Loading...
HomeMy WebLinkAboutNC0003425_Monitoring (Report)_20190219Permit NC0003425 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER RESOURCES PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provisions 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, Duke Energy Progress, LLC is hereby authorized to discharge wastewater from a facility located at the Roxboro Steam Electric Generating Plant 1700 Dunnaway Road, Semora Person County to receiving waters designated as Hyco Reservoir in the Roanoke River Basin in accordance with effluent limitations, monitoring requirements, and other applicable conditions set forth in Parts I, II, III and IV hereof. This permit modification shall become effective August 1, 2021. This permit and the authorization to discharge shall expire at midnight on June 30, 2025. Signed this day June 25, 2021. DOCUSM^ea by: payof for S. Daniel Smith, Director Division of Water Resources By Authority of the Environmental Management Commission Page I of 29 -.A Permit NCO003425 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. Duke Energy Progress, LLC 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: • Outfall 001. Discharge overflow from the East Ash Basin Extension, extracted groundwater, ash basin closure flows, and storimvater runoff into a UT to Hyco Reservoir. • Ash Pond Treatment System (Internal Outfall 002). Continue to discharge ash transport water, low volume wastewater, runoff from the ash landfill, dry fly ash handling system wash water, ash 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 through an internal conveyance to the heated discharge pond, and is ultimately released into Hyco Reservoir through Outfall 003. • Heated Discharge Pond (Outfall 003). Continue to discharge once -through cooling water, stortnwater runoff, coal pile runoff, flue gas desulfurization treated wastewater, flue gas desulfurization cooling water, ash pond dam chimney drains and other basin seepage flows, anhydrous ammonia testing waters and emergency flows (until construction of low volume wastes treatment system), effluent from the ash pond (Outfall 002), ash basin closure flows, and extracted groundwater. Continue to discharge the effluent from the low volume waste treatment systems (Outfall 012A and 012B), and yard sump overflow to the heated discharge pond. This outfall discharges to Hyco Reservoir. • Cooling Tower Blowdown System (Internal Outfall 005). Continue to discharge cooling tower blowdown from unit number 4 into the low volume wastewater treatment system (outfall 012B) or into the heated discharge pond. • Coal Pile Runoff Treatment System (Outfall 006). Emergency overflow from the coal pile and other coal handling areas, runoff from the limestone and emergency gypsum stack, raw water tank drainage, incidental leakage from absorbent seats, and the truck wheel wash water. On a non - emergency basis these waters are routed to a retention pond for treatment by neutralization, sedimentation, and equalization prior to being discharged directly into Hyco Reservoir. • Domestic Wastewater Treatment System (Internal Outfall 008). Continue to discharge effluent from the domestic treatment system into the ash pond or the low volume waste treatment system (Outfall 012B). • Chemical Metal Cleaning Treatment System (Internal Outfall 009). Continue to discharge chemical metal cleaning wastes into the low volume waste treatment system (Outfall 012). • Flue Gas Desulfurization Treatment System (Internal Outfall 010). Continue to operate a FGD wet scrubber treatment system consisting a settling pond and a bioreactor, discharging into the heated discharge pond. • Flue Gas Desulfurization Treatment System (Internal Outfall 011). Upon completion of construction, operate a Flue Gas Desulfurization System discharging to the low volume waste treatment system (outfall 012B) or the heated discharge pond. • Low Volume Wastes Treatment System (Internal Outfall 012A). Upon construction, discharge landfill stormwater, east ash basin closure flows, treated extracted groundwater, contact and non - contact storm water runoff into the heated discharge pond. • Lined Retention Basin (Internal Outfall 012B). Continue to discharge low volume wastes, metal cleaning wastes (Internal Outfall 009), ash silo wash water, cooling water from Unit 4, anhydrous ammonia testing waters and emergency flows, domestic sewage treatment plant effluent, domestic W WTP effluent (Internal Outfall 008), bottom ash purge from the submerged flight conveyers (purge volume not to exceed 10% of the water systems volume), ash landfill leachate, treated FGD Page 2 of 29 Permit NC0003425 blowdown, storm water runoff, runoff from the coal pile and other coal handling areas, runoff from the limestone and emergency gypsum stack, raw water tank drainage, incidental leakage from absorbent seals, 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 to retention basin. The retention basin discharges into the heated discharge pond. • Emergency overflow from low volume wastewater treatment system (Outfall 012C). Continue to discharge emergency overflow from retention basin to Hyco Reservoir. 2. Discharge from said treatment works and/or outfalls at the locations specified on the attached map into the Hyco Reservoir, classified as WS-V & B waters in the Roanoke River Basin. Page 3 of 29 Permit NC0003425 Part I A. (1) Effluent Limitations and Monitoring Requirements (Outfall 001) 115A NCAC 02B .0400 et seq., 02B .0500 et seq.] During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 001 (overflow from East Ash Basin Extension, and stormwater runoff). Such discharees shall be limited and munitoredI by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequency Sample Type Sample Location Flow, MGD Weekly Estimate Effluent H 6.0 to 9.0 S.U. Monthly Grab Effluent TSS 30.0m /L 100.Om /L Monthly Grab Effluent Oil and Grease 15.0 m>/L 20.0 m /L Monthly Grab Effluent Fluoride 1.8m /L 1.8m /L Month) /Week) 2 Grab Effluent Total Arsenic, µ L 10.0 µ /L 340.0 µ /L Month) Weeklv2 Grab Effluent Total Copper, µ L Month) / Weekl 2 Grab Effluent Total Antimony, µ /l Month) Weekl 2 Grab Effluent Total Lead, µ /L Monthly/ Weekl 2 Grab Effluent Total Selenium 5.0 µ /L 56.0 µ /L Month) Wceklv2 Grab Effluent Total Barium, m /L Month) Weekl 2 Grab Effluent Total Iron, µ /L Month) Weekl 2 Grab Effluent Total Manganese, µ L Month) Weekl 2 Grab Effluent Total Zinc, µ /L Month) Weekl 2 Grab Effluent Total Nickel, jig/ L Month) Weekl 2 Grab Effluent Total Mercury, n /L' Month) / Weekl 2 Grab Effluent Chlorides, m>/L Month) /Weeklv2 Grab Effluent Nitrate/Nitrite as N Monthly Grab Effluent Sulfates Month) Grab Effluent Total Dissolved Solids, m /L Monthly Grab Effluent Hardness -Total as [CaCOz or Ca + M ] m / L Quarterly Grab Effluent Acute Toxicf Quarterly Grab Effluent Notes: 1. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR application system. See Special Condition A. (29). 2. The facility shall conduct weekly sampling during removal of the ash from the east ash basin extension. 3. The facility shall use EPA method 1631E. 4. Acute Toxicity (Pimephales promelas, 24-hour) monitoring shall be performed in accordance with Special Condition A. (14) of this permit. There shall be no discharge of floating solids or visible foam in other than trace amounts. Within 180 days of the issuance date of the permit the permittee shall submit Items V and VI of NPDES application Form 2C. If any one of the pollutants (As, Se, Hg, Ni, and Pb) reaches 85% of the allowable level during the decanting/dewatering, the facility shall immediately discontinue discharge of the wastewater and report it to the Regional Office and Complex NPDES Permitting Branch via telephone and e-mail. Page 4 of 29 Permit NC0003425 A. (2) Effluent Limitations and Monitoring Requirements (Outfall 002 - normal operation - decanting phase) 115A NCAC 02B .0400 et seq., 02B .0500 et seq.] During the period beginning on the effective date of the permit and lasting until expiration or commencement of the dewatering operations, the Permittee is authorized to discharge from Internal Outfall 002 ash pond effluent (decanting the free water above the settled ash layer that does not involve mechanical disturbance of the ash). Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Avera Daily Maximum Measurement Frequeng Sample Tvpe Sample Location Flow Daily Continuous Effluent Oil and Grease 15.0 m L 20.0 m /L 2/Month Grab Effluent Total Suspended Solids? 30.0 mg/ L 100 m L 2/Month Grab Effluent Total Arsenic, µ /L Weekly Grab Effluent Total Molybdenum, µ /L Weekly Grab Effluent Total Selenium, µ /L Weekly Grab Effluent H+ Monthly Grab Effluent Notes: 1. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR application system See Special Condition A. (29). 2. Samples taken in compliance with the monitoring requirements listed above shall be taken at the ash pond discharge prior to mixing with other sources of wastewater. 3. The facility shall continuously monitor TSS concentration when the decanting process commences and the pump is operating. The dewatering pump shall be shutoff automatically when one half of the Daily Maximum limit (15 minutes average) is exceeded. Pumping will be allowed to continue if interruption might result in a dam failure or damage. Continuous TSS monitoring is only required when pumps are employed for decanting. 4. The facility shall continuously monitor pH when the decanting process commences and the decanting pump shall be shutoff automatically when 15 minutes running average pH falls below 6.1 standard units or rises above 8.9 standard units. Pumping will be allowed to continue if interruption might result in a dam failure or damage. Continuous pH monitoring is only required when pumps are employed for decanting. By April 30, 2021 there shall be no discharge of pollutants in bottom ash transport waters. This requirement only applies to bottom ash transport water generated after April 30, 2021. In accordance with N.C.G.S. § 130A-309.210, by December 31, 2019, the facility shall convert to the disposal of dry bottom ash, as defined in the Coal Ash Management Act ("CAMA"). Fly ash is handled dry at this facility. The facility is allowed to draw down the wastewater in the ash pond to no less than three feet above the ash. The limits and conditions in Section A. (3) of the permit apply when water in the ash settling basin is lowered below the three feet trigger mark, measured at the pump intake. The rate for lowering the liquid level in a coal ash pond shall not exceed one (1) foot per day unless a higher rate is supported to the satisfaction of DEMLR and in accordance with NCAC, Title 15A, Subchapter2K. Page 5 of 29 Permit NC0003425 The facility shall use a floating pump station with free water skimmed from the basin surface using an adjustable weir. The facility shall notify via e-mail DWR Complex NPDES Permitting Unit and DWR Raleigh Regional Office seven calendar days prior to the commencement of the dewatering. When the facility commences the ash pond decanting/dewatering, the facility shall treat the wastewater discharged from the ash pond using physical -chemical treatment, if necessary, to assure state Water Quality Standards are not contravened in the receiving stream. Duke Energy shall notify DWR NPDES Permitting and DWR Raleigh Regional Office, in writing, within seven calendar days of installing additional physical -chemical treatment at this Outfall. Page 6 of 29 Permit NC0003425 A. (3) Effluent Limitations and Monitoring Requirements (Outfall 002 - dewatering phase) [15A NCAC 02B .0400 et seq., 02B .0500 et seq.] During the period beginning upon the commencement of the dewatering operations and lasting until expiration, the Permittee is authorized to discharge from Internal Outfall 002 (Ash Pond Treatment System Dewatering - removing the interstitial water). Such discharges shall be limited and monitored' by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Fre uenc Sample T e Sample Location Flow, MGD Weeklv Continuous Effluent Interstitial Flow 3.0 MGD Weekly Continuous Effluent Total Selenium, µ /L Weekly Grab Effluent Total Arsenic, µ /L Weekly Grab Effluent Total Mercury, n /L Weeklv Grab Effluent Total Molvbdenum, µ /L Weekl Grab Effluent Total Antimonv, µ /L Weekly Grab Effluent Total Copper, µ /L Weekly Grab Effluent Oil and Grease 15.0 m /L 20.0 m /L Weekly Grab Effluent Total Suspended Solids' 30.0 mg/ L 100 mg/L Weekly Grab Effluent H4 Monthly Grab Effluent Notes: 1. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR application system. See Special Condition A. (29). 2. Effluent sampling shall be conducted at the discharge from the ash settling pond prior to mixing with any other waste stream. 3. The facility shall continuously monitor TSS concentration when the dewatering process commences and the pump is operating. The dewatering pump shall be shutoff automatically when one half of the Daily Maximum limit (15 minutes average) is exceeded. Pumping will be allowed to continue if interruption might result in a dam failure or damage. The continuous TSS monitoring only required when the pumps are employed for dewatering. 4. The facility shall continuously monitor pH when the dewatering process commences and the dewatering pump shall be shutoff automatically when the 15 minutes running average pH falls below 6.1 standard units or rises above 8.9 standard units. Pumping will be allowed to continue if interruption might result in a dam failure or damage. The continuous pH monitoring only required when the pumps are employed for dewatering. There shall be no discharge of floating solids or visible foam in other than trace amounts. By April 30, 2021 there shall be no discharge of pollutants in bottom ash transport waters. This requirement only applies to fly ash transport water generated after April 30, 2021. In accordance with N.C.G.S. § 130A-309.210, by December 31, 2019, the facility shall convert to the disposal of dry bottom ash, as defined in the Coal Ash Management Act ("CAMA"). Fly ash is dry handled at this facility. The rate for lowering the liquid level in a coal ash pond shall not exceed one (1) foot per day unless a higher rate is supported to the satisfaction of DEMLR and in accordance with NCAC, Title 15A, Subchapter 2K. Page 7 of 29 Permit NC0003425 The facility shall notify via e-mail DWR Complex NPDES Permitting Unit and DWR Raleigh Regional Office seven calendar days prior to the commencement of the dewatering. When the facility commences the ash pond decanting/dewatering, the facility shall treat the wastewater discharged from the ash pond using physical -chemical treatment, if necessary, to assure state Water Quality Standards are not contravened in the receiving stream. Duke Energy shall notify DWR NPDES Permitting and DWR Raleigh Regional Office, in writing, within seven calendar days of installing additional physical -chemical treatment at this Outfall. Page 8 of 29 Permit NC0003425 A. (4) Effluent Limitations and Monitoring Requirements (Outfall 003) [15A NCAC 02B .0400 et seq., 02B .0500 et seq.] During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 003 (Heated Discharge Pond to the Hyco Reservoir). Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequency Sample T e Sample Location Flow Daily Calculation Effluent Total Residual Chlorine 28 µ>/L 2/Month Grab Effluent Total Phosphorus Monthly Grab Effluent Total Nitrogen Monthly Grab Effluent Temperature Continuous Recorder Effluent, Afterbay Discharge Total Arsenic, jig/ L Monthl Weeklv5 Grab Effluent Total Selenium, µ /L Monthl /Weekl 5 Grab Effluent Chloride, m /L Monthly/ Weeklv5 Grab Effluent Total Mercury, n / L6 Monthl Weekl 5 Grab Effluent Total Antimon , µ /L Monthl Weeklv5 Grab Effluent Total Molybdenum, µ /L Monthly/ Weekl 5 Grab Effluent Total Thallium µ L Monthl Weekl 5 Grab Effluent H 6.0to9.0S.U. Monthly/Weekl 5 Grab Effluent Ammonia% 1.0 m L 5.0 m /L Daily Grab Effluent Acute Toxicit e Quarterly Composite Effluent Hardness -Total as [CaCOi or (Ca + Mg)], m /L Quarterly Grab Effluent, 4C 4D Turbidit 9, NTU Monthl Weekl ' Grab Effluent Notes: 1. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR application system. See Special Condition A. (29). 2. Effluent sampling shall be performed in the heated discharge pond at the point of discharge into Hyco Reservoir. 3. Total Residual Chlorine compliance (including monitoring) is required only if chlorine or chlorine derivative is added to the cooling water. The Division shall consider all effluent TRC values reported below 50 µg/L to be in compliance with the permit. However, the permittee shall continue to record and submit all values reported by a North Carolina certified laboratory (including field certified), even if these values fall below 50 µg/L. 4. The Permittee shall operate so as to remain in compliance with the conditions outlined in the mixing zone defined in Special Condition A. (17) of this permit. The temperature of Hyco Reservoir at no time shall exceed the thermal water quality standard outside the mixing zone defined in Special Condition A. (17). These thermal limitations may be deleted or revised, as appropriate, based upon evaluation of the results of the thermal studies. This permit may be reopened to implement a temperature limit if the permittee is not in compliance with Special Condition A. (17). 5. The facility shall conduct weekly sampling during dewatering of the ash basin. 6. The facility shall use EPA method 1631E. 7. Ammonia limit and monitoring is only applicable in the event of an emergency release of anhydrous ammonia during the time the released waters are discharged through outfall 003. Page 9 of 29 Permit NCO003425 8. Acute Toxicity (Pimephales promelas) P/F ® 90%, March, June, September and December. See Special Condition A. (14) of this permit. Composite samples for this effluent characteristic shall consist of 24 or more grab samples of equal volumes collected at equal intervals over a 24-hour period. 9. The net turbidity shall not exceed 50 NTU using a grab sample and measured by the difference between the effluent turbidity and the background turbidity. The sample for the background turbidity shall be taken at a point in the receiving waterbody upstream of the discharge location, and the background turbidity and the effluent turbidity samples shall be taken within the same 24 hour period. NTU - Nephelometric Turbidity Unit The Permittee is allowed to operate Unit 3 in a once -through cooling mode from October 15 through April 30. If any one of the pollutants (As, Se, and Hg) reaches 85% of the allowable level during the decanting/dewatering, the facility shall immediately discontinue discharge of the wastewater and report it to the Regional Office and Complex NPDES Permitting Branch via telephone and e-mail. There shall be no discharge of floating solids or visible foam in other than trace amounts outside a distance five (5) meters from the discharge pipe. Page 10 of 29 Permit NC0003425 A. (5) Effluent Limitations and Monitoring Requirements (Internal Outfall 005) 115A NCAC 02B .0400 et seq., 02B .0500 et seq.] During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from Internal Outfall 005 (Cooling Tower Blowdown). Such discharges shall be limited and monitored) by the Permittee as specified below: LIMITS MONITORING REQUIREMENTS EFFLUENT Monthly Daily Measurement Sample CHARACTERISTICS Average Maximum Frequency Sample Type Location Flow Continuous pump Logs Effluent durin discharge Free Available Chlorine; 200 µ L 500 µ L 2/ month Multiple Grabs Effluent Total Residual Chlorine3 Monthly Multiple Grabs Effluent Total Chromium4 200 µ L 200 µ /L 2/Month Composite Effluent Total Zinc; 1.0 m /L 1.0 m L 2/Month Composite Effluent The 126 Priority Pollutants (40 CFR Part 423, Appendix A) No Detectable Amount Annual Grab Effluent Exclusive of Zinc and Chromium' Notes: 1. The pennittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR application system. See Special Condition A. (29). 2. Effluent sampling shall be conducted at the discharge from the cooling tower prior to mixing with other waste streams. 3. Neither free available chlorine nor total residual chorine may be discharged from any single generating unit for more than two hours per day, unless the Permittee demonstrates to the Division that discharge for more than two hours is required for macroinvertebrate control. The 500 µg/L is a daily maximum limitation and is to be measured during the chlorine release period. The 200 µg/L limitation is an average during the chlorine release period. Monitoring is required only when chlorine is added to the cooling water system. 4. Limitations and monitoring requirements for the 126 Priority Pollutants (per 40 CFR Part 423, Appendix A, exclusive of zinc and chromium) apply only if these substances are added by the permittee for cooling tower maintenance. Compliance with the limitations for the 126 priority pollutants in 40 CFR 423.13 (d)(1) may be determined by engineering calculations which demonstrate that the regulated pollutants are not detectable in the final discharge by the analytical methods in 40 CFR Part 136. All primary industries are required to submit a priority pollutant analysis in accordance with 40 CFR Part 122 with their application for permit renewal. Discharge of blowdown from the cooling tower is defined as the minimum discharge of recirculation water necessary for the purpose of discharging materials contained in the process, the further build-up of which would cause concentration in amounts exceeding limitations established by best engineering practice. The Permittee is authorized to discharge Maintenance Drain wastewater from the Cooling Tower for Unit 4 directly to the discharge canal. Grab samples of the following parameters are to be collected prior to mixing with other waste streams and the results shall be submitted to DWR: pH (SU), flow (MGD) and total residual chlorine (mg/ L). The Permittee shall notify the Division of Water Resources, Raleigh Regional Office, prior to draining the cooling tower, except during non -office hour emergencies when notification must be made the next working day. Total residual chlorine monitoring is required prior to a maintenance drain of the Unit 4 Cooling Tower only if chlorine is added to the system. Page I I of 29 Permit NCO003425 A. (6) Effluent Limitations and Monitoring Requirements (Outfall 006) [15A NCAC 02B .0400 et seq., 02B .0500 et seq.] During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 006 (Coal Pile Runoff Treatment System to the Hyco Reservoir). Such discharges shall be limited and monitored' by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Avera a Daily Maximum Measurement Frequency2 Sample Type Sample Location-v Flow Monthly Estimate Effluent Total Suspended Solids 50.0 m L Monthly Grab Effluent Total Selenium 56.0 µ /L Monthly Grab Effluent Oil and Grease 20.0 m L Monthly Grab Effluent H 6.0 to 9.0 S.U. Monthly Grab Effluent Acute Toxicity' I Annually Grab Effluent Notes: 1. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR application system. See Special Condition A. (29). 2. The permittee shall collect samples if the pond discharges during a calendar month. If there is no discharge during the calendar month "No Flow" shall be denoted in the DMR. 3. Effluent sampling shall be conducted at the point of discharge into Hyco Reservoir. Samples taken in compliance with the monitoring requirements listed above shall be taken prior to mixing with other sources of wastewater. 4. Acute Toxicity (Pimephales promelas, 24-hour) monitoring shall be performed in accordance with Special Condition A. (15) of this permit. There shall be no discharge of floating solids or visible foam in other than trace amounts outside a distance five (5) meters from the discharge pipe. Material storage runoff shall include rainfall to navigable waters through any discernable, confined and/or discrete conveyance from, or through, coal. Within 180 days of the effective date of the permit, the permittee shall submit Items V and VI of NPDES application Form 2C. Page 12 of 29 Permit NCO003425 A. (7) Effluent Limitations and Monitoring Requirements (Internal Outfall 008) [15A NCAC 02B .0400 et seq., 02B .0500 et seq.] During the period beginning upon the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from Internal Outfall 008 (Domestic Wastewater Treatment System) into the low volume waste treatment system. Such discharges shall be limited and monitored' by the Permittee as specified below: EFFLUENT CHARACTERISTICS DAILY MAXIMUM MONITORING REQUIREMENTS Monthly AverageMaximum Daily Measurement Frequency Sample Type Sample Location Flow 0.025 MGD Quarterly/Annual; Pump Logs Effluent Biochemical Oxygen Demand 5-day@ 20°C 30.0 mg/L 45.0 mg/L Quarterly/Annual3 Grab Effluent Total Suspended Solids 30.0 m /L 45.0 m L Quarterly/ Annual-' Grab Effluent Total Ammonia as N Quarterly/Annual-' Grab Effluent PH Quarterly/Annual' Grab Effluent Fecal Coliform 200/100 mL 400/100 mL Quarterly/Annual' Grab Effluent Notes: 1. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR application system. See Special Condition A. (29). 2. Samples taken in compliance with the monitoring requirements listed above shall be taken after treatment and prior to mixing with other sources of wastewater. 3. After one year of quarterly monitoring the sampling frequency will be modified to Annual. See Special Condition A. (22). Page 13 of 29 Permit NC0003425 A. (8) Effluent Limitations and Monitoring Requirements (Internal Outfall 009) 115A NCAC 02B .0400 et seq., 02B .0500 et seq.] During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from Internal Outfall 009 (Metal Cleaning Wastes). Such discharges shall be limited and monitored' by the Permittee as specified below: LIMITS MONITORING REQUIREMENTS EFFLUENT Monthly Daily Measurement Sample Sample CHARACTERISTICS Average Maximum Frequency Type 2 Location Once per Discharge Pump Logs Flow Event or similar Outfall 012B reading Total Suspended Solids 30.0 mg/L 100 mg/L Once per Discharge Event Grab Outfall 012B Oil and Grease 15.0 mg/L 20.0 mg/L Once per Discharge Event Grab Outfall 012B Total Copper 1.0 mg/L 1.0 mg/L Once per Discharge Grab Outfall 012E Event Total Iron 1.0 mg/L 1.0 mg/L Once per Discharge Grab Outfall 012B Event PH Once per Discharge Grab Outfall 012B Event Notes: 1. The permittee shall submit Discharge Monitoring Reports electronically using NC DW Ws eDMR application system. See Special Condition A. (29). 2. Samples taken in compliance with the monitoring requirements listed above shall be taken prior to mixing with other sources of wastewater. Page 14 of 29 PermitNCO003425 A. (9) Effluent Limitations and Monitoring Requirements (Internal Outfall 010) [15A NCAC 026.0400 et seq., 02B .0500 et seq.] During the period beginning on the effective date of the permit and lasting until the existing FGD treatment system is decommissioned, the Permittee is authorized to discharge from Internal Outfall 010 (FGD blowdown). Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequency Sample Type Sample Lc cation= Flow Monthly Pump Logs or similar reading Effluent Total Suspended Solids 30.0 m /L 100.0 m /L Quarterly Grab Effluent Oil and grease 15.0 mg/ L 20.0 m /L Quarterly Grab Effluent TotalArsenic3 8.0 /L 18.0 L Quarterly Grab Effluent Total Mercury3 34.0 n / L 103.0 n / L Quarterly Grab Effluent Total Selenium3 29.0 L 7 L Quarterl Grab Effluent Nitrate/Nitrite as N3 3.0 m /L 4.0 m /L Quarterl Grab Effluent H Quarterly Grab Effluent Notes: 1. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR application system. Special Condition A. (29). 2. Samples taken in compliance with the monitoring requirements listed above shall be taken after bioreactor treatment and prior to mixing with other sources of wastewater. 3. In accord with the Steam Electric Effluent Limitations Guidelines for FGD wastewater (40 C.F.R. 423), these limits shall become effective on December 31, 2021. This permit maybe reopened and modified if changes are made to 40 C.F.R. 423. There shall be no discharge of untreated FGD blowdown. The permittee will operate the FGD wastewater system until all coal-fired generation units at the site are retired. Performance of the FGD wastewater treatment system shall be optimized to maximize pollutant reduction and minimize variability. Page 15 of 29 AM Permit NC0003425 A. (10) Effluent Limitations and Monitoring Requirements (Internal Outfall 011) 115A NCAC 02B .0400 et seq., 02B .0500 et seq.) During the period beginning upon the commencement of operations of the new FGD system and lasting until expiration, the Permittee is authorized to discharge from Internal Outfall 011 (FGD blowdown). Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequency Sample Type Sample Location Flow Monthly Pump Logs or similar reading Effluent Total Sus ended Solids 30.0 m /L 100.0 m /L Quarterly Grab Effluent Oil and grease 15.0 mgZL 20.0 m L Quarterly Grab Effluent Total Arsenic' 8.0 /L 18.0 /L Quarterly Garb Effluent Total Mercury 34.0 n / L 103.0 n / L Quarterly Grab Effluent Total Selenium a 29.0 L 7 L QuarterlyGrab Effluent Nitrate/Nitrite as N' 3.0 m /L 4.0 m /L Quarterly Grab Effluent H Quarterly Grab Effluent Notes: 1. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR application system. See Special Condition A. (29). 2. Samples taken in compliance with the monitoring requirements listed above shall be taken after bioreactor treatment and prior to mixing with other sources of wastewater. 3. In accord with the Steam Electric Effluent Limitations Guidelines for FGD wastewater (40 C.F.R. 423), these limits shall become effective on December 31, 2021. This permit maybe reopened and modified if changes are made to 40 C.F.R. 423. There shall be no discharge of untreated FGD blowdown. The permittee will operate the FGD wastewater system until all coal-fired generation units at the site are retired. Performance of the FGD wastewater treatment system shall be optimized to maximize pollutant reduction and minimize variability. Page 16 of 29 Permit NC0003425 A. (11) Effluent Limitations and Monitoring Requirements (Internal Outfall 012A) [15A NCAC 02B .0400 et seq., 02B .0500 et seq.] During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from Internal Outfall 012A. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequency Sample Type Sample Locationz Flow Monthly Pump Logs or similar reading Effluent Total Suspended Solids 30.0 m L 100.0 m /L Monthly Grab Effluent Oil and grease 15.0 m /L 20.0 m L Monthly Grab Effluent Total Arsenic, µ /L Weekly' Grab Effluent Total Molybdenum, µ /L Weekly' Grab Effluent Total Selenium, µ /L Weekl 3 Grab Effluent Total Mercury, n /L Weekl 3 Grab Effluent Total Antimony, µ /L Weekl " Grab Effluent Total Copper, µ /L k Weel ' Grab Effluent H Weekly" Grab Effluent Notes 1. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR application system. See Special Condition A. (29). 2. Samples taken in compliance with the monitoring requirements listed above shall be taken after the treatment system and prior to mixing with other sources of wastewater. 3. Monitoring is only required when discharging east ash basin closure flows or treated groundwater through this outfall. Within 180 days of the commencement of operations of the treatment system the permittee shall submit Items V and VI of NPDES application Form 2C. Page 17 of 29 Permit NC0003425 A. (12) Effluent Limitations and Monitoring Requirements (Internal Outfal1012B) [15A NCAC 02B .0400 et seq., 02B .0500 et seq.] During the period beginning on the effective date of the permit and lasting until expiration, the Pennittee is authorized to discharge from Internal Outfall 012B. Such discharges shall be limited and monitored' by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Fre uenc Sam ple Type Sample Location Floxr Monthly Pump Logs or similar readingEffluent Total Suspended Solids 30.0 mg/ L 100.0 m /L Monthly Grab Effluent Oil and grease 15.0 m /L 20.0 m /L Monthly Grab Effluent H Quarterly Grab Effluent Ammonia' Dail 3 Grab Effluent Total Arsenic Monthly Grab Effluent Total Selenium Monthly Grab Effluent Total Mercurv4 Monthly Grab Effluent Notes 1. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR application system. See Special Condition A. (29), 2. Samples taken in compliance with the monitoring requirements listed above shall be taken after the treatment system and prior to mixing with other sources of wastewater. 3. Ammonia limit and monitoring is only applicable in the event of an emergency release of anhydrous ammonia during the time the released waters are discharged through outfall 012B. 4. The facility shall use EPA method 1631E. Within 180 days of the commencement of operations of the treatment system the permittee shall submit Items V and VI of NPDES application Form 2C. Except for those discharges authorized below, or when the bottom ash transport water is used in the FGD scrubber, there shall be no discharge of pollutants in bottom ash transport water. Bottom ash transport water shall be discharged to the FGD scrubber during normal operations. If the FGD Scrubber is unavailable to receive bottom ash transport water, the discharge of pollutants in bottom ash transport water (bottom ash purge water) from a properly installed, operated, and maintained bottom ash system to the Lined Retention Basin is authorized under the following conditions: A. To maintain system water balance when precipitation -related inflows are generated from a 10- year storm event of 24-hour or longer duration (e.g., 30-day storm event) and cannot be managed by installed spares, redundancies, maintenance tanks, and other secondary bottom ash system equipment; or B. To maintain system water balance when regular inflows from waste streams other than bottom ash transport water exceed the ability of the bottom ash system to accept recycled water and segregating these other waste streams is feasible; or C. To maintain system water chemistry where current operations at the facility are unable to currently manage pH, corrosive substances, substances or conditions causing scaling, or fine particulates to below levels which impact system operation or maintenance; or Page 18 of 29 Permit NC0003425 D. To conduct maintenance not otherwise described above and not exempted from the definition of transport water in 40 C.F.R. § 423.11(p), and when water volumes cannot be managed by installed spares, redundancies, maintenance tanks, and other secondary bottom ash system equipment. In no event shall the total volume of the discharge to the Lined Retention Basin exceed a 30-day rolling average of ten percent of the primary active wetted bottom ash system volume. The volume of daily discharges used to calculate the 30-day rolling average shall be calculated using measurements from flow monitors or pump logs. Based on a calculated bottom ash transport system volume of 0.995 million gallons, the 30 day rolling average discharge shall not exceed 0.099 MGD. Page 19 of 29 Permit NCO003425 A. (13) Effluent Limitations and Monitoring Requirements (Outfall 012C) [ 15A NCAC 02B .0400 et seq., 02B .0500 et seq.) During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 012C. Such discharges shall be limited and monitored' by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequency Sample Type Sample Location] Flow Per discharge event Estimate Effluent Total Suspended Solids 30.0 m /L 100.0 m /L Per discharge event Grab Effluent Oil and grease 15.0 m /L 20.0 m L Per discharge event Grab Effluent H 6.0 to 9.0 S.U. Per discharge event Grab Effluent Ammonia3 1.0 m L 5.0 m /L Per discharge event Grab Effluent Total Arsenic, pg/L Per discharge event Grab Effluent Total Mercury, ng/L Per discharge event Grab Effluent Total Selenium, µg/ L Per discharge event Grab Effluent Nitrate/Nitrite as N, m /L Per discharge event Grab Effluent Total Copper, µg/ L Per discharge event Grab Effluent Total Iron, pg/L Per discharge event Grab Effluent Notes 1. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR application system. See Special Condition A. (29). 2. Samples taken in compliance with the monitoring requirements listed above shall be taken after the treatment system and prior to mixing with other sources of wastewater. 3. Ammonia limit and monitoring is only applicable in the event of an emergency release of anhydrous ammonia during the time the released waters are discharged at the same time as the emergency overflow. Within 180 days of the first discharge event the permittee shall submit Items V and VI of NPDES application Form 2C. YUI flows shall be reported on monthly DiXIRS. If no flow occurs during a given month, the words "no flow" should be clearly written on the front of the DbIR. All samples shall be of a representative discharge. Page 20 of 29 Permit NC0003425 A. (14) Acute Toxicity Testing PASS/FAIL Permit Limit Outfalls 001 and 003115A NCAC 02B .0200 et seq.] The Permittee shall conduct acute toxicity tests on a quarterl basis using protocols defined in the North Carolina Procedure Document entitled "Pass/Fail Methodology For Determining Acute Toxicity In A Single Effluent Concentration" (Revised -December 2010 or subsequent versions). The monitoring shall be performed as a Fathead Minnow (Phnephales promelas) 24 hour static test. The effluent concentration at which there may be at no time significant acute mortality is 90% (defined as treatment two in the procedure document). The tests will be performed during the months of March, June, September and December. These months signify the first month of each three month toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge below all treatment processes. The parameter code for Pimephales pronielas is TGE6C. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Form (MR-1) for the month in which it was performed, using the appropriate parameter code. Additionally, DWR Form AT-2 (original) is to be sent to the following address: Attention: North Carolina Division of Water Resources Water Sciences Section/Aquatic Toxicology Branch 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Or, results can be sent to the email: ATForms.ATBClncdenr.gov. Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during any month, the Permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Water Sciences Section at the address cited above. Should the Permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will begin immediately. Upon submission of a valid test, this monthly test requirement will revert to quarterly in the months specified above Should any test data from either these monitoring requirements or tests performed by the North Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit may be re- opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. Page 21 of 29 Permit NC0003425 A. (15) Acute Toxicity Monitoring (ANNUAL) Outfall 006 [15A NCAC 02B .0200 et seq.] The permittee shall conduct annual acute toxicity tests using protocols defined as definitive in EPA Document EPA-821-R-02-012 entitled "Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms." The monitoring shall be performed as a Fathead Minnow (Phnephales pronielas) 24 hour static test. Effluent samples for self -monitoring purposes must be obtained during representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge below all waste treatment processes. The parameter code for Pimephales proruelas is TAA6C. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Form (MR-1) for the month in which it was performed, using the appropriate parameter code. Additionally, DWR Form AT-1 (original) is to be sent to the following address: Attention: North Carolina Division of Water Resources Water Sciences Section/Aquatic Toxicology Branch 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Or, results can be sent to the email: ATForms.ATB@ticdenr.Kov. Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during any month, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Water Sciences Section at the address cited above. Should any test data from either these monitoring requirements or tests performed by the North Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit may be re- opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. A. (16) Intake Screen Backwash Condition ]NCGS 143-215.1(b)] Continued intake screen backwash discharge is permitted without limitations or monitoring requirements A. (17) Temperature Requirements (Outfall 003 Mixing Zone) [NCGS 143-215.1(b)] a. Water quality standards for temperature for lower piedmont waters (32° C) will not apply within a mixing zone, which shall include the North Hyco arm downstream of NC Highway 57, the main body of Hyco Reservoir downstream of the confluence of the Cobbs Creek Arm and the North Hyco Arm, and the entire afterbay lake. The area described does not include the South Hyco Arm or the first finger arms on the west side of the reservoir lying upstream of the dam. Water within the main Page 22 of 29 Permit NC0003425 lake and the afterbay lake to Hyco River shall comply with water quality standards except the temperature standards in the areas of the lake defined herein as a mixing zone. Water discharged from the afterbay shall comply with the temperature standard. Temperature readings from the afterbay shall be obtained from the existing USGS station (02077303). b. Temperature measurements made to monitor compliance with this provision shall be made at least six inches, but not more than one foot, below the surface of the lake. c. Temperature shall be measured daily. In case where the permittee experiences equipment problems and is unable to obtain daily temperatures from the monitoring station temperature monitoring must be reestablished within five working days. d. Temperature increases shall be determined as the increase in temperature above the background level. Background level shall be defined as the temperature measured at the confluence of the two southern finger arms on the north side of the lake (Lat. 36.5111, Long 79.06629). The downstream compliance point shall be defined as the afterbay discharge. e. A summary of the temperature monitoring results at all sampling locations as established in the biological monitoring program for Hyco Reservoir and condition A.(4) shall be submitted to the Division with the annual Biological Monitoring Report due by July 31 of the following year. A. (18) Instream Monitoring [NCGS 143-215.1(b)] In accordance with the previously submitted biological monitoring program (as approved by the Director of the Division, and as it may be amended), the Permittee shall submit results of biological studies and monitoring programs by July 31 of the following year. The facility shall conduct monthly in -stream monitoring at Station F2 (formerly 6B) for total arsenic, total selenium, total mercury, total chromium, dissolved lead, dissolved cadmium, dissolved copper, dissolved zinc, total bromide, total hardness (as CaCO.), turbidity, and total dissolved solids (TDS). The monitoring results shall be reported on the facility's Discharge Monitoring Reports and included with the NPDES pernut renewal application. A. (19) Fish Tissue Monitoring Near Ash Pond Discharge [NCGS 143-215.3 (a) (2)] The facility shall conduct fish tissue monitoring annually and submit the results with the NPDES permit renewal application. The objective of this monitoring is to evaluate potential uptake of pollutants by fish tissue near the ash pond discharge. The parameters analyzed in fish tissue shall include arsenic, selenium, and mercury. The monitoring shall be conducted in accordance with the sampling plan approved by the Division. The plan should be submitted to the Division within 180 days from the effective date of the permit. Upon approval, the plan becomes an enforceable part of the permit. Copies of all the study plans, study results, and any other applicable materials should be submitted to Electronic Version Only (PDF and CD) Division of Water Resources WQ Permitting Section - NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 Electronic Version (PDF and CD) and Hard Copy Division of Water Resources Water Science Section 1621 Mail Service Center Raleigh, NC 27699-1621 A. (20) Applicable State Law (State Enforceable Only) [NCGS 143-215.1(b)] This facility shall meet the General Statute requirements under NCGS § 130A-309.200 et seq. This permit may be reopened to include new requirements imposed under these Statutes. Page 23 of 29 PermitNC0003425 A. (21) Limitations Reopener [NCGS 143-215.1(b)] The permit shall be modified, or revoked and reissued, to comply with any applicable effluent guideline or water quality standard issued or approved under sections 302(b)(2)(c) and (d), 304(b)(2) and 307(a) of the Clean Water Act, if the effluent guideline or water quality standard so issued or approved: a. Contains different conditions or is otherwise more stringent than any effluent limitation in the permit; or b. Controls a pollutant not limited in the permit. The permit as modified or reissued under this paragraph shall also contain any other requirements in the Act then applicable. A. (22) Domestic Wastewater Treatment Plant [NCGS 143-215.1(b)] The permittee shall at all times properly operate and maintain the domestic wastewater treatment plant to meet secondary standards as specified for internal outfall 008. A. (23) Bioreactor Condition [NCGS 143-215.1(b)] An operation and maintenance plan, including a monitoring regimen for the bioreactor units and an emergency response plan in the event of an upset, shall be maintained and available for inspection by Division personnel. A. (24) Ash Pond Closure [NCGS 143-215.1(b)] The facility shall prepare an Ash Ponds Closure Plan. This Plan shall be submitted to the Division one month prior to the closure of ash ponds. A. (25) Clean Water Act Section 316(b) [40 CFR 125.95) The pernuttee shall comply with the Cooling Water Intake Structure Rule per 40 CFR 125.95. The pernrittee shall submit the following information as required in 122.21 (except 122.21 (r)(6)) by May 31, 2023. §122.21(r)(2) Source Water Physical Data §/22.21(r)(3) Cooling Water Intake Structure Data §122.21(r)(4) Source Water Baseline Biological Characterization Data §/22.21(r)(5) Cooling Water System Data §122.21(r)(6) Chosen Method(s) of Compliance with the Impingement Mortality Standard (the chosen method will be defined after the site -specific BTA determination is made by the Director) §122.21(r)(7) Entrainment Performance Studies §122.21(r)(8) Operational Status §122.21(r)(9) Entrainment Characterization Study §122.21(r)(10) Comprehensive Technical Feasibility and Cost Evaluation Study §122.21(r)(11) Benefits Valuation Study §122.21(r)(12) Non -water Quality and Other Environmental Impacts Study Based on the director's selection of entrainment, this permit may be reopened to establish a schedule to implement the selected technology. Copies of all the study plans, study results, and any other applicable materials should be submitted to: Page 24 ot'29 Permit NC0003425 1. Electronic Version Only (PDF and CD) Division of Water Resources WQ Permitting Section - NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 2. Electronic Version (PDF and CD) and Hard Copy Division of Water Resources Water Sciences Section 1623 Mail Service Center Raleigh, NC 27699-1623 Based on 40 CFR 125.92 (c) and 40 CFR 125.94 (c) & (d), the Director has determined that operating and maintaining the existing closed -cycle recirculating system meets the requirements for a provisional BTA. The final determination will be made upon review of the materials submitted by the permittee. This determination does not preclude the Division from implementing additional requirements to minimize impingement and entrainment of the aquatic organisms based on the results of the studies. The facitity shall continue to demonstrate that make-up water withdrawals attributed specifically to the cooling portion of the cooling system have been minimized. Nothing in this permit authorizes take for the purposes of a facility's compliance with the Endangered Species Act. A. (26) Structural Integrity Inspections of Ash Pond Dam [15A NCAC 02K.0208] The facility shall meet the dam design and dam safety requirements per 15A NCAC 2K. A. (27) Biocide Condition [NCGS 143-215.1(b)] The permittee shall not use any biocides except those approved in conjunction with the permit application. The permittee shall notify the Director in writing not later than ninety (90) days prior to instituting use of any additional biocide used in cooling systems which may be toxic to aquatic life other than those previously reported to the Division of Water Resources. Such notification shall include completion of Biocide Worksheet Form 101 and a snap locating the discharge point and receiving stream. Completion of Biocide Worksheet Form 101 is not necessary for those outfalls containing toxicity testing. Division approval is not necessary for the introduction of new biocides into outfalls currently tested for whole effluent toxicity. A. (28) Compliance Boundary [15A NCAC 02L.01071 The compliance boundary for the disposal system shall be specified in accordance with 15A NCAC 02L .0107(a) or (b) dependent upon the date permitted. An exceedance of groundwater standards at or beyond the compliance boundary is subject to remediation action according to 15A NCAC 02L .0106(c), (d), or (e) as well as enforcement actions in accordance with North Carolina General Statute 143-215.6A through 143- 215.6C. The compliance boundary maps for this facility are incorporated herein and attached hereto as Attachments A and B. Attachment A includes the temporary compliance boundary around the East Ash Basin Extension. Attachment B is the future compliance boundary effective upon completion of the removal of coal ash from the East Ash Basin Extension. Page 25 of 29 Permit NC0003425 A. (29) Electronic Reporting of Discharge Monitoring Reports [G.S.143-215.1(b)] Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015. NOTE: This special condition supplements or supersedes the following sections within Part II of this permit (Standard Conditions for NPDES Permits): • Section B. (11.) Signatory Requirements • Section D. (2.) Reporting • Section D. (6.) Records Retention • Section E. (5.) Monitoring Reports 1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)l The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application. Monitoring results obtained during the previous month(s) shall be summarized for each month and submitted electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring data and submit DMRs electronically using the internet. Until such time that the state's eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation (CROMERR), permittees will be required to submit all discharge monitoring data to the state electronically using eDMR and will be required to complete the eDMR submission by printing, signing, and submitting one signed original and a copy of the computer printed eDMR to the following address: NC DENR / Division of Water Resources / Water Quality Permitting Section ATTENTION: Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-161.7 If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being physically located in an area where less than 10 percent of the households have broadband access, then a temporary waiver from the NPDES electronic reporting requirements may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2,3) or alternative forms approved by the Director. Duplicate signed copies shall be submitted to the mailing address above. See "How to Request a Waiver from Electronic Reporting' section below. Regardless of the submission method, the first DMR is due on the last day of the month following the issuance of the permit or in the case of a new facility, on the last day of the month following the commencement of discharge. Starting on December 21, 2025, the permittee must electronically report the following compliance monitoring data and reports, when applicable: • Sewer Overflow/Bypass Event Reports; • Pretreatment Program Annual Reports; and • Clean Water Act (CWA) Section 316(b) Annual Reports. The permittee may seek an electronic reporting waiver from the Division (see "How to Request a Waiver from Electronic Reporting" section below). Page 26 of 29 Permit NC0003425 2. Electronic Submissions In accordance with 40 CFR 122.41(l)(9), the permittee must identify the initial recipient at the time of each electronic submission. The permittee should use the EPA's website resources to identify the initial recipient for the electronic submission. Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity (EPA or the state authorized by EPA to implement the NPDES program) that is the designated entity for receiving electronic NPDES data [see 40 CFR 127.2(b)]. EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each type of electronic submission and for each state. Instructions on how to access and use the appropriate electronic reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting Rule is found at: http://www2.epa.gov/compliance/final-national-pollutant- d ischarge-elim ination-s v ste m-nvdes-electronic-reporting-rule. Electronic submissions must start by the dates listed in the "Reporting Requirements" section above 3. How to Request a Waiver from Electronic Reporting The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to the Division. Requests for temporary electronic reporting waivers must be submitted in writing to the Division for written approval at least sixty (60) days prior to the date the facility would be required under this permit to begin submitting monitoring data and reports. The duration of a temporary waiver shall not exceed 5 years and shall thereupon expire. At such time, monitoring data and reports shall be submitted electronically to the Division unless the permittee re -applies for and is granted a new temporary electronic reporting waiver by the Division. Approved electronic reporting waivers are not transferrable. Only permittees with an approved reporting waiver request may submit monitoring data and reports on paper to the Division for the period that the approved reporting waiver request is effective. Information on eDMR and the application for a temporary electronic reporting waiver are found on the following web page: http: / / deq.nc.gov/about/ divisions/ water -resources/ edmr 4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) Ml All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part 11, Section B. (11.)(a) or by a duly authorized representative of that person as described in Part 11, Section B. (11)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting purposes. For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and login credentials to access the eDMR system. For more information on North Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the following web page: httl2://deg.nc.gov/about/`divisions/`water-rc,,,OLirces/edmr Page 27 of 29 Permit NC0003425 Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED: "I certify, under penalty of law, that this document and till attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the infmuation submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations." 5. Records Retention [Supplements Section D. (6.)l The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These records or copies shall be maintained for a period of at least 3 years from the date of the report. This period may be extended by request of the Director at any time [40 CFR 122.411. A. (30) Additional Conditions And Definitions [NCGS 143-215.3 (a) (2) and NCGS 143-215.661 1. EPA methods 200.7 or 200.8 (or the most current versions) shall be used for analyses of all metals except for total mercury (EPA Method 1631E). 2. All effluent samples for all external outfalls shall be taken at the most accessible location after the final treatment but prior to discharge to waters of the U.S. (40 CFR 122.410)). 3. The term low volume waste sources mean wastewater from all sources except those for which specific limitations are otherwise established in this part (40 CFR 423.11 (b)). 4. The term chemical metal cleaning waste means any wastewater resulting from cleaning any metal process equipment with chemical compounds, including, but not limited to, boiler tube cleaning (40 CFR 423.11 (c)). 5. The term metal cleaning waste means any wastewater resulting from cleaning [with or without chemical cleaning compounds] any metal process equipment including, but not limited to, boiler tube cleaning, boiler fireside cleaning, and air preheater cleaning (40 CFR 423.11 (d)). 6. For all outfalls where the flow measurement is to be "estimated" the estimate can be done by. using calibrated V-notch weir, stop -watch and graduated cylinder, or other method approved by the Division. 7. The term "FGD wet scrubber wastewater" means wastewater resulting from the use of the flue -gas desulfurization wet scrubber. 8. There shall be no discharge of polychlorinated biphenyl compounds. 9. The permfttee shall report the presence of cenospheres observed in any samples on the DMRs in the comment section. 10. The applicant is permitted to discharge chemical metal cleaning wastes to the Lined Retention Basin. 11. Nothing contained in this permit shall be construed as a waiver by the permittee of any right to a hearing it may have pursuant to State or Federal laws and regulations. Page 28 of 29 nnry lll%%r�"' `_� _ Outfall0lX' �1�1/ F� Permit NC0003425 I r � � t Outfalll2B o-� Internal Outfall 00' �,.> ; ��- Internal Outfal1010 g - g f wis �� a: i I Duke Energy Progress — Roxboro Steam Station, Person County Facility Location Receiving Stream: Hyco Reservoir Stream Gass: WS-V, B .* Sub -Basin: 03-02-05 State Grid: B22NE/Olive Hill N Drainage Basin: Roanoke River Basin Outfall 001: Latitude 36° 29' 1.25" Longitude 79' 3' 23.0" Outfall 003: Latitude 36' 28' 48" Longitude 79' 05' 11" Outfall 006: Latitude 36' 19' 13" Longitude 79°04041" NPDES Permit NC0003425 Outfall 012C: Latitude: 36' 129 14" Longitude 79' 04' 55" Paw 29 of 29 Outfalll2B o-� Internal Outfall 00' �,.> ; ��- Internal Outfal1010 g - g f wis �� a: i I Duke Energy Progress — Roxboro Steam Station, Person County Facility Location Receiving Stream: Hyco Reservoir Stream Gass: WS-V, B .* Sub -Basin: 03-02-05 State Grid: B22NE/Olive Hill N Drainage Basin: Roanoke River Basin Outfall 001: Latitude 36° 29' 1.25" Longitude 79' 3' 23.0" Outfall 003: Latitude 36' 28' 48" Longitude 79' 05' 11" Outfall 006: Latitude 36' 19' 13" Longitude 79°04041" NPDES Permit NC0003425 Outfall 012C: Latitude: 36' 129 14" Longitude 79' 04' 55" Paw 29 of 29 Permit NC0003425 lake and the afterbay lake to Hyco River shall comply with water quality standards except the temperature standards in the areas of the lake defined herein as a mixing zone. Water discharged from the afterbay shall comply with the temperature standard. Temperature readings from the afterbay shall be obtained from the existing USGS station (02077303). b. Temperature measurements made to monitor compliance with this provision shall be made at least six inches, but not more than one foot, below the surface of the lake. c. Temperature shall be measured daily. In case where the permittee experiences equipment problems and is unable to obtain daily temperatures from the monitoring station temperature monitoring must be reestablished within five working days. d. Temperature increases shall be determined as the increase in temperature above the background level. Background level shall be defined as the temperature measured at the confluence of the two southern finger arms on the north side of the lake (Lat. 36.5111, Long 79.06629). The downstream compliance point shall be defined as the afterbay discharge. e. A summary of the temperature monitoring results at all sampling locations as established in the biological monitoring program for Hyco Reservoir and condition A.(4) shall be submitted to the Division with the annual Biological Monitoring Report due by July 31 of the following year. A. (18) Instream Monitoring [NCGS 143-215.1(b)] In accordance with the previously submitted biological monitoring program (as approved by the Director of the Division, and as it may be amended), the Permittee shall submit results of biological studies and monitoring programs by July 31 of the following year. The facility shall conduct monthly in -stream monitoring at Station F2 (formerly 6B) for total arsenic, total selenium, total mercury, total chromium, dissolved lead, dissolved cadmium, dissolved copper, dissolved zinc, total bromide, total hardness (as CaCOg), turbidity, and total dissolved solids (TDS). The monitoring results shall be reported on the facility's Discharge Monitoring Reports and included with the NPDES permit renewal application. A. (19) Fish Tissue Monitoring Near Ash Pond Discharge [NCGS 143-215.3 (a) (2)] The facility shall conduct fish tissue monitoring annually and submit the results with the NPDES permit renewal application. The objective of this monitoring is to evaluate potential uptake of pollutants by fish tissue near the ash pond discharge. The parameters analyzed in fish tissue shall include arsenic, selenium, and mercury. The monitoring shall be conducted in accordance with the sampling plan approved by the Division. The plan should be submitted to the Division within 180 days from the effective date of the permit. Upon approval, the plan becomes an enforceable part of the permit. Copies of all the study plans, study results, and any other applicable materials should be submitted to Electronic Version Only (PDF and CD) Division of Water Resources WQ Permitting Section - NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 Electronic Version (PDF and CD) and Hard Copy Division of Water Resources Water Science Section 1621 Mail Service Center Raleigh, NC 27699-1621 A. (20) Applicable State Law (State Enforceable Only) [NCGS 143-215.1(b)] This facility shall meet the General Statute requirements under NCGS § 130A-309.200 et seq. This permit may be reopened to include new requirements imposed under these Statutes. Page 23 of 29 (> DUKE ENERGY, April 23, 2020 Via Overnight Mail NC Dept of Environmental Quality MAY - 1 2020 Raleigh Regional Office Rick Bolich Raleigh Regional Office Regional Supervisor North Carolina Department of Environmental Quality Division of Water Resources 1628 Mail Service Center Raleigh, NC 27609 Bob Sledge North Carolina Department of Environmental Quality Division of Water Resources Water Quality Permitting Program 1617 Mail Service Center Raleigh, NC 27699-1617 James Wells Vice President Environmental, Health and Safety Programs & EnAm mental Sciences 526 South Church Street Charlotte, NC 28202 (980) 373.9646 Subject: Report Under Special Order by Consent — EMC SOC WQ S 18-005 Duke Energy Progress, LLC — Mayo Steam Electric Plant NPDES Permit NCO038377 2019 Annual Seep Survey Report Dear Messrs. Bolich and Sledge: On behalf of Duke Energy Progress, LLC (DEP), I am submitting to you the Mayo Steam Electric Plant Annual Seep Report summarizing the findings of the comprehensive survey as required by Special Order by Consent (SOC), SOC No. S 18-005 Section 2.c.3). As required by the SOC, I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Messrs. Bolich and Sledge April 23, 2020 Page 2 Please direct any questions concerning the Mayo Steam Electric Plant SOC No. S 18-005 to Lori Tollie at (336) 8544916 and to Chris Hallman at (980) 373-7892 relative to the annual seep inspection report. Sincerely, Vice President, Environment, Health & Safety - Programs and Environmental Sciences Duke Energy Attachment: Mayo Steam Electric Plant 2019 Annual Seep Survey CC: Richard Baker, Duke Energy Lori Tollie, Duke Energy Chris Hallman, Duke Energy Leanne Wilson, Duke Energy Paul Draovitch, Duke Energy Matt Hanchey, Duke Energy 167, synTerra NC Dept of Environmental Quality MAY -1 2020 Raleigh Regional Office 2019 ANNUAL SEEP REPORT MAYO STEAM ELECTRIC PLANT EMC SOC WQ S18-005 10660 BOSTON ROAD ROXBORO, NC 27574 APRIL 2020 PREPARED FOR DUKE ENERGYw PR(1(`.p r c c� DUKE ENERGY PROGRESS, LLC erry y ie, C G #1425 Senior Proi ct Manager 2019 Annual Seep Report April 2020 Mayo Steam Electric Plant, Duke Energy Progress, LLC SynTena TABLE OF CONTENTS SECTION PAGE 1.0 INTRODUCTION.........................................................................................................1-1 1.1 Inspection Details......................................................................................................1-1 2.0 FINDINGS..................................................................................................................... 2-1 2.1 General Observations...............................................................................................2-1 2.2 Effects of Decanting..................................................................................................2-1 2.3 Changes to Seep Status.............................................................................................2-1 3.0 REFERENCES................................................................................................................3-1 LIST OF FIGURES Figure 1 SOC Locations and Inspection Areas LIST OF TABLES Table 1 SOC Locations and Descriptions — 2019 Inspection LIST OF APPENDICES Appendix A Photographs Page 2019 Annual Seep Report April 2020 Mayo Steam Electric Plant, Duke Energy Progress, LLC SynTerra LIST OF ACRONYMS C&D Landfill Constructrion and Debris Landfill EMC Environmental Management Commission SOC Special Order by Consent Page ii 2019 Annual Seep Report April 2020 Mayo Steam Electric Plant, Duke Energy Progress, LLC SynTerra 1.0 INTRODUCTION On February 28, 2019, Jerry Wylie (NC L.G. #1425) of SynTerra inspected the Mayo Steam Electric Plant (Mayo or Site) property for existing and potential new seeps. Inspection activities were performed in accordance with North Carolina Environmental Management Commission (EMC) Special Order by Consent WQ #518-005. That Special Order by Consent (SOC) describes inspection requirements as follows: Duke Energy shall conduct annual comprehensive surveys of areas down gradient of ash basins identifying new seeps, and documenting the physical characteristics of previously documented seeps. All examinations of seeps must include identification of seeps by approximate latitude and longitude and date -stamped digital photographs of their appearance. A report summarizing the findings of the surveys, including a section analyzing the effect decanting of the basin(s) has on seep flows, accompanied by copies of the photographs noted above ("Annual Seep Report"), shall be submitted to DWR in conjunction with submittal of the April 30 quarterly report noted in 2(c)(2) above. This Annual Seep Report must list any seep that has been dispositioned (as described below) during the previous year, including an analysis of the manner of disposition. Each location documented as a seep at issuance of the SOC, as listed in Table 1 of the SOC, was observed and documented with photographs during the inspection. General observations include: • No previously unidentified seeps were observed during the inspection. • No noteable changes to seep status were observed during the inspection. • Decanting had not begun at the time of this inspection. 1.1 Inspection Details Weather before and during the inspection was clear. Temperatures ranged from approximately 40 to 50 degrees Fahrenheit (F). There was no precipitation on the day of the inspection, according to information from the on -Site rain gauge. Information from the rain gauge indicated there was no precipitation during the three days before the inspection. The inspector reviewed previous inspection reports and dam safety inspection reports pertaining to the ash basin. Cedric Fairbanks (Duke Energy system owner) conducted the ash basin dam safety inspections and prepared the reports. Ms. Leanne Wilson (Mayo Plant Environmental Coordinator) and Mr. Fairbanks were interviewed Page 1-1 2019 Annual Seep Report April 2020 Mayo Steam Electric Plant, Duke Energy Progress, LLC SynTerra concerning recent rainfall, construction/stabilization projects associated with the ash basins, and general Site conditions in and surrounding the ash basin. Observations from the dam safety inspection reports were consistent with observations made during the annual inspection. The inspection included observations in the following areas (Figure 1): • Along the perimeter of the ash basin (at the toe of the dam) • Along the area north of the 1981 Construction and Debris (C&D) Landfill • Within areas at or below the ash basin water elevation and downgradient and/or downstream Drainage features associated with the basin, including engineered channels Seep locations and inspection areas are shown on Figure 1. Observations noted during the inspection are summarized on Table 1. Photographs taken of each seep location during the inspection are included in Appendix A. Page 1-2 2019 Annual Seep Report April 2020 Mayo Steam Electric Plant, Duke Energy Progress, LLC SynTerra 2.0 FINDINGS 2.1 General Observations Inspection observations of each seep are shown in Table 1. Details include: • No new seeps were observed during the inspection. • No previously unidentified or unreported pipes were observed during inspection. • Ash basin dam toe drains (S-01 and S-02) are enclosed within a confined space. • A system designed to capture flow from S-01 and S-02 and from nearby seep locations — including S-01A, S-02A, and S-02B — is in operation. 2.2 Effects of Decanting Decanting of the ash basin at Mayo had not yet begun at the time of this inspection. 2.3 Changes to Seep Status Mr. Wylie inspected each seep to evaluate whether it may be dispositioned in accordance with the SOC. The requirements for dispositioning a seep are as follows: For purposes of this Special Order, "dispositioned" includes the following: (1) the seep is dry for at least three consecutive quarters, (2) the seep does not constitute, and does not flow to, waters of the State or Waters of the United States for three consecutive quarters; (3) the seep is no longer impacted by flow from any coal ash basin as determined by the Director of DWR in accord with applicable law and best professional judgment; or (4) the seep has been otherwise eliminated (e.g., through an engineering solution). If a seep that has been dispositioned through drying up reappears in any subsequent survey, such a seep will no longer be deemed dispositioned and can be subsequently re-dispositioned as specified above. Non -constructed seeps described in paragraph 1(h) of this SOC cannot be dispositioned through option (2) above. No changes to seep status were observed during this inspection. Page 2-1 2019 Annual Seep Report April 2020 Mayo Steam Electric Plant, Duke Energy Progress, LLC SynTerra 3.0 REFERENCES North Carolina Department of Environmental Quality. (2018). Special Order by Consent EMC SOC WQ 518-005. Page 3-1 2019 Annual Seep Report April 2020 Mayo Steam Electric Plant, Duke Energy Progress, LLC SynTerra FIGURE SOC LOCATIONS AND DES 2019 ANNL MAYO STEAr DUKE ENERGY PRO( Location Coordinates Receiving Facility Sample ID Receiving Waterbody Waterbody DI Latitude Longitude Classification Intermittently o downslope fron location. No flov Mayo S-07* 36.521798 -78.892152 Mayo Reservoir WS-V evaluations. southeast, me before reachim sampling Seep forms ono Mayo 5-08 36.537502 -78.890398 Crutchfield Branch B east toe drain,fl channelto Natural stream Maya S-09* 36.522902 -78.886868 Mayo Reservoir WS-V originating south upstream of, al From sampli Mayo S-10 36.538422 -78.890395 Crutchfield Branch B Minor seep to northwest inl Not"* ' - Location previously investigated as a seep_ Monitoring has not indicated the presence of coal combustion residuals. " - Seep dispositioned via repair and/or non -Rowing condition to potentially reach Waters of the U. S., or other, as noted. Monitoring shall be conducted at the app All monitoring shall be conducted per the requirements found in Attachment B of this Order. 28 - 15A NCAC 02L .0202 Standard CCR - Coal Combustion Residuals ft - feet NA - Not Applicable NPDES - National Pollutant Discharge Elimination System SOC - Special Order by Consent UT - Unnamed Tributary 1BLE 1 ;RIPTIONS - 2019 INSPECTION AL SEEP REPORT ELECTRIC PLANT RESS, LLC, ROXBORO, NC scription SOC Monitoring Interim Action Levels Notes from Inspection served area of wetness former production well observed during recent NA - Seep my flow would drain Dispositioned NA - Seep Dispositioned Historical sample location. Dispositioned. ®ing with flow at 5-06 Mayo Reservoir. From no CCR impacts. Area of emergence is a small pool (-3 ft x 6 Monitoring in ft) with little discernible flow that increases ridge over (east) from Crutchfield Branch downslope. A small, wet, muddy area is wing northwest in small 'rutchfield downstream of all seep NA - 2B Standards Apply present near sign (east) flowing across leaf Branch. flow contributions litter with iron floc present. About 50 feet uphill is an area of emergence in a scour channel that Flows towards and into channel. dow to Mayo Reservoir ast of plant. Location is fl d flowing toward S-06. NA - Seep Dispositioned NA - Seep Dispositioned Historical sample location. Dispositioned. - no CCR impacts. Seep is located to the southeast of 5-03 on a Monitoring in hillside between two topographic draws. mall channel, flowing Crutchfield Branch NA - 2B Standards Apply Shallow flow was present in the channel Crutchfield Branch. downstream of all seep directly below sign. Flow increased downslope flow contributions and crossed the monitoring well access road and continued into Crutchfield Branch. ximate locations indicated on the attached site map. Prepared by: P)WJ Checked by: PWA Page 2 of 2 SOC LOCATIONS AND DES 2019 ANNI MAYO STEAf DUKE ENERGY PRO( Location Coordinates Receiving Facility Sample ID Receiving Waterbody Waterbody D. Latitude Longitude Classification NA - Flow is collected and pumped back to NPDES- Mayo 5-01 36.538849 -78.893512 permitted wastewater system N4 Seep flow f in accordance with the pumping system's design capacity. Minor seep forma Mayo S-01A 36.538903 -78.89351 UT to Crutchfield Branch B toe of the west UT to Cr NA - Flow is collected and pumped back to NPDES- Mayo 5-02 36.537964 -78.891364 permitted wastewater system NA Seep flow 1 in accordance with the pumping system's design capacity. Minor seep forr Mayo S-02A 36.538005 -78.891611 Crutchfield Branch B feet upslope of e collection box, Minor seep form Mayo S-02B 36.537989 -78.891339 Crutchfield Branch B 02 collection bo> Mayo 5-03** 36.538654 -78.890714 Crutchfield Branch B Sampling Mayo 5-04** 36.538896 -78.89341 Crutchfield Branch B Sampling Mayo 5-05** 36.535039 -78.891693 Mayo Reservoir WS-V Ash basin samp Seep flow to sma Mayo 5-06* 36.521971 -78.88526 Mayo Reservoir WS-V southeast of poi f -kBLE 1 :RIPTIONS - 2019 INSPECTION AL SEEP REPORT ELECTRIC PLANT RESS, LLC, ROXBORO, NC scription SOC Monitoring Interim Action Levels Notes from Inspection Constructed seep. Water level in box is low and sump is active. Evidence of sediment im west toe drain. NA NA transport from upslope gravel and riprap is present around the area surrounding the box structure. g within filter bed at the Monitoring in An area of rip rap and gravel at the toe of the am and flowing into an Crutchfield Branch NA - 2B Standards Apply west side groin ditch of the dam. Minimal flow tchfield Branch. downstream of all seep beneath/around rip rap. Seep captured by flow contributions collection system. om east toe drain. NA NA Constructed seep. Water level in box is low and sump is active. ing within filter bed 20 Monitoring in st dam toe drain (5-02) owing into Crutchfield Crutchfield Branch downstream of all seep NA - 2B Standards Apply Dry. Seep captured by collection system. &ranch. flow contributions Monitoring in Seep is adjacent to east toe drain structure in ig just downgrade of S- Crutchfield Branch area of rip rap at the toe of the east side groin Flowing into Crutchfield downstream of all seep NA - 2B Standards Apply of the ash basin dam. Flow downslope and Iranch. flow contributions along/within groin on east side of the toe drain structure. =ation; not a seep NA - Seep Dispositioned NA - Seep Dispositioned Dispositioned. Not a seep. ration; not a seep NA - Seep Dispositioned NA - Seep Dispositioned Dispositioned. Not a seep. ng location, not a seep NA - Seep Dispositioned NA - Seep Dispositioned Dispositioned. Not a seep. channel that originates NA - Seep ar plant. Flows to Mayo Dispositioned NA - Seep Dispositioned Historical sample location. Dispositioned. servoir. Page 1 of 2 v x NOTES, I SPECIAL ORDER BY CONSENT (SOC) LOCATIONS ARE DESCRIBED IN EMC SOC WO .I&W5 A 2. THE WATERS OF THE U.S. DELINEATION HAS NOT BEEN APPROVED BY THE U.S. ARMY CORPS OF ENGINEERS AT THE TIME OF THE MAP CREATION. THIS MAP IS A PRELIMINARY JURISDICTIONAL DETERMINATION ONLY THE PRELIMINARY WETLANDS AND STREAMS BOUNDARIES WERE OBTAINED FROM AMEC FOSTER WHEELER ENVIRONMENTAL 6INFRASTRUCTURE, INC. NATURAL RESOURCES TECHNICAL REPORT (NRTR) FOR MAYO STEAM ELECTRIC PLANT DATED JANUARY 2014 AND UPDATED ON JULY 11, 201B TO REMOVE ONE PREVIOUSLY MISIDENTIFIED WETLAND NEAR THE ASH BASIN DISCHARGE CHANNEL 0. SAMPLE LOCATIONS WERE DERIVED FROM VARIOUS SOURCES AND ARE A MIX OF SURVEYED AND APPROXIMATE LOCATIONS. THEREFORE. SAMPLE LOCATIONS ARE APPROXIMATE. A ALL BOUNDARIES ARE APPROXIMATE 5. MAYO PLANT PROPERTY BOUNDARY PROVIDED BY DUKE ENERGY PROGRESS. 6 AERIAL PHOTOGRAPHY OBTAINED FROM ESRI ONLINE ON JUNE 10, 2019 AERIAL WAS COLLECTED ON FEBRUARY 6. 2017 T. DRAWING HAS BEEN SET WITH A PROJECTION OF NORTH CAROLINA STATE PLANE COORDINATE SYSTEM RIPS 02M (NAD83). � +jElA�lli+r'yy1� r: u l • __v rNORTH CAROLINA NRGWN STATE UNE WLLIfA%COVNTY (APPROXIMATE) --7!!Illllllllll r j \ MAYO RESERVOIR V. WE. 433.0t LEGEND • CONSTRUCTED SEEP (APPROXIMATE) 0 NON -CONSTRUCTED SEEP (APPROXIMATE) • DISPOSITIONED SEEP (APPROXIMATE) SPECIAL ORDER BY CONSENT (SOC) INSPECTION AREA — ASH BASIN WASTE BOUNDARY • - • GEOGRAPHIC LIMITATION - - - - RIGHT-OF-WAY (DUKE ENERGY PROPERTY) — • DUKE ENERGY PROGRESS PROPERTY ' - -► STREAM (AMEC NRTR 2014) 7= WETLAND (AMEC NRTR 2014) DUKE GRAPHIC SCALE 500 0 500 1.000 FIGURE 1 ENERGY IN ' SOC LOCATIONS AND INSPECTION AREAS PROGRESS DRAWN BY: &ROBINSON DATE05/03/20w 2019 ANNUAL SEEP REPORT REVISEDBY: nROBINSON DATE: 03/19,2020 MAYO STEAM ELECTRIC PLANT ` CHECKEDBV..J. MLIE DARE: 03/192D2[ APPROVED BY J.W IT DATE 03I392D2n ROXBORO, NORTH CAROLINA PROJEE, MANADEP J LIE synTem ww,.svnterrawrD.Com 2019 Annual Seep Report April 2020 Mayo Steam Electric Plant, Duke Energy Progress, LLC SynTerra TABLE 2019 Annual Seep Report April 2020 Mayo Steam Electric Plant, Duke Energy Progress, LLC SynTerra APPENDIX A PHOTOGRAPHS 2019 Annual SOC Report Mayo Steam Electric Plant - Duke Energy Progress, LLC O 179"S M * 36°32'19"N, 78053'36"W z16.4ft 1 418ft s View of constructed seep location, facing down (top of photo is to the S-01 I 028•NE m 0 36°32'21"N, 78.53'37WJ z32.8ft A 394ft S-01A I View of seep location facing northeast. RT1 KI)V.Dl SynTerra Page 1 of 7 2019 Annual SOC Report Mayo Steam Electric Plant - Duke Energy Progress, LLC O 220-SW M ! 36°32'15-N, 78°53'28"W x32.8ft ♦ 390k S-02 I View of constructed seep location facing southwest. 0231•SW(T) 036°32'16"N, 78-5N z16.4f11387f1 7i Ni L i"T,_ ins S-02A I View of seep location facing southwest. mril 2020 �enTerra Page 2 of 7 2019 Annual SOC Report Mayo Steam Electric Plant - Duke Energy Progress, LLC l` } g-0 ; I View of dispositioned seep location facing northeast. Lpril 2020 SynTerra Page 3 of 7 2019 Annual SOC Report Mayo Steam Electric Plant - Duke Energy Progress, LLC 0101°E (T) OO 36°32'20"N, 78°53'36"W t16.4ft ♦ 426ft Lpril 2020 wnTerra 5-04 I View of dispositioned seep location facing east. ! No photo provided. Location was dispositioned prior to issuance of SOC because it is not a seep. Location was an ash basin location. S-05 Page 4 of 7 2019 Annual SOC Report Mayo Steam Electric Plant - Duke Energy Progress, LLC Loril 2020 ';%,nTerra No photo provided. Location was dispositioned prior to issuance of SOC based can no CCR impacts. Location is a historical sampling location. No photo provided. Location was dispositioned prior to issuance of SOC based on no CCR impacts. Location is a historical sampling location. 5-0 i Page 5 of 7 2019 Annual SOC Report Mayo Steam Electric Plant - Duke Energy Progress, LLC No photo provided. Location was dispositioned prior to issuance of SOC based on no CCR impacts. Location is a historical sampling location. S-09-1- Loril 2020 S � nTerra Page 6 of 7 w 2019 Annual SOC Report Mayo Steam Electric Plant - Duke Energy Progress, LLC NW N NE 0 355•N M 3 38°32'18"N, 78°53'25"W s16.4f1 ♦ 408f1 - l Q View of seep location facing north. ,pril 2020 SynTerra Page 7 of 7 DocuSign Envelope ID: CF6912A6-A9284BBD-9I-. ­BiF12AADBD Sun .' -.' r ROY COOPER #e _ GOYMnM T� ELIZABETH S. BISER RICHARD E. ROGERS. JR. NORTH Caao.INA Dim, for Environmental Quality July 7, 2022 Ms. Jessica Bednarcik, Senior Vice President Environmental Health and Safety, CCP Jessica.Bednarcik@duke-energy.com Duke Energy Carolinas, LLC 526 S Church St. Mail Code Ec13k Charlotte, NC 28201-1002 Subject: Compliance Evaluation Inspection Cape Fear Steam Electric Power Plant NPDES Permit No. NC0003433 Chatham County Dear Ms. Bednarcik On June 8, 2022, Jason Robinson and Alys Hannum of the Division of Water Resources' Raleigh Regional Office (RRO) conducted a compliance evaluation inspection of the subject facility. The assistance provided by Jonathan Stamas (Operator in Responsible Charge — ORC), Joyce Dishmon (Permitting and Compliance), and John Toepher (Environmental Engineer) was appreciated. The NPDES Compliance inspection consisted of the following: • Review of the NPDES permit • Review of the owner/facility information • Review of monitoring data and Electronic Discharge Monitoring Reports (eDMRs) • Review of operator logbook • Walk-thru inspection of the outfalls Finding during the pre -inspection were as follows: 1. The recent permit became effective October 1, 2020 and expires on June 30, 2023. If the permit is not rescinded prior to expiration, please submit a permit renewal application at least 180 days prior to expiration to comply with permit requirements. 2. The facility entered into a Special Order of Consent (SOC) on January 27, 2020. The SOC involves a Corrective Action Plan to address seeps. DocuSign Envelope ID: CF6912A6-A9294BBD-91 , , , B1F12AADBD 3. The facility is classified as a PC-1 Wastewater Facility. Mr. Jonathan Stamas is designated as the Operator in Responsible Charge (ORC) and Robert Howard and Jaquelin Wilson are the designated back-up operators (bORC). All are certified Grade 1 operators. 4. DWR last inspected this facility for NPDES compliance in December 2020. 5. No DMR violations have occurred since the last inspection. 6. Prior to 2012, the facility employed two coal-fired units along with four oil -fueled combustion turbine units. Residuals generated from coal combustion were stored in on -site ash basins. The plant ceased operations in 2012, and demolition activities of the plant have been completed. The site has five ash basins: 1956, 1963, 1970, 1978 and 1985. The 1956, 1963 and 1970 basins are dry and vegetated, except for the southern end of the 1970 basin that is seasonally wet. All wastewater generated by the site were discharged to the discharge canal at Outfall 007. A new Outfall 008 was added to the permit to allow for releases to the Cape Fear River associated with basin closures, and Outfall OO8a and 008b were added for emergency discharge and emergency overflow. An ash beneficiation facility became operational in 2021 to convert the residuals to fly ash material for use in the production of concrete. This facility is located beside the existing site. The facility reported effluent discharges at Outfall 008 for all months in 2020 except for January and August. In 2021, the facility only reported effluent discharges at 008 in January, February, and July. As of this inspection, the facility only reported one 2022 discharge from Outfall 008 in April. The permittee is compliant with the self -monitoring requirements of the permit. Findings during the inspection were as follows: 1. Daily operation logbooks were available for review. The books were detailed and complete and kept onsite going back at least three years. 2. Upstream and downstream samples are collected by Duke Environmental Services and sent to Pace Labs for analyzation: • Instream samples are analyzed at Pace's Asheville laboratory, Certification #40. • Instream and dewatering Mercury are analyzed at Pace's South Carolina laboratory (#329). • Dewatering field samples are analyzed by Pace Field Services (#5342). Duke Energy Progress -HEEC collects and analyzes instream field samples (#5710). Outfall 008 samples are collected by Pace Field Services and sent to the Duke McGuire lab: • Oil & Grease, turbidity, Al, As, Cd, Cu, Pb, Ni and Se are analyzed by Duke (#248). • TSS and Mercury are analyzed by Pace labs. Toxicity is collected by Duke and analyzed by ETT Environmental, Inc. (#22) 2of3 DoaSgn Envelope ID: CF6912A6-A92B-4BBD-9h,,-,,B1F12AADBD 3. Laboratory Bench sheets, chain of custody forms and lab results for December 2021 and April 2022 were reviewed and found to be complete. Bench sheet values were compared to the Electronic Discharge Monitoring Reports (eDMR) submitted by the permittee and no discrepancies were found. Past laboratory documents are kept on site (required to keep at least five years). Chronic Toxicity is sample monthly (in months where discharges occur) 4. Outfalls 001, 005, 007, 008, 008a & 008b were visited. Outfall 008 on the Cape Fear River is the only active discharge (see Item 6 above). The facility has been dewatering from the 1978 and 1985 basins since November 12, 2019. Water from the two ash ponds is pumped and treated at the on -site treatment facility before being discharge at Outfall 008. Flow meters are located at the discharge of the 1978 and 1985 basin, and at Outfall 008. The outfalls appeared to be in good condition, and the right of ways were properly maintained. The facility was not discharging at the time of the inspection. The inspector did not observe any issues of concern during this inspection. The facility appeared well maintained, and documentation was found to be detailed, organized, and complete. Thank you again for your cooperation with this inspection. If you have any questions regarding the report or any of the findings, please contact Jason Robinson at Jason.Robinson@ncdenr.gov. ATTACHMENTS • EPA Inspection Checklist Cc: Raleigh Regional Office and Laserfiche ionathan.stamas@duke-eneray.com iovice.dishmon@duke-enerev.com Sincerely, DocuSigned by: A E4wotatAt SSa f, 0291fiE6AB]2144F.. Vanessa Manuel, Assistant Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ 3of3 DocuSign Envelope ID: D8DOA05A-7AF1 ROY COOPE k ELIZABEFH S. RISER 5. DANIEL SMITH Pr :,, Jessica Bednarcik Duke Energy Progress, LLC 526 S Church St. — Ec13k Charlotte, NC 28201-1002 Dear Ms. Bednarcik: 8A06-8A5476502AC5 Emir onmvnlal Qua 1, r, September 9, 2021 Subject: Compliance Evaluation Inspection Duke Energy — Roxboro Steam Plant NPDES Permit No. NC0003425 Person County On August 18, 2021 Jason Robinson of the Raleigh Regional Office (RRO) conducted a compliance evaluation inspection of the Duke Energy Roxboro Steam Plant. The assistance provided by Mr. Kevin Clayton (Operator in Responsible Charge (ORC)), Ms. Amber Sarver (Chemistry & Process Safety Management Supervisor & bORC) and Lori Tollie (Permitting and Compliance) was appreciated. • The facility is located at 1700 Dunnaway Road in Semora, North Carolina. • NPDES permit NCO003425 was modified and issued for the treatment facilities on August 1, 2021 and expires on June 30, 2025. • The facility has both Grade I Physical/Chemical Water Pollution Control Systems that treat industrial wastewater (numerous Outfalls) and a Grade 11 Biological Water Pollution Control system with an as - built and permitted flow of 0.025 MGD that treats domestic wastewater (Outfall 008). • The permit authorizes the facility to discharge the treated wastewater through Outfalls 001, 003 and 006, with accompanying monitoring requirements and limits, to receiving waters designated as Hyco Lake, a waterbody classified as WS-V and B waters within the Roanoke River Basin. The permit also authorizes the discharge of numerous internal outfalls, with accompanying monitoring requirements and limits. Finding during the compliance inspection were as follows: 1. The operator's on -site log and supporting documentation was reviewed and found to be complete. 2. The Roxboro Stem Plant's on -site lab is field certified for and self -reports monitoring data for the following parameters (Certification Number 5080): pH, Temperature and Turbidity. Meter calibration logs were reviewed and found to be complete, buffers were within expiration dates, and refrigerator temperature and log was within range. Samples are transported offsite to the Duke Analytical Lab (certification number 248) to analyze additional parameters. A few parameters are sent to be analyzed by a commercial lab. 3. Discharge Monitoring Reports for September 2020 and February 2021 were reviewed and compared D_E Q DowSgn Envelope ID: DBDOA05A-7AF1 5A06-BA5476502AC5 to laboratory bench sheets. No discrepancies were noted. Lab results, chain of custody records, and bench sheets were available for review and found to be complete. 4. All outfalls listed in the permit were observed during the inspection. No issues were found. All domestic wastewater is treated by a package treatment plant with chorine disinfection (Internal Outfall 008). The effluent from the package plant goes to the low volume wastewater treatment system. No issues were found. This facility was found to be compliant with NPDES permit conditions as a result of this inspection. If you have any questions regarding the attached reports or any of the findings, please contact Jason Robinson at Jason.t.robinson@ ncden r.gov). Sincerely, CDocuSiyned by: Valtf sSa f. kAUAXd 82916E6AB32141F Vanessa Manuel, Assistant Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ ATTACHMENTS Compliance Inspection Report Cc: DWR Laserfiche Raleigh Regional Office w/attachment Lori.Tollie@duke-energy.com Kevin.Clayton@duke-energy.com Amber.Sarver@duke-energy.com Robert.Howard@duke-energy.com DocuSign Envelope ID: 098EDE31-B6EA 4,45F-0D1E975F71DF United States EmAmn"Mal Protection Agency Form Approved. EPA Washington. D C 20460 OMB No. 2040-0057 Water Compliance Inspection Report 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 IN I 2 u 3 I NCO003425 I11 12 21/08/18 17 181 r 1 191 S I 201 I 2111111111111111111111111111111111111111111I f6 Inspection Work Days Facility Self-Momtonng Evaluation Rating B7 GA Reserved I 71 I I. 72 I ti I 731 I 174 75I I I I I I I I80 67I 1 70I J L I—� LL_I LLJ 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 Dermil Number) 01:OOPM 21/08/18 21/08/01 Roxboro Steam Electric Power Plant 1700 Dunaway Rd Exit Time/Date Permit Expiration Date Semora NC 27343 04:OOPM 21/08/18 25/06/30 Names) of Onshe Representative(s)ROes(s)/Phone and Fax Numbers) Other Facility Data 111 Kevin Danny Clayton/ORC/336-330-2055/ Name, Address of Responsible Officiall7tle/Phone and Fax Number LORI 'TOLL16 Contacted yQ Mana er/336-597-6101/ Section C. Areas Evaluated During Inspection (Check only those areas evaluated) Permit E Flow Measurement Operations & Maintenar 0 Records/Reports Effluent/Receiving Wate N 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 Jason T Robinson j�oe<ss,�rd by DWR/RRO WQ1919-791�2001 9/8/2021 CSJAx.osL �b10, ovu l BF93314C1EE14A9 Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date Dxd919nad by. UAIALSSX f- hi%AA A4.1. DwR/WQRos-RRO/919-791-4232 9/8/2021 "—an 1GE41A8321W Li -A Norm jmv-j tKBv b-u4) vrevlous editions are obsolete. Page# DocuSign Envelope ID: 098EDE31-B6EA 445F-0D1E975F71DF NPDES NCO003425 I11 yr/mo/day Inspection Type 1 2110W18 17 18ICI (Cont.) Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On August 18, 2021 Jason Robinson of the Raleigh Regional Office (RRO) conducted a compliance evaluation inspection of the Duke Energy Roxboro Steam Plant. The assistance provided by Mr. Kevin Clayton (Operator in Responsible Charge (ORC)), Ms. Amber Sarver (Chemistry & Process Safety Management Supervisor & bORC) and Lori Tollie (Permitting and Compliance) was appreciated. The facility is located at 1700 Dunnaway Road in Semora, North Carolina. • NPDES permit NC0003425 was modified and issued for the treatment facilities on August 1, 2021 and expires on June 30, 2025. • The facility has both Grade I Physical/Chemical Water Pollution Control Systems that treat industrial wastewater (numerous Outfalls) and a Grade II Biological Water Pollution Control system with an as -built and permitted flow of 0.025 MGD that treats domestic wastewater (Outfall 008). • The permit authorizes the facility to discharge the treated wastewater through Outfalls 001, 003 and 006, with accompanying monitoring requirements and limits, to receiving waters designated as Hyco Lake, a waterbody classified as WS-V and B waters within the Roanoke River Basin. The permit also authorizes the discharge of numerous internal outfalls, with accompanying monitoring requirements and limits. Finding during the compliance inspection were as follows: 1. The operator's on -site log and supporting documentation was reviewed and found to be complete. 2. The Roxboro Stem Plant's on -site lab is field certified for and self -reports monitoring data for the following parameters (Certification Number 5080): pH, Temperature and Turbidity. Meter calibration logs were reviewed and found to be complete, buffers were within expiration dates, and refrigerator temperature and log was within range. Samples are transported offsite to the Duke Analytical Lab (certification number 248) to analyze additional parameters. A few parameters are sent to be analyzed by a commercial lab. 3. Discharge Monitoring Reports for September 2020 and February 2021 were reviewed and compared to laboratory bench sheets. No discrepancies were noted. Lab results, chain of custody records, and bench sheets were available for review and found to be complete. 4. All outfalls listed in the permit were observed during the inspection. No issues were found. 5. All domestic wastewater is treated by a package treatment plant with chorine disinfection (Internal Outfall 008). The effluent from the package plant goes to the low volume wastewater treatment system. No issues were found. This facility was found to be compliant with NPDES permit conditions as a result of this inspection Page# DocuSign Envelope ID. 098EDE31-66EA 4451`-0D1E975F71DF Permit: NC0003425 Inspection Date: 08/18/2021 Owner -Facility: Roxboro Steam Electric Power Plant Inspection Type: Compliance Evaluation Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? M ❑ ❑ ❑ Does the facility analyze process control parameters. for ex MLSS, MCRT. Settleable 0 ❑ ❑ ❑ 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 M ❑ ❑ ❑ application? Is the facility as described in the permit? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ 0 ❑ ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑ Comment Record Keepinq Yes No NA NE Are records kept and maintained as required by the permit? 0 ❑ ❑ ❑ Is all required information readily available, complete and current? M ❑ ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? M ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? 0 ❑ ❑ ❑ Is the chain -of -custody complete? M ❑ ❑ ❑ 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? M ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? 0 ❑ ❑ ❑ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified M ❑ ❑ ❑ 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? M ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility M ❑ ❑ ❑ classification? Page# 3 I . DocuSign Envelope ID: 098EDE31-86EA 445F-OD1E975F71DF Permit: NC0003425 Owner -Facility: Roxboro Steam Electric Power Plant Inspection Date: 08118/2021 Inspection Type: Compliance Evaluation Record Keepinq Yes No NA NE Is a copy of the current NPDES permit available on site? 0 ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? 0 ❑ ❑ ❑ Comment: Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? 0 ❑ ❑ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? M ❑ ❑ ❑ # Is the facility using a contract lab? N ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 M ❑ ❑ ❑ 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? ❑ ❑ 0 ❑ Comment Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? 0 ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? 0 ❑ ❑ ❑ Comment Page# 4 DUKE ENERGY® PROGRESS File: 12520 Mr. Danny Smith, Director North Carolina Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: Duke Energy Progress, LLC. Roxboro Steam Electric Plant Special Order by Consent (SOC) EMC SOC WQ S18-005 Interim date compliance submittal Dear Mr. Smith: Duke Energy Progress, LLC Roxboro stems Electric Pion, 1700 Dunaway Road Sentora, NC 27143 February 11,2020 NC Dept of Environmental Quality F EB 14 2020 Raleigh Regional Office In accordance with the NC Environmental Management Commission Special Order by Consent, EMC SOC WQ S 18-005, Duke Energy Progress, LLC. hereby submits this notification related to the completion of decanting of the ash basin in accordance with SOC condition 2.b.2. The subject SOC requires decanting completion by June 30, 2020. While no permit has been issued authorizing decanting as of the date of this letter, as discussed previously with Department staff, all wastewater inflows to the West Ash basin were ceased on April 10, 2019. This occurred with the redirection of plant wastewaters to the site's newly constructed Lined Retention Basin treatment system. Since that time, the level of water in the northern section of the ash basin (area north of the internal filter dike) has been reduced significantly. The water level in the basin has equalized across the north and south sides of the internal filter dike at approximately elevation 447' (see attached picture 1). Attached pictures 2 and 3 show the volume of water that has been removed from the ash basin through natural gravity outflow. Based on elevation changes, the basin has been lowered by approximately 90 million gallons of wastewater through the gravity drainage process. The elevation has been lowered approximately 13'. Due to the design of the basin, this is the total amount of water that can be decanted from the basin without allowing water to flow back through the internal filter dike from south to north. Therefore, as discussed with Department staff, decanting is complete. The area will continue to be maintained at this level and no mechanical removal of water will commence prior to NPDES permit receipt. This notice fulfills our reporting obligation found in section 2.) b. of the subject Order. (' DUKE ENERGY. PROG5I5C Duke Energy Progress, LLC Roxboro Steam Electric Plant 1700 Dmmakny Raad Senmm. NC 27343 If you have any questions, please contact Mr. Shannon Langley at (919) 546-2439. I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. 1 am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. Sincerely, Tom Copolo — Plant Manager Roxboro Steam Electric Plant cc: Jeff Poupart NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Scott Vinson, Supervisor Raleigh Regional Office 3800 Barrett Drive Raleigh, NC 27608 (' DUKE ENERGY, PROGRESS bc: Robert Howard Lori Tollie/FileNet — via email Shannon Langley — via email Duke Energy Progress, LLC Roxboro Steam Electric Plant 1700 Dunnawav Road Semora, NC 27343 DUKEDuke Energy Progress, LLC RosboraElectric Plant 40) ENERGY. 1 700 Dunnna v Rmid PROGRESS semorn. NC 27343 Pictures of Roxboro ash basin NC0003425 SOC# WQS 18-05 February 2020 Decanting completion submittal (' DUKE ENERGY,. PROGRESS Picture 1 Water level across internal filter dike Operational level (2016 photo) January 2020 level Duke Energy Progress, LLC Roxboro Steam Electric Plant 1700 Duniumav Rood Semnra. NC 27343 1 It I ENERGY. PROGRESS Picture 2 Ash basin looking North Operational level (2016 photo) January 2020 Level (Gravity decanted) Duke Energy Progress, LLC Roxboro Steam Electric Plant 1700 Dunnanay Road Senana, NC 27343 mi •DUKE ENERGY. PROGRESS Picture 3 Ash basin looking South Operational level (2016 photo) January 2020 level Duke Energy Progress, LLC Roxboro Steam Electric Plant I700 Duruwu'oc Rrwd Senwrtt. NC 27343 ,R Manuel, Vanessa From: Tollie, Lori White <Lori.Tollie@duke-energy.com> Sent: Wednesday, March 25, 2020 8:43 AM To: Manuel, Vanessa Cc: Howard, Robert E; Enoch, Ryan S.; Sarver, Amber Michelle Subject: [External] Roxboro Permit Number NC0003425 Missed sample Vanessa, This email is to summarize our phone call this morning. The Roxboro legacy bioreactor had been out of service due to low wastewater flows going into the FGD Pond with only a single unit being online during the month of February. The bioreactor was put into service on Thursday February 13th, 2020 requiring a weekly sample for Be and Hg to be collected by February 15'. This sample was inadvertently missed. The oversight was discovered during the monthly eDMR review. The February eDMR will be submitted electronically, noted as "Non -Compliant' on the summary submission page. Please let me know if you have any further questions or concerns. Thank you. Duke Energy Permitting & Compliance 2500 Fairfax Road Greensboro, NC 27407 Cell: (336) 408-2591 Office: (336) 854-4916 DEPARTEMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER RESOURCES FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES No. NC0003425 Facility Information Applicant/ FaciliName: Duke Energy Progress/ Roxboro Steam Electric Generating Plant Applicant Address: 1700 Dunnawa • Rd., Semora, NC 27343 Facility Address: 1700 Dunnawa y Rd., Semora, NC 27343 Permitted Flow Not limited Type of Waste: 99.8 % Industrial, 0.2% - domestic Facility/Permit Status: Existing/ Renewal County: Person Miscellaneous Receiving Stream: Hyco Reservoir Stream Classification WS-V, B Subbasin: 03-02-05 303 d Listed?: No Drainage Area mil : N/A Prima SIC Code: 4911 Summer 7Q10 cfs 0 Regional Office: RRO 30Q2 cfs : 0 Quad Olive Hill Average Flow cfs : 0 Permit Writer: Ser ei Chernikov, Ph.D. IWC % : 100% Date: 04/11/2019 Summary The Roxboro Steam Electric Plant is an electric generating facility that uses steam turbine generation via four coal-fired units with a with a combined electric generating output of 2558 MW: Unit No. 1(385 MWe), Unit No. 2 (670 MWe), Unit No. 3 (707MWe) and Unit No. 4 (700 MWe). The facility discharges to subbasin 030205 in the Roanoke River Basin. The facility operates five internal outfalls and two outfalls to Hyco Reservoir. Discharges are mostly industrial, with a very small domestic flow (internal Outfall 008) piped to the on -site ash pond. Discharges from the ash pond (internal Outfall 002), once -through cooling water and FGD treatment system (internal outfall 010) are discharged to the Heated Water Discharge Pond (outfall 003). The Heated Water Discharge Pond and Coal Pile Runoff (outfall 006) both discharge to Hyco Reservoir. The Hyco Reservoir is a 17.6 km2 waterbody constructed in 1963 by CP&L to serve as a cooling water source. The receiving waterbody is class WS-V; B. The facility is located in the Lower Piedmont area of the state, the applicable state water quality temperature standard is 32'C (89.6' F). This facility is subject to EPA effluent guideline limits per 40 CFR 423 - Steam Electric Power Generating Point Source Category which were amended November 3, 2015. The facility is also subject to the Cooling Water Intake Structures Rules (40 CFR 125) effective October 14, 2014. The intake flow is > 125 MGD. Duke requested the addition of three new outfalls on the permit; two to reflect the future treatment systems for the low volume wastes as the ash basin will be closed and one for the overflow from the east ash basin extension and stormwater runoff. Description of existing outfalls: Outfall 003 - Heated Water Discharge Pond to Hyco Reservoir. This pond combines all internal outfalls (002, 005, 008, 009, 010) before discharging to Hyco Reservoir. In addition, once -through cooling water from condensers for units 1, 2, and 3, once -through cooling water from heat exchangers, seepage from ash pond, and stormwater runoff from plant drainage areas are discharged to the discharge pond. NPDES PERMIT FACT SHEET Roxboro Steam Electric Plant Page 2 NPDES No. NC00003425 Outfall 006 - Coal Pile Runoff discharges directly to Hyco Reservoir. Coal pile runoff wastewaters include runoff from the coal pile, limestone pile and gypsum pile, truck wheel wash area and coal handling areas. Treatment is accomplished by neutralization, sedimentation and equalization. This is an episodic discharge. Internal Outfall 002 - Ash Pond discharging to the heated water discharge pond. The ash pond receives wastewater from the following source: • Bottom ash transport waters • Silo wash water • Ash landfill leachate and runoff (this landfill receives CCR from Mayo and Roxboro plants) • Dry -ash handling system wash water • Blowdown from Unit 4 cooling tower • Coal mill rejects and pyrites • Sewage treatment plant effluent • Low volume waste consisting of boiler blowdown, equipment maintenance cleaning wastewaters, RO reject wastewater and floor drains. Low volume wastes are treated by neutralization. • Emergency overflow from FGD system blowdown Internal Outfall 005 - Cooling tower blowdown from Unit 4. Internal Outfall 008 - Treated domestic wastewater. The treatment system consists of a screen, communitor, surge tank, aeration tank, clarifier, chlorine contact chamber and sludge holding tank. A new package plant will be installed to replace the existing plant. Internal Outfall 009 - Chemical metal cleaning waste. Wastewaters from cleaning of the boilers is generated every five to eight years. Every three to five years wastewaters are generated from cleaning the heat exchangers. The wastewaters generated can be treated by evaporation or by neutralization and precipitation. Internal Outfall 010 - Flue Gas Desulfurization (FGD) treatment system discharging to the discharge canal. The scrubber system removes SOx by mixing flue gas with a limestone slurry. The blowdown from the scrubber is discharged to a gypsum settling pond system then to a bioreactor which utilizes microorganisms to reduce soluble contaminants to insoluble forms (under anaerobic conditions) that then precipitate from solution. Wastewater is discharged to the ash pond effluent channel. An emergency overflow from the FGD system blowdown discharges to the ash pond. Proposed Outfalls: Outfall 001- Stormwater and the oveflow from the east ash basin extension. The east ash basin was closed and subsequently a landfill was built over the old basin. A portion of the basin remained as an open pond. It has come to the attention of the Division that there are some coal combustion residuals within the pond. The Division has requested that Duke removes the residuals. In addition to the pond overflow this outfall discharges stormwater runoff. Internal Outfalls 012A, 012B and 012C - Low volume waste and other wastewaters. Duke will build two basin treatment systems to treat wastewaters that now go to the ash basin. The basins will discharge to the heated discharge pond and an emergency overflow from one of the basins will discharge to Hyco Lake (012C). NPDES PERMIT FACT SHEET Roxboro Steam Electric Plant Page 3 NPDES No. NC00003425 CWA 316 (b) The permittee shall comply with the Cooling Water Intake Structure Rule per 40 CFR 125.95. The Division approved the facility request for an alternative schedule in accordance with 40 CFR 125.95(a)(2). The permittee shall submit all the materials required by the Rule by May 31, 2022. This is an accelerated schedule that includes: I year for the development of the sampling plan and obtaining approval from the Division, 2 years of sampling to adequately characterize seasonal variation, and 1 year for the report development Based on the results of the studies, the Division may require an implementation of the additional measures to reduce impingement and entrainment of the aquatic organisms. The facility's total intake is designed for approximately 1,114 MGD. Units No.1 and 2 use condensers as cooling devices. Units No. 3 and 4 use cooling towers as cooling devices. Units 1 and 2 operate in a once - through cooling mode year round. Unit 3 operates in a once -through cooling mode part of the year (October 15th - April 30th) and during summer months (May 1st - October 14th) condenser cooling water is routed to once -though mechanical draft cooling tower. Unit 4 is equipped with closed -cycle evaporative cooling towers that operate year-round. The CWIS for Unit 4 (CWIS 4) is located on the north bank of the heated water discharge pond, adjacent to the Unit 4 closed -cycle cooling tower. As a result, there is no net increase in cooling water withdrawal for the Unit 4 cooling tower make-up water. The CWiS for Units 1-3 (CWIS 1) is located at the intake forebay immediately east of the Unit 1 turbine - generator. Cooling water for Units 1-3 is withdrawn through eight bays in CWIS 1 via a 1.7-mile intake canal located east north-east of the plant The intake canal directs water to an intake pond which is connected to the CWIS 1 intake forebay area via a submerged culvert. Unit 1 consists of two intake bays equipped with one circulating water pump per bay. Units 2 and 3 each consist of three intake bays equipped with one circulating water pump per bay. Each of the eight intake bays for CWIS 1 is equipped with trash racks and coarse -mesh (3/8-inch mesh size) vertical traveling screens with a debris spray wash system and debris collection trough. Duke Enerev provided the following iustification as Basis for Designation Belews Station as a Closed Cycle Recirculation System: A "closed -cycle recirculating system' is defined at 40 CFR 125.92 (c). The definition addresses facilities with CCRS that withdraw from waters of the United States where the impoundment was constructed for the purpose of providing cooling water for the facility: "Closed -cycle recirculating system also includes a system with impoundments of waters of the U.S. where the impoundment was constructed prior to October 14, 2014 and created for the purpose of serving as part of the cooling water system as documented in the project purpose statement for any required Clean Water Act section 404 permit obtained to construct the impoundment. In the case of an impoundment whose construction pre -dated the CWA requirement to obtain a section 404 permit, documentation of the project's purpose must be demonstrated to the satisfaction of the Director. This documentation could be some other license or permit obtained to lawfully construct the impoundment for the purposes of a cooling water system, or other such evidence as the Director finds necessary." 40 CFR 125.92 (c)(2). Impoundments are further defined and discussed as a dosed -cycle cooling system in the rule's preamble, stating that "Impoundments are surface waterbodies that serve as both a source of cooling water and a heat sink. As with cooling towers, impoundments rely on evaporative cooling to dissipate the waste heat; a facility withdraws water from one part of the impoundment and then discharges the heated effluent back to the impoundment, NPDES PERMIT FACT SHEET Page 4 Roxboro Steam Electric Plant NPDES No.NC00003425 usually in another location to allow the heated water time to cool. Depending on local hydrology, impoundments may also require makeup water from another waterbody. Impoundments can be man-made or natural, and can be offset from other water bodies or as part of a "run of the river" system (the latter are sometimes referred to as cooling lakes)." 79 Fed. Reg. 48,334 (August 15, 2014) The system at Roxboro meets the criteria for classification as a CCRS. Roxboro withdraws cooling water from Hyco Lake which was constructed in a water of the United States for the purpose of providing cooling water for the Carolina Power & Light Company (now Duke Progress, LLC) Roxboro Steam Electric Plant prior to the Clean Water Act 404 permitting program. The Carolina Power & Light Company received authorization for the creation of Hyco Lake in April 1964 for the Roxboro facility. Numerous documents issued by the State contain several statements and commensurate justification that the purpose of Hyco Lake was to be "operated ... to reduce pollution [via condenser cooling water recirculation] in the Hyco River' and is a "cooling pond": • State of North Carolina Department of Water and Air Resources Permit 522 issued May 4, 1964 • Carolina Power & Light Company, North Carolina State Stream Sanitation Committee "Application for Approval of Plans" dated April 13,1964 • North Carolina Board of Water and Air Resources Permit 522 Certification dated October 1,1971 North Carolina Environmental Management Commission Permit 2523 issued July 22,1974 The permit issued by the State of North Carolina Department of Water and Air Resources (the predecessor Agency to the North Carolina Department of Environmental Quality) authorized ...operation of a 3,800 acre cooling lake for a design flow of 2,400,000,000 G.P.D., and the discharge of the effluent into the Hyco River, a tributary in the Roanoke River Basin". The dam was completed in 1964 and Hyco Lake reached full pool elevation in 1965. As also required by the definition, make-up water withdrawals attributable to the cooling portion of the Roxboro cooling system have been minimized. The source of all makeup water is the approximately 300 square mile Hyco lake watershed. No other sources of makeup water are currently available and none are planned. In addition to minimizing withdrawals for make up water to Hyco Lake, Roxboro also minimizes cooling water withdrawals from Hyco Lake in multiple ways. First, Unit 4 operates on recirculating cooling towers that require only small volumes of makeup waters. Those make up waters are taken from internal process areas consisting of Unit 1-3 cooling water discharge and the ash basin discharge flows. Second, the cooling water system for Units 1-3 has several design features that increase their efficiency, including (a) directing deeper, cooler water to the intake as needed to maintain efficiency by using cooler water from deeper in the reservoir; (b) routing of cooling water discharges as far as possible upstream from the cooling water intake (subject to constraints imposed by the Department for thermal impact reasons); and (c) utilization on Unit 3 of a helper cooling tower seasonally which reduces the thermal discharge load to the lake and allows for more efficient cooling during the summer months. Third, as reflected in the company's Integrated Resources Plans, filed with the North Carolina Utilities Commission, Roxboro has operated since 2016 as an "Intermediate" rather than "Baseload" generation source. The reduction in operating time has resulted in a reduction of average daily withdrawals from greater than 800 MGD when the plant operated as Baseload to 592 MGD in 2018, as reported in the station's annual water withdrawal reports. 4 NPDES PERMIT FACT SHEET Roxboro Steam Electric Plant Page 5 NPDES No. NC00003425 The Division concurs with the justification provided by Duke on a provisional basis. Based on 40 CFR 125.92 (c) the Director has determined that operating and maintaining the existing closed - cycle recirculating system meets the requirements for a provisional BTA. The final determination will be made upon review of the materials submitted by the permittee. This determination is consistent with the EPA Region W decision regarding Robinson station and Belews station, and the EPA Region III decision regarding North Anna station. Temperature Mixing Zone - Outfall 003 The facility is located in the Lower Piedmont area of the state, the applicable state water quality temperature standard is 32°C (89.6° F). The authorized temperature mixing zone for outfall 003 includes the North Hyco Arm downstream of NC Hwy 57, the main body of Hyco Reservoir downstream of the confluence of the Cobbs Creek Ann and the North Hyco Arm and the entire after bay lake. USGS data at the after bay monitoring station (USGS Station 02077303) was reviewed for the period of January 2011 to April 2016. Data shows that the temperature water quality standard was not exceeded for this period. Maximum temperature recorded was 305C. Instream Monitorine The permit requires monitoring of Hyco Reservoir in accordance to the Biological Monitoring Program as approved by the Division. Based on the Divisions review of the reports the fish community is comparable to other piedmont reservoirs and no problems were noted. The draft permit includes instream monitoring for total arsenic, total selenium, total mercury, total chromium, dissolved lead, dissolved cadmium, dissolved copper, dissolved zinc, total bromide, total hardness (as CaCO3), turbidity, and total dissolved solids (TDS). The draft permit also includes annual fish tissue monitoring. DATA REVIEWPERMIT REQUIREMENTS Internal Outfall 002 - Ash Pond This outfall is subject to the Effluent Limitations Guidelines (ELG) in Table 1. Table 1. ELG Outfall 002 (Prior to November 1, 2018) Pollutant Daily Maximum Monthly Average ELG TSS 100 m /L 30 mg/ L 40 CFR 423.12 4 Oil & Grease 20 m / L 15 mg/ L 40 CFR 423.12 4 The current permit requires monitoring for flow and total selenium, limits for Oil & Grease and TSS. A summary of DMR data for the period of January 2011 to January 2016 is included in Table 2. There have been no violations of permit limits or conditions. Table 2. DMR Summary Outfall 002 Parameter Average Maximum Minimum Flow 10.8 MGD 48.3 MGD 3.1 MGD TSS 5m /L 21m /L <2.5mg/ L Total Selenium 14.6 µ /L 68.8 µ /L < 10 µ /L O&G <5m L 13.5m /I <5m L Table 3. Monitoring Requirements/Proposed Changes Outfall 002 Parameter Monitoring requirements Chan s Basis Flow Monitor No chan es 15A NCAC 2B.0505 TSS 30 mg/L monthly aver 100 m /L daily max No changes 40 CFR 423.12(b)(4) NPDES PERMIT FACT SHEET Page 6 Roxboro Steam Electric Plant NPDES No.NC00003425 Oil & Grease 15 mg/L monthly aver No Changes 40 CFR 423.12(b)(4) 20 m /L daily max Total Selenium Monthly monitoring No changes Pollutant of concern Turbidity, pH No requirement Monitor Pollutant of concern for dewatering/decanting Schedule of Compliance Fly Ash/Bottom Ash: As per 40 CFR 423.13 (k) (1) (i) bottom ash transport water shall not be discharged, compliance with this section shall be as soon as possible beginning on November 1, 2020, but no later than December 31, 2023. Duke utilizes wet bottom ash transport system. Duke is proposing to install a remote mechanical drag chain system. Design of the system is expected to be completed in 8 months, followed by procurement in 12 months. Construction is expected to be completed in 13 months. Duke proposes a 16 month window to optimize the system at full load and additional 6 months for potential permitting delays. Consideration was given to the fact that Duke will be undertaking design, procurement and installation activities in multiple facilities simultaneously. Duke will meet the no discharge of bottom ash requirement by April 30, 2021. Fly ash transport water is no longer discharged therefore Duke meets the compliance date of November 1, 2018. Internal Outfall 002 - Dewaterine To meet the requirements of the Coal Ash Management Act of 2014, the facility needs to dewater two ash ponds by removing the interstitial water and excavate the ash to deposit it in landfills. The facility's highest discharge rate from the dewatering process will be 2 MGD. The facility submitted data for the standing surface water in the ash ponds, interstitial water in the ash, and interstitial ash water that was treated by filters of various sizes. The following pollutants were detected at concentrations higher than the water quality standards: selenium, arsenic and molybdenum. A new effluent and monitoring sheet is included in the permit for the ash pond dewatering phase. As this is an internal outfall the water quality standards are not applied. Monitoring will be required for selenium, arsenic, molybdenum, antimony, mercury and copper. Outfall 003 - Heated Water Discharge Pond (Combined outfalls) DMR/Compliance Review Data were reviewed for the period of January 2011 to March 2016. There have been no violations of permit limits or conditions. Table 4. DMR Summary Outfall 003 Parameter Average Maximum Minimum Flow MGD 840 1130 6.9 TRC Not discharged TP m /L < 0.036 < 0.05 < 0.05 TN m L 0.68 1.08 0.44 Temperature 29 41 130C Total Arsenic µ L 6.2 17.1 < 2.8 H SU 7.34 8 6.38 Toxicity Testing (003): Current Requirement Acute P/F at 90%, February, May, August, November. Proposed Requirement: Acute P/F at 90%, February, May, August, November. The facility passed 21 tests out of 21 tests performed for the period of January 2011 to January 2016. NPDES PERMIT FACT SHEET Roxboro Steam Electric Plant Page 7 NPDES No. NC00003425 Reasonable Potential Analysis Outfall 003: The Division conducted EPA -recommended analyses to determine the reasonable potential for toxicants to be discharged at levels exceeding water quality standards/EPA criteria by this facility from outfall 003. For the purposes of the RPA, the background concentrations for all parameters were assumed to be below detection level. The RPA uses 95% probability level and 95% confidence basis in accordance with the EPA Guidance entitled "Technical Support Document for Water Quality -based Toxics Control." With the approval of the Triennial Review (2007-2014) of the NC Water Quality Standards by the Environmental Management Commission (EMC) in 2014 and US -EPA (with some exceptions) on April 6, 2016, the NPDES Permitting Unit is required to implement the new dissolved metal standards in all permits public noticed after April 6, 2016. The RPA included evaluation of dissolved metals' standards, utilizing measured hardness value of 100 mg/L CaCO3 for hardness -dependent metals. A reasonable potential analysis was conducted for arsenic, copper, nickel, selenium, strontium, thallium, chlorides and zinc. Arsenic data used for the RPA was collected between 2011 and 2016. Data for the remaining parameters was from a special study for the period of March 2010 to August 2011. Based on this analysis, the following permitting actions are proposed for this permit • Monitoring Only. The following parameters will receive a monitor -only requirement since they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria, but the maximum predicted concentration was >50% of the allowable concentration: Arsenic, selenium, chloride. • No Limit or Monitoring: The following parameters will not receive a limit or monitoring, since they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria and the maximum predicted concentration was <50% of the allowable concentration: copper, nickel, strontium, and zinc. Mercury Evaluation Outfall 003: A mercury evaluation was conducted in accordance with the permitting guidance developed for the implementation of the statewide Mercury TMDL to determine the need for a limit and Mercury Minimization Plan (MMP). Monitoring for mercury is not required for outfall 003 but mercury data was collected during a special study during the period of March 2010 to August 2011. The water quality based effluent limitation (WQBEL) for mercury is 12 ng/1. The technology based effluent limit (TBEL) is 47 ng/1. None of the annual averages exceeds the WQBEL or TBEL, no limit is required. See the attached mercury evaluation spreadsheet Table 5. Mercury Evaluation 2010 2011 # of Samples 20 16 Annual Average, n /L 3.6 4.4 Maximum Value, n L 7.63 6.92 TBEL, n /L 47 WQBEL, n /L 12.0 Table 6. Monitoring Reauirements/Proposed Changes Outfall 003 Parameter Monitoring Changes Basis reguirement5Limits Flow Monitor I No changes I 15A NCAC 2B.0505 NPDES PERMIT FACT SHEET Page 8 Roxboro Steam Electric Plant NPDES No. NC00003425 TRC 200 µg/L Modified limit to State WQ standards, 15A NCAC instantaneous max 28 µg/ L daily max 2B .0200. The water quality standard is more stringent than the effluent guidefines limit. TP Monitor No changes 15A NCAC 2B .0500 TN Monitor No changes 15A NCAC 2B .0500 Temperature Monitor No changes A roved Mixing zone Total Arsenic Monitor No changes Based on results from RPA, Predicted concentration greater than 50% of allowable. Total Selenium No requirement Quarterly monitoring Based on results from RPA, Predicted concentration greater than 50% of allowable. Total Thallium No r ement Quarterly monitoring Pollutant of concern. Chloride No requirement Quarterly monitoring Based on results from RPA, Predicted concentration greater than 50% of allowable. PH 6 to 9 SU No changes State WQ standards, 15A NCAC 2B .0200 Acute toxicity P/F 90% No changes State WQ standards, 15A NCAC 2B .0200 Internal Outfall 005 - Cooling Tower Blowdown from Unit 4 This outfall is subject to the ELGs in Table 7. Table 7. ELG Outfall 005 Free Available Chlorine Daily Maximum 0.5 mg/L Monthl Aver a 0.2 mg/L ELG 40 CFR 423.12 (d) (1) 126 Pollutants No detectable amounts 40 CFR 423.13 d 1 Total Chromium 0.2 m /L 0.2 m /L 40 CFR 423.13 d 1 Total Zinc 1.0 m /L 1.0 m /L 40 CFR 423.13 d 1 The permit includes monitoring for flow and Total Residual Chlorine (TRC), limits for Free Available Chlorine, Total Chromium, Total Zinc and 126 priority pollutants. Special condition A. (14) in the current permit doesn't allow the discharge of the cooling tower blowdown to the discharge pond, it has to be discharged to the ash pond. With the modifications planned to the site and the future closure of the existing ash pond Duke will like to have the option to discharge the blowdown to the discharge pond. This will continue to be an internal outfall subject to the same limits under 40 CFR 423. The limits apply before it comingles with any other waste stream so there is no change in limits or other permit conditions by allowing the cooling tower blowdown to discharge into the discharge pond. DMR/Compliance Review: Data were reviewed for the period of January 2011 to January 2016. There have been no violations of permit limits or conditions. Flow was the only parameter monitored at this outfall since the facility did not chlorinate or added chromium or zinc for maintenance activities. Flow is reported as 7.2 MGD on a daily basis. NPDES PERMIT FACT SHEET Page 9 Table 8. MonitoringRe uirements/ Proposed Changes Outfall 005 Roxboro Steam Electric Plant NPDES No. NC00003425 Parameter Monitoring Changes Basis RequirementWLimits Flow Monitor No changes 15A NCAC 2B.0505 Free available 500 µg/L daily max No changes 40 CFR 423.13 (d)(1) chlorine 200 µ /L monthlyaverage Total Residual Monitoring No changes 40 CFR 423.13 (d)(2) Chlorine Total chromium 200 µg/L daily max No changes 40 CFR 423.13 (d)(1) 200 µ L monthly average Total Zinc 1.0 mg/L daily max No changes 40 CFR 423.13 (d)(1) 1.0 mL monthlyaverage The 126 priority No detectable amount No changes 40 CFR 423.13 (d)(1) pollutants Outfall 006 - Coal Pile Runoff This outfall is subject to the ELG in Table 9. Table 9. ELG Outfall 006 Pollutant Daily MiMum Monthly Average ELG TSS 50 m / L 40 CFR 423.12 b 9 H 6 to 9 SU 40 CFR 423.12 b l DMR/Compliance Review: Data were reviewed for the period of January 2008 to March 2013. There have been no violations of permit limits or conditions. Table 10. DMR Summary Outfall 006 Parameter Average Maximum Minimum Flow MGD 0.23 0.05 0.002 TSS m / L 2.6 76.6 < 2.5 H SU 7.39 8.9 6.04 Priority Pollutant Scan: The application included the results of one scan. Selenium was detected above the water quality standard. This is an episodic discharge. The pond only discharges under heavy rain events, therefore limits will be applied as acute limits. Table 11. Monitoring Requirements/Proposed Changes Outfall 006 Parameter Monitoring Changes Basis requirements/Limits Flow Monitor No changes 15A NCAC 2B .05 TSS 50 mg/L instantaneous No changes 40 CFR 423.12(b)(9) max H 6 to 9 SU No changes 40 CFR 423.12 1 Total selenium No requirement 56 Mg L Daily Max RPA State WQ standards, 15A Acute toxicity P/F 90% No changes NCAC 2B .0200 NPDES PERMIT FACT SHEET Page 10 Internal Outfall 008 - Domestic W WTP Table 12. DMR Review Outfall 008 Roxboro Steam Electric Plant NPDES No. NC00003425 Parameter Average Maximum Minimum Flow MGD 0.007 0.01 0.002 TSS m /I 14.7 30 5 H S 6.8 7.3 6.5 BOD m /L 10.4 28 2.1 NH3N m /L 0.8 1.6 <0.1 Table 13. Monitoring Requirements/Proposed Chances Outfall 008 Parameter Monitoring Changes Basis requirements imits Flow 0.015 MGD 0.025 MGD W WTP was upgraded TSS 30 mg/ L monthly No changes NPDES rules for secondary aver treatment of domestic 45 mg/ L daily max wastewater,15A 2B .0400 pH 6 to 9 SU No changes State WQ standards,15A 2B 0200 BOD 30 mg/ L monthly No changes NPDES rules for secondary aver treatment of domestic 45 mg/ L daily max wastewater,15A 2B .0400 Total ammonia Monitor No changes DWQ Policy Internal Outfall 009 - Chemical cleaning waste Table 14. Monitoring Requirements/ Proposed Changes Outfall 009 Parameter Monitoring Changes Basis requirements/Limits Flow Monitor No changes 15A NCAC 26.0505 Total Copper 1.0 mg/ L monthly aver No changes 40 CFR 423.13 (e) 1.0 m /L daily max Total Iron 1.0 mg/L monthly aver No changes 40 CFR 423.13 (e) 1.0 m L dail max TSS 30 mg/L monthly aver No changes 40 CFR 423.13 (e) 100 m / L dail max Oil & Grease 15 mg/L monthly aver No changes 40 CFR 423.13 (e) 20 m / L dail max Internal Outfall 010 - FGD This outfall is subject to the Effluent Limitations Guidelines (ELG) in Table 15. These are new limitations promulgated November 3, 2015. Table 15. ELG Outfall 010 Pollutant `'"'' "" Daily`Maximum I Monthly Average ELG H 6to9SU 40CFR 423.12 1 TSS 100 m L 30 m L 40 CFR 423.12 11 Oil and grease 20 mg/ L 15 m /L 40 CFR 423.12 11 Total Arsenic 11 µ /L 8 µ /L 40 CFR 423.13 1 i Total Mercury 788 n L 356 n L 40 CFR 423.13 l i Total Selenium 23 µ /L 12 µ L 40 CFR 423.13 1 i Nitrate/nitrite 17 mg/ L 4.4 mg/ L 40 CFR 423.13 1 i 10 NPDES PERMIT FACT SHEET Page I 1 Roxboro Steam Electric Plant NPDES NO. NCO0O03425 The current permit includes monitoring for flow, total beryllium, total mercury, total antimony, total selenium, total silver and total vanadium. Table 16 includes a summary of DMR data for the period of January 2011 to January 2016. There have been no violations of permit limits or conditions. Table 16. DMR Summary 0utfa11010 Parameter Average Maximum Minimum Flow MGD 0.84 1.77 0.01 Total Beryllium µ /L 3.9 10 < 1 Total Mercury µ L 1.08 9.6 < 1 Total Selenium µ /L 102 712 < 50 Total Silver µ / L 6 8.4 < 5 Total Antimon µ L 31 70 < 25 Total Vanadium µ / L < 25 < 25 < 5 Table 17. Monitorine Requirements/Proposed Chances Outfall 010 Parameter Monitoring requirements/Limits Changes Basis Flow Monitor No changes 15A NCAC 2B.0505 Total Beryllium Monitor Remove monitoring Internal outfall, not a parameter of concern. Total Vanadium Monitor Remove monitoring Internal outfall, not a arameter of concern. Total Antimony Monitor Remove monitoring Internal outfall, not a parameter of concern. Total Silver Monitor Remove monitoring Internal outfall, not a arameter of concern. Total Arsenic No monitoring 11 µg/ L daily max and 8 µg/L monthly 40 CFR 423.13 (g) (1) (f) average Total Selenium Monitor 23 µg/L daily max and 12 µg/ L monthly 40 CFR 423.13 (g) (1) (1) average Nitrate/Nitrite No monitoring 17 mg/L daily max and 4.4 mg/L monthly 40 CFR 423.13 (g) (1) (i) average Total Mercury Monitoring 788 ng/L daily max and 356 ng/ L monthly 40 CFR 423.13 (g) (1) (i) average. Schedule of Compliance FGD: 40 CFR 423 establishes compliance dates for the new limitations. Permittee must meet limits as soon as possible beginning on November 1, 2020 but no later than December 31, 2023. Duke utilizes a biological treatment system to treat FGD wastewaters. Duke anticipates that it will be required to install physical/chemical treatment followed by selenium reduction technology to meet the FGD guidelines. Evaluation of new technologies, design, and siting of the system is expected to take 30 months. The evaluation phase includes evaluation of existing treatment system, flow optimization, siting of the new system within the plant, selection of technology and permitting. Procurement is expected to be completed in 20 months, construction and tie-in expected to be completed in 16 months considering that tie-in has to be done during outages. Startup and optimization under all expected operating conditions is estimated for 15 months. An additional 6 months is included in the schedule for potential permitting delays. Duke will meet the FGD ELG by December 31, 2021. As the new treatment system will be placed NPDES PERMIT FACT SHEET Roxboro Steam Electric Plant Page 12 NPDES No. NC00003425 in operation and the old pond may still discharge until it is decommissioned a new outfall is included in the permit for the new system. Provosed Outfalls Requirements: Outfall 001 RPA: An RPA was conducted for proposed outfall 001. RPA was conducted for total arsenic, cadmium, chlorides, total chromium, total copper, total lead, total mercury, total molybdenum, total nickel, selenium, total zinc, antimony, sulfate and total thallium. As a result of the RPA limits are required for the following parameters: arsenic, fluoride, sulfides and selenium. Mercury Mercury data was collected during 2014 and 2015.2014 data was collected using method 245 which has a higher detection limit that 1631. Data for 2015 was used to evaluate a need for a limit. The annual average was 5.2 ng/1, no limit will be implemented. Table 18. Outfall 001 Proposed Limits/Monitorine: Parameter Monitoring requirementWLimits Basis Flow Monitor 15A NCAC 213.0505 pH 6 to 9 SU State WQ standards,15A 213.0200 Total arsenic, total copper, total Monitor Coal ash parameters of concern. antimony, total lead, total zinc, total barium, total iron, total manganese, total nickel, total mercury, and chlorides Total Selenium 5 µg/L Monthly Average RPA 56 µg/L Daily Max Total Arsenic 10 µg/L Monthly Average RPA 340 µg/L Daily Max Fluoride 1.8 mg/L Monthly Average RPA 1.8 mg/ L Daily Max Sulfates 250 mg/L Monthly Average RPA 250 mg/L Daily Max TDS, Hardness, Conductivity Monitor Parameters of concern Acute toxicity Quarterly Limit State WQ standards,15A NCAC 2B .0200 Low Volume Waste Treatment System: Two new treatment systems will be installed to treat wastewaters currently delivered to the ash basin. Low volume wastes, metal cleaning wastes, stormwater, and other miscellaneous wastes that are routed to the ash basin will be rerouted to new treatment systems. Duke proposes two separate treatment systems. The new outfalls will be designated as outfall 012A and outfall 012B. The overflow from the 012B basin will be designated as outfall 012C. Duke estimated that design, construction and start up of the new treatment system will be completed within 30 months of permit issuance. 12 NPDES PERMIT FACT SHEET Roxboro Steam Electric Plant Page 13 NPDES No. NC00003425 Internal Outfall 012A - treatment system for the landfill stormwater, treated extracted groundwater, contact and non -contact storm water and discharging to the discharge pond. Table 19.Outfall 012A Proposed Limits/Monitoring: Parameter Monitoring Basis requirements/Limits Flow Monitor 15A NCAC 213.0505 Total Suspended Solids 30 mg/L Monthly Average 40 CFR 423.12 (b)(3) 100 m /L Daily Max Oil & Grease 15 mg/L Monthly Average 40 CFR 423.12 (b)(3) 20 m /L Daily max Total arsenic, total selenium, total Monitor during ash basin Parameters of concern mercury, total molybdenum, total closure antimony, total copper Internal Outfall 012B - treatment system for plant low volume wastes, FGD treatment system effluent, domestic waste treatment system, anhydrous ammonia emergency discharge, metal cleaning wastes, stormwater runoff, and cooling tower blowdown. The discharge from outfall 012B will go to the discharge canal. Table 20. Outfall 012E Proposed Limits/Monitoring: Parameter Monitoring requirements/Limits Basis Flow Monitor 15A NCAC 2B.0505 Total Suspended Solids 30 mg/L Monthly Average 100 m L Daily Max 40 CFR 423.12 (b)(3) Oil & Grease 15 mg/L Monthly Average 20 m L Daily max 40 CFR 423.12 (b)(3) Ammonia Monitor Monitor during emergency discharge of anhydrous ammonia Emergency Outfall 012C - This is the emergency overflow from the low volume waste treatment system (Outfall 012B) Table 21. Outfall 012C Proposed Limits/Monitoring: Parameter Monitoring requirements/Limits Basis Flow Monitor 15A NCAC 213.0505 Total Suspended Solids 30 mg/L Monthly Average 100 m L Daily Max 40 CFR 423.12 (b)(3) Oil & Grease 15 mg/L Monthly Average 20 mg /L Daily max 40 CFR 423.12 (b)(3) Ammonia 1.0 mg/L Monthly average 5.0 mg/L Daily max Monitor during emergency discharge of anhydrous ammonia Arsenic Monitor Parameter of concern Mercury Monitor Parameter of concern Selenium Monitor Parameter of concern Nitrate/ nitrite Monitor Parameter of concern Copper Monitor Parameter of concern Iron Monitor Parameter of concern 13 NPDES PERMIT FACT SHEET Page 14 Public Notice/Public Hearing Roxboro Steam Electric Plant NPDES No. NCO0003425 The first draft of this permit was public noticed on August 30, 2016. A public hearing was held on October 4, 2016. A second public notice was done on January 21, 2017 since the first notice went to a newspaper out of the area. Summary of permit modifications: • A separate effluent page for the dewatering of the ash ponds (Outfall 002) was added to the permit. • Outfall 001 was reinstated to monitor discharge of seeps and stormwater. • A new internal outfall (Outfall 011) was added to the permit to monitor the discharge from the proposed FGD treatment system. • Special Condition A. (14) that prohibited the discharge of cooling tower blowdown from outfall 005 to the discharge canal was eliminated from the permit. • A special condition was added to describe Section 316(b) requirements for submittal of applicable information. • A special condition was added to the permit to require an Ash Pond Closure Plan. • A Special Condition was added to the permit to require compliance with Senate Bill 729 (Coal Ash Management Act). • Attachment 1 entitled "Groundwater Monitoring Plan" was added to the permit. • Attachment 2 entitled "Plan for Identification of New Discharges" was added to the permit. Summary of modifications to October 2016 permit: • Condition A. (1) Effluent Limitations and Monitoring Requirements for seeps - monitoring requirements were updated to include the same list of parameters monitored for seeps in other Duke permits. • Condition A. (2) Effluent Limitations and Monitoring Requirements for the ash basin - monitoring was added for arsenic, molybdenum, and chromium. In addition, a statement was added with the requirement to use physical/chemical treatment during dewatering. • Condition A. (2) & A. (3) Effluent Limitations and Monitoring Requirements for the ash basin - Statement regarding no discharge of fly ash was modified to read that no discharge of fly ash is allowed. The statement pertaining to the schedule of compliance with the ELG for zero discharge of bottom ash was corrected to read April 30, 2021 instead of November 1, 2018. • Condition A. (10) & A. (11) Effluent Limitations and Monitoring Requirements for the FGD - footnote 3 was corrected to read December 31, 2023. • Turbidity sampling was eliminated from internal outfall 002. Turbidity monitoring is included at outfall 003. • Supplement to cover sheet was modified to include flows that were not listed and add proposed outfalls and outfalls. • Condition A. (6) Effluent Limitations and Monitoring Requirements outfall 006: o Oil and Grease limits were added since it receives truck wash waters. o The RPA was revised and limits for total selenium were added. • Condition A. (4) Effluent Limitations and Monitoring Requirements for outfall 003: o Footnote 4 was modified to include a statement regarding the addition of temperature limits if the facility is not in compliance with the temperature water quality standard. o Reporting of the temperature at the afterbay station was added to the monitoring requirements for outfall 003, reporting of temperature at 4C, 41) was eliminated. o The RPA was revised and limits for thallium were added. • Condition A. (17)- temperature reporting requirements were modified. 14 NPDES PERMIT FACT SHEET Page 15 Roxboro Steam Electric Plant NPDES NO. NC00003425 • A. (8) Effluent Limitations and Monitoring Requirements for outfall 008 - monitoring requirements were modified to require quarterly monitoring for one year after the new plant start operations, annual monitoring is required after one year of quarterly monitoring. • Two new internal outfalls (Outfall 012A and 012B) were added to the permit for the two proposed retention basins for the treatment of low volume wastes that are now sent to the ash basin. Duke will build two separate wastewater treatment systems to handle the wastes that go to the ash pond. These ponds will be in different locations in the site and will require each a separate outfall into the effluent channel. • Outfall 012C was added to the permit for the emergency overflow of the proposed lined retention basin discharging through outfall 012B. • A table including a list of all the seeps locations was added to Condition A. (14). Modifications to January 2017 draft permit: • Seeps special condition was eliminated. Seeps will be addresses through Special Order by Consent EMC SOC WQ 518-005. • The groundwater monitoring well construction and sampling condition was eliminated from the permit. • A footnote was added to outfalls 001 and 003 that requires that the discharge from the decanting/dewatering operations is discontinued if any of the identified pollutants reaches 85% of the allowable concentrations. • Requirements for Outfall 001 were modified. The outfall location was established at the OF to Hyco Lake. Monitoring was increased to weekly during the removal of the asKfrom the east ash basin extension. • RPA for outfall 003 was revised using updated thallium criteria. As a result of the RPA no limit for thallium is necessary. • Monitoring frequency for arsenic, selenium and mercury at outfall 003 was increased to weekly during dewatering. • The note for outfall 002 that contained the requirement to use physical -chemical treatment during decanting and dewatering was modified. The installation of physical/chemical treatment is not required unless necessary to meet the water quality standards. • Outfall 006 requirements were modified to reflect the nature of the discharge. This pond discharge is episodic, it only discharges if there is a heavy rain event, therefore limits were implemented as daily maximums. • pH limits were eliminated from internal outfalls. • The flow page for 0.15 MGD for the domestic treatment system (outfatl 008) was eliminated since the W WTP was upgraded to 0.25 MGD. • Monitoring for arsenic, mercury, antimony, copper, molybdenum and selenium were added to Outfall 012A due to the contribution from ash basin closure flows and treated groundwater. • The schedule of compliance to meet FGD ELG limits was modified to December 31, 2021. • The Groundwater Monitoring Well Construction and Sampling condition was eliminated. • Special condition A. (28) Compliance Boundary was added to the permit. Groundwater compliance boundary maps were added to the permit as Attachment A and B. Attachment A describes the current compliance boundary and Attachment B describes the compliance boundary once the ash is removed from the East Ash Basin Extension. • Special condition for instream sampling was modified to require monthly sampling, to add sulfides to the list of monitored parameters and to specify the sampling location. • Fish tissue monitoring special condition was modified to clarify requirements. • For clarification the identification of outfall 003 was modified to heated water discharge pond. • The special condition for 316(b) requirements was modified to include a schedule to submit the required information in 122.21(r) by May 31, 2022. 15 NPDES PERMIT FACT SHEET Page 16 Public Notice schedule: Draft permit to Public Notice: Permit Scheduled to issue: Roxboro Steam Electric Plant NPDES NO.NCO0003425 STATE CONTACT If you have any questions on any of the above information or on the attached permit, please contact - Sergei Chemikov at (919) 707-3606. 16 ROY COOPER Govern WCHAEL S. REGAN Secretary UNDA CULPEPPER Director January 27, 2020 Tom Copolo Duke Energy Progress 10660 Boston Road Roxboro. North Carolina 27574 NORTH CAROLINA Enviranotenial Quality Response: Review of Duke Energy Progress, Roxboro Steam Electric Plant (NC0003425): Environmental Monitoring Report (2017-2018). Dear Mr. Copolo: prtOY7 a o41 Thank you for your submission of the 2017-2018 Environmental Monitoring Report for this facility. Based on a review of the information submitted, we find no major concerns associated with the Limnological data. Similarly, in terms of the fisheries, we find that the data submitted support the broad guidelines of a Balanced and Indigenous Population. In addition, as it pertains to the fish tissue data, we note that trace elements in fish tissues rnntinue to show spatial patterns that align with plant operations and are, overall, showing minimal or declining trends in Hyco Reservoir (especially for selenium). However, in future reports, please make the following amendments to the current format: 1) When making comparisons to North Carolina fish tissue criteria, please use current NC DPH fish tissue screening levels for TE comparisons, rather than their outdated fish consumption advisory levels. DHHS no longer uses "advisory" levels for TE comparisons when performing fish - based risk assessments. This document is appended for your convenience. 2) The Map (Figure 1) on Page 5 appears to be an older version and does not match up with the text in the report. Please address this discrepancy. 3) In the future, please include a historical (10-year record) graphical data set for the fish community data. This would make for significantly quicker review of the data for BIP determinations. North Carolina Department of Environmental Quality I Division of water Resources 512 North Salisbury Street 11634 Mail Seryfce Center I Raleigh. North Carolina 276991634 919.7079000 If you have any questions or comments regarding this matter, please do not hesitate to contact me. Sincerely, Cyndi Karoly Chief, Water Sciences Section Cc: Rick Bolich, Raleigh Regional Office Julie Grzyb, Complex Permitting Unit Kennedy Holt, NC DHHS Linda Hickock, Duke Energy Manuel, Vanessa From: Martin, Sharon L. Sent: Thursday, January 2, 2020 10:11 AM To: DEQ.AI I Subject: DEQ secures the nation's largest coal ash excavation of nearly 80 million tons of coal ash Roy Cooper, Governor D.EO!' DeW,t vM of rm,rimmorltal CWIICy ease: IMMEDIATE e: January 2, 2020 Contact: Sharon Martin Phone:919-707-8670 Michael S. Regan, Secretan DEQ secures the nation's largest coal ash excavation of nearly 80 million tons of coal ash LEIGH — The North Carolina Department of Environmental Quality (DEQ) has secured the excavation of nearly 80 million tons of coal ix facilities in North Carolina. Under a settlement agreement with community and environmental groups and Duke Energy that ends the eal litigation, Duke Energy will move forward with excavation plans at the Allen, Belews Creek, Cliffside, Marshall, Mayo ands s, moving coal ash into on -site lined landfills. : excavation is the largest coal ash clean up in the nation's history and will result in more excavation than in four neighboring states rbined. orth Carolina's communities have lived with the threat of coal ash pollution for too long. They can now be certain that the clean-up of th coal ash impoundments in our state will begin this year," said DEQ Secretary Michael S. Regan. "We are holding Duke accountable and I continue to hold them accountable for their actions as we protect public health, the environment and our natural resources." ter the signed agreement, Duke will be required to excavate more than 76 million tons of coal ash from open, unlined impoundments at tl facilities. More than 3 million tons of non -impoundment coal ash will also be excavated. Two facilities, Roxboro and Marshall, will be ject to additional protective measures for specific sections of impoundments that will remain under existing permitted landfills or structur :. Protective measures will include stabilization requirements, and surface water and groundwater monitoring and any necessary iedgation. agreement also requires Duke to enter into a court -supervised consent order with DEQ and the groups represented by Southern ,ironmental Law Center. tis agreement is a historic cleanup of coal ash pollution in North Carolina, and the Department of Environmental Quality and community ups throughout the state have provided essential leadership in obtaining it," said Frank Holleman, senior attorney at the Southern dronmental Law Center which represents community groups in court seeking coal ash cleanups in North Carolina. "The water resources families of North Carolina will benefit from this statewide coal ash cleanup for years to come." ce has submitted closure plans for the excavations by the December 31, 2019 deadline, as required by the Coal Ash Management Act tMA) of 2016 and in accordance with the agreement. The public will have an opportunity to comment on the closure plans during a tment period and at public hearings near each of ix sites in February. Under CAMA, DEQ's tmal action on the closure plans is due iin 120 days of receipt of the complete closure plans. Within 60 days of approval, implementation of the plans must begin. more information and to read the agreement and closure plans: hugs://deq.nc.pov/coalashexcavation Website: ,NiNxv.deq.nc.cox Facebook: ivwvuw.facebookconincdeo Twitter: wvvrxhvitter.comNCDEQ 1601 Mail Sen-ice Center, Raleigh, IBC 27699-1601 If you vould rather not receive future communications from North Carolina Department of Environmental Quality, let us know by clicking here. North Carolina Department of Environmental Quality, 217 W. Jones St., Raleigh, NC 27699 United States Manuel, Vanessa From: Sent: To: Subject: fyi Bolich, Rick Thursday, December 5, 2019 3:17 PM Vinson, Scott; Manuel, Vanessa FW: Duke Startup of Roxboro FGD System Rick Bolich, L.G. Chief, Ground Water Resources Section NCDEQ Division of Water Resources 1636 Mail Service Center Raleigh, NC 27699-1636 919-707-3671 From: Poupart, Jeff XCoo03°F2.{5, Sent: Thursday, December 5, 2019 3:14 PM To: Langley, Shannon <Shannon.Langley@duke-energy.com> Cc: Chernikov, Sergei <sergei.chernikov@ncdenr.gov>; Bolich, Rick <rick.bolich@ncdenr.gov>; Sledge, Bob <bob.sledge@ncdenr.gov> Subject: Duke Startup of Roxboro FGD System We concur with the commissioning and startup of the new Flue Gas Desulfurization (FGD) wastewater treatment system at the Roxboro Steam Electric Plant NPDES permit NC0003425 as described in your November 6 letter to Sheila Holman. This concurrence is based on the startup occurring under the existing expired and administratively continued permit. Sampling for the new FGD system will be associated with Internal Outfall 010 with ultimate discharge through Outfall 003. The new FGD system will be incorporated into the permit renewal currently being drafted. Please let me know if you have any questions or clarifications. Jeff Poupart Section Chief Water Quality Permitting Section NC Division of Water Resources 919-707-3600 E-mails to and from this address are subject to release under NC Records Act (' DUKE ENERGY., November 6, 2019 Ms. Sheila Holman Assistant Secretary NC Department of Environmental Quality 217 West Jones Street Raleigh, NC 27603 Paul Dreovitch, P.E. Senior Vice President NC Dept ofEnvironmental Quality Environmental, Health & Safety and Operations Support 58 S. Church Street NUV - 7 2019 Mail Code., 3XP Charlotte, NC 28202 (704) 373-0408 Raleigh Regional Office Subject: Startup of new FGD treatment components Internal process flow modifications Roxboro Steam Electric Plant NC0003425 Person County Dear Assistant Secretary Holman, This letter is to provide details and notice about the planned startup of required treatment components at the subject facility. Duke Energy has constructed a new wastewater system to replace the existing system used to treat flue gas desulfurization (FGD) wastewater since 2008. Details of this new system were shared with the Department in an application submittal dated August 15, 2016. That submittal is enclosed with this letter for ease of reference. Much of the existing system sits within the footprint of the west ash basin which will be closed resulting in the need for the new system. Duke Energy intends to commence commissioning activities for the new FGD wastewater system and place it into service after concurrence from your agency. Commissioning is expected to take between 6-8 weeks with tuning of the system taking up to 6 months to reach optimum treatment efficiencies of the biological system. As indicated in the 2016 submittal, flows from the new FGD wastewater treatment system will be directed to the lined retention basin for commingling with other wastewater sources and then to outfall 003, the same discharge point where current flows are directed. The internal flow path from the lined retention basin is currently in use as approved by the Department earlier this year. As described in the 2016 submittal, there will be a period where flows from both the old and new FGD wastewater treatment system occur as the old system processes remaining flow in the FGD settling basin until that system is closed. Duke Energy will continue to properly operate the old system and will sample as required while that system continues to function. www.dukc<nergy.com Ms. Sheila Holman Roxboro FGD startup concurrence request November 6, 2019 Duke will sample the new FGD treatment system in accordance with the existing permit requirements associated with outfall 010. These sample results will be reported as an attachment to our monthly required NPDES Discharge monitoring report much like our lined retention basin samples are currently reported. Duke Energy hereby requests your concurrence with this action with the understanding that this action is being taken under the conditions of the existing permit and is not intended in any way to be binding on the future permitting decisions or terms currently under review by the Department. If there are any questions about this matter please contact Mr. Shannon Langley at (919) 546- 2439 or shannon.langiey@duke-energy.com. Since y, Paul Draovitch Senior Vice President, Environmental, Health & Safety and Operations Support Duke Energy Enclosure cc: RRO DEQ WQ Supervisor w/enclosure 3800 Barrett Drive Raleigh, NC 27609 Jeff Poupart — DWQ Section Chief w/enclosure 1617 Mail Service Center Raleigh, NC 27699-1617 Lori Tollie - via email Shannon Langley — via email DUKE ENERGY® August 15, 2016 NC Dept of Environmental Qnality NOV - 7 2nI9 f i Raleigh Regional Office Ms. Teresa Rodriquez North Carolina Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Re: NPDES Wastewater Permit Application Submittal #8 Duke Energy Progress, LLC. Roxboro Steam Electric Plant Permit #: NC0003425 Person County Dear Ms. Rodriquez, Harry K. Sidens Senior Vice President Environmental, Health & Safety 526 S. Church Street Mail Code: ECUP Charlotte, NC 28202 (704) 3824303 Duke Energy Progress, LLC (Duke) is submitting herewith three copies of supplemental information in support of the NPDES renewal application submitted in September 2011 for the subject facility. This update is in addition to the previous updates and requests submitted dated July 27, 2011, March 31, 2012, October 15, 2014, December 17, 2014, July 22, 2015 and July 5, 2016. Please include this supplemental information and the information in the previous submittals in your review. This submittal is intended to provide an update of modifications that will be necessary to comply with recently enacted laws and regulations including the Federal Steam Electric Effluent Guidelines (ELG), Federal Coal Combustion Residual (CCR) rule, the North Carolina Coal ash Management Act of 2014 and HB 630 of 2016. Specific permit requests from Duke Energy are identified in bold throughout this submittal. With numerous federal and state requirements to coordinate and implement in a short time for the site, planning and sequencing of work are paramount and dynamic. As such, final scope and sequence for all work is not complete at this time. Where scope is still not finalized, Duke has provided a range of options that are being evaluated and provided various alternate scenarios in an attempt to limit the number of subsequent submittals necessary. As there are no requests for previously unpermitted external outfalis to waters of the United States and all proposed modifications contained herein are internal to our wastewater process flows, it is Duke's belief that the information provided in this submittal is of sufficient detail to allow for review and issuance or renewed NPDES permit for the Roxboro Steam plant. This is consistent with the guidance received from DEQ staff in a meeting on November 20, 2015 and follow up correspondence dated January 11, 2016 and January 28, 2016. Roxboro Steam Plant NPDES application update #8 NC0003425 Person County Page 2 of38 1. Duke requests a new internal outfall to be associated with a retention basin for treatment of low volume waste. North Carolina's Coal Ash Management Act and the Federal CCR rule will prohibit continued wastewater flows to the existing ash basin at Roxboro. Projects are underway to convert ash handling of all ash (both bottom ash and fly ash) to 100% dry handling and disposal systems. All other wastewater inputs to the current ash basin must be redirected and handled in another manner. Duke intends to construct a lined, retention basin to handle all flows currently directed to the active ash basin with the following exceptions: Storm water runoff from the landfill on the east side of Dunaway road that currently flows to the ash basin will be relocated (discussed below). Cooling Tower blowdown in cases where blowdown flows exceed 500 gpm will be relocated (discussed below). Additionally, the retention basin will consist of two basins: a primary and a secondary basin. The primary basin is where the majority of solids settling will occur, while the secondary basin provides adequate retention time for settling of fine particles. The primary basin will also have a location to allow various vacuumed sediments and solids to be decanted prior to disposal of materials into the onsite landfill. Periodically, any accumulated solids in the retention basin will be disposed of in the facility's onsite landfill. The retention basin will be approximately l l acres in area and have the capability to have additional of flocculent and pH adjustment chemicals. The primary basin will be designed for continuous flow through it. A holding basin will be constructed for high volume flows such as air heater washes, process washes, etc. The holding basin will have a chemical feed system for adjusting pH and polymer addition to enhance settling. Once acceptable, the holding basin contents will be transferred to the primary basin in the retention basin. The holding basin will be designed for batch processing and will be approximately 6.6 Acres in area. The requested internal outfall from the newly constructed retention basin will discharge into the heated water mixing zone upstream of outfall 003 and ultimately flow to Hyco reservoir thorough outfall 003 as is currently authorized by the subject permit. An aerial photo with potential locations being evaluated for the new retention basin can be found in Attachment I. Duke is evaluating the addition of a second retention basin southeast of the generation nits to be used to treat flows from silo wash water, stormwater runoff, landfill leachate and runoff from the gypsum pad area. Flows from this basin would enter the heated water effluent channel east of the generation units upstream of NPDES outfall 003. Duke requests an internal outfall be added to the permit for this basin. Roxboro Steam Plant NPDES application update #8 NC0003425 Person County Page 3 of 38 2. Duke requests that a new internal outfall for modified FGD wastewater treatment system be added to the permit. To comply with Federal ELG guidelines for FGD wastewater, a new treatment system for FGD wastewater will be constructed and utilized. This system will consist of physical/chemical treatment units, a new Bioreactor and ultrafiltration system. Solids settled and collected in the physical/chemical system will be handled via a series of filter presses and disposed of in the facility's onsite landfill. Duke intends to process legacy FGD wastewater through existing permitted outfall 010 until the treatment units associated with that outfall are decommissioned and closed. The requested new internal outfall for FGD wastewater and outfall 010 will need to both be operational for a period of time. The new internal outfall will be directed to the retention basin described in item #1 of this letter. If the new FGD treatment system must be in service before the retention basin is constructed, treated wastewater from the FGD internal outfall will be directed to the heated water mixing zone upstream of NPDES outfall 003 until the retention basin is completed. For reference, this is the point at which current flows are released to Hyco Reservoir. The location of the new FGD wastewater treatment system is identified in Attachment 1. 3. Duke intends to install heat exchangers or small auxiliary cooling tower for influent flows to the new FGD wastewater treatment system. Duke requests that this flow be listed as a contributing flow to outfall 003. Water will be withdrawn from within the process heated water mixing zone, used to cool FGD blowdown prior to treatment in the biological system and returned to the heated water mixing zone upstream of NPDES outfall 003. The heat exchangers or small cooling tower will be utilized to assure process water remains below bioreactor operational temperature requirements, which can potentially present an operational concern during the summer months. This addition is intended to assure efficient operation of the FGD blowdown treatment system. 4. Duke is installing a new domestic package plant for plant sanitary waste. Duke intends to replace the current domestic package plant with a new above ground package plant. The new domestic package plant will have a capacity of 0.025 MGD. With this modification, Duke requests the flow limit of 0.015 MGD associated with the existing plants design capacity be removed from outfall 008 or modified to 0.025 MGD to reflect the new plant's capacity. Treated flows from the new plant will be directed to the ash basin until such time that the retention basin described in item #1 is complete. Upon completion of the retention basin, treated domestic flows will be sent to the retention basin and flow to outfall 003 as they currently do. A narrative description and Roxboro Steam Plant NPDES application update #8 NC0003425 Person County Page 4 of 38 specification sheet for the new domestic package plant is provided in Attachment 2 with this submittal for your files. 5. Duke requests modification of the terms related to internal outfall 005 (Unit # 4 cooling tower blowdown). Currently, a slip stream of blowdown from the Unit 4 cooling tower is used to sluice ash and is directed to the ash basin. With modifications to the plant to handle ash in a completely dry form and future prohibition on sending wastewaters to the ash basin, Duke is requesting outfall 005 be permitted to be released directly to the heated water mixing zone or to the retention basin described in item #1 above (based on Duke's future determination) as both of these flows paths are upstream of NPDES outfall 003. Duke requests modification of NPDES permit condition A. (14) to facilitate this change. 6. Duke intends to install a vapor suppression system in 2016 at the anhydrous ammonia tanks to be used in the case of an emergency due to a release of anhydrous ammonia. This modification is intended to enhance the safety of our employees and local residents should there be an unintended release of anhydrous ammonia from the facility's tanks. This system will use raw lake water from Hyco reservoir. The system will be tested periodically with flows from tests (consisting of raw, untreated lake water) entering the heated water mixing canal just to the west of the unit #4 cooling tower. In the event of an actual emergency operation of the system due to a release of anhydrous ammonia, flows from the vapor suppression system will follow this same flow path and will potentially contain significant concentrations of ammonia. Upon completion of the retention basin, test flows and emergency operation flows will be directed to the retention basin described in item #1 of this letter. Flow rates for tests and emergency operation of the vapor suppression system are anticipated to be approximately 1882 gallons per minute. Duke requests concurrence in the permit that any impacts associated with the emergency operation of this system do not constitute a violation of the permit. Duke requests this flow be added to the list of flows tributary to outf d! 003 and, upon completion, the new retention basin described in item #1 of this submittal. 7. Landfill leachate is currently sent to the west ash basin. Landfill leachate flows will be directed to one of the retention basins (both upstream of outfall 003) described in item # 1 upon completion of that basin. Duke requests that ELG permit limits associated with landfill leachate be applied after the treatment provided in the retention basin described in item #1 of this submittal. Roxboro Steam Plant NPDES application update #8 NC0003425 Person County Page 5 of 38 8. Duke requests specific authorization within the reissued permit that upon ceasing flows to the west ash basin, decanting and dewatering of the basin through existing internal outfa11002 can occur. Specific authorization for decanting and dewatering is a condition currently in the NPDES permit at Sutton and Marshall. Duke requests specific authorization that the ash basin may be decanted and dewatered and what the permit limits associated with that activity are. A characterization of the ash basin interstitial water has been previously provided. This submittal was dated July 22, 2015. Decanting and dewatering will occur through NPDES internal outfall 002 and will ultimately flow to Hyco reservoir through NPDES outfall 003. 9. Duke requests the re-insertion of NPDES outfall 001 in the NPDES permit. This outfall was removed from the NPDES outfall by the Department in 1994. There have been no modifications to the flow since that time however, the flow originates at the retired east ash basin remnant area and contains flow from several areas recently identified as AOW's. Specifically, S-9, S-10, S-11, S-12 and S-13 flow to the point of S- 13 which is the former outfall 001 in the NPDES permit. Chemical characterization of this water was provided recently and was identified as S-13. If a full characterization of the water is required, Duke request that this be made a condition of the permit and be submitted 6 months after the permit effective date. Flows at this point consist of stormwater through the remaining area of the retired east ash basin, the AOW's identified above and other stormwater flows not associated with industrial activity. 10. Modifications associated with the coal pile runoff pond (NPDES outfall 006). Duke is constructing an emergency gypsum stack out area on the west side of the plant near the existing limestone ball mill and FGD filter press building. The emergency stack out area is not expected to be used routinely and is being constructed to comply with Federal CCR requirements. The area is approximately 0.3 acres in size. Runoff from the emergency gypsum stack out and surrounding area including a lay down yard, truck wash facility and gypsum conveyor system will flow to the coal pile runoff pond and to Hyco reservoir after treatment through NPDES permitted outfall 006. Additionally, there is a need to periodically drain a raw lake water tank located in the area of the coal pile runoff pond for routine maintenance. As part of routine maintenance, this raw lake water tank may be allowed to drain to the coal pile runoff pond. The tank can hold up to 50,000 gallons of water. 11. Landfill storm water flows. As discussed above, storm water flows from the existing landfill must be rerouted in order to comply with CAMA 2014 and the Federal CCR rule. Landfill storm water flows consists of runoff from approximately 250 acres of landfill Roxboro Steam Plant NPDES application update #8 NC0003425 Person County Page 6 of 38 and surrounding, up gradient area. Currently, storm water flows from the landfill flow into the west ash basin for treatment prior to being released through NPDES outfall 003. Currently three options are being considered for re-routing stormwater flows. An aerial photo depicting these options is included with this submittal in Attachment 3 a. Option 1: Duke is evaluating the feasibility of constructing a stormwater retention pond in the area just west of Dunaway road between Dunaway and the active ash basin. Flow from this storm water retention pond would enter the once through cooling water discharge canal and flow to Hyco Reservoir through NPDES permitted outfall 003. Duke requests review and concurrence that this modification is acceptable. b. Option 2: Flows may be directed into the once through cooling water discharge canal just to the north of the retired ash basin dam. The flow would then travel to Hyco Reservoir through the heated water mixing zone and NPDES permitted outfall 003 as it currently does. This will require permitting through NC DEQ Dam Safety program. Duke requests review and concurrence that this modification is acceptable. c. Option 3: Duke is evaluating the feasibility of routing stormwater flows to the plant's intake canal through the former NPDES outfall 001 discharge channel. Outfall 001 was removed from the NPDES permit in 1994 due to the retirement of the east ash basin. Duke has identified this discharge point into the intake canal as a seep and the discharge location and sampling data is referenced as "5-13" in previous submittals. Duke believes that Option 1 and Option 2 above can be accomplished without permit modification. Duke requests concurrence of this understanding. Duke believes that if the flow identified as "5-13" in previous submittals is permitted as a seep to the intake canal, or is reinserted into the permit as outfall 001, then Option 3 above can be undertaken without additional permitting. If coverage for "5-13" is not necessary, it is Duke understands that option 3 could be undertaken but may require industrial stormwater coverage under NPDES General Permit NCG12000. An aerial photo showing the route and location for each of these options is included in Attachment 3. Duke requests concurrence of this understanding. 12. Ongoing Landfdl/Basin closure groundwater dewatering — Development of future cells of the landfill and/or basin closure will require the lowering of groundwater levels in and around the retired ash basin to meet separation and stability requirements for the landfill. Duke intends to install a dewatering system and route extracted groundwater to Roxboro Steam Plant NPDES application update #8 NC0003425 Person County Page 7 of 38 outfall 003 and/or the re -permitted outfall 001 after treatment. Duke requests this flow be listed as a contributing flow to outfall 001 and outfall 003. 13. Steam Electric Effluent Guidelines Alternate schedule justification. Duke requests an alternate applicability date for the Steam Electric Effluent Guidelines in accordance with the request found in Attachment 4. As the Steam Electric Effluent Guidelines makes clear, BAT limits may apply - depending on the individual circumstances of the facilities subject to the rule - any time within the window of November 1, 2018 to December 31, 2023. In selecting an appropriate applicability date for each waste stream subject to the new BAT limits, the permitting authority is called upon to determine an "as soon as possible" date when supplied with appropriate information by the permittee. Attachment 4 provides the appropriate information justifying the following applicability dates: — Bottom Ash Transport Water: To convert the wet bottom ash transport system at Roxboro to a closed loop system, Duke plans to install a remote mechanical drag chain system (RMDS). Duke would like to request April 30, 2021 as the applicability date for the zero discharge of bottom ash transport water, assuming a permit effective date of October 1, 2016. — FGD wastewater: Duke is planning on conducting several evaluations to determine whether the FGD wastewater flow can be reduced, and the existing bioreactor can be utilized in addition to evaluating viable selenium reduction technologies. These evaluations will allow Duke to select the most cost effective FGD wastewater system for Roxboro. In addition, it has recently come to Duke's attention GE is claiming intellectual property rights on the biological treatment system for FGD wastewater, thus, making GE the sole provider of EPA's model technology. With these evaluations in process and the uncertainty of GE's intellectual property claim, Duke would like to request December 31, 2023 as the applicability date for the BAT limits for FGD wastewater, assuming a permit effective date of October 1, 2016. — Fly Ash Transport Water: Fly ash is handled dry during normal operation; therefore, Duke is not requesting an applicability date for the zero discharge of fly ash transport water beyond November 1, 2018. 14. CWA Section 316(b) alternate schedule. Duke requests an alternate schedule for compliance with Section 316(b) of the Clean Water Act. Specifics of the request can be found in Attachment 5. Roxboro Steam Plant NPDES application update #8 NC0003425 Person County Page 8 of 38 15. Area of wetness (AOW) disposition. Duke has previously identified a number of Areas of Wetness within the property. All of these AOW's are upstream of permitted outfalls. Consequently, Duke requests that there be no sampling required for the AOW's. These de minimus AOW flows are part of existing processes and are sampled through NPDES outfalls. Duke requests that the AOW's be listed as contributing flows the respective outfall in either the NPDES permit of NPDES permit fact sheet as follows: AOW's that are contributing flows to NPDES outfall 003 are: SI, S2, S3, S4, S5, S6, S7, S8, S14, S18 and S l9. AOW's that are contributing flows to requested NPDES outfall 001 are: S9, 510, Sl 1, S12 and S13. Duke requests that any future AOW's that are identified and are tributary to these permitted outfalls not require notification to DEQ. 16. Duke has included an updated water process flow chart with this submittal that shows the water flow path for the site after the ash basin is no longer used. This can be found in Attachment 6. The only substantive change in flow volumes will be the removal of ash sluice flows. This volume is negligible at outfafl 003. We appreciate your attention to these requests and look forward to finalizing the NPDES permit for the Roxboro Steam Electric plant in the near future. Should you have any questions regarding this letter or require additional information, please contact Mr. Shannon Langley at (919) 546-2439 or at shannon.langley@duke-energy.cwm. "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qual fled personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility offines and imprisonment for knowing violations. " Sincerely, Harry Sideris SVP - Environmental, Health & Safety Enclosures Roxboro Steam Plant NPDES application update #8 NC0003425 Person County Page 9 of 38 NCDEQ cc: Sergei Chemikov Duke Energy cc: William J. Thacker, Shannon Langley, Robert Howard, Rob Miller, Danny Satterwhite Attachment 1 Proposed retention basin location August 15, 2016 NPDES application update Roxboro Steam Plant NC0003425 Attachment 2 Domestic package plant narrative description and specification sheet August 15, 2016 NPDES application update Roxboro Steam Plant NC0003425 Roxboro Steam Electric Plant Domestic package plant improvements Sanitary wastewater at Roxboro station is currently treated in an in ground package wastewater treatment system which is more than 20 years old. A new package plant is being installed to replace the existing package plant on an in -kind basis. The new package plant will be installed above grade on a concrete foundation. The plant will have an average capacity of 15,000 gallons per day with a peak capacity of 25,000 gallons per day. The process will consist of an influent comminutor, influent equalization, extended aeration, secondary clarification, disinfection, and effluent pumping. Wastewater will be pumped from the equalization tank to the aeration tank through a flow control weir box, which will maintain a constant forward flow rate as long as there is wastewater in the equalization tank. The package plant will arrive with course bubble aeration diffusers pre -installed. Air to the process will be supplied by a connection to the plant air system. Aeration piping will include a filter and pressure reducing valves to condition the air supplied to two zones: zone 1 includes the equalization tank and the waste sludge tank, and zone 2 includes the aeration tank itself. Mixed liquor from the extended aeration process will flow by gravity to the secondary clarifier. Biomass settled in the clarifier will be pumped via air lift pump back to the aeration tank as RAS or to the waste sludge tank as WAS, where sludge will be accumulated prior to disposal off - site. Clarified effluent will leave the clarifier by a series of v-notch weirs and flow to the chlorination chamber for disinfection. A two -tube tablet chlorinator will be installed in the chlorination chamber to provide chlorine for disinfection. Treated effluent will be pumped to the Unit 3-4 sump via the existing effluent pipeline for the existing package plant. Flows from the Unit 3-4 sump are currently directed to the ash basin. Upon completion of the retention basin, flows from the package plant will be redirected to the retention basin and ultimately to Hyco Reservoir through NPDES outfall 003. The package plant will be insulated to help prevent freezing. Attachment 3 Landfill Stormwater flow options aerial photo August 15, 2016 NPDES application update Roxboro Steam Plant NC0003425 Roxboro Plant landfill stormwater redirection options T I•10 Site Overview 1 vN iv n� (To outfall 003) Attachment 4 Steam Electric Effluent Guidelines Alternate Schedule justification August 15, 2016 NPDES application update Roxboro Steam Plant NC0003425 Roxboro Electric Generating Plant: Effluent Guidelines Rule Justification for Applicability Dates A. Introduction Duke Energy (Duke) is working diligently to develop and refine an optimized schedule for the installation and upgrades to wastewater treatment systems to comply with the Steam Electric Power Generating Effluent Limitation Guidelines (ELG) at seven coal-fired stations in North Carolina. Duke submits the following information as a justification for appropriate applicability dates for compliance with the new Effluent Guidelines Rule (ELG Rule) (80 Fed. Reg. 67,838 (Nov. 3, 2015)) at Roxboro Electric Generating Plant (Roxboro), located near Roxboro, North Carolina. Roxboro consists of four coal fired generating units with nameplate generating capacities of 410.8, 657, 745.2, and 745.2 MWe for Units 1, 2, 3, and 4 respectively. The station currently discharges treated bottom ash transport water, and FGD wastewater. Under normal plant operations, fly ash is collected dry and either disposed in a permitted on -site landfill or transported offsite for beneficial reuse. If the dry fly ash collection system is not operating, the fly ash is sluiced to the ash basin in which the transport water is treated in the ash basin and subsequently discharged through outfall 002. Bottom ash from the boilers is sluiced with transport water to the west ash pond. The transport water is treated by the ash pond system and is discharged through outfall 002. The FGD blowdown is discharges to a gypsum settling pond were suspend solids are settled out prior to flowing to the bioreactor. The bioreactor effluent is discharged to the effluent channel through outfall 010 prior to outfall 002. The ELG Rule sets a range of possible applicability dates for compliance with the new BAT limits for bottom ash transport water (zero discharge) and FGD wastewater (numeric limits for selenium, arsenic, mercury, and nitratetnitrite), as well for fly ash transport water (zero discharge). The regulation provides that all permits issued after the effective date of the rule (January 4, 2016) should contain applicability dates for compliance with the BAT limits, and that those dates should be "as soon as possible" but not sooner than November 1, 2018 and not later than December 31, 2023. For Roxboro, since the plant's final NPDES permit will be issued after January 4, 2016, but before November 1, 2018, EPA specifically instructs permit writers to "apply limitations based on the previously promulgated BPT limitations or the plant's other applicable permit limitations until at least November 1, 2018." 80 Fed. Reg. at 67,883, col. 1 (emphasis added). As the rule makes clear, however, BAT limits may apply — depending on the individual circumstances of the facilities subject to the rule — any time within the window of November 1, 2018 to December 31, 2023. In selecting an appropriate applicability date for each waste stream subject to the new BAT limits, the permitting authority is called upon to determine an "as soon as possible" date. The ELG Rule provides a very specific definition for "as soon as possible." The permit writer — when supplied with appropriate information by the permittee — must consider a range of factors that affect the timing of compliance. Those factors are as follows: (1) Time to expeditiously plan (including to raise capital), design, procure, and install equipment to comply with the requirements of this part. (2) Changes being made or planned at the plant in response to: (i) New source performance standards for greenhouse gases from new fossil fuel - fired electric generating units, under sections 111, 301, 302, and 307(d)(1)(C) of the Clean Air Act, as amended, 42 U.S.C. 7411, 7601, 7602, 7607(dXIXC); (ii) Emission guidelines for greenhouse gases from existing fossil fuel -fired electric generating units, under sections 111, 301, 302, and 307(d) of the Clean Air Act, as amended, 42 U.S.C. 7411, 7601, 7602, 7607(d); or (ui) Regulations that address the disposal of coal combustion residuals as solid waste, under sections 1006(b), 1008(a), 2002(a), 3001, 4004, and 4005(a) of the Solid Waste Disposal Act of 1970, as amended by the Resource Conservation and Recovery Act of 1976, as amended by the Hazardous and Solid Waste Amendments of 1984,42 U.S.C. 6906(b), 6907(a), 6912(a), 6944, and 6945(a). (3) For FGD wastewater requirements only, an initial commissioning period for the treatment system to optimize the installed equipment. (4) Other factors as appropriate. 40 C.F.R. § 423.11(t). The wastewater treatment systems at Roxboro will undergo significant modifications and in most cases complete replacement to comply with the revisions to the ELG Rule. Duke would like sufficient time to select, design and install the most cost effective technology at Roxboro to comply with the ELG limits and reduce the burden to the ratepayers. We have prepared a preliminary timeline for planning, designing, procuring, constructing and optimizing the technology once it is selected, for each applicable waste stream. Based on our preliminary analysis, we request the following applicability dates: — Bottom Ash Transport Water: To convert the wet bottom ash transport system at Roxboro to a closed loop system, Duke plans to install a remote mechanical drag chain system (RMDS). Duke would like to request April 30, 2021 as the applicability date for the no discharge of bottom ash transport water, assuming a permit effective date of October 1, 2016. Duke anticipates that equipment will be installed by December 31, 2019 to comply with the North Carolina -Coal Ash Management Act (NC -LAMA) and the Coal Combustion Residual (CCR) rule. These rules, however, only regulate the material, not the water. As discussed below, Duke will need a 16 month window to optimize the system to operate as a zero discharge system. This additional time is needed to account managing the installation and optimization of four RMDS being installed in N. Carolina simultaneously. In addition, the extent and complexity of the permits required are unknown at this time. Duke, therefore, allocated 6 months to account for potential permitting delays. — FGD wastewater: Duke is reviewing options to determine whether the FGD wastewater system at Roxboro will need to be completely replaced or if existing components can be utilized. In addition, to construct a cost effective system, Duke is evaluating options to reduce the FGD flow to the treatment system. Furthermore, it has come to Duke's attention the availability of biological treatment systems may be limited due to intellectual property rights be claimed by GE, which would limit the available vendor resources to supply the model technology. At a minimum, we plan to evaluate the development of a new physical/chemical system augmented by a selenium reduction system. To account for the multiple evaluations needed and the limited vendor resources, Duke would like to request December, 31, 2023 as the applicability date for the best available technology (BAT) limits for FGD wastewater. — Fly Ash Transport Water: Fly ash is handled dry during normal operation; therefore, Duke is not requesting an applicability date for the zero discharge of fly ash transport water beyond November 1, 2018. The following provides necessary information justifying the requested applicability dates provided above. B. Bottom Ash Transport Water As stated above, significant portions of the bottom ash transport system at Roxboro will need to be replaced to comply with the no discharge limit of bottom ash transport water (BATW). The rule identified dry handling or closed -loop systems as the BAT technology basis for control of pollutants in bottom ash transport water. Specifically, a mechanical drag system (MDS) was identified as the technology basis for a dry handling system, where as a RMDS was identified as the technology basis for a closed -loop system. Duke is planning on installing a RMDS at Roxboro to handle bottom ash dry. The system will be designed to operate in a closed -loop mode to meet the zero discharge limits for BATW. Duke anticipates 55 months from the effective date of the permit will be needed to design, install and commission the RMDS as a zero discharge system based on the following preliminary timeline. It is important to note Duke will be installing RMDS at four stations in N. Carolina; therefore, additional time is needed compared to a single installation to account for managing multiple projects simultaneously. Remote Mechanical Drag System (RMDS) Activity T Duration (Months) Design' 8 • Siting 3 • Engineering 5 Procurement 12 Potential Permitting Delays 6 Construction/Tile-in 13 Optimization & Operational Experience 16 • Commissioning 2 • Start -Up 6 Total: 55 1) The design tasks has been initiated and Duke estimates an additional 8 months from the permit effective (assuming Oct. 1, 2016) will be needed to complete the design. 2) Even though is it estimated that commissioning and start-up can occur in 8 months, Duke anticipates needing a 16 month window to obtain the necessary operating time at full load and account for commissioning / optimizing occurring at multiple facilities simultaneously. Assuming a permit effective date of October 1, 2016, Duke estimates the system can be installed and operated to comply with the zero discharge limit of BATW on or before April 30, 2021. To design, procure, construct and optimize the RMDS at Roxboro to operate as a closed -loop system, the following steps must be taken: Design & Engineering Duke has initiated the design phase, but, due to the simultaneous implementation of programs, such as the CCR Rule and NC-CAMA across applicable sites in North Carolina, engineering and technology resources are limited. Duke, therefore, estimates the design and engineering process will take an additional 8 months from the permit effect date. Some of the activities within the water balance and siting task will occur concurrently; however the design cannot be completed until the siting task is completed. The permitting process, if necessary, will be initiated in the design and engineering phase, but it is assumed permit receipt / approval will be conducted concurrently with the design and procurement phase and will be completed prior to the construction phase. The following tasks will need to be completed. Water Balance The first step in the design process of the RMDS is to develop a detailed water balance of the current BATW. To operate the system as a zero discharge system, there is a balance between the inputs of water into the system and the outputs of water through evaporation and bottom ash removal. This is necessary to determine if any additional treatment of the BATW is needed to avoid increase in fines and concentration of other constituents that could affect equipment operability. In addition, several non-BATW waste streams are currently commingled and treated along with BATW. The flow of these waste streams will be rerouted from the BATW system to a new wastewater treatment system. This will require the streams to be characterized for both volumetric flow and constituent make-up in order to size and design an appropriate treatment system. It is important to note that not all waste streams discharge continuously or simultaneously. Some waste streams discharge intermittently based on activity occurrence, such air preheater and precipitator washes, while others may only discharge under certain rainfall events. In addition, many waste streams do not discharge if the unit is not running. With most coal-fired units operating in an infrequent mode, the opportunities to collect samples are limited and the operation schedule could affect the schedule of this task. Upon completion of the water balance, detailed engineering of the RMDS system and piping reroutes of non-BATW can commence. Siting The RMDS will need to be sited appropriately to avoid any historical or current coal combustion product disposal (CCP) sites and avoid construction areas that will be used to complete closure of the ash basins at Roxboro. In addition, Duke will attempt to site the system to avoid waters of the U.S. (WOTUS). However, based on the final siting of the system, WOTUS may not be avoided, and permits from the U.S. Army Corps of Engineers may be required. Permitting If WOTUS cannot be avoided, then permitting from the U.S. Army Corps of Engineers (USAGE) will be needed. At this time, it is unknown whether a USACE permit will be required or the type of permit that may be required (nationwide permit (NPW) or individual permit). Duke, therefore, has included 12 months in the schedule to prepare and obtain any necessary USACE permits. Once the RMDS is commissioned, the permitted discharge flows will change drastically. The amount of water discharged could be reduced by as much as 85%. In addition, these flows typically were treated along with the BATW in the ash basin. Duke, therefore, will need to design, and construct a new treatment system for these low volume wastes. The size and technology of the treatment system will be determined based on the water characterization study discussed above. In addition, based on the final siting of the low volume wastewater treatment system, a new outfall may be needed for the discharge of the effluent from this new wastewater treatment system. With significant changes to the characteristics of the permitted discharge, Duke anticipates a NPDES permit modification will be required to revise the permit to account for the changes in flow and constituent make-up. Even though the permitting task will be initiated during the design and engineering phase, it is expect to continue through the procurement phase and up to the construction phase. In addition, the extent and complexity of the permits required are unknown at this time. The required permits will be evaluated during the engineering and design phase. Since the time needed to prepare the permit applications and the time needed to receive the permits is uncertain, Duke allocated 6 months to account for potential permitting delays. Procurement After the design is complete, Duke will initiate the process to procure the necessary outside resources to construct and install the new wastewater treatment systems. This process will involve the following steps: — Evaluate potential vendors for proposal solicitation; — Develop and submit request for proposal (RFP) to selected vendors; — Conduct a review and vendor selection based on the received bids; — Develop required contract documents; Acquire materials (potentially from overseas), which involves: o Shipment, and o Equipment Fabrication — Fabrication and inspection of equipment. RMDS have a fabrication queue that is dependent on total industry -wide demand. Duke, therefore, has allocated 12 months to acquire the necessary materials. Construction Once all the necessary materials are procured, Duke estimates construction of the RMDS will take approximately 13 months. In addition, the tie-in of the RMDS to each individual generating unit will need to occur during outages, which are anticipated to occur between March to May and October to November depending on generation demand. Optimization and Operational Experience As stated above, Duke is planning to have the equipment installed by December 31, 2019 at the latest to meet the obligations under CAMA, in addition, to any CCR requirements. Again, these rules regulate the bottom ash material, not the transport water. Given the system will continue to utilize water to transport bottom ash, time will be needed to gain operational experience and optimize the system to meet the zero discharge limit. Duke estimates a 16 month window will be required to gain the necessary operational experience and fine-tune the system. The 16 month window is estimated based on the potential that the station may only be operating at full load during the winter and summer months and load and account for commissioning / optimizing occurring at multiple facilities simultaneously. In addition, with NCDEQ approving the implementation date of January 31, 2021 for Marshall Steam Station, Duke would like to stagger the commissioning / optimization activities for Roxboro by 3 months. C. New Wastewater Treatment System As discussed above, with the removal of several non-BATW waste streams from the bottom ash transport system, a new wastewater treatment system will need to be designed and constructed for co -treatment of low volume waste and other regulated process streams per the CCR rule, ELGs, and NDPES permitting requirements. The activities associated with the new wastewater treatment system will be conducted concurrently with the other design activities at the site. These waste streams are not subject to the applicability date in the ELG rule, therefore, Duke is not requesting a compliance date, but this task will need to be completed prior to the effective date of the zero discharge of BATW. Duke anticipates 30 months will be needed to design, install and commission the new wastewater treatment system, based on the following preliminary timeline. New Wastewater Treatment System Activity Duration(Months) Siting 3 Engineering 6 Procurement 3 Construction/fie-in 9 Commissioning 3 Start -Up 6 Total: 30 D. FGD Wastewater Duke expects significant capital improvements to the FGD wastewater treatment system will be needed to meet the ELG limits. At a minimum, Duke anticipates having to install a new tank -based physical / chemical treatment system followed by a selenium reduction technology. The selenium reduction technology has not yet been selected and Duke will be evaluating suitable technologies based on cost and feasibility. A biological treatment system is currently installed at Roxboro, but the ELG limits cannot be achieved with the current system. Duke will evaluate the current biological treatment system to determine whether the system can be used as part of an upgraded treatment system or will need to be discarded and completely replaced. In addition, the FGD flow rate for Roxboro is estimated at approximately 1,094 gallons per minute (gpm). In the proposed ELG rule, EPA assumed Roxboro could reduce its FGD flow to 375 gpm by recirculating some of the FGD water back to the FGD system. This would allow for the design of a significantly smaller system, resulting in a significant reduction in cost. Duke is evaluating options to reduce the FGD flow, which would affect the technology selection, design and cost of the system. To further complicate matters, EPA's model technology for the treatment of FGD wastewater is physical/chemical followed by biological treatment. Recently, the biological treatment system vendor for the ABMet system, GE, has claimed intellectual property rights on all biological treatment technologies for FGD wastewater. This could have significant impacts on the cost and procurement schedule of the treatment system. With an EPA estimate of 88 stations within the industry expected to upgrade the FGD wastewater treatment system to comply with the ELG limits, the implementation date must take into account limited resources of EPA's chosen model technology. EPA recognizes that designing, procuring, installing, and optimizing an FGD wastewater treatment system is a complicated and time-consuming undertaking, involving much study and careful planning. For example, EPA states: "For plants that are planning to include fuel flexing in their operations, in the years prior to the installation and operation of the FGD wastewater treatment system, the plant should consider sampling the untreated FGD wastewater to evaluate the wastewater characteristics that are present based on the differing fuel blends. Based on those characteristics, the plant will be better able to design a system that can properly treat its FGD wastewater given variability that might occur at the plant, and it will be better prepared to adjust chemical dosages in the chemical precipitation system to mitigate the variability in the wastewater that enters the biological treatment system." Response to Comments, p. 5-387. EPA also states: "While EPA has based the effluent limitations and standards for selenium and nitrate/nitrite (as N) for FGD wastewater based on the performance of the Allen and Belews Creek biological treatment systems, EPA does not contend that every plant in the industry can simply take the design parameters from those two plants, install the biological treatment system, and meet the effluent limitations. Each plant will need to work with engineering and design firms to assess the wastewater characteristics present at their plant to determine the most appropriate technologies and design the system accordingly meet the effluent limitations. Therefore, some plants may need to design the bioreactors to provide additional bed contact time (as provided by the hydraulic residence time and volume of biomass and carbon substrate), while other plants may find they need less." Response to Comments, p. 5-389 Duke is requesting 87 months from the effective date of the permit to design, install and commission the FGD wastewater treatment system to meet the BAT limits based on the following preliminary timeline. FGD WWT Upgrade Activity Duration (Months) Design & Engineering 30 • Flow Reduction Evaluation 6 • Evaluation of the existing biological system 6 • Technology Evaluation 8 • Siting 4 • Engineering 6 Procurement' 20 Potential Permitting Delays 6 Construction/Tie-in' 16 Start-up & Optimization' 15 • Commissioning 6 • Start -Up 6 Total: 87 1) Duke is allocating a 20 month window for procurement and a 16 month window for construction and tie-in to account for only one vendor available to supply and construct the biological treatment system. 2) Duke is allocating a 15 month window to complete the commissioning and start-up under all expected operating conditions from full load to partial load to periods of no load. Assuming a permit effective date of October 12016, Duke estimates the system can be installed and commissioned to meet the BAT limits on or before December 31, 2023. To design, procure, construct and commission the FGD WWT system at Roxboro, the following steps must be taken: Design & Engineering As with the RMDS, engineering and technology resources are limited due to regulatory requirements for concurrent implementation of programs, such as the CCR Rule and NC-CAMA across applicable sites in North Carolina. Duke is, therefore, estimating 30 months to complete the design and engineering phase of the project. FGD Flow Reduction Evaluation Duke is evaluating options, such as recirculating some of the FGD water back to the FGD system, to reduce the FGD wastewater flow rate to design and install a cost effective system. As stated above, EPA assumed Roxboro could reduce the FGD wastewater flow to 375 gpm. Whether recirculating some of the FGD water back to the FGD system is a viable option is dependent on the chlorides in the FGD water and chloride impacts on the materials of construction of the FGD scrubber. Duke will also determine if other flow reduction measures are available for Roxboro. This is a critical step in the design and technology evaluation to ensure a cost effective treatment system. Existing Bioreactor Evaluation A biological treatment system is installed at Roxboro. However, the current system cannot meet the final ELG limits for FGD wastewater. Currently, it is unknown whether the existing biological treatment system can be used as part of an upgraded treatment system or if the biological treatment system will need to be discarded and completely replaced. Duke, therefore, is planning on conducting an evaluation to determine the feasibility and cost of using the existing biological reactor or replacing the entire system. Siting As with the RMDS, the FGD WWT system will need to be sited to avoid any former or current CCR sites and avoid construction areas that will be used to complete closure of the ash basins at Roxboro. Additionally, Duke will need to site the system to avoid nuisance odor outside the property boundary. Duke will also attempt to site the system to avoid WOTUS. However, based on the final siting of the system WOTUS may not be avoided, and permits from the U.S. Army Corps of Engineers may be required. Technology Selection Duke has significant experience in the design, construction and operation of biological treatment systems for selenium reduction. Based on Duke's experience, biological treatment alone may not be a fool proof technology based on the characteristics of the coal. Duke, therefore, is obligated to review and evaluate whether other suitable technologies are available to treat FGD wastewater for selenium reduction at Roxboro. This is particularly important with GE claiming intellectual property rights on the biological treatment system for FGD wastewater, thus being the sole provider of this technology. Duke will be working closely with utility organizations, such as the EPRI, to identify suitable technologies for the removal of selenium from FGD wastewater and possibly additional polishing steps that may be required to meet the limits. Upon completion of the siting and technology selection, the engineering design of the system will be completed. Permitting If WOTUS cannot be avoided, then permitting from the U.S. Army Corps of Engineers (USACE) will be needed. At this time, it is unknown whether a USACE permit will be required or the type of permit that may be required (nationwide permit (NPW) or individual permit). Duke, therefore, has included 12 months in the schedule to prepare and obtain any necessary USACE permits. The installation of the FGD WWT may change the characteristics of the final discharge, therefore, a NPDES permit modification may be required to revise the permit to account for the changes in flow and constituent make-up. Even through the permitting task will be initiated during the design and engineering phase, it is expect to continue through the procurement phase and up to the construction phase. In addition, the extent and complexity of the permits required are unknown at this time. The required permits will be evaluated during the engineering and design phase. Since time needed to prepare the permit applications and the time needed to receive the permits is uncertain, Duke allocated 6 months to account for potential permitting delays. Procurement After the design is complete, Duke will initiate the process to procure the necessary outside resources to construct and install the new wastewater treatment systems. This process will involve the following steps: — Evaluate potential vendors for proposal solicitation; — Develop and submit a request for proposal (RFP) to selected vendors; — Conduct a review and vendor selection based on the received bids; — Develop required contract documents; — Acquire materials (potentially from overseas), which involves: o Shipment, and o Equipment Fabrication Fabrication and inspection of equipment. The selenium reduction technology will have a fabrication queue that is dependent on total industry -wide demand. With GE claiming intellectual property rights on biological treatment additional time will need to be factored into the implementation date. Duke, therefore, has allocated 24 months to acquire the necessary materials. Additionally, raw materials needed may have an extended lead-time from time of order to delivery, such as the granulated activated carbon used in the biological system, which has a lead time of 12 months. As stated above, GE is claiming intellectual property rights on the biological treatment system. If this claim is upheld, GE will be the only supplier of the biological treatment system. Given the potential number of facilities installing treatment system for FGD wastewater in the industry, additional 8 months is allocated to account for an extended procurement period. Construction / Tie In Once all the necessary materials are procured, Duke estimates construction of the FGD WWT will take approximately 16 months to complete. In addition, the tie-in of the FGD WWT to each individual FGD scrubber will need to occur during outages, which are anticipated to occur between March to May and October to November depending on generation demand. Furthermore, an additional 4 months were included in the schedule to account for the potential of GE being the sole provider of the biological treatment system. Commissioning & Start-up Duke estimates that commissioning and start-up of the FGD WWT will take 12 months to complete, 6 months for each task. Duke, however, is allocating a 15 month window to complete the commissioning and start-up under all expected operating conditions from full load to partial load to periods of no load. This will allow the identification of necessary actions that need to be completed in order to maintain the system under different operating scenarios. E. EPA Provided a Range of Applicability Dates To Allow For Coordination across Regulatory Requirements and to Promote Orderly Decisions The steam electric industry is in the midst of major transitions driven by new environmental regulatory requirements in the air, waste, and water arenas. In the ELG Rule, EPA explicitly acknowledged the complications of planning and executing ELG retrofits while developing and executing compliance strategies under the other rules. EPA made it clear that the range of applicability dates provided in the ELG Rule are supposed to be implemented in a manner that avoids stranded costs and promotes orderly decision making. For instance, EPA states: "From an environmental protection/coordination standpoint, with the increased use of flue gas desulfurization scrubbers and flue gas mercury controls in response to air pollution -related requirements, this rule makes sense from a holistic environmental protection perspective and from the perspective of coordinating across rules affecting the same sector. This final ELG controls the discharges associated with these particular waste streams." Response to Comments, p. 8-388. EPA also states that the permitting authority may "account for time the facility needs to coordinate all the requirements of this rule, along with other regulatory requirements, to make the correct planning and financing decisions, and to implement the new requirements in an orderly and feasible way." Response to Comments, p. 8-129. At Roxboro, we need to coordinate our ELG implementation strategy with CCR and NC-CAMA rules. For both the CCR and CAMA rules, we are evaluating the current CCR ash ponds to determine whether the ponds meet the locational restrictions of 40 C.F.R. 4 257.60 - .64. The future of the ash pond under both of these rules will determine whether it is available or not to receive legacy wastewaters (i.e., those wastewaters generated before the applicability date for bottom ash transport water retrofits) and continue to receive non-BATW. In addition, as discussed above, the final determination of the extent of the ash pond, as well as the closure method could have significant ramifications for the siting of both the RMDS and FGD W WT. F. ELG Implementation Should be Coordinated with the Clean Power Plan (CPP) to Avoid Stranded Costs The ELG Rule clearly contemplates that the compliance timelines for its requirements should account for any applicable obligations under the CPP. However, the affected units at Roxboro will not know their individual obligations under the CPP until well after November 1, 2018. As promulgated by EPA, the CPP's emission guidelines do not apply directly to units. Instead, states are responsible for developing state plans setting forth requirements applicable to individual units that implement those emission guidelines. These state plans are subject to review and approval by EPA. If EPA determines that the state has not submitted an approvable plan, then EPA will promulgate a federal plan in its place. The timeline the CPP provides for developing and reviewing these state plans involves numerous steps. The initial deadline for state plan submittal was September 6, 2016. 40 C.F.R. § 60.5760(a). The vast majority of states were expected to seek and obtain a two-year extension for final state plan submittal until September 6, 2018. See id. § 60.5760(b). However, the Supreme Court issued a stay of the CPP on February 8, 2016. Thus, the timing of the requirements of the CPP is uncertain at this time, as we wait further decisions by the Supreme Court. Duke would like to request the option to revise the applicability dates for the ELG requirements if the stay of the CPP is lifted and the operation of Roxboro will be affected. Statements in the Response to Comments regarding stranded costs apply to any rule, not just the CPP. EPA explains in the Response to Comments that it provided flexibility in applicability dates so that facilities could consider all new regulatory requirements and then have an adequate time to plan and implement accordingly, and thus avoid stranded costs: "EPA is sensitive to the need to provide sufficient time for steam electric power plants to understand, plan for, and implement any changes to their operation to meet their environmental responsibilities, and agrees with the commenter that transparency of requirements is important for minimizing "stranded investments." ...Furthermore, as described in the preamble, the final rule provides time for plant owners or operators to implement changes to plant operations in order to meet the final limitations and standards, as well as flexibility to permitting authorities in implementing the final rule. The Agency specifically considered the timing of requirements of other environmental regulations in establishing implementation requirements for the ELGs, in order to provide steam electric power plants time to consider and implement their strategy for compliance." Response to Comments, p. 8-388. Even though the implementation and effects of the CPP are uncertain, North Carolina Department of Environmental Quality (NCDEQ) is justified providing flexibility in the applicability dates from other regulatory requirements such as the CCR and NC-CAMA, as discussed above. G. The Proposed Schedules Help to Maintain Roxboro's Availability to the Grid, Which Promotes Grid Reliability Duke developed the proposed BATW retrofit schedule and its applicability date with grid reliability in mind. The dispatch of units at Roxboro varies throughout the year. Typically one unit is operating throughout the year and all four units are typically dispatched from December to March and June thru September. Therefore, the final tie-in schedule will avoid these months and more than likely tie-ins will need to occur across more than one outage. EPA explicitly notes that the permitting authority should consider grid reliability in setting applicability dates: "EPA's decision is also designed to allow, more broadly, for the coordination of generating unit outages in order to maintain grid reliability and prevent any potential impacts on electricity availability, something that public commenters urged EPA to consider." 80 Fed. Reg. at 67,854, col. 2. See also Response to Comments, p. 8-138. Also, EPA clearly anticipated that much of the new technology required for retrofits to bottom ash transport water and FGD wastewater systems would be constructed in a manner that would not interrupt routine facility operations, and then tied in during regularly scheduled plant or unit outages. According to the preamble, the timing of the final rule "enables facilities to take advantage of planned shutdown or maintenance periods to install new pollution control technologies." 80 Fed. Reg. at 67,854, col. 2. EPA also recognizes that tie-ins of new equipment may need to occur across more than one outage. EPA states: "the need to span installation of equipment over separate unit outages [is] a consideration that can be incorporated into the permit writer's determination of the 'as soon as possible' date, assuming the plant provides documentation demonstrating such a need." Response to Comments, p. 8-54. Attachment 5 Clean Water Act 316(b) alternate schedule request August 15, 2016 NPDES application update Roxboro Steam Plant NC0003425 Alternate Schedule Request §316(b) of the Clean Water Act Roxboro Generating Station Final regulations to establish requirements for cooling water intake structures at existing facilities were published in the Federal Register on August 15, 2014 (i.e. regulations implementing §316(b) of the Clean Water Act) with an effective date of October 14, 2014. Per §125.91(a)(1)-(3) Applicability, the Roxboro Generating Station (Roxboro) is subject to the requirements at §125.94 through §125.99 (316(b) requirements) based on the following: — The facility is defined as an existing facility (i.e. commenced construction prior to January 17, 2002); — The facility is a point source discharge; — The facility uses a cooling water intake with a design intake flow (DIF) of greater than 2 million gallons (MGD) to withdraw water from waters of the U.S.; and — Twenty-five percent or more of the water withdraws on an actual intake flow basis are exclusively used for cooling purposes. Per §125.98(b) Permitting requirements, 316(b) requirements are implemented through the NPDES permit. Facilities subject to the final rule are required to develop and submit application materials identified at § 122.21(r). The actual intake flow (AIF) of the facility determines which submittals will be required. All facilities with an DIF 2 MGD or greater are required to submit material identified at §122.21(r)(2){8), whereas, facilities with an AIF greater than or equal to 125 MGD are required to submit additional information presented in §122.21(r)(9)-(13). The AIF withdrawn by the station from Hyco Reservoir is above the 125 MGD threshold; therefore, Duke Energy is planning on completing the following 316(b) submittals: • § 122.2 1 (r)(2) Source Water Physical Data • §122.21(r)(3) Cooling Water Intake Structure Data • § 122.2 1 (r)(4) Source Water Baseline Biological Characterization Data • § 122.2 1 (r)(5) Cooling Water System Data • § 122.21(r)(6) Chosen Method(s) of Compliance with Impingement Mortality Standard • §122.21(rx7) Entrainment Performance Studies • § 122.2 1 (r)(8) Operational Status • § 122.21(rx9) Entrainment Characterization Study • § 122.21(r)(10) Comprehensive Technical Feasibility and Cost Evaluation Study • §122.21(r)(l l) Benefits Valuation Study • § 122.21(r)(12) Non -water Quality and Other Environmental Impacts Study • § 122.21(rx13) Peer Review Per §125.98(b) Permitting requirements, 316(b) requirements are implemented through the NPDES permit. For Roxboro, the NPDES permit proceedings had begun prior to the effective date of the rule. Therefore, 40 C.F.R §125.98(g) Ongoing permitting proceedings, applies to Roxboro, which states: "... whenever the Director has determined that the information already submitted by the owner or operator of the facility is sufficient, the Director may proceed with a determination of BTA standards for impingement mortality and entrainment without requiring the owner or operator of the facility to submit the information required in 40 CFR 122.21(r).." Only limited information regarding 316(b) was previously submitted to NCDEQ for Roxboro. The previously submitted information consisted of a Proposal for Informational Collection (PIC) request and a 316(b) Barrier Net Conceptual Design Report. In Duke's opinion, the previously submitted information is not sufficient for NCDEQ to proceed with a determination of BTA standards for impingement mortality and entrainment. As stated in the preamble to the rule, "In such circumstances where permit proceedings have already begun prior to the effective date of the rule, these facilities will still need to submit the appropriate permit application materials found at § 122.21(r) permit applications during their next application." 1 Furthermore, the regulation states the owner of a facility whose current effective permit expires after July 14, 2018, must submit the above information when applying for a subsequent permit and the owner of a facility whose current effective permit expires on or before Jul 14, 2018 may request an alternate schedule for the submission of the above information . As allowed under §125.95(a)(2) and stated in the preamble to the rule, Duke Energy would like to request an alternate schedule for the submittals listed above. Duke Energy would like to request the 316(b) submittals, with the exception of §122.21(r)(6) Chosen Method(s) of Compliance with Impingement Mortality Standard, for Roxboro be required with the subsequent permit renewal application due after July 14, 2018. Since Roxboro is subject to the entrainment best technology available (BTA) determination, a compliance schedule to complete §122.21(r)(6) Chosen Method(s) of Compliance with Impingement Mortality Standard will be requested to be included in the permit upon issuance of the entrainment BTA determination. The alternate schedule request is justified based on the following: — Roxboro was not required to submit information requested in § 122.2 1 (r)(2), (3), (4) and (5) under the remanded Phase II Rule because the station was planning to comply by installing a barrier net to meet the through screen velocity limit. — Information requested in §122.21(r)(6) — r(12) are new provisions and these submittals must be developed with r(9) requiring two years of entrainment data. ' 79 Fed. Reg. 48358 (15 August 2014) 'Refer to §125.95(ax]) and (2) l — For the §122.21(r)(13) Peer Review, Duke Energy estimates this could take up to 12 months to complete. This, also, takes into account the other six Duke Energy stations in N. Carolina and two stations in S. Carolina that will be undergoing the peer review process concurrently. — Additionally, the United States Environmental Protection Agency (USEPA) — Headquarters (HQ) have indicated guidance is being prepared to assist in interpreting and implementing the rule requirements, however, this guidance is not expected to be issued until the 316(b) litigation is completed, which is not expected to occur until 2017. Attachment 6 Process flow diagram with proposed future water flow path August 15, 2016 NPDES application update Roxboro Steam Plant NC0003425 Roxboro Steam Electric Plant Post ash basin flow outfall 003 Plant Proof Streams Water Treatment Systems Unit 4 Cooling Water 0 N KQ E B Unit 3 Cooling LL Water' Altemative modes C`I Unit 182 Cooling Water Plant Drainage System Drains from oil filled equipment containment Treatment (Oil/Water Separator) Unit Cooling To Atmosphere Tower D Outfall 005 (internal) ........................................................... Maintenance Drain To Atmosphere Unit 3 Cooling Tower Stomrwater from Gypsum Storage Pile Area H Domestic Sewage Low Volume Waste Treatment Plant Hyco Collection Sump ReserVOlr P I Ems, Flue Ges ......,_. Desulfudza0on - Dledtarge NH3 Vapor Suppression Lined P/C, FGD 0.. 00 (Emergency) Retention <""'- Uhra<"""'" Blowdown �p basins filtration OR (east and qBi�actor R Ash Landfill west) Leachate EaWaY seMeettltg t and SW stormwater Sea PoPond below Silo Unit 3 Coding Wash Water Tower Pond Healed Water Moong Zone Stoonwator Efnuent Channel AOW's and seeps FromLined Out1a11010 1 Flush - pond Ash basin closure 0ows M _ Hyco Reservoir Evaporalmn Outfall 003 Form 2C - Item II A Flows, Sources of Pollution, and Treatment Technologies Outfall 003 Augusl2016 Roxboro Steam Plant Outfall 006 Raw water tank tlreinage Stomnvater (maintenance) Oulfall 006N I Pile Runoff Treatment Basin Hyco Reservoir pile runoff ugenq Gypsum I Truck wheel wash stack Fonn 2C — Item II A Flows, Sources of Pollution, and Treatment Technologies Ouffall 006 August 2016 Roxboro Steam Plant Outfall 001 Stomreater through remnant of east ash basin Outfall 001 Intake pumps (or Plant Intake Canal � plant processes Incidental AOW's entl Gypsum and rail seepage runoR Outfall 000 Form 2C—Item It A Flows, Sources of Pollution, and TreatmentTechnologies Outfall 0011 Augusl2616 DUKE ENERGY, PROGRESS File: 12520 Mr. Rick Bolich North Carolina Division of Environmental Quality 1628 Mail Service Center Raleigh, NC 27699-1628 Subject: Roxboro Electric Generating Plant NPDES Permit No.00003425 Five-day Follow-up Letter Incident No.222096 Dear Mr. Bolich: Duke Energy Progress, LLc Roxboro Steam Electric Plont ! 700 Dannau'av Rmd Semora. NC 17.t43 October 22, 2019 t If "/A l l NC Dept of Environmental Quality OCT 282019 Raleigh Regional Office On October 20, 2019 at approximately 1:23 P.M., Duke Energy staff made verbal notification to Mr. George Bernard of an unanticipated bypass of treatment at the Roxboro Steam Station in Person County. The verbal notification was made as required by Part II, Section E.9.(c) of the above -referenced permit. Also, as required by Part II, Section E.9, this letter fulfills the five-day written letter requirement. At approximately 7:32 A.M. on Sunday, October 20, 2019, station operations received a Hi level alarm in the process water redirect sump during a period of intense rain. Station operations verified from DCS that two available normal service pumps (pumps B & C) were in service and operating when the Hi Hi level alarm was received approximately two minutes after the first alarm. A station operator was dispatched to investigate. While in route, another alarm for Lined Retention Basin inlet valve deviation was received, indicating low flow for the B & C pumps and tripping both off. The station operator and supervisor arrived at the sump to find the level elevated and overflowing into the heated water discharge canal. A higher capacity secondary Lined Retention Basin inlet valve failed to open on the Hi Hi level alarm which also had signaled and caused the primary valve to close. The primary inlet valve was forced open from the DCS allowing flow from the B & C pumps to be restored. Concurrently, the operator and supervisor placed the standby diesel pump in service. The process water redirect sump level decreased below overflow within 4 minutes. Total estimated overflow time was 10 minutes according to DCS alarm history. The primary inlet valve will remain in manual to prevent loss of flow until the secondary valve can be repaired. The total bypass volume discharged to heated water discharge canal was estimated to be 3,500 gallons. Duke Energy made an environmental event press release on October 20, 2019 and included it on the Duke Energy website. If you have any questions concerning this submittal, please contact Ms. Lori Tollie at (336)-8544916 or at Lori.Tollie@duke-eneray.com. '7 certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or �L) DUKE ENERGY_ PROGRESS juke Energy Progress, LLC Roxboro Steam Eleetde Plans 700 Dunnawav Rood Serm m. NC 27343 persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. f am aware that there are significant penalties for submitting false information, including the possibility of f nes and imprisonment for knowing violations. " Sincerely, Tom Copolo General Manger — Roxboro Steam Station (' DUKE ENERGY, PROGRESS File: 12520 Mr. Rick Bolich North Carolina Division of Environmental Quality 1628 Mail Service Center Raleigh, NC 27699-1628 Subject: Roxboro Electric Generating Plant 00a 3.4t%X NPDES Permit No.00003425 F N Five-day Follow-up Letter Incident No.222096 Dear Mr. Bolich: Duke Energy Progress, LLC Roxboro Steam Electric Plant 1700 Amami Rmid Semra. NC 27343 October 22, 2019 fpjA 11 NC Dept of Environmental Quality OCT 2 8 2m Raleigh Regional Office On October 20, 2019 at approximately 1:23 P.M., Duke Energy staff made verbal notification to Mr. George Bernard of an unanticipated bypass of treatment at the Roxboro Steam Station in Person County. The verbal notification was made as required by Part II, Section E.9.(c) of the above -referenced permit. Also, as required by Part II, Section E.9, this letter fulfills the five-day written letter requirement. At approximately 7:32 A.M. on Sunday, October 20, 2019, station operations received a Hi level alarm in the process water redirect sump during a period of intense rain. Station operations verified from DCS that two available normal service pumps (pumps B & C) were in service and operating when the Hi Hi level alarm was received approximately two minutes after the first alarm. A station operator was dispatched to investigate. While in route, another alarm for Lined Retention Basin inlet valve deviation was received, indicating low flow for the B & C pumps and tripping both off. The station operator and supervisor arrived at the sump to find the level elevated and overflowing into the heated water discharge canal. A higher capacity secondary Lined Retention Basin inlet valve failed to open on the Hi Hi level alarm which also had signaled and caused the primary valve to close. The primary inlet valve was forced open from the DCS allowing flow from the B & C pumps to be restored. Concurrently, the operator and supervisor placed the standby diesel pump in service. The process water redirect sump level decreased below overflow within 4 minutes. Total estimated overflow time was 10 minutes according to DCS alarm history. The primary inlet valve will remain in manual to prevent loss of flow until the secondary valve can be repaired. The total bypass volume discharged to heated water discharge canal was estimated to be 3,500 gallons. Duke Energy made an environmental event press release on October 20, 2019 and included it on the Duke Energy website. If you have any questions concerning this submittal, please contact Ms. Lori Tollie at (336)-854-4916 or at Lori.Tollie@duke-energy.com. "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qu alifted personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or (� DUKE Duke Energy Progress, LLC ENERGY:; Roxboro Steam Electric Plant 1700 Dunn"m Raid PROGRESS Semora. NC 273d3 persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. / am aware that there are significant penalties for submitting false information, including the possibility of f nes and imprisonment for knowing violations. " Sincerely, Tom Copolo General Manger — Roxboro Steam Station Manuel, Vanessa From: Manuel, Vanessa Sent: Wednesday, September 25, 2019 2:10 PM To: Grzyb, Julie; Chernikov, Sergei; Weaver, Charles; Hill, David A Cc: Bolich, Rick Subject: Duke Energy Roxboro Steam Electric Plant (NC0003425) - Permit Condition A. 12 Julie or Sergei — For the Roxboro Steam Electric Plant (NC0003425), I need your help with interpreting the permit requirement established by permit condition A.12 regarding temperature. For the June and July 2019 monitoring data, BIMS has generated monitoring frequency violations for Duke Energy's Roxboro plant (NC0003425) for failing to monitor temperature daily on outfall 002A. The RRO issued a NOV to DE for the June 2019 violations. In response, DE stated that based on permit condition A.12, the monthly average for temperature shall consist of at least 5 temperature readings (determinations) ... there is no requirement to monitor temperature daily. This seems to be one of those unique type permit conditions that's hard to reflect in BIMS. What is the required monitoring frequency for temperature? If it's less than daily, could BIMS be updated accordingly? This will prevent future, unwarranted violations from being generated. Thanks for your help with this permit condition interpretation. Vanessa E. Manuel Environmental Program Consultant Division of Water Resources — Raleigh Regional Office Department of Environmental Quality 919 791-4255 office vanessa.manuel(a)ncdenr.gov Physical: 3800 Barrett Drive, Raleigh, NC 27609 Mailing: 1628 Mail Service Center, Raleigh, NC 27699-1628 1� Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. 0-1 DUKE ' ENERGY: September 16, 2019 Rick Bolich Water Quality Regional Operations North Carolina Division of Water Quality 1628 Mail Service Center Raleigh NC 27699-1628 RE: Duke Energy Progress, LLC — Roxboro Plant NPDES Permit Number NC0003425 Response to NOV-2019-MV-0130 Request for withdrawal of NOV LUTIM3fn.31in111 Paul Draovitch SVP Environmental Health & Safety 526 S. Church Street Mail Code:EC3XF Charlotte, NC 28202 W( Oept of F,nvironmental Quality tiEP 19 20111 0-,IriW,,II Regional Office Duke Energy received the subject NOV on September 9, 2019 for perceived monitoring frequency violations related to temperature monitoring at the Cane Creek temperature buoy identified as sample location "002A:" in the BIMS computer system. This submittal is intended to provide some background and clarification as to the circumstances surrounding the situation and to follow up on conversations between members of Duke Energy staff (Robert Howard and Lori Tollie) and Ms. Vanessa Manual of your staff subsequent to the receipt of the NOV. On June 7 h, 2019 the historical temperature data loggers were removed from service as part of a temperature monitoring upgrade project. The antiquated temperature dataloggers were replaced with radio frequency devices that will transmit data wirelessly. The new wireless data loggers were placed in service on July 23rd, 2019. The Roxboro Steam Station eDMR listed 6 days of temperature data for the month of June and a comment detailing the equipment upgrades being undertaken as described above. The effective Roxboro NPDES permit does not identify or list an outfall 002A. This designation was set up in the BIMS system to be able to submit temperature readings from the Cane Creek temperature location buoy. The permit contains two conditions, A(2) and A(12), that describe limits and monitoring frequencies for the effluent and the 4C4D transect location temperature buoy within the reservoir. Condition A(12) details the terms regulating the temperature monitoring in the reservoir and states that "A monthly average temperature shall consist of at least five determinations conducted on five separate days." Historically, the Roxboro Steam Station has submitted at least five determinations monthly for all temperature monitoring locations identified in the permit. The Hyco Reservoir is permitted as a thermal mixing zone with the water quality temperature compliance point being the USGS gauging station located on the Hyco River just downstream of the Afterbay of the Reservoir dam. Mr. Rick Bolich NOV-2019-MV-0130 Response September 16, 2019 The attached graph represents the compliance temperature data for the month of June 2019 as recorded by this USGS gauging station. The graph confirms water released from the Afterbay was well within compliance with the water quality temperature standard for the entire month of June. Because language related to temperature requirements has caused confusion in the past, Duke Energy has previously requested the language related to temperature monitoring in condition A(2) and A(12) be clarified in the next issued permit for the station. This has been done by the agency in the DRAFT permits for the station but no final permit has been reissued as of the date of this letter. In summary, Duke Energy complied with the terms of temperature monitoring found in condition A(12) of the existing permit while taking the steps to upgrade its network of temperature monitoring equipment to a more advanced state. There is not an outfall 002A in our effective permit. Outfall 002A is a point set up in the BIMS system to be able to accept data from the Cane Creek location of the reservoir. Data attached demonstrates that the temperature of water released from the Afterbay was well within the temperature standard as required by the permit. Duke Energy respectfully requests that this Notice be rescinded and the BIMS system be updated to reflect the monitoring conditions specified in condition A(12) of the NPDES permit for each temperature monitoring location. Duke also requests that the language related to temperature monitoring in the DRAFT permit be evaluated to assure a consistent and clear requirement going forward. Thank you for your time and attention to this request. If there are any questions, please contact Lori Tolfie at 336.854.4916 or at Lori.Tollie@duke-enerey.com. I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. Environmental Health & Safety Duke Energy Mr. Rick Bolich NOV-2019-MV-0130 Response September 16, 2019 USGS 02077303 HYCO R BL ABAY D NR MCGEHEES MILL, NC H 27.8 88.8 L u � 26.8 u 78.8 i N 25.8 ` u 76.8 H v 24.8 yn 23.8 74.8 9 N 72.8 d m 22.6 m L 2 d CL r 21.8 78.8 ti L 28.8 68.0 LO a 19.8 u Jun 81 Jun 88 Jun 15 Jun 22 Jun 29 �- 2819 2819 2819 2819 2819 ---- Provisional Data Subject to Revision ---- - Daily naminun temperature — Daily nean tenperature — Daily nininun tenperature ROY COOPER Gmrrnw MICHAEL S. REGAN Srvrfarl LINDA CULPEPPER W.T w Certified Mail # 7017 0190 0000 9562 7213 Return Receipt Requested Paul Draovitch, Senior VP Duke Energy Progress LLC 526 S Church St - Ec3xp Charlotte, NC 28202 cur NOR'.N CAROLNA Envnrmmenral Quallry September 4, 2019 SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: NOV-2019-MV-0130 Permit No. NC0003425 Roxboro Steam Electric Power Plant Person County DearPermittee: SEP 0 .i 2019 BY:?.D �1 • A review of the June 2019 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s) indicated below: Monitoring Violation(s): Sample Location Parameter 002A Effluent Temperature, Water Deg Centigrade (00010) Monitoring Date Frequency Type of Violation 6/7/2019 Daily all days Frequency Violation 002A Effluent Temperature, Water Deg. 6/8/2019 Daily -- all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/9/2019 Daily -- all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/10/2019 Daily -- all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/11/2019 Daily all days Frequency Violation Centigrade (00010) Q �•I y�, '.:YJ':r:�lCi7^fr::`.Er..,=!'U ti-: :.l::fa:i 1••tt!'F13:.':!3 F:: t•F!{:r. Cr:013£:-Err; �•.l I F:lt• M1: ••=va n; 2_z Monitorino Violation(s): Sample Monitoring Location Parameter Date Frequency Type of Violation 002A Effluent Temperature, Water Deg. 6/12/2019 Daily — all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/13/2019 Daily — alldays Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/14/2019 Daily — all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/15/2019 Daily — all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/16/2019 Daily — all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg Centigrade (00010) 6/17/2019 Daily — all days Frequency Violation 002A Effluent Temperature, Water Deg. 6/18/2019 Daily — all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/19/2019 Daily — all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/20/2019 Daily — all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/21/2019 Daily — all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/22/2019 Daily -- all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/23/2019 Daily — all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. Centigrade (00010) 6/24/2019 Daily — all days Frequency Violation 002A Effluent Temperature, Water Deg. 6/75/2019 Daily -- all days Frequency Violation Centigrade (00010) - - 002A Effluent —Te—mperature, Water Deg.. - 6J26/2019 Daily -- all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/27/2019 Daly -- all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/28/2019 Daily — all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. Centigrade (00010) 6/29/2019 Daily -- all days Frequency Violation 002A Effluent Temperature, Water Deg. !6/30/2019 Daily — all days Frequency Violation Centigrade (00010) DEWs Kah ear- ro Dapanmtn:-fer. r:rma•to rlcs::I DvSir aMrr Ras -"al 0 Fo#I, Sol zrA CB: 5: So, e=Dtra IF* e;c N:,v:are rs:o:e A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1. If you wish to provide additional information regarding the noted violation, request technical assistance, or discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice. A review of your response will be considered along with any information provided on the submitted Monitoring Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no response is received in this Office within the 10-day period, a civil penalty assessment may be prepared. Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or potential problems due to planned maintenance activities, taking units off-line, etc. If you have any questions concerning this matter or to apply for an SOC, please contact Vanessa Manuel of the Raleigh Regional Office at 919-791-4200. Sincerely, Rick Bolich, L.G., Assistant Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ Cc: WQS Raleigh Regional Office - Enforcement File Laserfiche -�� L`S!Jr" rf :!car}r:: ¢r. :rr:•:f i•f ij I ��'t:-Ct i. fif'F3F:•':!1 _ `1.4' -,.i rea.r. [":f. n___of—:r [�.f!:fe{• �..:f•: •f i'e_c i 1 ROY COOPER Cmtrnur MICHAEL S. REGAN Secretary LINDA CULPEPPER Uary nN Certified Mail # 7017 0190 0000 9562 7213 Return Receipt Requested Paul Draovitch, Senior VP Duke Energy Progress LLC 526 S Church St - Ec3xp Charlotte, NC 28202 N04 i H "ARCLIN?, Environmental Quality September 4, 2019 SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: NOV-2019-MV-0130 Permit No. NC0003425 Roxboro Steam Electric Power Plant Person County Dear Permittee: A review of the June 2019 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s) indicated below: Monitoring Violation(s): Sample Location Parameter Monitoring Date Frequency Type of Violation 002A Effluent Temperature, Water Deg. 6/7/2019 Daily -- all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/8/2019 Daily -- all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/9/2019 Daily all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/10/2019 Daily all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/11/2019 Daily all days Frequency Violation Centigrade (00010) D_EQ�a Monitoring Violation(s): ... Sample ..ice .. Parameter 002A Effluent Temperature, Water Deg. Centigrade (00010) Monitoring Date Frequency Type of Violation 6/12/2019 Daily -- all days Frequency Violation 002A Effluent Temperature, Water Deg. 6/13/2019 Daily -- all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/14/2019 Centigrade (00010) Daily -- all days Frequency Violation 002A Effluent Temperature, Water Deg. 6/15/2019 Daily all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/16/2019 Daily -- all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/17/2019 Daily -- all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/18/2019 Daily all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/19/2019 Daily -- all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/20/2019 Daily all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/21/2019 Daily all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/22/2019 Daily -- all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/23/2019 Daily -- all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/24/2019 Daily -- all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/25/2019 Daily -- all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/26/2019 Daily all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/27/2019 Daily all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/28/2019 Daily all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/29/2019 Daily all days Frequency Violation Centigrade (00010) 002A Effluent Temperature, Water Deg. 6/30/2019 Daily all days Frequency Violation Centigrade (00010) MEhoar Fr A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1. If you wish to provide additional information regarding the noted violation, request technical assistance, or discuss overall compliance please respond in writing within ten 10 business days after receipt of this Notice. A review of your response will be considered along with any information provided on the submitted Monitoring Report(s). You will then be notified of any civil penalties that may be assessed regarding the violations. If no response is received in this Office within the 10-day period, a civil penalty assessment may be prepared. Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or potential problems due to planned maintenance activities, taking units off-line, etc. If you have any questions concerning this matter or to apply for an SOC, please contact Vanessa Manuel of the Raleigh Regional Office at 919-791-4200. Sincerely, Rick Bolich, L.G., Assistant Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ Cc: WQS Raleigh Regional Office - Enforcement File Laserfiche glgi'/y (' DUKE n ENERGY PROGRESS File: 12520Q NCDEQ — Division of Water Resources Information Processing Unit 1617 Mail Service Center Raleigh, NC 27699-1617 Subject:: Roxboro Steam Electric Plant Groundwater Monitoring Sampling and Analysis Result% NPDES Permit #NC0003425 Dear Sir or Madam: Duke Energy Progress, LLC Roxboro Steam Eleetric Plats 1700 D unn,mar Rmd .Semnra, NC 27343 August 20, 2019 NC Dept of Environmental Qua Iit.. (..uu 7 F ?r',,Q Raleigh Regional Ufficc Duke Energy Progress, LLC. (DEP) sampled eight compliance wells around the ash basins at the Roxboro Steam Electric Plant on July 24 and 29, 2019. Attached are two copies of the results on DEQ approved electronic version of Form GW-59CCR. Please contact Kim Witt at (336) 215-4576 or kimberlee.witt@duke-energy if you have any questions on the sampling results. I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility offnes and imprisonmentfor knowing violations. Sincerely, lz,—_ � Tom Copolo GM 111 Regulated Fossil Roxboro Steam Electric Plant Attachment NCDEQ Cc: Debra Watts Rick Bolich GROUNDWATER QUALITY MONITORING COMPLIANCE REPORT FORM FACILITY IXFORMGTNNI FaCRI' NBme: .-Fi Name (R diherem, Facllh, Address: Semora IGtN Centad Peorms Well Le.,Fm/She Name'. Noeawmarerl arT e Roabere Steam EleRdc Plant Dube Ere Y'Alms, UC t,. Dunnewy Read Isneeel NC 1 27343 Caesars 0 Wart) (be) IOm VAR lekpnmse0 336215-15]fi ROaboroA POM WeAs xD. W wIIFm Oe umPkd: 8 IM1um Pe�hl WV Units M I I CW-1 CW-20 M-3 M 3D CM 4 Well De h Itsbatow land ardfimil It 39.75 1].50 29.90 11 a0 66.50 3900 Mesaurin Poim (t«)Ih.beee land sume.) X 20 2.8fi 2.45 3.33 3A9 2.39 Well Diameter In 20 10 2.0 ID 2.0 2O SrevoT Ih Whose land surlarel X 1995 1)0 2510 3at) 4170 2a 20 Breen Bette lh benaxr land surlaae7 X 39)5 1]50 2990 1140 4650 3900 Martha MeasuringPoint Elevatlen h 1.R a2460 424.60 45119 45161 4]965 CHECK IF DRY WEIL AT TIME OF SAMPLING ["°1 ❑%av ❑w+r [, xr ❑wv [xr 15A ZL Units LW-1 1 (W-3 I CW-20 1 M 3 01 ONA Am le Data 07IM12019 0724/2019 01/2112019 07/211ZG19 07/21/2019 07/29/2019 VhumeoFWatmpum d/balled al owl O.Hil Iml 2501 CA51 1. acll Te eretort 00010 d .0 5 .1 182 18101 19,01 190 36.0 Oder 100085) Narc None Has, None NmeA,pi Nm! a O Uear O® Char caa Dear TuMidiN (82018) Nlll 4.]5 4.3i 28 lA 25 933 Dinobeda en 00300) 0.3] 0.fi) 2.39 26 2.44 1.17 Oxidation BNustim Potential RUD901 mV 122 194 302 269 2% 131 SOetlR<Cord -field OK umM1m/on 714 g91 661 ]3] 569 590 Waterrevel lX below measuring A.1 RUS461 h 21 t3J5 1384 55 2]] 30.3E ins. .field0r400 6.5-9.5 SU 6.1 6.8 ]D 63 73 6) 11WpaW1 Labaea<ory Name Sample Ana'sis Date Dube Energy Analytical Laboratory IUIY 35, 2019-.'st REAC3 1SA-21 I Units CW-1 1 .2 NF20 CW-3 1CW-3D 0" I16-Tatelqu.5olids )11300I SOD 1 48a 513 413 424 344 3521 CI. Ubrlde 100940) ]50 m 9A 28 16 a1 15 ! As Alsmk(01002) ]0 I <1 <1 <] <] <1 <1 scia se a4 009a5 250 I 95 " 1M Sal32 3] NNatr NO3 aaN OOfi20 10 I <U.DE 0.22 D.35 0.66 e0.0i3 03a U.Odmlum 02027 2 I Q <I .11 ell <3 41 G-Uromlum l01D34 l0U&JI 6 <5 6 -$1 4 Cu-Cmxr101042 1 m m.Das mms 0005 <o.ODs row s 41005 Fe.Imn I0104S 3W 171 137slal <101 71 116 -Merau ]1900 1all Amsl 401 < Usl <0.05 40.95 Mn-lea'.... 010 5 SO u I 29 137es<5 4 4 6 N M-du01057 ]00 <5 d .5<5 <S Po. used I01651 IS .11 <1 <1 <1 <1 < la OIPR 1 000E si <0105 0. N'BNIYm 10100] MO 111 49 1! 8-Bw0n101022 ]ILO W 60 <SO tl-Tha01um(01059) Ol NE 1 N.2 W2 <O.i 41 Sb-Mtlmony(0107) t NF <1 <1 <1 m5n Se- Selenium 10130 !0 <1 <1 <1 Aleallnity 200410) NE 1 2% 349 226 N-Aluminum Ulm NE 40 19 66 1 M- Runs... 4 M I <1 <1 K03- NnrbOnata 100440 NE ZDi 3a9 2M 3 6 GIdum100916 NF 1 a9.b 488 a8 5L5 CO3-Carbonate ears RE e5 <5 b 6 6 Go. CebaDl0103T 1 NE 1 <1 q sl <1 <1 < -Ma euum W93)) NF real' 223 3]5 384 30.6 MD-Mhybdenum101062 NF rI 4 el 6 246 5. A'PotaMlam M37 NF 265 126 255 3.21 a.32 43 Na 50dism 82035 NF 1 ]G.] 84.1 37 483 188 TSS-T.1 Su,. Solid, 702311 Nf 6 <5 CS <5 S V-Wn dher 0108] 03 HE 1 21.4 22 I3 3.42 2,13 21' Sr-SXentlum l01M2) NF .0 0.52] 0.425 0323 0.3]5 DIBl blO values seual or eemed the coremramhng 2L s4Mand m evMee wmbmwon we vary. -`J�d ti Ye u - &k 1u Q� V StAucabs euxa6eic none 1-ineelor AummiledAgmDHameanalme rueremmwrym GW.59CCR 09/2015 slM IMACf wee lNaNm ml0,xolv.na:Dss; nOwv.. NCDEDna4 elm aUAWISM.nSm mae. amentamN,sdes0lb.dmlSA Mall original a dltoay m: ' Samples For metals were collected unfiltered! L Vas L No and field addifiednyet No �PWP"b nlatnds daeryNaq aUW?ae'frd lalonbry Iamwwle Mal XiereaaaalY"(aan1 Pa11Nllaabr udrMlnP iia YdunlsEm,n4Madfielpondabilityadfififinds 0L@02 IeL For MIS reemn, IMACt noted on the report are he reference onry. 0' E O a 0 4E ubo o � w /a ti GROUNDWATER QUALITY MONITORING COMPLIANCE REPORT FORM FACILITY INFORM4PDX pease %Int CleerlY erT e Fadliry Name: Roxboro Steam FleddC Punt Remit Name lit different): Duke t,,trgy P,ogmss. DEC FaeiIHYAddmin: 1 17M Dunnamy Road Is0eed Senn.o NC 27M3 j Gamnry Person IOhI (-I Ilipl Contact le-ii I we. Win Telephmd I 33 2153576 Well botien/she Mame: RMbOr0 A5b POntl Wells Ne. el wellam6e sampled: 8 frompermul 77 841 units ME CW-2 I CW-2D CW A CW 30 M4 Well Depth IF below lane a„daeel h 1250 2990 11.40 4fi.50 390D Measurin emm" I lh slimes land wrfaee) h 2.M 2A5 3.33 3.49 239 We1101ame<v In 30 zO 20 2.0 20 1,rmn Tom lh Mimw lantlwrtaml h 15�24 270 25.10 340 41.70 2420 sve- emImn lh bet. land surfaal h 1] 50 29.90 1140 46.50 39 M Relative Measmrin ii Flewlism h 42460 42460 45179 451.61 479.65 CHECK IF DRY WELL AT TIME OF SAMPLING ❑wr ❑mv ❑oer ❑0cr ❑DRY ❑wr ISA-2l Units CW1 M2 CW-2D CW-3 CW-31) Cl Sam Ie one 07/29/2019 07/24/2019 07/24/2019 07/24/2019 07/24/2019 0)/29/2015. Youme ml Waler 1-ned/belled Fell 0.50 0.50 1Do 350 0.45 1. T erature OOo10 tl .< 25.0 1110 UB0 190 190 26. Odor100085) "'me, Name N. uses N. Me Cleser Gear Onr Our sea ae Turetn"1820]B NFU 4.fi 4.32 2A 1.4 2.5 9.3r NsvlvsE Distill00300 0.37 O67 2.39 2.6 2.44 1E Oddetbn hduttlem Potential(0009p) mV in 194 202 269 256 13 ed6a Cmnd - field Doi umhm/am 714 891 "1 ]1) 56e) 5% Water level lh below measuring pL1145W1 It 21 1375 13M 5.5 272 302{ Xflela W4DJ 6.5-8.5 SU 1 621 691 Dal 631 7 31 6.' laboratory Name Sample Analysis Date DURe Fnerry MaMinl laboratory luly Is. 2079 ..st )... ,.Mi 15A11 Units CW-1 CUM-2 CW-20 CW-3 CW-30 M. TOS- Fetal qn. Solids (703001 500 Rai Fee 511 413 424 314 35, a -al«Ids 100940) 350 m 1 9A 26 16 41 25 2F As. Arsmk 101002) 10 1 R1 <1 <1 <1 R1 Sp -Ulu. 1009451 3511 Will 95 90 110 54 32 3. IK4me INCH) - N 100620 W 1 N.W6 0.22 0.35 066 AD13 0.3: CL Ctlmlum 01027 2 Ull q <S <1 R1 Q Or -Chromium (01034) 0 sells 6 <5 RS <5 6 a- Cell0104x I m I moos m.005 a90s moos m.aas mW� Fe - ben 101045 300 Uelf 17 137 RED <20 II 211 -Mery r, 171100)1 u I 41% RODS REM RODS <005 <0.01 an Mn-Manise 101055 SO uFit 29 127 b <5 M 11 M-rests) poloi 100 u I 6l <5 a 51 RS ro-I:W(01051) ssugA R21 <1 <1 <1 n 2a-Zinc I01092 I m D.WS 4LUDS moos moos moos 0.Doi a-eadum 0100)) Mi 160 ios 350 111 48 1T 8-loon I01033 7e0 u I 40 <50 W 50 b0 <51 T-Thallium 101M9 0.2 ME u 1 m2 <0.2 AS <0.2 <03 A: Sh-AmImamY10109)) I MF <1 q <1 <1 <S S-Lknlum 0114] ID u .1 <I <t <3 A AlblinlM � (00410) ME 1 259 313 2W 249 226 23f N-Aluminum 01105 ME <10 19 QO 19 fi6 W 8e- Ilum 01012 4 NE u I <1 <1 <1 <1 R1 < HCO3-vtemb nmM40 e O NE m I 259 313 209 249 an 2 6-Oldum 111i - NF I FEES 488 N 57..5 73.9 4 Oil -Cadmium fool M I 6 <5 b R5 <5 Cn'CObaNI0103) 1 NE u I <1 Q <1 <1 <1 nulum 10092) ME nod, 223 37.5 39.4 30.6 18.6 26: rem-Mal"cu uml0lWzl MI ull, R1<3 A .12.46 5. K-NMsslumf00Y3)l F. I65 1.26 255 121 4.32 4.3 Ne- Imdium l820351 NE I mK/I 76.7 84.1 37 48.3 18A TSS- Tmul Susp. Solids 170031 M 1 911 6 <5 R5 RS 5 V-Vanaelum 01087 03 1 NE u 1 LA 22 13 142 2.13 2.2 Sr-Suontlum(01W2) ME m8/I O.S27 0425 0.322 0375 0.281 0.19, solo came, mmamr--dth--lomntlmg 21 ]mnmm n-, O /ax P/ W w OA W CIS V StAial JS Perminee for Aum«ode ABenq xame and ram-pea-imm «type GW-59CCR 09/2015 r01e 1MA4 were laauad In 2010,ZY21.a1Wx012;NereerHDF1 Fee net esbblls8ed a 11M these eene0luema-dawumit N IMA I I Mall erl{Innl ' add 1pppy.. ' .w. Indoctrination Well to Number (From Permit) and field acidified: Itic to 0®®®®®®®®®® yappmvedmeOgEsofanapalsbya OWO-cerll(ed laboratory Iam entire mat thereare stpndram penaMles for submiXiep bite recantation, froludmBOupossibilMolri 02L0202 (c). for Mli reeeen. IMP[; noted on the report are for reference only. WWTP Upset, Spill, or Bypass 5-Day Reporting Form Page 2 DWR Division of Water Resources (Please Print or Type Use Permittee: Duke Energy Carolinas, LLC Permit Number. NC00003425 Facility Name: Roxboro Steam Electric Plant County: Person Incident Started: Date: 6/14/19 Time: 10:00 am Incident Ended: Date: 6/14/19 Time: 2:05 pm Level of Treatment: _X—None _Primary Treatment _Secondary Treatment Chlorination/Disinfection Only Estimated Volume of Spill/Bypass: 12,500 gallons (must be given even if it is a rough estimate) Did the Spill/Bypass reach the Surface Waters? X Yes No The discharge was to the permitted heated discharge canal which discharges out permitted outfall 003 to Hyco Reservoir If yes, please list the following: Volume Reaching Surface Waters: 12,500 gallons Surface Water Name: Hyco Reservoir Did the Spill/Bypass result in a Fish Kill? _Yes X No Was WWTP compliant with permit requirements? X Yes No Were samples taken during event? _Yes X No Source of the Upset/Spill/Bypass (Location or Treatment Unit): At approximately 08:53 am on Friday, June 141h, a 3rd party contractor inadvertently struck a powerfeed from Unit 1 at Duke Energy's Roxboro Steam Station causing a power failure to the pump in the water redirect collection sump. The water redirect sump collects various process wastewaters from the steam station, such as cooling tower blowdown and facility wash water. These process waters are directed to a Lined Retention Basin, LRB, for treatment and discharge to the heated water discharge canal which discharges to Hyco Reservoir through Roxboro Steam Station's NPDES permitted outfall 003. The power failure caused the collection sump to begin overflowing into the heated water discharge canal bypassing treatment in the LRB at approximately 10:00 am. WWTP Upset, Spill, or Bypass 5 r Reporting Form Page 2 Cause or Reason for the Upset/Spill/Bypass: A contractor inadvertently struck a power feed from Unit 1 at Duke Energy's Roxboro Steam Station causing a power failure to the pump in the water redirect collection sump. Describe the Repairs Made or Actions Taken: The Station was able to stop the overflow/bypass at approximately 2:05 pm by slowing process flows into the water redirect sump and utilizing a vacuum truck to remove water from the sump. Power was restored to the pump at 2:20 pm. It is estimated that approximately 12,500 gallons of untreated wastewater was discharged into the heated water discharge canal. Given the relatively small volume of this discharge compared to the volume of water in the canal, we do not anticipate anythreat to public health orthe environment. We also have no reason to expect any exceedance of permit limits at Outtall 003. Action Taken to Contain Spill, Clean Up and Remediate the Site 6f applicable): The wastewater was discharged to an NPDES effluent channel. Cleanup was not required. Action Taken or Proposed to be Taken to Prevent Occurrences: The system is designed with redundant backup pumps. Additional Comments About the Event: 24-Hour Report Made To: Division of Water Resources X Emergency Management Contact Name: Jason Robinson Date: 6/14/19 Time: 4:30 pm Other Agencies Notified (Health Dept, etc): NA Person Reporting Event: Joyce Dishmon, Duke Enerqv Phone Number. 336-394-5524 Did DWR Request an Additional Written Report? X Yes No If Yes, What Additional Information is Needed: Jason requested a completed WWTP Upset, Spill, or Bypass 5-Day Reporting Form 1 to be submitted to his attention via emai. Robinson, Jason From: Dishmon, Joyce Martin <Joyce.Dishmon@duke-energy.com> Sent: Monday, June 17, 2019 3:16 PM To: Robinson, Jason Cc: Conner, Steven B; Tollie, Lori White; Howard, Robert E; Winston, Cynthia C Subject: [External] Roxboro Steam Electric Plant - Bypass Reporting Attachments: W WTP-Bypass-Rpt-Form-1-20140805-D W R-SW P-N PDES.doc Jason, Per our conversation on Friday, 6/14/19, at approximately 4:30 pm, I have attached a copy of the requested WWTP Bypass/Upset Report Form-1 for your review and file. A description of the event is outlined below: At approximately 08:53 am on Friday, June 14'h, a 31d party contractor inadvertently struck a power feed from Unit 1 at Duke Energy's Roxboro Steam Station causing a power failure to the pump in the water redirect collection sump. The water redirect sump collects various process wastewaters from the steam station, such as cooling tower blowdown and facility wash water. These process waters are directed to a Lined Retention Basin, LRB, for treatment and discharge to the heated water discharge canal which discharges to Hyco Reservoir through Roxboro Steam Station's NPDES permitted outfall 003. The power failure caused the collection sump to begin overflowing at approximately 10:00 am into the heated water discharge canal bypassing treatment in the LRB. The Station was able to stop the overflow at approximately 2:05 pm by slowing process flows to the sump and utilizing a vacuum truck to remove wastewater from the sump. Power was restored to the pump at 2:20 pm. It is estimated that approximately 12,500 gallons of untreated wastewater was discharged into the heated water discharge canal. Given the relatively small volume of this discharge compared to the volume of water in the canal, we do not anticipate any threat to public health or the environment. We also have no reason to expect any exceedance of permit limits at Outfall 003. Please let me know if you have questions/comments or need additional information Regards, Joyce Dishmon Permitting and Compliance, Carolinas Office: 336-623-0238 Cell: 336-394-5524 Email: joyce.dishmon@duke-energy.com GROUNDWATER CIU41T'7 MONITORING COMPLIANCE REPOT M FACILITY INFORMATION pease Print Clearly or Type Facility Name: Roxboro Steam Elettric Plant Permit Name (d different): Duke Energy Progresa, LLC Facility Address: 1700 Dundawi y Road 15trem) Semora County Perzon (Cr,) (Stare) (zip) Contact Person: Kim Witt T ephoneK 336-215A576 Well Wcation/Site Name: Roxboro Ash Pond Wells No. of wells to be sampled: 8 (from Permit) Monitoring Well Co Units CW-1 CW-2 CW-2D CW-3 CW-3D CW.4 Well Depth IN below land surface] it 39.75 17,50 29.90 11.40 4650 39.00 Measuring Point(toc) (X above land surfacel it 2.47 2.86 2.45 3.33 3.49 2.39 Well Diameter in 2.0 2.0 2.0 2.0 2.0 2.0 Screen Top [ft below land surface] it 19.95 7.70 25.10 3.40 41.70 24.20 soeen Sonom [X below land surface] it 39.75 17.50 29.90 11.40 46.50 39.00 Relative Measuring Point Elevation X 508.24 424.60 424.60 45179 1 451.61 479.65 Sampiinglakim at CHECK IF DRY WELL AT TIME OF SAMPLING ❑DRY ❑oRy ❑MY ❑DRY ❑MY DRY 1SA-2L Units CW-1 0011-2 CW-2D ON-3 CW-3D CW.4 Sample Date 04/24/2019 04/24/2019 04/24/2019 04/24/2019 04/24/2019 04/23/2019 Volume of Waterumed/bailed gat 0.50 0.50 0.75 1.00 0.40 3.00 Temperature (MID) deg. C 24.0 17.0 18.0 14.0 1&0 17.0 Odor(00085) SuNur M. None None None None Appearance ❑e. Clear Clear Clear Gear clew Turbidity182078) NTU 6.6 2.7 1.9 5.8 1.8 9.9 Dissolved Oxyen(00i m L 0.25 0.21 2.79 0.3 5.1 016 Oxidation Reduction Potential(013(1 mV 24 -53 30 107 111 27 Specific Cond - field 100094) umhos/tsn 698 95211 655 O83 566 595 Water Level[X below measuring pt.] 1925") X 17.84 I2A ]243 4.23 L1fi 28.35 PH -field 00400 6.5-8.5 5U 5.8 6.4 6,5 5.6 7.2 6.A 14bw~ Laboratory Name Sample Analysis Date Duke Energy Analytical laboratory April 24 - 30, 2019 IMACs 15A-1L Units CW-1 CW.2 CW-20 CW-3 CW-30 CWA TOS- Total Diss. Solids(70300) 500 m9A 480 540 420 290 360 360 G- Chloride (00940) Z50 mg/I 11 30 16 61 27 27 As-Arxnic(01002) 10 ug/I <1 <1 <1 <3 <1 <1 SOC-Sulfate(009451 250 owl 96 49 120 52 33 37 Nitrate N031 as N (00620) 10 m{/I <0.046 CIAS 0.37 0.04 4.023 0.32 Cd - Cadmium (01027) 2 u1/1 <1 <3 <3 <1 <1 <1 Cr- Chromium(01034) 10 ug/I b <5 b d <5 <5 Ca - Copper 1010421 1 mg/I 4.005 <0.005 <0.005 4.005 4.DGS 4.005 Fe-Iron(01045) 300 ug/I 33 46S <30 M <10 76 HIS -Mercury 171900) 1 u <0.05 4.05 <O.05 ADS <0.05 4.05 Man -Mumgm x(01055) so ug/I SS 515 <5 in 27 b Ni - Nickel (01067) too u914 b <5 <5 <5 b b Pit - Lead (BIDS1) is u&A <1 <3 <1 <1 <1 <1 Zn - Zinc 010921 1 mgQ 4.D05 <0.005 <0405 4.005 4.005 <0.005 Ba- Barium [01007) 700 USA 143 Its 153 105 44 130 B- Boron (01022) 700 ug/I b0 b0 <50 b0 60 b0 TI- Thallium 1010591 0.2 NE ug/I <01 4.2 4.2 4.2 <0.2 4.2 Sb-Antimony(01097) 1 ME ui <1 <1 <3 <1 <1 <3 Se - Selenium (01147) 20 ug/I <1 <I <1 <S <1 <1 Alkalinity -(00410) NE .611 258 387 201 97.7 230 229 AI- Aluminum(0110S) NE ug/I <10 161 <10 637 <10 116 Be- Beryllium (01012) 4 NE ug/I <1 <1 <3 <1 <1 <3 HCO3- Bicarbonate(00440) 1 258 387 201 97.7 23p ZZ9 Ca-Caidum(01I 49.8 52.2 47.6 310 75A 42.7 CO3- Carbonate(00445) I b b b <5 b d Co - Cobak (01037) 1 <1 <1 <1 <1 <1 <1 Mg -Ma esium(00927) 1 21.7 39.6 37.9 18.8 18.8 26.3 Mo- Molybdenum(03062) I RNEugn <I <I <I <1 2.56 5." K- Potassium(00937) 2,73 IA3 2.63 3.41 4,23 411 Na- Sodium (920351 I 77.3 96.6 37.2 32.0 19.1 "A TSS - Total Saw. Sofids 70031) b <5 b b b b V- Vanadium(01097) 0.31 18 14.2 13.0 2.12 202 237 A- Strontium(01082) I 0.512 OA59 0320 0.28] 0.ZH5 0.192 urn: NE - No<EsnbinnM BOLD values equal or exceed the corresponding 2L standard qwn wn:1-c a 1.clr r-Ir .,nv mm�aN �: neie I cerfify that, to Me b �sl of my Knowledge and �Ixef Me infionnziti,, �6'1'710'F is tme accurate, and c, hiplele, and that Me labori analytical and mripinsorment to �Jurfiowing violations, 77777 7i' c.P.L. Permittee (or ADMoriaed Agent) Name and Tide- Nease print or, type GW-59CCR 09/2015 'The IMACs were issued in 2010,2011, and 2012; however NCDEO has not established a 21. for hese constituents as described In ISAN 'Alkalinity, Bicarbonate, and Carbonate were subcontracted by Duke Energy Analytical Laboratory to Pace Analytical Services, LLC in Hu Mail and 1 Of WATER QUAILITIF - INFORMATION PR0aSsING UNIT TYPE OF PERAVITTED OPERATION BEING MONITORED Mah Intto.morarmt -action Infcontuation Weli ID Number (From Permit) 19.50 o ■ ■ ©�������:il Cdf]7�3�SiTiY1�1411tK'-� 3 approved meth, sby a DWQ- rtfied labo'A'>-; n; '-' -y :'-.;- _i ^,;!i ng false informa!bn rJudmo tce possibdiN of fines Oi L.0101([l. For tN6 reason. IMACs noted On fhe repms ere for reference only. rsuille, NC State of North Carolina Wam. a....... Department of Environmental Quality a Division of Water Resources EDMR REGISTRATION FORM NC Dept of Environmental Quality Part A. PERMIT/FACIUTY INFORMATION 1. NPDES Permit Number: N I C 10 10 10 13 14 12 15 1 APR 16 206 2. Owner/Organization Name: Duke Energy 3. Facility Name: Roxboro Steam Electric Plant C1g egtona Office 4. Facility's Physical Address: 1700 Dunnaway Road City: Sera State: NC Part B. OWNER USER INFORMATION 1. Responsible Official's Name: Steve Immel (Owner or duly authorized representative) 2. Mailing Address: 526 South Church Street r:_.. Charlotte c _ -. NC 3. Telephone Number: 980-272-8182 4. Email Address: steve.immet®duke-onergy.com 5. User ID (Assigned by NCOWR eDMR Administrator): PartC. USER ACCOUNT INFORMATION 1. Facility Administrator Permission Zip Code: 273343 26202 Title: VP Carolinas Coal Generation The Facility Administrator user permission can be assigned at the time of registration by the NCDWR eDMR Administrator. If someone other than the Owner will be responsible for managing facility users within eDMR and you would like the Division to set up the permission at the time of registration, then please provide the user details for the individual who will need the Facility Administrator user permission. Note: !f this person will be responsible forsubmitting eDMR reports, then you will also need to request Submitter permission for this user. In addition to the user details, please specify the permit number(s) to which the user will be associated. If additional space is needed, please make additional copies of the Facility Administrator User Details and complete as needed. Facility Admtnistrator User Details Permit NO. (s): NCOD03425 First Name: Robert Middle Name: Last Name: Howard Phone Number 3365984077 Email: robert.howard&ukeanergy.com User ID: PzVned by DMeDMR Adm/nhovror NC eDMR Registration Form (Revision 4.1) bi/ -AOf Flo M SIB /ydvno 10&.,v pk`l des " L,l oz j rt l /r M-2N V-W 4�Lp*v�p!o sr,elf /IV.�J 2. Submitter Permission Provide the users, in addition to the Owner, who will need Submitter permission. The Submitter user permission can only be assigned by the NCDWR eDMR Administrator. The Owner specified above will be given full eDMR permissions including Submitter permission. In addition to the user details, please specify the permit(s) to which each user will be associated for eDMR submittal. Should additional space be needed for users and/or permits, please make additional copies of this page and complete as needed. NOTE: The Owner will be responsible for creating all facility users except those with Submitter permissions. In addition to the Owner and Submitter user groups, there are four user types identified by user permission level: Facility Administrator, Certifier, Data Entry and View Only. The Owner and Facility Administrator will have the ability to create and manage facility users. The Facility User Management Guide, located on the eDMR User Documentation web page, provides the appropriate procedures for facility user management. Submitter User Details Permit No. (s): NC0003425 Rrst Name: Ton Middle Name: Last Name: Copoto Phone Number. 336-597.6101 Email: tom. oopolo@duk"nergy cam User ID-. I (Assioned by DWR eDMR Adminkbvtor) NC eDMR Registration Fonn (Revision 4.1) 2 RESPONSIBLE OFFICIAL AUTHORIZATION The Responsible Official, as identified in accordance with Part 11, Section B.11 of the Standard Conditions for NPDES Permits and 40 CFR 122.22, is the appropriate individual with the authority to sign applications or reports for the Owner/Organization. 1, StBVe Invw (printed name), have the authority to make this request for Dwro EnOWMOXbM seam Electric wm (Owner/Organization Name). REGISTRATION CERTIFICATION For the permit(s) associated with the Owner identified above, I request permission to submit DMR data using the NCD W R eDMR system. I understand that electronic submittal of the DMR does not fully satisfy US EPA's electronic signature requirements and as a result, I understand I will be required to print, sign, and submit hardcopies (one signed original and a copy) of the eDMR to NCDWR under the same reporting requirements as paper -based DMRs as specified in Part II, Condition D (2) of the NPDES Permit. I agree to protect the security of my user ID and password from compromise and shall take all necessary steps to prevent its loss, disclosure, modification, or unauthorized use. Steve Immel VP Carolinas Coal Generation Owner/Responsible Official Name (type or print) Official Title (type or print) Owner esponsible Official Signature Date North Carolina General Statute 4143-215.68 provides that: Any person who knowingly makes any fake statement, representation, or certification in any application, record, report, plan, or other document filed or required to be maintained under this Article or a rule Implementing this Article; or who knowingly makes a false statement of a material fact in a rulemaking proceeding or contested case under this Article; or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under this Article or rules of the Commission implementing this Article, shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed ten thousand dollars ($10,000). 18 U.S.C. Section 1001 provides a punishment by a fine or imprisonment not more than 5 years, or both, for a similar offense. NC eDMR Registration Form (Revision 4.1) 4� DUKE ENERGY. PROGRESS File: 12520 B NO Dept of Environmental Quality Ms. Julie Grzyb Division of Water Resources Water Quality Permitting Section - NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 APR 1 B 2019 Raleigh Regional Office Duke Energy Progress, LLC. Roxkom Steam Elearie Plant 1700 Dunnm Road Semora. NC 27343 April 2, 2019 Subject: Revision to Delegations of Authority for Duke Energy Progress, LLC, NC NPDES-Permitted Facility -Roxboro Steam Electric Plant Dear Ms. Grzyb: Duke Energy Progress, LLC, submits this correspondence as a revision to documentation for your records of responsible corporate officers ("Responsible Officials") and designation of duly authorized representatives ("Delegated Authorities") for the NPDES-Permit for the Roxboro Steam Electric Plant. We are requesting that Jason Haynes be removed as the Responsible Official and be replaced with Tom Copolo. We appreciate the timely update of the Division of Water Resources database to reflect this information so that we may begin submitting Discharge Monitoring Reports (DMRs), as required by our permit, in NCDEQ's eDMR system. No other changes are needed at this time. Duke Energy NPDES Permit Responsible Official Progress LLC Number Name - Title Roxboro Steam NC0003423 Tom Copolo - Electric Plant GM 11 Regulated Generation If you have any questions regarding these designations, please do not hesitate to contact Mr. Robert Howard at (336) 598-4077 or via email at Robert.Howard@Duke-Energy.com. Sincerely, Steve Immel, VP Carolinas Coal Generation Attachment: eDMR Registration forms cc: Raleigh Regional Office - NCDEQ eDMR Registration DUKE ENERGY. PROGRESS bc: Mr. Ryan Enoch Mr. Lori Tollie Mr. Amber Sarver Mr. Robert Howard Mr. Don Safrit Duke EMW PeogrM LLC Roxbom S1eme Ekmic P&W 1700 Duwaway Road Semom NC 27343 Manuel, Vanessa From: Howard, Robert E <Robert.Howard @duke-energy.com> Sent: Tuesday, April 02, 2019 2:02 PM To: Manuel, Vanessa Cc: Kinney, Maureen Subject: [External] RE: Roxboro Steam Electric Power Plant, NC0003425 - Removing Designated Operators Maureen, Please remove the below referenced back up ORCs listed below from the Duke Energy Roxboro Steam Electric plant. Contact me if any additional forms are needed to complete this action. Thanks Robert E. Howard Lead EHS Professional Environmental Field Support Roxboro Steam Plant 336-203-2875 DUKE MRGY. From: Manuel, Vanessa [mailto:vanessa.manuel@ncdenr.gov] Sent: Thursday, February 21, 2019 12:40 PM To: Enoch, Ryan S. < Ryan. Enoch @duke-energy.com>; Howard, Robert E <Robert.Howard@duke-energy.com>; Tollie, Lori White <Lori.Tollie@duke-energy.com>; Sarver, Amber Michelle <Amber.Sarver@duke-energy.com> Cc: Kinney, Maureen <Maureen.Kinney@ncdenr.gov> Subject: Roxboro Steam Electric Power Plant, NC0003425 - Removing Designated Operators *** Exercise caution. This is an EXTERNAL email. DO NOT open attachments or click links from unknown senders or unexpected email. *** All — During the recent NPDES inspection, you indicated the individuals listed below were no longer designated backup operators at the plant. To update this information in the Division's data system, someone with the organization will need to send an email to Maureen Kinney with the Operators Certification unit (she is copied on this email) or complete the online Operator Designation - Expiration/Resignation Form. See link below to access the form. If you have any questions, please feel free to contact me. Link to form: https://deg.nc.gov/about/ pns/water-resources/operator-certifica_.-.., wastewater-operator- certification/wastewater-operator-certification-downloads Designated Backup Operators no longer with Roxboro Steam Electric Power Plant (NC0003425): 1. Ronald D. Easley 2. Dana Hill Newcomb 3. Eric Daniel Satterwhite Maureen, during the inspection, it was noted that a name correction for an existing backup operator is needed in the Operator Certification data system. Amber Michelle Ramey needs to be updated to Amber Michelle Sarver. If Amber needs to provide additional information to you or complete a specific form, please let me know. Thanks. Vanessa E. Manuel Environmental Program Consultant Division of Water Resources — Raleigh Regional Office Department of Environmental Quality 919 7914255 office vanessa. man uel(c?ncdenr.00v Physical: 3800 Barrett Drive, Raleigh, NC 27609 Mailing: 1628 Mail Service Center, Raleigh, NC 27699-1628 !'"Nothing Compares Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Manuel, Vanessa From: Sent: To: Subject: Attachments: xternal emai MMEWmffn:ov Hi Vanessa, Tollie, Lori White <Lori.Tollie@duke-energy.com> Monday, March 25, 2019 8:49 AM Manuel, Vanessa (External] Roxboro Steam Station Submerged Flight Conveyor Startup Roxboro SFC startup Letter 03_2019.pdf A(000 0 3 42 S The attached letter was mailed to DEQ on Friday to document the completion of construction and startup of the submerged flight conveyor (SFC) at Roxboro. The SFC will handle bottom ash as we continue to remove flows from the ash basin and reroute them to the new lined retention basin. I will be happy to mail you a hard copy also if you would like. Thank you. Duke Energy EHS CCP Permitting & Compliance 2500 Fairfax Road Greensboro, NC 27407 Cell: (336) 408-2591 Office: (336) 854-4916 DUKE ENERGY March 21, 2019 Mr. Jeff Poupart, Section Chief NC DWR Permitting Section 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: Installation of Submerged Flight Conveyer Roxboro Steam Station Permit #NC0003425 Person County Dear Mr. Poupart: Duke Energy EHS CCP Environmental Programs 411 Fayetteville St, 15th Floor Raleigh NC 27601-1849 In accordance with requirements found in state and federal laws, Duke Energy is re-routing bottom ash sluice wastewaters away from ash basins. To continue to handle these wastestreams, Roxboro Steam Station is installing a Submerged Flight Conveyer (SFC) for the dry handling of bottom ash. This change was communicated to your office as part of the pending NPDES permit application dated August 15, 2016. The installation of the new SFC will be completed in this month. This letter is intended to provide notification of the process startup and redirection of the wastewater prior to receipt of final NPDES permit. This is consistent with guidance received by our staff on January 3, 2018 from Sergei Chernikov. Bottom ash from the boilers will be collected in water filled troughs for transfer to the SFC to direct the bottom ash wastewater away from the ash basin. Overflow water from the SFC trough is captured, cooled, and recirculated. The SFC is designed with a blowdown system for the overflow water to be discharged to the Flu -Gas Desulfnization wastewater treatment system (FGD WWTS) as needed. Federal Effluent Limitation Guidelines (ELGs) contain allowance to route bottom ash transport water overflows from the SFC to the FGD WWTS. Additionally, small, incidental flows from the SFC may be sent to the ash basin or Lined Retention basin (once in service). The FGD WWTS discharges to NPDES internal outfall 010, then to the west ash basin internal outfall 002, finally discharging to NPDES outfall 003. In conclusion, the startup of the SFC will decrease the pollutant load and flow volumes of the ash basin discharge. The startup of the SFC is a necessary step in the process or re -directing process wastewater flows away from the ash basin as we proceed with activities to comply with various statutory requirements. It is our understanding from previous discussions with your staff that no additional approvals are necessary beyond this notification. If there are any questions about this matter, please Lori Tollie at (336) 854-4916. Sincerely, Lori Tollie Senior Environmental Specialist cc: Sergei Chemikov—NC DWR 1617 Mail Service Center Raleigh, NC 27699-1617 Shannon Langley - via email Richard Baker - via email Julie Grzyb — NC DWR 1617 Mail Service Center Raleigh, NC 27699-1617 �? DUKE ENERGY, March 14, 2019 Ms. Sheila Holman Assistant Secretary NC Department of Environmental Quality 217 West Jones Street Raleigh NC 27603 RE: Startup of treatment components Internal process flow modifications Roxboro Steam Electric Plant NC0003425 Person County Dear Assistant Secretary Holman, Paul Draovitch, P.E. Senior Vice President Environmental, Health 8 Safety 526 S. Church Street Mail Code. EC3XP Charlotte, NC 28202 (704) 382-4303 XC Dept of Environmental Quality Raleigh Regional Office This letter is to provide details about the forthcoming startup of required treatment components at the subject facility. Between the date of this letter and April 12, Duke Energy intends to complete final commissioning of the newly constructed Lined Retention Basin ("LRB"), divert certain waste streams from the ash basin to the LRB, and begin discharging from the LRB to wastewater treatment system upstream of Outfall 003. It is our understanding, based on language in the existing NPDES permit and on previous discussions with you and your staff, that these changes can be implemented without a new or modified permit because they are internal to the system and do not materially affect the quality of the water discharged. In accordance with the North Carolina Coal Ash Management Act's mandate to discontinue the use of ash basins for wastewater treatment and a comparable requirement in the Federal CCR Rule, Duke Energy has constructed replacement treatment systems for low volume waste and other wastestreams that will continue to be generated in the future. These replacement systems, commonly called "Lined Retention basins" or "LRB's" were constructed to replace ash basins at sites that will remain active and generate electricity using coal as a fuel source. Discharges from LRBs have been included in NPDES permits recently issued for other Duke Energy generating stations where LRB replacement treatment for ash basins has been constructed. The LRB replacement treatment system at the Roxboro station is nearing completion of construction and will be ready for commissioning and use very soon. As previously shared with your office, Duke must cease all flows into the existing ash basin at the Roxboro plant by April 12 to comply with requirements in the Federal CCR rule. To comply kith this requirement, Duke must complete commissioning of the Roxboro LRB and divert remaining waste streams from the ash basin to the LRB. Duke intends to undertake the following activities at Roxboro to begin use of the new LRB and discontinue sending flows to the ash basin under the existing permit. Final commissioning of the LRB system components will be undertaken using service water. Service water is water withdrawn from Hyco reservoir. Ms. Sheila Holman March 14, 2019 Page 2 2. After final construction checks using service water, Duke intends to redirect influent flows from the ash basin to the LRB and place the LRB into service at Roxboro. For clarity, this LRB system will only receive flows that previously were directed to the ash basin and no new flows are included. Some flows have been removed (e.g. routine bottom ash sluice waters) but no new sources of wastewater are present that were not previously directed to the respective sites ash basins for treatment. 3. Flows from the LRB at Roxboro will be reintroduced into the wastewater flow path prior to outfall 003 to the Hyco reservoir. The internal outfall has been constructed and includes a diffuser system to assure rapid and complete mixing with other wastestreams prior to discharge. As the flows at Roxboro, will not commingle solely with flows from the existing ash basin before being commingled with cooling water flows, Duke will sample the Roxboro LRB to demonstrate that discharges from the system meet Steam Electric Effluent Guidelines for TSS and Oil and Grease. Duke will also sample the LRB discharge for all constituents required to be sampled for the ash basin in our NPDES permit. These internal sample results will be reported as an attachment to our monthly required NPDES Discharge Monitoring report. Duke Energy appreciates your agency's assistance as we have completed an unprecedented amount of modifications at our coal fired facility's over the last few years. The compliance deadlines associated with the North Carolina Coal Ash Management Act and Federal CCR rule have been aggressive and required significant effort and expenditures comply with. Duke Energy is focused on safely closing ash basins in ways that are dictated by science and engineering and the work described in this submittal is being undertaken with that common goal in mind. Duke Energy hereby requests your concurrence with this action with the understanding that this action is being undertaken under the conditions of the existing permit and is not intended in any way to be binding on future permitting decisions or terms currently under review by the Department. If there are any questions about this matter, please contact Mr. Shannon Langley at (919) 546- Senic Duke Energy Ms. Sheila Holman March 14, 2019 Page 3 Cc: RRO DEQ WQ Supervisor 3800 Barrett Drive Raleigh, NC 27609 Jeff Poupart — DWQ Section Chief 1617 Mail Service center Raleigh, NC 27699-1617 Shannon Langley —via email Lori Tollie - via email Manuel, Vanessa From: Tollie, Lori White <Lori.Tollie@duke-energy.com> Sent: Thursday, March 07, 2019 2:12 PM To: Manuel, Vanessa; Howard, Robert E; Sarver, Amber Michelle; Enoch, Ryan S. Subject: [External] Roxboro Compliance Evaluation Inspection outfall 003 Attachments: GoogleEarth Imagejpg; Compliance Evaluation Inspection Roxboro NPDES Permit NC0003425.pdf �E�SJnf Cvr�..7 Vanessa, This email is a follow up to the voicemail I left for you earlier today concerning the sampling location for NPDES outfall 003 at the Roxboro Station. I have included a Google Earth image of Duke's proposed new location for reference. The Roxboro station will be placing a new floating dock/sampling station on the East side of the fence at outfall 003 rather than request the sampling location be changed. We realize that the sampling location needs to be safe, accessible, and be representative of the wastewater after all treatment but prior to discharge to the reservoir. We feel that this new location will achieve these requirements. Please let me know if I can answer any questions or if we need to discuss further. I can provide a latitude and longitude on the new sampling location to your office and to the Complex permitting unit after completion. Thank you. X�nAr.Yf& Duke Energy EHS CCP Permitting & Compliance 2500 Fairfax Road Greensboro, NC 27407 Cell: (336) 408-2591 Office: (336) 854-4916 DG �!! 003 EA OOPER EL S. REGAN Secretary LINDA CULPEPPER Director Paul Draovitch, Senior VP Duke Energy Progress, LLC 526 S Church Street — Ec3xp Charlotte, NC 28202 NORTH CAROLINA Environmental Quality February 25, 2019 Subject: Compliance Evaluation Inspection Roxboro Steam Electric Power Plant NPDES Permit NC0003425 Person County Dear Mr. Draovitch: r'! r- J a Z -ZT^rq On Tuesday, February 19, 2019, Vanessa Manuel of the Raleigh Regional Office conducted a compliance evaluation inspection of the treatment facilities located at the Roxboro Steam Electric Power Plant. The purpose of this inspection was to ensure compliance with the subject NPDES permit. During the inspection, the presence and cooperation of Ryan Enoch, Operator in Responsible Charge (ORC), Amber Sarver and Robert Howard, Backup ORCs, and Lori Tollie were helpful and appreciated. The Roxboro Steam Electric Power Plant is located at 1700 Dunnaway Road in Semora, North Carolina. The facility has both a Grade II Biological Water Pollution Control System with an as - built and permitted flow of 0.015 MGD that treats domestic wastewater, and a Grade I Physical/Chemical Water Pollution Control System that treats industrial wastewater. Through NPDES permit NC0003425, Duke Energy Progress, hereinafter referred to as Duke Energy, is authorized to discharge the treated wastewater through outfalls 003 and 006 to receiving waters designated as Hyco Lake, a waterbody classified as WS-V and B waters within the Roanoke River Basin. This NPDES compliance evaluation inspection consisted of the following: • Review of the NPDES permit; • Review of the owner/facility information; • Review of December 2016 — November 2018 monitoring data; • Review of December 2016 — November 2018 compliance history; • On -site inspection of the laboratory and wastewater treatment units; and • On -site inspection of the discharge outfalls. cr,e­ D;.� Q North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional Office 1 3800 Barrett Drive I Raleigh. North Carolina 27609 919.791.4200 If } Duke Energy Progress, NPDES Permit NCO003425 February 25, 2019 Page 2 of 3 Findings during the pre -inspection file review were as follows: 1. The current NPDES permit was issued effective May 1, 2007, modified effective June 10, 2009, and expired March 31, 2012. On September 28, 2011, the Division received Duke Energy's permit renewal application for the Roxboro Steam Electric Power Plant. The Division is in the process of renewing this NPDES permit. 2. As listed in the subject pen -nit, the treatment systems include the Ash Pond Treatment System (Internal Outfall 002), Heated Water Discharge Canal System (Outfall 003), Cooling Tower Blowdown System (Internal Outfall 005), Coal Pile Runoff Treatment System (Outfall 006), Domestic Wastewater Treatment System (Internal Outfall 008), Chemical Metal Cleaning Treatment System (Internal Outfall 009), and Flue Gas Desulfurization Treatment System (Internal Outfall 010). 3. Beginning December 21, 2016, EPA's NPDES Electronic Reporting Rule requires permittees to submit their discharge monitoring reports (DMRs) electronically, instead of on paper. Duke Energy has been using the Division's eDMR system to electronically report the subject facility's monitoring data beginning with its November 2016 DMR. To learn more about the eDMR system, please visit the Division's eDMR website at httos://deq.nc.poN"about/divisions/water-resources/edmr. 4. For the review period December 2016 through November 2018, the following violation was detected: Total Suspended Solids daily maximum limit exceeded on October 10, 2018. The Division issued a Notice of Violation for this violation. No penalty assessments have been issued during the period of review. For the 2-year period ending November 2018, Duke Energy has been compliant with its Whole Effluent Toxicity limit and monitoring requirements. Findings during the inspection were as follows: 5. The operator's log and supporting analytical documentation were consistent and up to date. 6. The Roxboro Steam Electric Power Plant on -site laboratory is field certified for and self - reports monitoring data for the following parameters (certification number 5080): pH and temperature. Duke Energy uses its off -site environmental laboratory, Duke Analytical Lab (certification number 248), to analyze the remaining parameters required by the permit. Samples analyzed off -site are stored in the sample storage refrigerator until transported off - site. The inspector observed the temperature of the refrigerator at 3.1 degrees Celsius, which is in compliance with the requirements of proper temperature for sample storage. The inspector reviewed the sample storage temperature logs, pH meter calibration logs and standards, and found these items to be compliant with record -keeping requirements. The in- house thermometers are NIST certified and replaced annually. 7. The inspector compared the February 2018 DMR data against the labs' analytical results. No discrepancies were noted. A review of the associated chain -of -custody forms showed documentation complete and compliant with record -keeping requirements. Duke Energy Progress, NPDES Permit NC0003425 February 25, 2019 Page 3 of 3 8. The inspector observed all outfalls during the inspection. For Outfal1003, the NPDES permit requires the permittee to perform the effluent sampling on the discharge canal at the point of discharge into Hyco Lake. Duke Energy has installed a fence that spans the length of the discharge canal and separates the Heated Water Discharge Canal System from Hyco Lake. The operators monitor temperature continuously from a thermometer mounted on the fence and submerged into the effluent discharge. Samples for the remaining effluent parameters are taken from the dock over Hyco Lake approximately 15-feet from the effluent discharge, which may not meet the sampling location requirements of the NPDES permit. As the inspector discussed with Lori Tollie, Duke Energy should contact the Division's NPDES Permitting Unit and discuss the possibility of changing the sampling location for Outfall 003. No other compliance issues were observed at the time of the inspection. 9. All domestic wastewater is treated by a package treatment plant with chlorine tablet disinfection. The effluent from the package plant goes to the Ash Pond Treatment System. No issues of concern were observed with the package treatment plant. If you have questions or comments about the inspection, this report or the requirements to take corrective action (if applicable), please contact Vanessa Manuel at 919-791-4255 or via email at Vanessa. Manuel Camcdenr. eov. Sincerely, Rick Bolich, L.G., Assistant Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Attachments: EPA Water Compliance Inspection Report Cc: RRO/SWPFiles Laserfiche U.1ad States Environmemal Protection Agency Form Approved. EPA Washington. D C. 20460 OM6 No. 2040-0057 Water Compliance Inspection Report Approval expires 6-31-98 Section A: National Data System Coding (i.e., PCs) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 I„ I 2 IS I 3 I N00003425 I11 12 19,02/19 17 18 L] 19 1 � I 201 I 211 1 1 I1 11 I1II III II I I I I I 111111111 11I26 Inspection Work Days Facility Self -Monitoring Evaluation Rating B 1 CA Reserved 70 LJ 71 I 72 r 73I 74 75L I I I80 67 L ..... .... j 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) 10:05AM 19/02/19 09/07/01 Roxboro Steam Electric Power Plant Exit Time/Date Permit Expiration Data 1700 Dunnaway Rd Senor NC 27343 01 05PM 19/02119 1203/31 Name(s) of Onsite Repreaentative(syrndes(s)/Phone and Fax Numbers) Omer Facility Data Ryan Stephen Enoch/ORC/336-598-7609/ Name, Address of Responsible Of6cial/Ti9e/Phone and Fax Number Je So ( y-y'les r rile-'i .•fav"." kr-' . Contacted M,N9mr7'Rrarker,1700 Dunnaway Rd Semora NC 27343/Plant Manager/336-597.6101/ Yes Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Operations & Maintenance Records/Reports Self -Monitoring Program Facility Site Review EfftuenVReceiving Waters Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(e) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Vanessa E Manuel RRO WO//B10 087699V �. 7—i9 9i9-f9/-4153 �20, Signature of Ma agement 0 A Reviewer Agency/ORcs/Phone and Fax Numbers D to �I EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Pageli NPDES yr/mo/day Inspection Type N00003425 121 19/02119 17 18 I C I Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checidists as necessary) See attached inspection report. Page# Permit.- NC0003425 Owner - Facility: Roxboro Steam Electric Power Plant Inspection Date: 02/19/2019 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 0 ❑ ❑ ❑ application? Is the facility as described in the permit? ❑ ❑ ❑ # Are there any special conditions for the permit? 0 ❑ ❑ ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? M ❑ ❑ ❑ Comment: The current NPDES permit expired on March 31 2012. The Division received the oermittee's renewal application on September 28, 2011. Record Keeoina Yes No NA NE Are records kept and maintained as required by the permit? 0 ❑ ❑ ❑ Is all required information readily available, complete and current? 0 ❑ ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? 0 ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? 0 ❑ ❑ ❑ Is the chain -of -custody complete? M ❑ ❑ ❑ 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? 0 ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ M ❑ (If the facility is = or > 5 MGD permitted Flow) Do they operate 24n with a certified operator ❑ ❑ 0 ❑ on each shift? Is the ORC visitation log available and current? 0 ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? 0 ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility classification? 0 ❑ ❑ ❑ Is a copy of the current NPDES permit available on site? ❑ ❑ ❑ 0 Facility has copy of previous year's Annual Report on file for review? ❑ ❑ M ❑ Comment: The permitted facility is classified as both a Grade II Biological Water Pollution Control System and a Grade I Physical/Chemical Water Pollution Control System The ORC Ryan Enoch, possesses valid certificates for WW-3 and PC-2 treatment systems and each Backup ORC is certified at the appropriate type and grade for the treatment systems. Page# 3 PermlL• NC0003425 Owner • Paclllty: Roxboro Steam Electric Power Plant Inspection Dab: 02/192019 Inspection Type: compliance Evaluation Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? 0 ❑ ❑ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? M ❑ ❑ ❑ # Is the facility using a contract lab? ❑ 0 ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees M ❑ ❑ ❑ Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+f- 0.2 degrees? ❑ ❑ ❑ Incubator (BOD) set to 20.0 degrees Celsius +1- 1.0 degrees? ❑ ❑ ❑ Comment: The on -site lab is field Parameter certified (certificate # 5080) and lab personnel analyzes PH and temperature. All other required parameters are analyzed by the permittee's off -site lab, Duke Analytical Lab (certificate # 248). Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? M ❑ ❑ ❑ Does the facility analyze process control parameters, for exMLSS, MCRT, Settleable ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Bar Screens Type of bar screen Yes No NA NE a.Manual b.Mechanical ❑ Are the bars adequately screening debris? M ❑ ❑ ❑ Is the screen free of excessive debris? 0 ❑ ❑ ❑ Is disposal of screening in compliance? N ❑ ❑ ❑ Is the unit in good condition? 0 ❑ ❑ ❑ Comment: The package wastewater treatment plant is relatively new and treats domestice wastewater. Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? ❑ ❑ 0 ❑ Are weirs level? 0 ❑ ❑ ❑ Is the site free of weir blockage? 0 ❑ ❑ ❑ Is the site free of evidence of short-circuiting? 0 ❑ ❑ ❑ Is scum removal adequate? 0 ❑ ❑ ❑ Is the site free of excessive floating sludge? 0 ❑ ❑ ❑ Page# 4 Permit: NC0003425 Owner -Facility: Roxboro Steam Electric Power Plant Inspection Date: 02/19/2019 Inspection Type: Compliance Evaluation Secondary Clarifier Yes No NA NE Is the drive unit operational? ❑ ❑ ❑ Is the return rate acceptable (low turbulence)? ❑ ❑ ❑ Is the overflow Gear of excessive solids/pin floc? ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately Y, of the sidewall depth) ❑ ❑ ❑ Comment: Part of the Package treatment plant. Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? 0 ❑ ❑ ❑ Are surface aerators and mixers operational? ❑ ❑ E ❑ Are the diffusers operational? ❑ ❑ ❑ Is the foam the proper color for the treatment process? ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? 0 ❑ ❑ ❑ Is the DO level acceptable? ❑ ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mg/1) ❑ ❑ ❑ Comment: Part of the package treatment plant Disinfection -Tablet Yes No NA NE Are tablet chlorinators operational? ❑ ❑ ❑ Are the tablets the proper size and type? ❑ ❑ ❑ Number of tubes in use? 1 Is the level of chlorine residual acceptable? 0 ❑ ❑ ❑ Is the contact chamber free of growth, or sludge buildup? 0 ❑ ❑ ❑ Is there chlorine residual prior to de -chlorination? ❑ ❑ 0 ❑ Comment: De -chlorination is not used Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ ❑ 0 ❑ Is sample collected below all treatment units? 0 ❑ ❑ ❑ Is proper volume collected? ❑ ❑ ❑ Is the tubing clean? ❑ ❑ ❑ E Page# 5 Permit: NC0003425 Owner • Facility: Roxboro Steam Electric Power Plant Inspection Date: 02,'19/2019 Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees 0 ❑ ❑ ❑ Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type ❑ ❑ ❑ representative)? Comment: For outfall 003 the composite sampler is set up at the time of sample collection to collect a quarterly toxicity sample During the inspection the composite sampler was not set up Upstream / Downstream Sampiina Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and M ❑ ❑ ❑ sampling location)? Comment: Stream monitorinq for temperature is performed to meet the mixing zone requirements of Special Condition A. (12). Effluent Pipe 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? 0 ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ Comment: The facility has 2 effluent outfall pipes (003 and 006) and 5 internal outfalis (002, 005, 006. 009 and 010) that eventually discharges to the heated water discharge canal system (outfall 003), Page# 6 Inspection Age,,,, — Roxboro Steam Electric P.er Plant, NCO003425 2019Feb19 Opgning Conference JPurpose of inspection Flow of inspection V Overview of plant layout (treatment components) Per it Requirements NPDES WW Contacts Report J • Permit status /• Electronic reporting -1"eDMR. November2016 • Other Laboratory / n / ✓ • Analytical lab(s): Duke Analytical Lab (cert. # 248) • Fe4oe c v4,`/;Co( Sd�Ci ✓/• Parameters analyzed on -site PH 111'c"P; 11)� cc I" ,a..,,,eyrr rw 0-/4VI2 V • Field Parameters- Inspectors' Checklist FY * -}gyp, f • Meter calibration logs and standards -Calibration frequency ✓• Analytical bench sheets �/• Thermometer calibration dates) - NIST certified in-house thermometers ZY_ C"I Ai �rh, 2CiCA it, (LailPiper Trail - Data Comparison (LData to DMRs) ✓ • Review period:'] ec. J 2d(o-✓r� �)%3 • Selected DMRs (n=2 max.): F4.20(g NJ �sQi5Oa..U•�-4- Tre/a�tnent Components ORC logbook La/ ov / %f Treatment unit observations Backup Generator • Run schedule • Auto switch on i run under load? Flow Measurement / • Meter calibration date 2een11 p ID 9pPt�r�� Mar (u j�Art�i 9t� Sample Collection / K C�'`b '�*d r� 4ggU, P)n ct-,, J�t E yr SrtIeV;CF i, e/ • Composite sampler- program setup ✓• Sample storage temperature Reviews pier temperature logs • Tubing appearance,- Kr-[ E✓�✓u� — �� ,��r+� ��f S� f • Sample handling after collection Receiving Waters �KE • Appearance !l~I(o Cling Conference �• Findings ✓• Expectations I I P a g e ,WtVer, ID;OSA Z112/Z.>/-2----- S— Rrq�, p1 3 �0 7 �i.. ✓/i.-��/•1 or.:JY �in ✓I' , i�I P (—�J' , Q�— ,�,,��,hL _mot 0 Q-vE 2%i9.� tT �`/ (t����s__.C_��f_- r`ME • �j�.gp vG -�,�� inr:-f�•a,/s dJ r Y s•4 •�'a it P1,r.�� v -NA T C1of�Sc�vf� 'J rr �•� Ck- v 8 - - -.. L S', f) (>,4.Fou (a0z , 'K64Y ,O 1*CC+ny � r[� I Gxti� 6c 4a s%,Ac,, Suk'%►cF fFYO. Jf ob - NC0003425 - Roxbc... steam Electric Friday, October 12, 2018 8:12 AM Owner / Facility Names: Duke Energy Progress LLc / Roxboro Steam Permit Number. Electric Power Plant Last inspection conducted: 4/27/2017 Inspector. Note/Comment: EPA Major Inspection Assigned(FY/QTR): FY19/Q2 Basic Facility Information ORC: Ryan S. Enoch (WW-3 & PC-2) Certification active Certification inactive No designated ORC Note comment J Annual feels) paid Annual feels) overdue Note comment NC0003425 County: Person Stephanie Goss Planned Inspection Date: 2/19/2019 (10:00 am) 7 Facility Treatment Classification: Biological Water Pollution Control System (W W-2) & PC-1 As -Built Flow / Permitted Flow: 0.015 MGD / 0.015 MGD Backup Operator(s): Chris G. Clayton, W W-2 & PC-1 W Certification active Certification inactive Kevin D. Clayton, W W-2 & PC-1 J Certification active [ Certification inactive Receiving Waters Current Permit: Effective 7/1/2009 - 3/31/2012 Stream: Hyco lake _ Active, >180 days until permit expire Classified: WS-V & B — Active, will expire within 180 days River Basin: Roanoke Expired, renewal application received timely Expired, renewal application overdue Treats: 50% domestic and 50% industrial wastewater Inspection Prep To Dos: Schedule inspection site vi i Notelcomment On 21512019, scheduled site visit w/ / ORC ViY Review last inspection report Review permit file '� Generate BIMS reports: Permit Enforcement History and MR Violations (2-yrs of data) C✓� Pull 2-yrs. of DMRS (Dec. 2016 - Nov. 2018) enerate NPDES WW Permit Contacts Report Prepare inspection agenda Enter inspection into BIMS Prepare inspection letter/report Renewal application received September 28, 2011 Permit reviewer.' Teresa Rodriguez (retired) Facility Contacts: Name Affiliation Jason Haynes, Plant Manager Facility & Permit Contact Phone Number Email 336-597-6101 lody.thackw@dukeemrgy.com �RyyanfS. Enncxh,, ORC 336-598-76099,,,,� Ryan.enoch@duke-energy.com NPDES W W Majors Page I North Carolina Department of Environmental Quality Division of Water Resources Permit Number: NC0003425 Permit Type: Industnal Process & Commercial Wastewater Discharge Facility Name: Roxboro Steam Electric Power Plan[ Facility Addressl: 1700 Dunaway Rd Facility Addressl: City, State & Zip: Semora. NC 27343 Owner Information Details: MUST submit a Change of Name/Ownership form to DWR to make any changes to this Owner information. (Click Here for "Change of Name/Ownershio"Form) Owner Name: Duke Energy Progress LLC Owner Type: Non -Government Owner Type Group: Organization *** Legally Responsible for Permit *** (Responsible corporate officer/principle executive officer or ranking elected official/general Partner or proprietor, or any other person with delegated signatory authority from the legally responsible person.) Owner Affiliation: Paul Draovdch Title: & EH S Senior VP Addressl: 526 S Church St - EQa Addressl: City, State & Zip: Charlotte. NC 28202 Work Phone: 980-373-0408 Fax: Email Address: Paul Draovitch(alduke-enerov com Owner Contact Person(s) Contact Name rttlfl Adder Phone EM Email Tam Copolo /Manager %ant ( 0660 Boston Rd, Roxboro, NC 27574 336-597-7307 tom.cope-e olo@duknergy. f r✓ ff�( tz./O �C^^ Corr Facility Contact Person(s) Contact Name rl112 Address Phone fax Email 4' .il. Idaaagerf`IaM 1700 Dunnaway Rd, Semora, NC 336-597-6101 27343 arom— ✓lason Haynes �a vr� ,.Ar' 491 Energy Way, Hamlet, NC 28345 Jmn.haynes@duke-energy 3 l O/ Permit Contact Contact Name rift Address Phone fag Laid Yc •' Manager Ra^- 1700 Dunnaway Rd, Semora, NC 27343 336-597-6101 .igdy H+=rkcrrnld,ba-cnargy. Permit Billing Contact Person(s) Contact Name Tit g Address Phone Fpx Email Cynthia Winston 410 S Wilmington St NCrhIS, Raleigh, 919-546-5538 NC 27601 -i- /(v k'ntey— ",)[ t cr9 y 2/5/2019 Page 1 Permit Number: NC0003425 Permit Type: Industrial Process & Commercial Wastewater Discharge Facility Name: Roxboro Steam Electric Power Plant Facility Addressl: 1700 Dunnaway Rd Facility Address2: City, State & Zip: Semora, INC 27343 Persons with Signatory Authority Type Contact Name Title Address Phone Fax €hill Permit Andy Solomon Operations 1700 Dunnaway Rd, Semora, 336-597-6136 andy.solomon@duke-ener Superintendent NC 27343 gy.com Permit Robbie 1700 Dunnaway Rd, Semora, 336-598.4038 robbie.chamers@dukeen Chambers NC 27343 erpv.com Permit Ryan Stephen 2039 Elder Rd, Nathalie, VA 336-598-7609 ryan.enoch@dukeenergy Enoch 24577 .Wm 2B6f8704 704=387473T ShanneRrFaddCaBMake-ene r(jv.com Permit Jason Haynes 1700 Dunnaway Rd, Semora, NC 27343 Permit Lucas Henderson 1700 Dunaway Rd, Semora, NC 27343 Permit Alan E Madewell Dir Field Support 526 5 Church St, Charlotte, NC alan.madewell@duke-ener Designated Operators if the designated operators listed below are incorrect orfro longer associated with Me collection system, the information can be updated by submitting a completed "Operator Designation Form"(Dick Here for ORC Desmnabon Forrrrl. Please provide specific debits as to the changes requested, including the addition/removal of designated operators. For all otlrer operator questions orissue; please call 919-807-6353. Facility Classification: PC1 Operator Name B212 Cert Type Cart c��e.�� Cert # Effective Date Ryan Stephen Enoch ORC PC-2 Active 1007136 T 12/13/2018 Chris G. Clayton Backup PC-1 Active 989418 C 5/23/2011 Kevin Danny Clayton Backup PC-1 Active 1005543 1/1/2019 Aeaald-�EasieT- Backup PC -I Active 989628 2/10/2009 Robert Earl Howard Backup PC-1 Active 985778 2/10/2009 William Edward Milam Backup PC-1 Active 28546 2/10/2009 Bane-HiN-Newcemk_., Backup PC-1 Active 989611 5/1 W01I Amber Michelleµamey-, Sq ,Q l��y2 Backup PC-1 Active 991238 1/7/2013 Backup PC-1 Active 985810 10/1/2016 Facility Classification: lVW2 Operator Name $pig Cert Type Cert Status Cert # Effective DafB Ryan Stephen Enoch ORC WW-3 Active 1004802 1/1/2019 Chris G. Clayton Backup W W-2 Active 985915 5/18/2016 Kevin Danny Clayton Backup WW-2 Active 1006784 1/1/2019 Robert Ead Howard Backup W W-2 Active 13403 5/18/2016 William Edward Milam Backup WW-2 Active 23490 5/18/2016 Amber Michelle P." Backup WW-2 Active 992112 5/18/2016 Backup WW-3. Active 989354 10/1/2016 Derrick Antonio Smith Backup WW-3 Active 1005215 9/14/2017 2/5/2019 Papa 2 I r C" 1:') 7p-C ��"� / t laO �t rr /J �,- L boi--Jde%tz,� SY� K-• - ��C"a�L- t/01) -�Nj 0.4,�« P505) (it r Q -b6NE5a,c W v T ealwtt tf sy , 1� �y ycrl GE M' Oro 4, LAV'� CO �oK 5IFeCx ,W) fi 0457 �1 ,4r«0034f2s 7REA�+E7(� G.,: { S�7onC�se ✓fi+� %LrL.121;?v/.j /3JyYn✓c S%Q.n F/FrAr MONITORING REPORT(MR) VIOLATIONS for: Report Date02/12/19 Page: 1 of 1 Permit: nc0003425 MRS Between 12 - 2016 and 11 - 2018 Region: Raleigh Violation Category:% Program Category: NPDES Vvw Facility Name' % Param Name % County: % Subbasin: % Violation Action: % Major Minor: % A PERMIT: NC0003425 FACILITY: Duke Energy Progress LLC - Roxboro Steam Electric COUNTY: Portion REGION: Raleigh Power Plant Limit Violation MONITORING OUTFALL/ VIOLATION UNIT OF CALCULATED % REPORT PPI LOCATION PARAMETER DATE FREOUENCY MEASURE LIMIT VALUE Over VIOLATION TYPE VIOLATION ACTION 10.2018 006 Effluent Solids, Total Suspended - 10/10/18 2 X month mgfl 50 56 12 Daily Maximum Proceed to NOV Concentration Exceeded t)20 r[. - Y�o✓ 20, �3 Lr /�c �eT��l4% ACX ss."aIrk rev✓-ZoiB-LV- vg yq (Ko e4cA-al) Whole Effluent Toxicity Testing and Self Monitoring Summary Duke Energy Lee Steam/003 NC0003417/003 County: Wayne Fthd24Ac Begin: 10/1/2030 24hr LCSO ac monit ft NonComp: J F M A M 2015 H H H H 2016 H H 2017 H H H 2018 H H H H Duke Energy Lee Steam Plant NC0003417/001 County: Wayne Cerl7cIPF Begin: 11/1/2009 chr IIm: 2.1% NonComp: Single J F M A M 2015 H H H H 2016 H H H H 2017 H H H H 2018 - - Pass H Pass 2019 H Duke Energy -Cape Fear S.E./007 NC0003433/007 County: Chatham Cer17cIPF Begin: 2/1/2019 chr I1m: 90% NonComp: Single J F M A M 2025 H H 2016 H H H 2017 - Pass - - Pass 2018 H H 2019 H Duke Energy-Roxboro/003 NC0003425/003 County: Person Fthd24PF Begin: 5/1/2007 24hr ac p/f IIm: 90%f . NonComp: Single / F M A M 2015 - - Pass - - 2036 - - Pass - - 2017 - - Pass - - 2018 - - Pass - - Duke Energy-Roxboro/006 NC0003425/006 County: Person Fthd24Ac Begin: 5/1/2007 24hr LC50 ac monit a NonComp: J F M A M 2015 >100 - - - - 2036 - - >100 - - 2017 - - - - >100 2018 - - - - >100 Region: WARD Basin: NEU12 SOC_JOC: 7Q10: PF: IWC: Freq: SOWD/A l l A S O N H H H H H H H H H H H H H H H H H H Region: WARD Basin: NEU12 Mar Jun Sep Dec SOC_JOC: 7QIO: 263.0 PF: VAR IWC: 0.47 Freq: 1/Qtr l J A S O N H H H H Pass H H H H H H H H Pass H H NR H Region: RRO Basin: CPF07 Feb May Aug Nov SOC_JOC: 7Q30: 0.0 PF: NA IWC: 100 Freq: Q J J A S O N H H H H - - Fail >100 >100 Pass H - - Fail Region: RRO Basin: ROA05 Mar Jun Sep Dec SOC_JOC: 7Q10: lake PF: NA IWC: NA Freq: Q / J A S O N Pass - - Pass - - Pass - - Pass - - Pass - - Pass - - Pass - - Pass - - Region: RRO Basin: ROA05 SOC_JOC: 7Q10: lake PF: NA IWC: NA Freq: A / J A 5 O N D H H H D H H Pass H D H D Pass Pass Pass Pass D r Legend: P= Fathead minnow (Pimohales oromelas). H=No Flow ffacility is activel. s = Split test between Certified Labs Page 32 of 108 Region nspectors' Checklist for Fi Parameters [This checklist is to be coral udng regional plant inspections for Field Laboratodes. do )y certification numbers in the 5000s] Facility Name: tj tF d Ekc. Regional Plant Inspector:VUF-stAlAeouel NPDES#: cvoo3-Iz 'Roock Plla.t Regional Insector ontact#: tq- /-yzsf Field Lab Certification #: 6o,80 Re ion: Lab Contact: 6-1Z S 0.vc Date: I. Check the parameter(s) performed at this site for reporting purposes. ❑ Total Residual Chlorine (TRC) Temperature (TEMP) ❑ Specific Conductivity (SC) 'KpH Dissolved Oxygen (DO) ❑ Settleable Residue (SETT) IL General Laboratory note any exceptions in section XI Are instruments meters probes, photometric cells etc. maintained in good condition? I M Yes ❑ No Are standards, reagents and consumables used within manufacturer expiration dates? RC gel standard is exempt.] Yes ❑ No Are the following items documented where a livable Item TRC pH TEF4P DO SC J Date of sample collection* Time of sample collection* Sample collectors initials or signature Date of sample analysis* Time of sample analysis* T/A Analyst initials or signature Sample site i.e., facilityname, location, ID, etc. Instrument ID Parameter Data qualifiers, when required `Date and time of sample collection and analysis may be the same for in situ or on -site measurements. III. Total Residual Chlorine — reference method: Total Residual Chlorine meter make and model: Is a check standard analyzed each day of use? Circle one: gel or liquid standard Yes No What is the assigned/observed value of the daily check standard? Is a 5-point calibration verificationperformed? Note date of last verification: Yes ❑ No Alternatively, does the lab construct a linear regression, using 5 standards, to calculate results? Note date of last calibration curve constructed: ❑ Yes ❑ No True values: ❑ pg/L ❑ mg/L Obtained values: ❑ pg/L ❑ mg/L What program are samples analyzed on? Are results reported in proper units? Check one: /L ❑ m /L Yes ❑ No Are results reported between the facility's permit limit and the compliance limit of 50 pg/L? If value is less than the low standard, report as "<x", where x=low standard conc. ❑ Yes ❑ No Are samples analyzed within 15 minutes of collection? ❑ Yes ❑ No IV. pH — reference method: pH meter manufacturer and model: fawn L,' "Y✓1{ Is the pH meter calibrated with jlit least 2 buffers per mfg's instructions each day of use? Note buffers used: d to. 0 qYes ❑ No Is the pH meter calibration checked with an additional buffer each day of use? Note check buffer used: -.O Yes ❑ No Does the check buffer read within t0.1 S.U. of the known value? ffYes ❑ No Are the following items documented: Meter calibration? Yes ONo Check buffer readin s ? Yes No Are samples analyzed within 15 minutes of collection? Z Yes ❑ No Are sample results reported to 0.1 pH units on the eDMR? V Yes 0 No V. Temperature - reference m d: What instrument(s) is used to meas__3mperature? Check all that apply: ,,, , meter DO meter ❑ . _ Conductivit meter Digital thermometer Glass thermometer Is the instrument/thermometer calibr ion ch��ked at least annually against a NIST traceable thermometer? 's 7�rPm- jGeAeA , e n,n q Yes ❑ No Is NIST traceability documentation maintained on site? es ❑ No Are samples measured in situ or on -site? [REQUIRED - there is no holding time for temperature] d ; -6 - NrYes ❑ No Are sample results reported in degrees C? Yes ❑ No VI. Dissolved Oxygen - reference method: DO meter make and model: Is the air calibration of the DO meter performed each day of use? 0 Yes ❑ No Are the following items documented: Meter calibration? Yes ❑ No Are samples analyzed within 15 minutes of collection? ❑ Yes ❑ No Are results reported in m /L? Yes ❑ No VII. Conductivity - reference method: Conductivity meter make and model: Is the meter calibrated daily according to the manufacturer's instructions? Note standard used this is generally a one -point calibration): ❑ Yes ❑ No Is a daily check standard analyzed? Note value: El Yes ❑ No Are the following items documented: Meter calibration? ❑ Yes ❑ No Are samples analyzed within 28 days of collection? Yes ❑ No Are results reported in mhos/cm some meters display equivalent S/cm units)? Yes No Vill. Settleable Residue - reference method: Does the laboratory have an Imhoff Cone in good condition? ETYes 0 No Is the sample settled for 1 hour? ❑ Yes ❑ No Is the sample aitated after 45 minutes? ❑ Yes ❑ No Are the following items documented: Volume of sample analyzed? Note volume analyzed: ❑ Yes ❑ No Date and time of sample analysis(settling start time)? Yes No Time of agitation after 45 minutes of settling? ❑ Yes ❑ No Sample analysis completion(settling end time)? 0 Yes No Are samples analyzed within 48 hours of collection? ❑ Yes ❑ No Are results reported in ml/L? Yes ❑ No IX. Was a paper trail (comparing contract lab and on -site data to DMRs) performed? If so list months reviewed: ❑ Yes ❑ No X. Is follow-up by the Laboratory Certification program recommended? ❑ Yes No XI. Additional comments: Please submit a copy of this completed form to the Laboratory Certification program at DWR Lab Certification, Water Sciences Section, 1623 Mail Service Center, Raleigh NC, 27699-1623 Electronic copies may be emailed to dana.satterwhite(a)ncdenr.gov. Revision 12/13/2016