NC0003425_NOV-2024-MV-0041_20240409

,;f --= DUKE
. ENERG,0
APR it ''
April 8, 2024
Vanessa Manuel, Assistant Regional Supervisor
Division of Water Resources
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27609
Subject: NOV-2024-W-0041
Duke Energy Progress, LLC - Roxboro Steam Electric Plant
Permit No. NC0003425
Semora, North Carolina; Person County
Dear Ms. Manuel:
Duke Energy Progress, LLC
Roxboro Steam Electric Plant
1700 Dunnaway Road
Semora, NC 27343
Duke Energy received a Notice of Violation (NOV-2024-MV-0041) that was issued to the
Roxboro Steam Electric Plant (Roxboro) from the Raleigh Regional Office on April 1, 2024,
The NOV was issued for a monitoring frequency violation on the December 2023 Discharge
Monitoring Report. Duke Energy would like to highlight the chain of events that led to the
monitoring frequency violation. They are as follows:
• 12/20/23 - Samples collected at the Roxboro Plant (Wednesday).
• 12/21/23 - Samples were received at Duke Energy Central Lab (DECL) (Thursday).
• 12/21/23 - Eurofins (contract laboratory) picked up the samples from DECL on Thursday
afternoon and sent to Eurofins laboratory facility in Florida via FedEx.
• 12/22/23 - Samples received by Eurofins in Florida on Friday at 09:48.
• 12/22/23 - Eurofins sent the Sample Acknowledgement Form (SAF) to DECL on Friday
at 17:42.
o The SAF indicated that there were no cracks or leaks present in the sample
containers. Had the issue been identified at this point, Duke Energy could have
collected additional samples.
• 12/28/23 — Duke Energy received email notification from Eurofins of the broken sample
containers on at 08:47 (one week after sample collection).
• 12/28/23 — DECL notified Roxboro personnel of the broken sample containers at 08:53.
• 12/28/23 - Duke Energy staff notified the Raleigh Regional Office of the issue at 13:23.
As shown on the bulleted list above, the sample containers were in good condition when they left
Duke Energy's custody on December 21, 2023. The sample containers were compromised after
Eurofins took possession of the sample containers later that day. The compromised sample
containers were then discovered by Eurofins a week later, when they opened the shipment to
complete the analysis. Because of the delay in opening the shipment, Duke Energy personnel
www.dukecnergy.wm

had no time to collect back-up samples to comply with permit monitoring requirements. As
required, Duke Energy staff immediately notified your office of the issue.
Please find enclosed information pertaining to the events that led to the missing weekly mercury
sample in December 2023. Enclosed are the SAF sheet, corrective actions that Eurofins lab has
implemented to prevent recurrence of the issue, a copy of the email notifying your office of the
issue, and a letter dated March 11, 2024 from Duke Energy providing information regarding the
issue.
As this chain of circumstances makes clear, the missing sample was the result of the actions of a
third party and beyond the ability of Duke Energy to control. For this reason, Duke Energy
suggests that a civil penalty is not warranted, and that withdrawal of the Notice of Violation
would be appropriate. It is also our intent to request removal of this weekly sample requirement
when the renewal application is submitted later this year given the changes in process flows that
led to the requirement. If you have any additional questions, please feel free to contact Mr. Steve
Cahoon at [phone] or [e-mail].
Sincerely,
Tom Copo
General Manager
Roxboro Steam Electric Plant
Attachments
Cc: Jessica Bednarcik
Steve Cahoon
Jason Robinson
Robert Howard

DUKE
ENERGY
Attachment A
Sample Acknowledgement Form

0510W1e rex 2 0
Sample Login Acknowledgement
Job 400-248845-1
Client Job Description:
J23110072 Roxboro NPDES Weekly Dewater (Week 3) Report To:
Duke Energy Corporation
Purchase Order #:
10865759
Jason Robinson
Work Order
J23110072
/'
13339 Hagers Ferry Road ��, JP rd £�%UA
Project Manager:
Todd Rea
Huntersville, NC 28078
Job Due Date:
12/29/2023
Job TAT:
3 Days
Max Deliverable Level:
II
Bill To:
Duke Energy Corporation
Accounts Payable
Earliest Deliverable Due: 12/29/2023
13339 Hagers Ferry Road
Huntersville, NC 28078
Login 400-248845
Sample Receipt:
12/22/2023 9:48:00 AM
Number of Coolers:
1
Method of Delivery:
FedEx Prionty, Overnight
Cooler Temperature(s) (C'):
0.0;
Lab Sample #
Client Sample ID
Date Sampled
Matrix
Method
Method Description I Work Location
Rpt Basis Dry I Wet"
400-248845-1
2023027182
12/20/2023 10:16:00 AM
Water
1631E
Mercury, Low Level/In-Lab
Total Wet
400-248845.2
2023027183
12/20/2023 10:15:00 AM
Water
1631E
Mercury, Low Level / In -Lab
Total Wet
400-2488464
2023027184
12/2012023 10:15:00 AM
Water
1631E
Mercury, Low Level / In -Lab
Total . Wet
400.248846-4
2023027186
12/19/2023 1:00:00 PM
Water
1631E
Mercury, Low Level / In -Lab
Total Wet
400-24884"
2023027186
12/2012023 10:15:00AM
Water
1631E
Mercury, Law Level / In -Lab
Total Wet
Method on -hold
" Wet/Dry indicates whether the reported results will be corrected for moisture content. and based on sample Wet weight or Dry weight. Page 1 of 1

Login Sample Receipt Checklist
Client: Duke Energy Corporation
Login Number: 248845
List Number: 1
Creator: Perez, Trina M
Question
Radioactivity wasn't checked or is </= background as measured by a survey
meter.
The cooler's custody seal, if present, is intact.
Sample custody seals, if present, are intact.
The cooler or samples do not appear to have been compromised or
tampered with.
Samples were received on ice.
Cooler Temperature is acceptable.
Cooler Temperature is recorded.
CDC is present.
CDC is filled out in ink and legible.
COC is filled out with all pertinent information.
Is the Field Samplers name present on COC?
There are no discrepancies between the containers received and the COC.
Samples are received within Holding Time (excluding tests with immediate
HTs)
Sample containers have legible labels.
Containers are not broken or leaking.
Sample collection date/times are provided.
Appropriate sample containers are used.
Sample bottles are completely filled.
Sample Preservation Verified.
There is sufficient vol. for all requested analyses, incl. any requested
MS/MSDs
Containers requiring zero headspace have no headspace or bubble is
<6mm (1/4").
Multiphasic samples are not present.
Samples do not require splitting or composiling.
Residual Chlorine Checked.
Answer Comment
N/A
True
N/A
True
True
True
True
True
True
True
True
True
True
True
True
True
True
True
N/A
True
N/A
True
True
N/A
0.0°C IR-8
Job Number: 400-248845-1
List Source: Eurofins Pensacola
Eurofins Pensacola

osiasnmo rev 2c
Job 400-248845-1
Client Job Description
Purchase Order M
Work Order #:
Project Manager:
Job Due Date:
Job TAT:
Max Deliverable Level,
Earliest Deliverable Due
Login 400.248845
Sample Login Analytes / Limits
J23110072 Roxboro NPDES Weekly Dewater (Week 3)
10865759
J23110072
Todd Rea
12/292023
3 Days
11
12292023
Sample Receipt: 12/222023 9:48:00 AM
Method of Delivery: FedEx Priority Overnight
Method
Method Description
1631E
Mercury, Low Level
Mercury
Report To: Duke Energy Corporation
Jason Robinson
13339 Hagers Ferry Road
Huntersville, NC 28078
Duke Energy Corporation
Accounts Payable
13339 Pagers Ferry Road
Huntersville, NC 28078
Number of Coolers: 1
Cooler Temperature(s) (C°): 0.0;
Bill To:
Rpt Basis
Total MDL RL
0.2 0.5
Units
ngIL
Sample #s Applicable
1,2,3 4.5
Page 1 of 1

%> DUKE
ENERGY,
Attachment B
Eurfins Timeline and Corrective Ations

titi eurofins
Environment Testing
03/11/2024
Jason Robinson
Duke Energy Corporation
13339 Hagers Ferry Road
Huntersville, NC 28078
Re: Broken Sample Vials Received for Low Level Mercury (LL HG) Analysis for Duke Energy -Addition a I
Corrective Action Information
Mr. Robinson,
In December of 2023, samples for LL Hg analysis were collected from Duke Energy to be submitted to our
Eurofins Pensacola facility for analysis. The timeline from courier sample pick-up to when Duke was
notified of the broken sample containers is summarized below:
Duke Energy LL HgTimeline
Action
Date
Charlotte Courier Pick -Up from Duke Energy
12/21/2023
Samples Shipped to Pensacola from Charlotte SC
12/21/2023
Samples Received in Pensacola
12/22/2023
Sample Login Review Completed
12/22/2023
PM Notified of Broken Containers by the Lab
12/27/2023 (After COB)
PM Notified Duke of Broken Containers
12/28/2023 (Morning)
As stated in the initial Corrective Action Response dated 12/29/23, our Charlotte Service Center has re-
assessed its cooler packing and shipping procedures to include extra layers of bubble wrap for sample
containers as well as inside of the cooler to eliminate shifting and movement during transit. LL Hg samples
will also be packaged in a separate cooler without thermal preservation to eliminate any unnecessary
objects packed inside of the cooler that may cause damage to the sample vials.
The Pensacola facility also incorporated process changes to aid in communicating issues of problematic
receipts in a more timely manner. Due to the stringent method requirements for LL Hg sample handling,
prior receipt procedures did not allow for full inspection of sample vials upon receipt in order to avoid
contamination when taken out of the bubble bags received in. Sample containers were received double
bagged from Duke with the client ID printed on the outside of the "dirty" bag. The double bagged samples
were then packed in single bubble wrap bags for shipping. Once received in Pensacola, the coolers would
be unpacked, but the LL Hg samples would not be removed from bubble bags - only opened just enough to
read the client labels then re -sealed with the UMS generated client labels affixed to the outside of the
bubble bag. Client samples would not be fully removed from the "clean" interior bag for labeling and
complete inspection until they were transferred to the clean area for LL Hg analysis. Only then would
communication proceed regarding broken sample containers.
These procedures, while meticulous, disallowed the containers to be fully inspected upon receipt which
would delay communicating issues of broken containers in a timely manner to PMs and clients. As such, no
record of any issues upon lab receipt were documented or communicated for these samples. The sample
Evdns Enrimrment Testing Sot&*t LLC 5102 LaFkche A.. T 912-356-Ta5S
Sw..n h. CA 314O4-6019 ..EwAnsUS.t ''En,

eurofins
Environment Testing
receipt confirmation, which includes the receipt checklist, was emailed to Duke on 12/22/23 and listed no
discrepancies or issues with sample containers. This, in addition to the holidays, led to a 5-day delay in
notifying the PM about this occurrence. Furthermore, it is inconclusive as to when the containers broke
and the sample volume was lost - in transit, upon receipt, or upon transfer to the lab for analysis. It is likely
that the 3rd party courier mishandled this cooler shipment over the busy holiday season resulting in the
vials being damaged.
With the incorporation of changes in packing samples for shipment from Charlotte and adjusting receipt
procedures in Pensacola, samples will now be fully inspected upon receipt in the Pensacola Receiving
Department. Since samples are already submitted double bagged, the containers will be fully removed
from the bubble bag in the receiving department without risk of contamination. Once out of the bubble
bag, containers can be fully inspected for breakages with more timely notifications sent to PMs regarding
non -conformances and container issues. This will allow for more accurate real-time notifications of such
issues to the client.
Should you have any further questions regarding this occurrence or if additional information is necessary,
please feel free to contact me at [phone] or via email at [e-mail].
Sincerely,
6kja —Mo7, 661
Polly Thornton
Quality Assurance Manager
Eurofins Environment Testing Southeast, Savannah
Eudga Ea,.n nt Tong S..M ast LLC 5102 laftc Meru T 1912-354-78%
Sararaah GK 314Wf019 0 EurdWM S.dmYEm

It DUKE
ENERGY
Attachment C
Email to Raleigh Regional Office Regarding Missing Sample

From: Tollie, Lori White <[e-mail]>
Sent: Thursday, December 28, 2023 1:23 PM
To: [e-mail]; Clayton, Kevin D <[e-mail]>; Enoch, Ryan S.
<[e-mail]>
Cc: McDaniel, Kim Spence <[e-mail]>
Subject: Roxboro Steam Station Permit #NC0003425
Vanessa,
The weekly low level mercury sample for internal outfall 002 at the Roxboro Steam Station collected for
the week of December 20`h, was broken in transit so that the low level Hg analysis could not be
completed. Internal outfall 002 has augmented sampling requirements because the former FGD outfall
was upstream of internal outfall 002. This FGD outfall is no longer in service. The eDMR will have notes
added referencing this issue. Please let me know if you would like to discuss further or if you will require
any further information.
Thankyou
Lori W. Tollie
Duke Energy
Permitting & Compliance
500 Utility Drive
Lewisville, NC 27012
Cell: [phone]
Office: [phone]

%> DUKE
ENERGY
Attachment D
Duke Energy Letter to Raleigh Regional Office Dated March 11, 2024

DUKE
ENERGY.,
March 11, 2024
Vanessa Manuel, Assistant Regional Supervisor
Division of Water Resources
Raleigh Regional Office
3800 Barrett Drive
Raleigh, NC 27608
Duke Energy
Environmental Services
410 S. Wilmington Street
Raleigh, NC 27601
Subject: Information from contract lab on broken Low Level Mercury sample
bottles — December 2023 DMR
Roxboro Steam Electric Plant
NC0003425
Person County
Dear Ms. Manuel:
Attached to this letter please find information from Eurofins lab as to the events that led to the
missing weekly mercury sample in December 2023 and corrective actions implemented.
Duke Energy station personnel collected samples as required however, the low-level sample
vials were broken either in transit with the vendor courier or at our vendor lab facility. Upon
notification of this, Duke staff immediately notified your office, but were unable to collect another
sample for the week due to the delayed notification from the lab associated with the Christmas
Holiday. The attached document contains additional process improvements implemented by the
vendor lab to provide further assurance that additional occurrences are avoided.
Duke Energy requests that you consider these actions when evaluating any response to the
missing weekly sample. It is also our intent to request removal of this weekly sample
requirement when the renewal application is submitted later this year given the changes in
process flows that led to the requirement. If you have any additional questions, please feel free
to contact Mr. Steve Cahoon at [phone] or [e-mail].
S-T- incerelW
Zach Hall
Vice President
Environmental, Health & Safety
Attachment
Cc: Tom Copolo
Steve Cahoon
Jason Robinson
Robert Howard
w w��.dukc<wm,.umi

eurofins
Environment Testing
03/11/2024
Jason Robinson
Duke Energy Corporation
13339 Hagers Ferry Road
Huntersville, NC 28078
Re: Broken Sample Vials Received for Low Level Mercury (LL HG) Analysis for Duke Energy - Additional
Corrective Action Information
Mr. Robinson,
In December of 2023, samples for LL Hg analysis were collected from Duke Energy to be submitted to our
Eurofins Pensacola facility for analysis. The timeline from courier sample pick-up to when Duke was
notified of the broken sample containers is summarized below:
Duke Energy LL Hg Timeline
Action
Date
Charlotte Courier Pick -Up from Duke Energy
12/21/2023
Samples Shipped to Pensacola from Charlotte SC
12/21/2023
Samples Received in Pensacola
12/22/2023
Sample Login Review Completed
12/22/2023
PM Notified of Broken Containers by the Lab
12/27/2023 (After COB)
PM Notified Duke of Broken Containers
12/28/2023 (Morning)
As stated in the initial Corrective Action Response dated 12/29/23, our Charlotte Service Center has re-
assessed its cooler packing and shipping procedures to include extra layers of bubble wrap for sample
containers as well as inside of the cooler to eliminate shifting and movement during transit. LL Hg samples
will also be packaged in a separate cooler without thermal preservation to eliminate any unnecessary
objects packed inside of the cooler that may cause damage to the sample vials.
The Pensacola facility also incorporated process changes to aid in communicating issues of problematic
receipts in a more timely manner. Due to the stringent method requirements for LL Hg sample handling,
prior receipt procedures did not allow for full inspection of sample vials upon receipt in order to avoid
contamination when taken out of the bubble bags received in. Sample containers were received double
bagged from Duke with the client ID printed on the outside of the "dirty" bag. The double bagged samples
were then packed in single bubble wrap bags for shipping. Once received in Pensacola, the coolers would
be unpacked, but the LL Hg samples would not be removed from bubble bags - only opened just enough to
read the client labels then re -sealed with the LIMS generated client labels affixed to the outside of the
bubble bag. Client samples would not be fully removed from the "clean" interior bag for labeling and
complete inspection until they were transferred to the clean area for LL Hg analysis. Only then would
communication proceed regarding broken sample containers.
These procedures, while meticulous, disallowed the containers to be fully inspected upon receipt which
would delay communicating issues of broken containers in a timely manner to PMs and clients. As such, no
record of any issues upon lab receipt were documented or communicated for these samples. The sample
EumfN En vmmeat Tot-ng 5av[ ' LLC 5102 LaRoche Avenue T 912-354 7858
Sa mh. GA 31404-6019 _E fi,_US.ce E. v

. -. eurofins
Environment Testing
receipt confirmation, which includes the receipt checklist, was emailed to Duke on 12/22/23 and listed no
discrepancies or issues with sample containers. This, in addition to the holidays, led to a 5-day delay in
notifying the PM about this occurrence. Furthermore, it is inconclusive as to when the containers broke
and the sample volume was lost - in transit, upon receipt, or upon transfer to the lab for analysis. It is likely
that the 3rd party courier mishandled this cooler shipment over the busy holiday season resulting in the
vials being damaged.
With the incorporation of changes in packing samples for shipment from Charlotte and adjusting receipt
procedures in Pensacola, samples will now be fully inspected upon receipt in the Pensacola Receiving
Department. Since samples are already submitted double bagged, the containers will be fully removed
from the bubble bag in the receiving department without risk of contamination. Once out of the bubble
bag, containers can be fully inspected for breakages with more timely notifications sent to PMs regarding
non -conformances and container issues. This will allow for more accurate real-time notifications of such
issues to the client.
Should you have any further questions regarding this occurrence or if additional information is necessary,
please feel free to contact me at [phone] or via email at polls.thorntonCcDet.eurofinsus.com.
Sincerely,
Polly Thornton
Quality Assurance Manager
Eurofins Environment Testing Southeast, Savannah
Emafur Ewm .t Tesb g Smn e� f1C 5102 laRmc Aw T 912-354 7858
Sav hm GA 31404-6019 wwr_EaufimsUS-cm E,%

OSM&10 rev 2.0
Sample Login Acknowledgement
Job 400-248845-1
Client Job Description: J23110072 Roxboro NPDES Weekly Dewater (Week 3) Report To:
Purchase Order#: 10865759
Work Order#: J23110072
Project Manager: Todd Rea
Job Due Date: 12/29/2023
Job TAT: 3 Days
Max Deliverable Level: II Bill To:
Earliest Deliverable Due: 121292023
Login 400-248845
Duke Energy Corporation
Jason Robinson
13339_Hagers Ferry Road
Huntersville, NC 20078
Duke Energy Corporation
Accounts Payable
13339 Hagers Ferry Road
Huntersville, NC 28078
Sample Receipt:
12/222023 9:48:00 AM
Number of Coolers:
1
Method of Delivery:
FedEx Prionty Overnight
Cooler Temperature(s) (C'):
0.0;
Lab Sample #
Client Sample ID
Date Sampled
Matrix
Method
Method Description I Work Location
Rpt Basis
400-248845-1
2023027182
12/2012023 10:15:00 AM
Water
1631E
Mercury, Low Level / In -Lab
Total
400-248846.2
2023027183
12/20/2023 10:15:00 AM
Water
1631E
Mercury, Law Level / In -Lab
Total
400-248846-3
2023027184
12/20/2023 10:16:00 AM
Water
1631E
Mercury, Low Level / In -Lab
Total
400-248846-4
2023027186
12119/2023 1:00:00 PM
Water
1631E
Mercury, Low Level / In -Lab
Total
400-240846-5
2023027186
12/20/2023 10:15:00 AM
Water
1631E
Mercury, Low Level / In -Lab
Total
Dry/Wet"
Wet
Wet
Wet
Wet
Wet
Method on -hold
" Wet/Dry indicates whether the reported results will be corrected for moisture content, and based on sample Wet weight or Dry weight. Page 1 of 1

Login Sample Receipt Checklist
Client: Duke Energy Corporation
Login Number: 248845
List Number: 1
Creator: Perez, Trina M
Question
Radioactivity wasn't checked or is 4= background as measured by a survey
meter.
The cooler's custody seal, if present, is intact.
Sample custody seals, if present, are intact.
The cooler or samples do not appear to have been compromised or
tampered with.
Samples were received on ice.
Cooler Temperature is acceptable.
Cooler Temperature is recorded.
COC is present.
CDC is filled out in ink and legible.
CDC is filled out with all pertinent information.
Is the Field Sampler's name present on COC?
There are no discrepancies between the containers received and the COC.
Samples are received within Holding Time (excluding tests with immediate
HTs)
Sample containers have legible labels.
Containers are not broken or leaking.
Sample collection date/times are provided.
Appropriate sample containers are used.
Sample bottles are completely filled.
Sample Preservation Verified.
There is sufficient vol. for all requested analyses, inol. any requested
MS/MSDs
Containers requiring zero headspace have no headspace or bubble is
46mm (1/4").
Multiphasic samples are not present.
Samples do not require splitting or compositing.
Residual Chlorine Checked.
Answer Comment
N/A
True
N/A
True
True
True
True
True
True
True
True
True
True
True
True
True
True
True
N/A
True
N/A
True
True
N/A
0VC IR-8
Job Number: 400-248845-1
List Source: Eurofins Pensacola
Eurofins Pensacola

05I0512010 nv 2 0
Sample Login Analytes / Limits
Job 400-248845-1
Client Job Description:
J23110072 Roxboro NPDES Weekly Dewater (Week 3) Report To:
Duke Energy Corporation
Purchase Order #:
10865759
Jason Robinson
Work Order #:
J23110072
13339 Hagers Ferry Road
Project Manager:
Todd Rea
Huntersville, NC 28078
Job Due Date:
12/292023
Job TAT:
3 Days
Max Deliverable Level:
II
Bill To:
Duke Energy Corporation
Accounts Payable
Earliest Deliverable Due:
12/29/2023
13339 Hagers Ferry Road
'
Huntersville, NC 28078
Login 400-248845
Sample Receipt:
12/22/2023 9:48:OOAM
Number of Coolers:
1
Method of Delivery:
FedEx Priority Overnight
Cooler Temperature(s) (C°):
0.0;
Method
Rpt Basis
Units Sample#s Applicable
Method Description
1831E
Total MDL RL
1,2,3,4,5
Mercury, Low Level
Mercury
0.2 0.5
ng/L
Page 1 of 1