NC0003425_Permit Modification_20090710

r
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 Sidens, Plant Manager
Roxboro Steam Electric Plant, d/b/a Progress Energy Carolinas, Inc
1700 Dunaway Road
Semora, North Carolina 27343
Subject: Permit Modification for Reverse Osmosis
NPDES Permit NC0003425
Roxboro Steam Electric Plant
1700 Dunaway Road
Person County
Dear Mr. Sidens:
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 0.034 % of your
average daily discharge to the natural environment.
Considering the proposed volume and concentrations of RO parameters of concern, the Divisionjudges 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,
e. Sullins
Enclosure: NPDES permit modification pages - NC0003425
cc Raleigh Regional Office/Surface Water Protection Section
Central Files
NPDES Program'
Aquatic Toxicology Unit, Attn. Susie Meadows
EPA Region 4, Attn Marshall Hyatt
1617 Mall Service Center, Raleigh, North Carolina 27699-1617
Location 512 N Salisbury St Raleigh, North Carolina 27604
Phone [phone] FAX [phone] \ Customer Service 1-877-623-6748
Internet www ncwaterquality org
An Equal Opportunity \ Affirmative Action Employer
Nne
orthCarolina
Amma,!!11

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 ..Tune 10, 2009.
Coleen H. Sullins, Director
orDivision of Water Quality
By Authority of the Environmental Management Commission

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 &s 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 Slowdown System (Internal Outfall 005). Cooling tower
blow4own from unit number 4 discharges into the ash transport,system, and
ultimately flows into the ash pond (Outfall 002).
■ 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
3. 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.

Joe's MOD Log NC0003425
04Jun09 -- Shannon Langley (Permittee: 919-546-2439; cell: 919-219-0905) called to
discuss progress on the MOD; he had talked to Gil who told him it was assigned to Joe.
Joe said he had looked at the file briefly but had not reviewed the MOD in detail.
08Jun09 -- Joe evaluated the MOD to add RO discharge; this discharge is proposed to
the Ash Pond (an internal outfall 002) as "low volume waste." RO discharge @ 250 gpm
(0.360 MGD) = 3.39 x 10-4 % @ flow rate of 1060 MGD from Outfall 003.
Joe discussed the MOD w/ Sergei (NPDES) and we agreed that @ this dilution, changes
to the effluent pages will not be necessary, therefore Joe will add RO to the permit
Supplement to Cover Sheet only Joe called Shannon Langley to ask if they were
planning to request an ATC for the permanent RO (initially lease to buy); he said that
since RO was not waste treatment equipment and he did not expect to go through CG&L.
Joe agreed. Joe submitted draft MOD to Gil and Jim for peer review.
09Jun09 -- Joe received comments on draft from Autumn Hoban (W -SRO) who
tentatively approved but noted that there are WQ issue with the holding pond; she
suggests we review these at next renewal. Gil returned DRAFT to Joe with comments
and corrections. Joe generated final documents and submitted to Jeff for final review,
signature and issuance.

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 refect 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
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 refect (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 refects 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 refect
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
�1� A*
V fitLfitLYtL7tPLllt—n-0-LIlteS/�Z
Environmental Senior Specialist
Division of Water Quality
Surface Water Protection
3800 Barrett Drive
Raleigh, NC 27609