NC0003425_Compliance Evaluation Inspection_20190225

I�
ROY COOPER
Governor
MICHAEL 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 Quaflty
February 25, 2019
Subject: Compliance Evaluation Inspection
Roxboro Steam Electric Power Plant
NPDES Permit NCO003425
Person County
Dear Mr. Draovitch:
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 PIant. 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 0.0I5 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.
DNorth Carolina Department of Environmental Quality i Division of Water Resources
A Raleigh Regional Office 1 3800 Barrett Drive I Raleigh, North Carolina 27609
919-791.4200

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 3I, 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 permit, 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 Desulf irization
Treatment System (Internal Out fal1010).
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
htt s:'!de .nc.aov.`about:'divisions:'«-ater-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 NCO003425
February 25, 2019
Page 3 of 3
8. The inspector observed all outfalls during the inspection. For Outfall 003, the NPDES permit
requires the permittee to perform the effluent sampling on the discharge canal at the Point o
dischar a into H co 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 witlu Lori Tollie, Duke Energy should contact the Division's NPDES
Permitting Unit and discuss the possibility of changing the sampling location for Ouutfall
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 e ncdenr.gox-.
Rick Bolich, L.G., Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Attachments: EPA Water Compliance Inspection Report
Cc: RRO::SWP Files
Laserfiche

United States Environmental Protection Agency Form Approved.
EPA Washington. DC.20460 OMB No.204M057
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 1 2 15 E 3 NC0003425 l i i 12 19.0V19 17 181 ! 1 19 1 c I 201 I
21 lJ LJ L_!
IttlIII5
InspecUon Work Days Facility Self -Monitoring Evaluation Rating B1 GA Reserved
67 70 i I 71 I I 72 I ti I 73 I I 174 75III 80
� —{ Section 8- Facility Data LJ I I I
Name and Locatror of Facl ty Inspected ,For Industrial Users discharging to POTW also include Entry Time/Date Permit Effective Date
POTW name and NPDES perm t Numbed
10 05AM 19/02/19 09/07/01
Roxboro Steam Electric Power Pla-t
1700 Dunnaway Rd Exit Time/Date Permit Expiration Date
Semora NC 27343 01 05PM 19/02/19 12/03/31
Name(s) of Onsite Representafive(s:mtles(s%-Phone and Fax Number(s) Other Facility Data
Ryan Stephen Enoch ORC+736-598-7609/
Name, Address of Responsible Ofr1ciallTtle/Phone and Fax Number
Contacted
�...... Dunnaway Rd Semora NC 273431Plant
Manager1336-597-6101/ Yes
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit E Operations & Maintenance E Records/Reports Self -Monitoring Program
Facility Site Review 0 EfiluenVReceiving Waters 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+Officer Phone and Fax N mbers Date
Vanessa E Manuel RRO WOe.eile 697-699jy
5ignatura of Ma agement O A Reviewer AgencyOfrice/Phone and Fax N.mbers D to
EPA Form 3560-3 (Rev 9-94) Previous edit-ons are obsolete.
Page#

NPOES ydrno/day Inspection Type
31 NCO003425 I11 121 19102119 117 18 LC
Section 0 Summary of FindinglCommenls (Attach additional sheets of narrative and checklists as necessary)
See attached inspection report.
PaPA

ParmlL• NC0003425 Owner - Facility; Roxboro Steam Electric Power Plant
Inspection pate: 02/1gi2oi9 Inspection Type! Compliance Evaluation
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
application?
Is the facility as described in the permit?
❑
❑
❑
# Are there any special conditions for the permit?
❑
❑
❑
Is access to the plant site restricted to the general public?
❑
❑
❑
Is the inspector granted access to all areas for inspection?
❑
❑
❑
Comment: The current NPDES permit expired on March 31 2012. The Division received the
ermittee's renewal aRglication on September 28 2011.
Record Keeping
Yes
No NA NE
Are records kept and maintained as required by the permit?
❑
❑
❑
Is all required information readily available, complete and current?
❑
❑
❑
Are all records maintained for 3 years (lab_ reg. required 5 years)?
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
M❑
❑
❑
Is the chain -of -custody complete?
❑
❑
❑
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
■
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
0❑
❑
❑
Has the facility submitted its annual compliance report to users and DWO?
❑
❑
0
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 2417 with a certified operator
❑
❑
0
❑
on each shift?
Is the ORC visitation log available and current? M ❑ ❑ ❑
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 classification? 0 ❑ ❑ ❑
Is a copy of the current NPDES permit available on site? ❑ ❑ ❑
Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑
Comment: The Permitted facility is classified as both a Grade II Biological Water Pollution Control
System and a Grade I Ph sicallChemical Water Pollution Control System. The ORC Ryan
Enoch ossesses valid certificates for WW 3 and PC-2 treatments stems and each
Backup ORC is certified at the approgriate a and grade for the treatments stems.
Page# 3

Permit NC0003425 Owner -Facility: Rcxbcro Steam Electric Power Plant
Inspection Date: 0211912019 Inspection Type: GempFance Evaluation
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a cerlifed lab?
M
❑
❑
❑
# Is the facility using a contract lab?
❑
S
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6 0 degrees
❑
❑
❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0 2 degrees?
❑
❑
0
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
■
❑
Comment: The on -site lab is field parameter certified certificate # 5080 and lab
personnel analyzes RH
and temperature. All other required Parameters are analyzed by the
ermittee'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 ex MLSS. MCRT, Settleable ❑ ❑ ❑ M
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment:
Bar Screens Yes No NA NE
Type of bar screen
a.Manual
b.Mechanical
❑
Are the bars adequately screening debris?
S
❑
❑
❑
Is the screen free of excessive debris?
[]
❑
❑
Is disposal of screening in compliance?
❑
[l
❑
Is the unit in good condition?
0
❑
[]
❑
Comment. The acka a wastewater treatment
dant is relative!y new and treats domestice wastewater.
Secondary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewate,?
!
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
❑
❑
a
❑
Are weirs level?
M❑
❑
❑
Is the site free of weir blockage?
■
❑
❑
❑
Is the site free of evidence of short-circuiting-,
0
❑
El
❑
Is scum removal adequate?
❑
❑
❑
Is the site free of excess ve floating sludge?
❑
❑
❑
Page# 4

Permlt: NCO003425 Owner -Facility:
Roxboro Steam Electric Power Plant
Inspection pate: 02/19/2019 Inspection Type:
Compliance Evaluation
Secondary Clarifier
Yes No NA NE
Is the drive unit operational?
0
Is the return rate acceptable (low turbulence)?
0
Is the overflow clear of excessive solidstpin floc?
0
11❑
Is the sludge blanket level acceptable? (Approximately '/. of the sidewall depth)
11
11110
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?
Are surface aerators and mixers operational?
Are the diffusers operational?
0
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin's surface?
Is the DO level acceptable?
■
Is the DO level acceptable?(1.0 to 3.0 mgll)
E3
11
.
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?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de -chlorination?
Comment: De -chlorination is not used
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
■
El
Is sample collected below all treatment units?
Is proper volume collected?
■
Is the tubing clean?
11
El
El
.
Page# 5

Permit: NCO003425 Owner- Facility: Roxboro Steam Electric Power --lant
Inspection Date: OV1912,19 Inspection Type: Compliance Evaluation
Effluent Samulina Yes No NA NE
# Is proper temperature set for sample storage;kept at less than or equal to 6.0 degrees ❑ ❑ ❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type ❑ ❑ ❑
representative)?
Comment: For outfall 003, the composite sampler is- setup at the time of sample collection to collect a
quarterly toxicity sample. During the inspection. the composite sampler was not set up -
Upstream ! Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type and ❑ ❑ ❑
sampling location)?
Comment: Stream monitoring 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' N ❑ ❑ ❑
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? ❑ ❑ M ❑
Comment: The facility_ has 2 effluent outfall pipes (003 and 006) and 5 internal outfalls (002, 005, 008,
009 and 010) that eventually discharges to the heated water discharge canals stem outfall
03.
Page# 6