NC0005088_Compliance Evaluation Inspection_20240709

SENT VIA ELECTRONIC MAIL ONLY: NO HARDCOPY WILL BE MAILED

July 09, 2024

Steve D Hodges
Duke Energy Carolinas LLC
Email: [e-mail]

SUBJECT: Compliance Inspection Report
Rogers Energy Complex
NPDES WW Permit No. NC0005088
Rutherford County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Rogers Energy Complex
on 7/02/2024. This inspection was conducted to verify that the facility is operating in compliance with
the conditions and limitations specified in NPDES WW Permit No. NC0005088. The findings and
comments noted during this inspection are provided in the enclosed copy of the inspection report
entitled "Compliance Inspection Report".

There were no significant issues or findings noted during the inspection and therefore, a response to this
inspection report is not required.

If you should have any questions, please do not hesitate to contact Mikal Willmer with the Water
Quality Regional Operations Section in the Asheville Regional Office at 828-296-4686 or via email at
[e-mail].

Sincerely,

Daniel Boss, Assistant Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection report

Ec: Joe Hall, Duke Energy
Docusign Envelope ID: 32B1ACB6-0FC2-4929-A552-8DD1C0D8543B
EPA
United States Environmental Protection Agency
Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
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 N 52 NC0005088 24/07/02 C S31112171819 20
21 66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
N67707172 73 74 75 80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Rogers Energy Complex
573 Duke Power Rd
Mooresboro NC 28114
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
09:40AM 24/07/02 21/07/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Joseph David Hall/ORC/828-657-2326/
Other Facility Data
12:00PM 24/07/02 23/08/31
Name, Address of Responsible Official/Title/Phone and Fax Number
Steve D Hodges,573 Duke Power Rd Mooresboro NC
28114//828-657-2000/8286572060
Contacted
Yes
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self-Monitoring Program Sludge Handling Disposal Facility Site Review Compliance Schedules
Pretreatment Effluent/Receiving Waters 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 Inspector(s)Agency/Office/Phone and Fax Numbers Date
Mikal Willmer DWR/ARO WQ/828-296-4686/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Daniel J Boss DWR/ARO WQ/828-296-4658/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#1
Docusign Envelope ID: 32B1ACB6-0FC2-4929-A552-8DD1C0D8543B
7/11/2024
7/11/2024
NPDES yr/mo/day
24/07/02
Inspection Type
C3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Mikal Willmer, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of
Roger’s Energy Complex on July 2, 2024. This inspection was conducted to determine whether the
facility is being operated and maintained in compliance with NPDES Permit #NC0005088. Randy
Hawkins, Steve Hodges and Joe Hall, with Duke Energy, were present and assisted in the inspection.
Overall, the facility appeared to be operated and maintained in compliance with the NPDES permit
requirements.
Several small, Grade II Biological package plants onsite service sanitary wastes from the
administration building, the Unit 5 and Unit 6 production areas of the facility. All have audio and visual
alarms and are connected to the main control room for monitoring. Staff check these plants daily. All
sanitary wastes discharge to the Final WWTS
Unit 5: A natural gas and coal co-fired system. Duke continues to reduce the amount of coal used.
Unit 5 is used when needed. Cannot switch unit 5 completely to natural gas due to the size of the gas
line coming into the facility.
Unit 6: Primary unit in use. Can be operated on coal, natural gas or co-fired.
Onsite water treatment systems clarify water pulled from the broad river to be used as cooldown
water within Unit 5 and Unit 6. Staff stated they are piloting the use of alum instead of ferric sulfate for
water treatment due to costs and additional precipitate associated with the use of ferric. Pilot tests
are promising, and staff report improved settling within their onsite clarifiers. Sludge blankets are
measured frequently and maintained at approximately 4.5’ out of 15’.
All drains within the active production area of the property are routed to one of the basins or pumped
to the treatment system. Stormwater outfalls under their individual stormwater permit are located
outside of the production area.
Flue Gas Desulfurization (FGD) system WWTS: Receives blow down water from the FGD system.
Consists of an EQ tank, reaction tanks, clarifiers, gravity tanks, a two-stage bioreactor and ultrafilters.
Bioreactors were the most recent addition to the treatment system to help further remove metals from
the waste stream. The bioreactors contain a carbon media that is periodically replaced. Staff report
they continue to fine tune the operation of the system since their one selenium exceedance in 2023.
The ORC reports part of the issue arose from the intermittent use of Unit 5. This has required
modifying nutrient addition to keep the bacteria in the bioreactor at an optimal level. Staff are also
reviewing process data more frequently to adjust the system before sampling. It should be noted that
004 is an internal outfall and is mixed with the effluent from the Final WWTS before being discharged
to the Broad River under outfall 005.
Coal Storage: A drainage system is located around the coal pile and a berm is present along the
roadway to funnel any runoff to the holding basin. Coal would have to travel approximately 500 feet to
enter the Broad. One incident in the past where one cubic yard reached the river. A track-hoe is kept
onsite by the pile to move any coal that is clogging the drainage ditch or has migrated from the main
pile.
Limestone Storage: Limestone is brought in via rail to make the lime slurry for the FGD system. Any
runoff is routed to the holding basin.
Final WWTS: Most of the onsite process flows are routed through the Final WWTS. Receives flows
from stormwater runoff via the basement basin, coal, limestone and gypsum pile runoff via the holding
basin, sanitary and water treatment wastewaters, cooling tower blowdown water, landfill leachate and
other process wastewaters from the production area. The System consists of two EQ tanks, reaction
NC0005088 17 (Cont.)
Page#2
Docusign Envelope ID: 32B1ACB6-0FC2-4929-A552-8DD1C0D8543B
Permit:NC0005088
Inspection Date:07/02/2024
Owner - Facility:
Inspection Type:
Rogers Energy Complex
Compliance Evaluation
tanks for pH neutralization and coagulation and three high-rate Actiflo clarifiers. The system also has
polishing disc filters to use as needed.
Solids: Belt-filter press onsite near the Final WWTS. All pressed solids are hauled to the onsite
landfill for disposal.
Outfall 005: Staff use pump run time to measure flow for 005. The size of the pipe entering the flume
does not allow for accurate measurements in the primary Parshall flume. pH is monitored near the
outfall and flow can be diverted to the holding basin if the pH of the waste stream approaches 9.
Onsite laboratory: Analyze most parameters in-house. Send out low-level mercury, nutrients and
aquatic toxicity. Outside laboratories used are ETS, Eurofins and Waypoint.
Outfall 002: Has not had a discharge since April 2020 when the valve was shut. All flows are currently
routed to the Final WWTS.
Toe seeps: Constructed seeps 106 and 104 below the active ash basin & storage area currently have
minimal flow. TSS is occasionally an issue at these outfalls due to proximity to river and sampling
point. DWR requested Duke inform the Division if at any point they feel the sampling locations are no
longer representative of the waste stream.
Inactive Ash Basin 5: Is currently in Phase II of closure. Uncontaminated soil from the Dam
embankment is being retained in cell 5 of the landfill for use in basin closure.
Active Ash Basin: Basin was removed from service in 2019 and decanting completed in 2020. The
SOC was terminated in 2021 with the approval of the Corrective Action Plan. Coal ash removal began
approximately one year ago, and Duke staff indicate the contractor will likely be ahead of schedule.
Approximately 200 trucks-loads on average are hauled to the onsite landfill a day. Staff noted there
are several natural springs within the basin which will require the last layers of coal ash to be dried
before hauling to the landfill. The ORC indicated they can pump water out of the basin during the
closure process as needed.
Landfill: The landfill consists of five cells in total. The contractor is currently applying ash to open
cells 3 and 4. It is currently unknown if cell 5 will be needed. The leachate system around the landfill
drains to a retention pond. Pumps are float activated and a dedicated generator is onsite in the event
of a power outage. The retention pond has approximately seven days of storage. Staff can access
the leachate system for observation and cleaning at several locations.
002B & 002C: Both outfalls are designed to only discharge during a 100 yr. 24-hr storm event. Staff
report these have not overflowed during the latest permit cycle. Any sample from a discharge would
likely exceed permit limits since they were not designed for treatment. Staff indicated the aquatic tox
condition for these outfalls is also hard to comply with due to having to notify the laboratory in
advance for the test and would request this special condition of the permit be removed.
Page#3
Docusign Envelope ID: 32B1ACB6-0FC2-4929-A552-8DD1C0D8543B
Permit:NC0005088
Inspection Date:07/02/2024
Owner - Facility:
Inspection Type:
Rogers Energy Complex
Compliance Evaluation
Compliance Schedules Yes No NA NE
Is there a compliance schedule for this facility?
Is the facility compliant with the permit and conditions for the review period?
The SOC for the facility has been terminated and Duke Energy is carrying out their
Corrective Action Plan.
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:
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?
Significant work has been completed since last permit modification. The permittee has
listed several corrections in the permit renewal application based on current process
flows.
Comment:
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain-of-custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Page#4
Docusign Envelope ID: 32B1ACB6-0FC2-4929-A552-8DD1C0D8543B
Permit:NC0005088
Inspection Date:07/02/2024
Owner - Facility:
Inspection Type:
Rogers Energy Complex
Compliance Evaluation
Record Keeping Yes No NA NE
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified
operator on each shift?
Is the ORC visitation log available and current?
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?
Daily checks and DMR associated data were available for review. A checklist is
retained with the DMR and laboratory data to ensure all sampling and procedures are
completed for compliance.
Comment:
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment:
Flow Measurement - Effluent Yes No NA NE
# 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?
Pump logs are used for flow reporting.Comment:
Solids Handling Equipment Yes No NA NE
Is the equipment operational?
Is the chemical feed equipment operational?
Is storage adequate?
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
Is the site free of sludge buildup on belts and/or rollers of filter press?
Is the site free of excessive moisture in belt filter press sludge cake?
The facility has an approved sludge management plan?
Page#5
Docusign Envelope ID: 32B1ACB6-0FC2-4929-A552-8DD1C0D8543B
Permit:NC0005088
Inspection Date:07/02/2024
Owner - Facility:
Inspection Type:
Rogers Energy Complex
Compliance Evaluation
Solids Handling Equipment Yes No NA NE
Solids are disposed of in the onsite landfill.Comment:
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type,
and sampling location)?
Temperature sampling is required.Comment:
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
Sampler not setup during inspection. Composite for TSS & O&G only required twice
per month.
Comment:
Page#6
Docusign Envelope ID: 32B1ACB6-0FC2-4929-A552-8DD1C0D8543B