NC0003425_EPA-No objections to Draft Permit Conditions_20021003

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
Ms. Teresa Rodriguez DEC 0 3 2002
North Carolina Department of Environment and
Natural Resources
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
SUBJ: NPDES Permit for CPL Roxboro Steam Facility
Pen -nit No NC0003425
Dear Ms. Rodriguez.
In accordance with the EPA/NCDENR MOA, we have completed review of the draft
permit referenced above and we have no objections to the draft permit conditions. We request
that we be afforded an additional review opportunity only if significant changes are made to the
permit prior to issuance, or if significant comments regarding the draft permit are received
Otherwise, please send us one copy of the final permit when issued.
If you have any questions, please call me at [phone]
Sincerely,
/�rv'�k'A �\ A°ik
Marshall Hyatt, Environmental Scientist
Permits, Grants and Technical Assistance Branch
Water Management Division
Intemet Address (URL) • http Hwww epa gov
Recycled/Recyclable • Pnnted with Vegetable 01 Based Inks on Recycled Paper (Minimum 30% Postconsumer)

Re commentij on NC0003425 - CPL Roxboro Steam Electric
Subject: Re: comments on NC0003425 - CPL Roxboro Steam Electric
Date: Tue, 03 Dec 2002 09:28:54 -0500
From: [e-mail] gov
To: Teresa Rodriguez <teresa rodrlguez@ncmall net>
CC: [e-mail] gov
finally had time to review the fax that you sent. Here's a summary of
the EPA initial comments, NC response, and EPA reply for NC0003425. I
will send you a no comment letter. thanks for your patience and making
changes based on our comments. We'd appreciate it if you would send us
an electronic version of the revised permit to review before you issue
it. Marshall
1. Section A(11)a spells out the spatial extent of the temp mixing zone
This seems to include whole arms of the lake and at least part of its
main body. 15A NCAC 02B.0204(a)(1) requires that the discharge will not
prevent free passage of aquatic organisms around the mixing zone.
Because the depth of the mixing zone isn't provided, what documentation
do you have to assure that there is a zone of free passage and that this
mixing zone conforms with NC requirementsP The fact sheet doesn't
address this If this is based on previous modeling, have recent data
been used in the model to re -verify?
The mixing zone was based on monitoring and modeling done by the
USGS,UNC and CP&L during the late seventies. The data gathered
during the study were used to establish the mixing zone. Since
the characteristics of the effluent or the conditions under which
the mixing zone was developed have not changed, we believe the
conditions should remain as previously approved.
The water column temperature profile data that you faxed show me that
there is a zone of passage for fish. EPA concern resolved.
2. A. Footnote 3 in Section A(2) says that continuous monitoring for
temp shall occur between 4C and 4D in the attached map. However, the
sample location in the table above doesn't reflect this ambient
monitoring requirement, it only indicates that there is effluent
monitoring for temp Why doesn't it reflect this ambient monitoring
requirement','
The sampling location column does not reflect the requirement but
it is referenced in the footnote for temperature. For clarity I
can add the locations in the sampling location column for
temperature.
EPA concern resolved.
B. The last bullet in the "DMR Data" portion of the fact sheet says
that there is no instream monitoring requirements in this permit. In
light of footnote 3 cited above, this statement doesn't seem correct.
I agree, they do have instream monitoring I will make a note in
the amended fact sheet.
EPA concern resolved.
C. If Footnote 3 requires continuous monitoring, is that consistent
with the last sentence in Section A(11)(d)? I can interpret the latter
to require discrete samples, not continuous sampling. Pls explain.
As per CP&L this provision was included to allow for downtime in
equipment maintenance or failure. I will try to reword this so
that the intention is stated clearly
1 of 2 12/3/2002 9 42 AM

Re comments on NC0003425 - CPL Roxboro Steam Electnc
EPA concern resolved.
3. Section A(11)(b) says that all water discharged from the afterbay
(mixing zone) shall comply with NC temp standards. However, as far as I
can tell, the permit does not require ambient measurement outside the
mixing zone to assess and confirm compliance. Pls explain the lack of
ambient measurements outside the mixing zone to show that NC temp stds
are being met.
They sample within the mixing zone and the results show that they
are meeting the temperature standard within the mixing zone. They
have,a biological monitoring program (Special Condition A.(12))
for monitoring the lake which covers many parameters including
temperature at various locations in the lake outside of the mixing
zone. Since they are meeting the standard in the mixing zone no
sampling outside of the mixing zone was included in addition to
the biological monitoring plan.
The ambient data that you faxed show me that ambient sampling outside
the mixing zone does occur. EPA concern resolved.
4. A. In the last sentence in the 4th bullet under the "Summary" section
of the fact sheet, why is NC's 2000 303(d) list referred to as "draft"?
Isn't it final and hasn't EPA approved it?
The list is final, I had an old version that said draft, but this
section didn't change
EPA concern resolved.
B. 1. 1. it isn't clear to me how the RPA for selenium was conducted.
Pls explain. I am also very curious about what background conc was
assumed. I am concerned that zero was used. If it was, pls explain or
document why that is a valid assumption.
I did the reasonable potential for selenium based on the existing
limit as the allowable concentration. The limit was developed
some years ago based on a model for fate and transport of selenium
in the lake, but I don't have the details of the calculations.
Data from the monitoring program have shown decreased
concentrations of selenium in the lake. The limit is not necessary
now that the fish advisory was lifted and they showed no
reasonable potential.
Based on the data summary that you faxed me that indicate that fish
tissue levels are declining, EPA concern is resolved.
2 of 2 12/3/2002 9 42 AM

Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27604
FaX
To:
Marshall Hyatt
From:
Teresa Rodriguez
Fax:
404-562-8692
Fax:
919-733-0719
Phone: [phone] Phone: [phone] ext 595
Pages: 5 Date: 11 I13 O Z
Re: CP&L NC0003425
-Comments:
Marshall,
These are copies from sections of the Environmental Report for Hyco Reservoir from
CP&L that have some information on temperature and fish data.

heD003W 5
,Roxboro Steam Electric Plant 2000 Environmental Monitoring Report
Executive Summary
Hyco Reservoir has been in an eleven -year period of recovery from the earlier effects of
selenium bioaccumulation following conversion in 1990 of the Roxboro Steam Electric Plant
from a wet ash sluicing method to a predominantly dry fly ash handling system. This dry fly ash
system continues to be very effective in reducing the amount of selenium entering the reservoir
from the ash pond and, subsequently, in bringing about recovery of the fish community which
was impacted by selenium bioaccumulation since the late 1970s.
During 2000, concentrations of selenium in reservoir surface remained well below the
North Carolina state water quality standard of 5 µg/L. Depuration of selenium from tissues of
aquatic organisms and recovery of the fish community has occurred with waterborne selenium
concentrations generally ranging from < 1.0 to < 2.0 Mg/L during the eleven -year recovery period.
There have been significant declining trends in selenium concentrations in net plankton,
benthic invertebrates, and in the liver and muscle tissues of white catfish and bluegill when
considering data from the pre -recovery (1986-1989) and recovery (1990-2000) periods. Selenium
concentrations in largemouth bass muscle tissue at all monitored reservoir locations also exhibited
significant declining trends in the recovery period.
Favorable trends in species composition and dominance in the fish community continued
during 2000. The fish community has shifted from undesirable, selenium -tolerant species (satinfin
shiner and green sunfish) to a bluegill-dominated community that is more representative of a
piedmont North Carolina impoundment during the recovery period. Bluegill has been the
dominant species in the fish community since 1994. Successful reproduction by largemouth bass
and bluegill resulted in electrofishing catch rates in Hyco Reservoir that were comparable to other
piedmont North Carolina impoundments that have similar or higher biological productivity.
In summary, the favorable changes documented for the recovery period (1990-2000)
demonstrated the continued effectiveness of the Roxboro Plant's dry fly ash handling system in
reducing the amount of selenium entering Hyco Reservoir. The decline in selenium
concentrations and positive shifts in the fish community structure indicate further recovery of
Hyco Reservoir from previous effects of selenium bioaccumulation
rPR,L—A Proaress Enerav Companv vi Environmental Services Section

Roxboro Steam Electric Plant 2000 Environmental Monitoring Report
Ro>boro Steam
Electric Plant
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Figure 1. Hyco Reservoir sampling locations during 2000.
CP&L—A Progress Energy Company 6 Environmental Services Section

Roxboro Steam Electric Plant zuuu tnvironmentai monnoring Kepon
Appendix 1. Water temperature, dissolved oxygen, specific conductance, pH, and Secchi
disk transparency data collected from Hyco Reservoir during 2000.
ICP&L—A Progress Energy Company A-1 Environmental Services Section
April 5, 2000
February 2, 2000
J
Depth Temperature
Depth
Temperature
Specific conductance
Dissolved oxygen
Specific conductance
pH
(m)
Secchi disk depth
(m)
(-C)
(mg/L)
(kis1cm)
(mg/L)
(/.'S/cm)
(m)
(m)
3B 4B
2B
3B
4B
6B
2B
3B
4B
6B
2B 3B 4B
6B
2B
3B
4B
6B 2B 3B 4B 6B
02
49
12
183
118
119
122
98
100
67 49 96
81
64
65
52
63 11 08 23 27
10
49
18
184
118
119
123
97
101
66 49 95
81
65
65
52
63
20
49
18
161
118
119
123
101
101
66 49 90
81
65
65
59
63
30
49
18
132
118
119
123
103
101
66 50 83
81
65
65
65
63
40
49
36
121
118
119
119
102
101
66 63 80
81
65
65
66
62
50
42
38
102
121
119
101
180
66 65 76
92
66
65
67
60
42
75
98
121
153
101
66 75
76
66
72 74
67
74
70
41
92
80
121
149
101
67 74
67
68
80
88
139
100
55
73
69
68
73
90
100
86
130
98
73
68
100
85
97
73
68
Depth Temperature
ICP&L—A Progress Energy Company A-1 Environmental Services Section
April 5, 2000
J
Depth Temperature
Dissolved oxygen
Specific conductance
pH
Secchi disk depth
(m)
(° C)
(mg/L)
(kis1cm)
(m)
2B
3B 4B
6B
2B
3B 4B
6B
2B 3B 4B
6B
2B
3B
4B
6B
2B 3B 4B 6B
02
167
158 267
198
94
94 83
89
74 66 95
80
71
72
73
73
11 10 21 22
10
167
158 267
198
94
94 84
89
74 66 95
80
73
73
74
73
20
164
157 262 '196
94
94 85
89
73 66 94
80
73
73
75
73
30
162
156 215
195
93
94 85
89
73 66 83
80
74
73
75
74
40
162
15.4 207
92
93 85
73 66 81
74
73
75
50
162
143 198 '
92
74 84
73 64 80
74
73
75
60
162
180
92
82
73 77
74
75
70
153
167
72
76
72 74
74
74
80
149
69
70
74
90
139
55
69
73
100
130
36
68
72
June 8, 2000
Depth Temperature
Dissolved oxygen
Specific conductance
pH
Secchi disk depth
(m)
(° C)
(mg/L)
(µS/cm)
(m)
2B
3B 4B
6B
2B
3B 4B
6B
2B 3B 4B
6B
2B
3B
4B
6B
2B 3B 4B 6B
02
264
263 303
271
95
97 81
84
118 112 129
120
81
81
77
78
17 13 21 23
10
264
257 304
271
94
98 81
84
118 110 136
119
81
82
77
78
20
258
253 304
270
92
96 81
83
117 109 136
119
81
82
77
77
30
254
238 280
269
87
80 70
82
115 105 123
119
80
80
76
77
-' 40
252
200 274
82
16 70
115 106 121
79
78
76
50
248
163 260
73
01 59
114 114 117
78
71
74
_ 60
242
246
53
55
115 112
78
74
70
230
220
14
33
139 109
72
73
80
190
04
103
72
90
175
01
104
71
100
164
01
113
69
ICP&L—A Progress Energy Company A-1 Environmental Services Section

Roxboro Steam Electric Plant
2000 Environmental Monitoring Report
Appendix,l (continued)
August 9, 2000
Depth
Temperature
Dissolved oxygen
Specific conductance
pH
Secchi disk depth
(m)
(°C)
(mom)
(/-cS/cm)
(m)
2B
3B 4B 6B
2B
3B
4B
6B
2B 3B 4B
6B
2B
3B
4B
6B
2B 3B 4B 6B
02
315
308 364 323
104
108
84
94
116 110 131
120
67
77
71
73
23 18 24 28
10
315
306 356 323
105
109
86
94
116 109 129
120
67
77
71
73
20
314
300 333 321
106
109
83
95
116 108 122
120
68
77
71
73
30
306
279 318 318
106
59
80
94
113 106 118
119
68
77
71
73
40
301
260 297
105
10
72
111 121 113
68
76
71
50
292
223 286
78
02
46
111 147 110
68
73
70
60
284
199 282
11
01
46
116 153 110
68
71
70
70
278
278
03
31
126 _ 109
67
70
80
268
15
108
70
90
231
04
133
69
100
189
01
170
68
October 3, 2000
Depth Temperature
Dissolved
oxygen
Specific conductance
pH
Secchi dish depth
(m)
CQ C)
(mgt)
(/zS/cm)
(m)
2B
313 4B 6B
2B
3B
4B
6B
2B 3B 4B
6B
2B
3B
4B
6B
2B 3B 4B 6B
02.
243
226 285 258
84
92
72
74
101 97 115
107
75
75
76
75
21 14 24 31
10
243
21-7 285 255
84
93
72
74
101 95 114
107
75
75
76
75
20
233
215 283 253
83
90
72
74
98 95 114
106
75
75
75
75
30
231
212 261 246
83
90
66
76
100 95 108
102
75
75
75
75
40
230
209 258
82
71
58
99 95 108
75
74
75
50
224
207 252
75
46
56
99 97 107
75
74
75
60
223
20:7 240
72
34
45
99 101 106
75
73
74
70
219
238
52
46
102 104
74
73
80
236
46
103
73
90
23 1
1 3
121
7 1
100
227
03
141
71
December 12, 2000
Depth Temperature
Dissolved oxygen
Specific conductance
pH
Secchi disk depth
(m)
(IC)
(mg/L)
(/.i-S/cm)
(m)
2B
3B 4B 6B
2B
3B
4B
6B
2B 3B 4B
6B
2B
3B
4B
6B
2B 3B 41B 6B
02
101
77 208 144
111
113
90
96
78 72 104
88
70
70
72
72
18 18 11 3 23
10
101
77 203 144
109
113
90
95
78 72 102
88
70
70
72
72
20
102
77 191 144
108
113
90
95
78 72 98
88
70
69
72
72
30
103
77 179 145
107
112
90
95
78 72 96
88
70
69
73
72
40
103
77 161
105
112
88
78 72 91
70
69
73
50
103
77 153
105
112
87
78 72 89
70
69
72
60
102
69 134
105
109
86
78 71 85
70
70
72
F 70
101
127
99
83
78 83
70
72
80
124
82
83
71
90
123
81
83
71
100
118
81
80
70
CP&L—A Progress Enerav Comnanv Qer..i- C. ..a,...