NC0003425_Compliance Evaluation Inspection_20120208

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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Waklld, P E Dee Freeman
Governor Director Secretary
February 8, 2012
Mr. Mike Mosley
Plant Manager
Progress Energy Carolinas, Inc.
Roxboro Steam Electric Generating Plant
1700 Dunnaway Rd.
Semora, NC 27343
Subject: Compliance Evaluation Inspection (Revised)
NPDES Permit No. NC0003425
Roxboro Steam Electric Generating Plant
Person County
Dear Mr. Mosley:
F R 16 2012
CENTRAL FILES
DWQ/BCG
This letter supersedes the Compliance Evaluation Inspection Letter dated October 13, 2011, which
contained incorrect reference in Item 6 (correct reference is underlined and highlighted)
On September 27, 2011, Cheng Zhang and Autumn Romanski of the Raleigh Regional Office (RRO)
conducted a compliance evaluation inspection of the subject facility. The assistance of Ms. Amber
Ramey, Mr. Robert Howard, and Mr. Shannon Langley, was appreciated as it facilitated the inspection
process. The inspection report is attached. The following observations were made:
Progress Energy Carolinas, Inc., Roxboro Steam Electric Generating Plant is authorized to operate
the following systems: ash pond treatment system, heated water discharge canal system, cooling
tower blowdown system, coal pile runoff treatment system, domestic wastewater treatment system,
chemical metal cleaning treatment system, and flue gas desulfurization (FGD) treatment system.
The final effluent is discharged into the Hyco Lake, classified WS -V & B waters in the Roanoke
River basin.
1. The newly built east FGD pond and refurbished west FGD pond are redundant, at the time of
this inspection only the west FGD pond was in use to receive FGD blowdown water and
supernatant from the nearby bioreactor flush pond. Supernatant from the FGD pond is treated
by the bioreactors and then discharged in to the canal at Outfall 010.
North Carolina Division of Water Quality 1628 Mail Service Center Raleigh, NC 27699-1628 Phone [phone]
Service
Internet www ncwaterquality org Location 3800 Barrett Drive Raleigh, NC 27609 Fax [phone]
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NPDES Permit No NCO058416
Compliance Evaluation Inspection
2. An alum feeding system, which is comprised of two 250 -gallon totes, pump, and solar power
panels, is available to feed alum to the channel in the west ash pond. The system was not
running at the time of the inspection because the plant was not running wet ash.
3. The domestic wastewater treatment system was operated properly. The aeration basin was
reseeded in July 2011.
4. The coal pile runoff treatment system was observed during the inspection. It was noted that the
proposed sodium hydroxide feed system had not been constructed yet. Caustic is fed to the
runoff manually.
5. Lab results, chain -of -custody forms, and DMRs were complete and current, kept in good order
and ready for review. June 2011 DMR data were compared to lab results; no discrepancies
were noted.
6. Outfalls 002, 003, 006, 008, and 010 were observed during the inspection. It was noted that
there were several leaking spots at outfall 002, not all effluent flew through the v -notch weir,
which affects the accuracy of estimating the flow from the outfall. This problem had been
_mentioned in the Memorandum to EPA from RRO dated November 16, 2009 (see
enclosed copy of the Memorandum). Mr. Langley stated that Progress Energy had hired a
consultant to evaluate the problem. Please resolve this problem and respond to RRO in
writing within 90 days of receipt of this letter.
The overall condition of the subject facility is compliant with Division standards. If you have any
questions regarding the attached report or any of the findings, please contact Cheng Zhang at: (919)
791-4200 (or email: (cheng zhang@ncdenr. ov)).
Sincerely,
117��I.�/'��•
lu�tumn
Cheng Zhang Romanski
Environmental Specialist Environmental Senior Specialist
Attachments: Memorandum to EPA from DWQ RRO
Cc: Central Files w/attachment
Raleigh Regional Office w/attachment
Amber Ramey - Roxboro Steam Electric Generating Plant

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RMENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins Dee Freeman
Beverly Eaves Perdue Director Secretary
Governor
November 16, 2009
MEMORANDUM
To: Mr. Jim Kohler, P E.
Environmental Engineer LT, U.S. Public Health Service
U.S. Environmental Protection Agency
Office of Resource Conservation and Recovery
From: Autumn Hoban Romanski
Raleigh Regional Office, Surface Water Protection Section
Division of Water Quality
Through: Danny Smith O��—
Raleigh Regi al Office, Surface Water Protection Section
Division of Water Quality
Subject: Impoundment Inspection Comments
Roxboro Steam Electric Power Plant
NPDES Wastewater Discharge
Permit No. NC0003425
On September 1, 2009, Autumn Hoban Romanski of the Raleigh Regional Office (RRO) Surface Water
Protection Section (SWP) North Carolina Division of Water Quality (NC DWQ) participated in the Coal
Combustion Waste (CCW) Surface Impoundment Assessment conducted at the Roxboro Plant Site in
Person County North Carolina. The EPA's Impoundment Condition Assessment was satisfactory for
the West Ash Pond Dam and fair for the Flue Gas Desulfurization (FGD) Settling Pond and FGD Flush
Pond wastewater treatment units at the Roxboro Plant Site. This memorandum is provided in
response to your request for comment on the draft report regarding the subject facility.
A NC DWQ annual NPDES Wastewater Discharge Permit Inspection at the Roxboro Steam Electric
Power Plant was conducted on May 27, 2009. This inspection was conducted to venfy/determine the
compliance status of this facility with the conditions and limitations specified in NPDES Wastewater
Permit No. NC0003425.
While the facility was reported to be compliant with NPDES permit conditions, the site has been
required to provide additional sampling and monitoring to NC DWQ since March of 2008.
The RRO SWP staff of the NC DWQ has reviewed the draft EPA report and offers the following
corrections and observations for consideration in the final report development:
1) The report identifieslexplains that the toe drains from the West Ash Pond Dam outlet to Hyco
Lake This is not accurate. The toe drains from the West Ash Pond outlet to a mixing zone, at
the confluence of outfall 002 and the heated water discharge canal, prior to the final outfall at
003 to Hyco Lake The toe drains are an internal outfall.
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Roxboro Impoundment RRO Comments
IN
2) The report accurately explains that the West Ash Pond Dam is regulated by the NC Utilities
Commission. However, NC DWQ regulates the NPDES wastewater treatment units and
respective discharges associated with the wet ash.
3) The draft report states " the treatment units are at approximately the same elevation as the too
of the West Ash Pond Dam and dikes for the West Ash Pond within which they are located."
The statement underlined above is accurate. In keeping with the findings of the EPA report, NC
DWQ observed the West Ash Impoundment and the permitted wastewater treatment units
constructed within the West Ash Pond. These treatment units discharge under the current NPDES
Discharge Permit. it is noted that current construction plans for repairs of the existing FGD Settling
Pond and the design of a new FGD Settling Pond indicate the elevation of the new FGD Settling
Pond will be raised an additional 4 feet. (Saturation of ash/groundwater table elevations are
recorded in Progress Energy's geotechnical data.)
In a written response to the NC DWQ's NPDES inspection from May 2009, the Progress Energy
Roxboro facility explained the following:
Progress Energy recently completed bathymetry work for the existing ash pond
(excluding the footprint of the currently constructed FGD wastewater treatment units ).
The volume of the Roxboro Ash Pond as surveyed on September 17 & 18, 2009 is
563,217 cubic yards. This is based on the water surface elevation of 462.13 ft MSL
(NAVD88) taken at the time of the bathymetry survey. The volume of the pond after the
2007 bathymetry survey was 445,149 cubic yards at a water surface elevation of 458.7 ft
MSL (NAVD88).
Available freeboard — The elevation of the ash pond dam crest is 470 ft. The design
water elevation is 463 ft with a maximum water elevation of 465 ft. Water elevation
surveyed during the last bathymetry event was 462.13 at the time of the survey.
4. The Roxboro Plant is located within the Piedmont Physiographic Province and near the Milton
and Charlotte Belts. More specific geologic details of the site can be found on the North
Carolina Geologic Map last dated 1985, as well as, in Progress Energy's geotechnical data.
5 The Roxboro Steam Electric Plant is located approximately 6.5 miles downstream of the Town
of Roxboro's surface water supply intake. This intake is located on South Hyco Creek and is
classified as Water Supply (WS -II) High Quality Waters (HQW) critical area (CA) in the
Roanoke River Basin.
6. The power plant intakes and discharges water from Hyco Lake classified as Class B Primary
Recreation, Water Supply (WS -V) waters in the Roanoke River Basin.
7 Much of the vegetative cover and side slopes of the Ash Pond Dam consisted of a tall, thick
vegetative cover that inhibited full observation of all slopes. The toe drain slopes of the West
Ash Pond were clear of vegetation.
8. The EPA report explains the discharge ends of the concrete swales are undermined. Further
the report states that this was not part of a dam safety concern due to the distance from the toe
of the dam. NC DWQ staff agrees that the toe drains of the dam showed signs of erosion
around the cement. These drains which convey internal dam seepage should be inspected
frequently (e.g. weekly) to ensure stability and proper operation of the dam. [During the site
visit seven toe drains with the exception of the middle toe drain were discharging]
9. The #3 Summary Recommendation in the EPA report is to quantify the seepage/discharge rate
from the toe drains. The RRO concurs with this recommendation [Note: EPA and NC DWQ
observations indicated that one of the toe drains showed evidence of soil transport, the subject
of the # 2 Summary Recommendation in the EPA report.]
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f �
Roxboro Impoundment RRO Comments
10. The northwest berm of the West Ash Pond by the NPDES internal outfall 002, had apparent
seepage at the discharge weir from beneath the concrete abutment that appears to be coming
from the rock foundation, as described in the EPA report. This is of concern to the Raleigh
Regional Office from an NPDES discharge standpoint. he additional flow could alter
measurements/sampling results at other NPDES outfalls. (Note: Based on boring data
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recorded in the geotechnical data received by the Raleigh Regional Office on January 26,
2009, no location tr oaoutfalld002) feet
(depth r
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he closest
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Recommendation in the EPA report.
11. The EPA report # 4 Summary Recommendation is to continue monitoring the seepage at
the toe of the West FGD Settling Pond.
Note: repair efforts are currently ongoing and permitted/addressed through NPDES permit
conditions. The FGD Flush Pond was under construction, as repairs for this treatment unit
were underway the day of this inspection.
If you have any questions or if I can be of further assistance, please do not hesitate to contact me.
Cc: Raleigh Regional Office — DWQ SWP and DLQ Files
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