NC0003425_Compliance Evaluation Inspection_20140121

A4
tCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A Reeder
Governor Director
January 21, 2014
Mr. Mike Mosley
Plant Manager
Roxboro Steam Electric Power Plant
1700 Dunnaway Rd
Semora, NC 27343
Dear Mr. Mosley:
AN
John E Skvada, III
Secretary
AN 2
Subject: NPDES Compliance Evaluation Inspection
NPDES Wastewater Discharge
Permit No. NC0003425
Roxboro Steam Electric Power Plant
Person County
On December 12, 2013, Autumn Romanski with the North Carolina Division of 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 me at 919-791-4255 in the
Raleigh Regional Office.
nc ely,
Danny Sm'th
Raleigh Regional Operations Supervisor

Attachments
Cc: (w/attachments) Raleigh Regional Office — File
DWQ/Raleigh — Central Files
Electronic Cc:
Mr. Shannon Langley, Mr. Robert Howard, and Mrs. LeToya Ogallo
2 1 P a g e

Section D Summary of Findings /Comments
R
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 wastewater requirements of the NPDES permit the day of
the inspection. The application for permit renewal was received on October 10, 2011 as
required The new permit has yet to be re -issued by the Division of Water Resources,
therefore, this inspection was conducted based on NPDES wastewater discharge permit issued
Al
u 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 acility was issued no penalty assessments and no notices of violation for the 12 -
month period
The wastewater and ,groundwater reports data was reviewed One data discrepancy
was found between a log book date for pH reading for Outfall 003 and date listed on
the DMR and an amended DMR was requested According to the data entered in the
DWR BIMs system the facility has provided the groundwater monitoring results as
required by the Groundwater Monitoring Plan dated March 17, 2011.
The records for the Biological Monitoring Plan reside with the Environmental Sciences
Section (DWR ESS). The facility has provided a copy of the 2012 results and is
currently completing the 2013 Monitoring Plan
31 Page

The records for the Ash Pond Dam IntegrzbY Inspections and the NPDES Stormwater
permitting and compliance now reside with the Division of Energy Mines and Land
Resources (NC DEMLR) and were not part of this inspection
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 compliance 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)
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 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 utzlizes 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 #5080 for pH and temperature measurements
The Regional Field Inspectors checklist (to be forwarded to the DWO LaboratozY
Certification Program) was completed the day of the inspection and reflects the extent of
laboratory items investigated by Regional inspectors Lab inspections are also _per ormed
separately by the Lab Certification Program The Regional lab checklist results are
attached.
4 1 P a g e

7. Flow Aleasurement:
Tf the permit regnires a Clow measurement device, doe determini-ig the eBluent flow, the
flow,measurement device must be calibrated annually
This fcredi'ty is regaire,d to monitor and report pl'ant pump log readings intake }low for
Outfall 003 and effiyent flow dor Outfall 002 (�hotil meter , Out all 010 (pump log flow
meter) Oulfall 009 (pump log flow meter at 002) (Jut cdl 006 (e3tianate stuf(Quake); cand
Outfall 008' (planp lob The f wili(y wav in comph nce with flow measurement
regiarementg (he day of the inspecnan The fiiadity completed extensive, repair upgrade at
the Internal Outfall 002 canal weir, and pl'a'ced a new flow meter in services (see photos of
Ow ul'7 002 below)
5IP'

SOfety improveinents and netiv oulfcll sign ~mere observed at the fined Outfall 003
8. Effluent/Receiving Waters:
The effluent discharge should be elear with a continuous flow with no visible changes to
the receiving waters -
The effluent discharge was clear and flotii� iiwy eontanuous The receiving ivaters looked
clear iiwh no visible changes from the effluent chscharve
9. Pretreatment:
This taeility currently has no pretreatment permit and does not accept or discharge
clotmolic or industrial wa&e to a asanitaiy seivet• vvstem Pre-treatment permits ure
requirecl, if applicable, by your VPLES Discharge Permit
10. Solids Handlinp-/Disposal:
The facility must dispose of solids bv ars 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 thecontractor's non -discharge permit 0 e land application) The
facility is reminded to maintain adequate records (i e, shipment dates, quantities etc) of
any solids hauling and/or disposal iienvities
61Page

The facilio� 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 day of the inspection.
7 1 P a g e

United States Environmental Protection Agency
Form Approved
Washington, D C 20460
EPA
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 ^ I 2 U 11 12I
117 18U 19U 20II 1 3/1/2 _j
Remarks
211111 Jill 1111 Jill 11111111111111111111111111111116
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA --------- - - --- —Reserved----- - -------
67 I 169 70 71 I I 721 N � 73 � 74 751 I I I I I I 180
—�
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
10 00 AM 13/12/12
09/07/01
Exit Time/Date
Permit Expiration Date
Person County Rd 1377
Roxboro NC 27573
12 00 PM 13/12/12
12/03/31
Name(s) of Onsite Rep resentative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
///
Eric Daniel Satterwhite/ORC/336-597-6270/
Name, Address of Responsible OfficialfTitle/Phone and Fax Number
Contacted
Mike Mosley700 Dunnaway Rd Semora NC 27343///
,1
No
Section C Areas Evaluated During Inspection (Check only those areas evaluated)
Permit N 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 / kl;
Autumn H Romanski �7LrJ%1— RRO WQ//919-791-4247/ 1.23
re of Manageme Q A Review r Agency/Office/Phone and Fa Numbers Date
:)2/9
EPA Form 3564 (Rev 9-94) Previous editions are obsolete
Page # 1

NPDES yr/mo/day Inspection Type
31 NC0003425 111 121 13/12/12 1 17 18I C
Section D Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
The facility was compliant with the permit requirements reviewed the day of this inspection
Page # 2

Permit NC0003425 Owner - Facility: Roxboro Steam Electric Power Plant
Inspection Date: 12/12/2013 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? ■ ❑ ❑ Cl
Is the facility as described in the permit? 0000
# 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: Permit expired 12/30/2012. The permittee submitted the renewal
application on October 5, 2011 and it was stamped received on October 10, 2011.
The expired permit will remain active until a new permit Is Issued.
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? ❑ ❑ ■ ❑
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:
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 pumps through pump logs as required
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?
Comment: The effluent flow Is reported from the Influent flow readings ( assumes all
water taken In Is discharged).
Equalization Basins
Yes No NA NE
Yes No NA NE
Yes No NA NE
Page # 3

Permit: NC0003425
Inspection Date: 12/12/2013
Owner - Facility: Roxboro Steam Electric Power Plant
Inspection Type: Compliance Evaluation
Equalization Basins
Is the basin aerated?
Is the basin free of bypass lines or structures to the natural environment?
Is the basin free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Are audible and visual alarms operable?
# Is basin size/volume adequate?
Comment: The facility has FGD Treatment basins (East and West, and a FGD
Backwash Pond). The FGD backwash pond (designed to overflow to the FGD West
Pond) can be pumped (portable temporary pump) to either the West or East Ponds as
needed. The West Pond (designed to overflow if needed to the East Pond). Overall
treatment capacity was improved with the addition of the East Pond.
Yes No NA NE
❑ ❑ ■ ❑
0❑■0
0❑■❑
0❑■❑
0000
❑0■0
❑0■0
❑0■❑
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 filte- 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?
❑
❑
❑
■
Comment: Gypsum Is dewatered and solid cake is provided to the CertianTeed Plant
located adjacent to the power plant for the production of wallboard. The solids handling
equipment for this process was not inspectec the day of this inspection.
Chemical Feed
Yes
No
NA
NE
Is containment adequate'?
■
❑
❑
❑
Is storage adequate?
■
❑
❑
❑
Are backup pumps available?
■
❑
❑
❑
Is the site free of excessive leaking?
■
Cl
❑
❑
Comment. Chemical feed for ash pond and coal pile runoff - 250 gallon tote bins with
meter pumps are set up for feeding Nalco product (settling/coag aid) as needed for
wastewater treatment.
Page # 4

Permit: NC0003425 Owner - Facility: Roxboro Steam Electric Power Plant
Inspection Date: 12/12/2013 Inspection Type: Compliance Evaluation
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: Outfall 003, Hyco Lake receiving water was clear, free of foam/debris the
day of this inspection.
The facility reduced safety risks associated with sampling from the pier by adding a new
platform and a new outfall identification sign.
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
000
❑
Is sample collected below all treatment units?
■
❑
❑
❑
Is proper volume collected?
000
❑
❑
❑
Is the tubing clean?
000
■
❑
❑
# 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)? ■ ❑ ❑ ❑
Comment:
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ❑ ❑ ■ ❑
Comment: DWR Environmental Sciences Section approves a Biological Monitoring
Plan for Hyco Lake annually. This plan is also referenced in the NPDES Permit
conditions.
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
000
❑
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 ■
Page # 5

Permit: NC0003425 Owner - Facility: Roxboro Steam Electric Power Plant
Inspection Date: 12/12/2013 Inspection Type: Compliance Evaluation
Yes
No
Record Keeping
Yes
No
NA
NE
Name of person performing analyses
■
Are all other parameters(excludmg field parameters) performed by a certified lab?
■
❑
Transported COCs
■
# Is the facility using a contract lab?
■
❑
Are DMRs complete* do they include all permit parameters?
■
❑
❑
❑
Has the facility submitted its annual compliance repor to users and DWQ9
❑
❑
❑
■
(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 creater 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?
❑
❑
Cl
■
Comment: One discreptancy was noted, results in wrong date column, but results
were verified and the facility will submit an amended DMR for September 2013
providing the results in the correct date column.
The facility keeps good records and was in compliance with the permit requirements the
day of this Inspection.
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
■
❑
❑
❑
Are all other parameters(excludmg 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 holds a DWR Field Lab Certification for pH and Temperature.
A Field Lab Inspection was completed and the checklist is attached. The facility lab was
in compliance with the lab requirements the day of this inspection.
Page # 6