
immediately above rock used to construct the working pad be removed and a layer of
sand or other material should be placed above the rock fill to choke it off and prevent
future migration of fly ash into the material. Field investigation or review of CQA/other
available information should be completed to determine the extent of rock fill.
Although outside the scope of this study, Progress may wish to further evaluate the risk
associated with a seismic event (earthquake). The site is not located within a seismic
impact zone with the maximum horizontal acceleration in bedrock (90% probability of
not being exceeded in 250 years) estimated to be 0.08 g. However, the ash upon which
the embankments rest may liquefy during an earthquake, potentially resulting in large
scale settlement and potential catastrophic failure of the pond embankments.
Closure
If you have any questions regarding this Preliminary Evaluation, or need any
clarification, please do not hesitate to contact me at 336,852,4903
Sincerely,
Golder Associate C C.
ck-
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Charles Hiner, P.E.
Senior Consultant
Attachments
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Biology Program
2009 QA Records Checklist
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Mar
Apr
Mav
June
July
Aug
Sept
Oct
Nov
Dec
Special Study
NR-000%
FV
Water Chemistry
Data
Nil-1111119-
FV
Wale[ Quality
Data
.....
...............
..
NR-00056
FV
Dissolved Oxygen Special Study
Data
_.._..... ...
__.... ....... ..._......
......______._
.....__...__.__
__._._...._......._._
........_..._.... __....
................. _._.
V1: unn
FV
Data
\ R-001111
l; %'
Data
20
R9Environmental ServiuslNamnl It s w eslBAU QA files\Checklist-QA 01es\2009 QA Checklist

Appendix 1: Boring Logs

RECORD OF BOREHOLE 1 SHEET of 1
PROJECT: Progress Energy- Roxboro DRILL RIG: Deiddch U720, Deiddch 0,50 not surveyed DEPTH W.L: 31.1 fi PROJECT NUMBER: 07396258.101
Tuft. Ddllech D25KW GS ELEVATION: ELEVATION W.L.:
DRILLED DEPTH: 50.0 If DATE STARTED: 417108 TOC ELEVATION:
DATE W.L: 4114/08
LOCATION: Roxboro, NC DATE COMPLETED: 4114/06 TIME W.L: 12:D0 am
SOIL PROFILE
SAMPLES
O
a E
¢ E
u
ELEV.
Of
MONITORING WELV
WELL
oy
��
DESCRIPTION
y
OWS
derr 6In
N
[Via
DIAGRAM andTNOTES ER
CONSTRUCTION
(d
DEPTH
(fl)
Z
140bM r
0
when amp
0.0.3 o
Dan gray (N4) to vary dark gray (Nat SILT,
WELLCASING
Mlle 1-) nne Sala: dry, no mars, no stelm,.
Interval: 030
(FLY ASH)
Malerlal: PVC
Diamere- T
Janl Type: Threaded
1
SPIT
8a8
14
5
WELL SCREEN
Interval: 3040
Melemll: PVC
Diameter. 2-
SlolSim: 0.010
End Cap: 40.0
10
FILTER PACK
Inlenmi: 26-50
2
Type: send pack
"6,-7-916
fit_
FILTER PACK SEAL
Interval: 23-26
Type: Rentonite
ANNULUS SEAL
Interval: 043
3
15
ML
Type: Gomd
WELLCOWLETION
Pad: Fluty nl
ProlecOve Casing: none
DRILLING METHODS
4
SPT
8810
19
1.5
20
Solt Drill: 4.254noh ID Hollow
Stem Auger
Rod[ pill: WA
25
Berdonite_
5
SPT
8813
19
aeal
8
SPf
8-3e
9
1..S5
_30
11.5
31.0 - 38.031.0
Dark gray (W) to very dad[ gray (N3) SILT.
little (q fine Sand; wel, no odors, no
ateining.(FLY ASH)
Sam Pack —
7
SPT
WOR44
8
-
ML
i
Screen—
.'•
T
38.0 - wo
38.0
8
SPf
tfi-$W6'
S0r6
�-
1S
•
Light Wve gmy(10YR 7M) to greemeh gray
(N11) weathered oeNock(mlraraaus sNel)
40
I
I
I
9
SPT
2&W4'
50/4-
- -
45
1.5
Sand Pack —
1D
SPT
29-504'
50/4-
�'S-
am" mmplwed al 550 0.0 fl
55
LOG SCALE: 1 In = 7!t GA INSPECTOR: Richard P. Lovett, P.G.
DRILLING COMPANY: GEOlogic Exploration CHECKED BY: CDH Golder
DRILLER: Mike MCCOnnahey DATE: 4118108 deg

RECORD OF BOREHOLE 2 SHEET 1 of 1
PROJECT: Progress Energy - Roxboro DRILL RIG: Deidrich D-120, Deidrich 650 not surveyed DEPTH W.L: 26.2 B
PROJECT NUMBER 07396258.101 Turbo, Driltech D25KW GS ELEVATION: ELEVATION W.L:
DRILLED DEPTH: 50.0It DATE STARTED: 417108 TOC ELEVATION: DATE W.L: 4114108
LOCATION: Roxboro. NC DATE COMPLETED: 4114108 TIME W.L: 12:00 am
0
2
SOIL PROFILE
SAMPLES
MONITORING WELU
DIAGRAM and NOTES
WELL
CONSTRUCTION
DETAILS
DESCRIPTION
m
i
BLOWS
per 61n
wlu'k tlmp
N
0PIEZOMETER
ua
H
0.0-23.5
Grey (NS) la very diri,mom, gray staff SILT, gale
fine SeM; tlry, no adore, no staining. (FLY
ASH)
InW�e CASING
MateDuvet : PVC
Diameter 2-
JOIN Typa: Threaded
Typ
1
SpT
5$13
21
51.5
WELL SCREEN
Interval: 30-40
Material: PVC
Size: 0Af0
End
End DOP: 40.0
10
FILTER PACK
tnimai: 2B.50
Type: sand pack
2
SPT
4-0.16
25
-11'�S-
MIL
uI_
FILTER PACK SEAL
Interval: 23-4
Type: Bentonite
13
ANNULUS SEAL
Intervtl: 0-23
Type: Giwl
3
SPT
511-12
23
_11.,5i
WELL COMPLETION
Pad: FIeshmwnt
Protective Casing: none
20
DRILLING METHODS
Sd1 pill: 4.25tinch 10 Holm
Slam Augers
4
SPT
7-7-10
17
"5
1.5
Rack Dell: WA
25
Very dark gray(N3) SILT, little fine Sand;
vrel, Its odors, no staining. (FLY ASH)
Bentodle_
seal
23.5
5
SPT
4.34
7
-
1.5
6
SPT
3.2.2
4
W.
SendPack-
7
SPT
4.3-2
5
33
Screen_
2.
38.5-48.5
Very dslk gray (N3) fine to medium SAND,
Iilde
ASH) Sill; vrel, no odors, no staining. (FLY
38.5
8
SPT
WOR-4.5
9
SP.SIVI
8
SPT
5-1.1
2-
Sand Peck—
48.5-50.0
Light diva gmy (10YR 711)10 greenle}i 9raY
HUI) vreelhenal bedrock (mioacsws
Mist);
48.5
10
SPT
88-14
ZO
1e.a
1.5
Baring complaned at 50.0 ft
55
LOG SCALE: 1 in = 7 ft GA INSPECTOR: Richard P. Lovett, P.G.
DRILLING COMPANY: GEOlogic Exploration CHECKED BY: CDH GO1deP
DRILLER: David Lonorgia DATE: 4/18/08 A.9SOCt2iC'3

RECORD OF BOREHOLE 3 SHEET of 1
PROJECT: Progress Energy - Roxboro DRILL RIG: Deldrich D-120, Deidrich 0.50 not surveyed DEPTH W.L: 27.4 ft
PROJECT NUMBER: 07396258A01 Turbo, Driltech D25KVV GS ELEVATION: ELEVATION W.L:
DRILLED DEPTH: 40.0 it DATE STARTED: 4/9/08 TOC ELEVATION: DATE W.L.: 4114/08
LOCATION: Roxboro, NC DATE COMPLETED: 4114/08 TIME W.L: 12:00 am
SOIL PROFILE
SAMPLES
U
ELEV.
do
E2
<a
MONITORING WELL?
WELL
DESCRIPTION
8�d
O
e�
w
w
BLOWS
per 61n
0
N
O
w
PIEZOMETER
DIAGRAM and NOTES
CONSTRUCTION
DETAILS
w
DEPTH
i
e)
1401E n.mmer
°
circ cop
gas
Verydart; gmy IN
I(FLY
dry, odono sl)alning.. ASH)
al: D.3DG
Maternal: PVC
Diameter:7
Joint TYPO: TMaeded
1
SPr
6-10.12
22
5
WELLSCREEN
Interval: 3040
Metedal: PVC
Demeter: 2-
�' '
Slot Sure: 0.010
End Cap: 10.0
FILTER PACK
Interval: 2740
2
SPT
54411
19
-
10
Type: send pack
ML
Grout-
FILTER PACK SEAL
Interval: 23.27
Type: Benlonile
ANNULUSSEAL
Interval: 0-23
3
SPT
C74
13
- -
15
Type: Grace
WELL COMPLETION
Pad: Rushmounl
ProleotNO Casing: none
DRILLING METHODS
4
SPr
S-I(M0
20
- -
Solt Nil: 4254nch )0 Hallow
20
Stan Augers
Rock Drill: WA
23.6
25
Very derkgmy(N3) SILT. little MO Sand;
5
SPT
54-3
7
1.5
wet. no odors, no stelning.(FLY ASH) -wet
Benlonile_
st 23.5 feel bg5
seal
ML
6
SPT
4-2-2
4-
is
Sand ParA— :
7
SPT
6"/1'
Sal
34.5-40.0
34.6
35
5
9laY
weamherreo
Steen
I
(li) bedrock)(mto ioaceouus
shist); dry
i
S
SPT
12-10.13
23
-1.5-
40
aping completed al 40.0 0
i
I
45
S0
r
55
LOG SCALE: 1 in = 7 R GA INSPECTOR: Richard P. Lovett, P.G.
DRILLING COMPANY: GEOlogic Explom8on CHECKED BY: CDH Golder
DRILLER: David Lonorgia DATE: 4/1&08 A.SSOCJ2tes

RECORD OF BOREHOLE 4 SHEET of 1
PROJECT: P, Energy - Roxboro DRILL RIG: Deldrich D-120, Deidrich D-50 not wrveyetl DEPTH W.L: 27.8 ft
PROJECT
NUM R' 07396258.101 Turbo, Driltech D25KW GS ELEVATION: ELEVATION W.L:
DRILLED DEPTH: 40.0 It DATE STARTED: 4/10108
TOC ELEVATION: DATE W.L: 4/14/08
LOCATION: Roxboro, NC DATE COMPLETED: 4/14108
TIME W.L: 12:00 am
SOIL PROFILE
SAMPLES
x
4
as
¢c
9
ELEV,
¢
MONITORING WEW
WELL
o
DESCRIPTIO N
Stp
u
w
m
w
a
BLOWS
u
PIEZOMETER
CONSTRUCTION
w
�O
2
per an
N
DIAGRAM and NOTES
DETAILS
w
DEPTH
z
Z
0
lfl)
tM le nemmer
solrchdmp
O
Veeryq dark
k
(st m medium
WELL CASING
.gmy no door , n
SAND: dry. no pone, no staining. (FLY
Interval: 0-20
ASH)
Maledal: PVC
OtT 2
SM
Joint Ty}1e: Threaded
1
an
6.9-14
23
1.6
5
WELL SCREEN
Inlevel: 20J0
Malenal: PVC
-----------
69y
—
Diamelen 2'
Sot Sae: 0.010
6.5
dank
VerydankOd Orgyos SILT, Iltde
Grout_
End Cap: 30.0
dry, rw adM, no staining. (PLY ASH)
ASH)
FILTER PACK
Internet:
2
SPT
7-10-11
21
15
10
s nd pa
Typo: sand peck
FILTER PACK SEAL
Interval: 1518
Type: aienonite
ANNULUS SEAL
Interval: D-15
3
SPT
7.7-9
16
t6
ML
1.5
Tips: Growl
BanlcNte
WELL COMPLETION
�—
Pod: Flaslnnunt
Praecdee Casing: lane
DRIWNG METHODS
4
SPT
6510
18
15
SellONI: 4254noh 10 Hallow
Stan A,.
Rock OdIl: WA
,
24.0-29.9
24.0
5
SPT
5-6.7
13
JA
25
Very deck gray IN3) Silt, Iltlle fine Send;we,
1.5
no owns. ro staining. (FLY ASH) -One inch
Screen—
wens of wmle from 24.0 to 25.01ee1 bps.
ML
Sand PaCk— •.,'
6
SPT
6-0-7
13
-U
2g9-40.029.9
U9h1 olive grey (lOYR 7/1) to greenish gray
(1,1311) wealMew bewtock (micaceous
snisl); Dry
7
SPT
14-13-14
27
35
i
15
Sara Pack—
i
8
GPT
&13d1
24
la
5
40
i
Boll g cenpleted a 40.0 R
45
50
55
1 in = 7 fl GA INSPECTOR: Richard P. Lovett, P,G.
DSCALE:
LING COMPANY: GEOlogic Exploration CHECKED BY: CDH
LER: David Lonorgia DATE: 4/18/08 eS

RECORD OF BOREHOLE 5 SHEET 1 or 1
w
w
PROJECT: Progress Energy - Roxboro DRILL RIG: Deiddch D-120, Deidrich D-50 not surveyed DEPTH W.L: 31.1 ft
PROJECT NUMBER: 07396258.101
Turbo, Ddltech D25KW GS ELEVATION: ELEVATION W.L.:
DRILLED DEPTH: 40.0 ft DATE STARTED: 4/10108
TOC ELEVATION: DATE W.L.: 4/14/08
LOCATION: Roxboro, NC DATE COMPLETED: 4114108
TIME W.L: 12:00 am
SOILPRORI-E
SAMPLES
z
as'
V
<z
O
ELEV.
u�
MONITORING WELU
WELL
o
DESCRIPTION
u¢ 00
m
>>w
per sin
w
a d NOTES
CONSTRUCTION
in
O
J
N
DIAGRAM
¢
DEPTH
O
2
F
w
°
(8)
1a016 kamnw�
wlnm 4mn
60-27.0
Very dad gray IN3) SILT, little fine Sand;
WELL CASING
wet, no odors, no staining. (FLY ASH)
Interval: 0-25
Material: PVC
Diameter. T
Joint Type: Threatlatl
1
SPT
5-10-13
73
-75
5
WELLSCREEN
Interval: 2535
Materiel: PVC
Dweller: 7
Slot Size: a.o10
End Cap: W
Grout-
FILTER PACK
Interval: 22-0o
2
SPT
13&12
20
_U
10
Type: send Deck
FILTER PACK SEAL
Interval: 18-22
Type: aentonite
ML
3
SP7
8-9-12
21
Jt.`sV.
ANNULUS SEAL
Interval: 0.'IB
15
Type : crest
WELLCOMPLETON
Pad: Flushmaunt
Pmleodw± Casing: none
DRIWNG METHODS
4
SPT
5.7-10
17
-1 5
Sol pill: 4.2SInch 10 Hollow
20
Berl
Stern Augers
seal
Rock Ddll: WA
5
SPT
6b9
14
-�
25
2].0-31.0
27.0
very dad grey (N3) SILT, Inge line Sand;
wet, no More, no staining. (FLY ASH)
"
8
55S
10
--
SPSM:..;
30
1.5
Sceen-
Sertl Pads- .:
3L0-40.0
31.0
Light dive gray (10YR 7/1) to greenish gray
(N3r1) wealhared bedrock (micaceous ended)
Ism
]
WOR-WOR-5
0
Sand Pack-
8
SPT
10A3-20
33
-LS-
-
40
?
i
I
Boring completed at 40.0 it
i
i
i 45
�
I
55
LOG SCALE: 1 in = 7 ft GA INSPECTOR: Richard P. Lovett, P.G.
DRILLING COMPANY: GEOlogic Exploration CHECKED BY: CDH�
*A
Goldff
DRILLER: David Lonorgia DATE: 4118/08

RECORD OF BOREHOLE 6 SHEET 1 of 1
PROJECT: Progress Energy - Roxboro DRILL RIG: Deldrich D-120, Deldrich D-50 not surveyed DEPTH W.L: 37.1 ft
PROJECT NUMBER: 07396258.101 Turbo, Drlltech D25KW GS ELEVATION: ELEVATION W.L:
DRILLED DEPTH: 45.0 it DATE STARTED: 4/10108 TOO ELEVATION: DATE W.L: 4114/08
LOCATION: Roxboro, NC DATE COMPLETED: 4114I08 TIME W.L: 12:00 am
� �
lam
[1�
D
¢2
SOIL PROFILE
SAMPLES
MONITORING WEW
PIEZOMETER
DIAGRAM and NOTES
WELL
CONSTRUCTION
DETAILS
DESCRIPTION
e�
U
a13
�O
D,
ELEy,
m
j
Z
aW.
SLOWS
par 6ln
140lb bummer
d0 NU Omp
N
O
uaJ
D
((ft)
0.0-3e.5
Grey INS) m very dark gray (N3) SILT, ISSe
fine Sang dry, no odors, no staining. (FLY
ASH)
i
WELL CASING
Interval0-31.5
Matenal PVC
Diameter:?
Jent Type: Threaded
1
SPr
7-8-11
19
�
5
WELL SCREEN
Interval: 31.541.5
Material: PVC
Diameter: 7
Slot an: 0.010
EN Cap: 41.5
10
FILTER PACK
Interval: 2743.5
Type: sMd pack
2
SPT
7-9A
IS
�1.+Si
FILTER PACK SFAL
Grout-
Interval: 24-27
Type: Sentoute
15
ANNULUS SEAL
Interval: D-24
Typo: Grout
3
SIFT
4b9
14
-
1.5
-
WELL COMPLETION
Pad: Flushmount
Pmladive Casing: none
20
ML
1
DRILLING METHODS
Sol Dnll: 4.25-inch 10 Hollow
Stem Augers
4
SPT
a-11-11
22
1.5
Rock Drill: WA
25
Bento
5
SPT
8-8-12
20
-
6edl eel
5
SPT
445.5
10
351.5
Sand Pack-
Screen- `+
7
SPT
4.7-10
17
-
40
38.5-0.5.0------_---
Gray INS) to very dark grey (1,13) SILT, SWe
Me Sand; wet, no coots, no staining. (FLY
ASH)
—
38.5
S
SPT
Sib
i5
js-
ML
Send Pack-
45
9
SPT
2-2-3
5-
1.5
Boring compleled at 45.0 8
SD
55
LOG SCALE: 1 in = 7 ft GA INSPECTOR: Richard P. Lovett, P.G.
DRILLING COMPANY: GEOlogic Exploration CHECKED BY: CDH
DRILLER: David Lonorgia DATE: 4M8108 AS OC T(CS

RECORD OF BOREHOLE 7 SHEET 1 or 1
PROJECT: Progress Energy- Roxboro DRILL RIG: Deldrich D-120, Deldrich D-50 not surveyed DEPTH W.L: 37.0 tt
PROJECT NUMBER: 07396258,101
Turbo, Driltech D25KW GS ELEVATION: ELEVATION W.L.:
DRILLED DEPTH: 39.2 ft DATE STARTED: 4/14/OB
TOC ELEVATION: DATE W L: 4114/08
LOCATION: Roxboro, NC DATE COMPLETED: 4/14/08
TIME W.L: 12:00 am
a
SOIL PROFILE
SAMPLES
O
s
63?
ELEV.
K
BLOWS
MONITORING VVEW
PIEZOMETER
WELL
ov
�V
w
DESCRIPTION
c�
j
am
�O
M
per 6ln
N
O
ow
OIAGMEMand NOTES
CONSTRUCTION
DETAILS
0
O
DEPTH
h)
2
t4dione-nax
ap inW dmp
0.0-37.0
Very dark grey (W) SILT, little line Sand.
WELL CASING
dry, no odors, no staining. (FLY ASH)
Initiml:
MatedaC
Olametec
Joint Type:
1
SIFT
5-ID-14
24
15
5
WELLSCREEN
Interval:
Materiel:
Demelec
Slol Size:
End Cep:
in
FILTER PACK
Interval:
2
SPT
10-11.13
24
1-5
Type:
FILTER PACK SEAL
Interval:
Type:
15
ANNULUS SEAL
Interval:
3
SPT
10.11.13
24
Type:
WELL COMPLETION
Fed:
Protective Casing:
ML
DRILLING METHODS
4
SPT
7-9-16
25
1.5
20
Sal Ong.
Rock Drill:
25
5
SPT
g-14-te
30
15
30
6
SPT
7-7.9
16
15
35
7
SPT
7-B-13
21
15
37.0
i
Very cork gray (1,13) SILT, Illlle fine Sand:
ML
t
wet, no odors, no stainln . FLV ASH
38.5-3%2
38.5
a
SPT
50/S
5N5-
9
SPT
37-SO12"
50/Y
40
U9hl olive gmy(10YR 7/1) togreenish gray
0.7
1.5
(N3I1) weaihered bedrock (a
shisll: dd
Boring completed at 39.2It
45
so
55
LOG SCALE: 1 in = 7 ft GA INSPECTOR: Richard P. Lovett, P.G.
DRILLING COMPANY: GEOlogic Exploration CHECKED BY: CDH
DRILLER: David Lonorgia DATE: 4/18108 G ldlex

Appendix 2: Stability Analyses

0
0
N
E
reachompacted Ash Density
ro Plant FGD W W Settling Pond
\ 300.00 IM/ft2
o , \ Top Soil 1
d ComBA+FA GypPond
StiffAsh COM BA
� ExstDam
� ExstLAsh
0 50 100 150 200 250 300 350 400 450 500 550 600

Slide Analysis Information
Document Name
File Name: Roxboro 1.sli
Project Settinas
Project Title: SLIDE - An Interactive Slope Stability Program
Failure Direction: Right to Left
Units of Measurement: Imperial Units
Pore Fluid Unit Weight: 62.4 Ib/ft3
Groundwater Method: Water Surfaces
Data Output: Standard
Calculate Excess Pore Pressure: Off
Allow Ru with Water Surfaces or Grids: Off
Random Numbers: Pseudo -random Seed
Random Number Seed: 10116
Random Number Generation Method: Park and Miller v.3
Analysis Methods
Analysis Methods used:
Bishop simplified
Janbu simplified
Number of slices: 30
Tolerance: 0.005
Maximum number of iterations: 10
Surface Options
Surface Type: Circular
Search Method: Auto Refine Search
Divisions along slope: 10
Circles per division: 10
Number of iterations: 10
Divisions to use in next iteration: 50%
Composite Surfaces: Disabled
Minimum Elevation: Not Defined
Minimum Depth: Not Defined
Loading
1 Distributed Load present:
Distributed Load Constant Distribution, Orientation: Normal to boundary, Magnitude: 300 Ib/ft2
Material Properties

Material: Too Soil
Strength Type: Mohr -Coulomb
Unit Weight: 110lb/ft3
Cohesion: 0 psf
Friction Angle: 30 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: ComBA+FA
Strength Type: Mohr -Coulomb
Unit Weight: 90lb/ft3
Cohesion: 0 psf
Friction Angle: 30 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: COM BA
Strength Type: Mohr -Coulomb
Unit Weight: 95lb/ft3
Cohesion: 0 psf
Friction Angle: 34 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: ExstLAsh
Strength Type: Mohr -Coulomb
Unit Weight: 92.4lb/ft3
Cohesion: 0 psf
Friction Angle: 30 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: PWR
Strength Type: Mohr -Coulomb
Unit Weight: 130.4lb/ft3
Cohesion: 18000 psf
Friction Angle: 0 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: GvoPond
Strength Type: Mohr -Coulomb
Unit Weight: 65 Ib/ft3
Cohesion: 0 psf
Friction Angle: 0 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: ExstDam
Strength Type: Mohr -Coulomb
Unit Weight: 120 Ib/ft3
Cohesion: 250 psf

Friction Angle: 30 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: StiffAsh
Strength Type: Mohr -Coulomb
Unit Weight: 116.4 Ib/ft3
Cohesion: 0 psf
Friction Angle: 33 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
List of All Coordinates
Material Boundary
346.350 67.000
445.000 102.900
471.000 103.000
Material Boundary
483.000 99.000
579.000 67.000
Material Boundary
340.500 67.000
346.350 67.000
579.000 67.000
600.000 67.000
Material Boundary
329.000 65.000
600.000 65.000
Material Boundary
325.000 67.000
329.000 65.000
353.000 53.000
600.000 53.000
Material Boundary
353.000 53.000
439.000 10.000
Material Boundary
100.000 10.000
439.000 10.000
600.000 10.000
External Boundary
600.000 10.000
600.000 53.000

600.000
65.000
600.000
67.000
600.000
99.000
483.000
99.000
471.000
103.000
465.000
105.000
445.000
105.000
340,500
67.000
325.000
67.000
315.000
70.300
295.000
70.300
182.000
20.000
100.000
10.000
100.000
0.000
600.000
0.000
Piezo Line
0.000
10.000
100.000
10.000
182.000
20.000
340.500
67.000
346.350
67.000
483.000
99.000
600.000
99.000
Distributed Load
465.000 105.000
445.000 105.000

RoxoWWSettlingPond - Run 1 - GCL Breach Low Compacted Ash Density
S:\DOCICIVILIGYPSUM-21STABIL-11STABIL-MUN1A.PL2 Real By: Dipti Sheth 5130/2006 11:08AM
800
# FS
Soil Soil Total Saturated Cohesion Friction Piez. Load Vaiue
a 1.32
Desc. Type Unit WL Unit Wt. Intercept Anple Surface LI 700 twrgfl
b 1.33
No. (pcf) (Pcf) (PSO (deg) No.
c 1.33
Top Soil 1 110.0 110.0 0.0 30.0 Wt
d 1.33
ComBA+FA ;2 90.0 90.0 "0.0 30.0 W1
e 1.37
COM BA -3 95.0 95.0 0.0 34.0 W1
f 1.37
ExstLAsh ;4 92.4 92.4 10.0 30.0 W1
g 1.38
PWR 5 130.4 130.4 18000.0 0.0 Wt
h 1.38
GyPPond ;6 65.0 65.0 p.0 0.0 W1
i 1.39
ExstDam 7 120.0 120.0 250.0 30.0 0
700
f-1.40
'-StlflAsh--,8,--116.4`--116.4__.)0.O.___ 33.0 --- fl--------------------- --------- .______ -_._.._-..______..__
1
�
i
i
a
fg
Le
600
---------------
c
L----------------a----------------a---------------------
2 2`�.
2
4
'7-i'"
7
__-_______-
9
400 v1
al 5
0
100 200 300 400 500 600
STABI-61-1 FSmin=1.32
STED
Safety Factors Are Calculated By The Modified Bishop Method

5:\doc\civil\gypsum-2\stabil-1\stabil-l\runla.OUT Page 1
•�' STABL6H *•
by
Purdue University
--Slope Stability Analysis --
Simplified Janbu, Simplified Bishop
or Spencer's Method of Slices
Run Date: 5/30/2006
Time of Run: 11:08AM
Run By: Dipti Sheth
Input Data Filename: X:RUNIA.
Output Filename: X:RUNIA.OUT
Plotted Output Filename: X:RUNIA.PLT
PROBLEM DESCRIPTION RoxoWWSettlingPond - Run 1 - GCL Breach
BOUNDARY COORDINATES Lou Compacted Ash Density
Note: User origin value specified.
Add 0.00 to X-values and 400.00 to Y-values listed.
10 Top Boundaries
19 Total Boundaries
Boundary X-Left
No. (ft)
1 100.00
2 182.00
3 295.00
4 315.00
5 325.00
6 340.50
7 445.00
8 465.00
9 471.00
10 483.00
11 342.50
12 441.50
13 483.00
14 340.50
15 329.00
16 325.00
17 353.00
18 353.00
19 100.00
ISOTROPIC SOIL PARAMETERS
8 Type(s) of Soil
Soil Total Saturated
Type Unit Wt. Unit Wt. I
No. (pcf) (pcf)
1 110.0 110.0
2 90.0 90.0
3 95.0 95.0
4 92.4 92.4
5 130.4 130.4 1
6 65.0 65.0
7 120.0 120.0
8 116.4 116.4
1 PIE2oMETRIC SURFACE(S)
Unit Weight of Water
Piazometric Surface No.
Point X-water
No. (ft)
1 .00
2 100.00
3 182.Oe
4 340.50
5 342.50
6 483.00
7 600.00
BOUNDARY LOAD(S)
Y-Left
X-Right
Y-Right
Boil Type
(ft)
(ft)
(ft)
Below Bnd
10.00
182.00
20.00
7
20.00
295.00
70.30
7
70.30
315.00
70.30
7
70.30
325.00
67.00
7
67.00
340.50
67.00
3
67.00
445.00
105.00
1
105.00
465.00
105.00
1
105.00
471.00
103.00
1
103.00
483.00
99.00
2
99.00
600.00
99.00
6
67.00
441.50
103.00
2
103.00
471.00
103.00
2
99.00
579.00
67.00
2
67.00
600.00
67.00
3
65.00
600.00
65.00
8
67.00
353.00
53.00
7
53.00
600.00
53.00
4
53.00
439.00
10.00
7
10.00
600.00
10.00
5
Cohesion Friction Pore Pressure Piez.
ntercept Angle Pressure Constant Surface
(psf)
(deg) Param.
(psf)
No.
.0
30.0 .00
.0
1
.0
30.0 .00
.0
1
.0
34.0 .00
.0
1
.0
30.0 .00
.0
1
8000.0
.0 .00
.0
1
.0
.0 .00
.0
1
250.0
30.0 .00
.0
0
.0
33.0 .00
.0
0
HAVE BEEN
SPECIFIED
62.40
1 Specified
Y-Water
(ft)
10.00
10.00
20.00
67.00
67.00
99.00
99.00
by 7 Coordinate Points

s:\doc\civil\gypsum-2\stabil-1\stabil-1\runla.OUT Page 2
1 Load(s) Specified
Load X-Left X-Right Intensity Deflection
No. (ft) (ft) (lb/sgft) (deg)
1 445.00 465.00 300.0 .0
NOTE - Intensity Is Specified As A Uniformly Distributed
Force Acting On A Horizontally Projected Surface.
A Critical Failure Surface Searching Method, Using A Random
Technique For Generating Circular Surfaces, Has Been Specified.
300 Trial Surfaces Have Been Generated.
10 Surfaces Initiate From Each Of 30 Points Equally Spaced
Along The Ground Surface Between X - 310.00 ft.
and X - 380.00 ft.
Each Surface Terminates Between X - 430.00 ft.
and X - 470.00 ft.
Unless Further Limitations Were Imposed, The Minimum Elevation
At Which A Surface Extends Is Y - .00 ft.
10.00 ft. Line Segments Define Each Trial Failure Surface.
Following Are Displayed The Ten Most Critical Of The Trial
Failure Surfaces Examined. They Are Ordered - Most Critical
First.
* * Safety Factors Are Calculated By The Modified Bishop Method
Failure Surface Specified By 12 Coordinate Points
Point X-Surf Y-Surf
No. (ft) (ft)
1 348.62 69.95
2 358.47 68.25
3 368.45 67.5E
4 378.45 67.95
5 388.35 69.35
6 398.05 71.78
7 407.44 75.21
8 416.43 79.59
9 424.91 84.89
10 432.80 91.04
11 440.00 97.98
12 445.92 105.00
Circle Center At X - 369.9 ; Y - 163.6 and Radius, 96.0
*** 1.319 ***
Failure Surface Specified By 14 Coordinate Points
Point X-Surf Y-Surf
No. (ft) (ft)
1 326.90 67.00
2 336.84 65.93
3 346.83 65.56
4 356.83 65.91
5 366.77 66.97
6 376.61 68.73
7 3H6.31. 72.19
8 395.80 74.33
9 405.05 78.14
10 414.00 82.60
11 422.61 87.68
12 430.84 93.36
13 438.64 99.62
14 444.10 104.67
Circle Center At X = 346.9 ; Y = 206.0 and Radius, 140.5
"** 1.326 ***
Failure Surface Specified By 11 Coordinate Points
Point X-Surf Y-Surf
No. (ft) (ft)
1 346.21 69.08
2 � 356.12 67.75
3 366.12 67.54
4 376.08 68.44
5 385.87 70.44
6 395.39 73.52
7 404.51 77.63

s:\doc\civil\gypsum-2\stabil-1\stabil-1\runla.OUT Page 3
8
413.11
82.73
9
121.09
88.75
10
428.35
95.63
11
432.40
100.42
Circle
Center At X -
363.0 ; Y
***
1..330
***
Failure
Surface Specified By 12
Point
X-Surf
Y-Surf
No.
(ft)
(ft)
1
351.03
70.83
2
360.87
69.02
3
370.84
68.24
4
380.84
68.51
5
390.75
69.81
6
400.47
72.15
7
409.90
75.48
8
418.93
79.79
9
427.46
85.01
10
435.40
91.09
11
442.66
97.96
12
448.68
105.00
Circle Center At X -
373.3 • Y
Failu
Poi
No
1
2
3
4
5
6
7
8
9
10
11
12
13
Circl
Failur
Poi
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
Circle
e
Failur
Poi
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
Circle
+++ 1.334 •**
re Surface Specified By 13
nt X-Surf Y-Surf
(ft) (ft)
353.45 71.71
363.31 70.04
373.28 69.26
303.28 69.38
393.23 70.40
403.04 72.30
412.65 75.07
42.1.97 78.70
430.93 83.14
439.45 80.37
447.47 94.34
4.54.93 101.01
458.66 105.00
Center At X - 376.9 ; Y =
*** 1.372 ***
157.4 and Radius,
Coordinate Points
163.9 and Radius,
Coordinate Points
89.9
01-Mi
180.7 and Radius, 111.5
e Surface Specified By 14 Coordinate Points
nt X-Surf Y-Surf
(ft) (ft)
346.21 69.08
356.17 60.22
366.17 68.00
376.16 68.42
386.10 69.47
395.96 71.16
405.69 73.47
415.25 76.40
424.61 79.93
433.72 84.04
442.55 88.73
451.07 93.98
459.23 99.75
465.51 104.83
Center At X - 364.6 ; Y -
*** 1.374 ***
224.9 and Radius, 156.9
Failure Surface Specified By 15 Coordinate Points
Point _X-Surf Y-Surf
No. (ft) (ft)
1 341.38 67.32
2 351.31 66.11
3 361.29 65.52
4 371.29 65.54
157.4 and Radius,
Coordinate Points
163.9 and Radius,
Coordinate Points
89.9
01-Mi
180.7 and Radius, 111.5
e Surface Specified By 14 Coordinate Points
nt X-Surf Y-Surf
(ft) (ft)
346.21 69.08
356.17 60.22
366.17 68.00
376.16 68.42
386.10 69.47
395.96 71.16
405.69 73.47
415.25 76.40
424.61 79.93
433.72 84.04
442.55 88.73
451.07 93.98
459.23 99.75
465.51 104.83
Center At X - 364.6 ; Y -
*** 1.374 ***
224.9 and Radius, 156.9
Failure Surface Specified By 15 Coordinate Points
Point _X-Surf Y-Surf
No. (ft) (ft)
1 341.38 67.32
2 351.31 66.11
3 361.29 65.52
4 371.29 65.54
224.9 and Radius, 156.9
Failure Surface Specified By 15 Coordinate Points
Point _X-Surf Y-Surf
No. (ft) (ft)
1 341.38 67.32
2 351.31 66.11
3 361.29 65.52
4 371.29 65.54

s:\doc\civil\gypsum-2\stabil-1\stabil-1\run18.OUT Page 4
5 381.27 66.18
6 391.19 67.44
7 401.01 69.31
8 410.70 71.77
9 420.22 74.84
10 429.54 78.48
11 438.61 82.69
12 447.40 87.46
13 455.88 92.75
14 464.02 98.56
15 469.92 103.36
Circle Center At X 365.9 ; Y - 227.4 and Radius, 161.9
*** 1.375 ***
Failure Surface Specified By 14 Coordinate Points
Point X-Surf Y-Surf
No. (ft) (ft) ,
1 348.62 69.95
2 350.59 69.11
3 360.58 68.97
4 378.57 69.53
5 388.49 70.82
6 398.29 72.78
7 407.93 75.44
8 417.36 78.78
9 426.52 82.77
10 435.38 87.41
11 443.90 92.66
12 452.01 98.50
13 459.70 104.90
14 459.80 105.00
Circle Center At X = 365.6 ; Y = 210.1 and Radius, 141.2
*** 1.378 ***
Failure Surface Specified By 12 Coordinate Points
Point X-Surf Y-Surf
No. (ft) (ft)
1 346.21 69.08
2 356.20 68.59
3 366.19 68.92
4 376.13 70.06
5 385.94 71.99
6 395.56 74.72
7 404.93 78.22
8 413.98 82.46
9 422.66 87.42
10 430.91 93.08
11 430.68 99.38
12 444.29 104.74
Circle Center At X - 357.2 ; Y - 191.9 and Radius, 123.3
*** 1.388 ***
Failure Surface Specified By 12 Coordinate Points
Point X-Surf Y-Surf
No. (ft) (ft)
1 350.20 73.46
2 367.99 71.09
3 377.91 69.80
4 387.90 69.61
5 397.86 70.52
6 407.66 72.52
7 417.18 75.60
8 426.30 79.70
9 434.91 84.78
10 ,� 442.91 90.78
11 450.20 97.63
12 456.49 105.00
Circle Center At X - 384.6 ; Y = 160.2 and Radius, 90.6
*** 1.396 ***

0
N
I
O
N
1.176
Roxboro Plant FGD Settling Pond j
GCL Breach i
o Design Piezomentric Surface �
Observed Ash Density '
300.00 lblft2
i
1
7
0
0
0
100 150 200 250 300 350 400 450 500 550 500

Slide Analysis Information
Document Name
File Name: Roxboro 1k.sli
Project Settinas
Project Title: SLIDE - An Interactive Slope Stability Program
Failure Direction: Right to Left
Units of Measurement: Imperial Units
Pore Fluid Unit Weight: 62.4 Ib/ft3
Groundwater Method: Water Surfaces
Data Output: Standard
Calculate Excess Pore Pressure: Off
Allow Ru with Water Surfaces or Grids: Off
Random Numbers: Pseudo -random Seed
Random Number Seed: 10116
Random Number Generation Method: Park and Miller v.3
Analysis Methods
Analysis Methods used:
Bishop simplified
Janbu simplified
Number of slices: 30
Tolerance: 0.005
Maximum number of iterations: 10
Surface Options
Surface Type: Circular
Search Method: Auto Refine Search
Divisions along slope: 10
Circles per division: 10
Number of iterations: 10
Divisions to use in next iteration: 50%
Composite Surfaces: Disabled
Minimum Elevation: Not Defined
Minimum Depth: 10
Loadina
1 Distributed Load present:
Distributed Load Constant Distribution, Orientation: Normal to boundary, Magnitude: 300 Ib/ft2
Material Properties

Material: Too Soil
Strength Type: Mohr -Coulomb
Unit Weight: 110 Ib/ft3
Cohesion: 0 psf
Friction Angle: 30 degrees
Water Surface: None
Material: ComBA+FA
Strength Type: Mohr -Coulomb
Unit Weight: 85lb/ft3
Cohesion: 0 psf
Friction Angle: 27 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: COM BA
Strength Type: Mohr -Coulomb
Unit Weight: 95lb/ft3
Cohesion: 0 psf
Friction Angle: 34 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: ExstLAsh
Strength Type: Mohr -Coulomb
Unit Weight: 92.4 Ib/ft3
Cohesion: 0 psf
Friction Angle: 30 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: PWR
Strength Type: Mohr -Coulomb
Unit Weight: 130.4lb/ft3
Cohesion: 18000 psf
Friction Angle: 0 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: GVDPond
Strength Type: Mohr -Coulomb
Unit Weight: 65lb/ft3
Cohesion: 0 psf
Friction Angle: 0 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: ExstDam
Strength Type: Mohr -Coulomb
Unit Weight: 120 Ib/ft3
Cohesion: 250 psf
Friction Angle: 30 degrees

Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: StiffAsh
Strength Type: Mohr -Coulomb
Unit Weight: 116.4lb1ft3
Cohesion: 0 psf
Friction Angle: 33 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Global Minimums
Method: bishop simplified
FS:1.175870
Center: 365.596, 185.492
Radius: 118.483
Left Slip Surface Endpoint: 345.326, 68.755
Right Slip Surface Endpoint: 452.541, 105.000
Resisting Moment=4.96537e+006 lb-ft
Driving Moment=4.22274e+006 lb-ft
Method: ianbu simolified
FS:1.118670
Center: 365.596, 185.492
Radius: 118.483
Left Slip Surface Endpoint: 345.326, 68.755
Right Slip Surface Endpoint: 452.541, 105.000
Resisting Horizontal Force=37841.1 lb
Driving Horizontal Force=33827lb
Valid I Invalid Surfaces
Method: bishop simplified
Number of Valid Surfaces: 1889
Number of Invalid Surfaces: 1
Error Codes:
Error Code -112 reported for 1 surface
Method: ianbu simplified
Number of Valid Surfaces: 1831
Number of Invalid Surfaces: 59
Error Codes:
Error Code -111 reported for 59 surfaces
Error Codes
The following errors were encountered during the computation
-111 = safety factor equation did not converge

-112 = The coefficient M-Alpha = cos(alpha)(1+tan(alpha)tan(phi)/F)
< 0.2 for the final iteration of the safety factor calculation. This screens out
some slip surfaces which may not be valid in the context of the analysis, in
particular, deep seated slip surfaces with many high negative base angle
slices in the passive zone.
List of All Coordinates
Material Boundary
346.350 67.000
445.000 102.900
471.000 103.000
Material Boundary
483.000 99.000
579.000 67.000
Material Boundary
340.500 67.000
346.350 67.000
579.000 67.000
600.000 67.000
Material Boundary
329.000 65.000
600.000 65.000
Material Boundary
325.000 67.000
329.000 65.000
353.000 53.000
600.000 53.000
Material Boundary
353.000 53.000
439.000 10.000
Material Boundary
100.000 10.000
439.000 10.000
600.000 10.000
External Boundary
600.000 10.000
600.000 53.000
600.000 65.000
600.000 67.000
600.000 99.000
483.000 99,000
471.000 103.000

465.000
105.000
445.000
105.000
368.000
77.000
340.500
67.000
325.000
67.000
315.000
70.300
295.000
70.300
182.000
20.000
100.000
10.000
100.000
0.000
600.000
0.000
Piezo
Line
100.000
10.000
182.000
20.000
340.500
67.000
346.350
67.000
483.000
99.000
600.000
99.000
Distributed Load
465.000 105.000
445.000 106,000

GCL Breach
Observed Phreatic Surface
Roxboro Plant FGD WW Settling Pond
300.00 IWO
1

Slide Analysis Information
Document Name
File Name: Roxboro 1e.sli
Project Settinas
Project Tide: SLIDE - An Interactive Slope Stability Program
Failure Direction: Right to Left
Units of Measurement: Imperial Units
Pore Fluid Unit Weight: 62.4 Ibtft3
Groundwater Method: Water Surfaces
Data Output: Standard
Calculate Excess Pore Pressure: Off
Allow Ru with Water Surfaces or Grids: Off
Random Numbers: Pseudo -random Seed
Random Number Seed:10116
Random Number Generation Method: Park and Miller v.3
Analysis Methods
Analysis Methods used:
Bishop simplified
Janbu simplified
Number of slices: 30
Tolerance: 0.005
Maximum number of iterations: 10
Surface Options
Surface Type: Circular
Search Method: Auto Refine Search
Divisions along slope: 10
Circles per division: 10
Number of iterations: 10
Divisions to use in next iteration: 50%
Composite Surfaces: Disabled
Minimum Elevation: Not Defined
Minimum Depth: 10
Loading
1 Distributed Load present:
Distributed Load Constant Distribution, Orientation: Normal to boundary, Magnitude: 300 Ibtft2
Material Properties

Material: Too Soil
Strength Type: Mohr -Coulomb
Unit Weight: 110 Ib/ft3
Cohesion: 0 psf
Friction Angle: 30 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: ComBA+FA
Strength Type: Mohr -Coulomb
Unit Weight: 85 Ib/ft3
Cohesion: 0 psf
Friction Angle: 27 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: COM BA
Strength Type: Mohr -Coulomb
Unit Weight: 95 Ib/ft3
Cohesion: 0 psf
Friction Angle: 34 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: ExstLAsh
Strength Type: Mohr -Coulomb
Unit Weight: 92.4 Ib/ft3
Cohesion: 0 psf
Friction Angle: 30 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: PWR
Strength Type: Mohr -Coulomb
Unit Weight: 130.4 Ib/ft3
Cohesion: 18000 psf
Friction Angle: 0 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: GVDPond
Strength Type: Mohr -Coulomb
Unit Weight: 65lb/ft3
Cohesion: 0 psf
Friction Angle: 0 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: ExstDam
Strength Type: Mohr -Coulomb
Unit Weight: 120lb/ft3
Cohesion: 250 psf

Friction Angle: 30 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: StiffAsh
Strength Type: Mohr -Coulomb
Unit Weight: 116.4 Ibfft3
Cohesion: 0 psf
Friction Angle: 33 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Global Minimums
Method: bishop simplified
FS: 0.689447
Center: 359.170, 119.105
Radius: 51.995
Left Slip Surface Endpoint: 345.691, 68.887
Right Slip Surface Endpoint: 401.758, 89,276
Resisting Moment=382591 lb-ft
Driving Moment=554924lb-ft
Method: lanbu simplified
FS:0.648601
Center: 363.082, 105.258
Radius: 38.003
Left Slip Surface Endpoint: 348.830, 70.029
Right Slip Surface Endpoint: 396.635, 87.413
Resisting Horizontal Force=5521.35 lb
Driving Horizontal Force=8512.7 lb
Valid / Invalid Surfaces
Method: bishop simplified
Number of Valid Surfaces: 1474
Number of Invalid Surfaces: 1
Error Codes:
Error Code -112 reported for 1 surface
Method: ianbu simplified
Number of Valid Surfaces: 1440
Number of Invalid Surfaces: 35
Error Codes:
Error Code -111 reported for 30 surfaces
Error Code -112 reported for 5 surfaces
Error Codes
The following errors were encountered during the computation

-111 = safety factor equation did not converge
-112 = The coefficient M-Alpha = cos(alpha)(1+tan(alpha)tan(phi)/F)
< 0.2 for the final iteration of the safety factor calculation. This screens out
some slip surfaces which may not be valid In the context of the analysis, in
particular, deep seated slip surfaces with many high negative base angle
slices in the passive zone.
List of Ali Coordinates
Material Boundary
346.350 67.000
445.000 102.900
471.000 103.000
Material Boundary
483.000 99.000
579.000 67,000
Material Boundary
340.500 67.000
346.350 67,000
579.000 67.000
600.000 67.000
Material Boundary
329.000 65.600
600.000 65.000
Material Boundary
325.000
67.000
329.000
65.000
353.000
53.000
600.000
53.000
Material Boundary
353.000
53.600
439.000
10.000
Material Boundary
100.000
10.000
439.000
10.000
600.000
10.000
External Boundary
600.000
10.000
600.000
53.000
600.000
65.000
600.000
67.000
600.000
99.000

Slide Analysis Information
Document Name
File Name: Roxboro 1h.sli
Project Settings
Project Title: SLIDE - An Interactive Slope Stability Program
Failure Direction: Right to Left
Units of Measurement: Imperial Units
Pore Fluid Unit Weight: 62.4lb/ft3
Groundwater Method: Water Surfaces
Data Output: Standard
Calculate Excess Pore Pressure: Off
Allow Ru with Water Surfaces or Grids: Off
Random Numbers: Pseudo -random Seed
Random Number Seed: 10116
Random Number Generation Method: Park and Miller v.3
Analysis Methods
Analysis Methods used
Bishop simplified
Janbu simplified
Number of slices: 30
Tolerance: 0.005
Maximum number of iterations: 10
Surface Options
Surface Type: Circular
Search Method: Auto Refine Search
Divisions along slope: 10
Circles per division: 10
Number of iterations: 10
Divisions to use in next iteration: 50%
Composite Surfaces: Disabled
Minimum Elevation: Not Defined
Minimum Depth: Not Defined
Loading
1 Distributed Load present:
Distributed Load Constant Distribution, Orientation: Normal to boundary, Magnitude: 300 Ib/ft2
Material Properties

Material: Too Soil
Strength Type: Mohr -Coulomb
Unit Weight: 110 Ib/ft3
Cohesion: 0 psf
Friction Angle: 30 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: ComBA+FA
Strength Type: Mohr -Coulomb
Unit Weight: 85 Ib/ft3
Cohesion: 0 psf
Friction Angle: 27 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: COM BA
Strength Type: Mohr -Coulomb
Unit Weight: 95 Ib/ft3
Cohesion: 0 psf
Friction Angle: 34 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: ExstLAsh
Strength Type: Mohr -Coulomb
Unit Weight: 92.4 Ib/ft3
Cohesion: 0 psf
Friction Angle: 30 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: PWR
Strength Type: Mohr -Coulomb
Unit Weight: 130.4 Ib/ft3
Cohesion: 18000 psf
Friction Angle: 0 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: GvpPond
Strength Type: Mohr -Coulomb
Unit Weight: 65 Ib/ft3
Cohesion: 0 psf
Friction Angle: 0 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: ExstDam
Strength Type: Mohr -Coulomb
Unit Weight: 120 Ib/ft3
Cohesion: 250 psf

Friction Angle: 30 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: StiffAsh
Strength Type: Mohr -Coulomb
Unit Weight: 116.4lb/ft3
Cohesion: 0 psf
Friction Angle: 33 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Global Minimums
Method: bishop simplified
FS: 1.452220
Center: 319.304, 254.009
Radius: 187.380
Left Slip Surface Endpoint: 343.958, 68.258
Right Slip Surface Endpoint: 419.722, 95.808
Resisting Moment=2.16054e+006 lb-ft
Driving Moment=1.48776e+006lb-ft
Method: ianbu simplified
FS: 1.435400
Center: 322.446, 239,193
Radius: 173.125
Left Slip Surface Endpoint: 340.548, 67.017
Right Slip Surface Endpoint: 419.167, 95.606
Resisting Horizontal Force=12806.1 lb
Driving Horizontal Farce=8921.64lb
Valid / Invalid Surfaces
Method: bishop simplified
Number of Valid Surfaces: 1742
Number of Invalid Surfaces: 0
Method: ianbu simplified
Number of Valid Surfaces: 1733
Number of Invalid Surfaces: 9
Error Codes:
Error Code -111 reported for 9 surfaces
Error Codes
The following errors were encountered during the computation:
-111 = safety factor equation did not converge

List of All Coordinates
Material Boundary
346.350
67.000
445.000
102.900
471.000
103.000
Material Boundary
543.000
79.000
579.000
67.000
Material Boundary
340.500
67.000
346.350
67.000
579.000
67.000
600.000
67.000
Material Boundary
329.000
65.000
600.000
65.000
Material Boundary
325.000
67.000
329.000
65.000
353.000
53.000
600.000
53.000
Material Boundary
353.000
53.000
439.000
10.000
Material Boundary
100.000
10.000
439.000
10.000
600.000
10.000
External Boundary
600.000
10.000
600.000
53.000
600.000
65.000
600.000
67.000
600.000
79.000
543.000
79.000
471.000
103,000
466.000
105.000
445.000
105.000
340.500
67.000
325.000
67.000
315.000
70.300
295.000
70.300
182.000
20.000

100.000 10.000
100.000 0.000
600.000 0.000
Piezo
Line
0.000
10.000
100.000
10.000
182.000
20.000
340.500
67.000
346.350
67.000
543.000
79.000
600.000
79.000
Distributed Load
465.000 105,000
445.000 105.000

Roxboro Plant FGD Settling Pond
I12 foot pond level with observed ash density
Totallinerbreach
i
L230
300.00 Ib/ft2
MA

Slide Analysis Information
Document Name
File Name: Roxboro 1m.sli
Proiect Settinas
Project Title: SLIDE - An Interactive Slope Stability Program
Failure Direction: Right to Left
Units of Measurement: Imperial Units
Pore Fluid Unit Weight: 62.4 Ib/ft3
Groundwater Method: Water Surfaces
Data Output: Standard
Calculate Excess Pore Pressure: Off
Allow Ru with Water Surfaces or Grids: Off
Random Numbers: Pseudo -random Seed
Random Number Seed: 10116
Random Number Generation Method: Park and Miller v.3
Analysis Methods
Analysis Methods used:
Bishop simplified
Janbu simplified
Number of slices: 30
Tolerance: 0.005
Maximum number of iterations: 10
Surface Options
Surface Type: Circular
Search Method: Auto Refine Search
Divisions along slope: 10
Circles per division: 10
Number of iterations: 10
Divisions to use in next iteration: 50%
Composite Surfaces: Disabled
Minimum Elevation: Not Defined
Minimum Depth: Not Defined
Loading
1 Distributed Load present:
Distributed Load Constant Distribution, Orientation: Normal to boundary, Magnitude: 300 Ib/ft2
Material Properties

Material: Too Soil
Strength Type: Mohr -Coulomb
Unit Weight: 110 Ib/ft3
Cohesion: 0 psf
Friction Angle: 30 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: ComBA+FA
Strength Type: Mohr -Coulomb
Unit Weight: 85lb/ft3
Cohesion: 0 psf
Friction Angle: 27 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: COM BA
Strength Type: Mohr -Coulomb
Unit Weight: 95lb/ft3
Cohesion: 0 psf
Friction Angle: 34 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: ExstLAsh
Strength Type: Mohr -Coulomb
Unit Weight: 92.4 Ib/ft3
Cohesion: 0 psf
Friction Angle: 30 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: PWR
Strength Type: Mohr -Coulomb
Unit Weight: 130.4lb/ft3
Cohesion: 18000 psf
Friction Angle: 0 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: GvoPond
Strength Type: Mohr -Coulomb
Unit Weight: 65lb/ft3
Cohesion: 0 psf
Friction Angle: 0 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: ExstDam
Strength Type: Mohr -Coulomb
Unit Weight: 120 Ib/ft3
Cohesion: 250 psf

Friction Angle: 30 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: StiffAsh
Strength Type: Mohr -Coulomb
Unit Weight: 116.41b/ft3
Cohesion: 0 psf
Friction Angle: 33 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Global Minimums
Method: bishop simplified
FS: 1.230190
Center: 341.094, 158.081
Radius: 91.139
Left Slip Surface Endpoint: 337.835, 67.000
Right Slip Surface Endpoint: 400.205, 88.711
Resisting Moment=872930 lb-ft
Driving Moment=709588 lb-ft
Method: ianbu simDlified
FS: 1.191700
Center: 348.485, 136.161
Radius: 70.122
Left Slip Surface Endpoint: 336.919, 67.000
Right Slip Surface Endpoint: 400.068, 88.661
Resisting Horizontal Force=11416.7 lb
Driving Horizontal Force=9580.17lb
Valid / Invalid Surfaces
Method: bishop simplified
Number of Valid Surfaces: 1422
Number of Invalid Surfaces: 1
Error Codes:
Error Code -112 reported for 1 surface
Method: ianbu simplified
Number of Valid Surfaces: 1365
Number of Invalid Surfaces: 58
Error Codes:
Error Code -111 reported for 58 surfaces
Error Codes
The following errors were encountered during the computation:
-111 = safety factor equation did not converge

-112 = The coefficient M-Alpha = cos(alpha)(1+tan(alpha)tan(phi)/F)
< 0.2 for the final iteration of the safety factor calculation. This screens out
some slip surfaces which may not be valid in the context of the analysis, in
particular, deep seated slip surfaces with many high negative base angle
slices in the passive zone.
List of All Coordinates
Material Boundary
346.350 67.000
445.000 102.900
471.000 103.000
Material Boundary
543,000 79.000
579.000 67.000
Material Boundary
340.500 67.000
346.350 67.000
579.000 67.000
600.000 67.000
Material Boundary
329.000 65.000
600.000 65.000
Material Boundary
325.000 67.000
329.000 65.000
353.000 53.000
600.000 53.000
Material Boundary
353.000 53.000
439.000 10,000
Material Boundary
100.000 10.000
439.000 10.000
600.000 10,000
External Boundary
600.000 10.000
600.000 53.000
600.000 65.000
600.000 67.000
600.000 79.000
543.000 79.000

471.000
103.000
465.000
105.000
445.000
105,000
351.500
71.000
340.500
67.000
325.000
67.000
315.000
70.300
295.000
70.300
182.000
20.000
100.000
10.000
100.000
0.000
600.000
0.000
Piezo
Line
100.000
10.000
182.000
20.000
340.500
67.000
351,500
71.000
543.000
79.000
600.000
79.000
Distributed Load
465.000 105.000
445.000 105.000

Roxboro Plant FGD Settling Pond
GCL Breach
Design Piezometric Surface with 9-foot Toe Drain 300.00 ib_/ft2
Observed Ash Density 5W
A

Slide Analysis Information
Document Name
File Name: Roxboro 11,sh
Project Settings
Project Title: SLIDE - An Interactive Slope Stability Program
Failure Direction: Right to Left
Units of Measurement: Imperial Units
Pore Fluid Unit Weight: 62.4 Ib/ft3
Groundwater Method: Water Surfaces
Data Output: Standard
Calculate Excess Pore Pressure: Off
Allow Ru with Water Surfaces or Grids: Off
Random Numbers: Pseudo -random Seed
Random Number Seed:10116
Random Number Generation Method: Park and Miller v.3
Analysis Methods
Analysis Methods used:
Bishop simplified
Janbu simplified
Number of slices: 30
Tolerance: 0.005
Maximum number of iterations: 10
Surface Options
Surface Type: Circular
Search Method: Auto Refine Search
Divisions along slope: 10
Circles per division: 10
Number of iterations: 10
Divisions to use in next iteration: 50%
Composite Surfaces: Disabled
Minimum Elevation: Not Defined
Minimum Depth: 10
Loading
1 Distributed Load present:
Distributed Load Constant Distribution, Orientation: Normal to boundary, Magnitude: 300 Ib/ft2
Material Properties

Material: Too Soil
Strength Type: Mohr -Coulomb
Unit Weight: 110 Ib/ft3
Cohesion: 0 psf
Friction Angle: 30 degrees
Water Surface: None
Material: ComBA+FA
Strength Type: Mohr -Coulomb
Unit Weight: 85 Ib/ft3
Cohesion: 0 psf
Friction Angle: 27 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: COM BA
Strength Type: Mohr -Coulomb
Unit Weight: 95lb/ft3
Cohesion: 0 psi
Friction Angle: 34 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: ExstLAsh
Strength Type: Mohr -Coulomb
Unit Weight: 92.4 Ib/ft3
Cohesion: 0 psf
Friction Angle: 30 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: PW R
Strength Type: Mohr -Coulomb
Unit Weight: 130.4lb/ft3
Cohesion: 18000 psf
Friction Angle: 0 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: GvPPond
Strength Type: Mohr -Coulomb
Unit Weight: 65lb/ft3
Cohesion: 0 psf
Friction Angle: 0 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: ExstDam
Strength Type: Mohr -Coulomb
Unit Weight: 120lb/ft3
Cohesion: 250 psf
Friction Angle: 30 degrees

Water Surface: Piezometric Line 1
Custom Hu value: 1
Material: StiffAsh
Strength Type: Mohr -Coulomb
Unit Weight: 116.41b/ft3
Cohesion: 0 psf
Friction Angle: 33 degrees
Water Surface: Piezometric Line 1
Custom Hu value: 1
Global Minimums
Method: bishop simplified
FS:1.559730
Center: 395.425, 131.900
Radius: 57.129
Left Slip Surface Endpoint: 373.688, 79.068
Right Slip Surface Endpoint: 445.824, 105.000
Resisting Moment=1.82074e+006 lb-ft
Driving Moment=1.16735e+006lb-ft
Method: ianbu simDlified
FS:1.324770
Center: 401.070, 116.196
Radius: 46.133
Left Slip Surface Endpoint: 373.688, 79.068
Right Slip Surface Endpoint: 445.824, 105.000
Resisting Horizontal Force=33444.5 lb
Driving Horizontal Force=25245.5 lb
Valid / Invalid Surfaces
Method: bishop simplified
Number of Valid Surfaces: 13
Number of Invalid Surfaces: 0
Method: ianbu simplified
Number of Valid Surfaces: 13
Number of Invalid Surfaces: 0
List of All Coordinates
Material Boundary
346.350 67.000
445.000 102.900
471.000 103.000
Material Boundary
483.000 99.000
579.000 67.000

Material Boundary
340.500
67.000
346.350
67.000
349.500
67.000
579.000
67.000
600.000
67.000
Material Boundary
329.000
65.000
600.000
65.000
Material Boundary
325.000
67.000
329.000
65.000
353.000
53.000
600.000
53.000
Material Boundary
353.000
53.000
439.000
10.000
Material
Boundary
100.000
10.000
439.000
10.000
600.000
10.000
External Boundary
600.000
10.000
600.000
53.000
600.000
65.000
600.000
67.000
600.000
99.000
483.000
99.000
471.000
103.000
465.000
105.000
445.000
105.000
368.000
77.000
340.500
67.000
325.000
67.000
315.000
70.300
295.000
70.300
182.000
20.000
100.000
10.000
100.000
0.000
600.000
0.000
Piezo
Line
349.500
67.000
483.000
99.000
600.000
99.000

Distributed Load
465.000 105.000
445.000 105.000

0 ARCADIS
ARCADIS
Infrastructure, environment, facilities
1210 Premier Drive
Suite 200
Chattanooga
Tennessee 37421
Mr. John Edelen
Tel [phone]
Progress Energy
Fax [phone]
410 S. Wilmington St.
w .arcadls�us.com
PEB 8
Raleigh, NC 27601
DAM SAFETY
Subject
Roxbury Plant —Flush Pond and Settling Pond Dikes
Dear John:
Date:
March 7, 2008
We appreciate the opportunity to assist you with dike stability concerns at the
Roxbury Plant. As you know, on March 4, 2008, 1 made a site visit to observe the
Conw:
flush pond and settling pond dikes. After the site visit, you and I briefly discussed the
Paul Booth
issues noted in the field. We also looked at two drawings, a plan sheet and a sheet of
typical dike sections, and discussed some of the design features that may be
Extension:
729
impacting slope stability. I would like to itemize the field observations, discuss some
of the design considerations, and close with conclusions and recommendations.
email
paul.booth@arcadis-
In conducting our review, we recognize that we have very limited information about
us.com
the dikes and that the project's designer has had far greater involvement in the
project, its materials and setting, and its specific demands. Therefore, in our review
our mt.
CT053248.0000.0001
we may make the error of critiquing the design out of ignorance of important areas or
considerations that were part of the design. Against this background, we offer our
observations and opinions.
Field Observations
Settling Pond Dike
1. A few small boils were noted in the toe ditch along the north end of the pond.
No significant piping was occurring.
2. For several hundred feet, the lower one-third of the outside slope of the west
side of the dike was saturated, soft, and with diffuse seepage from the
saturated zone. This same area had intermittent longitudinal cracks at the
upper limit of the saturated zone. Crack widths appeared to be less than %-
Imagine the result

ARCADIS John Edelen
March 7, 2008
inch, but the cracks are indicative of marginal stability of the embankment
slope in this area.
3. Six new piezometers have been installed in this saturated area. At least one
of the piezometers indicated artesian conditions (water levels at or above the
slope surface).
4. Seepage is being monitored near the southwest corner of the dike with a V-
notched weir.
5. Minor bulging of the slope maybe present near the lower portions of the
slope in the saturated area. This bulging is consistent with the cracks noted
in Item 2.
6. The pond was being lowered at the rate of approximately 1 foot per day
using three pumps located in the emergency spillway.
7. Wastewater was being pumped into the pond at the northeast corner.
8. The inside slopes and dike crest appeared uniform with no signs of
movement or distress.
Flush Pond Dike
Several apparent small failures had occurred on the lower inside slope along
the south side of the dike. These failures may be "veneer" failures and are
located near the current water level. Signs of failure were noted along almost
all of the south side of the dike.
2. The inside slopes of the north side of the dike appeared uniform with no
signs of movement.
3. A small failure approximately 20 feet wide has occurred at the toe of the
outside slope near the southwest corner of the dike. This failure has a
vertical scarp approximately 5 feet high in which the demarcation of fly ash
and "topsoil" was clearly visible. Seepage was emitting from the toe of the
failed area and moving in a westerly direction. The seepage appeared to be
traveling along the interface of recently placed fill and natural ground, leaving
areas of fill that caved into voids. It appeared that upon failure, a moderate
Page.
2/6

ARCADIS John Edelen
March 7, 2008
amount of fly ash was washed into the nearby low area, but the seepage
was clear at the time of the visit with a flow of approximately 10 to 15 gallons
per minute. Fly ash exposed in the scarp appeared to have a particle size
distribution that would classify the ash as fine silty sand. The embankment
slope around the failure did not appear to be saturated and showed no sign
of further instability.
Design Considerations
1. Because of the height of the dikes, the magnitude of the investment cost,
and their designated function as wastewater treatment facilities, we feel that
the design basis should be similar to that used in dam design. Such design
would provide for robust and redundant features for retention of water and
internal drainage.
2. It appears that the design of the dikes relies upon the geosynthetic clay liner
(GCL) as the primary impermeable layer. If the GCL is compromised, the
water retention capability is compromised.
3. The drawings indicate a 12-inch-minimum layer of fly ash beneath the GCL,
and a 2-foot-minimum layer of fly ash above the GCL. Such thin layers are
difficult to compact, especially on the 1V on 3H slope. Since it is above the
GCL, the 2-foot layer becomes completely saturated upon pond filling. If this
layer is not well -compacted and not confined, it could lose strength upon
saturation.
4. If the exposed fly ash layers have reduced strength upon saturation, there
will be corresponding reductions in interface strength with the geosynthetics
in the system.
5. The adopted slopes (shown as Won 3H inside and Won 2.75H outside)
seem somewhat steep for an embankment primarily consisting of fly ash,
especially given the design philosophy noted in Item 1.
6. There appears to be no explicit consideration given to internal drainage. As a
result, if the GCL is compromised, the embankment behaves as a
homogenous structure. The saturated conditions and seepage observed at
the downstream toe of the dikes are indicative of the behavior of a
homogenous embankment. The drawings indicate a layer of 2 feet of
Page:
cdv�4 i 'Sftwn as Mo dw 3/6

ARCADIS John Edelen
March 7, 2008
"topsoil" cover on the outside slopes. This cover is exposed in the scarp of
the small failure at the southwest toe of the flush pond dike. Examination of
this material indicates a fairly clayey sand. This cover is probably less
permeable than the fly ash, thereby inhibiting drainage and creating the
artesian conditions seen in the piezometers. Elevated piezometric conditions
adversely affect the slope stability.
7. Underlying original ground and geologic conditions can influence drainage
pathways and dike performance. The failure at the flush pond dike appears
to be at a very specific location and not the result of a generalized high
seepage surface in the dike. Upon failure, the water took the route of least
resistance which may have been along some preferential pathway in the
underlying ground surface. The boils in the toe ditch may be the result of
underlying geologic or soil conditions that indicate a preferential path of
drainage.
Conclusions and Recommendations
The inside slope of the flush pond dike has failed at numerous places on the south
side. The mechanism of this failure is uncertain. It is possible that the shear strength
of the thin fly ash layers or the interface strength of the geosynthetics is less than
that assumed during design. These shallow surface failures have likely compromised
the GCL impermeable barrier and have allowed uncontrolled seepage to develop,
resulting in the failure at the southwest outside corner of the dike.
In both ponds, it is likely that the GCL has been compromised and allowed significant
seepage to develop in the dikes. The dikes exhibit characteristics similar to a
homogenous embankment. Since no internal drainage features exist in the dikes,
uncontrolled seepage has developed. The presence of a less permeable soil cover
on the outside slopes serves to block drainage, further aggravating seepage
pressures and reducing the slope stability. Lowering of the pool level, now underway,
will reduce overall seepage and improve the stability of the slopes.
Whereas the condition of the dikes is not good, failure of the dikes which would
cause an uncontrolled release of wastewater does not appear imminent. Although
small surficial failures may continue to develop, the quick response of Progress
Energy to lower the pond levels has served to mitigate a potentially hazardous
situation.
Page:
c,�,erasu�eK,.+w�xaw,r vmeawdn� 4/6

ARCADIS John Edelen
March 7. 2008
Recommendations are categorized as short-term and long-term. Short term
recommendations are focused on documenting and monitoring the existing
conditions within the dikes and include:
t. Continue drawdown of the water level within the ponds.
2. Continue daily inspections of the dikes with emphasis on the existing
problem areas.
3. Install additional piezometers. Locate piezometers so that good definition of
piezometric conditions can be made on cross sections for analytical
purposes. Once piezometers are installed and developed, conduct falling or
rising head tests to determine horizontal permeability. These permeability
values should then be evaluated for use in further analyses and design.
4. Install a simple system of stakes upslope and downslope of cracks so that
distance measurements between the stakes will document future slope
movement.
5. Continue monitoring seepage flows with ditch weirs.
6. Locate problem areas with a good survey. Document location and
elevations of key seepage areas, failures, boils, cracks, and other signs of
distress.
To fully assess long term recommendations, Progress Energy will need to decide if
controlling the seepage is sufficient or if reducing the amount of seepage is also
necessary. If seepage reduction is required to meet the intent of the NPDES
discharge permit, it appears that remedial design and construction of the inside
slope, pond bottom, and the associated impermeable barrier will be required. If
simply controlling the seepage is sufficient, this can perhaps be accomplished with
an outside slope filter blanket alone. The following long-term recommendations
assume that the existing rate of seepage must be reduced and that seepage control
alone is not acceptable.
Redesign the water retaining features of the dikes with more robust
impermeable barriers. Such features could consist of a new impermeable
barrier on the slopes and pond bottom or a slurry cutoff wall through the crest
of the dike. In this redesign, carefully evaluate constructability and the
Page.
0 NpWi41Tl4p 1iJ/nNodryYu kMft 5/6

ARCADIS John Edelen
March 7, 2008
impacts it has on the strength of the materials. Consider the need for flatter
slopes on the inside of the dikes.
2. Regardless of the inside slope treatment, provide seepage control measures
as a redundant feature to prevent inadequate stability in the outer slopes of
the dikes. One effective method of seepage control is a filtered drainage
blanket on the lower portions of the outside slope. For such a drainage
blanket, we recommend utilizing natural sands and gravels in lieu of
geosynthetics. Seepage control measures should be designed using proper
filter criteria for the fly ash. Designers should consider the need for flatter
outside slopes. If a drainage blanket is used on the outside slope, the
existing soil cover should first be removed to allow for free drainage of the fly
ash.
3. Evaluate the impacts of foundation conditions on the overall design. The
conditions of the original soils and geology will play an important role in the
design and performance of the project. If sufficient information is not
available, a subsurface investigation (drilling, sampling, and testing) may be
warranted.
As mentioned earlier, we offer our comments and recommendations based on very
limited information. Our goal is not to be critical of the existing design, but to offer
insights and recommendations for moving forward from a difficult situation. We
appreciate the opportunity to be of service on this project and will support you in
whatever role you feel is best.
Please call if you have any questions or wish to discuss our review.
Sincerely,
/_1CZN_1DW
Paul E. Booth, PE
Dam Safety Manager
Page:
G IrgICi05JMA1CwW1{yywRUDuryDwgpFw Ux 6/6

1/ Worley Parsons
Date: 5/29/2008
2675 Morgantown Road
Reading, PA 19607
USA
Telephone [phone]
Facsimile + 1 610 855 2001
www.warleypemons.com
File: ROXO-O-CO-526-PCLT-0145
WBS: 526
Mr. Danny Johnson
Progress Energy Carolinas
410 S. Wilmington St.
PEB 8A3
Raleigh NC 27601
Re: Roxboro - FGD and SCR Projects
Response to Golder Letter
Dear Mr. Johnson:
The attached table contains our comments to the report issued by Mr. Charles Hiner of Golder
Associates to Mr. Charlie Madsen, dated May 1, 2008. While we do not disagree with his
statement that "the root cause of the failures to date is considered to be the failure of the GCL
panel seams.", we do not agree that the ......bentonite incompatibility with the FGD wastewater
..... would have eventually resulted in failure of the seam and resultant failure of the GCL
liner...". WorleyParsons has just received permission to send Mr. Hiner s report to CETCO, the
supplier of the GCL liner for the wastewater settling pond. As soon as we receive a response
back from CETCO we will evaluate that information and provide additional information to
Progress Energy.
Additionally, we agree that the root cause of flush pond failure is the migration of the ash into
the working pad. However, the liner must have leaked to cause this problem to occur. The liner
was severely compromised in the failure area and therefore it would be impossible to determine
why the liner leaked. It can, however, be conjectured that either bentonite wasn't installed on the
seam in the area or that the seams were separated during construction.
We welcome an opportunity to discuss our comments with Progress Energy personnel and
Golder Associates at any time and we will forward additional information regarding the GCL as
soon as we receive a response back from CETCO.
Enclosures
cc: R. Burkee
J. Edelen
Encompass Letter i of 6
Roxo-O-Co-526-Pcit-0145. Doc
z
Jy yDnald A. Afflerbach, P.E.
Project Manager

The following are our comments to the Golder Associates letter to Charlie Madison of
Progress Energy Carolinas, Inc. on May 1, 2009:
SECTION
COMMENT
Pond Design — ly
The project specifications for embankment fill require a
Paragraph
maximum loose lift thickness of 10-inches and not 12-inches as
stated. See Specification TS-02200, Section 3.09, Item I for
specific details. In addition, "the flyash below the Geosynthetic
Liner shall be placed wet of optimum moisture." There is no
indication in the compaction test results that we have that these
requirements were followed for the construction of the flyash
embankments.
Project
Documentation
The following two documents should not have been reviewed
nor should they have been part of the construction for the
Wastewater Settling Ponds: ROXO-O-SP-535001-RA and
ROXO-O-TS-02750-RA. These two documents were
preliminary and never issued for construction.
The following document should have been reviewed as part of
the review of the construction of the Wastewater Settling Ponds:
Technical Specification for Construction Quality Assurance!
Quality Control Plan, ROXO-O-TS-02220-RO. This document
contains numerous requirements to help ensure proper
construction of the Wastewater Settling Ponds. It is not known
if all of these requirements were followed for construction of the
ponds.
The calculation reviewed is Revision I and there was a
subsequent Revision 2 that was issued in May 2006.
WorleyParsons does not have a copy of the log bk prepared by oo
Michael Fussell and therefore did not review this document.
Stability Analyses
It should be noted that the area of the worst seeps also is the area
where significant amounts of rock fill was placed. The Golder
logs show this as partially weathered rock. This layer is actually
fill and is one of the reasons that seepage is apparent in this area.
Rock fill was not supposed to be used to construct part of the
flyash embankments.
.---.�_._.__ - ....._....._..—
WorleyParsons is presently preparing calculations to show that
liquefaction of the ash beneath the pond is unlikely.
Encompass Letter 2 of 6
Roxo-O-Co-526-Pelt-0145. Doc

SECTION COMMENT
Review of CQA The specifications require a smooth -wheel vibratory roller to
Documentation compact granular materials, i.e flyash and bottom ash, not a
sheepsfoot roller. Therefore, the wrong roller was used to
compact the flyash fill. In addition, the specifications for lifts
are 10-inches loose and not the 12-inches compacted as appears
to have been done at the site.
Observations and
Comments for FGD
Wastewater Settling
Pond
Nuclear density gauges are highly inaccurate for moisture
content of ash fills. There is no indication in the field density
tests that corrections were made with the test results from the
nuclear density gage.
There is no indication that the flyash was compacted wet of
optimum as required below the GCL.
In accordance with Specification TS-02246 the compaction tests
were supposed to he located within 5-feet horizontally and 0.5
feet vertically. As indicated by Golder these requirements were
not followed for the soil testing during construction. It is not
known if the minimum number of tests that were required for the
flyash fill were done in the field. These tests include one proctor
and gradation for every 2,000 cubic feet of fill placed, one field
density test for each 5000 square feet of fill placed, and one test
for lift thickness every lift placed.
It is recommended that further investigation
an why
appears that there is no bentonite in numerous seams even
though the CQA records indicate otherwise.
We agree that the tears in the Typar geotextile caused the
interior veneer failures of the flyash. This is the reason that the
Specification TS-02200, Section 3.12, Items F, G, and H
contained the following requirements: "The geotextile shall be
fully sewn in the long dimension parallel and perpendicular with
the slope direction. Heat bonding and/or overlapping of the
geotextile in not permitted:' " Backfilling operations shall be
performed in a manner, which prevents damage to the geotextile.
Any geotextile damaged during backfilling operations shall be
repaired." "The riprap over the geotextile for the wastewater
settling ponds shall not be pushed up the slope. The Contractor
shall devise a plan to place the riprap over the geotextile, which
prevents damage to the fabric."
Encompass Letter 3 of 6
Roxo-O-Co-526-Pclt-0145.Doc

SECTION
COMMENT
We agree that one of the root causes is probably the failure of
the GCL seams due to no bentonite placed in the seams. As for
the incompatibility of the wastewater to the bentonite, we are
awaiting additional comments from CETCO. Note even if the
bentonite was exposed to FGD wastewater the permeability of
the bentonite would still be very low. In accordance with
CETCO's requirements, Specification TS-02210, Section 2.1,
Item DI, "the GCL shall be hydrated with fresh or rain water."
This requirement helps to mitigate the concerns of the
incompatibility of the bentonite with the wastewater.
We request that we be provided with any data from the testing
that Golder perfonned in evaluating the incompatibility of the
GCL with the wastewater.
At this time we reserve judgment on whether the GCL seams
would have failed in the future due to incompatibility with the
wastewater.
During design we recognized issues related with incompatibility
of the GCL with the wastewater. The following infonnation was
contained in the design calculation. "For many GCL liners, the
hydraulic conductivity is approximately in the order of I x 10-9
cm/sec. The hydraulic conductivity of the liner can be altered
over time due to many reasons such as gaps or holes formed and
the surrounding environment. First, the bentonite needs to be
kept hydrated so it doesn't crack over the years and form gaps.
Secondly, chemical durability of the liner is mainly affected by
the pH of the surrounding material. The bentonite can be
subjected to the cation exchange if the surrounding material has
excessive amounts of salts carrying detachable K+, Ca4-4 ,
Mg++, or Al4-++. These cations are exchanged with the sodium
cation (Na+) in the bentonite and cause a different orientation of
the particles which may increase the hydraulic conductivity. Fly
ash is alkaline in nature and it releases a relatively low amount
of metal ions when leached with an aqueous solution of a pH
greater than seven (7). Alternatively, bottom ash can exhibit
corrosive properties due to its acidic nature and high salt content.
Encompass Letter 4 of 6
Roxo-0-Co-526-Pelt-0145. Doc

SECTION
COMMENT 1
The embankments will be exposed to fresh water, rainwater and
wastewater. The fresh water and rainwater are not expected to be
a problem since the pH of the water is probably around seven
(7). However, the pH of the FGD wastewater is between 5.5 and
6.5 based on Reference 17. Additionally, the FGD wastewater
contains dissolved solids such as Ca++. Mg++ and Na 1-.
Compatibility tests were conducted and the results are given in
Attachment 1. The fly ash is compatible with the bentonite and
shall be placed around the GCL during the construction of the
embankments. Since the GCL is most likely incompatible with
wastewater, the GCL shall be a plastic -laminated GCL with the
membrane side to the wastewater and sodium bentonite side
down to the fly ash." This issue was discussed with CETCO
who was the supplier of the GCL.
------------
We propose that another root cause could be the separation of or
damage to the GCL panels, especially at the toe of the slope.
This item can not be observed until after the pond is emptied and
the area is investigated.
Observations and
We agree that the root cause of the flush pond failure is the
Comments for
migration of ash into the working pad. The blasted rock was
Flush Pond
observed to be coarse and open graded. The specifications (TS-
02200, Section 2.1, Item L) required that "the partially
weathered rock be broken and well -graded, containing particle
size not greater than eight (8) inches." We agree with the Golder '
conclusion that "the working pad should have been choked off
with finer aggregates/sands or geotextile fabric to protect against
the migration of the overlying ash into the working pad."
Recommendations
We agree with relining the ponds with a flexible membrane.
However, we feel that a LLDPE liner is much more suitable due
to much higher biaxial stain capabilities than an HDPE liner.
The pond is expected to settle as it tills with water and gypsum.
thereby putting biaxial strain on the liner system.
�
We agree that for rehabilitation of the flush pond that the extent
of the rock fill tier the working pad be determined and it be
properly sealed so that ash cannot migrate into the open voids.
Note there is a large layer of rock fill above the working pad in
the southwest comer of the Wastewater Settling Pond. This area
needs further investigation and may require repairs during pond
rehabilitation.
Encompass Letter 5 of 6
Roxo-O-Co-526-Pclt-0145.Doc

SECTION COMMENT
WorleyParsons is presently preparing calculations to address
concerns related to potential liquefaction of the wet ash below
the settling pond.
We believe that careful forensic analyses should continue to be
done on the ponds to help determine if there are other causes for
the failures and to ensure that all items are addressed if the
ponds are rehabilitated.
Encompass Letter 6 of 6
Roxo-O-Co-526-P clt-0145. Doc

Attachment B
Summary of Emergency Berm Failure Plan

Waste Water Treatment Pond
Emergency/Contingency Plan
Potential Short Term
Pond Failure Solution Scenario

aut of Laree Settling Pe
Pond_ and Bioreacta

"Pond Failure" Plan
• Immediately after a pond failure we would:
— Implement Event Notification Process by contacting Unit
1&2 Control Room (336)-597-6172
— Notify G&TCD and Roxboro key personnel
Stop pumping wastewater to WWTP-Roxboro Plant
• Contain WW in absorber vessels, blowdown tanks and emergency
storage tank while connections are made to the reroute piping
already in place
— Inspect WWT area for safety, health & environmental
concerns - G&TCD and Roxboro Plant
— Notify Env. Services and ESS will notify DWQ — Roxboro
Plant

After Unit 1 &2 Control Room - Contact:
G&TC Personnel to Contact:
Bill Easter— Cell 919-219-1574 Office 919-546-6021
John Mangum— Cell 336-504-3427 Office 336-597-6145 Home 336-364-8571
Danny Johnson —Cell 919-632-2989 Office 919-546-7724 Home 919-851-4092
John Slothower — Cell 336-504-4452 Office 336-597-7681 Home 919-720-4147
Plant Personnel to Contact:
Billy Milam — Pager 336-216-0160 Office 336-597-6284
Reggie Clay — Cell 336-504-2317 Office 336-597-6116 Home 336-234-9192
Jodirah Green — Cell 336-503-2869 Office 336-598-4068 Home 919-752-0089
Mike Mosley — Cell 336-597-1413 Office 336-597-6275
Issa Zarzar — Cell 919-812-0446 Office 919-881-3850 Home 919-872-8448
A determination will be made to stop pumping to WWTP by Plant Personnel in
coordination with G&TC to coordinate next step in the Failure Plan; To Reroute
Blowdown Piping.

Notifications to our Environmental Services Group
by Plant Personnel would include:
Earl Enzor — Cell 919-271-3655 Office 919-546-2136
Shannon Langley — Cell 919-219-0905 Office 919-546-2439
Alan Madewell — Cell 919-749-8778 Office 919-546-5797
ESS would notify the DWQ of this emergency and advise them
of our need to implement this plan.
G&TC to contact and communicate this emergency to these key people:
Teresa Williams —Cell 919-216-0160 Office 919-546-4111
Al Rios — Cell 919-546-4799 Office 919-219-6923
Andy Solomon — Cell 336-597-1845 Office 336-597-6136
John Edelen — Cell 919-215-2164 Office 919-546-6765

The WWTP Area will be inspected for safety, health and environmental
concerns beyond the obvious failure of the pond by:
A G&TC and Plant Team Comprised of Key Members such as but not limited to:
Bill Easter — Cell 919-219-1574 Office 919-546-6021
John Mangum— Cell 336-504-3427 Office 336-597-6145
Danny Johnson — Cell 919-632-2989 Office 919-546-7724
John Slothower — Cell 336-504-4452 Office 336-597-7681
Billy Milam — Pager 336-216-0160 Office 336-597-6284
Dewayne Gibson — Cell 336-504-7122 Office 336-597-6237
Reggie Clay —Cell 336-504-2317 Office 336-597-6116
Mike Mosley — Cell 336-597-1413 Office 336-597-6275
Issa Zarzar — Cell 919-812-0446 Office 919-881-3850
John Edelen — Cell 919-215-2164 Office 919-546-6765
Jodirah Green — Cell 336-503-2869 Office 336-598-4068
Note: All personnel listed are not required to inspect the area, however, the more eyes available the better our
chances to identify any hazards that may exist as a result of a pond failure. The object is to assess the area,
determine any issues that must be addressed to ensure that any work activity in and around the WWTP failure
can be conducted safely. The area will be secured until it can be made safe for work activities to continue.

go
Pond Failure Contingency (cont.)
Following Area Inspection:
• Emergency cleanup or mitigation actions will
be implemented as needed following the
assessment of the area.
• Appropriate measures will be taken to ensure
the
safety
of
all employees participating in
any
clean
up
effort.

Pond Failure Contingency
• In the first 24 hours following a pond failure
we would: (cont.)
— Redirect blowdown flow to ash pond — G&TCD
— Inspect bioreactor and place in standby mode —
Roxboro Plant
— Repair/splice bioreactor fiber optic and power
cables if needed — G&TCD (splice kits are to be
onsite)

Redirect the FGD Blowdown pipe (will be directed by G&TQ.
The process will include:
Excavation of the pipe near the base of the ramp to the WWTP
Excavating a new pipe path to Ash Pond
Cutting of the pipe and fabricating an elbow to direct pipe to Ash Pond
Adding the appropriate length of piping to elbow to get discharge into Ash Pond
Testing for flow, leaks, and discharge into Ash Pond
Covering the pipe to re-establish the roadway
This scope of work will be coordinated by G&TC leads and staff. The work will be done by
Contractors at an estimated cost of $4,500.00.
Note:
4 man crew 24 hours to complete the tasks above. Excavator and Fusion machine equipment rental and mobilization costs are
included in the estimate. Estimated Labor Costs of $2,000 Equipment and Mobilization costs of $2,500.

Inspection of the Bioreactor will be coordinated by Roxboro Plant
Personnel with the intent of placing the Bioreactor in `standby
mode' until proper and acceptable WW flow can be re-established.
G&TC will support this effort in any way necessary to help ensure a safe work
environment. This may include an alternative access route to the bioreactor.
This
alternative
route will
be from
Dunnaway
Road
to
the
Ash
Pond
Dam
continuing
across the
dam
to
the
bioreactor from
the
south.
The scope of work to prepare the roadway from Dunnaway Road to the dam would include some
tree and scrub brush removal from an existing roadway, some chain saw work to remove debris from
fallen trees, and minor road maintenance to include some leveling of the roadway and finally, the
addition of #39 stone to ensure a safe driving path.
Matt's Trucking, Inc. is the preferred contractor coming in at a total cost of $10,580.00. This is an
approved vendor/contractor who can mobilize within a day or two.
Contact information: 336-597-5654 or email at mattstrucking&embargmail.com

Pond Failure Contingency
• While the FGD discharge pipe rerouting is
ongoing, the next step of the contingency
plan will be put into motion.
• This plan would include the process of
contacting the vendors and contractors that
have committed to meeting the needs of this
contingency plan on a timely basis; according
to the plan outline.

Pond Failure Contingency
• Mechanisms, contracts, materials, and
preparatory work will all be in place so
that the phone calls made will initiate
actions that will help to ensure that we
can complete the installation and be
ready to accept the FGD Blowdown
through the new flow path at the
bioreactor within an aggressive
schedule of 4 to 6 weeks.

Modular Wanks with Liners and Connectors
Civil Work, prep of area for tanks and pumps
— Surveying to assure a level surface
— Materials Ordered
• Lumber and Ballast for tank installation
• Piping and Fittings
— Frac Tanks Ordered
— Pumps and Hoses
— Installers for Tanks
— Labor to complete the system piping installation
and connect to bioreactor intake

800gpm diesel
Dual Pumping Station
Unit Modular
\
FGD Slowdown Tanks located east of WWTP \y
40 x 475
Modular
7T506300glal
Tank
545300gaI
Tank
( Overflow
Rerouted Discharge Pipe Back to
Modular
Tanks
24" Suction Line
Bioreactor
21, 000 ga I
Frac Tanks
Set on Top of Berm
Between Ponds

Schedule - to order/deliver/install
We k
Notifications
Civil Work
Leveling tank/pump areas
Prep area for frac tanks
Unearthing Bio suction Line
Modular Tanks
Liners and tanks
Delivery
Lear Installer
Installing tanks
Order Materials
Lumber for tanks - delivered
Pipe and fittings - delivered
Frac Tanks Ordered
Delivery & Set Up
Pipe and fittings Connected
Pumps & Hoses
Delivery & Set Up
■■■■■■■■■_______________.^.■■■■■■■■■■■■■■■■■

$ 170,000.00
$ 50,000.00
$ 20,000.00
$ 100,000.00
5 120,000.00
$ 460,000.00
Cost Summary for WWTP Contingency Plan
Rental of Modutanks
Purchased Items Modutanks
Frac Tanks Rental
Misc Purchased/Rental Items
Assorted Labor Costs for all activities
Total estimated costs
Additional Costs for Flush Capabilities
$
85,000.00
Modutank Rental
$
25,000.00
Puchased Items
$
52,000.00
Pumps and Hoses
$
40,000.00
Labor
$
38,000.00
Misc. Fuel, Incidental Materials, etc.
$ 240,000.00
Total estimated costs
Total-$700,000.00

Attachment C
URS Study Schedule

Revised Project Schedule (February 24, 2009)
Hyco Lake Water Quality Improvement Proiect
Week
Wof k
Phase 1 Tasks
Phase 2 Tasks
Phase 3 Tasks
Phase 4 Tasks
Project authorization
1
2/16
Receive all required data from
PE
Kick-off meeting at Roxboro
Site visit
Site visit
2
2/23
Plant
Receive all required data from
PE
Complete Phase 1 data
Receive all required data from
3
3/2
review and develop mass
PE
balance
4
3/9
5
3/16
Complete Phase 1 summary
and resent results
Complete Phase 2 impacts
6
3/23
analysis and mass balances
for near term changes
7
3/30
Complete Phase 2 summary
Meeting — Review Phase 1
Meeting — Review Phase 1
Meeting — Review Phase 1
8
4/6
and Phase 2 results and
and Phase 2 results and
and Phase 2 results and
brainstorm for Phase 3
brainstorm for Phase 3
brainstorm for Phase 3
9
4/13
10
4120
11
4/27
12
5/4
Complete Phase 3 preliminary
analysis
Conference call - Narrow
13
5/11
down preliminary options to
Tier 1 options
14
5/18
15
5/25
16
6/1
17
618
18
6/15
Complete Phase 3 detailed
evaluation
19
6122
Hyco Lake Water Quality Improvement Study
31826673

4r
Week
of k
Phase 1 Tasks
Phase 2 Tasks
Phase 3 Tasks
Phase 4 Tasks
20
6/29
Submit draft report
21
7/6
Present study results at
Roxboro Plant
22
7/13
PE comments on draft report
23
7/20
24
1 7/27
1
Issue final report
25
8/3
Complete stud
26
8/10
Possible presentation of
results
27
8/17
Respond to questions on
results
28
8/24
Final project closure
Calls
Biweekly
Biweekly
Biweekly
Biweekl
Hyco Lake Water Quality Improvement Study
31826673

Attachment D
Settling Column Test Results

Roxboro column settling test
F.D. Fitzgerald

Original settling pond
14/000/000 ft3=48 days @ 1500 gpm

Exist west pond — 48 days - sludge
This cX11(lr g wust snUbsgt pwjd was co"trumed wl-.J) She folkwIng 41inansion q and a5.snciatcd zn-ics.
K2 S 53.E - ,T.vr.- !a Fm �1.u..tl ^r ` •Y . � ?�. %•aq f '•`
2 4i•o )R3i1gS']___•__-_t{y•�\` -� if
<47T (42'R-p- 2. ]:!o
ci6::• Sl' :.M_ri Zens� .. _--_ii_•Y. i
-r, .;_
}�P.1
awu¢t
(/ y ' N ,I +t;
sCtaS T i Yn¢"vx->n osYn Ml, __ _-__— ti
]'FyJ..i • �41>to.d. C.e.,a Fill
P v.[.
Brb:i» OCL >h F`s A•h a>d 5�.1 Fi111.T.mid.
Temporary east pond- 10 days- sludge
9Md• Cfrse of PwsA)___.____
s¢Lo• �725' I(USr Hxrci_"""-._ ??,lSI,= �'>' .,
ee. s•(a�-n,.ysfal.aPJrs r) ',7.3.5e 5. aen {a -3c /b.j.•^• r
.a a�-N'+STJMP4R(RJ ____.__-___.. �i�.vl. nv': flu .� •
liS'{4m'1vJ�Aw�-_____ ., lEE _ ___.i. _ ram_... n�• T AIM
ti.:.rat¢ 6Av¢m.M rn wrs.Eh. acwsisne<. •+/.bvvtv>r.r.xc rA. w..2
r`,>n1 aed Jy RtA� roafAr e�bS>.p nrw Ax6 ha 4r..msaaara'i d -d
ene. .vg. •.is �.�r: j rnl lM:abe•.W.daMS.Efa..an-w.<rwi'
•v-/an,M.• M...b. yv. rr+W 'wY ae•pWCrf tAYt.Y1SP, Jt'[1: w'hb
f
id' c7W Line' (emu M."')
..m
.ke i ♦t•Jt 9.:...m n.lj
S.t� PW4rm Can.>.L It
tt ssaS.liu: ?...y

➢ Original pond sizing- based on "discrete settling" and
ignored flocculating behavior.
➢Discrete settling assumes "Stoke flow" behavior, valid for
influent TSS< 500 ppm.
➢Sizing based on discrete settlement yields "overflow " rate
and large surface area.
➢Actual TSS ranges from 6000 ppm < TSS < 20,000 ppm, so
should include flocculating effects.
➢Flocculating effects must be determined via "column
settling test"
➢Sizing based on combined discrete + floc based on
residence time, not area.
➢A smaller footprint can be justified if floc occurs, provided
geometry is correct

t2 !2 ti
Time
FIOURe? 7-1) Scffling colunui and isopercenzage settling eurvcs tar fivxu
lint ;unities. (Sourre- McWalf and Eckiv, Lttgitt:c.t�, 1991. Was!ewuter l ngs
aecri71g, arc 4 New York; McGraw -hill. Reprtduce<7 by permtssioi; of t1le
McGulw-Hill Compnnirs.1
Established test protocols by US Army corps of engineers
And by Metcalf & Eddy for flocculating sedimentation ponds

3 x 6" dia x 6' tall columns tested over a 14 day period at Enco-cary
WAIM.Utnfalme alf fen
"to,i
3 duplicate columns tested In parrallel, 6" dla a 6If long
Run tests per chart
4 umbidrty test levels I. diagram)
R enough sludge is present perform a %solids ten @ day ":a
Decant 3/4 of the water from all 3 tests and save bottom I/e of water/sludge midum
Place Mudge and water m]Mre Into 1 tube for settling
Perform a %solids test after 2 weeks
Send A Mudge bIX to progress Energy
M(I.g Metals, Turbidity, 1755
psi, temperature
3/a height
112 height
1/a height

M
2500
KIIIII]
1500
1000
500
If,
Column C
n
D
\ .1
� \ 1
1,
1 `
1 7 3 4 5 6 7 8 9 10 11 12 13
Time, hours 0=12 noon of 16 Dec 2008
— 1
— 0.75
----- 0.5
— ' - 0.25

��
. � ���, V � ��' � __ ,,.!
d
��� _ fdl
�.: � � ^-i... :A .. ..
.. .. ....
Y
(� ':t
3
N. ?.. '.�� L _e`II
'M1 ;q.
m �{ N
!1 rryrWH�

3000
2500
2000
z
Z' 1500
L.,
1000
500
0
Column C (Turbidity and TSS vs Time)
0 15 30 45 60 120 180 240 360 480 720 1080 1440 2160 2880 4170 4320 5760 7200
Time (min)
- 4 - 0.25 'f- 0.5 0.75 -X 1 -*- TSS — Poly. (TSS)
7000
A
5000
4000 -j
w
E
3000
2000
1000
0

pond influent pond effluent
flag
element
units
as rec'v
filtered avg
% reduct
Aluminum
ug/L
47100
72.23
99.847%
u,d
antimony
ug/L
68
6.80
ng
arsenic
ug/L
562
243.67
56.643%
barium
ug/L
938
411.50
56.130°%
berylium
ug/L
12.5
1.17
90.613%
boron
ug/L
74900
77266.67
0.000°%
u,d
cadmium
ug/L
6.1
1.55
74.536%
chromium
ug/L
28.1
1.00
96.441%
cobalt
ug/L
42.7
1.10
97.424%
copper
ug/L
113
443.50
ng
iron
ug/L
60500
42.80
99.929%
lead
ug/L
84.1
165.62
ng
manganese
ug/L
2550
867.17
65.993%
mercury
ug/L
500
7.04
98.591%
u
molybdenum
ug/L
2.5
2.77
ng
nickel
ug/L
166
105.50
36.446%
selenium
ug/L
4080
3353.33
17.810%
u,d
silver
ug/L
2
0.20
ng
u,d
thallium
ug/L
3.6
0.36
ng
vanadium
ug/L
111
1.40
98.739°%
zinc
ug/L
237
415.50
ng
COD
mg/L
750
305.00
59.333%
chloride
mg/L
4700
4683.33
0.355%
flouride
mg/L
70
9.67
86.190°%
pH
6.8
6.86
sulphate
mg/L
7400
1183.33
84.009°%
TDS
mg/L
15000
10000.00
33.333%
TSS
mg/L
6200
8.40
99.865°%
turbidity
NTU
2300
2.25
99.902%
Flag: u= below detectable limits
ignore
ignore
note: leak in column B+C columns implied tap = 1.0was dry and needed to sample from tap= 0.75

Final report from Enco Cary due on Friday 9 Jan 09

1. Pond sized by discrete settling is too conservative- yields excessive footprint
2. Flocculating behavior should be considered, implies a design based on residence time, not area
3.Very fast settlement allows for a small pond , if geometry is correct .
4. Some neutralization occurs , pH increases over time, this removes some metal ions, but not all
5. pond design features of inlet weir, outlet curtain + skimmer may improve small pond performance
6. add'I nuetralization can be obtained by addition of lime
7. add'I metals precipitation can be obtained by addition of metclear, TNT 20, Nalmet
8. Use of settling pond with neutralization implies high future cost of sludge disposal

Romanski, Autumn
From:
Sent:
To:
Subject:
lets discuss
cs
Smith, Danny
Tuesday, December 22, 2009 12:43 PM
Romanski, Autumn
FW: Progress SOC
Myemail has changed to dannv.smith@ncdenroov
**E-mail correspondence to and from this address maybe subject to the North Carolina Public Records Lawandmaybe disclosed to third
parties.
From: Manuel, Vanessa
Sent: Tuesday, December 22, 2009 12:02 PM
To: Smith, Danny
Subject: RE: Progress SOC
Hey Danny,
I finally got around to looking at this SOC. Paragraph la left me a little confuse when I initially read it (it also confused
another staff when she read it). I was also left asking "what about compliance now?" The way the latter part of the
paragraph reads, it is talking about future compliance ... well, what about compliance now? Are they complying now or
not? It might be a question others ask when they read it.
Paragraph ld, I would like to change the word "will' to "shall." The latter is more directive and more of a requirement.
Also need to add "of' between "constructing" and "new" in the 1" sentence.
In addition to paragraph 2b, need to add 2f to the stipulated penalty for failure to submit progress reports (page 4 of 5).
For these minor edits, I will incorporate the change. However, for paragraph la, let me know what you want. If you
want it to stand as is, then I will forward it on to Jeff & Matt for review.
-Vanessa
From: Smith, Danny
Sent: Monday, November 09, 2009 5:27 PM
To: Manuel, Vanessa
Cc: Romanski, Autumn
Subject: Progress SOC
Hey Vanessa!
Please see the attached SOC for Progress Energy... I believe they are good to go with this... Attached is the "Final SOC
draft" also attached is the draft that has "identified edits"... a version for you, so you know where the changer are
located... to help ease your review.
Anyway, you will notice there is no attachment A... The monitoring will required by letter from the RRO.
Please forward as appropriate.
Let me or autumn know if you have any questions
Thanks!
canny

My email has changed to dannv.smiMncdenrgov
• *E--mail correspondence to and from this address maybe subject to the North Carolina Public Records Lawandmaybe disclosed to third
Partin

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
November 16, 2009
Harry Sideris, Plant Manager i k7
Roxboro Steam Electric Plant k7
1700 Dunnaway Road J
Semora, NC 27343
Subject: Review of Progress Energy's "Roxboro Steam Electric Plant 2008 Environmental Monitoring Report,
August 2009", NPDES Permit NC0003425
Environmental Sciences Section staff have reviewed the document: "Roxboro Steam Electric Plant 2008 Environmental
Monitoring Report, August 2009" as it relates to NPDES Permit NC0003425 requirements A.(12) Temperature
Requirements and A.(13) Biological Monitoring. The report was received by the Environmental Sciences Section on
August 18, 2009. We apologize for the two month delay on communicating our concerns and comments back to you. Jeff
DeBerardinis, Debra Owen, and Bryn H. Tracy reviewed the sections on trace elements in fish, limnology, and fisheries,
respectively. The document fulfills the permit obligations for reporting the results of the annual biological monitoring.
However, we do have some concerns and comments. We would appreciate receiving written responses to the concerns
we have raised.
Concerns
1. The surface water temperature at Station 2B on August 5, 2008 was 32.2eC (Appendix 1). This station, located in
the mid- to upper reach of the North Hyco Creek Arm, is well upstream and outside the designated mixing zone
as described in A.(12)a of the NPDES permit. This temperature exceeded the state water quality standard of
320C for Piedmont lakes. Although natural conditions (i.e., late summer air temperature and solar radiation) may
have been the most likely source of this increased temperature, can power plant operations be ruled out as a
factor? These exceedances were also measured in August 2006 and August 2007. In addition, specific
conductance at Station 2B seems to be strongly influenced by the plant and is much greater than that in the South
Hyco Creek Arm (Appendices 1 and 2). And finally, although it is understandable why there are fewer fish in
areas influenced by the plant's thermal discharge than in areas away from the discharge (i.e., Transacts 4 and 6
vs. Transacts 1 and 3) (Appendix 6), the number of fish collected at Transact 2 in the North Hyco Arm is much
fewer than the number collected at the other two "control" transects (Transacts 1 and 3) and more similar to the
discharge site (Transact 4).
The temperature exceedances and the evidence of elevated specific conductance, combined with the difference
in the number of fish collected in the North Hyco Arm in contrast to the South Hyco Arm, suggests the possibility
of more than just natural spatial and temporal differences. Overall, it seems that the effects of the plant's thermal
discharge and other permitted effluents may possibly extend beyond the mixing zone as described in A.(12)a of
the NPDES permit. We would like for you to explore if these measurements are due to natural variability or if
these measurements indicate a plant impact far outside the designated mixing zone.
2. The copper concentration at Station 3B in the South Hyco Arm in June (8.3 pg/L) was greater than the state water
quality standard (7.0 pg/L). Copper concentrations at this station in other months in 2008 were less than the
standard, suggesting that the June concentration was not due to ongoing contamination (Appendix 3). However,
elevated copper concentrations have been previously measured in 2005, 2006, and 2007 at various stations
throughout the reservoir. Explanations or enhanced interpretations of the copper concentrations in the reservoir
should be further evaluated.
1621 Mail Service Center, Raleigh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Raleigh, North Carolina 27607
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet htm1m2o.enr.sta1e.nc.us/esW
oe
NCarolina
Naturally
An Equal Opportunity 1 Affirmative Action Employer

Harry Sidens
November 16, 2009
Page 2
Comments and Observations
1. In the future, please include more historical data for all programs in the figures, tables, and analyses to compare
pre -and post- operations of the Flue Gas Desulfurization system and to characterize the extent and impact of the
thermal discharge.
2. In the future, please send one copy of the annual monitoring report to DWQ's Environmental Sciences Section, as
has been the customary practice, and one copy to Mr. Danny Smith, Surface Water Protection Supervisor, DWQ
Raleigh Regional Office, 3800 Barrett Drive, Raleigh, NC 27609.
3. In the future, in addition to sending one copy of the annual monitoring report to Mr. Danny Smith, please submit
all the water quality, water chemistry, and trace elements in fish and sediment data in electronic format (Excel®) to
Ms Autumn Romanski (Autumn. Romanski(ancdenr.aovl, Raleigh Regional Office, 3800 Barrett Drive, Raleigh,
NC 27609.
4. The fish assemblage in this multi -purpose reservoir is comprised of 15 indigenous and 10 nonindigenous species.
The nonindigenous species have been introduced for one reason or another either accidentally or to manage the
reservoir's fishery and aquatic since impoundment of the Hyco River. In 2008 nonindigenous species made up
76% of the total number and 30% of the total weight of all fish collected (Appendix 5). Although the fish
community is far from being what one normally considers indigenous, §316(a) of the Clean Water Act does allow
for "... Such a community may include historically non-native species introduced in connection with a program of
wildlife management and species whose presence or abundance results from substantial, irreversible
environmental modification" (40CFR 125.71(c).
5. Trace Elements in Fish
a. All concentrations of heavy metals were well below the criteria set by North Carolina Department of
Health and Human Services (NCDHHS).
b. Arsenic concentrations continued to be low and well below the US EPA screening value for recreational
fishermen (1.2 pg/g).
c. Cadmium concentrations were less than the laboratory reporting limit, and therefore, well below the US
EPA screening values for recreational and subsistence fishermen, 4.0 and 0.491 pg/g, respectively.
d. Copper concentrations were reported as: "... relatively low during the observation period. There are no
specific federal or state screening criterion for copper in fish tissue.
e. Most total mercury concentrations were less than the laboratory reporting limit and all concentrations
were well below the NCDHHS criterion of 0.4 pg/g.
f. Selenium concentrations continued to be greatest at Transact 4. However, all concentrations were well
below the NCDHHS criterion of 10 pg/g.
If you have any questions, please do not hesitate to contact me or my staff.
Yours truly,
Jay Sau er
Acting Chief, Environmental Sciences Section
cc: Robert L. Curry, NCWRC
Jeff DeBerardinis, Environmental Sciences Section
E. Shannon Langley, Progress Energy
Debra Owen, Environmental Sciences Section
Jeff Poupart, Surface Water Protection Section
Danny Smith, Raleigh Regional Office
Bryn H. Tracy, Environmental Sciences Section

NORTH CAROLINA � r
ENVIRONMENTAL MANAGEMENT COMMISSION
COUNTY OF PERSON
IN THE MATTER OF
NORTH CAROLINA ) SPECIAL ORDER BY CONSENT
PERMIT NUMBER NC0003425 held by ) EMC SOC WQ NO. 509-007
CAROLINA POWER AND LIGHT COMPANY D/B/A )
PROGRESS ENERGY CAROLINAS, INC. )
Pursuant to provisions of Northth Car -Carolina General Statutes (G.S.) 143-215.2, this Special Order---- Fennateed: Tab stops: 3.63•, Left
by Consent is entered into by Carolina Power and Light Company D/B/A Progress Energy Carolinas,
Inc., hereinafter referred to as Progress Energy, and the North Carolina Environmental Management
Commission, an agency of the State of North Carolina created by G.S. 143E-282, and herein after
referred to as the Commission:
1. Progress Energy and the Commission hereby stipulate the following:
a. Progress Energy holds North Carolina NPDES permit number NC0003425 for operation of
an existing wastewater treatment works and for making an outlet from there for treated
wastewater to Hyco Lake, classified as WS-V and B waters of this state in the Roanoke
River basin, but has experienced structural signs of stress within the plant's existing
(West) Flue Gas Desulfurization (FGD) Wastewater Gypsum Settling Pond. In addition to
the efforts made by Progress Energy, this shall affect future compliance by requiring
preparation and implementation of wastewater treatment plant (WWTP) repairs and
upgrades, and collecting additional sampling and monitoring data of the effluent waste
streams as requested by the NC Division of Water Quality Raleigh Regional Office Surface
Water Protection letter dated November 6, 2009.
b. Progress Energy installed wet limestone, forced oxidation Flue gas desulfurization (FGD)
scrubbers on all four operating units at the Roxboro Steam Electric Plant in response to
requirements from the State of North Carolina under the clean smokestacks legislation.
Accordingly, Progress Energy installed a FGD Wastewater Gypsum Settling Pond, a
bioreactor (a biological treatment unit), and a FGD Flush Pond to treat wastewater
generated by the recently added FGD scrubbers.
c. Progress Energy has deconstructed the existing FGD Flush Pond and lowered the
operational level of the existing (West) FGD Wastewater Gypsum Settling Pond to a level
where structural concerns and signs of stress are minimized.
d. Progress Energy will fund the planning, designing, and constructing new or improved
wastewater treatment and disposal facilities which, once constructed and operated, will be
sufficient to adequately convey and treat wastewater presently being discharged, to the
extent that Progress Energy will be able to comply with the NPDES permit requirements
and North Carolina rules and regulations.

Progress Energy Carolinas, Inc.
EMC SOC WQ NO. 5D9-007
e. Since this special order is by consent, neither party will file a petition for a contested case
or for judicial review concerning its terms.
2. Progress Energy hereby agrees to do the following:
a. Undertake the following activities in accordance with the indicated time schedule
(1) FGD Flush Pond. Complete construction of the FGD Flush Pond on or before
November 7, 2009.
(2) New FGD Wastewater Gypsum Settling Pond. Begin construction of the new FGD
Wastewater Gypsum Settling Pond on or before December 22, 2009 and
complete construction on or before May 31, 2011.
(3) Existing (West) FGD Wastewater Gypsum Settling Pond. If necessary, begin
the refurbishment of the existing (West) FGD Wastewater Settling Pond within 45
days of completion of the new FGD Wastewater Gypsum Settling Pond. If Progress
Energy's decision does not include rebuilding the existing pond, then the pond will
be modified in a manner to prevent continued water accumulation. This includes
process water, stormwater, and water from precipitation.
If necessary to rebuild the existing (West) FGD Wastewater Gypsum Settling Pond,
complete construction of the existing (West) FGD Wastewater Gypsum Settling
Pond within 270 days of beginning construction or on or before May 31, 2011,
whichever is later.
Beginning construction shall be defined as mobilizing contractors for specified work
and completing construction shall be defined as completing a signed engineer's
certificate of completion.
b. Quarterly Progress Reports. Progress Energy will submit quarterly progress reports
detailing the work and activities undertaken with regards to schedules and activities
included in this SOC. The reports are to be submitted as follows: one copy must be mailed
to the Raleigh Regional Supervisor, Division of Water Quality, Surface Water Protection
Section, 1628 Mail Service Center, Raleigh, NC 27699-1628, and one copy must be mailed
to the Point Source Branch, Eastern NPDES Program, Division of Water Quality, 1617 Mail
Service Center, Raleigh, NC 27699-1617. The quarterly reports are due in each respective
office no later than January 311, April 30'", July 31' and October 31� for the duration of
this order.
c. Final Written Account. Progress Energy must provide a final written account of findings
and results, specifically using both qualified and statistically valid sample data (the
additional sampling and monitoring data collected by the letters dated March 4, 2008 and
November 6, 2009 through to the end of this SOC).
This written account of findings and results shall provide a demonstration of any need for
additional control or treatment of process or industrial waste stream contaminants that
may directly cause or contribute to exceedence of applicable water quality standards in
Hyco Lake.
Page 2 of 5

Progress Energy Carolinas, Inc
EMC SOC WQ NO. S09-007
If Progress Energy's final account of findings and results reveal that process or industrial
waste stream contaminants directly cause or contribute to exceedence of applicable water
quality standards in Hyco Lake, then Progress Energy must also include proposals for
additional modifications to the wastewater treatment units. This proposal for modification
must minimally address the suitability of pH adjustment, clarification, chemical
precipitation, other appropriate treatment options, and provide a respective
implementation schedule with dates.
The final written account of findings and results must be submitted to the Raleigh Regional
Office on or before August 1, 2011.
d. In addition to the account of Findings and results required by paragraph 2c above, other
sampling and monitoring results obtained utilizing labs not certified in North Carolina and
altemative lab methods not currently certified by the EPA may also be reported and used
in the final written account.
e. Progress Energy will also provide a presentation (e.g. PowerPoint /oral presentation) of the
final written account of findings and results to the North Carolina Division of Water Quality,
Raleigh Regional Office on or before August 31, 2011.
The presentation must be given by Progress Energy personnel; however, Progress Energy
can utilize evaluations, results, and findings of consultants, as appropriate. Progress
Energy must address the existing wastewater treatment system, any new/proposed
changes to the existing wastewater system, and Progress Energy's position on process
wastewaters or industrial waste contaminants that may directly cause or contribute to
exceedence of applicable water quality standards in Hyco Lake.
f. No later than fourteen (14) calendar days after any date identified for accomplishment of
any activity listed in paragraph 2 above, submit to the Raleigh regional office of the
division of water quality written notice of compliance (including the date compliance was
achieved along with supporting documentation if applicable) or noncompliance therewith.
In the case of noncompliance, the notice shall include a statement of the reason(s) for
noncompliance, remedial action(s) taken, and a statement identifying the extent to which
subsequent dates or times for accomplishment of listed activities may be affected.
Scheduled deadlines affected by events of noncompliance shall be adjusted to reflect such
periods of delay.
3. Progress Energy agrees to pay DWQ, by check payable to the North Carolina Department of
Environment and Natural Resources, stipulated penalties according to the following schedule for
failure to meet the deadline set out in paragraph 2.
Failure to meet a schedule date listed in paragraph 2a; $1,000 per day.
Failure to submit a final written account on or before $5,000 per day
August 1, 2011, as required by paragraph 2c and/or
failure to provide a presentation of the final written
account of findings and results on or before August 31,
2011, as required by paragraph 2e;
Page 3 of 5

Progress Energy Carolinas, Inc.
EMC SOC WQ NO. 509-007
Failure to submit progress reports as required by $1,000 for the first violation;
paragraph 2b; penalty doubles with each
subsequent assessment for late
reports.
4. Progress Energy and the commission agree that the stipulated penalties are not
due if Progress Energy satisfies the Division of Water Quality that noncompliance was caused
solely by:
a. An act of God;
b. An act of war;
c. An intentional act or omission of a third -party, but this defense shall not be available if the act
or omission is that of an employee or agent of the defendant or If the act or omission occurs
in connection with a contractual relationship with Progress Energy;
d. An extraordinary event beyond Progress Energy's control. Contractor delays or failure to
obtain funding will not be considered as events beyond Progress Energy's control;
or
e. Any combination of the above causes.
Failure within 30 days of receipt of written demand to pay the penalties, or challenge them by a
contested case petition pursuant to G.S. 150 B-23, will be grounds for a collection action, which
the Attorney General is thereby authorized to initiate. The only issue in such an action will be
whether the 30 days has elapsed.
5. Noncompliance with the terms of the special order by consent is subject to enforcement action in
addition to the above stipulations, including injunctive relief pursuant to G.S. 143-215.6.C.
6. This special order by consent and any terms or conditions contained herein, hereby supersede any
and all previous Special Orders, Enforcement Compliance Schedules, Correspondence from the
Raleigh Regional Office, with the exception of the sampling and monitoring requested through the
letters dated March 4, 2008 and November 6, 2009, terms, and conditions contained therein.
7. Full compliance with the special order by consent will resolve existing FGD Wastewater Gypsum
Settling Pond and FGD Flush Pond issues identified in the March 4, 2008, letter from the North
Carolina Division of Water Quality to Progress Energy. This Special Order by Consent may be
amended provided Progress Energy has made good faith efforts to secure funding, complete all
construction, and achieve compliance within the dates specified.
S. Progress Energy, upon signature of this Special Order by Consent, will be expected to
comply with all schedule dates, terms, and conditions of this document.
Page 4 of 5

Progress Energy Carolinas, Inc.
EMC SOC WQ NO. S09-007
This Special Order by Consent shall expire on September 30, 2011.
For Progress Energy Carolinas, Inc.:
Name of Signing Official
Signature Date
For the North Carolina Environmental Management Commission:
Chair of the Commission Date
Page 5 of 5

i
_ Progress Energy
File No.: 12520
r.
Mr. Danny Smith
Division of Water Quality R
N. C. Department of Environment and Natural Resources1
1628 Mail Service Center
Raleigh, NC 27699-1628
Subject: Roxboro Steam Electric Plant
NPDES Permit No. NC0003425
Pyrite line release
DWQ Incident #: 200903009
Person County
Dear Mr. Smith:
December 10, 2009
On December 7, 2009, Shannon Langley of Progress Energy, made verbal notification of a
release from the Unit 2 pyrite line at the subject facility to Dave Parnell of your office. Pyrites
are any material that is rejected by the plants coal pulverizers. They include rocks and gravel,
bits of rejected coal, iron, etc and are typically disposed of in the plants ash pond in accordance
with our NPDES permit. The verbal notification was made as an "unusual circumstance" as
required by 15A NCAC 2B 0.506(a)(2)(B). As required by 15A NCAC 2B 0.506(a)(3), this
letter fulfills the five day written letter requirement.
This break occurred along the pipe corridor between the plant and ash pond. The water released
flowed overland and into an area in the eastern side of the heated water discharge mixing area
(part of the plants wastewater treatment). All of the solid material was contained on site with no
noted impacts at the plants wastewater outfall to Hyco Lake (outfa11003).
Upon discovery of the failure of the pyrite line, plant staff shut down flows to the line and began
implementing repairs. As of the date of this letter, repairs have been completed. An investigation
of the cause of the failure is still underway. Plant staff implemented a cleanup operation
utilizing the facility's Vacuum truck and onsite contractor resources to recover Pyrite material
and dispose of it in the plant's ash pond.
This line is scheduled for replacement in the next two years. Given this recent event, I am
evaluating options available to complete the replacement of this line sooner.
If you have any questions concerning this submittal, please contact Shannon Langley at (919)
546-2439.
Progress Energy Carolinas, Inc.
Roxllero Steam Plant
1700 Ounnaway Road
Semora. NC 27343

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.
Respectfully,
Harry Sideris
Plant Manager
Roxboro Steam Electric Plant
HS/sl
Cc Billy Milam
Robert Howard
Shannon Langley — PEB4

`� Progress Energy
File No.: 12520
Mr. Danny Smith
Division of Water Quality
N. C. Department of Environment and Natural Resources
1628 Mail Service Center
Raleigh, NC 27699-1628
Subject: Roxboro Steam Electric Plant
NPDES Permit No. NC0003425
Pyrite line release
DWQ Incident #: 200903009
Person County
Dear Mr. Smith:
December 10, 2009
On December 7, 2009, Shannon Langley of Progress Energy, made verbal notification of a
release from the Unit 2 pyrite line at the subject facility to Dave Parnell of your office. Pyrites
are any material that is rejected by the plants coal pulverizers. They include rocks and gravel,
bits of rejected coal, iron, etc and are typically disposed of in the plants ash pond in accordance
with our NPDES permit. The verbal notification was made as an "unusual circumstance" as
required by 15A NCAC 2B 0.506(a)(2)(B). As required by 15A NCAC 2B 0.506(a)(3), this
letter fulfills the five day written letter requirement.
This break occurred along the pipe corridor between the plant and ash pond. The water released
flowed overland and into an area in the eastern side of the heated water discharge mixing area
(part of the plants wastewater treatment). All of the solid material was contained on site with no
noted impacts at the plants wastewater outfall to Hyco Lake (outfall 003).
Upon discovery of the failure of the pyrite line, plant staff shut down flows to the line and began
implementing repairs. As of the date of this letter, repairs have been completed. An investigation
of the cause of the failure is still underway. Plant staff implemented a cleanup operation
utilizing the facility's Vacuum truck and onsite contractor resources to recover Pyrite material
and dispose of it in the plant's ash pond.
This line is scheduled for replacement in the next two years. Given this recent event, I am
evaluating options available to complete the replacement of this line sooner.
If you have any questions concerning this submittal, please contact Shannon Langley at (919)
546-2439.
Progress Energy Carolinas, Inc.
Roxboro Steam Plan
1700 Dunaway Rnnd
Senora, NC 27343

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 property 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 offines and imprisonment
for knowing violations.
Respectfully, ^_
Harry Sideris
Plant Manager
Roxboro Steam Electric Plant
HS/sl
Cc Billy Milam
Robert Howard
Shannon Langley — PEB4

Romanski, Autumn
From: Langley, Shannon [Shannon. [e-mail]]
Sent: Thursday, December 10, 2009 10:29 AM
To: Romanski, Autumn
Cc: Newcomb, Dana
Subject: RE: Repairs and Monitoring Letter Dated November 6 and November 13, 2009
Thanks Autumn.
I'll forward this to Dana Newcomb so she can attach it to her copy of the letter.
Shannon
E. Shannon LangCey
Senior Environmental Specialist
Environmental Services Section - Carolinas
Progress Energy Carolinas, Inc.
[phone] (public)
8-770-2439 (voicenet)
`m Progress Energy
From: Romanski, Autumn [mailto:[e-mail]]
Sent: Wednesday, December 09, 2009 4:47 PM
To: Langley, Shannon
Cc: Smith, Danny; Sideris, Harry
Subject: Re: Repairs and Monitoring Letter Dated November 6 and November 13, 2009
Shannon,
This e-mail is to confirm our discussion over the phone on November 16, 2009 with regards to the Repairs and
Monitoring letter(s).
The lab method requested for Strontium (Sr) in the monitoring table was incorrect. Please use lab method
200.7 as described by the EPA for Strontium.
Thank you,
Autumn
Environmental Senior Specialist
Division of Water Quality
Surface Water Protection
3800 Barrett Drive
Raleigh, NC 27609
http://h2o.enr.state.nc.us/
Office: 919-791-4247

I
Please note my e-mail address has changed:
E-Mail: autumn.romanski Cdncdenr.gov
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.

Romanski, Autumn
From: Parnell, David
Sent: Monday, December 07, 2009 5:18 PM
To: Parnell, David; Hall, Mandy; Menefee-dunn, Barbara; Herzberg, Barry; Zhang, Cheng; Smith,
Danny; Owen, Ed; Garrett, Judy; Witherspoon, Lauren; Wiggins, Mack; Richmond, Martin;
Hayes, Mitch; Nisely, Myrl; Landry, Natalie; Romanski, Autumn; Webb, Vicki
Subject: Progress Energy Roxboro Steam Electric Power Plant Pyrite bypass
Incident # 200903009 - 108,000 gallons of Pyrite (51 cubic yards of the material) from ruptured line to ash pond.
Contained within wastewater treatment system, surface water not impacted. Cleanup underway.

Procetture for Spills (Not SSO)
Emergency Fish Kill Non-compliance Repting Other Spill(non-sewage) SSO Upset
Date: 2 L Start Time: ( 30 P
County: er-s o n
rting Person: Circle if Anonymous, or Address:
First S an 11 01,1 Ci
fate
Last L4 n 9 �e ZI
Phone 9 f 9 6 46 . z 4 39
ition of Incident P-o x 6 or o _ aro q re s g
=/State/Zip
FObservation of Incident:
PLiur-r fyr
Action Taken: t✓ h f C r-r w ci 5 n c c �IQ Ir
Surface Water Impacted? Y N
Waterbody
[Rept Taken by: P 0.n
Phone: -79 ( 6 O
Date/Time: 1 2 .7. 0 9
Notified by what method? I t;¢ O Am
Cell/Pager `�
E h a rq /"
N L
Directions:
BIMS Incid No. 20 0,)O 3 00
M S Comment/Findings: ( Dig 1000 a-1 T F r( I
ev.c�di. l Contakr'r%eL-ft -kIr'n 44.t
Well within 1500 ft? Y
mpacted? Y
Passed to Other RO Contact: A 1..-4---v ^ti r, R,-o ,, am /G �
Phone: 79 t • 4-3 1-1
Date/Time: 12 .7 , 0 9
Notified by what method?
2. Enter into BIMS
Log into the public portal version of BIMS (http://bims.enr.state.nc.us:7001/Welwme.do)
Go to Tasks, Incident, Enter Incident
For Spills, check the type of spill box, fill in the Incident report, record the incident number and close.

,:earch+
Page 1 of 2
Bypass/Upset 24 Hour
Details Details
5 Day Details 10 Day Questions Agencies
Details
❑+K
Permit: NC0003425 Incident Nu
Facility Name : Roxboro Steam Electric Power Plant C
Owner: Carolina Power and Light Co DBA Progress Energy Carolinas Inc R
City: Roxboro
24 Hours
*Bypass/Upset Start Date/Time: 12/06/2009
01:30 pm
Report Received: 12/07/2009
*Did Bypass/Upset reach Surface Water? Yes • No Unknown
*Fish Killed? Yes No • Unknown
Other WaterBody:
5 Day Details
*Bypass/Upset Start Date/time:
*End Date/Time-
Report Received: F-
*Did Bypass/Upset reach Surface Water? Yes No Unknown
*Fish Killed? Yes No Unknown
Other WaterBody:
Regional Contact: Romanski, Autumn H
County : ---Select Value ---
*Location of Units being Bypassed?
pyrites line to ash pond
Comments:
*Est. Volume in gallons: 10l
Report Entered: 12/
Est. Volume: IV
Est. Fish Killed? I
Duration: F
*Est. Volume in gallons: F
Report Entered: I
Est. Volume: F
Est. Fish Killed? I
Date/Time (mm/dd/yyyy hh:mm am):
City : Roxboro
;V
Specific Cause (check all that Apply)
❑ Severe Natural Condition ❑ Vandalism ❑ Pump Station Equipment Failure
❑ Power outage Other (Please explain in Part II) ❑ For DWQ Use Only:
r
http://bims.enr.state.nc.us:7001/createBypass.do 12/7/2009

search ,
Page 2 of 2
Construction ❑ Maintenance ❑ Upsets
Finish Cancel
3.
http://bims.enr.state.nc.us:700 1 /createBypass.do
12/7/2009

Pr
ROXBORO POWER STATION - Semora, NC
Ash Pond
FGD Settling Pond
FGD Flush Pond
INFORMATION REQUEST RESPONSE RESPONSE RESPONSE
1. Relative to the National
Inventory of Dams criteria for
High, Significant, Low, or Less -
than -Low Hazard Potential, please
E rovide the potential hazard rating
for each management unit and
indicate who established the rating,
what the basis of the rating is, and
what federal or state agency
regulates the unit(s). If the unit(s)
does not have a rating, please note
that fact.
2. What year was each
management unit commissioned
and expanded?
Hazard Classification —
Significant. A professional
engineering firm established the
rating based on USCOE
guidelines and NCDENR
Regulations. The unit is under
the purview of the North
Carolina Utilities Commission.
The original pond was
commissioned in 1973. The
dam was raised in 1986.
Using the National Inventory of Using the National Inventory of
Dams criteria we rate the unit Dams criteria we rate the unit
Significant.
In 2008 a FGD settling pond
was constructed within the
boundary of the ash pond.
Progress Energy Roxboro Power Station
Significant.
In 2008 a FGD flush pond was
constructed within the boundary
of the ash pond.

Ash Pond
FGD Settling Pond
FGD Flush Pond
INFORMATION REQUEST RESPONSE RESPONSE RESPONSE
3. What materials are temporarily The unit contains fly ash, bottom The unit contains Flue Gas The unit contains Flue Gas
or permanently contained in the ash, boiler slag, Other- ash Desulfurization Desulfurization
unit? Use the following categories sluice water, storm water, residuals/wastewater. residuals/wastewater from
to respond to this question: (1) fly categorical low volume. backflushing the wastewater
ash; (2) bottom ash; (3) boiler slag; treatment unit.
(4) flue gas emission control
*Piduals; (5) other. If the
ranagement unit contains more
than one type of material, please
identify all that apply. Also, if you
identify "other," please specify the
other types of materials that are
temporarily or permanently
contained in the unit(s).
4. Was the management unit(s)
designed by a Professional
Engineer? Is or was the
construction of the waste
management unit(s) under the
.,upervision of a Professional
Engineer? Is inspection and
monitoring of the safety of the
waste management unit(s) under
the supervision of a Professional
Engineer?
The unit was designed by a
professional engineer. The
construction was under the
The unit was designed by a
professional engineer. The
construction was under the
The unit was designed by a
professional engineer. The
construction was under the
supervision of a professional supervision of a professional supervision of a professional
engineer. Some inspections arc engineer. Current inspections engineer. The unit is currently de -
under the supervision of a are under the supervision of a constructed and will undergo a
professional engineer, some are professional engineer. The rebuild in near future.
not. See response to item 5. berms are inspected five to
below. seven days per week. Attached
is an example inspection form.
Progress Energy R,.,.uoro Power Station 2

INFORMATION REQUEST
5. When did the company last
assess or evaluate the safety (i.e.,
structural integrity) of the
management unit(s)? Briefly
describe the credentials of those
conducting the structural integrity
assessments/evaluations. Identify
actions taken or planned by facility
personnel as a result of these
assessments or evaluations. If
corrective actions were taken,
briefly describe the credentials of
those performing the corrective
actions, whether they were
company employees or contractors.
If the company plans an assessment
or evaluation in the future, when is
it expected to occur?
Ash Pond FGD Settling Pond FGD Flush Pond
RESPONSE
Monthl inspections that
include visual inspections and
data gathering to detect any
problems at an early stage of
development are conducted by
plant personnel. Attached is a
copy of the most recent
inspection report available.
The company last conducted a
comprehensive inspection in
2008. The engineering firms
that conducted the inspections
have expertise in geotechnical
and civil engineering. Actions
taken: lower the operating level
RESPONSE
The company last conducted a
comprehensive inspection in
2008. The engineering firms that
conducted the inspections have
expertise in geotechnical and
civil engineering. Actions taken: .
take the unit off line, de -
of the pond. It was further construct it and reconstruct with
Actions or planned: None taken determined that the pond should different liner. These activities
or planned. be taken off line and possibly are underway.
rebuilt using a different lining.
A new pond located adjacent to
the existing pond is under
design.
Progress Energy Roxboro Power Station

Ash Pond
FGD Settling Pond
FGD Flush Pond
INFORMATION REQUEST RESPONSE
RESPONSE
RESPONSE
Annual inspections are
This unit will be incorporated
This unit will be incorporated
conducted by a third -party
into the company's procedure
into the company's procedure for
professional engineering
for a weekly/monthly, annual,
a weekly/monthly, annual, and
contractor. The engineering
and five year inspection
five year inspection program.
firms that conduct the
program.
inspections have expertise in
geotechnical and civil
engineering. Attached is the
most recent annual inspection
report which is also the five year
report.
Progress Energy R,...joro Power Station

INFORMATION F
Comprehensive
Ash Pond FGD Settling Pond
RESPONSE RESPONSE
are conducted by a third -party professional
engineering contractor. The engineering firms that conduct the inspections have
expertise in geotechnical and civil engineering. Attached is the most recent
comprehensive inspection dated 2008. Actions taken or planned: EMBANKMENT
STRUCTURES - Drain outlet channels at the toe of the dam will require regular
maintenance to clear vegetation and sediment. This should be done every two years.
Continue vegetation control program. Continue observation at east end of dam where
seepage has been observed on occasion. Place rip rap where needed to retard erosion.
This unit will be
into the company's procedure
for a weekly/monthly, annual,
and five year inspection
program.
FGD Flush Pond
RESPONSE
This unit will be incorporated
into the company's procedure for
a weekly/monthly, annual, and
five year inspection program.
Progress Energy Roxboro Power Station

Ash Pond FGD Settling Pond FGD Flush Pond
INFORMATION REQUEST RESPONSE RESPONSE RESPONSE
6. When did a State or a Federal The North Carolina Utilities In 2008 a state dam safety In 2008 a state dam safety
regulatory official last inspect or
evaluate the safety (structural
integrity) of the management
unit(s)? If you are aware of a
planned state or federal inspection
or evaluation in the future, when is
it expected to occur? Please
identify the Federal or State
regulatory agency or department
which conducted or is planning the
inspection or evaluation. Please
provide a copy of the most recent
official inspection report or
evaluation.
7. Have assessments or evaluations,
or inspections conducted by State
or Federal regulatory officials
44 conducted within the past year
uncovered a safety issue(s) with the
management unit(s), and, if so,
describe the actions that have been
or are being taken to deal with the
issue or issues. Please provide any
documentation that you have for
these actions.
Commission requires a five year inspector visited the site and
inspection report. We are not
aware of any planned
inspections by state or federal
officials. Refer to the five year
report submitted in response to
item 5 above for the most recent
official report.
There have been no inspections
conducted by state or federal
official that evaluated the
structural integrity other than a
visual observation by NPDES
inspectors. There have been no
follow-up actions.
concurred with the company
findings. The company is not
aware of any planned state or
federal inspections in the future.
A copy of the state's inspection
report is attached.
Refer to item five and six
above.
Progress Energy ku.00ro Power Station
inspector visited the site and
concurred with the company
findings. The company is not
aware of any planned state or
federal inspections in the future.
A copy of the state's inspection
report is attached.
Refer to item five and six above.

Ash Pond FGD Settling Pond FGD Flush Pond
INFORMATION REQUEST
RESPONSE
RESPONSE
RESPONSE
8. What is the surface area (acres)
The surface area is
The surface area is
the surface area is
and total storage capacity of each of
approximately 240 acres. The
approximately 16.6 acres. The
approximately 3 acres. The total
the management units? What is the
total storage capacity is
total storage capacity is
storage capacity is approximately
volume of materials currently
approximately 4,800 acre-feet.
approximately 419.5 acre-feet.
53 acre-feet. No material is
stored in each of the management
The volume of material currently The volume of material
currently stored in the unit. The
unit(s). Please provide the date that
the volume measurement was
taken. Please provide the
maximum height of the
management unit(s). The basis for
determining maximum height is
explained later in this Enclosure.
9. Please provide a brief history of
known spills or unpermitted
releases from the unit within the
last ten years, whether or not these
were reported to State or federal
regulatory agencies. For purposes
of this question, please include only
releases to surface water or to the
land (do not include releases to
groundwater).
stored is approximately 4,526 (wastewater) currently stored is maximum height is 33 feet.
acre-feet and was estimated in approximately 103 acre-feet.and
March 2007. The maximum
height is 70 feet.
was determined on March 19,
2009 The maximum height is 32
feet.
There have been no known spills 2008 -Wastewater from the unit 2008 - Pond dike experienced a
or releases was diverted to the adjacent ash breach with contents being
pond for a two week period in released to adjacent ash pond.
order to lower the operating Incident was reported to state
level. This activity was reported regulatory agency.
to the state regulatory agency.
Progress Energy Roxboro Power Station

Ash Pond FGD Settling Pond
FGD Flush Pond
INFORMATION REQUEST RESPONSE RESPONSE RESPONSE
10. Please identify all current legal
owner(s) and operator(s) at the
facility.
The Roxboro Power Station The Roxboro Power Station
consists of four generation units. consists of four generation
Units 1, 2, & 3 are owned by
Carolina Power & Light
Company d/b/a Progress Energy
Carolinas, Inc. Unit 4 has
12.94% ownership by the North
Carolina Eastern Municipal
Power Agency (NCEMPA).
Roxboro Common has 3.77%
ownership by the NCEMPA.
The Roxboro Power Station
consists of four generation units.
units. Units 1, 2, & 3 are owned Units 1, 2, & 3 are owned by
by Carolina Power & Light
Company d/b/a Progress Energy
Carolinas, Inc. Unit 4 has
12.94% ownership by the North
Carolina Eastern Municipal
Power Agency (NCEMPA).
Roxboro Common has 3.77%
ownership by the NCEMPA.
Carolina Power & Light
Company d/b/a Progress Energy
Carolinas, Inc. Unit 4 has
12.94% ownership by the North
Carolina Eastern Municipal
Power Agency (NCEMPA).
Roxboro Common has 3.77%
ownership by the NCEMPA.
Progress Energy R,.,,ioro Power Station

Hall, Mandy
From:
Pugh, James L.
Sent:
Friday, November 06, 2009 11:19 AM
To:
Hall, Mandy
Subject:
FW: Draft of Minor Modifications to Progress Energy's Mayo Plant -Question for TACU
Attachments:
image001.1pg
Mandy
What is your thoughts on this
***Please note new email address: [e-mail]***
James L. Pugh, Extension Education & Training Specialist
NCDWQ, Technical Assistance and Certification Unit
1618 Mail Service Center
Raleigh, NC 27699-1618
[phone] x341
[phone] Fax
[e-mail]
http://h2o.enr.state.nc.us/tacu/
E-mail correspondence to and from this address may be subject to the North Carolina
Public Records Law and may be disclosed to third parties.
From: Romanski, Autumn
Sent: Monday, November 02, 2009 4:33 PM
To: Pugh, James L.
Subject: FW: Draft of Minor Modifications to Progress Energy's Mayo Plant -Question for TACU
James,
checking back in on the Roxboro Plant classification in particular.
I received an inspection response from the Roxboro Plant with a comment that they do not believe a reclassification is
appropriate. I believe we have no choice by definition (complexity of system) which was the reason I recommended the
re-classification to begin with i.e.
(b) Any water pollution control system that utiM1zes a primarily chemical process to treat wastewaters, inducing those systems whose treatment processes are augmented try physical
processes, is classified as a Grade 11 Physica/Chemical Water Pollution Control System. Any reverse osmosis, electrodlalysis, and1SA NCAC 08G .0302 CLASSIFICATION OF BIOLOGICAL
WATER POLLUTION CONTROL TREATMENT SYSTEMS
ultrafiltration system is classified as a Grade II Physical/Chemical Water Pollution Control System.
They argue that the system is to treat intake water, not wastewater, but their intake water receives the NPDES
wastewater discharge of the plant which has levels of constituents that are driving the reason they must treat it with an
RO and the reason the demin's are fouling and inadequate. The wastewater RO rejects will go to the ash pond
wastewater treatment settling pond and then out the final NPDES outfall of the lake, then the lake water comes back in
the intake canal to be used by the plant again.
I am not sure what comes into play "with regards to classifying", so I am just checking in with you again, since I
understand the plant does not want a reclassification.
Any thoughts on where this is going?

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
November 16, 2009
Harry Sideris, Plant Manager I1119
Roxboro Steam Electric Plant
1700 Dunnaway Road -J
Semora, NC 27343
Subject: Review of Progress Energy's "Roxboro Steam Electric Plant 2008 Environmental Monitoring Report,
August 2009", NPDES Permit NC0003425
Environmental Sciences Section staff have reviewed the document: "Roxboro Steam Electric Plant 2008 Environmental
Monitoring Report, August 2009" as it relates to NPDES Permit NC0003425 requirements A.(12) Temperature
Requirements and A.(13) Biological Monitoring. The report was received by the Environmental Sciences Section on
August 18, 2009. We apologize for the two month delay on communicating our concerns and comments back to you. Jeff
DeBerardinis, Debra Owen, and Bryn H. Tracy reviewed the sections on trace elements in fish, limnology, and fisheries,
respectively. The document fulfills the permit obligations for reporting the results of the annual biological monitoring.
However, we do have some concerns and comments. We would appreciate receiving written responses to the concerns
we have raised.
Concerns
1. The surface water temperature at Station 2B on August 5, 2008 was 32.2°C (Appendix 1). This station, located in
the mid- to upper reach of the North Hyco Creek Arm, is well upstream and outside the designated mixing zone
as described in A.(12)a of the NPDES permit. This temperature exceeded the state water quality standard of
320C for Piedmont lakes. Although natural conditions (i.e., late summer air temperature and solar radiation) may
have been the most likely source of this increased temperature, can power plant operations be ruled out as a
factor? These exceedances were also measured in August 2006 and August 2007. In addition, specific
conductance at Station 2B seems to be strongly influenced by the plant and is much greater than that in the South
Hyco Creek Arm (Appendices 1 and 2). And finally, although it is understandable why there are fewer fish in
areas influenced by the plant's thermal discharge than in areas away from the discharge (i.e., Transacts 4 and 6
vs. Transects 1 and 3) (Appendix 6), the number of fish collected at Transact 2 in the North Hyco Arm is much
fewer than the number collected at the other two "control" transects (Transects 1 and 3) and more similar to the
discharge site (Transect 4).
The temperature exceedances and the evidence of elevated specific conductance, combined with the difference
in the number of fish collected in the North Hyco Arm in contrast to the South Hyco Arm, suggests the possibility
of more than just natural spatial and temporal differences. Overall, it seems that the effects of the plant's thermal
discharge and other permitted effluents may possibly extend beyond the mixing zone as described in A.(12)a of
the NPDES permit. We would like for you to explore if these measurements are due to natural variability or if
these measurements indicate a plant impact far outside the designated mixing zone.
2. The copper concentration at Station 3B in the South Hyco Arm in June (8.3 pg/L) was greater than the state water
quality standard (7.0 pg/L). Copper concentrations at this station in other months in 2008 were less than the
standard, suggesting that the June concentration was not due to ongoing contamination (Appendix 3). However,
elevated copper concentrations have been previously measured in 2005, 2006, and 2007 at various stations
throughout the reservoir. Explanations or enhanced interpretations of the copper concentrations in the reservoir
should be further evaluated.
1621 Mail Service Center, Ralegh, North Carolina 27699-1621
Location: 4401 Reedy Creek Road, Ralegh, North Carolina 27607
Phone: [phone] FAX: [phone] \ Customer Service: 1-877E23-6748
Internet httpJ1h2o.enr.state.nc.us/eS
-One arolina
JVatmally
An Equal Opportunity \ Affirmative Action Employer

Harry Sideris
November 16, 2009
Page 2
Comments and Observations
1. In the future, please include more historical data for all programs in the figures, tables, and analyses to compare
pre -and post- operations of the Flue Gas Desulfudzation system and to characterize the extent and impact of the
thermal discharge.
2. In the future, please send one copy of the annual monitoring report to DWQ's Environmental Sciences Section, as
has been the customary practice, and one copy to Mr. Danny Smith, Surface Water Protection Supervisor, DWQ
Raleigh Regional Office, 3800 Barrett Drive, Raleigh, NC 27609.
3. In the future, in addition to sending one copy of the annual monitoring report to Mr. Danny Smith, please submit
all the water quality, water chemistry, and trace elements in fish and sediment data in electronic format (Excel) to
Ms Autumn Romanski (Autumn. Romanski(dncdenr.00vl, Raleigh Regional Office, 3800 Barrett Drive, Raleigh,
NC 27609.
4. The fish assemblage in this multi -purpose reservoir is comprised of 15 indigenous and 10 nonindigenous species.
The nonindigenous species have been introduced for one reason or another either accidentally or to manage the
reservoir's fishery and aquatic since impoundment of the Hyco River. In 2008 nonindigenous species made up
76% of the total number and 30% of the total weight of all fish collected (Appendix 5). Although the fish
community is far from being what one normally considers indigenous, §316(a) of the Clean Water Act does allow
for". . . Such a community may include historically non-native species introduced in connection with a program of
wildlife management and species whose presence or abundance results from substantial, irreversible
environmental modification" (40CFR 125.71(c).
5. Trace Elements in Fish
a. All concentrations of heavy metals were well below the criteria set by North Carolina Department of
Health and Human Services (NCDHHS).
b. Arsenic concentrations continued to be low and well below the US EPA screening value for recreational
fishermen (1.2 pg/g).
c. Cadmium concentrations were less than the laboratory reporting limit, and therefore, well below the US
EPA screening values for recreational and subsistence fishermen, 4.0 and 0.491 pg/g, respectively.
d. Copper concentrations were reported as: "... relatively low during the observation period'. There are no
specific federal or state screening criterion for copper in fish tissue.
e. Most total mercury concentrations were less than the laboratory reporting limit and all concentrations
were well below the NCDHHS criterion of 0.4 pg/g.
f. Selenium concentrations continued to be greatest at Transact 4. However, all concentrations were well
below the NCDHHS criterion of 10 pg/g.
If you have any questions, please do not hesitate to contact me or my staff.
\—Yoouuurrrss truly, �
Jay Sau er
Acting Chief, Environmental Sciences Section
cc: Robert L. Curry, NCWRC
Jeff DeBerardinis, Environmental Sciences Section
E. Shannon Langley, Progress Energy
Debra Owen, Environmental Sciences Section
Jeff Poupart, Surface Water Protection Section
Danny Smith, Raleigh Regional Office
Bryn H. Tracy, Environmental Sciences Section

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
November 16, 2009
MEMORANDUM
To: Mr. Jim Kohler, P.E.
Environmental Engineer LT, U.S. Public Health Service
U.S. Environmental Protection Agency
Office of Resource Conservation and Recovery
From: Autumn Hoban Romanski �`—
Raleigh Regional Office, Surface Water Protection Section
Division of Water Quality
✓ 1`Qu
�
Through: Danny Smith
Raleigh Regi al Office. Surface Water Protection Section
Division of Water Quality
Subject: Impoundment Inspection Comments
Roxboro Steam Electric Power Plant
NPDES Wastewater Discharge
Permit No. NC0003425
Dee Freeman
Secretary
On September 1.. 2009. Autumn Hoban Romanski of the Raleigh Regional Office (RRO) Surface Water
Protection Section (SWP) North Carolina Division of Water Quality (NC DWQ) participated in the Coal
Combustion Waste (CCW) Surface Impoundment Assessment conducted at the Roxboro Plant Site in
Person County North Carolina. The EPA's Impoundment Condition Assessment was satisfactory for
the West Ash Pond Dam and fair for the Flue Gas Desulfurization (FGD) Settling Pond and FGD Flush
Pond wastewater treatment units at the Roxboro Plant Site. This memorandum is provided in
response to your request for comment on the draft report regarding the subject facility.
A NC DWQ annual NPDES Wastewater Discharge Permit Inspection at the Roxboro Steam Electric
Power Plant was conducted on May 27, 2009. This inspection was conducted to verify/determine the
compliance status of this facility with the conditions and limitations specified in NPDES Wastewater
Permit No. NC0003425.
While the facility was reported to be compliant with NPDES permit conditions, the site has been
required to provide additional sampling and monitoring to NC DWQ since March of 2008.
The RRO SWP staff of the NC DWQ has reviewed the draft EPA report and offers the following
corrections and observations for consideration in the final report development:
1) The report identifies/explains that the toe drains from the West Ash Pond Dam outlet to Hyco
Lake. This is not accurate, The toe drains from the West Ash Pond outlet to a mixing zone, at
the confluence of outfall 002 and the heated water discharge canal, prior to the final outfall at
003 to Hyco Lake. The toe drains are an internal outfall.
Page 1 of 3

Roxboro Impoundment RRO Comments
2) The report accurately explains that the West Ash Pond Dam is regulated by the NC Utilities
Commission. However, NC DWQ regulates the NPDES wastewater treatment units and
respective discharges associated with the wet ash.
3) The draft report states
The statement underlined above is accurate. In keeping with the findings of the EPA report, NC
DWQ observed the West Ash Impoundment and the permitted wastewater treatment units
constructed within the West Ash Pond. These treatment units discharge under the current NPDES
Discharge Permit. It is noted that current construction plans for repairs of the existing FGD Settling
Pond and the design of a new FGD Settling Pond indicate the elevation of the new FGD Settling
Pond will be raised an additional 4 feet. (Saturation of ash/groundwater table elevations are
recorded in Progress Energy's geotechnical data.)
In a written response to the NC DWQ's NPDES inspection from May 2009, the Progress Energy
Roxboro facility explained the following:
• Progress Energy recently completed bathymetry work for the existing ash pond
(excluding the footprint of the currently constructed FGD wastewater treatment units ).
The volume of the Roxboro Ash Pond as surveyed on September 17 & 18, 2009 is
563,217 cubic yards. This is based on the water surface elevation of 462.13 ft MSL
(NAVD88) taken at the time of the bathymetry survey. The volume of the pond after the
2007 bathymetry survey was 445,149 cubic yards at a water surface elevation of 458 7 ft
MSL (NAVD88).
Available freeboard — The elevation of the ash pond dam crest is 470 ft. The design
water elevation is 463 ft with a maximum water elevation of 465 ft. Water elevation
surveyed during the last bathymetry event was 462.13 at the time of the survey.
4 The Roxboro Plant is located within the Piedmont Physiographic Province and near the Milton
and Charlotte Belts. More specific geologic details of the site can be found on the North
Carolina Geologic Map last dated 1985, as well as, in Progress Energy s geotechnical data.
5. The Roxboro Steam Electric Plant is located approximately 6.5 miles downstream of the Town
of Roxboro's surface water supply intake. This intake is located on South Hyco Creek and is
classified as Water Supply (WS-ll) High Quality Waters (HQW) critical area (CA) in the
Roanoke River Basin,
6. The power plant intakes and discharges water from Hyco Lake classified as Class B Primary
Recreation, Water Supply (WS-V) waters in the Roanoke River Basin.
7. Much of the vegetative cover and side slopes of the Ash Pond Dam consisted of a tall, thick
vegetative cover that inhibited full observation of all slopes. The toe drain slopes of the West
Ash Pond were clear of vegetation.
8. The EPA report explains the discharge ends of the concrete swales are undermined. Further
the report states that this was not part of a dam safety concern due to the distance from the toe
of the dam NC DWQ staff agrees that the toe drains of the dam showed signs of erosion
around the cement. These drains which convey internal dam seepage should be inspected
frequently (e g weekly) to ensure stability and proper operation of the dam. [During the site
visit seven toe drains with the exception of the middle toe drain were discharging]
9. The #3 Summary Recommendation in the EPA report is to quantify the seepage/discharge rate
from the toe drains. The RRO concurs with this recommendation. [Note: EPA and NC DWQ
observations indicated that one of the toe drains showed evidence of soil transport, the subject
of the # 2 Summary Recommendation in the EPA report.]
Page 2 of 3

Roxboro Impoundment RRO Comments
10, The northwest berm of the West Ash Pond by the NPDES internal outfall 002. had apparent
seepage at the discharge weir from beneath the concrete abutment that appears to be coming
from the rock foundation, as described in the EPA report. This is of concern to the Raleigh
Regional Office from an NPDES discharge standpoint. The additional flow could alter
measurements/sampling results at other NPDES outfalls. (Note: Baser' on boring data
recorded in the geotechnical data received by the Raleigh Regional Office on January 26,
2009, no groundwater was found at 9 feet (depth of augur refusal) at location GP-8 (the closest
boring data location to outfall 002), This paragraph is the subject of the #5 Summary
Recommendation in the EPA report.
11. The EPA report # 4 Summary Recommendation is to continue monitoring the seepage at
the toe of the West FGD Settling Pond.
Note repair efforts are currently ongoing and permitted/addressed through NPDES permit
conditions. The FGD Flush Pond was under construction, as repairs for this treatment unit
were underway the day of this inspection.
If you have any questions or if I can be of further assistance, please do not hesitate to contact me.
Cc Raleigh Regional Office — DWQ SWP and DLQ Files
Page 3 of 3

7 o
�r
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue
Governor
November 13, 2009
Progress Energy Carolinas, Inc.
Attention: Mr. Harry Sideris, Plant Manager
Roxboro Steam Plant
1700 Dunnaway Road
Semora, NC 27343
Coleen H. Sullins
Director
Subject: Roxboro Steam Electric Plant—NC0003425 Person County
FGD Wastewater Treatment Systems
Repairs and Monitoring
Dear Mr. Sideris:
Dee Freeman
Secretary
The Division of Water Quality (DWQ) Raleigh Regional Office (RRO) replaces the addendum 1
attached to the additional monitoring request letter dated November 6, 2009 with the following
addendumlA.
Please see the attached addendum IA for corrected monitoring frequency.
The new monitoring plan should begin effective November 15, 2009. This monitoring must
continue at the frequency and as described in Addendum 1A, until otherwise notified in
writing by DWQ that monitoring is no longer needed.
Thank you for your attention to this matter. If you have any questions please do n hesitate to call
me at [phone].
Pincely,
rv/
Danny Smith
Raleigh egional Supervisor
Surface Water Protection

Kr n
v r«a c' i1;'',"sF Addendum — IA
Duration: This monitoring must continue at the frequency and as described in Addendum IA, until
otherwise notified in writing by DWQ that monitoring is no longer needed.
Reporting: This information must be provided to RRO DWQ Monthly.
Monitoring (beyond the requirements of the current NPDES Permit) is requested as specified from
the following locations:
1) FGD Settling Basin (Influent Flow- Prior to Settling Basin)
2) FGD Settling Basin (Influent sampling data) for the Bioreactor Influent
3) Effluent (Bioreactor) sampling data (if operational)
4) 002 effluent sampling data
5) 003 effluent sampling data
PARAMETERS
Metals -Total
Measure-
Sample
1) Infl prior
2) Intl Bio-
3) Eftl
4) Bill
5) Etil 003
Recoverable
ment
to Settling
reactor
Bio-
002 /Lab
Type
Basin in use
/Lab
reactor
Method
/Lab
Frequency
/Lab
Method
/Lab
Method
Method
Method
Pump
Continuous
logs or
x
x
x
x
x
Flow
similar
reading
x
x
PH
lst and 3rd
Week
Monthly
FHarnessd-
19 and 3rd
alcium
Week
xx
Carbonate
Monthly
SM 2340
SM 2340
Temperature
lar and 3rd
Week
x
x
Monthly
21Page

PARAMETERS
Metals -Total
Measure-
Sample
1) Infl prior
2) Infl Bio-
3) Effl
4) Effl
5) Efn 003
Recoverable
ment
to Settling
reactor
Bio-
002 /Lab
Type
Basin in use
/Lab
reactor
Method
/Lab
Frequency
/Lab
Method
/Lab
Method
Method
Method
Al
1s1 and 3rd
Grab
x
x
x
x
x
Week
Monthly
200.8
200.8
200.8
200.8
200.8
As
I� and 3rd
Grab
x
x
x
x
x
Week
Monthly
200.8
200.8
200.8
200.8
200.8
Chlorides
1� and 3rd
Week
Grab
x
x
x
x
x
Monthly
300
300
300
300
300
B
la and 3rd
Week
Grab
x
x
x
x
x
Monthly
200.7
200.7
200.7
200.7
200.7
Cn
In and 3rd
Grab
x
x
x
x
x
Week
Monthly
200.7
200.7
200.7
200.7
200.7
Zn
la and 3rd
Grab
x
x
x
x
x
Week
Monthly
200.8
200.8
200.8
200.8
200.8
Mn
1� and 3rd
Grab
x
x
x
x
x
Week
Monthly
200.7
200.7
200.7
200.7
200.7
Hg
1� and 3rd
Grab
x
x
x
x
x
Week
Monthly
245.1
1631E
1631E
1631E
1631E
Ni
1� and 3rd
Grab
x
xF20XO.8
xWeek
Monthly
200.8200.8
200.8
200.8
3 1 P a g e

PARAMETERS
1:
Metals -Total
Measure-
Sample
1) Infl prior
2) Infl Bio-
3) Bill
4) Effl
5) Eifl 003
Recoverable
meat
to Settling
reactor
Bio-
002 /Lab
Type
Basin in use
/Lab
reactor
Method
/Lab
Frequency
/Lab
Method
/Lab
Method
Method
Method
Se
13and 3 d
Grab
a
x
R
R
s
Week
Monthly
200.8
200.8
200.8
200.8
200.8
Sr
I� and 3rd
Grab
R
R
R
XWeek
Monthly
200.8
200.8
200.8
L
200.8
TI
lst and 3 d
Grab
R
R
R
R
R
Week
Monthly
200.8
200.8
200.8
200.8
200.8
NUTS: Progress Energy is responsible for ensuring that NC certified laboratories analyze the
samples above using the lab methods identified. Sample dilution should be minimized and the
appropriate PQL reported. If multiple dilutions occur and are necessary for a given sample, the
laboratory should provide a written explanation.
* An account must be provided in writing of the sample location and how samples
including, flow measurements are collected.
* In addition, all Current Permit Monitoring and Limit Requirements of the permit apply,
and must be properly monitored, collected and properly reported on (DMR).
*All effluent limits and monitoring requirements, as described in NPDES permit
NC0003425 remain in effect.
* Progress Energy must provide copies of the bench/laboratory sheets and monitoring
results data in an electronic PDF, as well as, in an electronic Excel spreadsheet created
in an Excel file format. A requirement of the electronic Excel spreadsheet submittal
includes that all results reported below the practical quantitation limit (PQL) be recorded
in the spreadsheet by dividing the PQL result by two.
For example: Arsenic Result is <6.5 (meaning the result is between 0 and 6.5)
report ''/2 of the result, as a whole number with decimals as needed to
two significant digits. In this case the number entered in the
spreadsheet would be 3.25.
41Pa,e

51
r F�,X COVER S1 dEET
ANORTH'a=^ CAROLINA
;V DEPARTMENT OF ENVIRONMENT
NCDEANR AND NATURAL RESOURCES
Raleigh Regional Office
1628 Mall Service Center
Raleigh, NC 27699-1628
Pages, including cover sheet �/
TO: t) � nnUl� Pr✓n I FAX: 4S (oo -
FROM: f i�R `� �� i t)n (gyp DATE: I I Ul C� 9
SUBJECT: G ( l Ue 5
MESSAGE:
If you do not receive alf pages, call 919, 791, 4200 or fax back to q I q - 789 - 7159
►aA 0e► I AW)u= As" ■.► 8

-t
TRANSMISSION VERIFICATION REPORT
TIME :
11/10/2009 12:16
NAME :
NCDWQRR0
FAX :
9197887159
TEL :
9197914200
SER.# :
BROF6J480635
DATEJIME
11/10 12:15
FAX NO./NAME
95464409
DURATION
00:01:09
PAGE(S)
b6
RESULT
qq��
�?5TANDARD
MODE
ECM

�0
VID NR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue
Governor
November 6, 2009
Certified Mail 70081140 0002 6738 6423
Return Receipt Requested
Progress Energy Carolinas, Inc.
Attention: Mr. Harry Sideris, Plant Manager
Roxboro Steam Plant
1700 Dunaway Road
Semora, NC 27343
Coleen H. Sullins
Director
Subject: Roxboro Steam Electric Plant—NC0003425 Person County
FGD Wastewater Treatment Systems
Repairs and Monitoring
Dear Mr. Sideris:
Dee Freeman
Secretary
The Division of Water Quality (DWQ) Raleigh Regional Office (RRO) staff received a telephone
call from Progress Energy of an "anticipated bypass" [Part II, Section C, 4. b. (1)] for the Roxboro
Flue Gas Desulfurization (FGD) Wastewater Treatment Systems at the Roxboro Steam Electric
Generating Plant (NC0003425). This information was received by RRO staff around 5:00 pm on
February 25, 2008. Progress Energy explained that the FGD Wastewater Settling Basin was seeping
and at risk of failure. Accordingly, Progress Energy explained that they were preparing to dewater
the Settling Pond into the adjacent Ash Pond to reduce the hydraulic head in the Settling Pond.
On February 27, 2008, Progress Energy called notifying DWQ RRO staff that the Flush Pond berm
partially failed, such that an 8 to 12 foot wide berm failure had occurred allowing water to discharge
into the adjacent Ash Pond. [It was explained to DWQ that the Flush Pond contained Bioreactor
"start up" water and did not house back wash water from the Bioreactor.]
On February 26, 2008 DWQ and Division of Land Quality (DLQ) staff visited the site and observed
seepage occurring along the western toe of the Settling Pond berm wall.
On February 28, 2008, DLQ RRO staff revisited the site to investigate Flush Pond structure failures
and to observe Settling Pond dewatering efforts.

C •J
On April 9, 2007, a NPDES Permit was issued (renewed) for the Roxboro Steam Electric Generating
` Plant (NC 0003425). The subject NPDES Permit, Part II, Section B., 8. and Part III, Section B states
the following:
"Part H, Section B., 8. Duty to Provide Information The Permittee shall furnish to the
Permit Issuing authority, within a reasonable time, any information which the Permit Issuing
Authority may request to determine whether cause exists for modifying, revoking and
reissuing, or terminating the permit or to determine compliance with this permit. The
Permittee shall also furnish to the Permit Issuing Authority upon request copies of records
required by this permit [40 CFR122.41 (h)]."
This letter replaces the sampling and monitoring request letter dated March 4, 2008 with the
following sampling and monitoring request:
The following additional monitoring (beyond the requirements of the current NPDES Permit) is
requested from the following locations:
1) FGD Settling Basin (Influent Flow- Prior to Settling Basin)
2) FGD Settling Basin (Influent sampling data) for the Bioreactor Influent
3) Effluent (Bioreactor) sampling data (if operational)
4) 002 effluent sampling data
5) 003 effluent sampling data
Please see the attached addendum 1 for locations, parameters, monitoring frequency, lab methods,
and excel spreadsheet reporting format requested.
The new monitoring plan should begin effective November 15, 2009. This monitoring must
continue at the frequency and as described in Addendum 1, until otherwise notified in writing
by DWQ that monitoring is no longer needed.
Thank you for your attention to this matter. If you have any questions please do not hesitate to call
me at [phone].
Sine rely,
i//1i7� h7/
army Smith
Raleigh Re onal Supervisor
Surface Water Protection
2 1 P a g e

a
Duration: This monitoring must continue at the frequency and as described in Addendum 1, until
otherwise notified in writing by DWQ that monitoring is no longer needed.
Reporting: This information must be provided to RRO DWQ Monthly.
Monitoring (beyond the requirements of the current NPDES Permit) is requested as specified from
the following locations:
1) FGD Settling Basin (Influent Flow- Prior to Settling Basin)
2) FGD Settling Basin (Influent sampling data) for the Bioreactor Influent
3) Effluent (Bioreactor) sampling data (if operational)
4) 002 effluent sampling data
5) 003 effluent sampling data
PARAMETER
Metals -Total
Measure- Sample 1) Infl prior 2) Infl Bio- 3) Efll 4) Efn 5) Em 003
Recoverable
meat to Settling reactor Bio- 002 /Lab
Type Basin in use /Lab reactor Method /Lab
Frequency
/Lab Method /Lab
Method Method Method
Pump
Continuous
Logs or
x
x
R
R
Flow
similar
x
reading
x
x
PH
Hardness -
Calcium
x
x
Carbonate
SM 2340
SM 2340
Temperature
R
x
31 P ;i

PARAMETERS
Metals -Total
Measure-
Sample
1) Infl prior
2) Intl Bio-
3) Effl
4) Ef11
5) EM 003
Recoverable
meat
to Settling
reactor
Bio-
002 /Lab
Frequency
Type
Basin in use
/Lab
reactor
Method
/Lab
/Lab
Method
/Lab
Method
Method
Method
Al
I n and 3rd
Grab
x
Tuesday
x
x
x
x
Monthly
200.8
200.8
200.8
200.8
200.8
As
1M and 3rd
Grab
x x
x
Tuesday
x R
Monthly
200.8 200.8
200.8 200.8 200.8
Chlorides
la and 3rd
Tuesday
Grab
x x
x x x
Monthly
300 300
300 300 300
B
la and 3rd
Tuesday
Grab
x x
R R x
Monthly
200.7 200.7
200.7 200.7 200.7
Cu
lat and 3rd
Tuesday
Grab
R R
x x R
Monthly
200.7 200.7
200.7 200.7 200.7
Zn
1� and 3rd
Tuesday
Grab
x x
x R x
Monthly
200.8 200.8
200.8 200.8 200.8
Mn
1� and 3rd
Grab
x x
x
Tuesday
x x
Monthly
200.7 200.7
200.7 200.7 200.7
HB
1� and 3rd
Tuesday
Grab
x x
x x R
Monthly
245.1 1631E
1631E 1631E 1631E
Ni
la and 3rd
Grab
x x
x
Tuesday
x x
Monthly
200.8 200.8
200.8 200.8 200.8
4 1 P a g e

PARAMETERS
Metals -Total
Measure-
Sample
11 Infl prior
21 Infl Bio-
3) EfA
4) Etfl
5) EI11003
Recoverable
meat
to Settling
reactor
Bio-
002 /Lab
Frequency
Type
Basin in use
/Lab
reactor
Method
/Lab
/Lab
Method
/Lab
Mcthod
Method
Method
Se
1st and 3rd
Grab
a
Tuesday
X
a
x
x
Monthly
200.8
200.8
200.8
200.8
200.8
Sr l9t and 3rd Grab g x x
s s
Tuesday
Monthly 200.8 200.8 200.8 200.8 200.8
Tl Istand 3rd Grab a a a a a
Tuesday
Monthly 200.8 200.8 200.8 200.8 200.8
NOTE: Progress Energy is responsible for ensuring that NC certified laboratories analyze the
samples above using the lab methods identified. Sample dilution should be minimized and the
appropriate PQL reported. If multiple dilutions occur and are necessary for a given sample, the
laboratory should provide a written explanation.
W-4. ..
* An account must be provided in writing of the sample location and how samples
including, flow measurements are collected.
* In addition, all Current Permit Monitoring and Limit Requirements of the permit apply,
and must be properly monitored, collected and properly reported on (DMR).
*All effluent limits and monitoring requirements, as described in NPDES permit
NC0003425 remain in effect.
* Progress Energy must provide copies of the bench/laboratory sheets and monitoring
results data in an electronic PDF, as well as, in an electronic Excel spreadsheet created
in an Excel file format. A requirement of the electronic Excel spreadsheet submittal
includes that all results reported below the practical quantitation limit (PQL) be recorded
in the spreadsheet by dividing the PQL result by two.
For example: Arsenic Result is <6.5 (meaning the result is between 0 and 6.5)
report ''/: of the result, as a whole number with decimals as needed to
two significant digits. In this case the number entered in the
spreadsheet would be 3.25.
51Pa-r

j Progress Energy
File: 12520 B
Autumn Hoban Romanski
NC Division of Water Quality
Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-1628
Dear Ms. Romanski:
October 29, 2009
Subject: Response to NPDES Inspection report
Roxboro Steam Electric Plant
Permit #: NCO03425
Person County
Progress Energy (PE) staff have reviewed your NPDES Inspection report dated August 27, 2009.
Comments and responses to requests for information are as follows
1. Permit — Progress Energy believes that reclassification of the wastewater treatment system to
a "Physical/Chemical IP' system because of the recent addition of a reverse osmosis (RO) system
is not appropriate. The RO system is not used for treatment of wastewater (it is used for
treatment of water from Hyco Lake for plant processes) and therefore a reclassification is
inappropriate.
7. Flow measurement - Outfall 006 - Measurement and required sample results for outfall 006
are reported on our NPDES Discharge monitoring report (DMR). The coal pile runoff pond was
designed and permitted to have adequate capacity for treatment. Periodic bathymetry is
performed on the pond to evaluate treatment volume. All analytical sample results from the
pond, including aquatic toxicity testing, are within permit limits. With regard to the Sediment
and Erosion control basin observed during the inspection, that basin no longer exists and final
grading and site closeout is being done in that area. PE staff will be contacting staff from the NC
Division of Land Resources to perform a "close out' inspection of the sediment and erosion
control plan for the site that was associated with the construction of the scrubbers.
Outfall 009 — Metal cleaning waste is evaporated in the plants boiler. Samples from the last
boiler cleaning event were taken from outfall 002 on May 6/2007 in accordance with the most
recent ash pond bathymetry at the time. Sample results were submitted to DWQ on the required
DMR form.
Progress Energy Carolinas, Inc. -"
Roxboro Steam Plant
1700 Runnawav Road — WN 'I jig
Semora, NC 27343 I �1

9. Solids Handling — Fly ash is disposed of in the facility's onsite landfill as referenced in your
inspection. Coal combustion Products are also disposed of through beneficial reuse in
accordance with State non -discharge permit WQ0000020. Reports of reuse activities are
provided to the Aquifer Protection Group annually.
12 Operation and maintenance
Current ash Pond capacity -PE recently completed bathymetry work for the existing
ash pond. The volume of the Roxboro ash pond as surveyed on September 17 & 18,
2009 is 563,217 cubic yards. This is based on the water surface elevation of 462.13 ft
MSL (NAVD88) taken at the time of the bathymetry survey. The volume of pond after
the 2007 bathymetry survey was 445,149 cubic yards at a water surface elevation of
458.7 ft MSL (NAVD88). NOTE — this water surface elevation is 3.43 ft lower than the
2009 survey. Please see the attached design specifications for information on design
water levels, etc.
2. Available freeboard - The elevation of the ash pond dam crest is 470 ft. The design
water elevation is 463 ft with a maximum water elevation of 465 ft. Water elevation
surveyed during the last bathymetry event was 462.13 at the time of the survey.
3. Treatment design specs — See attached information regarding dam and impoundment
area previously submitted to the Division of Water Quality.
4. Operation and Maintenance for the treatment unit — The treatment unit consist of a
240 acre surface area ash pond. Routine O&M consists of removal of bottom ash for
beneficial reuse and conducting periodic, scheduled bathymetry work. Regular
inspections of the condition of the impoundments by both PE staff and contracted
independent third party consultants ensure continued, stable operation of the treatment
unit. The ash pond has consistently met permit limit requirements.
It is unclear to PE what the DWQ is requesting with regard to specific efficiencies for
sedimentation, oxidation, neutralization, equalization and adsorption. PE provided
information in its NPDES permit application Form 2C and subsequent request for
modification that the ash pond provides treatment via these processes. Specific
"efficiencies" of these processes are not required or calculated. The facility continues to
meet all permit requirements for discharge from the ash pond in accordance with limits
established by the Steam Effluent guidelines.
b.) Design calculations for the coal pile runoff pond were submitted to and reviewed by the
DWQ as part of Authorization to Construct issuance for modification to this pond. As with
the ash pond, periodic, scheduled evaluations of treatment volume are calculated with survey
grade equipment to determine the treatment volumes of the coal pile runoff pond.
Discharges from the coal pile runoff pond have been compliant with permitted limits.

c.) See answer to this item under Item 7, outfall 009 above.
d.) In accordance with applicable North Carolina Administrative Code, the facility submits
all monitoring results taken from permitted outfalls.
If you have any questions, please feel free to contact Shannon Langley at [phone].
Res ctfully,
Harry Sideris, Plant Manager
Roxboro Steam Electric Plant
Attachment
cc: Billy Milam
Dana Newcomb
Shannon Langley — PEB 4

DAM INFORMATION SUMMARY
Roxboro Steam Electric Plant
West Ash Pond Dam and Dikes
Person County, North Carolina
1. Location
Latitude: N360 31' 16"
Longitude: W780 59' 55"
2. Size and Dimensions
Length:
Maximum Structural Height:
Surface Area (acres):
Storage capacity (acre-feet):
Drainage area (sq. miles):
Size Classification:
Hazard Classification:
Regulatory Design Storm
US Slope:
DS Slope:
US Slope protection:
Crest Width:
Crest Elevation:
Design Water elevation:
2005 Water elevation:
Maximum Water elevation:
Normal Tailwater elevation:
Instrumentation:
1,360 feet
70 feet
240
4,800
0.54
Large
Significant
PMF*
2.5 (H):1(V)
2.0 (H):1(V)
2 feet thick riprap between el. 405 and crest at e. 426
20 feet
470 feet
463 feet
463 feet
465 feet
410 feet
6 piezometers; 2 at toe and 2 pairs of 2 on crest.
* Probable Maximum Flood (PMF) is derived from Probable Maximum Precipitation
(PMP). The PMP rainfall is 30.6 inches for 24 hour duration.
3. Design Information
Original dike designed by Brown & Root. Subsurface exploration performed. A vertical
extension designed by CP&L in 1986. Stability analyses performed with lowest FS 1.46.
Seepage analysis performed and indicated about 10 gpm, a negligible quantity. A chimney
drain connected to a blanket drain with several pipe outlets serves as internal drainage.
There are no pipes through the dam. The outlet works for the pond consist of two 3'
diameter vertical risers (RCP) connected to 3' diameter RCP under the filter dike. The rock

filter dike allows a large volume of water flow through the dike, such that the pond level has
never risen to the top of the risers.
CP&L analyzed for a % PMP (6 hr) storm and determined the design 5 feet of freeboard was
sufficient.
4. Construction History
1973: Construction of Dam designed by Brown and Root with crest elevation of 457 feet in
an arm of Hyco Lake
1986: Dam crest raised 13 feet to 470 feet as designed by CP&L. Also modified circulation
pattern by constructing a rock fill filter dike (Dike No. 1) with crest elevation of 473
feet to create secondary settling basin and also to isolate major portion of ash pond
from the remaining watershed. In addition three random earth dikes (Dike Nos. 2, 3,
and 4) were constructed with crest elevation of 470 feet and riprap protected 2(H):1(V)
slopes on both US and DS. Bottom ash separation dike located on east side of the ash
pond raised to crest elevation of 463 feet.
2006-2007 :Wastewater treatment containment area enclosed by ash dikes was constructed
within the existing ash pond area. Engineering and design was provided by Worley
Parsons.
5. Inspection History
The dam is inspected on 5-year intervals. Since 2002, yearly site visits have been made for
limited visual observations.
William Wells: 1978
Ralph Fadum: 1983
LAW/MACTEC: 1988, 1993, 1998, 2002, 2003, 2004, 2005, 2006, 2007

•1
Golder Associates NC, Inc.
4900 Koger Boulevard, Suite 140
Greensboro, North Carolina 27407
Telephone [phone]
Fax [phone]
September 22, 2009
Construction Grants & Loans
DENR/DWQ
1633 Mail Service Center
Raleigh, North Carolina. 27699-1633
G
� Golder
Associates
E1 F
�t J ,j�i off 17�
Attn: Mr. Ken Pohlig om � SEC-GR O
TO
RE: ROXBORO STEAM STATION
FGD WASTEWATER TREATMENT SYSTEM - FLUSH POND
ATC NO.003425A05
Dear Mr. Pohlig:
I, Charles Hiner, as a duly registered Professional Engineer in the State of North Carolina,
having been authorized to observe full time the construction of modifications and
improvements to the Roxboro Steam Plant FGD Wastewater System, located on NCSR 1377
in Person County for Progress Energy, hereby state that, to the best of my abilities, due care
and diligence was used in the observation of the following construction:
Reconstruction of the FGD existing Flush Pond with approximate new volume of 15
MG (with 2 feet freeboard), including reconstruction of the southern berm wall and
pond bottom, relining the pond with a composite clay and 60 mil LLDPE synthetic
liner, and associated yard piping and appurtenances; in conformity with the project
plans, specifications, and other supporting data subsequently filed and approved by
the Department of Environment and Natural Resources.
I certify that the construction of the above referenced project was observed to be built within
substantial compliance and intent of the approved plans and specifications.
Sincerely,
Golder Associa e
Kn
C
Charles Hiner
Senior Consultant and Associate
NC Registration No. 029089
September 22, 2009
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FDA
EPA
Criteria for
Action
Recreational
EPA Subsistence
NC Health
Wildlife
Contaminant
Levels
Fishermen
Fishermen
Director
Protection
Wildlife Criteria Reference
Metals
Arsenic (Inorganic)
0. 026
0.00327
Cadmium
4
0.491
Lead (total)
0.8
Pommen 1989
Mercury
1
0A
0.049
0.4
0.1 - 5.0
USFW. 1987
Selenium
20
2,457
5
3.0
BCMOELP 1994
Tributyltin
1.2
0.147
Organics
Aldrin
0.3
0.022 - 0.12
Newell et al. 1987
Chlorpyrifos
1.2
0,147
Total chlordane
0.114
0.014
0.37
Newell et al. 1987
Cis -chlordane
0.3
Trans -chlordane
0.3
Total DDT'
0.117
0.0144
1
0.2 - 1
Newell et al. 1987
o, p DOD
5
1
p, p DOD
5
1
o, p DOE
5
1
p, p DOE
5
1
o, p DDT
5
1
p, p DDT
5
1
Diazinon
2.8
0.344
Dicofol
1.6
0.196
Dieldrin
0.0025
3.07x104
0.022 - 0.12
Newell at al. 1987
Dioxins (total)
2.56x10-7
3.15x104
4.0 (ppt)
Disulfoton
0.16
0.019
Endosulfan (I and II)
24
2.949
Endrin
0.3
1.2
0.147
Ethion
2
0.245
Heptachlorepoxide
0.00439
5.40x10'
Hexachlorobenzene
0.025
0.00307
0.2 - 0.33
Newell at al. 1987
Lindane
0.0307
0.00378
0.2
UNEP 1983
Mirex
0.8
0.098
0.33 - 0.37
Newell at al. 1987
Oxyfluorfen
0.546
0.0671
Pentachlorophenol
2.0
Newell et al. 1987
Total PCBs
0.02
0.00245
0.05
0.1 - 0.5
Pommen 1984, Newell at al. 1987
PCB-1254
2
PBDE
5000
Terbufos
0.08
0.009
Toxaphene
0.0363
0.00446

County. PERSON
L
f
River Basin RDA
Tr
Report To RROSP
Collector. A HOBAN
Region: RRO
Sample Matrix: WASTEWATER
Loc. Type'. EFFLUENT
Emergency Yes/No
CDC Yes/No
IL Location ID: NC0003425APO1
r
VisitlD
Loc. Descr.: NC0003425APTDI
Collect Date: 0910112009 Collect Time:: 09:55
Sample Qualifiers and Comments
Sample ID:
PO Number M
Date Received:
Time Received:
Labworks LoginlD
Date Reported:
Report Generated
Sample Depth
IT-
AB48939
SW7418
09/02/2009
09:15
SMATHIS
9/23/09
0923/2009
9las169
Routine Qualifiers
For a more detailed description of these qualifier codes refer
to www.dwglab.org under Staff Access
A -Value reported is the average of two or more determinations
81-Countable membranes with <20 colonies; Estimated
N3-Estimated concentration is < POL and >MOL
B2- Counts from all 51ters were zero.
NE -No established POL
B3- Countable membranes with more than 60 or 80 colonies; Estimated
P-Elevated POL due to matrix interference and/or sample dilution
B4-Flmrs have counts of both >60 or 80 and < 20; Estimated
07-Holding time exceeded prior to receipt at lab.
85-Too many colonies were present; too numerous to count (TNTC)
02- Holding time exceeded following receipt by lab
J2- Reported value failed to meet OC criteria for either precision or accuracy; Estimated
POL- Practical Ouantitation Limit -subject to change due to instrument sensitivity
J3-The sample matrix interfered with the ability to make any accurate tletermination; Estimated
U- Samples analyzed for this compound but not detected
J6-The lab analysis was from an unpreserved or improperly chemically preserved sample; Estimated
X1- Sample not analyzed for this compound
NI -The component has been tentatively identified based on mass spectral library search and has an estimated value
_
it
LAB Q
I
Laboratory Section» 1623 Mail Service Center, Raleigh, INC 27699-1623 [phone] Page 1 of 3

NC(D`WQ La6oratorySection [Results
Loudon ID' NC0003425APD1
Loc. Descr.: NC0003425APTDI
Visit ID
aeittpte temperature at receipt by Ieb 2.8
Collect Date:
Collect Time::
091012009
09:55
arvw
Melnad Reference grim
WET
Ion Chromatography
Method Reference
EPA 3tp.0
_TITLE_
mg/L
MIBRAHIMI
CGREEN
9/iN9
9/14M
Tatal D59dved Solidsin
liquid12
Method Reference
APHA3540C-18TH
720
mg/L
JSTALEV
MOVERMAN
Chloride
9209
99I09
Method Reference
EPA YJ0.0
1
62
mOtL
MIBRAHIMI
CGREEN
grim
9/14109
Fluoride
Method Reference
EPA 300.0
0.4
2.0
U,P
r)g/L
MIBRAHIMI
CGREEN
9/14109
Bulk"9/3m9
Method Reference
EPA 300,0
2
230
mw-
MIBRAHIMI
CGREEN
MET
grim
9I14I09
7440-224
Ag by ICPMS
5
Method Reference
EPA 200.8
5.0
U
bgll
DSTANLEY
ESTAFFORD
7429-90-5
AI by ICP
9/ism
923r109
Method Reference
EPA 200J
50
1900
ug/L
JJURGEVICH
ESTAFFORD
7440.38-2
A8 by ICPMS
921M
923m92
Method Reference
EPA 200.8
3.9
ug/L
BSKINNER
ESTAFFORD
7429-90-5
B by ICP
92IM9
923/09
Method Reference
EPA 200]
50
2300
ug/L
JJURGEVICH
ESTAFFORD
7440.
Be by ICP
921M
923I0938-]
Method Reference
EPA 200.7
10
210
ug/L
JJURGEVICH
ES TAFFORD
7440.11-7
Be by ICP
A'21M
92309
Method Reference
EPA 200J
5
'
5.0
U
ug/L
JJURGEVICH
ESTAFFORD
1440-70-2
Ca by ICP
921/09
923M
Method Reference
EPA 2(q.]
0.1
110
rtgrL
JJURGEVICH
ESTAFFORD
744043-9
CO by ICPMS
921/09
923/09
Method Reference
EPAMA
1
1'0
U
ug/L
DSTANLEY
ESTAFFORD
7440-IB-4
Cobalt by JCP
9116M
923N9
Method Reference
EPA 200.7
50
50
U
ug/L
JJURGEVICH
ESTAFFORD
144047-3
Cr by ICPMS
92IM9
923r09
Method Reference
EPA 200.8
10
10
U
ug/L
DSTANLEY
ESTAFFORD
7440.50-6
Cu by ICPMS
9116O9
923/p9
Method Reference
EPA 200.8
2
6.2
ug/L
DSTANLEY
ESTAFFORD
Laboratory Section>> 1623 Mail Service Center, Raleigh, NC 27699.1623 1919) 733-3908
9r16r09 923M9
Page 2 of 3

Location ID: NC0003425APD1
' ILoc. Descr.: NC0003425APTD1
Visit ID
CAS 9 AnalYte Name
7439-89-6 Fe by ICP
Method Reference EPA 2007
veaco-. e
WC(D'WQ La6oratorySection Resufts
0.2
Method Reference EPA245.1
K by ICP 0.1
Method Referenp EPA 2Dp.7
26000
0.20 U
25
25
L
Method Reference
Epp 20DJ
Mg b1' ICP
0.1
39
MethodReferenceEPA
2o0.7
Mn by ICP
0
2700
Method Reference
EPA 200J
MO by ICPMS
10
19
Method Reference
EPA 200.8
No by ICP
0.1
31
Method Reference
EPA 2007
NI by ICPMS
Method Reference
EPA 200.8
1 ct
10
U
Pb by ICPMS
Method Reference
EPA200.8
10
10
u
Sb by ICPMS
Method Reference
EPA 2008
t D
10
U
Se by ICPMS
Method Refxana
EPA200.8
5
5.0
U
in Dy ICPMS
10
10
U
Method Reference
EPA200.8
hallium (TO ICPMS
Melhce Reference
EPA 200.8
10
0
U
1 (TIIeNum) M ICP
Method Reference
EPA 2(p.]
10
78
by ICP
Method Refemrtee
EPA 200 ]
25
25
U
n by ICPMS
Method Reference
EPA 200.8
10
o
u
Laboratory Section>> 1623 Mail Service Center, Raleigh, NC 27699-1623 (9191733d908
Collect Date:
09/01/2009
Collect Time::
09:55
Analys VlJate
Approved By ID:
001E
JJURGEVICH
ESTAFFORO
921A19
923M
ug1L
JJURGEVICH
ESTAFFORD
%4/)9
923m
In01L
JJURGEVICH
ESTAFFORD
A'21109
923009
uyL
JJURGEVICH
ESTAFFORD
921109
923101)
n10IL
JJURGEVICH
ESTAFFORD
wlm9
923M
u9/L
JJURGEVICH
ESTAFFORD
921419
923M
ug/L
DSTANLEY
ESTAFFORD
W16M
923M
InOIL
JJURGEVICH
ESTAFFORD
9r21D9
923109
u0fL
DSTANLEY
ESTAFFORD
9'16M
923M
u9/L
DSTANLEY
ESTAFFORD
9/16N9
91223
u0/L
DSTANLEY
ESTAFFORD
W16109
923rV9
u0/L
BSKINNER
ESTAFFORD
921009
W3106
UT
DSTANLEY
ESTAFFORD
9116mg
923M
ug/L
DSTANLEY
ESTAFFORD
wism
923109
u0/L
JJURGEVICH
ESTAFFORO
921M
923M
uOIL
JJURGEVICH
ESTAFFORD
9121109
9231119
u9A-
DSTANLEY
ESTAFFORD
911699
923M
Page 3 of 3

COUNTY /`el&a
RIVER BASIN':
REPORTTO Q 9 i� Regional ORiee
Other
COLLECEOR(S)
Estimated BOD Range:
Se ;
It i
) _ 16-01
Chlorinated:_
Date Reg'n (YY/ym/JJ) Date
DIVISION OF 11VATER QUALITY
Chemialry laboratory Be,, I Water Quality
El SAMPLE PRIORITY
❑ AMBIENT QA ❑ STREAM
*FFLUCNT
COMPLIANCE CHAM OF CUSTODY LAKE
NlTcoapl,a gE ❑ ❑ INFLUENT
❑ EMERGENCY VISIT ID ❑ ESTUARY
Station Location: ti`�sfl PT.Vk LLJ
Remvhr: T 43 E4s4 {y Ic)
SKIS T�ne�M DePth - DM, DR. DBM
Valae TYPe-A, II,L
b361
I Numbe, ��
I)ar Rrcrmed � , 2 - o q
11mc Rocoivnl
Rccuvttl H, 9 I5
1
Uma Released
Date Reported
C—;mIte-T. S. B

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
August 27, 2009
Certified Mail # 7006 0810 0002 0649 6706
Return Receipt Requested
Mr. Harry Sideris
Plant Manager
Roxboro Steam Electric Power Plant
1700 Dunnaway Rd
Semora, NC 27343
Dear Mr. Sideris:
The North Carolina Division c
Electric Power Plant on 5/27/2
operating in compliance with thi
No. NC0003425 (currently there
■ Complete items 1, 2, and 3. Also com{
item 4 if Restricted Delivery is desired.
■ Print your name and address on the re
so that we can return the card to you.
■ Attach this card to the back of the me]
or on the front if space permits.
1. Article Addressed to:
MR. HARRY SIDERIS, PLANT MANAGER
ROXBORO STEAM ELECTRIC POWER P
1700 DUNNAWAY ROAD
SEMORA, NC 27343
CEI.NC0003425
ROXBORO.STEAM POWER PLNT PERSO
8/27/09 MAILED.W2M.S" HOBAN
A summary of the findings and
Page 2 of the attached copy of
Report'. Please provide a status 2. Article Number
letter regarding your plans or in (T a' fer hom sendoe /abed
the operations and maintenance PS Form 3811, February 2004
E
4
7006 0810 0002 60496706�
If you have any questions concerning this report, please contact me at 919-791-4247 in the Raleigh
Regional Office.
Sin c rely,
A tumn Hoban
Environmental Senior Specialist
Attachments
Cc: (w/o attachments) Mr. William Milan
1700 Dunaway Rd.
Semora, NC 27343
Ms. Dana Newcomb Mr. Shannon Langley
1700 Dunaway Rd. 410 S. Wilmington St. PEB 4
Semora, NC 27343 Raleigh, NC 27601
Cc: (w/attachments) Raleigh Regional Office — File
DWQ/Raleigh — Central Files and Stormwater Permitting Unit

r 60
Roxboro A,,.Sivairt Plant
3 Inspection 2009
1. Permit:
Your permit became effective May 1, 2007 and will not expire until March 31, 2012.
The facility is not currently under a Special Order by Consent, however, an
application for a Special Order by Consent was received on March 30, 2009.
The new FGD Bioreactor Treatment Unit started operations on February 2008. The
Raleigh Regional Once was notified of a structural stress of the FGD Settling Pond
on February 25, 2008, and subsequent dewatering started on February 28 2008 In
addition the RRO was notified of a collapse of a section of the FGD Flush Pond on
February 27, 2008. Additional monitoring in conjunction with the treatment unit
repairs noted above was requested by DWQ in a letter dated March 4 2008 and that
monitoring continues to date and remains in effect.
The permittee is reminded to read, understand and comply with all of the terms and
conditions contained in the permit. If you have questions concerning your
responsibilities, call the Raleigh Regional Office to speak to a Division of Water
Quality Surface Water staff member.
The facility filed a permit modification to discharge Reverse Osmosis (Low Volume
i Wastes) to internal outfall 002, and ultimately to Hyco Lake via final outfall 003.
This modification was approved on June 10, 2009. The Raleigh Regional Office has
( alerted the Technical Assistance and Certification Unit of the recent A to Cs and
permit modification A new classification to Physical Chemical II and Biolo icg al II
may be required Currently the faciliU classification is Physical Chemical I.
The facility currently has no stormwater requirements in this permit nor does the
facility have a separate individual stormwater permit The permit does report that
gypsum pile runoff stormwater (process stormwater) and stormwater are discharged
through the heated water discharge (outfall 003). Process stormwater will typically
prompt the need for a stormwater pollution prevention plan and other stormwater
requirements in the permit but as stated above the current permit does not have any
stormwater requirements.
The facility included two stormwater outfalls (SW -A and SW-B) on the NPDES Form
2F and described in attachment 6 and 7 of the application for renewal received by the
DWO RRO on October 2 2006 SW-B was reported as draining to the permitted
NPDES Wastewater Discharge Outfall 006 (Coal Pile Runoffl and SW -A was a
"proposed" Stormwater outer
2. Compliance Schedules:
The permit does not have any outstanding compliance schedules for this facility.
Page 2/8

m
Roib ja"ic. �m Plant
y nspection 2009
d
1. Permit:
Your permit became effective May 1, 2007 and will not expire until March 31, 2012.
The facility is not currently under a Special. Order by Consent, however, an
application for a Special Order by Consent was received on March 30, 2009.
The new FGD Bioreactor Treatment Unit started operations on February 2008. The
Raleigh Regional Office was notified of a structural stress of the FGD Settling Pond
on February 25 2008 and subsequent dewatering started on February 28, 2008- In
addition the RRO was notified of a collapse of a section of the FGD Flush Pond on
February 27 2008 Additional monitoring in conjunction with the treatment unit
repairs noted above was requested by DWO in a letter dated March 4, 2008 and that
monitoring continues to date and remains in effect.
The permittee is reminded to read, understand and comply with all of the terms and
conditions contained in the permit. If you have questions concerning your
responsibilities, call the Raleigh Regional Office to speak to a Division of Water
Quality Surface Water staff member.
The facility filed a permit modification to discharge Reverse Osmosis (Low Volume
Wastes) to internal outfall 002 and ultimately to Hyco Lake via final outfall 003.
This modification was approved on June 10 2009. The Raleigh Regional Office has
alerted the Technical Assistance and Certification Unit of the recent A to C's and
permit modification A new classification to Physical Chemical II and Biological II
may be required Currently the facility classification is Physical Chemical L
The facility currently has no stormwater requirements in this permit nor does the
facility have a separate individual stormwater permit The permit does report that
gypsum pile runoff stormwater (process stormwater) and stormwater are discharged
through the heated water discharge (outfall 003). Process stormwater will typically
prompt the need for a stormwater pollution prevention plan and other stormwater
requirements in the permit but as stated above the current permit does not have any
stormwater requirements.
The facility included two stormwater outfalls (SW -A and SW-B) on the NPDES Form
NPDES Wastewater Discharge Outfall 006 (Coal Pile Runof) and SW -A was a
"proposed" Stormwater outfall.
2. Compliance Schedules:
The permit does not have any outstanding compliance schedules for this facility.
Page 2/8

Roxboro Electric Steam Plant
Inspection 2009
3. Facility Site Review:
The overall condition of the plant site was satisfactory. The appearance of the facility
was in acceptable condition indicating that the current housekeeping practices are
very good.
4. Self-Monitorine Proaram:
You are reminded that your monitoring samples must be collected, preserved, and
analyzed by appropriate procedures and methods. You should maintain records of the
sampler temperature, and a certified laboratory must calibrate the sample
thermometers annually.
Your operator is reminded that he/she must keep a logbook of all
operation/maintenance activities undertaken at the facility. The logbook should
include all daily process control activities including any field measurements
conducted for process control. A visitation log for the facility must also be
maintained.
The facility is currently in compliance with these requirements
5. Records/Reuorts:
a) A review of the daily monitoring data submitted during the previous 12-month
period and a review of the permit conditions indicates the facility was in
compliance with the permit requirements and/or limitations for the period from
July 2008 to July 2009.
The facility was issued no penalty assessments and no notices of violation for the
12-month period from May 2008 to May 2009
b) The facility must designate a certified Operator -in -Responsible -Charge (ORC)
having a certification level equal to or greater than the facility classification. A
Back-up ORC must also be designated with a minimum certification level at least
one level less than the facility classification.
The facility is currently in compliance with these requirements This facility is
classified as a Physical Chemical I and the Operator in Responsible Charge
(ORO is Dana Newcomb and holds a Grade 11 Biological and Physical
Chemical I (Cert. 989334, 989611). William Milan is the back-up ORC and he
holds a Grade 2 Biological and Physical Chemical I Wert 28546 23490).
Page 3/8

s
Roxboro Electric Steam Plant
Inspection 2009
Mr. Steve Reid with the Division's Technical Assistance and Certification Unit
(TACU) is reviewing the current facility classification to determine if the facility
classification will chanPe to Biological 11 and possibly Physical Chemical H. The
TACU web site link is below ifvou have questions about facility classification and .
operator requirements :
http:Ilh2o. enr.state. nc. us/tacu/index. html
The ORC and the operators ofthis facility do an excellent iob.
The facility is currently in compliance with these requirements.
6. Laboratory:
For all analytical data submitted for compliance monitoring purposes, a certified
laboratory must be utilized for all laboratory analysis. Additionally, if field parameter
testing is conducted, an operator certified to perform the specified field parameter
analysis is also required. The operator needs to be sure to calibrate all
meters/instrumentation before each use and retain all calibration records.
The facility is currently in compliance with these requirements and utilizes the
Roxboro Plant lab field parameter certification # 5080 and ENCO Laboratory. Inc.
certified commercial laboratory # 591.
7. Flow Measurement:
If the permit requires a flow measurement device for determining the effluent flow,
the flow measurement device must be calibrated annually.
Outfa11003
water discharge) and the facility is in compliance with this requirement It was
explained that intake water meter calibrations are done annually as required
(Note: upon permit renewa4 this CWe of flow measurement should be reviewed as the
e uent flow is actually less at the )1nal outfall than the flow at the intake due to
process losses. Ideally, the flow at out all 002 as measured by a flow meter and
chart recording, and flow at the end of "heated water discharge" outfall 003 or (at
the heated water canal before it converges with other waste streams) as measured by
a flow meter and chart recording would be considered together for a total effluent
ow to outfall 003. This approach would seem a more accurate way to reflect actual
effluent flow, if logistically viable
Page 4/8

Roxboro Electric Stea Plant
Inspection 2009
Mr. Steve Reid with the Division's Technical Assistance and Certification Unit
(TACU) is reviewing the current facility classification to determine if the facility
classification will change to Biological II and possibly Physical Chemical II The
TACU web site link is below ifvou have questions about facility classification and
operator requirements :
hup: //h2o. enr. state. nc. us/tacOndex. html
The ORC and the operators ofthis facility do an excellent iob.
The facility is currently in compliance with these requirements.
6. Laboratory:
For all analytical data submitted for compliance monitoring purposes, a certified
laboratory must be utilized for all laboratory analysis. Additionally, if field parameter
testing is conducted, an operator certified to perform the specified field parameter
analysis is also required. The operator needs to be sure to calibrate all
meters/instrumentation before each use and retain all calibration records.
The facility is currently in compliance with these requirements and utilizes the
Roxboro Plant lab field parameter certification # 5080 and ENCO Laboratory, Inc.
certified commercial laboratory # 591.
7. Flow Measurement:
If the permit requires a flow measurement device for determining the effluent flow,
the flow measurement device must be calibrated annually.
Outfall003
water discharge) and the facility is in compliance with this requirement. It was
explained that intake water meter calibrations are done annually as required.
(Note: upon permit renewal, this We ofJlow measurement should be reviewed as the
effluent flow is actually less at the final outfall than the flow at the intake due to
process losses. Ideally, the flow at outfall 002 as measured by a flow meter and
chart recording, and flow at the end of "heated water discharge" outfall 003 or (at
the heated water canal before it converses with other waste streams) as measured by
a flow meter and chart recording would be considered together for a total effluent
ow to outfall 003. This approach would seem a more accurate way to reflect actual
effluent flow, if logistically viable).
Page 4/8

ft M
Roxboro Electric Steam Plant
Inspection 2009
Outfal1002
The facility monitors flow daily at outfall 002 (Ash Pond and outfall 010 FGD
treated combined flow) by open channel meter (v-notch weir and staff gauge), there is
also an ultrasonic flow meter that was calibrated in 2008, as required. Stormwater is
also discharged through the ash pond outfall 002, it was unclear if the stormwater is
"process stormwater" or just paved surfaces runoff.
Outfall 005
The facility monitors flow continuously "during discharge" at outfall 005 (Cooling
Tower Blowdown to Ash Pond) by effluent pump logs. A DMR review revealed that
no Chromium (Cr) or Zinc (Zn) data has been reported. Therefore it is the
understanding of the RRO that Cr and Zn are not added to the coolinP tower. As per
the permit, a composite sample is required for Total Chromium and Total Zinc twice
monthly at this outfall, ifZn and Cr are added by the permittee.
Please understand ifeffluent data is collected from any of your permitted outfalls you
are required to report the results. All effluent monitoring regardless of the permit
monitoring requirement must be reported.
Outfal1006
The facility estimates effluent flow twice per month at outfall 006 (Coal Pile Runoff
Treatment System to Hyco Reservoir). If samples of the effluent at outfall 006 have
been taken during this permit cycle (April 9. 2007 to present), please forward "all"
parameter results to the Raleigh Regional Office, if they have not already been sent in
with a Discharge Monitoring Report. If sample results were reported on the DMR,'
please note the DMR month these were reported. Please provide the operation and
maintenance plan utilized for the coal pile runoff treatment basin and the current
treatment (settling) efficiency that shows that the treatment basin is being_operated at
optimum efficiency.
Also near the coal pile treatment basin, and near the truck loading/truck wash by the
gypsum pile, we observed a sediment basin that is currently a requirement of the
sediment and erosion control permit from the Division of Land Quality for recent
construction activities. This basin was discharging stormwater, which is covered
under the NCG010000 general stormwater permit that is issued as part of the
sediment and erosion control permit. A NCG010000 inspection was not conducted
the day of this inspection. Observations of the basin indicated "maintenance " was
needed. The facility should review the requirements of the NCG010000 stormwater
permit and ensure compliance. Yyou have questions about this permit, please call
the Raleigh Regional Office.
Page 5/8

Roxboro Electric SteMNant
Inspection 2009
Outfall 008
The facility monitors effluent flow annually at outfall 008 (Domestic Wastewater to
the Ash Pond) by logs.
Outfall 009
The facility monitors flow once per discharge event at outfall 009 (cleaning metal
wastes). Once per discharge event, meaning the discharge from outfall 002 that
occurs within 30 minutes from the time the fly ash containing metal cleaning waste is
discharged into the ash pond plus the calculated detention time of the ash Pond.
Please forward the date of the last discharge and volume reported from outfall 009
and provide the calculated ash Pond detention time that was used to report the once
per discharge event at outfal1009.
Outfall 010
The acility is required to monitor treated FGD effluent (010) flow monthly by pump
log or similar reading. The facility has an inline flow meter at the bioreactor and is
reporting flow daily. It was explained that the flow meter is calibrated annually,
Effluent/Receivinz Waters:
The effluent discharge should be clear with a continuous flow with no visible changes
to the receiving waters.
The effluent discharge was clear and flow was continuous. The receiving waters
looked clear with no visible changes from the effluent discharge.
8. Pretreatment:
This facility currently has no pretreatment permit and does not accept or discharge
domestic or industrial waste to a sanitary sewer system.
9. Solids Handling/Disposal:
The facility must dispose of solids by an acceptable method such as a landfill or
utilize the services of an approved solids hauling and disposal contractor, which
requires the facility to be included under the contractor's non -discharge permit (i.e.
land application). The facility is reminded to maintain adequate records (i.e.
shipment dates, quantities, etc.) of any solids hauling and/or disposal activities.
The facility utilizes the Roxboro Steam Electric Plant Industrial Waste Landfill
permitted by NC Division of Waste Management, SWP# 73-02.
Page 6/8

Roxboro Electric Steam Plant •
Inspection 2009
Outfall 008
The facility monitors effluent flow annually at outfall 008 (Domestic Wastewater to
the Ash Pond) by pump logs.
Outfall 009
The facility monitors flow once per discharge event at outfall 009 (cleaning metal
wastes). Once per discharge event, meaning the discharge from outfall 002 that
occurs within 30 minutes from the time the fly ash containing metal cleaning waste is
discharged into the ash pond plus the calculated detention time of the ash pond.
Please forward the date of the last discharge and volume reported from outfall 009
and provide the calculated ash pond detention time that was used to report the once
per discharge event at outfall 009.
Outfall 010
The facility is required to monitor treated FGD effluent (010) flow monthly by pump
log or similar reading. The facility has an inline flow meter at the bioreactor and is
reporting flow daily. It was explained that the flow meter is calibrated annual
Effluent/Receivin¢ Waters:
The effluent discharge should be clear with a continuous flow with no visible changes
to the receiving waters.
The effluent discharge was clear and flow was continuous. The receiving waters
looked clear with no visible changes from the effluent discharge.
8. Pretreatment:
This facility currently has no pretreatment permit and does not accept or discharge
domestic or industrial waste to a sanitary sewer system.
9. Solids Handlina/Disuosal:
The facility must dispose of solids by an acceptable method such as a landfill or
utilize the services of an approved solids hauling and disposal contractor, which
requires the facility to be included under the contractor's non -discharge permit (i.e.
land application). The facility is reminded to maintain adequate records (i.e.
shipment dates, quantities, etc.) of any solids hauling and/or disposal activities.
The facility utilizes the Roxboro Steam Electric Plant Industrial Waste Landfill
Permitted by NC Division of Waste Management, SWP# 73-02.
Page 6/8

Roxboro Electric Steam Plant
Inspection 2009
11. Compliance Samplin¢:
Compliance sampling was not conducted during the inspection. However, sampling
data has been collected since March 2008 as requested by the RRO in the letter dated
March 4, 2008.
12. Operations & Maintenance:
a) Subsequent to a file review and site inspection. RRO does not have a clear
understanding of the following with regards to the ash pond:
1) current capacity of the treatment unit
2) available freeboard of the treatment unit
3) treatment unit design spectfications
4) operation and maintenance plan for the treatment unit
Please provide details regarding items (1-4) above for the ash pond in your
response.
Please provide the current sedimentation, oxidation, neutralization
equalization, and adsorption treatment efficiencies (ash pond treatments as
referenced in the request for minor permit modification letter dated Me 19.
2009 addressed to Mr. Vinzani) that show that the ash pond treatment basin is
being operated at optimum efficiency per permit requirement Part A Section
C Operation and Maintenance of Pollution Controls, (2) Proper Operation
and Maintenance.
b) Please provide the operation and maintenance plan utilized for the coal pile
runoff treatment basin and the current treatment (settling) efciency that shows
Controls). (2) Proper Operation and Maintenance.
c) Please forward the date of the last discharge and volume reported from outfall
009 and provide the calculated ash pond detention time that was used to report
the once per discharge event at outfal1009.
Page 7/8

Roxboro Electric Steam Plant
Inspection 2009
d) If samples of "any" effluent have been taken that were not required by the
current permit monitoring tables, please forward "all" effluent sampling results
or all parameters taken during this permit cycle (April 9, 2007 to present), if and
only if you have not already delivered the results to the Raleigh Regional Otrce
and/or attached the results to a monthly Discharge Monitoring Report (DMR).
e) The facility is in compliance with all permit requirements as of the date of this
inspection.
Please forward a response to items (a — d) above :
13. Compliance Status:
® Compliant ❑ Non -compliant ❑ Neither
Name and Signature of Inspector:
Water Protection Section
Regional Office
Date
Page 8/8

i 1
Roxboro Electric Steam Plant
Inspection 2009
d) If samples of "any" effluent have been taken that were not required by the
current permit monitoring tables please forward "all" effluent sampling results
for all parameters taken during this permit cycle (April 9 2007 to Present), if and
only if you have not already delivered the results to the Raleieh Regional Office
and/or attached the results to a monthly Discharge Monitoring Report (DMR).
e) The facility is in compliance with all permit requirements as of the date of this
inspection.
Pfease forty a reszvohse to items ( 4 t 1 'a' &Vol `�
13. Compliance Status:
® Compliant ❑ Non -compliant ❑ Neither
Name and Signature of Inspector:
Hob R manski Date
Water Protection Section
Regional Office
Page 8/8

6-7
Envir
Untied StateEnvironmental Protection Agency
es Envir
Form Approved,
ton, D C 20460
EPA
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 Uzi 2 i Ci 31 NC0003425 111 12I 09/05/27 117 18I C 19I cl 20U
l.J U U U
Remarks
21111111111111111111111111111111111111111111111116
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 CA --------Reserved- -----
67I 1 69 701 I 711 I 721 M I 731 I 174 751 1 1 1 1 1 1 1 80
LJ LJ LLJ
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time(Date
Permit Effective Date
POTW name and NPDES permit Number)
Roxboro Steam Electric Power Plant
09:30 AM 09/05/27
07/05/01
ExR Time/Date
Permit Expiration Date
Person County Rd 1377
Roxboro NC 27573
04:00 PM 09/05/27
12/03/31
Name(s) of Onsite Representative(s)/TRles(s)/Phone and Fax Number(s)
Other Facility Data
William Edward Milam/ORC/336-597-6284/
Name, Address of Responsible Official/Title/Phone and Fax Number
Harry R Sideris,1700 Dunaway Rd Semora NC 27343//336-597-1174/ Contacted
n
NO
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit E Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Compliance Schedules
Effluent/Receiving Waters Laboratory Storm Water
Section D: Summary of Finding/Comments Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspect ) /;(�//�q//_Lv Agency/Office/Phone and Fax Numbers Date n
Autumn Hoban /¢� a• PRO WQ/// ��27/�,Q /
Signa reof nagement O eviewer Agency/ ceJPhone and Fax Numbers Date
/ e
/lam!
EPA Form 3560-3 v 9-94) Previous editions are obsolete.
Page # 1

NPDES
yr/mo/day
N00003425 1
11 121 09/05/27 117
Inspection Type
18' C
(cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
General Information:
The domestic wastewater treatment units were not inspected on the day of this inspection.
new FGD scrubbers - all 4 on-line as of December 2008, Total volume to Bioreactor is approx. 1000 gpm
Flow through the bioreactor is measured with in -line flow meter.
It was explained that the flush/backwash schedule for the bioreactor has been increased from the original
schedule of semi-annually to one cell every month is flushed.
A to C to de -construct and re -construct FGD flush pond and re -construction of (west) FGD settling pond was
approved May 15, 2009.
A to C to construct new (east) FGD settling pond was approved on June 15, 2009.
A minor permit modification for the addition of Reverse Osmosis reject waste water to the ash pond was
approved on June 10, 2009.
The following items (a-d) require a response from the facility within 60 days of receipt of this inspection letter
dated August 27, 2009:
12. Operations & Maintenance:
a)Subsequent to a file review and site inspection, RRO does not have a clear understanding of the following
with regards to the ash pond:
1) current capacity of the treatment unit
2) available freeboard of the treatment unit
3) treatment unit design specifications
4) operation and maintenance plan for the treatment unit
Please provide details regarding items (1-4) above for the ash pond in your response.
Please provide the current sedimentation, oxidation, neutralization equalization, and adsorption treatment
efficiencies (ash pond treatments as referenced in the request for minor permit modification letter dated May
19, 2009 addressed to Mr. Gil Vinzani) that show that the ash pond treatment basin is being operated at
optimum efficiency per permit requirement Part Ii, Section C Operation and Maintenance of Pollution
Controls, (2) Proper Operation and Maintenance.
b)Please provide the operation and maintenance plan utilized for the coal pile runoff treatment basin and the
current treatment (settling) efficiency that shows that the treatment basin is being operated at optimum
efficiency per permit requirement Part II, Section C Operation and Maintenance of Pollution Controls), (2)
Proper Operation and Maintenance.
Page # 2

a t
NPDES yr/mo/day Inspection Type (cont.) 1
3I NC0003425 I11 12I 09/05/27 117 18 UC
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
General Information:
The domestic wastewater treatment units were not inspected on the day of this inspection.
new FGD scrubbers - all 4 on-line as of December 2008, Total volume to Bioreactor is approx. 1000 gpm
Flow through the bioreactor is measured with in -line flow meter.
It was explained that the flush/backwash schedule for the bioreactor has been increased from the original
schedule of semi-annually to one cell every month is flushed.
A to C to de -construct and re -construct FGD flush pond and re -construction of (west) FGD settling pond was
approved May 15, 2009.
A to C to construct new (east) FGD settling pond was approved on June 15, 2009.
A minor permit modification for the addition of Reverse Osmosis reject waste water to the ash pond was
approved on June 10, 2009.
The following items (a-d) require a response from the facility within 60 days of receipt of this inspection letter
dated August 27, 2009:
12. Operations & Maintenance:
a)Subsequent to a file review and site inspection, RRO does not have a clear understanding of the following
with regards to the ash pond:
1) current capacity of the treatment unit
2) available freeboard of the treatment unit
3) treatment unit design specifications
4) operation and maintenance plan for the treatment unit
Please provide details regarding items (1-4) above for the ash pond in your response.
Please provide the current sedimentation, oxidation, neutralization equalization, and adsorption treatment
efficiencies (ash pond treatments as referenced in the request for minor permit modification letter dated May
19, 2009 addressed to Mr. Gil Vinzani) that show that the ash pond treatment basin is being operated at
optimum efficiency per permit requirement Part ll, Section C Operation and Maintenance of Pollution
Controls, (2) Proper Operation and Maintenance.
b)Please provide the operation and maintenance plan utilized for the coal pile runoff treatment basin and the
current treatment (settling) efficiency that shows that the treatment basin is being operated at optimum
efficiency per permit requirement Part II, Section C Operation and Maintenance of Pollution Controls), (2)
Proper Operation and Maintenance.
Page # 2

Permit: NC0003426 Owner - Facility: Roxboro Steam Electric Power Plant
Inspection Date: 05/2712009 Inspection Type: Compliance Evaluation
c)Please forward the date of the last discharge and volume reported from outfall 009 and provide the
calculated ash pond detention time that was used to report the once per discharge event at outfall 009.
d)lf samples of "any" effluent have been taken that were not required by the current permit monitoring
tables, please forward "all" effluent sampling results for all parameters taken during this permit cycle (April 9,
2007 to present), if and only if, you have not already delivered the results to the Raleigh Regional Office
and/or attached the results to a monthly Discharge Monitoring Report (DMR).
The facility is in compliance with all permit requirements as of the date of this inspection.
Page # 3

Permit: NC0003425 owner - Facility: Roxboro Steam Electric Power Plant
Inspection Date: 05/27/2009 Inspection Type: Compliance Evaluation
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application? ❑ ❑ ■ ❑
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
is the inspector granted access to all areas for inspection?
Comment:
Compliance Schedules
Is there a compliance schedule for this facility?
Is the facility compliant with the permit and conditions for the review period?
Comment:
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping?
Yes No NA NE
0 0 M 0
❑ D 0 D
Yes No NA NE
■ ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MISS, MCRT, Settleable Solids, pH, DO, Sludge ■ ❑ ❑ ❑
Judge, and other that are applicable?
Comment: A response was requested regarding the operations and maintenance of
treatment units. The details are in the inspection letter dated August 27, 2009.
Flow Measurement - Influent
Yes
No
NA
NE
# Is flow meter used for reporting?
O
Q
❑
■
Is flow meter calibrated annually?
❑
n
n
■
Is the flow meter operational?
❑
❑
❑
■
(If units are separated) Does the chart recorder match the flow meter?
n
❑
❑
■
Comment: Flow is measured at the intake by pump logs. This flow is being reported
as effluent flow per the current outfall 003 effluent flow permit requirement.
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
❑
❑
❑
Is flow meter calibrated annually?
■
n
❑
n
Is the flow meter operational?
■
n
n
❑
(If units are separated) Does the chart recorder match the flow meter?
■
❑
00
Page # 4

41* 1-0
Permit: NC0003425 Owner - Facility: Roxboro Steam Electric Power Plant
Inspection Date: 05/27/2009 Inspection Type: Compliance Evaluation
Permit
Yes
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
❑
❑
■
❑
Is the facility as described in the permit?
■
❑
❑
❑
# Are there any special conditions for the permit?
❑
❑
■
❑
Is access to the plant site restricted to the general public?
M
❑
❑
❑
Is the inspector granted access to all areas for inspection?
■
❑
❑
❑
Comment:
Compliance Schedules
Yes
No
NA
NE
Is there a compliance schedule for this facility?
❑
❑
0
❑
Is the facility compliant with the permit and conditions for the review period? ❑ ❑ E ❑
Comment:
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ ❑ ❑ ❑
Judge, and other that are applicable?
Comment: A response was requested regarding the operations and maintenance of
treatment units. The details are in the inspection letter dated August 27, 2009.
Flow Measurement - Influent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment: Flow is measured at the intake by pump logs. This flow is being reported
as effluent flow per the current outfall 003 effluent flow permit requirement.
Flow Measurement - Effluent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Yes No NA NE
■❑❑❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
Page # 4

U
Permit: NC0003425 Owner - Facility: Roxboro Steam Electric Power Plant
inspection Date: 05/27/2009 Inspection Type: Compliance Evaluation
Chemical Feed
Yes No NA NE
Is containment adequate?
D D D
Is storage adequate?
D D D ■
Are backup pumps available?
D D D ■
Is the site free of excessive leaking?
D n M ■
Comment: A request was made for approval to run a chemical trial at the FGD
gypsum settling pond and to my knowledge this trial has not yet been ran to date. The
proposal was to add a flocculant, GE Betz NOVUS CE2688 and a polymer product, GE
Betz METCLEAR MR2405 to the pond.
The RRO (Barry Hertzberg and Autumn Hoban) forwarded comments in an e-mail dated
February 19, 2009 to Shannon Langley of Progress Energy concerning the trial request.
Primary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
0
O
■
D
Is the site free of excessive buildup of solids in center well of circular clarifier?
D
D
■
D
Are weirs level?
D
D
■
D
Is the site free of weir blockage?
D
❑
■
D
Is the site free of evidence of short-circuiting?
D
D
■
D
Is scum removal adequate?
D
D
■
D
Is the site free of excessive floating sludge?
D
D
■
D
Is the drive unit operational?
❑
❑
■
❑
Is the sludge blanket level acceptable?
D
D
■
D
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth)
D
D
■
D
Comment: There is currently no clarifier being used to treat FGD or other industrial
waste streams.
Pumps-RAS-WAS
Yes
No
NA
NE
Are pumps in place?
D
D
■
D
Are pumps operational?
n
n
■
D
Are there adequate spare parts and supplies on site?
D
D
■
D
Comment:
Sequencing Batch Reactors
Yes
No
NA
NE
Type of operation:
Is the reactor effluent free of solids?
D
D
D
■
Page # 8

L
Permit: NC0003425 Owner - Facility: Roxboro Steam Electric Power Plant
Inspection Date: 05/27/2009 Inspection Type: Compliance Evaluation
Chemical Feed
Yes No NA NE
Is containment adequate?
❑ ❑ ❑ ■
Is storage adequate?
❑ ❑ ❑ ■
Are backup pumps available?
❑ ❑ ❑ ■
Is the site free of excessive leaking?
❑ ❑ ❑ ■
Comment: A request was made for approval to run a chemical trial at the FGD
gypsum settling pond and to my knowledge this trial has not yet been ran to date. The
proposal was to add a flocculant, GE Betz NOVUS CE2688 and a polymer product, GE
Betz METCLEAR MR2405 to the pond .
The RRO (Barry Hertzberg and Autumn Hoban) forwarded comments in an e-mail dated
February 19, 2009 to Shannon Langley of Progress Energy concerning the trial request.
Primary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
❑
❑
■
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
❑
❑
■
❑
Are weirs level?
❑
❑
■
❑
Is the site free of weir blockage?
❑
❑
■
❑
Is the site free of evidence of short-circuiting?
❑
❑
■
❑
Is scum removal adequate?
❑
❑
■
❑
Is the site free of excessive floating sludge?
❑
❑
■
❑
Is the drive unit operational?
❑
❑
■
❑
Is the sludge blanket level acceptable?
❑
❑
■
❑
Is the sludge blanket level acceptable? (Approximately '/4 of the sidewall depth)
❑
❑
■
❑
Comment: There is currently no clarifier being used to treat FGD or other industrial
waste streams.
Pumps-RAS-WAS
Yes
No
NA
NE
Are pumps in place?
❑
❑
■
❑
Are pumps operational?
❑
❑
■
❑
Are there adequate spare parts and supplies on site?
❑
❑
■
❑
Comment:
Sequencing Batch Reactors
Yes
No
NA
NE
Type of operation:
Is the reactor effluent free of solids?
❑
❑
❑
■
Page # 8

Permit: NC0003425 Owner - Facility: Roxboro Steam Electric Power Plant
Inspection Date: 05127/2009 Inspection Type: Compliance Evaluation
Record Keeping
Yes
No
NA
NE
Is the ORC certified at grade equal to or higher than the facility classification?
■
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
■
❑
n
❑
Is a copy of the current NPDES permit available on site?
■
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
Q
❑
■
Comment: Record keeping was not reviewed at this inspection.
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
■
❑
❑
❑
Are all other parameters(exciuding field parameters) performed by a certified lab?
■
n
n
n
# Is the facility using a contract lab?
■
n
n
n
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
❑
❑
❑
■
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
n
❑
❑
■
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
Q
■
Comment: The facility is in compliance with laboratory requirements and utilizes the
Roxboro Plant Lab field parameter certification #5080 and ENCO Laboratory, Inc.
certfied commercial laboratory #591.
Page # 10

I
'try
Permit: NC0003425 Owner - Facility: Roxboro Steam Electric Power Plant
Inspection Date: 05/27/2009 Inspection Type: Compliance Evaluation
Record Keeping
Yes
No
NA
NE
Is the ORC certified at grade equal to or higher than the facility classification?
■
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
■
❑
❑
❑
Is a copy of the current NPDES permit available on site?
■
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
❑
■
Comment: Record keeping was not reviewed at this inspection.
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
■
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
■
❑
❑
❑
# Is the facility using a contract lab?
■
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
❑
❑
❑
■
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/_ 0.2 degrees?
❑
❑
❑
■
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
❑
■
Comment: The facility is in compliance with laboratory requirements and utilizes the
Roxboro Plant Lab field parameter certification #5080 and ENCO Laboratory, Inc.
certfied commercial laboratory #591.
Page # 10

E-mail correspondence to and fro,,, ...is address may be subject to the North C— -,.no Public Records law and may be
disclosed to third parties.
From: Hoban, Autumn
Sent: Wednesday, July 29, 2009 5:06 PM
To: Mckay, James
Subject: RE: Draft of Minor Modifications to Progress Energy's Mayo Plant
Jim,
So the facility is currently considered grade 1 (PC-1)physical chemical and grade II biological?
Just checking, since operators have only PC-1 certification and do not have a PC-2. They do all have the grade II
biological certification. Should I check with TACU?
Thanks again for your assistance.
Autumn
From: Mckay, James
Sent: Wednesday, July 29, 2009 4:27 PM
To: Hoban, Autumn
Subject: RE: Draft of Minor Modifications to Progress Energy's Mayo Plant
Autum,
Yes, I used Class and should have used Grade. The cheat sheet I use says for Physical/ Chemical Pollution Control
Treatment Systems, Grade I is Primary physical process, while Grade II is Primary chemical process, and includes
reverese osmosis, electrodialysis, and ultrafiltration. Grade II is much more complicated than Grade I.
A Grade II Biological WWTP has Activated sludge or fixed growth with flow less than or equal to 0.5 MGD. The
domestic WWTP would probably be Grade 11.
The reason the Grade level is mentioned is because we have been asked to send all drafts to the TACU for review, so
they can check on the ORC grade requirements, and see if the facility is properly Graded.
Thank you for your prompt review.
Jim McKay, Environmental Engineer
NC DENR / Division of Water Quality / Surface Water Protection Section
Point Source Branch
1617 Mail Service Center, Raleigh, NC 27699-1617
919/807-6404 (work); 919/807-6495 (fax)
"Please note, my email address has changed to [e-mail]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records law and may be
disclosed to third parties.
From: Hoban, Autumn
Sent: Wednesday, July 29, 2009 3:52 PM

To: Mckay, James
Subject: RE: Draft of Minor Modifications to Progress Energy's Mayo Plant
Jim,
Thank you for clarifying the wording for Condition A. 4. 1 think it reads clearly now.
Thank you for setting the flow frequency to weekly at outfall 009, such to allow a flow reading that would be recorded at
the same frequency as the samples that are to be collected. This assists RRO with analysis of the data results.
Only one other comment. The second page of the draft permit Mod says this facility is rated a Class I Wastewater
Treatment facility. (Is this the same as grade I Physical Chemical Water Pollution Control System, or does this reflect
"wastewater treatment facility grading based on flow", which may be different?)
During a recent inspection, I had noted that the facility is classified as a grade I Physical Chemical Water Pollution
Control System (and a grade II Biological Water Pollution Control System.) I do not know if this matters, just thought I'd
let you know, I have gotten confused by classifications before.
Reference:
ISA NCAC OBG.0306 CLASSIFICATION OF PHYSICAL/CHEMICAL WATER POLLUTION CONTROL TREATMENT SYSTEMS
(a) Any water pollution mntml system, Including systems designed for Me remediation of oomaminated groundwater, that utilizes a primarily physical process to treat wastewaters is classi0ed
as a Grade I Physical/Chemical Water Pollution Control System.
(b) Any water pollutlon control system Mat utilizes a primarily Chem"[ process to treat wastewaters, Including those systems whose treatment processes are augmented by physical processes,
is classified as a Grade II Physical/Chemical Water Pollution Control System. Any reverse osmoels, electrodialysls, andI A NCAC GBG .0302 CLASSIFICATION OF BIOLOGICAL
WATER POLLUTION CONTROL TREATMENT SYSTEMS
(a) O e following discharging systems tee assigned a classification of Grade I Biological Water Pollution Control System unless the permitted flow, or operational complexity of Me system
requires a higher classification:
(1) septic tank/sand filter systems;
(2) biological lagoon systems; and
(3) constructed wetlands and assotlMed appurtenances.
(b) Systems Mat utlllae an activated sludge or Fixed growth Process with a permittetl now less than or equal to 0.5 millon gallons per day (mgd) are assigned Me classification of Grade II
Biological Water Pollution Control System.
ultraflltration system Is dassified as a Grade II Physical/Chemical Water Pollution Control System.
Thanks again
Sincerely,
Autumn
From: Mckay, James
Sent: Wednesday, July 29, 2009 1:20 PM
To: Smith, Danny; Hoban, Autumn; Jones, Jennifer; Massengale, Susan; Pugh, James L.
Subject: Draft of Minor Modifications to Progress Energy's Mayo Plant
Attached is a copy of the draft permit modification for PEC's Mayo plant. It adds Stormwater Outfall 010 due to using
the plant access road as a haul road for trucks carrying limestone and gypsum, which is a new industrial use of the road.

The Stormwater Permitting Unit...---! a substantial update to the stormwate. r_. tion of the permit to bring it up to
current practices. We also modified the Supplement to Permit Cover Page to incorporate reject water from a Reverse
Osmosis water treatment unit to the low volume wastes. Footnotes were corrected on Special Condition A.(4) to clarify
the compliance schedule for mercury.
These changes are considered to be a minor modification, so no public notice will be posted. Please send all comments
and questions to me within 30 days.
Jim McKay, Environmental Engineer
NC DENR / Division of Water Quality / Surface Water Protection Section
Point Source Branch
1617 Mail Service Center, Raleigh, NC 27699-1617
919/807-6404 (work); 919/807-6495 (fax)
"Please note, my email address has changed to [e-mail]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records law and may be
disclosed to third parties.

E-mall correspondence to and from this ___.-ss maybe subject to the North Carolina Public t.___. _'s Law and maybe disclosed to third parties.
From: Hoban, Autumn
Sent: Monday, August 24, 2009 2:01 PM
To: Reid, Steve
Subject: FW: Draft of Minor Modifications to Progress Energy's Mayo Plant -Question for TACU
Steve,
I am forwarding an e-mail correspondence that Jim McKay and I were having concerning the wastewater classification of
Mayo Electric Steam Plant NC 0038377 in Roxboro.
During a recent inspection, I confirmed that operators were certified as PC I and Biological II and that the plant is
classified as PC-1 and Biological II.
The new FGD bioreactor was installed and started operation in June 2009. As I understand it, ORC Michael Talley, will be
operating the bioreactor wastewater treatment unit (advanced biological treatment unit) and he does hold a biological
II, so I guess this is adequate best I can tell from the NCAC language.
But, the plant recently requested through A to C/also part of minor permit modification to add reverse osmosis, and the
reverse osmosis unit rejects will go to the Ash Pond, so does that change the classification from PC —1 to PC-11?
The sister plant Roxboro Electric Steam Plant NC0003425 in Semora is classified as a PC-1 only?
This seems incorrect, since the facility is 4 time the size of Mayo, and has the same wastewater treatment units (FGD
bioreactor). I think it should be wastewater II as well. The plant also got an A to C approval for addition of reverse
osmosis, and the rejects will go to the Ash Pond. Would this move them up to PC -II? Roxboro's ORC's have wastewater
II certifications currently, but not PC-11.
Any assistance you can provide on these questions would be greatly appreciated.
Sincerely,
Autumn Hoban-Romanski
From: Mckay, James
Sent: Thursday, July 30, 2009 10:50 AM
To: Hoban, Autumn
Subject: RE: Draft of Minor Modifications to Progress Energy's Mayo Plant
I do not know. Do check with TACO.
Jim McKay, Environmental Engineer
NC DENR / Division of Water Quality / Surface Water Protection Section
Point Source Branch
1617 Mail Service Center, Raleigh, NC 27699-1617
919/807-6404 (work); 919/807-6495 (fax)
*'"Please note, my email address has changed to [e-mail]

Thanks,
Autumn
From: Hoban, Autumn
Sent: Friday, August 28, 2009 1:22 PM
To: Reid, Steve
Subject: RE: Draft of Minor Modifications to Progress Energy's Mayo Plant -Question for TACU
Steve,
Thanks for the reply. I will a -mail James Pugh with the justification information regarding these two facilities
classification.
Sincerely,
Autumn
From: Reid, Steve
Sent: Friday, August 28, 2009 10:04 AM
To: Hoban, Autumn
Cc: Pugh, James L.
Subject: RE: Draft of Minor Modifications to Progress Energy's Mayo Plant -Question for TACU
Autumn -
I'll comment on the Biological portion of your inquiry and let James address the P/C issue.
If I understand you correctly, you have a concern that the 2 Biological plants with similar treatment technologies are
classified differently. If you will send a request to reclassify the facility in question, including justification, I will be glad to
evaluate it and reclassify, including notification to the permittee. It appears to me that your assessment of the situation is
correct and both facilities should be classified as P/C 2 and Biological 2. Again, I will allow James to comment on the P/C
issue.
Thanks
sr
Steve Reid, Extension Education & Training Specialist
NCDENR, DWQ Technical Assistance & Certification Unit
919.733.0026 x314
** Please note new email address; [e-mail] **
219 E. North St. (physical)
Raleigh NC 27601
1618 Mail Service Center (mailing)
Raleigh, NC 27699-1618
919.733.1338 (fax)
http://ncwaterquality.org/tacu

plk�lRS ON
COUNTY
July 21, 2009
Cliff Reynolds
Contract Performance Specialist
CSD Real Estate-Projects/Property
Progress Energy Services Company, LLC
410 S. Wilmington St.
PEB3C4
Raleigh, NC 27601
RE: Roxboro Plant/ New Maintenance Building
Dear Mr. Reynolds:
ensuring a healthy environment
R,EcENED
JUL 2 3 2009
DENR , WATER 0U'4 tY
POINT SOURCE BRANCH
As we discussed today, the Roxboro Plant is served by a wastewater system that discharges treated effluent and
a public water supply. Both the wastewater system and water supply are permitted by the North Carolina
Department of Environment and Natural Resources. The Person County Health Department has no regulatory
responsibility or oversight with respect to these systems. Therefore, approval from the Health Department is
not required before initiating construction at the Roxboro Plant. However, approval from the appropriate State
permitting agencies may be required.
Please let us know if we can be of any assistance.
Sincerely,
Harold Kelly
Environmental Health Supervisor
cc: Person County Building Inspections
Person County Planning and Zoning
610h Carolina DENR, Division of Water Quality
3& 21 za
D/=�� �1�.
l�') R"c7
phone [phone]
fax [phone]
325 South Morgan Street, Suite C, Roxboro, NC 27573

V
2G(iL(;E BhW
DENIS • #o/I ELI onvniA
CN
iSECE1AED

NC®ENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Division of Water Quality
Coleen H. Sullins
Director
June 15, 2009
Mr. Harry Sideris, Plant Manager
Progress Energy Carolinas, Inc., Roxboro Steam Plant
1700 Dunnaway Road
1._
Semora, North Carolina 27343
SUBJECT: Authorization to Construct
A to C No. 003425A06
Progress Energy Carolinas, Inc.
Roxboro Steam Plant
New Gypsum Settling Pond
Person County
Dear Mr. Sideras:
Dee Freeman
Secretary
i7
A letter of request for Authorization to Construct was received March 11, 2009, by the
Division, and final plans and specifications for the subject project have been reviewed and found
to be satisfactory. Authorization is hereby granted for the construction of modifications to the
existing Roxboro Steam Plant FGD Wastewater System, with discharge of treated effluent from
the FGD Wastewater Treatment System (Internal Outfall 010) into the Ash Pond Discharge
Canal (Internal Outfall 002), which discharges to the Heated Water Discharge Canal, which
discharges to Hyco Lake (Outfall 003) in the Roanoke River Basin.
This authorization results in no increase in design or permitted capacity and is awarded
for the construction of the following specific modifications:
Construction of a new FGD (East) Setting Pond with approximate new volume of
22 MG, to include construction of the pond liner system with a geotextile, 1-foot
thick clay layer, and 60 mil LLDPE synthetic liner, a floating water intake with
associated yard piping and appurtenances; and construction of a new toe drain
around the northern and eastern side of the East Settling Pond, in conformity with
the project plans, specifications, and other supporting data subsequently filed and
approved by the Department of Environment and Natural Resources.
This Authorization to Construct is issued in accordance with Part III, Paragraph A of
NPDES Permit No. NC0003425 issued April 9, 2007, and shall be subject to revocation unless
the wastewater treatment facilities are constructed in accordance with the conditions and
limitations specified in Permit No. NC0003425.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One
Location: 512 N. Salisbury St. Ralegh, North Carolina 27604 NO hCarolina
Phone: [phone]'' FAX: [phone] \ Customer Service: 1-677-623-6748 Rurally
Internet: www.ncwaterquality.org atLurQ`L //
An Equal Opporlunity � ANimmmol Acton Employer ;/

t
Mr. Harry Sideris, Plant Manager
June 15, 2009
Page 2
The sludge generated from these treatment facilities must be disposed of in accordance
with G.S. 143-215.1 and in a manner approved by the Division.
In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, the Permittee shall take immediate corrective action, including those as may
be required by the Division, such as the construction of additional or replacement wastewater
treatment or disposal facilities.
The Raleigh Regional Office, telephone number [phone], shall be notified at least
forty-eight (48) hours in advance of operation of the installed facilities so that an on site
inspection can be made. Such notification to the regional supervisor shall be made during the
normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State
Holidays.
Upon completion of construction and prior to operation of this permitted facility, a
certification must be received from a professional engineer certifying that the permitted facility
has been installed in accordance with the NPDES Permit, this Authorization to Construct and the
approved plans and specifications. Mail the Certification to: Construction Grants & Loans,
DWQ/DENR, 1633 Mail Service Center, Raleigh, NC 27699-1633.
Upon classification of the facility by the Certification Commission, the Permittee shall
employ a certified wastewater treatment plant operator to be in responsible charge (ORC) of the
wastewater treatment facilities. The operator must hold a certificate of the type and grade at
least equivalent to or greater than the classification assigned to the wastewater treatment
facilities by the Certification Commission.
The Permittee must also employ a certified back-up operator of the appropriate type and
grade to comply with the conditions of T15A:8G.0202. The ORC of the facility must visit each
Class I facility at least weekly and each Class IT, III and IV facility at least daily, excluding
weekends and holidays, must properly manage the facility, must document daily operation and
maintenance of the facility, and must comply with all other conditions of T15A:8G.0202.
A copy of the approved plans and specifications shall be maintained on file by the
Permittee for the life of the facility.
During the construction of the proposed additions/modifications, the permittee shall
continue to properly maintain and operate the existing wastewater treatment facilities at all times,
and in such a manner, as necessary to comply with the effluent limits specified in the NPDES
Permit.

Mr. Harry Sideris, Plant Manager
June 15, 2009
Page 3
You are reminded that it is mandatory for the project to be constructed in accordance
with the North Carolina Sedimentation Pollution Control Act, and when applicable, the North
Carolina Dam Safety Act. In addition, the specifications must clearly state what the contractor's
responsibilities shall be in complying with these Acts.
Prior to entering into any contract(s) for construction, the recipient must have obtained all
applicable permits from the State.
Failure to abide by the requirements contained in this Authorization to Construct may
subject the Permittee to an enforcement action by the Division in accordance with North
Carolina General Statute 143-215.6A to 143-2I5.6C.
The issuance of this Authorization to Construct does not preclude the Permittee from
complying with any and all statutes, rules, regulations, or ordinances which may be imposed by
other government agencies (local, state, and federal) which have jurisdiction.
One (1) set of approved plans and specifications is being forwarded to you. If you have
any questions or need additional information, please contact Seth Robertson, P.E. at telephone
number [phone].
Sincerely,
/sy. 8
/Col
een H. Sullins
kp:sr
cc: Jon A. Winterhalter, P.E. — Parsons E & C, 2675 Morgantown Road, Reading, PA 19607
Person County Health Department
DWQ Raleigh Regional Office, Surface Water Protection
DWQ, Technical Assistance and Certification Unit
DWQ, Point Source Branch, NPDES Program
Ken Pohlig, P.E.
ATC File

Progress Energy Carolinas, Inc.
Roxboro Steam Station
A To C No. 003425A06
Issued June 15, 2009
Engineer's Certification
I, , as a duly registered Professional Engineer in the
State of North Carolina, having been authorized to observe (periodically/weekly/full time) the
construction of the modifications and improvements to the Roxboro Steam Plant FGD
Wastewater System, located on NCSR 1377 in Person County for Progress Energy, hereby state
that, to the best of my abilities, due care and diligence was used in the observation of the
following construction:
Construction of a new FGD (East) Settling Pond with approximate new volume of
22 MG, to include construction of the pond liner system with a geotextile, 1-foot
thick clay layer, and 60 mil LLDPE synthetic liner, a floating water intake with
associated yard piping and appurtenances; and construction of a new toe drain
around the northern and eastern side of the East Settling Pond, in conformity with
the project plans, specifications, and other supporting data subsequently filed and
approved by the Department of Environment and Natural Resources.
I certify that the construction of the above referenced project was observed to be built within
substantial compliance and intent of the approved plans and specifications.
Signature
Date
Registration No._
Send to: Construction Grants & Loans
DENR/DWQ
1633 Mail Service Center
Raleigh, NC 27699-1633

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
June 10,2009
Harry Sideris, Plant Manager
Roxboro Steam Electric Plant
1700 Dunaway Road
Semora, North Carolina 27343
Subject: Permit Modification for Reverse Osmosis
NPDES Permit NCO003425
Roxboro Steam Electric Plant
1700 Dunaway Road
Jmb�rfan3 County
Dear Mr. Sideris: loiLA50x-- 1/
The Division of Water Quality (the Division) has reviewed your request to add a reverse osmosis (RO) water
treatment system to the subject facility. Your request is hereby granted and is effective immediately. Please
insert the attached change -pages into your existing permit and discard the old pages.
We understand that you propose to discharge RO wastes as `low -volume wastes" via internal Outfall 002,
ultimately to Hyco Lake via final Outfall 003. Based on your reported flow at Outfall 003 (1,060 MGD) and
your proposed RO volume (0.360 MGD), the Division estimates that this new waste constitutes 3.36 x 104 % of
your average daily discharge to the natural environmcnt:
Considering the proposed volume and concentrations of RO parameters of concern, the Division judges the
potential impact to the environment to be insignificant. Therefore, per your request received May 22, 2009, we
have added reference to the new RO system on the permit Supplement to Cover Sheet, but have made no
additional changes to the permit.
The Division of Water Quality issues this permit modification pursuant to the requirements of North Carolina
General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S.
Environmental Protection Agency dated October 2007, or as subsequently amended. All active permit
parameters and monitoring conditions remain in effect. If you have questions or concerns about this
modification, please email Joe Corporon [e-mail]], or call [phone].
Respectfully,
Coleen H. Sullins
Enclosure: NPDES permit modification pages - NC0003425
cc: Raleigh Regional Office/Surface Water Protection Section
NPDES Program
Aquatic Toxicology Unit, Attn: Susie Meadows e wnrF9
EPA Region 4, Attn: Marshall Hyatt
o
1617 Mail Service Center, Ralegh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleoh, North Carolina 27604
Phone: 9M807E3001 FAX: [phone] Customer Service:1-877-623-6748
Internet www.nmaterqual4.org
Nunilly
eCarolina
An Equal Opportunity 1 Alfinndw Action Employer

It
Permit NC0003425
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
NPDES
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Carolina Power and Light Company d/b/a/ Progress Energy
Carolinas, Inc.
is hereby authorized to discharge wastewater from a facility located at the
Roxboro Steam Electric Generating Plant
NCSR 1377 near Roxboro
Person County
to receiving waters designated as Hyco Lake in the Roanoke River Basin in accordance with
effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II,
III and IV hereof.
This permit shall become effective .Tune 10, 2009.
This permit and the authorization to discharge shall expire at midnight on March 31, 2012.
Signed this day June 10, 2009.
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

1
Permit NC0003425
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked.
As of this permit issuance, any previously issued permit bearing this number is no longer effective.
Therefore, the exclusive authority to operate and discharge from this facility arises under the permit
conditions, requirements, terms, and provisions included herein.
Carolina Power & Light Company d/b/a Progress Energy Carolinas,
Inc.
is hereby authorized to:
1. Continue to operate the following systems located at Roxboro Steam Electric
Generating Plant off NCSR 1377 near Roxboro in Person County.
• Ash Pond Treatment System (Internal Outfall 002). To treat ash transport, low
volume wastewater including Reverse -Osmosis (RO) wastewater, runoff from the
ash landfill, dry fly -ash handling system wash water, coal pile runoff silo wash
water, storm water runoff, cooling tower blowdown from unit number 4, and
domestic sewage treatment plant effluent. Effluent from the ash pond discharges to
the heated water discharge canal, and is ultimately released into Hyco Lake
through Outfall 003.
• Heated Water Discharge Canal System (Outfall 003). At the point that the
discharge canal enters Hyco Lake, it contains flow from several waste streams
including; once -through cooling water, stormwater runoff, and the effluent from the
ash pond (Outfall 002).
• Cooling Tower Blowdown System (Internal Outfall 005). Cooling tower
blowdown from unit number 4 discharges into the ash transport system, and
ultimately flows into the ash pond (Outfall 602).
• Coal Pile Runoff Treatment System (Outfall 006). This system handles runoff
from the coal pile and other coal handling areas, including the limestone and
gypsum piles and the truck wheel -wash water. These waters are routed to a
retention pond for treatment by neutralization, sedimentation, and equalization
prior to being discharged directly into Hyco Lake.
• Domestic Wastewater Treatment System (Internal Outfall 008). Effluent from
the treatment system flows into the ash pond. Effluent from the ash pond
discharges into the heated water discharge canal.
• Chemical Metal Cleaning Treatment System (Internal Outfall 009). This
wastestream may occasionally be discharged to the ash pond treatment system. It
contains chemical metal cleaning wastes. Effluent from the ash pond discharges
into the heated water discharge canal.
• Flue Gas Desulfurization Treatment System (Internal Outfall 010). This waste
steam is generated from blowdown from the FGD treatment unit. After treatment in
the bioreactors, effluent will be discharged into the heated water discharge canal
upstream from outfall 002, and is ultimately released into Hyco Lake through
Outfall 003.
2. After receiving an Authorization to Construct from the Division, construct and operate a
Flue Gas Desulfurization (FGD) wastewater treatment system discharging to the ash
pond discharge canal through internal Outfall 002; and
Discharge from said treatment works and/or outfalls at the locations specified on the
attached map into the Hyco Lake, classified as WS-V & B waters in the Roanoke River
Basin.

Hoban, Autumn
From:
Hoban, Autumn
Sent:
Tuesday, June 09, 2009 9:06 AM
To:
Corporon, Joe
Cc:
Smith, Danny
Subject:
RE: Roxboro Modification for New RO-Thoughts
Joe,
Thanks for your consideration and appreciate your willingness to consider the RRO's comments.
I think through current negotiations of an SOC at Roxboro and at the next permit cycle we will be able to
address some of the RRO concerns.
Also wanted you to understand, and I forgot to mention that the ash pond receiving the low volume waste is
almost full, and 10 acres of the pond has been utilized by the failed FGD treatment pond. An additional 10
acres of the ash pond is being considered for the new FGD treatment pond, so they can possibly
decommission the failed FGD pond. (within the next year -future possible 20 acres of ash pond utilization) So
the treatment for RO reject claimed in the PE RO letter, is certainly not accurate, and PE has not completed
any recent studies to confirm capacity of ash pond or its treatment capability. The ash pond sends flow thru a
filter dam and then to the final outfall (no other treatment).
I think these comments are valid for our records.
Thanks again,
Autumn
From: Corporon, Joe
Sent: Tuesday, June 09, 2009 6:35 AM
To: Corporon, Joe; Hoban, Autumn
Cc: Poupart, Jeff; Mckay, James
Subject: RE: Roxboro Modification for New RO-Thoughts
correction on the % of discharge: should read 0.034 %.
From: Corporon, Joe
Sent: Tuesday, June 09, 2009 6:15 AM
To: Hoban, Autumn
Cc: Poupart, Jeff; Mckay, James
Subject: RE: Roxboro Modification for New RO-Thoughts
Autumn - My approach to adding RO @ Roxboro is in peer review (see attached), but we have tentative consensus here.
Paragraph 2 of the cover letter cuts to the heart of the issue, I think. Please let me know if you have any serious
objections.
From: Hoban, Autumn
Sent: Monday, June 08, 2009 4:49 PM
To: Mckay, James

Cc: Corporon, Joe; Smith, Danny
Subject: Roxboro Modification for New RO-Thoughts
Jim,
Not sure if you read my comments on Roxboro Reverse Osmosis addition/permit modification request. It was
sent to Gil and as I understand now, Joe is working on this one so I'm copying him on this e-mail.
I have researched some of the industrial permits that have RO reject (usually as part of their low volume
waste, that eventually discharges out an NPDES final outfall) and have found that in industry "some" of the
permits I reviewed already "incidentally" have monitoring requirements (for some of the parameters listed in
the 2007 RO technology permitting strategy) at the final outfall.
Example: The Mayo Plant via the NPDES permit already has some of the parameters being monitored at final
outfall 002, so it is the opinion of RRO that a future RO system should not prompt a need for additional
monitoring at the Mayo Plant, but that decision is ultimately up to the permit reviewer.
However, the Roxboro permit does not cover these parameters at the final outfall, therefore, the RRO will
recommend that the permit reviewer consider this information upon the review of the permit modification.
A different example: Small (low Megawatt Production CoGen power plant) Primary Energy- permit
NCO065099 in Southport where the permit required the "RO rejects as an internal outfall" with some of the
monitoring parameters in the RO permitting strategies. Those parameters relevant were TDS (926-1207) and
Conductivity (1100-1800). Attached is the data from BIMS. The final outfall does not have conductivity or
TDS? Instead requires annual priority pollutant scan (data not in Bims), so I have no final outfall data to
compare. This is a small plant discharging to the ocean, in comparison to the large Roxboro plant, discharging
to fresh water lake WS-V. The Roxboro permit does not look at TDS, or Conductivity, or other RO reject
parameters of concern at the final outfall, only covers Total As, and quarterly acute Toxicity.
I did not see any specific effluent guidelines to cover RO (covers Ion Exchange/Demineralization) in 40 CFR, but
it does seem that RO would be inclusive (as low volume waste in power plants) as it is not limited to what is
listed.
The 2007 RO policy -parameters for WTP's that serves as a reference tool for RO technologies indicates that RO
technologies yield different pollutants of concern and further discusses the need for a demonstration that the
environmental impacts would be minimal, especially to fresh waters. Applicability of this policy will be up to
the permit reviewer, but I think the reviewer should review the NCO065099 permit for reference and data, and
review the Mayo Permit, and understand that the Roxboro permit does not cover parameters of concern at
the final outfall (currently).
Just some thoughts, I hope this is not confusing, and is ultimately helpful at permit renewal time.
Sincerely,
Autumn

�twnn 97o6an-°�gman.r.Fi
Environmental Senior Specialist
Division of Water Quality
Surface Water Protection
3800 Barrett Drive
Raleigh, NC 27609
httP:Hh2o.enr.state.nc.us/
Office: 919-791-4247
Mobile: [phone]
Please note my e-mail address has changed:
E-Mail: [e-mail]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.

No prep needed. I just thought it might be useful to go over it together since this time we had some split samples ....I'll
come there first thing in the morning ... I don't anticipate taking up much time.
Shannon
E. Shannon Langley
Senior Environmental Specialist
Environmental Services Section - Carolinas
Progress Energy Carolinas, Inc.
[phone] (public)
8-770-2439 (voicenet)
Progress Energy
From: Hoban, Autumn [mailto:[e-mail]]
Sent: Monday, June 01, 2009 12:51 PM
To: Langley, Shannon
Subject: RE: current posted version of 15A NCAC 02H .1203 and § 143-215.2. Special orders.
Shannon,
Tuesday between 8-10 AM works for me. I have conf call at 10 AM.
Anything I need to prepare for your visit?
Thanks
Autumn
From: Langley, Shannon[mailto:[e-mail]]
Sent: Monday, June 01, 2009 9:16 AM
To: Hoban, Autumn
Subject: RE: current posted version of 15A NCAC 02H .1203 and § 143-21S.2. Special orders.
Autumn,
I can come by this afternoon, tomorrow morning or anytime Wednesday. Check your schedule and let me know what
works for you.
Shannon
E. Shannon Lang(ey
Senior Environmental Specialist
Environmental Services Section - Carolinas
Progress Energy Carolinas, Inc.
[phone] (public)
8-770-2439 (voicenet)

From: Hoban, Autumn [mailto:[e-mail]]
Sent: Thursday, May 28, 2009 4:28 PM
To: Langley, Shannon
Subject: RE: current posted version of 15A NCAC 02H .1203 and § 143-215.2. Special orders.
Shannon,
That would helpful, just let me know the date and time you are planning on coming and I'll check my schedule.
Thanks,
Autumn
From: Langley, Shannon[mailto:[e-mail]]
Sent: Thursday, May 28, 2009 12:39 PM
To: Hoban, Autumn
Subject: RE: current posted version of 15A NCAC 02H .1203 and § 143-215.2. Special orders.
Autumn,
Thanks for the Info.
On another issue, I have to deliver the latest "supplemental sampling" results to the RRO in the next few days. I had
planned on just dropping it off at the front desk but wondered if you would like to look at some of the data together
again. I realize we send you a ton of stuff it may be hard to understand some of the nomenclature (such as sampling
point ID's, etc ) so it may help with your review if we to sit down for 30 minutes or so and look at the results. This might
be most helpful with relation to the recent sets of split samples we did.
If you are interested, let me know.
Shannon
Ps. I'll try to get our correspondence changed to reflect your new last name.
E. Shannon LangCey
Senior Environmental Specialist
Environmental Services Section - Carolinas
Progress Energy Carolinas, Inc.
[phone] (public)
8-770-2439 (voicenet)
%� progress Energy
From: Hoban, Autumn [mailto:[e-mail]]
Sent: Thursday, May 28, 2009 9:22 AM
To: Holt, Fred; Sideris, Harry
Cc: Langley, Shannon
Subject: current posted version of 15A NCAC 02H .1203 and § 143-215.2. Special orders.

Mr. Sideris and Mr. Holt:
Thank you for your time and consideration during our annual NPDES inspection on May 27, 2009. The staff at
the plant were knowledgeable and very helpful in assisting the RRO with our duties. The facility was found to
be in compliance with the NPDES NC0003425 permit and an inspection letter will be forwarded via certified
mail.
Attached are the latest versions of NCAC and NCGS regarding SOC notice.
If you should have any further questions, please feel free to contact Danny Smith at 919-791-4200.
Regards,
Autumn Hoban-Romanski
umn 77o6an-�mand.Fx'
Environmental Senior Specialist
Division of Water Quality
Surface Water Protection
3800 Barrett Drive
Raleigh, NC 27609
http://h2o.enr.state.nc.us/
Office: 919-791-4247
Mobile: [phone]
Please note my e-mail address has changed:
E-Mail: [e-mail]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.

Zililtz
Progress Energy
File: 12520
Mr. Gil Vinzani
Supervisor, Eastern NPDES Unit
1617 Mail Service Center
Raleigh, NC 27606
Dear Mr. Vinzani:
Uma% 1 y, 2iju9
I,4 AY 2 2 2009
DENR - WATER QUALITY
POINT SOURCE BRANCH
NPDES permit application modification
Minor pemut modification request
Roxboro Steam Electric Plant
Permit Number: NC0003425
Person County
This correspondence is to follow up on earlier conversations and emails between you and staff of
Progress Energy regarding the use of a portable Reverse Osmosis (R.O.) system at Roxboro
Steam Electric Plant. The Roxboro Steam Electric plant intends to install a portable R.O. system
to aid in conditioning of Boiler make up water. The portable RO would be used in conjunction
with the existing demineralization equipment currently on site that conditions intake water from
Hyco Lake for use in plant processes. The system is not proposed to treat wastewater and would
be leased for temporary use with an option to purchase for permanent use.
The existing filtering, softening and demineralization equipment along with the waste stream
associated with this equipment is described in our NPDES permit in Attachment 4, under "Low
volume waste". Since the R.O. system waste stream is by definition "low volume waste" we
request a minor modification of our NPDES permit to include the portable R.O. system in the
description under "low volume waste." Enclosed are updated copies of Attachment 4 for your
files of our NPDES application. ZjLR.O system will have a reject stream that will go to the ash
pond with other low volume waste where it will be treated by sedimentation, oxidati
neutralization, equalization, and adsorption.
Also enclosed is an update to the chemicals list in Attachment 5 to identify the chemicals used in
the R.O. treatment process. These chemicals used in association with the R.O. system are
primarily acids and detergents that will be used every one to three months (for R.O. cleaning), an
anti-scalant and filter aid used in small quantity continuously.
Progress Energy Carolinas, Inc.
Roxboro Sleam Plant
1700 Dunns way Road
Santora„ NC 27343

In addition, we are planning to add Phosphate (Nalco BT 3000) for additional treatment of Boiler
water and Magnesium Hydroxide sprayed onto coal for Slagging mitigation and SO3 mitigation.
A chemical worksheet (DWQ form 101) has been prepared for all these constituents and has
been forwarded to the Aquatic Toxicology Unit of DWQ. All chemicals "pass" the aquatic
toxicity evaluation.
It is our understanding from conversations with you that this will be a minor modification of our
permit that will update the description of the term "low volume waste" in our "Supplement to
Permit Cover Sheet". As has been previously relayed to you, we wish to add the use of the RO
system as soon as possible to aid with plant operations. If you have any questions, please feel
free to contact Mr. Shannon Langley at [phone] or Shannon. lanelevnagnmail.com.
Respectfully,
Harry Sideris, Plant Manager
Roxboro Steam Electric Plant
HS/sl
Enclosures
Cc: Robert Howard
Shannon Langley -OPEB4

Attachment 4
Form 2C - Item II-B Flows, Sources of Pollution, and Treatment Technologies
The Roxboro Steam Electric Plant, located in Person County, North Carolina, consists of four
coal fired generating units with net dependable capacities of 385, 670, 707, and 700 MW for
units 1, 2, 3, and 4 respectively. All plant waste streams are routed directly or indirectly to
the Hyco Reservoir. Chemical constituents contained in these discharges will, in part, be
representative of the naturally occurring chemical quality and quantity of the intake water and
will also have chemical constituents of such quality associated with similar discharges for
fossil generating facilities of this size, type, and in this geographical location. Either all or
part of the elements in the Periodic Table, either singularly or in any combination, may from
time to time be contained in the discharges. Each component of the discharges is described
below.
Outfall 003 - Discharge Canal
At the point that the discharge canal enters the Hyco Reservoir, it contains the flows from
several waste streams, including once -through cooling water, stormwater runoff, and the
effluent from the ash pond, which in turn receives and treats combined flows from the ash
transport system, the low volume waste system, the dry fly ash handling system, cooling
tower blowdown, stormwater runoff, drainage from the ash landfill and from occasional
wastewater piping leakage.
Once -Through Coolinq Water
Condenser Cooling Water (CCW) for Units 1, 2, and 3 is drawn from the Hyco
Reservoir via an intake canal and discharges to the Hyco Reservoir via a discharge
canal. Flows for Units 1, 2, and 3 are 249 MGD, 342 MGD, and 505 MGD
respectively. Cooling is accomplished by evaporation from the surface of Hyco
Reservoir and mixing and convection with the reservoir waters.
During the summer months, Unit 3 CCW is routed through mechanical draft cooling
towers where most of the waste heat is removed by evaporation before the water is
discharged to the reservoir via the discharge canal along with the CCW of Units 1 and

water, the flow of which is combined with the CCW prior to introduction into the
discharge canal.
Ash Pond Discharge
The ash pond receives ash transport water, low volume wastes, runoff from the ash
landfill, dry fly ash handling system wash water, blowdown from Unit 4 cooling tower,
coal mill rejects and pyrites, and sewage treatment plant effluent. The pond provides
treatment by sedimentation, oxidation, neutralization, equalization, and adsorption.
Ash Transport Water
Water for sluicing ash to the ash pond is withdrawn from the CCW system as
needed. The plant will primarily supply ash sluice water from Unit 2. However,
the facility will continue to maintain the ability to operate the unit 4 ash sluice
pumps. The Unit 4 ash sluice pumps are and will continue to be utilized for the
following i) during maintenance draining of the cooling tower, ii) back-up supply
for the fire suppressant system, and iii) ash sluicing pumps during operational
events which require additional pumping. Normally, only bottom ash is
conveyed to the ash pond by sluicing. Fly ash is handled dry by a pneumatic
system and is landfilled on site or sold. If the dry fly ash handling system is out
of service during plant operating periods, fly ash will be sent to the ash pond via
the ash sluicing systems until the dry system is restored. Such occurrences are
expected to be infrequent and brief.
Silo Wash Water
Ash silo wash water runoff and dust suppressant spray runoff from the dry fly
ash handling system are routed to the ash pond.
Low Volume Wastes
Boiler make-up water is withdrawn from the CCW system and filtered, softened,
and demineralizered for treatment. This process may include treatment via a
reverse osmosis system. Boiler water is treated with ammonia, hydrazine
phosphate, and occasionally sodium hydroxide. Boiler blowdown is sent to the
ash pond via the low volume wastes collection system (LVWS); these are
special drains in the plant that flow by gravity to collection sumps and are
pumped to the ash pond. Ethylene glycol is used for freeze protection of some
2

equipment _J may be discharged to the LVWa, as is some molybdate waste
from the closed cooling water system, during periods of maintenance. The
plant's demineralizers are regenerated using sulfuric acid and sodium
hydroxide. When this equipment is rinsed, small amounts of these chemicals
are discharged to the low volume system via the neutralization basin. The
plant's Reverse Osmosis system produces a reject waste stream of
approximately 250 gpm. Essentially all plant equipment, floor drains, water
treatment filter backwashes, clarifier and sedimentation basin sludge, and ash
hopper seal water overflow also discharge to the LVWS. In addition, a back-up
domestic sewage system can discharge to the LVWS. The back-up system
consists of a septic tank with a subsurface sand filter and a chlorine dosing
chamber. The back-up system can be used if the facility's extended aeration
treatment system is temporarily out of service.
Cooling Tower Blowdown
Unit 4 is the only unit that produces cooling tower blowdown. A blowdown
stream is used to maintain concentrations of total dissolved solids in the cooling
tower to within proper operating limits. Make-up to the Unit 4 cooling tower is
from the Heated Water Discharge Canal.
Domestic Sewage
Domestic sewage is treated by an extended aeration treatment plant consisting
of a screen, comminutor, surge tank, aeration tank, clarifier, chlorine contact
chamber, and a sludge holding tank.
Coal Pile Runoff
The solids settling basin, which contains a portion of the wastewater runoff from
the coal pile and other coal handling areas of the plant, is routed to the ash
pond.
Ash Landfill Drainage
Water for sluicing a minimum amount of bottom ash to the ash landfill is
withdrawn from the ash transport system as needed. The bottom ash is used to
enhance the subsurface drainage of the landfill.
3

withdrawn from the ash transport system as needed. The bottom ash is used
to enhance the subsurface drainage of the landfill.
Air Preheater Cleaning (Low Volume Waste)
The air preheater will be water washed once per year or more frequently as
needed. The wastewater from this activity will be discharged to the ash pond.
Chemical Metal Cleaning Wastes
The boilers are chemically cleaned approximately every five -to -eight years as
required using Tetraammonia ethylene diamine tetraaccetic acid (EDTA)
solution or citric acid. This cleaning solution and its rinses are stored on site for
disposal by evaporation in an operating unit's furnace. Should evaporation not
be used, the wastewater can be treated by neutralization and precipitation prior
to being conveyed to the ash pond. Alternatively, the wastewater can be
disposed by other acceptable disposal methods. Cleaning of other heat
exchanger surfaces may produce 5,000-10,000 gallons of wastewater
approximately every three -to -five years.
Stormwater Runoff
The stormwater runoff, which flows into the ash pond includes runoff from the
plant drainage area, landfill runoff (including silo area drainage), and the
drainage area from the ash pond (including roadways).
Flue Gas Desulfurization (FGD) System Blowdown Emergency
Overflow/Pipeline Drain
Emergency overflow from the FGD System blowdown will discharge to the ash
pond. This is expected to occur only in the event of extreme rainfall. If the
FGD System blowdown pipeline requires emergency draining, the contents of
the pipeline will be drained to a sump that is pumped to the ash pond.
Stormwater Runoff
The stormwater, which flows into the discharge canal includes runoff from the plant
drainage area, the drainage area from the dry flyash handling system (including
4

roadways), Unit 4 ding tower drainage area, the fuel oil storage containment area,
the switchyard drainage area, the anhydrous ammonia tank farm, and the gypsum
storage pile area.
Flue Gas Desulfurization Blowdown (Low Volume Waste)
The Flue Gas Desulfurization (FGD) system directs flue gas into an absorber where
limestone (calcium carbonate) slurry is sprayed. Sulfur dioxide in the flue gas reacts
with the limestone slurry to produce calcium sulfate (gypsum). The system reclaims
any unreacted limestone slurry to be reused in the absorber. A small blowdown
stream is used to maintain the chloride concentration in the reaction tank. The
blowdown stream will be discharged to a gypsum settling pond where suspended
solids will be reduced prior to entering a bioreactor. The bioreactor utilizes microbes
to reduce soluble contaminants to insoluble forms that then precipitate from solution.
The treated wastewater will enter the ash pond discharge canal prior to outfall 002.
Outfall 006 — Coal Pile Runoff
Wastewater runoff from the coal pile, limestone pile, gypsum pile, truck wheel wash and
other coal handling areas of the plant is routed to a retention pond for treatment by
neutralization, sedimentation, and equalization. The pond is designed to store in excess of
the 10-year/24-hour storm event. Releases are controlled by a standpipe and skimmer
discharge structure. Included in the solids settling basin discharge beginning in January
2009 will be a truck wheel wash, which is necessary to help minimize offsite tracking of
gypsum and limestone onto state roads once the scrubber is online. Approximately 0.006
MGD of wheel wash water will be sent via gravity drain to the solids settling basin. Solids
from the wheel wash will accumulate in a separate settling basin to be removed by front end
loaders and sent to the landfill only the water will be going to the coal pile runoff pond via the
gravity drains.
5

Attachment 5
Form 2C - Item VI Potential Discharges Not Covered By Analysis
Chemical
Quantity
(used per year)
Frequency
Purpose
Anhydrous Ammonia
14,000 gal/wk
per unit
As required
(Seasonal)
Flue Gas Conditioning
Nalco 8338
385 gallons
As required
Corrosion Inhibitor
Nalclear 8173
(flocculant)
250 Ibs
As required
Water Treatment
H-130 (Microbiocide)
2300 gallons
As required
Unit 4 Cooling Tower
Algae Control
Nalco 71 D5 Plus
(Antifoam Agent)
630 gallons
As required
Unit 4 Cooling Tower
Foam Control
Nalco 7396
(Polyphosphate)
110 gallons
Twice per day
Corrosion Inhibitor
Potable Water
Ice Free Conveyor
(Propylene glycol)
750 gallons
2100 Ibs
As required
Conveyer Belt Freeze
Protection
Aluminum Sulfate
4000 gallons
As required
Water Treatment
Sodium Chloride
100,000 Ibs
As required
Softener Regeneration
Sulfuric Acid
13,000 gallons
Twice per week
Demineralizer
Regeneration
Sodium Hydroxide
15,000 gallons
Twice per week
Demineralizer
Regeneration
Ethylene Glycol
6,000 gallons
As required
Freeze Protection Hot
Water Coil System
Lime
2,500 Ibs
As required
Wastewater pH Control
Hydrazine
1,760 gallons
As required
Feedwater Oxygen
Ammonia Hydroxide
1,760 gallons
As required
Boiler Water pH Control
Chemical
Quantity
(used per year
Frequency
Purpose
Sodium Hydroxide
200 Ibs
As required
Boiler Water pH Control
Rev. 10/06

Sodium Hypochlorite
400 gallons
Twice per day
Potable Water
Treatment
BT-21OW
40,000 Ibs
As required
Dust Suppressant
(estimated)
Coaltrol 35
40,000 Ibs
As required
Dust Suppressant
Sodium Bicarbonate
20,000 Ibs
As required
Wastewater pH Control
Caustic Soda (20%)
110 gallons
Twice per day
Potable Water pH
Control
Molten Sulfur
525,000 Ibs
As required
Flue Gas Conditioning
Sanuril Tablets
135 Ibs
As required
Biocide for Sewage
(Calcium Hypochlorite)
Treatment
Nalclean
200 Ibs
As required
Softened Water System
Sodium Carbonate
8,000 Ibs
As required
Air preheater wash
water neutralization
EDTA
69,000 Ibs/boiler
As required
Boiler Cleaning
A300
50 gallons/boiler
As required
Boiler Cleaning
(Chelating Agent)
M045 Silicone
15 gallons/boiler
As required
Boiler Cleaning
Antifoam Agent
GEOMELT
87,000 gallons
Winter months
Anti -icing Fluid for Coal
per month
BT-930
87,000 gallons
Winter months
Anti -icing Fluid for Coal
per month
Limestone (calcium
492,000 tons
Continuous
Flue Gas
carbonate)
Desulfurization
EN/ACT 7880
As Required
Coagulant for
Coal Pile Runoff
RO Clean P112
81 gallons per use
As required
R.O system cleaning
(estimated every 1-3
months)
RO Clean P111
81 gallons per use
As required
R.O. System cleaning
(estimated every 1-3
months)
Rev. 10/06

Sumaclear 1000
6 gallons
Daily
R.O system treatment
VITEC 3000
5 gallons
Daily
R.O system treatment
Muriatic acid
1871 pounds
As required
R.O system cleaning
(estimated every 1-3
months
Citric Acid
675 pounds
As required
R.O. System cleaning
(estimated every 1-3
months
Magnesium
1 gallon per ton of
continuous
Slag mitigation
Hydroxide
coal
SO3 mitigation
Nalco BT 3000
1060 gallons
Per year
Boiler water treatment
Rev 10/06

Cc: Robert Howard
William Milam
Jodirah Green
Shannon Langley -OPEB4

NIFWA
RUMOR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
HARRY SIDERIS
PLANT MANAGER
PROGRESS ENERGY CAROLINAS INC
ROXBORO STEAM PLANT
1700 DUNNAWAY ROAD
SEMORA NC 27343
Division of Water Quality
Coleen H. Sullins
Director
May 22, 2009
Subject: Acknowledgement of Permit Modification Request for NC0003425
Progress Energy Carolinas Inc
Roxboro Steam Electric Power Plant
Person County
Dear Mr. Sideris:
Dee Freeman
Secretary
l
MAY 2 9 ?_TQ
The Division of Water Quality acknowledges receipt of your permit modification request and has assigned it to a
reviewer.
The reviewer will perform a detailed review and contact you with a request for additional information if necessary. To
ensure the maximum efficiency in processing permit applications, the Division requests your assistance in providing a
timely and complete response to any additional information requests.
Please note at this time, processing permit applications can take as long as 60 — 90 days after receipt of a complete
application.
If you have any questions, please contact Joe Corporon at 919-807-6394, or via email at [e-mail]. If the
reviewer is unavailable, you may leave a message, and they will respond promptly.
PLEASE REFER TO THE ABOVE APPLICATION NUMBER WHEN MAKING INQUIRIES ON THIS PROJECT.
Sincerely,
S4/t Jiy7'J1IUR.
Dina Sprinkle
Cc: Central Files
Raleigh Regional Office Surface Water Protection Section
Permit application file NC0003425
1617 Mail Service Center, Ralegh, North Carolina 276WI617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877623-6748
Internet www.ncwaterquality.org
An Equal Opportunity \ Afinnative Action Employer
None Carolina
�turallil

4or, Progress Energy
File: 12520
Mr. Gil Vinzani
Supervisor, Eastern NPDES Unit
1617 Mail Service Center
Raleigh, NC 27606
Dear Mr. Vinzani:
RECENEDMay 19, 2009
AY 2 2 2009
DENR - WATER QUALITY
POINT SOURCE BRANCH
NPDES permit application modification
Minor permit modification request
Roxboro Steam Electric Plant
Permit Number: NC0003425
Person County
MAy2a�
This correspondence is to follow up on earlier conversations and emails between you and staff of
Progress Energy regarding the use of a portable Reverse Osmosis (R.O.) system at Roxboro
Steam Electric Plant. The Roxboro Steam Electric plant intends to install a portable R.O. system
to aid in conditioning of Boiler make up water. The portable RO would be used in conjunction
with the existing demineralization equipment currently on site that conditions intake water from
Hyco Lake for use in plant processes. The system is not proposed to treat wastewater and would
be leased for temporary use with an option to purchase for permanent use.
The existing filtering, softening and demineralization equipment along with the waste stream
associated with this equipment is described in our NPDES permit in Attachment 4, under "Low
volume waste". Since the R.O. system waste stream is by definition "low volume waste" we
request a minor modification of our NPDES permit to include the portable R.O. system in the
description under "low volume waste." Enclosed are updated copies of Attachment 4 for your
files of our NPDES application. The R.0 system will have a reject stream that will go to the ash
pond with other low volume waste where it will be treated by sedimentation, oxidation,
neutralization, equalization, and adsorption.
Also enclosed is an update to the chemicals list in Attachment 5 to identify the chemicals used in
the R.O. treatment process. These chemicals used in association with the R.O. system are
primarily acids and detergents that will be used every one to three months (for R.O. cleaning), an
anti-scalant and filter aid used in small quantity continuously.
Progress Energy Carolinas, Inc.
Roxboro Steam Plant
1700 Dunnaway Road
Semora„ NC 27343

In addition, we are planning to add Phosphate (Nalco BT 3000) for additional treatment of Boiler
water and Magnesium Hydroxide sprayed onto coal for Slagging mitigation and SO3 mitigation.
A chemical worksheet (DWQ form 101) has been prepared for all these constituents and has
been forwarded to the Aquatic Toxicology Unit of DWQ. All chemicals "pass" the aquatic
toxicity evaluation.
It is our understanding from conversations with you that this will be a minor modification of our
permit that will update the description of the term "low volume waste" in our "Supplement to
Permit Cover Sheet". As has been previously relayed to you, we wish to add the use of the RO
system as soon as possible to aid with plant operations. If you have any questions, please feel
free to contact Mr. Shannon Langley at [phone] or Shannon. langley&gnmail.com.
Respectfully,
6)-�l 1, ✓�
Harry Sideris, Plant Manager
Roxboro Steam Electric Plant
HS/sl
Enclosures
Cc: Robert Howard
Shannon Langley -OPEB4

Attachment 4
Form 2C - Item II-B Flows, Sources of Pollution, and Treatment Technologies
The Roxboro Steam Electric Plant, located in Person County, North Carolina, consists of four
coal fired generating units with net dependable capacities of 385, 670, 707, and 700 MW for
units 1, 2, 3, and 4 respectively. All plant waste streams are routed directly or indirectly to
the Hyco Reservoir. Chemical constituents contained in these discharges will, in part, be
representative of the naturally occurring chemical quality and quantity of the intake water and
will also have chemical constituents of such quality associated with similar discharges for
fossil generating facilities of this size, type, and in this geographical location. Either all or
part of the elements in the Periodic Table, either singularly or in any combination, may from
time to time be contained in the discharges. Each component of the discharges is described
below.
Outfall 003 - Discharge Canal
At the point that the discharge canal enters the Hyco Reservoir, it contains the flows from
several waste streams, including once -through cooling water, stormwater runoff, and the
effluent from the ash pond, which in turn receives and treats combined flows from the ash
transport system, the low volume waste system, the dry fly ash handling system, cooling
tower blowdown, stormwater runoff, drainage from the ash landfill and from occasional
wastewater piping leakage.
Once -Through Cooling Water
Condenser Cooling Water (CCW) for Units 1, 2, and 3 is drawn from the Hyco
Reservoir via an intake canal and discharges to the Hyco Reservoir via a discharge
canal. Flows for Units 1, 2, and 3 are 249 MGD, 342 MGD, and 505 MGD
respectively. Cooling is accomplished by evaporation from the surface of Hyco
Reservoir and mixing and convection with the reservoir waters.
During the summer months, Unit 3 CCW is routed through mechanical draft cooling
towers where most of the waste heat is removed by evaporation before the water is
discharged to the reservoir via the discharge canal along with the CCW of Units 1 and
1

water, the flow of wnich is combined with the CCW prior to introduction into the
discharge canal.
Ash Pond Discharge
The ash pond receives ash transport water, low volume wastes, runoff from the ash
landfill, dry fly ash handling system wash water, blowdown from Unit 4 cooling tower,
coal mill rejects and pyrites, and sewage treatment plant effluent. The pond provides
treatment by sedimentation, oxidation, neutralization, equalization, and adsorption.
Ash Transport Water
Water for sluicing ash to the ash pond is withdrawn from the CCW system as
needed. The plant will primarily supply ash sluice water from Unit 2. However,
the facility will continue to maintain the ability to operate the unit 4 ash sluice
pumps. The Unit 4 ash sluice pumps are and will continue to be utilized for the
following i) during maintenance draining of the cooling tower, ii) back-up supply
for the fire suppressant system, and iii) ash sluicing pumps during operational
events which require additional pumping. Normally, only bottom ash is
conveyed to the ash pond by sluicing. Fly ash is handled dry by a pneumatic
system and is landfilled on site or sold. If the dry fly ash handling system is out
of service during plant operating periods, fly ash will be sent to the ash pond via
the ash sluicing systems until the dry system is restored. Such occurrences are
expected to be infrequent and brief.
Silo Wash Water
Ash silo wash water runoff and dust suppressant spray runoff from the dry fly
ash handling system are routed to the ash pond.
Low Volume Wastes
Boiler make-up water is withdrawn from the CCW system and filtered, softened,
and demineralizered for treatment. This process may include treatment via a
reverse osmosis system. Boiler water is treated with ammonia, hydrazine
phosphate, and occasionally sodium hydroxide. Boiler blowdown is sent to the
ash pond via the low volume wastes collection system (LVWS); these are
special drains in the plant that flow by gravity to collection sumps and are
pumped to the ash pond. Ethylene glycol is used for freeze protection of some
2

equipment ana may be discharged to the LVWS, as is some molybdate waste
from the closed cooling water system, during periods of maintenance. The
plant's demineralizers are regenerated using sulfuric acid and sodium
hydroxide. When this equipment is rinsed, small amounts of these chemicals
are discharged to the low volume system via the neutralization basin. The
plant's Reverse Osmosis system produces a reject waste stream of
approximately 250 gpm. Essentially all plant equipment, floor drains, water
treatment filter backwashes, clarifier and sedimentation basin sludge, and ash
hopper seal water overflow also discharge to the LVWS. In addition, a back-up
domestic sewage system can discharge to the LVWS. The back-up system
consists of a septic tank with a subsurface sand filter and a chlorine dosing
chamber. The back-up system can be used if the facility's extended aeration
treatment system is temporarily out of service.
Cooling Tower Blowdown
Unit 4 is the only unit that produces cooling tower blowdown. A blowdown
stream is used to maintain concentrations of total dissolved solids in the cooling
tower to within proper operating limits. Make-up to the Unit 4 cooling tower is
from the Heated Water Discharge Canal.
Domestic Sewage
Domestic sewage is treated by an extended aeration treatment plant consisting
of a screen, comminutor, surge tank, aeration tank, clarifier, chlorine contact
chamber, and a sludge holding tank.
Coal Pile Runoff
The solids settling basin, which contains a portion of the wastewater runoff from
the coal pile and other coal handling areas of the plant, is routed to the ash
pond.
Ash Landfill Drainage
Water for sluicing a minimum amount of bottom ash to the ash landfill is
withdrawn from the ash transport system as needed. The bottom ash is used to
enhance the subsurface drainage of the landfill.
9

withdrawn from the ash transport system as neeaeo. The bottom ash is used
to enhance the subsurface drainage of the landfill.
Air Preheater Cleaning (Low Volume Waste)
The air preheater will be water washed once per year or more frequently as
needed. The wastewater from this activity will be discharged to the ash pond.
Chemical Metal Cleaning Wastes
The boilers are chemically cleaned approximately every five -to -eight years as
required using Tetraammonia ethylene diamine tetraaccetic acid (EDTA)
solution or citric acid. This cleaning solution and its rinses are stored on site for
disposal by evaporation in an operating unit's furnace. Should evaporation not
be used, the wastewater can be treated by neutralization and precipitation prior
to being conveyed to the ash pond. Alternatively, the wastewater can be
disposed by other acceptable disposal methods. Cleaning of other heat
exchanger surfaces may produce 5,000-10,000 gallons of wastewater
approximately every three -to -five years.
Stormwater Runoff
The stormwater runoff, which flows into the ash pond includes runoff from the
plant drainage area, landfill runoff (including silo area drainage), and the
drainage area from the ash pond (including roadways).
Flue Gas Desulfurization (FGD) System Blowdown Emergency
Overflow/Pipeline Drain
Emergency overflow from the FGD System blowdown will discharge to the ash
pond. This is expected to occur only in the event of extreme rainfall. If the
FGD System blowdown pipeline requires emergency draining, the contents of
the pipeline will be drained to a sump that is pumped to the ash pond.
Stormwater Runoff
The stormwater, which flows into the discharge canal includes runoff from the plant
drainage area, the drainage area from the dry flyash handling system (including
n

roadways), Unit 4 cooling tower drainage area, the fuel oil storage containment area,
the switchyard drainage area, the anhydrous ammonia tank farm, and the gypsum
storage pile area.
Flue Gas Desulfurization Blowdown (Low Volume Waste)
The Flue Gas Desulfurization (FGD) system directs flue gas into an absorber where
limestone (calcium carbonate) slurry is sprayed. Sulfur dioxide in the flue gas reacts
with the limestone slurry to produce calcium sulfate (gypsum). The system reclaims
any unreacted limestone slurry to be reused in the absorber. A small blowdown
stream is used to maintain the chloride concentration in the reaction tank. The
blowdown stream will be discharged to a gypsum settling pond where suspended
solids will be reduced prior to entering a bioreactor. The bioreactor utilizes microbes
to reduce soluble contaminants to insoluble forms that then precipitate from solution.
The treated wastewater will enter the ash pond discharge canal prior to outfall 002.
Outfall 006 — Coal Pile Runoff
Wastewater runoff from the coal pile, limestone pile, gypsum pile, truck wheel wash and
other coal handling areas of the plant is routed to a retention pond for treatment by
neutralization, sedimentation, and equalization. The pond is designed to store in excess of
the 10-year/24-hour storm event. Releases are controlled by a standpipe and skimmer
discharge structure. Included in the solids settling basin discharge beginning in January
2009 will be a truck wheel wash, which is necessary to help minimize offsite tracking of
gypsum and limestone onto state roads once the scrubber is online. Approximately 0.006
MGD of wheel wash water will be sent via gravity drain to the solids settling basin. Solids
from the wheel wash will accumulate in a separate settling basin to be removed by front end
loaders and sent to the landfill only the water will be going to the coal pile runoff pond via the
gravity drains.
R

Attachment 5
Form 2C - Item VI Potential Discharges Not Covered By Analysis
Chemical
Quantity
(used per year)
Frequency
Purpose
Anhydrous Ammonia
14,000 gal/wk
per unit
As required
(Seasonal)
Flue Gas Conditioning
Nalco 8338
385 gallons
As required
Corrosion Inhibitor
Nalclear 8173
(flocculant)
250 Ibs
As required
Water Treatment
H-130 (Microbiocide)
2300 gallons
As required
Unit 4 Cooling Tower
Algae Control
Nalco 71 D5 Plus
(Antifoam Agent)
630 gallons
As required
Unit 4 Cooling Tower
Foam Control
Nalco 7396
(Polyphosphate)
110 gallons
Twice per day
Corrosion Inhibitor
Potable Water
Ice Free Conveyor
(Propylene glycol)
750 gallons
2100 Ibs
As required
Conveyer Belt Freeze
Protection
Aluminum Sulfate
4000 gallons
As required
Water Treatment
Sodium Chloride
100,000 Ibs
As required
Softener Regeneration
Sulfuric Acid
13,000 gallons
Twice per week
Demineralizer
Regeneration
Sodium Hydroxide
15,000 gallons
Twice per week
Demineralizer
Regeneration
Ethylene Glycol
6,000 gallons
As required
Freeze Protection Hot
Water Coil System
Lime
2,500 Ibs
As required
Wastewater pH Control
Hydrazine
1,760 gallons
As required
Feedwater Oxygen
Ammonia Hydroxide
1,760 gallons
As required
Boiler Water pH Control
Chemical
Quantity
(used per ear
Frequency
Purpose
Sodium Hydroxide
200 Ibs
As required
Boiler Water pH Control
Rev. 10/06

Sodium Hypochlorite
400 gallons
Twice per day
Potable Water
Treatment
BT-210W
40,000 Ibs
As required
Dust Suppressant
(estimated)
Coaltrol 35
40,000 Ibs
As required
Dust Suppressant
Sodium Bicarbonate
20,000 Ibs
As required
Wastewater pH Control
Caustic Soda (20%)
110 gallons
Twice per day
Potable Water pH
Control
Molten Sulfur
525,000 Ibs
As required
Flue Gas Conditioning
Sanuril Tablets
135 Ibs
As required
Biocide for Sewage
(Calcium Hypochlorite)
Treatment
Nalclean
200 Ibs
As required
Softened Water System
Sodium Carbonate
8,000 Ibs
As required
Air preheater wash
water neutralization
EDTA
69,000 Ibs/boiler
As required
Boiler Cleaning
A300
50 gallons/boiler
As required
Boiler Cleaning
(Chelating Agent)
M045 Silicone
15 gallons/boiler
As required
Boiler Cleaning
Antifoam Agent
GEOMELT
87,000 gallons
Winter months
Anti -icing Fluid for Coal
per month
BT-930
87,000 gallons
Winter months
Anti -icing Fluid for Coal
per month
Limestone (calcium
492,000 tons
Continuous
Flue Gas
carbonate)
Desulfurization
EN/ACT 7880
As Required
Coagulant for
Coal Pile Runoff
RO Clean P112
81 gallons per use
As required
R.O system cleaning
(estimated every 1-3
months)
RO Clean P111
81 gallons per use
As required
R.O. System cleaning
(estimated every 1-3
months)
Rev. 10106

Sumaclear 1000
6 gallons
Daily
R.O system treatment
VITEC 3000
5 gallons
Daily
R.O system treatment
Muriatic acid
1871 pounds
As required
R.O system cleaning
(estimated every 1-3
months
Citric Acid
675 pounds
As required
R.O. System cleaning
(estimated every 1-3
months
Magnesium
1 gallon per ton of
continuous
Slag mitigation
Hydroxide
coal
SO3 mitigation
Nalco BT 3000
1060 gallons
Per year
Boiler water treatment
Rev. 10/06

Cc: Robert Howard
William N ilam
Jodirah Green
Shannon Langley -OPEB4

Progress Energy RECEIVED
File: 12520 MAY 2 2 2009 May 12, 2009
Cindy Moore
Aquatic Toxicology Unit DENR - WATER QUALITY
North Carolina Division of Water Qua] ityPOINT SOURCE BRANCH
1621 Mail Service Center
Ralcigh, NC 27699-1621
Subject: Roxboro Steam Electric Plant
NPDES Number NC0003425
Change in Chemical
Dear Ms. Moore:
The Roxboro Steam Electric Plant may begin using several additional chemicals. These
include:
1. Nalco BT 3000 for Boiler water treatment,
2. MgOH for slagging control and SO3 mitigation,
3. Citric acid, Muriatic acid, Nalco ROClean P111, Nalco ROCIean P112,
Sumaclear 1000 and Vitec 3000 for cleaning and maintenance of a temporary
Reverse Osmosis water treatment system.
The temporary Reverse Osmosis system is in the approval process and may be used in
conjunction with our existing plant demineralization system to treat water withdrawn
from Hyco Lake for use in plant processes. Enclosed is a Biocide/Chemical Treatment
Worksheet-Form ] 01 which has been completed for each chemical. The worksheets
indicate that the proposed chemicals are acceptable for use at the facility. The Material
Safety Data Sheet (MSDS) for each chemical is also enclosed for your consideration.
If you have any questions or if you need any additional information, please contact
Shannon Langley at [phone].
Progress Enagy Carolinas, Inc.
13mboro sle Xn FWI
1?Ilg ChMwia, Road
Scaua. NC 22:N3
Pagel of 2

"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 managed 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 submittingfalse information, including the possibility offines and
imprisonment for knowing violations. "
Respectfully,
1
Harry Sideris
Roxboro Plant Managcr
Enclosures:
1. Biocide/Chemical Treatment Worksheet-Form 101
2. Material Safety Data Sheet
Page 2 of 2

be: Mr. Robert Howard
Shannon Langley — PE134
Page 3 of 2

BIOCIDE/CHEMICAL TREATMENT
WORKSHEET-FORM 101
The following calculations are to be performed on any biocidal products ultimately discharged to the surface waters of
North Carolina. This worksheet must be completed separately for each biocidal product in use. This worksheet is to b-
returned with all appropriate data entered into the designated areas with calculations performed as indicated.
Facility Name Roxboro Steam Plant
NPDES # NC NC0003425 Outfall # 003
County Person
Receiving Stream _Hyco Lake 7Q10 (cfs)
(All above information supplied by the Division of Water Quality)
What is the Average Daily Discharge (A.D.D.) volume of the water handling systems to the receiving water body?
A.D.D. = 1060.0000 (in M.G.D.)
Please calculate the Inslream Waste Concentration (IWC in percent) of this discharge using the data entered
above.
IWC = (A. D.5D X 100 = (1060.Op X 100 = 100.0 %
(7Q10)(0.646) + (A.D.D.) ( 0 ) (0646)+ (ID60.0)o
This value (IWC) represents the waste concentration to the receiving stream during low flow conditions.
II. What is the name of the whole product chemical treatment proposed for use in the discharge identified in Part I?
Coal Treat 300
Please list the active ingredients and percent composition:
Magnesium Hydroxide 100 %
What feed or dosage rate (D.R.) is used in this application? The units must be converted to maximum grams
of whole product used in a 24 hr period.
D.R. = 5831806 grams/24hr period
Please note. fluid ounces (a volume) must be converted to grams (a mass). The formula for this conversion is:
Grams of product = fluid oz. of product X 1 gal.water X 8.43 lbs. X specific gravity of product X 453.59g.
128 fl.oz. 1 gal. Water 1 lb.

Facility Name: Roxboro Steam Plant
NPDES # : NC NC0003425
Estimate total volume of the water handling system between entry of biocidal product and NPDES discharge point.
On an attached sheet please provide justification for this estimate (system volume, average cycles per blowdown,
holding lagoon size, etc.)
Volume = 165 million gallons 'estimate based on 15 MGD discharge from ash pond and 11
days detention time in ash pond.
What is the pH of the handling system prior to blocide addition? If unknown, enter NIA.
N/A
What is the decay rate (D.K) of the product? If unknown, assume no decay (D.K.=O) and proceed to asterisk.
The degradation must be stated at pH level within 1/2 pH standard unit within handling system. Enter the half life
(Half Life is the time required for the initial product to degrade to half of its original concentration). Please provide
copies of the sourees of this data.
H.L. = NA Days
The decay rate is equal to 1 X 0.69 =
H.L.
= Decay Rate (D.K.)
(A.D.D.) 1060.00 + ( 0 ) = 6,424
D.F. _ (Volume) + (D.K.) _ (165.00)
Calculate Steady State Discharge Concentration:
(D.R.) 5831806 =
Dischg Conc. _ (D.F.)(VOlume)(378 = ( 6.424) 27.95 (3785) 8.58 mgll
Calculate concentration of biocide instream during low flow conditions.
(Receiving Stream Concentration)
(Discha. Conc. X (IWC)%
100
III. Calculate regulated limitation.
X (100.A
100
8.58 mg/I
Receiving Stream Concentration
List all LC50 and EC50 data available for the whole product according to the following columns. (Note that units
should be in mg/1). Please provide copies of the sources of this data.
Organism Test Duration LC50IEC50 (moll)
Oral rat LID 50 LD 50 = 8500 mg/kg
This product is made from naturally occurring substances that are low in toxicity and should present no
unusual hazards to the environment There is no data currently available on ecotoxicity, mobility,
persistence or bioaccumulative potential.
D.W.Q. Form 101 (62000)

lV
Facility Name: Roxboro Steam plant NPDES # : NC
Choose the lowest LC50/EC50 listed above:
Enter the LC50/EC50: LD 50 - 8500 mg/l
If the half life (H.L.) is less than 4 days, perform the following calculation.
Regulated Limitation = 0.05 x LC50 =
mg/I
NCDO03425
If the half life (H.L.) is greater than or equal to 4 days or unknown, perform the following calculation.
Regulated Limitation = 0.01 x LC50 = 85 mg/I
Choose the appropriate regulated limitation from the calculations immediately above and place in this blank.
85 mg/llter
From Part II enter the receiving stream concentration:
8.58 mg/liter
Analysis. PASS
If the receiving stream concentration is greater than the calculated regulated limitation, then this biocide is
unacceptable for use.
Person in Responsible Charge
Name (Print)
Signature IDate
Person Completing This Worksheet (If different from above)
Shannon Langley
,Name (Print)
Signature Date
Please submit to: Division of Water Quality
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, NC 27699 - 1621
Anne Todd Christenson
D. W.O. Form 107 (612000) 3

BIOCIDUCHEMICAL TREATMENT
WORKSHEET- FORM 101
The following calculations are to be performed on any biocidal products ultimately discharged to the surface waters of
North Carolina. This worksheet must be completed separately for each biocidal product in use. This worksheet is to be
returned with all appropriate data entered into the designated areas with calculations performed as indicated.
Facility Name Roxboro Steam electric plant
NPDES # NC NC0003425 Outfall # 003
County Person
Receiving Stream Hyco lake 7Q10 (cfs)
(All above information supplied by the Division of Water Quality)
What is the Average Daily Discharge (A.D.D_) volume of the water handling systems to the receiving water body?
A.D.D. = 1060 (in M.G.D.)
Please calculate the Instream Waste Concentration (IWC in percent) of this discharge using the data entered
above.
IWC = (A.D.D.) X 100 = 1060.00 X 100 = 100.0 %
(7010)(0.646) + (A.D.D.) ( 0 ) (0.646)+ 1060.00
This value (IWC) represents the waste concentration to the receiving stream during low Flow conditions.
II What is the name of the whole product chemical treatment proposed for use in the discharge identified in Part I?
Citric Acid
Please list the active ingredients and percent composition:
2-Hydroxy-1,2-3 Propanetricarboxylic Acid
What feed or dosage rate (D.R.) is used in this application? The units must be converted to maximum grams
of whole product used in a 24 hr period.
D.R. = 10205 gramsl24hr period
Please note, fluid ounces (a volume) must be converted to grams (a mass). The formula for this conversion is,
Grams of product = fluid oz. of product X 1 gal.waler X 8.43 1 . X specific gravity of product X 453-59a.
128 fi.oz. 1 gal. Water 1 Ib.
675 pounds per leaning — every 1 to 3 months (as needed)
675 pounds = 10800 oz
10800 oz = 306174 grams
848671130 = 10205 grams per day

Facility Name: Roxboro Steam olant NPDES # : NC NC0003425
Estimate total volume of the water handling system between entry of biocidal product and NPDES discharge point
On an attached sheet please provide justification for this estimate (system volume, average cycles per blowdown,
holding lagoon size, etc.)
Volume = 165 ' million gallons 'estimate based on 15 MGD discharge from ash pond and 11
days detention time in ash pond.
What is the pH of the handling system prior to biocide addition? It unknown, enter N/A. N/A
What is the decay rate (D.K.) of the product? if unknown, assume no decay (D.K.=O) and proceed to asterisk.
The degradation must be stated at pH level within 12 pH standard unit within handling system. Enter the half life
(Halt Life is the time required for the initial product to degrade to half of its original concentration). Please provide
copies of the sources of this data.
H.L. = NA Days
The decay rate is equal to 1 X 0.69 = 0 = Decay Rate (D.K.)
H.L.
(A. D. D.) 1060.00 + ( 0 1 = 6.424
D.F. _ (Volume) + (D.K.) = 165.00
Calculate Steady State Discharge Concentration:
(D.R.) 10205 =
Dischg Conc. _ (D.F.)(Volume)(3785) _ ( 6.424) 165 (3785) 0.00254 mg/l
Calculate concentration of biocide instream during low flow conditions.
(Receiving Stream Concentration)
Disch __Conc. X (IWC)%
100
Calculate regulated limitation.
0.00254 X 100.0 = 0.00254 mg/I
100 Receiving Stream Concentration
List all LC50 and EC50 data available for the whole product according to the following columns. (Note that units
should be in mgll). Please provide copies of the sources of this data.
Organism Test Duration LC50/EC50 (ring/1)
No ECOTOX data availble
Oral rat LD50 11700 mglkg
D. W Q. Form 101 (&2000)

IV
Facility Name: Roxboro Steam plant NPDES # : NC NC0003425
Choose the lowest LC5O/EC50 listed above:
Enter the LC50/EC50: 11700 mg/I mg1l
If the half life (H.L.) is less than 4 days, perform the following calculation.
Regulated Limitation = 0.05 x LC50 = N/A mg/l
If the half life (H.L.) is greater than or equal to 4 days or unknown, perform the following calculation.
Regulated Limitation = 0.01 x LC50 = 117 mg/I
Choose the appropriate regulated limitation from the calculations Immediately above and place in this blank:
117
mg/liter
From Part 11 enter the receiving stream concentration,
0,00705 mg/liter
Analysis. PASS
If the receiving stream concentration is greater than the calculated regulated limitation, then this biocide is
unacceptable for use.
Person in Responsible Charge
R4rr7 ��4tar,�
Name (Print)
— Signature
Person Completing This Worksheet (if different from above)
Shannon Lanale
Name (Print)
Signature ,
Please submit to:
Division of Water Quality
Aquatic Toxicology Unit
1621 Mail service Center
Raleigh, NC 27699 - 1621
Attn: Todd Christenson
Date
D to
D.W.O. Form IOf (62000) 3

BIOCIDE/CHEMICAL TREATMENT
WORKSHEET -FORM 101
The following calculations are to be performed on any biocidal products ultimately discharged to the surface waters of
North Carolina. This worksheet must be completed separately for each btocidal product in use. This worksheet is to be
returned with all appropriate data entered into the designated areas with calculations performed as indicated.
Facility Name Roxboro Steam electric Plant
NPDES # NC NC0003425 Outfall # 003
County Person
Receiving Stream Hycolake 7Q10 (cfs)
(All above information supplied by the Division of Water Quality)
What is the Average Daily Discharge (A.D.D.) volume of the water handling systems to the receiving water body?
A.D.D. = 1060 (in M.G.D.)
Please calculate the Instream Waste Concentration (IWC in percent) of this discharge using the data entered
above.
IWC = (A.D.D.) X 100 = 1060.00 X 100 = 100.0 %
(7Q10) (0.646) + (A.D.D.) ( 0 ) (0.646) + 1060.00
This value (IWC) represents the waste concentration to the receiving stream during low flow conditions.
I I. What is the name of the whole product chemical treatment proposed for use in the discharge identified in Part I?
HCL or Muriabc Acid
Please list the active ingredients and percent composition:
Hydrochloric acid
°h
o�
o�
What feed or dosage rate (D.R.) is used in this application? The units must be converted to maximum grams
of whole product used in a 24 hr period.
D.R. = 28289 grams/24hr period
Please note. fluid ounces (a volume) must be convened 10 grams (a mass). The formula for this conversion is:
Grams of product = fluid oz. of product X 1 galmater X 8.43 tbs. X specific gravity of product X 453.59a.
128 fl.oz. 1 gal. Water 1 lb.
' 1871pounds per cleaning - every 1 to 3 months (as needed)
1871 pounds = 29936 oz
29936 oz = 848671 grams
848671 / 30 = 28289 grams per day

Facility Name: Roxboro Steam plant NPDES # : NC NC0003425
Estimate total volume of the water handling system between entry of biocidal product and NPDES discharge point.
On an attached sheet please provide justification for this estimate (system volume, average cycles per blowdown,
holding lagoon size, etc.)
Volume = 165 ' million gallons estimate based on 15 MGD discharge from ash pond and 11
days detention time in ash pond.
What is the pH of the handling system prior to blWde addition? If unknown, enter N/A. N/A
What is the decay rate (D. K.) of the product? if unknown, assume no decay (D. K.=O) and proceed to asterisk.
The degradation must be stated at pH level within 1/2 pH standard unit within handling system. Enter the half life
(Half Life is the time required for the initial product to degrade to half of its original concentration). Please provide
copies of the sources of this data.
H.L. = NA Days
The decay rate is equal to 1 X 0.69 = 0 = Decay Rate (D.K.)
H.L.
(A.D.D.) 1060.00 + ( 0 ) = 6.424
D.F. _ (Volume) + (D.K.) = 165.00
Calculate Steady State Discharge Concentration:
(D.R.) 28289 -
Dischg Conc. _ (D.F.)(Volume)(3785) _ ( 6.424) 165 (3785) 0.00705 mg/I
Calculate concentration of biocide instream during low flow conditions.
(Receiving Stream Concentration)
(Discho. Conc. X (IWC)% =
100
Calculate regulated limitation.
0.00705 X 100.0 = 0.00705 mg/I
100 Receiving Stream Concentration
List all LC50 and EC50 data available for the whole product according to the following columns. (Note that units
should be in mg/1). Please provide copies of the sources of this data.
Organism Test Duration LC50/EC50 (mg/)
Mosquitofish 96 hrs. LC50 =282 mgA
D.W.Q. Form 101 (6/2000) 2

IV.
Facility Name: Roxboro Steam plant NPDES S : NC NC0003425
Choose the lowest LC50/EC50 listed above:
Enter the LC501EC50: 282 mg/I mgn
If the half life (H.L.) is less than 4 days, perform the following calculation.
Regulated Limitation = 0.05 x LC50 = N/A mg/I
If the half life (H.L.) is greater than or equal to 4 days or unknown, perform the following calculation.
Regulated Limitation = 0.01 x LC50 = 2.82 mg/I
Choose the appropriate regulated limitation from the calculations immediately above and place in this blank:
2.82 mg/liter
From Part II enter the receiving stream concentration:
0.00705 mg/liter
Analysis. PASS
If the receiving stream concentration is greater than the calculated regulated limitation, then this biocide is
unacceptable for use.
Person in Responsible Charge
r'11r��i �IOIe�i
Name (Print)
Signature Date
Person Completing This Worksheet (If different from above)
Shannon Lanole
Please submit to:
Namg (Print)
Sig ature'
Division of Water Quality
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, NC 27699 - 1621
Attn: Todd Christenson
Date
D.W.Q. Form 101 (6/2000) 3

BIOCIDE/CHEMICAL TREATMENT
WORKSHEET- FORM 101
The following calculations are to be performed on any biocidal products ultimately discharged to the surface waters of
North Carolina. This worksheet must be completed separately for each biocidal product in use. This work8heet Is to be
returned with all appropriate data entered into the designated areas with calculations performed as indicated.
I. Facility Name
N PDES # NC
County
Receiving Stream
Roxboro Steam electric plant
NC0003425 Outfall 1$ 003
Person
lake
(All above information supplied by the Division of Water Quality)
7010
(cfs )
What is the Average Daily Discharge (A.D.D.) volume of the water handling systems to the receiving water body?
A.D.D. = 1060 (in M.G.D.)
Please calculate the Instream Waste Concentration (IWC in percent) of this discharge using the data entered
above
IWC = (A.D.D.) X 100 = 1060.00 X 100 = 100.0
(7010) (0.646) 1 TA. D.D_) ( 0 ) (0.646) + 1060.00
This value (IWC) represents the waste concentration to the receiving stream during low flow conditions.
I I. What is the name of the whole product chemical treatment proposed for use in the discharge identified in Part I?
Clean P111
Please list the active ingredients and percent composition
Inorganic Carbonate <30 %
EDTA Sall <30 %
Inorganic Phosphate Salt <30 %
Percarbonate Salt <30 %
Amphoteric Surfactant mixture <2
What feed or dosage rate (D.R.) is used in this application? The units must be converted to maximum grams
of whole product used in a 24 hr period.
D.R. = 6452 grams/24hr period
Please note, fluid ounces (a volume) must be converted to grams (a mass) The formula for this conversion is:
Grams of product = fluid oz. of product X 1 gal,wate X 8 431bs. X specific gravity of product X 453.59g.
128 fl.oz. 1 gal. Water 1 lb.
. 80.9 gallons per cleaning - every 1 to 3 months (as needed)
80.9 gallons ' 128 oz per gallon ' = 10355 oz
10355 oz = 293559 grams
293559 / 30 = 6452 grams per day

Facility Name: Roxboro Steam plant NPDES # : NC NG0003425
Estimate total volume of the water handling system between entry of biocidal product and NPDES discharge point.
On an attached sheet please provide justification for this estimate (system volume, average cycles per blowdown,
holding lagoon size, etc.)
Volume = 165 ' million gallons •estimate based on 15 MGD discharge from ash pond and 11
days detention time in ash pond.
What is the pH of the handling system prior to biocide addition? If unknown, enter N/A. NIA
What is the decay rate (D.K.) of the product? If unknown, assume no dewy (D.K.=O) and proceed to asterisk.
The degradation must be stated at pH level within 112 pH standard unit within handling system. Enter the half life
(Half Life is the time required for the initial product to degrade to half of its original concentration). Please provide
copies of the sources of this data.
H.L. = NA Days
The decay rate is equal to 1 X 0.69 =
0
= Decay Rate (D.K.)
H. L.
(A.D.D.)
1060.00
+ ( 0 )
= 6.424
` D.F. _ (Volume) + (D.K.) =
165.00
Calculate Steady State Discharge Concentration:
(D.R.)
6452
-
Dischg Conc. _ (D.F.)(Volume)(3785)
_
( 6.424) 165
(37a5) 0.00161 mg/I
Calculate concentration of biocide instream during
low flow conditions.
(Receiving Stream Concentration)
(Discha. Conc. X (IWC)% =
0.00161
X 1000
= 0.00161 mg/I
100
100
Receiving Stream Concentration
Calculate regulated limitation
List all LC50 and EC50 data available for the whole product according to the following columns. (Note that units
should be in mg/). Please provide copies of the sources of this data.
Organism Test Duration LC50/EC50 (mg/0
Daphnia magna 48 hrs EC 50 = > 1040 mg/1
Fathead minnow 96 hrs 59.8 mg/l
D. W.O. Form 101 (62000) 2

IV
Facility Name: Roxboro Steam plant NPDES # : NC NCDO03425
Choose the lowest LC50/EC50 listed above:
Enter the LC50/EC50. 59.8 mg1l mgll
If the half life (H.L.) is less than 4 days, perform the following calculation.
Regulated Limitation = 0.05 x LC50 = N/A mg/1
If the halt life (H.L.) is greater than or equal to 4 days or unknown, perform the following calculation.
Regulated Limitation = 0.01 x LC50 = 0.598 mg/I
Choose the appropriate regulated limitation from the calculations immediately above and place in this blank:
0.598 mg/liter
From Part II enter the receiving stream concentration:
0.00161 mg/liter
Analysis. PASS
If the receiving stream concentration is greater than the calculated regulated limitation, then this biocide is
unacceptable for use.
Person in Responsible Charge
�
/7"/Name (Print)
A�v�
Signature
51i-)l o9
Date
Person Completing This Worksheet (If different from above)
Shannon Lanole
Name (Print) ,
y�
Signature
Please submit to: Division of Water Quality
Aquatic ToAcology Unit
1621 Mail Service Center
Raleigh. NC 27699. 1621
Attn: Todd Christenson
D.W.Q. Form 101 (612000) 3

BICICIDE/CHEMICAL TREATMENT
WORKSHEET - FORM 101
The following calculations are to be performed on any biocidal products ultimately discharged to the surface waters of
North Carolina. This worksheet must be completed separately for each biocidal product in use. This worksheet is to be
returned with all appropriate data entered into the designated areas with calculations performed as indicated.
Facility Name Roxboro Steam electric plant
NPDES # NC NC0003425 Outfall # 003
County Person
Receiving Stream _Hyco lake 7Q10 (cfs)
(All above information supplied by the Division of Water Quality)
What is the Average Daily Discharge (A. D.D.) volume of the water handling systems to the receiving water body?
A.D.D. = 1060 (in M.G.D.)
Please calculate the Instream Waste Concentration (IWC in percent) of this discharge using the data entered
above.
IWC = A.D.D.) X 100 = 1060.00 X 100 = 100.0
(7Q10) (0.646) + (A.D.D.) ( 0 ) (0.646) + 1060.00
This value (IWC) represents the waste concentration to the receiving stream during low flow conditions.
11 What is the name of the whole product chemical treatment proposed for use in the discharge identified in Part I?
RO Clean P112
Please list the active ingredients and percent composition
MetaSilicate Compound 65-75 %
Cuic Salt compound 10-20 %
Phosphate salt Compound 10-20 %
Surfactant Mixture 1-5 %
What feed or dosage rate (D.R.) is used in this application? The units must be converted to maximum grams
of whole product used in a 24 hr period.
D.R. = 6452 grams/24hr period
Please note, fluid ounces (a volume) must be converted to grams (a mass). The formula for this conversion is:
Grams of product = fluid oz. of product X J. cal.waler X &43 Ibs. X specific gravity of product X 453.59 .
128 fl.oz. 1 gal. Water 1 lb.
80.9 gallons per cleaning - every 1 to 3 months (as needed)
80.9 gallons ' 128 oz per gallon "= 10355 oz
10355 oz = 293559 grams
293559 / 30 = 6452 grams per day

Facility Name: Roxboro Steam plant NPDES # : NC NCO003425
Estimate total volume of the water handling system between entry of biocidal product and NPDES discharge point.
On an attached sheet please provide justification for this estimate (system volume, average cycles per blowdown,
holding lagoon size, etc.)
Volume = 165 ' million gallons 'estimate based on 15 MGD discharge from ash pond and 11
days detention time in ash pond.
What is the pH of the handling system prior to biocide addition? If unknown, enter N/A. N/A
What is the decay rate (D.K.) of the product? If unknown, assume no decay (D.K.=O) and proceed to asterisk.
The degradation must be stated at pH level within 1/2 pH standard unit within handling system. Enter the half life
(Half Life is the time required for the initial product to degrade to half of its original concentration). Please provide
copies of the sources of this data.
H.L. = NA Days
The decay rate is equal to 1 X 0.69 = 0 = Decay Rate (D.K)
H.L.
(A.D.D.) 1060.00 + ( 0 ) = 6.424
D.F. _ (Volume) + (D K.) = 165.00
Calculate Steady State Discharge Concentration:
(D.R.) 6452 =
Dischg Conc. _ (D.F.)(Volume)(3785) _ ( 6.424) 165 (3785) 0.00161 mg/I
Calculate concentration of biocide instream during low flow conditions.
(Receiving Stream Concentration)
(Dischg. Conc. X QWCM = 0.00161 X 100.0 = 0.00161 mg/I
100 100 Receiving Stream Concentration
Calculate regulated limitation.
List all LC50 and EC50 data available for the whole product according to the following columns. (Note that units
should be in m9A). Please provide copies of the sources of this data.
Organism Test Duration LC501EC50 (mall)
Water flea 48 hrs LC 50 = 113 mg/l
Mosquitofish 530 mgA
D.W.Q. Form 10f (62000) 2

IV
Facility Name: Roxboro Steam plant NPDES # : NC NC0003425
Choose the lowest LC601EC50 listed above:
Enter the LC50/EC50: 113 mg/I mgn
If the half life (H.L.) is less than 4 days, perform the following calculation.
Regulated Limitation = 0.05 x LC50 = N/A mg/I
If the had life (H.L.) is greater than or equal to 4 days or unknown, perform the following calculation.
Regulated Limitation = 0.01 x LC50 = 1.13 mg/I
Choose the appropriate regulated limitation from the calculations immediately above and place to this blank:
1.13 mglliter
From Part 11 enter the receiving stream concentration:
0.00161 mg/liter
Analysis. PASS
It the receiving stream concentration is greater than the calculated regulated limitation, then this biocide is
unacceptable for use.
Person in Responsible Charge
Name (Print)
Signature
Person Completing This Worksheet (If different from above)
Shannon Lan
Name (Print)
Signature
Please submit to: Division of Water Quality
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, NC 27699 - 1621
Attn: Todd Christenson
0�
Date
Date
D.W.Q. Form 101 (6/2000) 3

BIOCIDEICHEMICAL TREATMENT
WORKSHEET - FORM 101
The following calculations are to be performed on any biocidal products ultimately discharged to the surface waters of
North Carolina. This worksheet must be completed separately for each biocidal product in use. This worksheet is to be
returned with all appropriate data entered into the designated areas with calculations performed as indicated.
I. Facility Name Roxboro Steam Electric plant
NPDES # NC NC0003426 Outfall # 003
County Person
Receiving Stream Hyco lake 7Q10 (cis)
(All above information supplied by the Division of Water Quality)
What is the Average Daily Discharge (A. D.D.) volume of the water handling systems to the receiving water body?
A.D.D. = 1060 (in M.G.D.)
Please calculate the Instream Waste Concentration (IWC in percent) of this discharge using the data entered
above.
IWC = (A.D.D.) X100 =
(7Q10) (0.646) + (A.D.D.)
1060.00 X 100
( 0 ) (0.646) + 1060.00
100.0 %
This value (IWC) represents the waste concentration to the receiving stream during low flow conditions.
II. What is the name of the whole product chemical treatment proposed for use in the discharge identified in Part 17
Sumaclear 1000
Please list the active ingredients and percent composition:
Water soluble aluminum compounds
%
%
What feed or dosage rate (D.R.) is used in this application? The units must be converted to maximum grams
of whole product used in a 24 hr period-
D.R. = 29171 grams/24hr period
Please note, fluid ounces (a volume) must be converted to grams (a mass). The formula for this conversion is:
Grams of product = fluid oz. of product X 1 aal.water X 8.43 Ib . X specific gravity of product X 4$3.59c.
128 fl.oz. 1 gal. Water 1 lb.
6 gallons per day
6 gallons ' 128 oz per gallon ' 1.34 specific gravity = 1029 oz
1029 oz = 29171 grams

Facility Name: Roxboro Steam Electric plant NPDES # : NC NC0003425
Estimate total volume of the water handling system between entry of biocidal product and NPDES discharge point.
On an attached sheet please provide justification for this estimate (system volume, average cycles per blowdown,
holding lagoon size, etc.)
Volume = 165 ' million gallons 'estimate based on 15 MGD discharge from ash pond and 11
days detention time in ash pond.
What is the pH of the handling system prior to biocide addition? If unknown, enter N/A
What is the decay rate (D.K) of the product? If unknown, assume no decay (D.K.=O) and proceed to asterisk.
The degradation must be stated at pH level within 1/2 pH standard unit within handling system. Enter the half life
(Half Life is the time required for the initial product to degrade to half of its original concentration). Please provide
copies of the sources of this data.
H.L. = NA Days
The decay rate is equal to 1 X 0.69 =
H.E.
(A.D.D.)
• D.F. _ (Volume) + (D.K) _
0 = Decay Rate (D.K.)
1060.00 +
165.00
6.424
NIA
Calculate Steady State Discharge Concentration:
(D.R.) 2917t -
Dischg Conc. _ (D.F.)(Volume)(3785) _ ( 6.424) 165 (3785) 0.00727 mg/I
Calculate concentration of biocide instream during low Flow conditions.
(Receiving Stream Concentration)
(Dischg. Conc. X (IWC)% _
100
Calculate regulated limitation.
0.00727 X 100.0 = 0.00727 mg/I
100 Receiving Stream Concentration
List all LC50 and EC50 data available for the whole product according to the following columns. (Note that units
should be in mgA). Please provide copies of the sources of this data.
Organism Test Duration LC50/EC50 (mg/1)
Water Flea 48 his LC 50 = 113 mgA
Mosquitofish 530 mg/I
D.W.Q. Form fof (62000) 2

Facility Name: Roxboro Steam Electric plant NPDES # : NC NC0003425
Choose the lowest LC50/EC50 listed above:
Enter the LC50/EC50: 113 mgA mgA
If the half life (H.L.) is less than 4 days, perform the following calculation.
Regulated Limitation = 0.05 x LC50 = NIA mgA
If the half life (H.L.) is greater than or equal to 4 days or unknown, perform the following calculation.
Regulated Limitation = 0.01 x LC50 = 1.13 mgA
Choose the appropriate regulated limitation from the calculations immediately above and place in this blank:
1.13
mgAiter
From Part II enter the receiving stream concentration:
0.00727 mgAiter
IV. Analysis. PASS
If the receiving stream concentration is greater than the calculated regulated limitation, then this biocide is
unacceptable for use.
Person in Responsible Charge
&rr,p
S1dPr) C
Name (Print)
✓��//(/�]L/l
) I
ignature
Person Completing This Worksheet (If different from above)
Shannon Len
Name (Print) _
ri Signat-
r
Please submit to: Division of Water Quality
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, NC 27699 - 1621
Attn: Todd Christenson
O.W.Q. Farm 101 (62000)
Date
Y
Dgte
3

BIOCIDElCHEMICAL TREATMENT
WORKSHEET - FORM 101
The following calculations are to be performed on any biocidal products ultimately discharged to the surface waters of
North Carolina. This worksheet must be completed separately for each biocidal product in use. This worksheet is to be
returned with all appropriate data entered into the designated areas with calculations performed as indicated.
Facility Name Roxboro Steam Electric plant
N PDES # NC NC0003425 Outfall # 003
County Person
Receiving Stream Hyco lake 7Q10 (cfs)
(All above information supplied by the Division of Water Quality)
What is the Average Daily Discharge (A. D.D.) volume of the water handling systems to the receiving water body?
A.D.D. = 1060 (in M.G.D.)
Please calculate the Instream Waste Concentration (IWC in percent) of this discharge using the data entered
above.
IWC = (A.D.D.) X 100 = 1060.00 X 100 = 100.0 %
(7Q10)(0.646) + (A.D.D.) ( 0 ) (0.646)+ 1060.00
This value (IWC) represents the waste concentration to the receiving stream during low Flow conditions.
I I. What is the name of the whole product chemical treatment proposed for use in the discharge identified in Part I?
Vitec(9 3000 (Avista antiscalant)
Please list the active ingredients and percent composition
Inorganic Chloride
0-02 %
Inorgannic acid
0-1 %
Inorganic Sodium Compound
<g
Deflocculant and Sequestrant
<12 %
Phosphoric Acid Derivative compound
0-16 %
What feed or dosage rate (D.R.) is used in this application? The units must be converted to maximum grams
of whole product used in a 24 hr period.
D.R. = 21772 grams/24hr period
Please note. fluid ounces (a volume) must be converted to grams (a mass). The formula for this conversion is:
Grams of product = fluid oz. of product X 1 galmater X 8.43 lbs. X specific gravity of product X 453-590.
128 fl.oz. 1 gal. Water 1 lb.
' 5 gallons per day
5 gallons' 128 oz per gallon ` 1.2 specific gravity-- 768 or
768 oz = 21772 grams

Facility Name: Roxboro Steam Electric plant NPDES # : NC NC0003425
Estimate total volume of the water handling system between entry of blocidal product and NPDES discharge point.
On an attached sheet please provide justification for this estimate (system volume, average cycles per blowdown,
holding lagoon size, etc.)
Volume = 165 ' million gallons 'estimate based on 15 MGD discharge from ash pond and 11
days detention time in ash pond.
What is the pH of the handling system prior to biocide addition? If unknown, enter N/A. NIA
What is the decay rate (D.K.) of the product? If unknown, assume no decay (D.K.=O) and proceed to asterisk.
The degradation must -be stated at pH level within 112 pH standard unit within handling system. Enter the half life
(Half Life is the time required for the initial product to degrade to half of its original concentration). Please provide
copies of the sources of this data.
H.L. = NA Days
The decay rate is equal to 1 X 0.69 = 0 = Decay Rate (D.K.)
H.L.
(AD.D.) 1060.00 + ( 0 ) = 6.424
D.F. _ (Volume) + (D.K.) = 165.00
Calculate Steady State Discharge Concentration:
(D-R) 21772 =
Dischg Conc. _ (D.F.)(Volume)(3785) _ ( 6.424) 165 (3785) 0.00543 mg/I
Calculate concentration of biocide instream during tow flow conditions.
(Receiving Stream Concentration)
(Discha. Conc. X (IWC)% = 0.00543 X 100.0 = 0.00543 mg/I
100 100 Receiving Stream Concentration
Calculate regulated limitation.
List all LC50 and EC50 data available for the whole product according to the following columns. (Note that units
should be in mg/l). Please provide copies of the sources of this data.
Organism Test Duration LC50/EC50 (mall)
Bluegill Sunfish 48 hrs. 3.6 mg/I
Selenastrum algae 96 hrs EC 50 = 1.9 mg/l
Mosquito fish 96 hrs 282 mgA
D.WO. Form 101 (6)2000) 2

IV
Facility Name: Roxboro Steam Electric plant NPDES # : NC NC0003425
Choose the lowest LC50/EC50 listed above:
Enter the LCWEC50: 1.9 mg/I mgfl
If the half life (H.L.) is less than 4 days, perform the following calculation.
Regulated Limitation = 0.05 x LC50 = N/A mg/I
If the half life (H.L.) is greater than or equal to 4 days or unknown, perform the following calculation.
Regulated Limitation = 0.01 x LC50 = 0.019 mg/l
Choose the appropriate regulated limitation from the calculations immediately above and place In this blank:
0.019 mg/iter
From Part II enter the receiving stream concentration:
0.00543 mg/liter
Analysis. PASS
If the receiving stream concentration is greater than the calculated regulated limitation, then this biocide is
unacceptable for use.
Person in Responsible Charge
SI�Q�'L�
Name (Print)
Signature
,5'lbj c11
Date
Person Completing This Worksheet (If different from above)
Shannon Lanale
/, Name (Print)('
4 Signature
Please submit to: Division of Water Quality
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, NC 27699 - 1621
Attn: Todd Christenson
!Date
D.WQ. Form 101 (&2000) 3

BIOCIDE/CHEMICAL TREATMENT
WORKSHEET - FORM 101
The following calculations are to be performed on any biocidal products ultimately discharged to the surface waters of
North Carolina. This worksheet must be completed separately for each biocidal product in use. This worksheet is to bi
returned with all appropriate data entered into the designated areas with calculations performed as indicated.
I. Facility Name Roxboro Steam Plant
NPDES # NC NC0003425 Outfall # 003
County Person
Receiving Stream Hyco Lake 7Q10 (cfs)
(All above information supplied by the Division of Water Quality)
What is the Average Daily Discharge (A.D.D.) volume of the water handling systems to the receiving water body?
A.D.D. = 1060.Oo00 (in M.G.D.)
Please calculate the Instream Waste Concentration (IWC in percent) of this discharge using the data entered
above.
IWC = (A.D.D.) X 100 = (1060.Op X 100 = 100.0 %
(7Q10) (0.646) + (A. D.D.) ( 0 ) (0.646) + (1060.Op
This value (IWC) represents the waste concentration to the receiving stream during low flow conditions.
11. What is the name of the whole product chemical treatment proposed for use in the discharge identified in Part I?
Nalco BT 3000
Please list the active ingredients and percent composition:
Sodium Hydroxide 1-5 %
Sodium Tripolyphosphate 1-5 %
What feed or dosage rate (D.R.) is used in this application? The units must be converted to maximum grams
of whole product used in a 24 hr period.
D.R. = 11951.36 grams/24hr period
Please note. fluid ounces (a volume) must be convened to grams (a mass). The formula for this conversion is:
Grams of product = fluid oz. of product X 1 gal.water X 8.43lbs. X specific gravity of product X 453.59a.
128 fl.oz. 1 gal. Water 1 lb.
Use 1000 gallons per year or 2.9 gallons per day
2.9 gallons ' 8.34 •1.09 (specific gravity) = 26.36 Ibs per day
26.36 lbs = 11951.36 grams per 24 hour period

Facility Name: Roxboro Steam plant
NPDES#:NC NC0003425
Estimate total volume of the water handling system between entry of biocidal product and NPDES discharge point.
On an attached sheet please provide justification for this estimate (system volume, average cycles per blowdown,
holding lagoon size, etc.)
Volume = 165 million gallons 'estimate based on 15 MGD discharge from ash pond and 11
days detention time in ash pond.
What Is the pH of the handling system prior to biocide addition? If unknown, enter N/A.
N/A
What is the decay rate (D.K) of the product? If unknown, assume no decay (D.K.=O) and proceed to asterisk.
The degradation must be stated at pH level within 1/2 pH standard unit within handling system. Enter the half life
(Half Life is the time required for the initial product to degrade to half of its original concentration). Please provide
copies of the sources of this data.
H.L. = NA Days
The decay rate is equal to 1_ X 0.69 = 0 = Decay Rate (D.K )
H.L.
(A.D.D.) 1060.00 + ( 0 ) = 6.424
D.F. _ (Volume) + (D.K.) _ ( 165.00)
Calculate Steady State Discharge Concentration:
(D.R.) 11961.36 -
Dischg Conc. _ (D.F.)(Volume)(378 = ( 6.424) 27.95 (3785) 0.02 mg/I
Calculate concentration of biocide instream during low flow conditions.
(Receiving Stream Concentration)
(Dischn. Conc. X (IWC)%
100
Calculate regulated limitation.
S 0.02) X ( 100.4 0.02 mgA
100 Receiving Stream Concentration
List all LC50 and EC50 data available for the whole product according to the following columns. (Note that units
should be in mg/1). Please provide copies of the sources of this data.
Organism Test Duration LC50/EC50 (MA)
Daphia Magna 48 hrs LC50 =3125 mgA
This product is made from naturally occurring substances that are low in toxicity and should present no
unusual hazards to the environment. There is no date currently available on ecotoxicity, mobility,
persistence or bioaccumulative potential.
D.W.Q. Form 101 (62000)

IV.
Facility Name: Roxboro Steam plant NPDES # : NC
Choose the lowest LC501ECSO listed above:
Enter the LC501EC50: LC 50 = 3125 mgA
If the half life (H.L.) is less than 4 days, perform the following calculation.
Regulated Limitation = 0.05 x LC50 =
mgA
NC0003425
If the half life (H.L.) is greater than or equal to 4 days or unknown, perform the following calculation.
Regulated Limitation = 0.01 x LC50 = 31.25 mgA
Choose the appropriate regulated limitation from the calculations immediately above and place in this blank:
31.25 mg/liter
From Part II enter the receiving stream concentration:
0.02 mg/liter
Analysis. PASS
If the receiving stream concentration is greater than the calculated regulated limitation, then this biocide is
unacceptable for use.
Person In Responsible Charge
Aar`r L) /-der.5
Na ee (Print)
Signature Date
Person Completing This Worksheet (if different from above)
Shannon Lanole
Nar(le (Print)
Signature
Please submit to: Division of Water Quality
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, NC 27699. 1621
Attn: Todd Christenson
v Date
D.W.Q. Form 101 (6?000) 3

w r
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
May 15, 2009
Mr. Mike Moseley, Plant Manager
Progress Energy Carolinas, Inc., Roxboro Steam Plant
1700 D imnaway Road
Semora, North Carolina 27343
Dear Mr. Moseley:
Dee Freeman
Secretary
.� 1 8 201,
SUBJECT: Authorization to Construct
A to C No. 003425A05
Progress Energy Carolinas, Inc.
Roxboro Steam Plant
FGD Wastewater Pond Reconstruction and Relining
Person County
A letter of request for Authorization to Construct was received January 13, 2009, by the
Division, and final plans and specifications for the subject project have been reviewed and found
to be satisfactory. Authorization is hereby granted for the construction of modifications to the
existing Roxboro Steam Plant FGD Wastewater System, with discharge of treated effluent from
the FGD Wastewater Treatment System (Internal Outfall 010) into the Ash Pond Discharge
Canal (Internal Outfall 002), which discharges to the Heated Water Discharge Canal, which
discharges to Hyco Lake (Outfall 003) in the Roanoke River Basin.
This authorization results in no increase in design or permitted capacity and is awarded
for the construction of the following specific modifications:
Reconstruction of the FGD existing (West) Settling Pond with approximate new
volume of 115 MG (with 2 feet freeboard), including grouting the southwest
comer of the pond, reconstruction of the pond bottom with two layers of
geotextile and clay liner, relining the pond with 60 mil LLDPE synthetic liner,
and associated yard piping and appurtenances; reconstruction of the FGD existing
Flush Pond with approximate new volume of 15 MG (with 2 feet freeboard),
including reconstruction of the southern berm wall, reconstruction of the pond
bottom with two layers of geotextile and clay liner, relining the pond with 60 mil
LLDPE synthetic liner, and associated yard piping and appurtenances; and
construction of a new toe drain around the West Settling Pond and the Flush
Pond, in conformity with the project plans, specifications, and other supporting
1617 Mail Service Center, Ralegh, North Carolina 27699-1617 One
Location: 512 N. Salsbury St Ralson. North Carolina 27604 N Carolina
Phone: [phone] FAX: [phone] Customer Service: "778238748
Internet w .ncwaterqualhy.orq atllra!ll,�
An Equal Opportunity I Atfimrabw Action Employer

T A -
Mr. Mike Moseley, Plant Manager
May 15, 2009
Page 2
data subsequently filed and approved by the Department of Environment and
Natural Resources.
This Authorization to Construct is issued in accordance with Part III, Paragraph A of
NPDES Permit No. NC0003425 issued April 9, 2007, and shall be subject to revocation unless
the wastewater treatment facilities are constructed in accordance with the conditions and
limitations specified in Permit No. NC0003425.
The sludge generated from these treatment facilities must be disposed of in accordance
with G.S. 143-215.1 and in a manner approved by the Division.
In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, the Permittee shall take immediate corrective action, including those as may
be required by the Division, such as the construction of additional or replacement wastewater
treatment or disposal facilities.
The Raleigh Regional Office, telephone number [phone], shall be notified at least
forty-eight (48) hours in advance of operation of the installed facilities so that an on site
inspection can be made. Such notification to the regional supervisor shall be made during the
normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State
Holidays.
Upon completion of construction and prior to operation of this permitted facility, a
certification must be received from a professional engineer certifying that the permitted facility
has been installed in accordance with the NPDES Permit, this Authorization to Construct and the
approved plans and specifications. Mail the Certification to: Construction Grants & Loans,
DWQ/DENR, 1633 Mail Service Center, Raleigh, NC 27699-1633.
Upon classification of the facility by the Certification Commission, the Permittee shall
employ a certified wastewater treatment plant operator to be in responsible charge (ORC) of the
wastewater treatment facilities. The operator must hold a certificate of the type and grade at
least equivalent to or greater than the classification assigned to the wastewater treatment
facilities by the Certification Commission.
The Permittee must also employ a certified back-up operator of the appropriate type and
grade to comply with the conditions of T15A:8G.0202. The ORC of the facility must visit each
Class I facility at least weekly and each Class II, III and IV facility at least daily, excluding
weekends and holidays, must properly manage the facility, must document daily operation and
maintenance of the facility, and must comply with all other conditions of T15A:8G.0202.
A copy of the approved plans and specifications shall be maintained on file by the
Permittee for the life of the facility.

Mr. Mike Moseley, Plant Manager
May 15, 2009
Page 3
During the construction of the proposed additions/modifications, the permittee shall
continue to properly maintain and operate the existing wastewater treatment facilities at all times,
and in such a manner, as necessary to comply with the effluent limits specified in the NPDES
Permit.
You are reminded that it is mandatory for the project to be constructed in accordance
with the North Carolina Sedimentation Pollution Control Act, and when applicable, the North
Carolina Dam Safety Act. In addition, the specifications must clearly state what the contractor's
responsibilities shall be in complying with these Acts.
Prior to entering into any contract(s) for construction, the recipient must have obtained all
applicable permits from the State.
Failure to abide by the requirements contained in this Authorization to Construct may
subject the Permittee to an enforcement action by the Division in accordance with North
Carolina General Statute 143-215.6A to 143-215.6C.
The issuance of this Authorization to Construct does not preclude the Permittee from
complying with any and all statutes, rules, regulations, or ordinances which may be imposed by
other government agencies (local, state, and federal) which have jurisdiction.
One (1) set of approved plans and specifications is being forwarded to you. If you have
any questions or need additional information, please contact Seth Robertson, P.E. at telephone
number [phone].
Sincerely,
nn ''/J a.� 1 • i3 �e e F
Coleen H. Sullins
kp:sr
cc: Jon A. Winterhalter, P.E. — Parsons E & C, 2675 Morgantown Road, Reading, PA 19607
Person County Health Department
DWQ Raleigh Regional Office, Surface Water Protection
DWQ, Technical Assistance and Certification Unit
DWQ, Point Source Branch, NPDES Program
Daniel Blaisdell, P.E.
Ken Pohlig, P.E.
ATC File

Progress Energy Carolinas, Inc.
Roxboro Steam Station
A To C No. 003425A05
Issued May 15, 2009
Engineer's Certification
I, , as a duly registered Professional Engineer in the
State of North Carolina, having been authorized to observe (periodically/weekly/full time) the
construction of the modifications and improvements to the Roxboro Steam Plant FGD
Wastewater System, located on NCSR 1377 in Person County for Progress Energy, hereby state
that, to the best of my abilities, due care and diligence was used in the observation of the
following construction:
Reconstruction of the FGD existing (West) Settling Pond with approximate new
volume of 115 MG (with 2 feet freeboard), including grouting the southwest
comer of the pond, reconstruction of the pond bottom with two layers of
geotextile and clay liner, relining the pond with 60 mil LLDPE synthetic liner,
and associated yard piping and appurtenances; reconstruction of the FGD existing
Flush Pond with approximate new volume of 15 MG (with 2 feet freeboard),
including reconstruction of the southern berm wall, reconstruction of the pond
bottom with two layers of geotextile and clay liner, relining the pond with 60 mil
LLDPE synthetic liner, and associated yard piping and appurtenances; and
construction of a new toe drain around the West Settling Pond and the Flush
Pond, in conformity with the project plans, specifications, and other supporting
data subsequently filed and approved by the Department of Environment and
Natural Resources.
I certify that the construction of the above referenced project was observed to be built within
substantial compliance and intent of the approved plans and specifications.
Signature Registration No.
Date
Send to: Construction Grants & Loans
DENR/DWQ r
1633 Mail Service Center I
Raleigh, NC 27699-1633
,-, EAL

►' Progress Energy
File: 12520-D
Surface Water Treatment Rule Manager
Public Water Supply Section
N. C. Division of Environmental Health
1634 Mail Service Center
Raleigh, NC 27699-1634
Subject: Safe Drinking Water Monthly Monitoring Report
Roxboro Steam Electric Plant, I.D. #02-73-409
Dear Gentlemen:
April 8, 2009
In accordance with the reporting requirements of 15A NCAC 18C .1525, find enclosed
monitoring data for Progress Energy Carolinas, Inc. Roxboro Steam Electric Plant for the month
of April 2009.
Please contact Mr. Shannon Langley at [phone] if you have any questions with the
information provided by this report.
SBC/sbc
Enclosures
c: Public Water Supply Technical Services
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
Progress Energy Carolinas, Inc.
H%Ima )IPam Plant
17M Diadlawa9 Aoed
Swnom. NC "Jd'a
Respectf ill ,
9'1�� -
Harry K: Sideris
Plant Manager
>_9
Tel [phone] Fax [phone]

N.C. Department of Environment.Health, and Natural Resources
Division of Environmental Health. Public Water Supply Section
Month: March
Year: 2009 PUBLIC WATER SYSTEM FOR: CP&L - ROXBORO E G PLANT
TURBIDITY MONITORING REPORT
PWSID. 02-73-409
Part Ill
DEHNR (9
Water Supplypply (Review 5/96) SIGNED,
SYS'fl m IN MANUAL MODE
GRADE:A
No. 60144

N.C. Department of Enviromnent,Health. and Natural Resources
Division of Environmental Health, Public Water Supply Section
Month: March
Year: 2009 PUBLIC WATER SYSTEM FOR -
RESIDUAL DISINFECTANT (CHLORINE) MONITORING REPORT
CP&L - ROXBORO E.G. PLANT PWSID: 02-73409
®OEM�0000000000
®Mwm
-------
Part IV
DEHNR 1940 (5/93)
Water Supply (Review 5/96)
' SYSTEM IN MANUAL MODE
No. 60144

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Environmental Conservation Laborstones, Inc.
102-A Woodwinds Industrial Court
Cary, NC 27511
Ph: [phone] Fax: [phone]
BACTERIOLOGICAL ANALYSIS
WATER SYSTEM ID #: 02-73-409
Name of Water System: Progress Energy Roxboro Steam Plant
Sample Type: �X Routine Repeat
Location Where Collected: 004-Unit 3 & 4 Control Room Kitchen
Facility lDNo: D01
Sample Point: a Routine Original (RTOR) EIRepeat-Original Tap (RPOR)
Location Code: 004
Collected By: Dana Newcomb
Mail Results to:
Progress Energy (PRO IS)
Attn: Dana Newcomb
1700 Dunnaway, Road
Semora, NC 27343
Phone #: [phone]
Fax #:
Responsible persons email: [e-mail]
LABORATORY ID #: 37724 ❑ Repeat Samples Required from Client
County: Person
System Type:
❑ Special/Non-compliance
Repeat-(Jpsneam (RPUP)
Collection Date
03/04/09
V V��
www.encolabs.com J
r-lRepeat-Downstream (RPDN)
Collection Time
11:10 am
Also Complete For REPEAT Samples -
Previous Positive Laboratory Log#:
Previous Positive Location Code:
Positive Collection Date:
If Chlorinated:
Total Chlorine Residual: - mg/L
Free Chlorine Residual: 0.96 mg/L
Combined Chlorine Residual: - mg/L
(Ca.luned Chlorine Total Chlorinr mrmu(•'reel Chlorine)
CONTAMINANT
METHOD CODE
RESULTS
PRESENT l•2
ABSENT
INVALID
CODE 3
Coliform, Total
319
X
Coliform, Fecal
320
X
Heterotrophic Plate Count
Laboratory Log #:
COMMENTS:
Resample Required from Client
INVALID CODES:
1)Courant Gmmh/No Coliform Gmwth Found
2) TNTC/No ColiformGrowm found
3) Turbid Culture/No Coliforin Growth Found
4) Over 30 Hours Old
5) Improper Sample or Analysis
Notes: 1) If Total Conform bacteria is present, the laboratory must Pox analytical results to the State within 48 hours.
2) IfFecal/E wit bacteria is present, the laboratory must fen analytical results to the State on day test completed.
3) Invalidmile 05 should be accompanied by an explanation in the comments below.
C902578-01
DATE:
TIME:
ANALYSES BEGUN:
03/04/2009
4:55 pm
ANALYSES COMPLETED:
03/05/2009
11:07 am
Certified By: "-�2 Link Thrower
Page 1 of I

Environmental Conservation Laborator,.., Inc.
102-A Woodwinds Industrial Court
Cary, INC 27511
Ph: [phone] Fax: [phone]
W Nk,CO
BACTERIOLOGICAL ANALYSIS
WATER SYSTEM ID #: 02-73-409 County: Person
Name of Water System: Progress Energy Roxboro Steam Plant System Type:
Sample Type: a Routine ❑ Repeat ❑ SpeciaVNon-compliance
Location Where Collected: 005- A Warehouse Ladies RR
Facility ID No:
Sample Point:
Location Code:
Collected By:
Mail Results to:
D01
�X Routine Original (RTOR)
005
Progress Energy (PRO18)
Attn: Dana Newcomb
1700 Dunnaway Road
Semora, NC 27343
Phone #: [phone]
Fax #:
Responsible persons email
Dana Newcomb
Repeat -Original Tap (RPOR)
danamcwcombnpgnmai I.com
www.encolabs.com
Repeat -Upstream (RPUP) Repeat -Downstream (RPDN)
Collection Daze Collection Time
03/18/09 08:30 am
Also Complete For REPEAT Samples'
Previous Positive Laboratory Log#:
Previous Positive Location Code:
Positive Collection Date:
If Chlorinated
Total Chlorine Residual: - mg/L
Free Chlorine Residual: 0.48 mg/L
Combined Chlorine Residual: - mg/L
(Combined Chlorine Total Chlorine minas Free/ Chlorine)
LABORATORY ID #: 37724 ❑ Repeat Samples Required from Client ❑ Resample Required from Client
CONTAMINANT
METHOD CODE
RESULTS
PRESENT 12
ABSENT
MVALID
CODE 3
Coliform, Total
318
X
Colifonn, Fecal
316
X
Heterotrophic Plate Count
Laboratory Log #:
COMMENTS:
INVALID CODES:
1) Confluent Growth/Ne Colifovn Growth Found
2) TNTC/No ColifonnGrowth found
3) Turbid Culture/No Coliforrn Growth Found
4) Over 30 Hours Old
5) Improper Sample or Analysis
Notes: 1) If Total Coliform bacteria is present, the laboratory must in analytical results to the State within 49 hours.
2) IfFecidlE. coh bacteria is present, the laboratory marl fan analytical results to the State on day test completed.
3) Invabdcode #5 should be accompanied by an explanation in the comments below.
C903427-01
DATE:
TIME:
ANALYSES BEGUN:
03/18/2009
1:35 pm
ANALYSES COMPLETED:
03/19/2009
1:45 pm
Certified By: ". -;? -- Link Thrower
Page 1 of I

ease
•)�`�^• ``"^'-""e `^'V wya.unmr u, ranum,nesourtes
aired TOC set per month. ^--lion of Environmental Health, Public Water Supply Section
Year: 2009
Month: March
w
Disinfectant/Disinfection Byproducts Rule - Treatment Technique
Report of DBP Treatment Technique Compliance
Public Water System Name: Roxboro E. G. Plant
System PWS ID#:
02-73-409
Source Name: H co Lake
Source Code:
S01
Water Treatment Plant Name: Roxboro E. G. Plant
Treated Code :
022
Lab Cart ID# (if performed in-house): 11137721
---- _-------
Table 1
,-------------------- --------- ______________.,
TOC Paired Sample Data
,
i
,
I ACC 9
Source Water
Treated
(A) Actual
(8)
(C)
Running
Month
Alkalinity
TOC
Water TOC
%TOC
Required
Removal
Used to
Used to
Quarter
Annual
Year
Img/L)
(mg/L)
(mg/L)
Removal
%TOD
Ratio
Comply'
Average
0
Average
Removal
(A+B)
(RAA)
2009
January
23
5.7
0.0
100.0
45.0
2.22
St 1
2009
February
23
5.5
6.0
100.0
45.0 1
2.22
1 StD1
1.98
180
2009
2008
2008
2008
2008
2008
2008
2008
2008
2008
Year
may
24
1 5.4
0.0
1 100.0
45.0
1 2.22
Stoll
1.96
June
24
5.2
0.0
1 100.0
45.0
2.22
Stpi
July
25
4.8
0.0 1
100.0
45.0
2.22
St 1
August
25
5.7
1.4
75.4
45.0
1.68
St 1
1.88
September
25
4.7
1.0
78.7
45.0
1.75
St 1
October
25
5.5
1.9
65.5
45.0
1.45
St 1
November
24
5.2
1.9
63.1
45.0
1.40
St 1
1.39
December
23
5.1
2.1
58.8
45.0
1.31
StD1
" RAA = Running Annual Average, Computed Ouw"
?-Source Water SUVA
• - `-
- '-^2'r.: Finished
Water SUVA
Month
,
UV -4 (m-)
DOC
(mgIL)
SUVA
(Llmg-m)
SUVA
QTR AVG
SUVA
RAA
,
UV,., (m)
DOC
(mg/L)
SUVA
(Umg-m)
SUVA
QTR AVG
SUVA
RAA
January
February
March
April
May
L
STEP 1 - Required %TOC
Removals
Source Water TOC
(mg/L)
Source Water Alkalinity
(Mg/L as CaCO3)
0.60 >60-120 >120
>2.0-4o
350%
25.0% 15.0%
>4.0-8.0
45.0%
35.0% 25.0%
>8.0
50.0%
40.0% 30.0%
OR.
Alternative Compliance Criteria (ACC)
ACC 1
r, Water TOC <2o MgA
ACC 2
Treated Water TOC < 2 0 m IL
ACC 3
Source Water SUVA < 2.0 Umg-m
ACC 4
Finoi+ed Water SWA < 2.0 um,an
ACC
Trained Water Alkalis <N for saftiming systems only)
ACC
TTHM a HM5 RM'a <1R MCL auaa only chbme
ACC T
Source TOC RM <4.0 man. and Source Alkatirim, RM > 0 mg& and
TTHM a HM5 1i < 1Q MCL
Report 64�1
Certified By: � -fit
AL... l� /]
1(I V Data:
(ORC Signature)

Environmental Conservation Laboratories, Inc.
102-A Woodwinds Industrial Court
Cary, NC 27511
Ph: [phone] Fax: [phone]
C
www.encolabs.com
TOC REQUIREMENTS - Disinfection Byproducts Precursor Analysis
WATER SYSTEM ID #:
02-13-409 County: Person
Name of Water System:
Progress Energy Roxboro Steam Plant
Sample Type:
Z Source Water ❑ Treated Water ❑ Special/Non-compliance
Location Where Collected:
Source Water(TOC-Alk) - -
FacilityIDNo.:
Sol
Sample Point:
RW2
Collected By:
Dana Newcomb Collection Date
Collection Time
Mail Results to:
03/03/09
09:56 am
Progress Energy (PRO18)
Attn: Dana Newcomb
1700 Dunnaway Road
Phone #: [phone]
Semora, NC 27343
Fax #;
LABORATORY ID #: 37724
SAMPLE UNSATISFACTORY ❑
RESAMPLE REQUIRED
CONTAM
CONTAMINANT
METHOD
REQUIRED
REPORTING LIMITUANTIFIED
NOT DETECTED
(i.e(i.e<R.R.L.)
ALLOWABLE
CODE
CODE
(R.R.L.)
(X)
RESULTS*
LIMIT
1927
Total Alkalinity
142
1 mg/L
23 mg/L
N/A
2919
Dissolved Organic Carbon
I mg/L
N/A
2920
Total Organic Carbon
I mg(L
N/A
2922
Absorbance at UV254nm
I I/m
N/A
DATE:
TIME:
ANALYSES BEGUN:
03/12/2009
I:00 pm
ANALYSES COMPLETED:
03/12/2009
1:00 pm
LaboratoryLog #: C901685-01 /—.—<�->''' Ste hanie Franz For Link Thrower
8 Certified By: P
COMMENTS:
Page I of I

Environmt I Chemists, Inc.
.. 6602 Wmthnill Way a V....... .gton, North Carolina 29405
[phone] Phone • [phone] In
ICIumW uixd cum
DWJZ C f! a #94, DLS Cerq�Jcale #37779 w
TOTAL ORGANIC CARBON (TOC) REQUIREMENTS
Disinfection Byproduct Precursor Analysis
Nay illl infi.nowon muu be strpplid for campluiY:e cr dt.
WATER SYSTEM NO. 02-73-409 County: PERSON
Name of Water System: PROGRESS ENERGY ROXBORO STEAM PLANT
Sample Type: X Source Water ❑ Treated Water ❑ Special/Non-compliance
Location Where Collected: SOURCE WATER
I e� 4.M0.4T4m4e1r:�dJ�S�m�Trt�. i )
Facility ID No. S01
Sample Point: RW2
Collected By: DANA NEWCOMB
Mail Results to (water system representative):
ENCO — CARY
102-A WOODWINDS INDUSTRIAL COURT
CARY, NC 27511
ATTN: STEPHANIE FRANZ
LABORATORY ID #: 37729
CODE
CONTAM CONTAMINANT ]E ED
1927 Alkalinity
2919 Dissolved Organic Carbon
2920 Total Organic Carton (TOC) SM 5310 B
is 2922 Ultraviolet Absorption 254
(Uv254)
ANALYSES BEGUN:
Collection Date Collection Time
9:56 AM
tsom a i
Phone #: [phone]
Fax #: [phone]
Responsible Person's email:
SFANZ(alENCOLLABS.0 OM
❑SAMPLE UNSATISFACTORY ❑RESAMPLE REQUIRED
REQUIRED MST DETECTED QUANTIFIED ALLOWABLE
REPORTING LIMIT (i.e. < R.R.L) RESULTS LIMIT 'I
(R.R.L) M
1.0 mg/L
❑
mg/L
N/A
1.0 mg(L
❑
_ _ _ _ mg/L
N/A
1.0 mg/L
❑
5.4 mg(L
N/A
1.0 m 1
❑
m-1
N/A
DATE:
TIME:
3/10/09
11:08 AM
ANALYSES COMPLETED: 3/10/09 2:52 P11�
Laboratory Log #: 5452 Certified By: ALCA-k_ =X�s ArL ' '
(Pont and sign nava)
COMMENTS: 7� REPORT # 9-1969
—
2009
Laboratory should Nail Results to:
Public Water Supply Section, Ann. Data Entry, 1634 Mal Service Center, Raleigh, NC 27699-1634
Fax: [phone]

Environmi I Chemists, Inc.
6602 Windmill Way. Wilmington, North Caroline 28405
[phone] Phone x [phone] Fax
1 C'hen1W4i':t.d eom
NCDENR. DWOCert�rcate #94, DGS Cent lent e #37729 w_..
TOTAL ORGANIC CARBON (TOC) REQUIREMENTS
Disinfection Byproduct Precursor Analysis
hi a A0 aonuiv a mum k'wplie for c<xvV1. c
WATER SYSTEM NO. 02-73409 County: PERSON
Name of Water System: PROGRESS ENERGY ROXBORO STEAM PLANT
Sample Type: ❑ Source Water X Treated Water ❑ Special/Non-compliance
Location Where Collected: CARBON FILTER EFFLUENT
IM,c Cgast �/n MUST ren6W fN EYn9w.w.wirttl[dibl
Facility ID No. POl
Sample Point: CFl
Collected By: DANA NEWCOMB
Mail Results to (water system representative):
ENCO—CARY
102-A WOODWINDS INDUSTRIAL COURT
CARY, NC 27511
ATTN: STEPHANIE FRANZ
Collection Date Collection Time
3V3310099 11: 9 AM
ism 1
Phone #: [phone]"
Fax #: [phone]
Responsible Persoo'semail: [e-mail]
LABORATORY ID #: 37729
C CODE CONTAMINANT METHOD
IICODE CODE
❑SAMPLE UNSATISFACTORY ❑RESAMPLE REQUIRED
REQUIRED NOTDETECTED,—�— _
REPORTING Lanz' (i.e <R.R.L.) QUANTIFIED ALLOWABLE
(R R L) (X) RESULTS LIMB
II 1927 Alladinity
1.0 mlr/[,
❑
mgfL.
N/A
I 2919 Dissolved Organic Carbon
1.0 mg/L
❑
mg/L
N/A �
2920 Total Organic Carbon (TOC) SM 5310 B
1.0 mg/L
❑
_ _ 1 2 mg(L
N/A
2922 Ultraviolet Absorption 254
I.0 rri l
❑
m I
N/A
(UV254)
---- __—
DATE:
TIME:
ANALYSES BEGUN:
3/10/09
11:08 AM
ANALYSES COMPLETED:
3/10/09
2:52 PM
Laboratory Log #: 5453 . _
.. Certlfied By: 10910'�
and sign name)
COMMENTS: _ _. _
REPORT # 9-1969
20011
L.aboratory sboald Mail
Results to:
Public Water Supply Section, Ann: 1Mm Entry, 16.M Mail Service Center, Raleigh, NC 27699-1634
Fax; 919.715.6637

[Fwd' mee,ing monday at RRO]
Subject: [Fwd: meeting monday at RRO]
From: Danny Smith <[e-mail]>
Date: Thu, 26 Mar 2009 16:06:05 -0400
To: Autumn Hoban <[e-mail]>
fyi
lets discuss on Fri. a.m.... Also, if you are in I have a conference call on SSOS.
please sit in if you can. (no problem if your scheduled.)
thanks
danny
E-mail correspondence to and from this address may be subject to the North Carolina
Public Records Law and may be disclosed to third parties
Subject: meeting monday at RRO
From: "Langley, Shannon" <[e-mail]>
Date: Thu, 26 Mar 2009 10:01:45 -0400
To: <[e-mail]>
Hey Danny,
Just wanted to confirm our appointment for Monday at 10:00 am out at the RRO to discuss Roxboro
SOC issues. We will be bringing an application with us ready to be submitted at that time. We are not
bringing a large contingent of people but for a situation like this we will have a few folks from different
areas within the company. We plan on having:
Harry Sideris — Roxboro Plant manager.
Alan Madewell — Progress Energy Corporate Environmental Manager
Fred Holt — Water Program Manager
Danny Johnson— Project Manager for evaluations at Roxboro —Progress Energy Construction
And myself
Just wanted to let you know who was coming.
We want to deliver the application discuss what we are doing and our plans at Roxboro. We're
interested in getting some feedback from you on where you see this situation and how you see it going
forward. Give me a ring if you have any questions before Monday.
Shannon
E. Shannon Langley
Senior Environmental Specialist
Environmental Services Section - Carolinas
Progress Energy Carolinas, Inc.
[phone] (public)
8-770-2439 (voicenet)
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2 of 2 3/26/2009 4:36 PM

North Carolina
Beverly Eaves Perdue
Governor
Harry Sideris, Plant Manager
Progress Energy Carolinas, Inc.
PO Box 1551
Raleigh, NC 27602
NCDENR
Department of Environment and
Division of Water Quality
Coleen H. Sullins
Director
April 2, 2009
Subject: Non -Refundable Processing Fee
Special Order by Consent
Roxboro Steam Electric Power Plant
EMC SOC WQ S09-007
NPDES Permit No: NC0003425
Person County
Dear Mr. Sideris:
Natural Resources
Dee Freeman
Secretary
This letter is to acknowledge receipt of your application for a Special Order by Consent (SOC) and
check number 182873 in the amount of $400.00 received from you on March 30, 2009.
Division staff in our Raleigh Regional Office has a copy of your application and will review and
process it accordingly.
If you have any questions concerning the SOC, you may contact Autumn Hoban in our Raleigh
Regional Office at 919-791-4247 or me at 919/807-6392.
Sincerely,
2. MK�4
Vanessa E. Manuel
Eastern NPDES Program
Cc: Autumn Hobam DWQ/SWP Raleigh Regional Office
SOC File•S09-007
DWQ/SWP Central Files
1617 Mail Service Center, Raleyh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: 91M07-64951 Customer Service: 1-871b23-6748
Internet: www.ncwaterquality.org
An Equal opportunity 1 Afimia6re Action Employer
Naurally
eCarolina

` Progress Energy
File: 12520-B
Mr. Gil Vinzani, Supervisor
NPDES East Unit
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Mr. Vinzani:
P1s received
o �-30-09
March 30, 2009
Subject: Application for Special Order by Consent
Roxboro Steam Electric Plant
NPDES Permit No.: NC0003425
Person County
Enclosed please find an original and two copies of a completed application form for Special
Order by Consent (SOC) at the Roxboro Steam Electric Plant operated by Carolina Power and
Light Company d/b/a Progress Energy Carolinas, Inc. (PEC). Also enclosed is the required
check for $400.00.
PEC staff have been in contact with staff of the Raleigh Regional Office (RRO) regarding
operation of Roxboro's Flue Gas Desulfurization (FGD) units' wastewater treatment system
since February 2008. PEC installed wet limestone forced oxidation scrubbers on all four
operating units at the Roxboro plant in response to requirements from the State of North Carolina
under the Clean Smokestacks legislation. The scrubbers have been effective at removing
pollutants from air emissions at the plant. However, like for many electric utilities that have
installed wet scrubbers, the new and evolving treatment of the FGD wastewater has been a
learning experience for PEC. The discharge into a re -circulating lake system as opposed to a
free flowing river system has also provided many challenges and we are still learning how to
meet those challenges. Significant research is being conducted by the Electric Power Research
Institute (EPRI), the Utility Water Act Group (UWAG) and Environmental Protection Agency
(EPA) on issues surrounding analytical sampling and treatment of FGD wastewaters. PEC is
working with these groups and is following the research and technology very closely. EPA has
Progress Energy Carolinas, Inc.
Roxboro Steam Plant
1700 Ounnaway Road
Semora„ NC 27343 Page 1 of 15

taken an interest in FGD wastewaters as they recently considered revisions to the Steam Electric
Effluent Guidelines. The Roxboro plant was chosen as a site visited by EPA while considering
modifications to these guidelines. We are seeking the best alternatives to address any potential
issues in the most effective manner.
As you will recall, there was a bypass of partially treated FGD wastewater from the facility in
March 2008 which led the Division to increase required monitoring throughout the wastewater
process. Since that time, several meetings and discussions with your Division have taken place
about the operation of this treatment system with a pre-SOC conference taking place on
November 17, 2008.
This SOC application is being submitted after consultation with staff of the RRO to allow for
identification of the scope of any problems with the FGD wastewater treatment system,
development of a schedule for restoring the use of the existing FGD settling pond and FGD
Bioreactor flush pond and evaluation of what additional treatment measures may be necessary.
In response to the letter dated January 26, 2009 from Mr. Danny Smith of the Raleigh Regional
Office, seven specific items were requested as part of the SOC application package. Following
are our responses to that information request.
Item 1: Analysis and root cause documentation of the pond slope failures and leakage and evaluation of
repair and replacement options.
Response: A copy of the root cause analysis has been previously provided to stab of the
RRO and Construction Grants and Loans (CG&L) as part of the review of the
Authorization to Construct package for repairs to the existing flush and settling ponds.
Repair and replacement options are also presented in the ATC submittal. An additional
copy is attached for you review.
Item 2: Specifically address the redesign and respective replacement of the existing FGD settling basin.
Response: Specific details on the redesign of the existing settling pond have been provided
in the application for Authorization to Construct submitted to the Division on January 13,
2009. As an overview, the plan is to replace the existing Geosynthetic Clay Liner (GCL)
Page 2 of 15

liner system with a dual liner system consisting of compacted clay and a 60 mil Linear Low
density Polyethylene (LLDPE) liner.
Item 3: Specifically address the redesign and respective replacement of the existing FGD flush pond.
Response: Specific details on the redesign of the existing flush pond have been provided in
the application for Authorization to Construct submitted to the Division on January 13,
2009. As an overview, the plan is to replace the existing GCL liner system with a dual liner
system consisting of compacted clay and a 60 mil LLDPE liner. The previous FGD flush
pond has been deconstructed in accordance with guidance from the RRO received October
2, 2008 from Mr. Danny Smith.
Item 4: Discuss ongoing monitoring efforts (visual, physical measurements, and documentation) efforts
that are in place to insure the interim safety and structural integrity of the berm walls, FGD Settling pond
Flush pond and Bioreactor. Include an emergency response plan in the event of a structural failure.
Response: The flush pond has been deactivated and removed so no continuing monitoring
of it is necessary (or possible). Flush water from the Bioreactor is currently capable of
being routed to the existing Settling pond in accordance with Authorization to Construct
Number 003425A04. The settling pond has been lowered from a designed operational level
of —26 feet to an operational level (depth) of — 10 feet. Analysis conducted by Golder
Associates, Inc. indicated that operation at this level would assure the risk of berm failure
was at a minimum. Continued monitoring of the berm walls includes daily checking to see
that controls are in place to prevent casual access to the top of the pond, checking the
ditches around the pond for accumulation, new flows or seepages, and that the pumps are
continuing our effort in pumping any leakage back into the settling pond. We also check
the slopes inside and out for any obvious and major changes, bulges, seepages, movement of
earth (outside), any new sloughing of rip rap (inside), and any other abnormal observation.
These inspections are being documented in a log book kept on site.
An Emergency management Plan is included with this application.
The bioreactor does not have berm walls and is not at risk for structural failure.
Page 3 of 15

Item 5: Analysis of wastewater treatment capability.
Response: The Bioreactor and settling pond (system) have performed well in terms of most
metals and suspended solids removal. The settling pond is designed to provide cooling of
the FGD blow down water, settle out solids and provide temporary storage of wastewater in
the event of a problem with the Bioreactor treatment unit. TSS removal of the settling pond
has been 99.72% since it has been in operation. This includes the ongoing operation of the
settling pond at the lower operating levels. (Data used through January 2009 shows an
average influent TSS of 3280 mg/I and an average outflow from the pond of 9.5 mg/1). The
system is designed to remove mercury and selenium from the waste stream. Removal of
mercury primarily occurs in the settling pond where mercury settles out with the solids in
the wastewater. Approximately 99% of mercury is settled out though this physical process.
Of the remaining 1%, on average, approximately 2/3 of it is removed from the wastewater
stream by the Bioreactor. Average mercury levels in the blow down for the period of
record has been — 160 ug/l with significant variability present. Mercury leaving the
Bioreactor has averaged 0.1 ug/1 or less. Samples for mercury at the NPDES permitted
outfall 003 have remained steady for mercury concentrations in the range of 1-2 ug/l since
we began conducting low level sampling at that point in June 2008. Selenium treatment has
also performed well. The majority of selenium in the waste stream is in the dissolved form.
Selenium levels vary greatly with different lab methodologies and analysis. Results from
split samples using different methods have produced results that differ by orders of
magnitude. In general, selenium removal levels have still been in excess of 95% for the
entire time the Bioreactor has been operational. Copies of these analyses have been
provided to the RRO on a monthly basis. PEC believes the proposed construction sequence
for refurbishment of the FGD wastewater ponds will allow PEC to treat FGD wastewater to
the same levels it is currently being treated. The current proposal calls for the flush pond to
be reconstructed initially. At that point, flush operations will be returned to the new flush
pond. Secondly, a new gypsum settling pond will be constructed for use while the original
settling pond is refurbished. As the new pond is proposed to be smaller than the existing
pond, PEC conducted settling tests using the established settling column test protocols by
US Army Corps of Engineers and by Metcalf & Eddy for flocculating sedimentation ponds
to evaluate the sizing of the new settling pond. Results of those tests are available for review
and indicate the new pond would allow for sufficient settling for the time period it is
Page 4 of 15

anticipated to be in use. The final step in the refurbishment will be to install the new liner
system in the existing settling pond and return it to use.
PEC staff are carefully monitoring selenium levels throughout Hyco Lake to insure any
potential issues are identified early. A CD with all applicable data is included with this
application. In addition to data previously submitted to the RRO, this CD contains results
from Applied Speciation and Frontier Labs. Applied Speciation performs process control
samples on the Bioreactor limited primarily to Selenium and Mercury. Frontier Labs
performed analysis of split process control samples and utilize a modified 200.8 method
with ultra clean sampling techniques and closed vessel digestion.
Item 6: Provide a performance analysis of the FGD settling pond and Bioreactor from March
2008 to present.
Response: The Bioreactor was commissioned and put into service in March 2008.
According to lab analysis from Applied Speciation, after a short "shakedown" period the
Bioreactor has operated as designed and expected. Performance analysis was discussed
above in response to item 5.
Item 7: A clear implementation schedule with project end date.
Response: PEC hap applied for the necessary "Authorization's to Construct" to make
needed repairs to the Settling pond and Flush pond. We have provided an estimate of the
timeframes to complete proposed work. PEC has contracted with URS to provide analysis
of current conditions and recommendations for going forward. URS has been instructed to
provide recommendations on any changes that could be made to assure operation of this
treatment system does not have significant impacts within Hyco Lake. A kickoff meeting
was held with URS staff at the Roxboro plant on February 24, 2009. The schedule we have
developed with URS to provide recommendations is attached. PEC has provided a final end
date for completion of refurbishment of the settling and flush ponds. This work is
somewhat dependent on approvals from the Division. We have provided an anticipated
completion date for the study from URS. PEC recommends development of an order that
Page 5 of 15

has as a milestone a study phase and then has dual paths based on what recommendations
are to be implemented. A copy of these milestones is presented in this application for SOC.
We appreciate the continued assistance of staff from the Division of Water Quality as we address
any potential issues at the Roxboro plant. If you have any questions, please feel free to contact
Mr. Shannon Langley at [phone] or [e-mail].
HS/sl
attachments
Respectfully
4tw) )4" '-
Harry Sideris, Plant Manager
Roxboro Steam Electric Plant
Page 6 of 15

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
APPLICATION FOR A SPECIAL ORDER BY CONSENT (SOC)
I. PERMIT RELATED INFORMATION:
1. Applicant (corporation, individual, or other): Carolina Power and Light Company d/b/a
Progress Energy Carolinas, Inc.
2. Print or Type Owner's or Signing Official's Name and Title:
Harry Sideris, Plant Manager, Roxboro Steam Electric Plant
3. Facility Name (as shown on Permit): Roxboro Steam Electric GeneratingPlant
lant
4. Application Date: March 30, 2009
5. NPDES Permit No. (if applicable): NC0003425
6. Name of the specific wastewater treatment facility (if different from I.3. above):
NA
H. PRE -APPLICATION MEETING:
Prior to submitting this completed application form, applicants must meet with the appropriate
regional office staff to discuss whether or not an SOC is appropriate for this situation. Please
note the date this meeting occurred: November 17, 2008.
Page 7 of 15

III. ADDITIONAL FLOW OR FLOW REALLOCATION:
In accordance with NCGS 143-215.67(b), only facilities owned by a unit of government may
request additional flow. Additional flow may be allowed under an SOC only in specific
circumstances. These circumstances may include eliminating discharges that are not compliant
with an NPDES or Non -discharge permit. These circumstances do not include failure to perform
proper maintenance on treatment systems, collection systems or disposal systems. When
requesting additional flow, the facility must include its justification and supporting
documentation. If the requested additional flow is non -domestic, the facility must be able to
demonstrate the ability to effectively treat the waste and dispose of residuals. The applicant must
provide a detailed analysis of the constituents in the proposed non -domestic wastewater.
The total domestic additional flow requested: _N/A gallons per day.
The total non -domestic additional flow requested: _N/A gallons per day.
The total additional flow (sum of the above): N/A gallons per day.
Please attach a detailed description or project listing of the proposed allocation for additional
flow, with an explanation of how flow quantities were estimated. Please be advised that any
additional flow allowed by this requested SOC will be determined by a complete analysis of any
projected adverse impact to wastewater treatment facilities and surface waters.
IV. NECESSITY NARRATIVE:
Please attach a narrative providing a detailed explanation of the circumstances regarding the
necessity of the proposed SOC. Include the following issues:
.Existing and/or unavoidable future violations(s) of permit conditions or limits(s),
•The existing treatment process and any modifications that have been made to date,
!Collection system rehabilitation work completed or scheduled (including dates),
Page 8 of 15

Coordination with industrial users regarding their discharges or pretreatment facilities.
Identify any non -compliant significant industrial users and measure(s) proposed or taken to bring
the pretreatment facilities. back into compliance. If any industrial facilities are currently under
consent agreements, please attach these agreements.
Response:
Progress Energy installed wet limestone forced oxidation scrubbers on all four operating units at
the Roxboro plant in response to requirements from the State of North Carolina under the Clean
Smokestacks legislation. The scrubbers have been effective at removing pollutants from our air
emissions at the plant. In order to provide treatment for the wastewater being generated by the
wet scrubber PE installed a wastewater settling pond, a bioreactor which is an innovative
biological treatment system, and a flush pond which would receive the backwash from
maintenance of the bioreactor.
Just before full commissioning of the complete treatment facility, in February 2008, a structural
failure occurred in one of the treatment ponds of the Roxboro Flue Gas Desulfurization (FGD)
wastewater treatment systems (flush pond) resulting in a release of partially treated wastewater
into the adjacent ash settling pond. A second FGD wastewater settling pond was showing signs
of stress, so a decision was made to invoke the bypass provisions of the NPDES permit in order
to lower that pond's water level by approximately 10 feet and reduce the hydraulic pressure
being exerted on the second pond's structure. This was done after consulting with NCDENR
staff in DWQ and DLQ. The bypass resulted in the diversion of partially treated FGD
wastewater into the facility's ash pond and eventually to Hyco Lake. This diversion took place
over approximately two weeks time and has been successful in reducing the stress on the settling
pond walls.
Since the bypass, the operating level in the settling pond has been stable at the lower levels, the
bioreactor has been placed into the service and temporary measures have been taken, with DWQ
authorization, to re-route the Bioreactor flush system to the settling pond until the flush pond can
Page 9 of 15

be repaired. The Bioreactor is new technology and contained performance guarantees on
Mercury and Selenium. Reduction of these two constituents has been effective.
Extensive monitoring at various points in the wastewater process has been taking place since the
wastewater diversion in February, 2008. Additionally, PEC has conducted sampling in the lake
to assess the impacts of the bypass and ongoing operation of the wastewater treatment system.
This sampling has indicated a rise in the levels of some parameters.
PEC is addressing the issues from two aspects. First, Progress Energy has submitted plans and
specifications to DWQ in order to receive an authorization to construct to make repairs to the
existing flush pond and settling pond. It is suspected that the existing settling pond is leaking
and may be leading to some of the increases in chemical concentrations we are seeing in the
Lake. Secondly, PEC has contracted with a consultant firm which has considerable experience
in wastewater treatment to identify both short tern and long term recommendations to address
this issue. A detailed list of options for further remediation of the situation will be developed
should the pond repairs not remedy the issue completely.
PEC believes that a Special Order by Consent is needed in order to allow PEC to sequentially
continue with their ongoing repairs, to assess the total impact of the wastewater discharge on the
lake, and to develop and construct any additional measures needed to provide adequate treatment
if needed.
V. CERTIFICATION:
The applicant must submit a report prepared by an independent professional with expertise in
wastewater treatment. This report must address the following:
!An evaluation of existing treatment units, operational procedures and recommendations as to
how the efficiencies of these facilities can be maximized.
!A certification that these facilities could not be operated in a manner that would achieve
compliance with final permit limits.
!The effluent limits that the facility could be expected to meet if operated at their
Page 10 of 15

maximum efficiency during the term of the requested SOC (be sure to consider interim
construction phases).
•Any other actions taken to correct problems prior to requesting the SOC.
Response
These actions are being undertaken to repair two compromised wastewater treatment units and to
proactively address and evaluate any needed modifications to our wastewater treatment system to
avoid potential impacts on Hyco Lake.
VI. PREDICTED COMPLIANCE SCHEDULE:
The applicant must submit a detailed listing of activities along with time frames that are
necessary to bring the facility into compliance. This schedule should include milestone dates for
beginning construction, ending construction, and achieving final compliance. In determining the
milestone dates, the following should be considered:
.Time for submitting plans, specifications and appropriate engineering reports to DWQ for
review and approval.
!Occurrence of major construction activities that are likely to affect facility performance
(units out of service, diversion of flows, etc.).
.Infiltration/Inflow work, if necessary.
!Industrial users achieving compliance with their pretreatment permits if applicable.
!Toxicity Reduction Evaluations (TRE), if necessary.
Response:
Proposed milestone dates
1. Submit application for AtoC to repair existing settling pond and flush pond by March 1,
2009. (Met)
2. Submit application for AtoC to build new gypsum settling pond by April 1, 2009. (Met)
Page 11 of 15

3. Select consultant and begin study of existing wastewater treatment system and long term
Potential impacts to Hyco Lake by March 1, 2009. (Met)
4. Complete consultant study and present findings with recommended solution to Division
of water Quality staff by October 1, 2009
5. Begin Construction of refurbished flush pond within 60 days of receiving necessary AtoC
and land disturbance permits (if onsite borrow material is used)
6. Complete construction of refurbished forward flush pond, west settling pond and new
settling pond within 270 days of receiving all necessary permits of by June 31, 2010
(whichever is later)
7. Take samples as follows:
FGD Blowdown (2/month until settling pond is refurbished)
Chlorides, TSS, Arsenic, Boron, Cadmium, Chromium, Manganese, Mercury (245.1), Molybdenum,
Nickel, Selenium, Silver and Thallium.
Influent to Bioreactor (2/month until settling pond is refurbished)
Chlorides, TSS, Arsenic, Boron, Cadmium, Chromium, Manganese, Mercury (245.1), Molybdenum,
Nickel, Selenium, Silver and Thallium.
Bioreactor Effluent (2/month)
Chlorides, TSS, Arsenic, Boron, Cadmium, Chromium, Manganese, Mercury (low level),
Molybdenum, Nickel, Selenium, Silver and Thallium.
Outfall 002 (2/month in addition to permit requirements)
Chlorides, TSS, Arsenic, Boron, Cadmium, Chromium, Manganese, Mercury (245.1), Molybdenum,
Nickel, Selenium, Silver and Thallium.
Outfall 003 (2/month in addition to permit requirements)
Chlorides, TSS, Arsenic, Boron, Cadmium, Chromium, Manganese, Mercury (low level),
Molybdenum, Nickel, Selenium, Silver and Thallium
Page 12 of 15

8. Continue taking water chemistry and fish tissue samples within Hyco Lake. Submit available
results as required by the Order.
9. If additional actions are determined to be necessary to protect long term viability of Hyco Lake
(as determined by consultant study) submit schedule for implementation of those actions along
with a request to modify this SOC by December 31, 2010. Otherwise, this SOC shall expire June
30, 2011.
VII. FUNDING SOURCES IDENTIFICATION:
The applicant must list the sources of funds utilized to complete the work needed to bring the
facility into compliance. Possible funding sources include but are not limited to loan
commitments, bonds, letters of credit, block grants and cash reserves. The applicant must show
that the funds are available, or can be secured in time to meet the schedule outlined as part of this
application.
Response
Funding for needed studies, engineering and any chosen additional technology deemed necessary
will be provided by the company.
THIS APPLICATION PACKAGE WILL NOT BE ACCEPTED BY THE DIVISION OF
WATER QUALITY UNLESS ALL OF THE APPLICABLE ITEMS ARE INCLUDED WITH
THE SUBMITTAL.
Required Items:
a. One original and two copies of the completed and appropriately executed application
forth, along with all required attachments.
!If the SOC is for a City / Town, the person signing the SOC must be a ranking
Page 13 of 15

elected official or other duly authorized employee.
!If the SOC is for a Corporation / Company / Industry / Other, the person signing
the SOC must be a principal executive officer of at least the level of vice-president, or his
duly authorized representative. (Included)
•If the SOC is for a School District, the person signing the SOC must be the
Superintendent of Schools or other duly authorized employee.
Note: Reference to signatory requirements in SOCs may be found in the North
Carolina Administrative Code [T15A NCAC 2H .1206(a)(3)].
b. The non-refundable Special Order by Consent (SOC) processing fee of $400.00. A
check must be made payable to The Department of Environment and Natural
Resources. (Included)
c. An evaluation report prepared by an independent consultant with expertise in
wastewater. (in triplicate) Response: Copies of failure analysis of the FGD flush pond are
attached. Progress Energy has contracted with URS to provide an evaluation and
recommendations for the FGD wastewater treatment process.
Page 14 of 15

APPLICANT'S CERTIFICATION:
I, Harry Sideris, attest this application for a Special Order by Consent (SOC) has been reviewed
by me and is accurate and complete to the best of my knowledge. I understand if all required
parts of this application are not completed and if all required supporting information and
attachments are not included, this application package may be returned as incomplete.
Furthermore, I attest by my signature that I fully understand that an upfront penalty, which may
satisfy as a full settlement for past violations, may be imposed. {Note: Reference to upfront
penalties in Special Orders by Consent may be found in the North Carolina Administrative Code
[T15A NCAC 2H .1206(c)(3)].]
Q 41"
Signature of Signing Official Date
Harry Sideris. Plant Manager Roxboro Steam Electric Plant
Printed Name of Signing Official
THE COMPLETED APPLICATION PACKAGE, INCLUDING THE ORIGINAL AND TWO
COPIES OF ALL SUPPORTING INFORMATION AND MATERIALS SHOULD BE SENT
TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DIVISION OF WATER QUALITY
POINT SOURCE BRANCH
1617 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1617
Page 15 of 15

Pm —E—W $ . Company. LLC
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RaWyh. NC 21602
,21 Progress Enemy
Check Date
26-NAR-09
Check Number
182873
Vendor name
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Vendor #
Invoice Number
Invoice Data
Adjustments
PaidAmount
030209
02-MAR-09
0.00
400,00
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Questions? Invoice.InquiryQDpnmail.c0m I
$ .00
$ 400.00
s 400.00
on behalf of Progress Energy, Inc. subsidiaries ,'I Progress; Energy
P.O. Box 1551 I
Raleigh, NC 27602
Vendor Number 11946
Check Date
20-MAR-09 182973
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TO THE N C DENR
ORDER DIV WATER QUALITY
OF 1617 MAIL SERV CTR
RALEIGH, INC 27699-1617
Wachovla Bank, N.A. m S
Augusta, GA
Signature
110182873119 1:0612097561 t■

ACCOUNTS PAYABLE
CHECK ROUTING INSTRUCTION REPORT
CHECKS RE"ING SPECIAL HANDLIM FOR:
Check Number Vendor Name InVOiCe NM
------------ _____________ _____
182873 N C DENR 030209
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Report Date: 26-MAR-09 07:26
Page: 1 of 1
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Subject: Roxboro Steam Electric Plant-NC0003425 j
Person County - 8
FGD Wastewater Treatment Systems Lr 0111 m a o
Monitoring, Repairs and Special Order by C( o R oru
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Final Effluent (NPDES Discharge) t $ ° 9 S 3
Dear Sirs: R n
❑❑ ❑❑
On December 1, 2008, the Raleigh Regional Office (R w
Quality (DWQ) requested confirmation from Progress ffi
a Special Order by Consent (SOC). On December 18, /vvo, u PL.
response. Accordingly, this follow-up letter is an effort to further detail components that
should be included in your pending SOC application.
Your Application should address the following items:
1) In a letter dated March 24, 2008 Progress Energy explained that a consulting firm
would analyze the pond slope failures and leakage problems, determine the root
causes of the problems, and prepare a high level evaluation of repair and
replacement options by June15, 2008.
a) Please include in your application the analysis and root cause
documentation.
b) Also, please include the evaluation of repair and replacement options.
2) Specifically address the redesign and respective replacement of the existing FGD
Settling Basin.
3) Specifically address the redesign and respective replacement of the existing the
FGD Flush Pond.
NQam�`hCarolina
N"frWhr
Raleigh Regional Office Surface Water Protection Phone [phone] Mail Service Center
Fax [phone] Raleigh, NC 27699-1628

f
4) Discuss the on -going monitoring (visual, physical measurements, and
documentation) efforts that are in place to insure the interim safety and structural
integrity of the berm walls, FGD Settling Pond, Flush Pond and Bioreactor.
Include an emergency response plan in the event of a structural failure.
5) Provide an analysis of your wastewater treatment capability that insures optimum
treatment of the FGD waste stream and NPDES wastewater discharge during
repairs, as well as, during future normal operations. Provide the design,
installation and implementation schedule of additional wastewater treatment
technologies (temporary and/or permanent) such as pH adjustment, clarification,
chemical precipitation, or other treatment system as necessary to abate concerns at
NPDES Outfall 003. [This should include an analysis of the monitoring Data
(influent prior to the settling pond/basin, influent after the settling pond/basin,
effluent of the bioreactor, outfall 002, and outfall 003) from March 2008 to
present]. Please identify lab methods and qualifiers as appropriate.
6) Provide a "performance" analysis of the FGD settling pond treatment and
bioreactor treatment based on the monitoring data [influent prior to settling
pond/basin, influent after the settling pond/basin, and effluent of the bioreactor
from March 2008 to present]. Please identify lab methods and qualifiers as
appropriate.
7) A clear implementation schedule with a project end date must also be included in
the application.
Thank you for your attention to this matter. If you have any questions please do not
hesitate to call me at [phone].
S' c ely,
Danny Smith
Raleigh Regional Supervisor
Surface Water Protection
cc: Raleigh Regional Office -File Copy
Central Files
Surface Water Protection Section Chief - Paul Rawls
NPDES Point Source Branch — Jeff Poupart
RRO - Autumn Hoban
Progress Energy Carolina, Inc. - Shannon Langley
410 S. Wilmington Street
PEB 4
Raleigh, NC 27601
VJ

O
January 5, 2009
Mr. Michael Mosley, Manager
Progress Energy Carolinas, Inc.
Roxboro Steam Electric Plant
1700 Dunnaway Road
Semora, NC 27343
Dear Mr. Mosley:
Michael F. Easley, Governor
William G. Ross Jr, Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
The Division of Water Quality has reviewed the 2009 biological monitoring study plan for the Roxboro Steam
Electric Plant (NC0003425), in Person County, and approves implementation of the plan, as there are no changes
from the 2008 plan, except the addition of two stations (5C and 7B) for water quality and water chemistry to help
assess any potential impacts from the recently installed wet scrubbers.
Sincerely,
m70ve!o
Chief, Environmental Sciences Section
Cc: Danny Smith, RRO
' Carolina
Wulwk
Environmental Sciences Section 1621 Mail Service Center Raleigh, NC 27699-1621 Phone [phone] Customer Service
Internet: w .esb.enr.state.nc.us 4401 Reedy Creek Road Raleigh, NC 27607 FAX [phone]
An Equal Opportunity/Affirmative Action Employer- 50%Recyded/10% Post Consumer Paper

FA , COVER SH�ET
NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
NCDENRRaleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-1628
�> Pages, inciuding cover sheet
TO: FAX:
FROM: DATE: 1- ,26-o i
SUBJECT:
i
If you do not receive all pages, call 919.791 4200 or fax back to a i 4 - -7F,8 - '71 5 9
PLEASE NOTE OUR PHONE NUMBER HAS CHANGED
THE FAX NUMBER REMAINS THE SAME

of W ArF Beverly Eaves Perdue, Governor
`0� 9OG Dee Freeman, Secretary
jLtin North Carolina Department of Environment and Natural Resources
< / G Coleen H. Sullins, Director
Division of Water Quality
January 26, 2009
Certified Mail # 7006 0810 0002 6049 6621
Return Receipt Requested
Progress Energy Carolinas, Inc.
Attention: Harry Sideris, Plant Manager
Roxboro Steam Plant
1700 Dunaway Road
Semora, NC 27343
Subject: Roxboro Steam Electric Plant—NC0003425
Person County
FGD Wastewater Treatment Systems
Monitoring, Repairs and Special Order by Consent
Final Effluent (NPDES Discharge)
Dear Sirs:
On December 1, 2008, the Raleigh Regional Office (RRO) of the Division of Water
Quality (DWQ) requested confirmation from Progress Energy of your intent to apply for
a Special Order by Consent (SOC). On December 18, 2008, the RRO received your
response. Accordingly, this follow-up letter is an effort to further detail components that
should be included in your pending SOC application.
Your Application should address the following items:
1) Ina letter dated March 24, 2008 Progress Energy explained that a consulting firm
would analyze the pond slope failures and leakage problems, determine the root
causes of the problems, and prepare a high level evaluation of repair and
replacement options by June15, 2008.
a) Please include in your application the analysis and root cause
documentation.
b) Also, please include the evaluation of repair and replacement options.
2) Specifically address the redesign and respective replacement of the existing FGD
Settling Basin.
3) Specifically address the redesign and respective replacement of the existing the
FGD Flush Pond.
ralCaro
ura/y
Raleigh Regional once Surface Water Protection Phone [phone] Mail Service Center
Fax [phone] Raleigh, NC 27699-1628

4) Discuss the on -going monitoring (visual, physical measurements, and
documentation) efforts that are in place to insure the interim safety and structural
integrity of the berm walls, FGD Settling Pond, Flush Pond and Bioreactor.
Include an emergency response plan in the event of a structural failure.
5) Provide an analysis of your wastewater treatment capability that insures optimum
treatment of the FGD waste stream and NPDES wastewater discharge during
repairs, as well as, during future normal operations. Provide the design,
installation and implementation schedule of additional wastewater treatment
technologies (temporary and/or permanent) such as pH adjustment, clarification,
chemical precipitation, or other treatment system as necessary to abate concerns
NPDES Outfall 003. [This should include an analysis of the monitoring Data
(influent prior to the settling pond/basin, influent after the settling pond/basin,
effluent of the bioreactor, outfall 002, and outfall 003) from March 2008 to
present]. Please identify lab methods and qualifiers as appropriate.
6) Provide a "performance" analysis of the FGD settling pond treatment and
bioreactor treatment based on the monitoring data [influent prior to settling
pond/basin, influent after the settling pond/basin, and effluent of the bioreactor
from March 2008 to present]. Please identify lab methods and qualifiers as
appropriate.
7) A clear implementation schedule with a project end date must also be included in
the application.
Thank you for your attention to this matter. If you have any questions please do not
hesitate to call me at [phone].
Sinc' ely,
Danny Smith
Raleigh Regional Supervisor
Surface Water Protection
cc: Raleigh Regional Office -File Copy
Central Files
Surface Water Protection Section Chief - Paul Rawls
NPDES Point Source Branch — Jeff Poupart
RRO - Autumn Hoban
Progress Energy Carolina, Inc. - Shannon Langley
410 S. Wilmington Street
PEB 4
Raleigh, NC 27601
N