NC0003425_Compliance Evaluation Inspection_20141215

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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Pat McCrory
Governor
December 15, 2014
Mr. Mike Mosley
Plant Manager
Roxboro Steam Electric Power Plant
1700 Dunnaway Rd
Semora, NC 27343
Dear Mr. Mosley:
DEC 17 2014
CENTRAL FILES
DWR SECTION
John E. Skvada, III
Secretary
Subject: NPDES Compliance Evaluation Inspection
NPDES Wastewater Discharge
Permit No. NC0003425
Roxboro Steam Electric Power Plant
Person County
On November 19, 2014, Autumn Romanski and Eric Rice with the North Carolina Division of
Water Resources conducted a Compliance Evaluation Inspection of the Roxboro Steam
Electric Power Plant. This inspection was conducted to verify that the facility is operating in
compliance with the conditions and limitations specified in NPDES Wastewater Permit No.
NC0003425. The time and assistance of Duke Energy Environmental Services Staff, Plant
Operators, and Laboratory Staff was greatly appreciated.
A summary of the findings and comments noted during this inspection is provided in the
attached copy of the complete inspection report titled "Water Compliance Inspection Report".
If you have any questions concerning this report, please contact Autumn Romanski 919-791-
4255 in the Raleigh R:egiOffice.
nicer ly,
GrJ /y
Danny Smi
Raleigh Regional Operations Supervisor
Attachments
Cc: (w/attachments) Raleigh Regional Office — File
DWQ/Raleigh — Central Files

Electronic Cc:
Mr. Shannon Langley and Mr. Robert Howard
2 1 P a g e

Summary of Findings /Comments
1. Permit:
Your NPDES Individual Wastewater permit became effective July 1, 2009 and expired on
March 31, 2012. The facility is not currently under a Special Order by Consent.
The facility was compliant with the NPDES permit wastewater requirements reviewed the day
of the inspection. The application for permit renewal was received on October 10, 2011 as
required. A recent update to the application has also been submitted The new permit has vet
to be re -issued by the Division of Water Resources, therefore, this inspection was conducted
based on NPDES wastewater dischargepermit issued July 1, 2009 as these requirements
remain in effect until the new permit is issued.
2. Compliance Schedules:
The permit does not have any outstanding compliance schedules for this facility.
3. Facility Site Review:
The overall condition of the plant site was satisfactory. The appearance of the facility was in
satisfactory condition indicating the current housekeeping practices are good.
4. Records/Reports:
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.
The acdiby was issued no penalty assessments and no notices of violation for the 12 -
month period
The wastewater reports data, bench sheets, and operator logs, for the months of
December 2013 and June 2014 were reviewed. The Flow data was provided on June 2,
but the BIMS DMR system flag edema frequency violation due to 7 consecutive dans
without a flow reading. This frequency violation can be corrected by forwarding an
amended June 2014 DMR with a Flow/No Flow reading as applicable between June 3
and June 9, for Outfall 006.
3 1 P a g e

The facility has provided the groundwater monitoring results as required by the
Groundwater Monitoring Plan gated March 17 2011. Monitoring wells BG -1 CW -2
CW -2D, CW -3, and CW -3D were inspected. All wells were observed to be locked with
well tags and caps present Monitoring wells were found to be in good condition Two
of the wells had loose fitting well caps which were corrected at the time of the
inspection
The records for the Biological Monitoring Plan reside with the Environmental Sciences
Section (DWR ESS
The records for the Ash Pond Liam Integrity Inspections and the NPDES Stormwater
permitting and compliance now reside with the Division of EnerQ,y Mines and Land
Resources tNC DEMLR) and were not part of this inspection However, safety
improvements were observed ar the Ash Pond Filter dike with the addition of new
stairs and access road improvements The Ash Pond filter dike discharge flows to the
internal NPDES Dischar e Outfall 002
An Operation and Maintenance Plan and Emergency Response Plan for the bioreactor
is required General Electric is the consultant/supplier of the Bioreactor operations
and maintenance and an Emergency Response Plan for the Roxboro Plant is inclusive
of Bioreactor operations
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 cor.iphance with these requirements The Operator in
Responsible Charge (ORC) is Eric D Satterwhite He holds a PC -1 (Cert No 996750)
and Wastewater III (Cert 989354) The permittee has several certified operators
designated as Back-up Operators (BORC's)
41 Page

5. Self -Monitoring Program:
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 acility 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 Pace NC
Certified Labs (different analytes are sent to different Pace locations- Raleigh
Asheville....) The facility holds a current NC DWO Laboratory Field Parameter
Certification 95080 for pH and temperature measurements.
The Regional Field Inspectors checklist (to be forwarded to the DWO Laboratory
Certification Program) was completed the day of the inspection and reflects the extent of
laboratory items investigated� by Regional inspectors. Lab inspections are also performed
separately by the Lab Certification Program. The Regional lab checklist results are
attached.
7. Flow Measurement:
If the permit requires a flow measurement device for determining the effluent flow, the
flow measurement device must be calibrated annually.
This facility is required to monitor and report plant pump log readings/intake flow for
Outfall 003 and effluent flow for Outfall 002 (flowmeter), Outfall 010 (pump log ow
meter), Outfall 009 (pump log - flows to Ash Pond 002), Outfall 006 (estimate/sta gua e),
and Ou all 008 (pump log -flows to Ash Pond 002. The facdity was in compliance with
flow measurement requirements the day of the inspection.
8. Effluent/Receiving 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
5 1 P a g e

9. Pretreatment:
This facility currently has no prerreatment permit and does not accept or discharge
domestic or industrial waste to a sanitary sewer system. Pre-treatment permits are
required, if applicable, by your NPDES Discharge Permit.
10. 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. The facility was in compliance with
these requirements the day of the inspection.
12. Compliance Sampling:
No compliance sampling was conducted the day of this inspection.
13. Operations & Maintenance:
The facility was in compliance with these requirements the da
y of the inspection
1) A recommendation was made to tighten well caps.
2) A recommendation was made to forward an Amended DMR for June 2014.
3) A recommendation was made to evaluate and consider the useful lie of the aging 1984
Domestic Wastewater Treatment package plant and ability to maintain dated
parts/structure into the future. The environmental risk would be an 1) un -anticipated
bypass of untreated/partially treated wastewater to the immediate plant area 2) the cost
of a pump and haul solution in the event ofplant failure, as the packagge plant is one
trane/no back-up.
-- - -- --- --- - -
61Page - -

United States Environmental Protection Agency
Form Approved
EPA Washington, D C 20460
OMB No 2040-0057
Water Compliance Inspection Report
Approval expires B-31-98
Section A National Data System Coding (i e , PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IA1 ' 2 15 1 3 I NC0003425 111 121 14/11/19 117 18 LCJ 19 I � I 201
211 11111 11111111111 1111111 1111111 1111111/1 I1 X66
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
67 70 I J _ 71 I 72 731 751 I 180
l-II I I I I
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)
09 30AM 14/11/19
09/07/01
Roxboro Steam Electric Power Plant
Person County Rd 1377
Exit Time/Date
Permit Expiration Date
Roxboro NC 27573
12 45PM 14/11/19
12/03/31
Name(s) of Onsite Representabve(s)/Tibes(s)/Phone and Fax Number(s)
Other Facility Data
///
Eric Daniel Satterwhite/ORC/336-597-6270/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Mike Mosley, 1700 Dunnaway Rd Semora NC 27343///
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
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
Eric S Rice RRO WQH919-791-4200/ 12—/
Autumn H Romanski RRO WQH919-791-4247/ (`(` 1i
Si natur of Managemen A R view �gency/Office/ ne and Fax um Date
�-'a
, ,
EPA Form 35 -3 (Rev 9-94) Previous editions are o solete
Page#

NPDES yr/mo/day Inspection Type
31 NC0003425 I11 12 14/11/19 i7 18 ICI
Section D Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
The permittee was compliant with teh permit requirements reviewed the day of this Inspection
Recommendations Included
1)Tlghten well caps
2)Amend June 2013 DMR
3)Evaluate useful life of the 1984 Domestic Wastewater Treatment Package Plant
Page#

Permit. NC0003425 Owner - Facility. Roxboro Steam Electric Power Plant
Inspection Date. 11/19/2014 Inspection Type: Compliance Evaluation
Permit
Yes No NA NE
(If the present permit expires in 6 months or less) Has the permittee submitted anew
E
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❑
application?
0
❑
❑
❑
Is the facility as described in the permit?
0
❑
❑
❑
# Are there any special conditions for the permit?
❑
❑
N
❑
Is access to the plant site restricted to the general public?
0
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment. The permit expired March 31, 2012. The permittee has submitted the permit renewal
application dated October 5 2011 and has recently submitted an update to that permit
renewal application The new permit has vet to be re -Issued by the Division of Water
Resources, therefore expired permit will remain the active permit until a new permit is
issued
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? ❑ ❑ N ❑
Comment:
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex MLSS, MCRT, Settleable 0 ❑ ❑ ❑
Solids, pH, D0, Sludge Judge, and other that are applicable?
Comment, Recommendations were made to evaluate and consider the useful life of the aging 1984
domestic wastewater treatment plant. NPDES Internal Outfall 008 The environmental risk
would be an 1)un-anticipated bypass of untreated/partially treated wastewater to the
Immediate plant area 2) the cost of a Dump and haul solution in the event of plant failure, as
the Dackage plant is one trane/no back-uD. The permittee has consistently met effluent limits
at Outfall 008, but the package plant Is 30 years old The permittee reported structural
inspection and repairs were completed In 2011-2012 Please routinely ensure that the high
level alarms are working (audible and visual) and that all drains to surface waters in the area
(If applicable) can be sealed in the event of a bypass
Flow Measurement - Influent
Yes No NA NE
# Is flow meter used for reporting?
E
❑
❑
❑
Is flow meter calibrated annually?
0
❑
❑
❑
Is the flow meter operational?
E
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117
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
❑
N
Comment- Flow is measured at the intake pumps as required by the permit
Page# 3

Permit: NC0003425
Inspection Date: 11/19/2014
Chemical Feed
Is containment adequate?
Is storage adequate?
Are backup pumps available?
Is the site free of excessive leaking?
Comment:
Sequencing Batch Reactors
Type of operation
Owner - Facility Roxboro Steam Electric Power Plant
Inspection Type. Compliance Evaluation
Yes No NA NE
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M
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M
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M
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M
Yes No NA NE
Is the reactor effluent free of solids?
❑
❑
0
❑
Does minimum fill time correspond to the peak hour flow rate of the facility?
❑
❑
0
❑
Is aeration and mixing cycled on and off during fill?
❑
❑
M
❑
The operator understands and can explain the process?
M
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❑
Comment, The Bioreactor Treatment for the FGD wastewater was operational the day
of the site visit
and the NPDES Discharge Outfal 010 which discharges below the surface of the ash
pond
discharge canal was observed clear, with a low sulfide odor present
A Sodium Bisulfite treatment is on-site for addition at the bioreactor inlet as needed DWR
has received notification of trials for this addition, and the information on this treatment was
submitted in the recent permit renewal application update
Lagoons
Type of lagoons?
# Number of lagoons in operation at time of visit'?
Are lagoons operated in?
# Is a re -circulation line present?
Is lagoon free of excessive floating materials?
# Are baffles between ponds or effluent baffles adjustable'?
Are dike slopes clear of woody vegetation?
Are weeds controlled around the edge of the lagoon?
Are dikes free of seepage?
Are dikes free of erosion?
Are dikes free of burrowing animals?
# Has the sludge blanket In the lagoon (s) been measured periodically In multiple
locations?
# If excessive algae is present, has barley straw been used to help control the growth?
Is the lagoon surface free of weeds?
Yes No NA NE
5
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Page# 4

Permit NC0003425
Inspection Date: 11/19/2014
Lagoons
Owner - Facility: Roxboro Steam Electric Power Plant
Inspection Type: Compliance Evaluation
Yes No NA NE
Is the lagoon free of short circuiting ❑ ❑ ❑ 0
Comment, The facility has the following settling pond treatment units associated with NPDES outfalls.
1 Ash Pond - Outfall 002
2 FGD Settlings ponds (East and West)- Outfall 010
1 FGD Backwash Pond - Can be recirculated/flow to FGD Settling Ponds - Outfall 010
1 Coal Pile Runoff Settlinq Pond - Outfall 006
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
❑
❑
0
❑
Is flow meter calibrated annually'?
❑
❑
M
❑
Is the flow meter operational?
❑
❑
0
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
0
❑
Comment. The Final NPDES Outfall 003 effluent flow Is reported from the influent flow readings
(assumes all water taken in is discharged) A flow meter is located at the internal Outfall
002 prior to mixing with the heated water (non -contact cooling water) discharge The Final
Outfall 003 receives flow from multiple wastewater/stormwater discharges
Effluent Pine Yes No NA NE
Is right of way to the outfall properly maintained? M ❑ ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris? M ❑ ❑ ❑
If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑
Comment:
Effluent Sampling
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)?
Yes No NA NE
❑ ❑ ❑ M
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Comment: No composite sampling is required by the permit, except for Acute Toxicity measured
quarterly
Grab sampling is completed as required by the permit
Page# 5

Permit NC0003425
Inspection Date: 11/19/2014
Upstream / Downstream Sampling
Owner - Facility: Roxboro Steam Electric Power Plant
Inspection Type. Compliance Evaluation
Is the facility sampling performed as required by the permit (frequency, sampling type, and
sampling location)?
Comment*
Record Keeping
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'7
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?
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?
Yes No NA NE
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Yes No NA NE
M
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M
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■
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■
000
Is a copy of the current NPDES permit available on site?
M
■
❑
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0
Comment* An amended DMR for June 2014 was requested for a flow recording for June 3 to be added
to the DMR. A flow reading was provided for June 2, but the Blms System flagged a
Page#
6
frequency violation because no reading was entered within a 7 -day running period
The
entry for Flow/NoFlow as applicable for June 3 will resolve the frequency violation.
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■
M
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Is the ORC visitation log available and current?
M
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Is the ORC certified at grade equal to or higher tha-i the facility classification?
M
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Is the backup operator certified at one grade less or greater than the facility classification?
0
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Is a copy of the current NPDES permit available on site?
M
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Facility has copy of previous year's Annual Report on file for review?
❑
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0
Comment* An amended DMR for June 2014 was requested for a flow recording for June 3 to be added
to the DMR. A flow reading was provided for June 2, but the Blms System flagged a
Page#
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frequency violation because no reading was entered within a 7 -day running period
The
entry for Flow/NoFlow as applicable for June 3 will resolve the frequency violation.
Laboratory
Yes No NA NE
Are field parameters performed by certified personrel or laboratory?
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Are all other parameters(excluding field parameters) performed by a certified lab?
M
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# Is the facility using a contract lab?
M
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# Is proper temperature set for sample storage (kept at less than or equal to 6 0 degrees
❑
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0
Celsius)?
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6

Permit NC0003425 Owner - Facility. Roxboro Steam Electnc Power Plant
Inspection Date, 11/19/2014 Inspection Type: Compliance Evaluation
Laboratory Yes No NA NE
Incubator (Fecal Coliform) set to 44 5 degrees Celsius+/- 0 2 degrees? ❑ ❑ E ❑
Incubator (BOD) set to 20 0 degrees Celsius +/- 1 0 degrees? ❑ ❑ 0 ❑
Comment. The permittee is currentiv in comDliance with Field Lab requirements (NC DWR Certfcation
#5080) and utilizes Pace NC Certfied Labs (different analytes are sent to different Pace Lab
locations
Pump Station - Influent Yes No NA NE
Is the pump wet well free of bypass lines or structures? ❑ ❑ ❑ N
Is the wet well free of excessive grease?
❑
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❑
N
Are all pumps present?
E
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Are all pumps operable?
0
❑
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❑
Are float controls operable?
N
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Is SCADA telemetry available and operational?
❑
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E
❑
Is audible and visual alarm available and operational?
0
❑
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❑
Comment, The alarm was tested at the domestic wastewater package plant Please ensure the alarm
is tested routinely
Bar Screens
Type of bar screen
Yes No NA NE
a Manual
Yes No NA NE
Is the basin aerated?
❑
❑
b Mechanical
❑
Is the basin free of bypass lines or structures to the natural environment?
❑
❑
Are the bars adequately screening debris?
E
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Is the screen free of excessive debris?
E
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Is disposal of screening in compliance?
E
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Is the unit in good condition?
E
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Comment Grinder pumps were being used at the inlet to the domestic wastewater
package plant
Debris is screened and removed as needed
Equalization Basins
Yes No NA NE
Is the basin aerated?
❑
❑
E
❑
Is the basin free of bypass lines or structures to the natural environment?
❑
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0
❑
Is the basin free of excessive grease?
❑
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0
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Are all pumps present?
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0
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Are all pumps operable?
❑
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E
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Are float controls operable?
❑
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E
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Page# 7

Permit. NC0003425
Inspection Date: 11/19/2014
Equalization Basins
Owner - Facility: Roxboro Steam Electric Power Plant
Inspection Type: Compliance Evaluation
Yes No NA NE
Are audible and visual alarms operable? ❑ ❑ E ❑
# Is basin size/volume adequate? ❑ ❑ E ❑
Comment: Ecluallzation occurs at the Influent well at the front of the package plant It appeared that the
alarm system was connected at the effluent well, there also may have been an alarm for the
Influent well. but I did not comment on this In my field notes The audible alarm worked, but
it was unclear at what Interval routine testing of the alarm(s) is completed.
Secondary Clarifier
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 return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable? (Approximately % of the sidewall depth)
Yes No NA NE
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N
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Comment. The package plant combines treatment into one compartmentalized unit with a catwalk
across the center of the unit The secondary clarifier follows in series after
equalization/aeration and observation of compartment components is limited during
operations Airlift pumps are used for return activated sludge
Aeration Basins
Yes No NA NE
Mode of operation
Ext Air
Type of aeration system
Diffused
Is the basin free of dead spots?
❑ N
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Are surface aerators and mixers operational?
❑ ❑
N
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Are the diffusers operational?
❑ ❑
E
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Is the foam the proper color for the treatment process?
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Does the foam cover less than 25% of the basin's surface?
❑
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Is the DO level acceptable?
❑ ❑
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0
Is the DO level acceptable?(1 0 to 3 0 mg/1)
❑ ❑
❑
E
Page# a

Permit NC0003425 Owner - Facility: Roxboro Steam Electric Power Plant
Inspection Date: 11/19/2014 Inspection Type: Compliance Evaluation
Aeration Basins Yes No NA NE
Comment: Aeration is by air lift pumps in continous operation. Airlift pumps are also used for
recircluation as needed.
Disinfection -Tablet
Are tablet chlorinators operational?
Are the tablets the proper size and type?
Number of tubes in use?
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de -chlorination?
Yes No NA NE
M ❑ ❑ ❑
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Comment: Chlorine tablets were in use as required No dechlorination is reouired by the permit.
Page# 9