NC0003425_Other Agency Documents_20190329

c_CkEz) DUKE Duke Energy
411 Fayetteville Street
Mail Code NC15
ENERGY® Raleigh,NC 27601
March 29, 2019
RECE,VED DENRIDWR
Ms. Julie Grzyb, Supervisor AV K 0 2 2019
NPDES Complex Wastewater Permitting Aster Resourcea
NC DEQ/DWR/WQ Permitting Section P@rmitting Section
1617 Mail Service Center
Raleigh NC 27699-1617
RE: Roxboro Steam Electric Plant,NPDES Permit NC0003425
Request for Designation as Closed-Cycle Recirculating System
Dear Ms. Grzyb,
This letter is to request that the Duke Energy Progress, LLC (Duke Energy)Roxboro Steam
Electric Plant be designated a closed cycle recirculating system (CCRS)pursuant to the United
States Environmental Protection Agency's Final Regulations to Establish Requirements for
Cooling Water Intake Structures at Existing Facilities and Amend Requirements at Phase I
Facilities, 79 Fed. Reg. 48,299 (August 15,2014) as codified at 40 CFR §§ 122 and 125 (the
Cooling Water Intake Rule).
The NPDES permit renewal application for the Roxboro Steam Electric Plant(Roxboro),
submitted on September 28,2011, is currently under review by the Department. Pursuant to 40
CFR § 125.95(a)(2),Duke Energy requested, and the Department established, an alternate
schedule for the submission of application materials described in 40 CFR§ 122.21(r). Until that
information is submitted,the Department can establish an interim Best Technology Available
(BTA)for this facility,per the Rule. A designation of BTA and identification of the Roxboro
system as CCRS for the purpose of the pending permit would allow Duke Energy additional time
to complete certain ongoing studies and provide the Department with additional time to review
entrainment and impingement at the facility. As stated in the preamble to the Cooling Water
Intake Rule, when cooling systems involving impoundments meeting the definition of CCRS,the
permitting authority can consider whether additional controls are warranted to protect against
adverse impacts due to entrainment or impingement(79 Fed. Reg. 48,348). To facility further
review, Duke Energy will submit the application information required by the Cooling Water
Intake Rule as set out in the alternate schedule in I(A.)(28.) of the January 21, 2017 Public
Notice draft(a requirement that Duke Energy expects in the final permit).
Basis for Designation as a CCRS
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:

Ms. Julie Grzyb, Supervisor
March 29, 2019
Page 2
"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 closed-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,
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. As demonstrated in the attached documents,the Carolina Power&Light Company
received authorization for the creation of Hyco Lake in April 1964 for the Roxboro facility.
Several references, including those listed below provided as an enclosure to this letter, 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

•
Ms. Julie Grzyb, Supervisor
March 29, 2019
Page 3
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.
Consistent with the purpose of its creation as a CCRS and the fact that there is no additional
makeup flow to the CCRS,make-up water withdrawals to the CCRS attributed specifically to the
cooling portion of the cooling system have been minimized.
If there are any questions,please contact me or Lori Tollie at [e-mail] or
336-854-4916. Duke Energy sincerely appreciates your assistance with this matter.
Sincerely,
E.,( Pk.syfivo-N-
E. Shannon Langley
Principal Environmental Specialist
Enclosures

Ms. Julie Grzyb, Supervisor
March 29, 2019
Page 4
Cc: Tom Copolo—Station Manager(w/attachments)
Robert Howard(w/attachments)—via email
Lori Tollie/FileNet(w/attachments)—via email
Stephen Conner(w/attachments)—via email
Richard Baker(w/attachments)—via email
Michael Smallwood (w/attachments)—via email
Reid Garrett(w/attachments)—via email

March 29, 2019 Submittal
Roxboro Steam Electric Plant, NPDES Permit
NC0003425
Request for Designation as Closed-Cycle
Recirculating System
Enclosures

•
NORTH CAROLINA t
STATE STREA'. SANITATION CO,.0 1 t tE
STATE DEPARTMENT OF WATER RESOURCES CP&L EXHIBIT NO. 1
P. 0. BOX 9392
RALEIGH
APPLICATION FOR APPROVAL OF PLANS AND ISSUANCE OF orlf.
"CERTIFICATE OF APPROVAL" OR "PERMIT" E
COPTO x
DISCHARGE SEWAGE, INDUSTRIAL WASTES OR TREATU`li PLANT
EFFLUENTS INTO THE WATERS OF THE STATE 1 t
• • a • a • a
/,
t `
Fbril 33 19_
To: The State Stream Sanitation Committee
Raleigh, North Carolina
Gentlemen:
)n acrordonce with the provisions of Article 2) of Chapter 143, General Statutes
of North Carolina (Chapter 100, Session Laws of )951), npplicntion i:, hereby made
by ^.a of the r',t'airt.a =.'v f- —GS:::fa7
(Name of beard, individual or others) (Name of wit2. village. town,
in the county of (.!nl.w to the State
sanitary diettiet or establishment) (Ni,;te of county)
Stieen Sanitation Committee for approval of the at.rnrpunying plefts, specificetinna and
other data aubmitt..d herewith covering LL collie':; p3:1j. I.L Ct3
tit tlil l t•:tv rm rtt)? .1ty of 3.,0.3 :"1 at Ll)c C+rpany'c ntu
1r�•::l;u:p i,t:::a ..i(:_L u is k i.ittt ir. P,^.rcna C:,ur,ey.
and for a "Certificate of Approval" and/or "Permit" for the discharge of
1-'? ire-- __T — (se:afe,
from the ^r: iCit�YQ scrrtng
indust:i:.l v.rsli or rerbineti,.na) (severs or treatment plant)
Oa 4:4 .. o:'o : t;t into the :tsrface
(Name of nanici;-ili:v n,tatatnnn or induetty, etr.) (aarfore or ground wnteis)
waters of `°` .,i +c:!' ;r.: ;.c I i y a �'�:� en t ue ltyco lover
(Name of eater course if suifree *eters; if ground raters, state water
at l4 c ..t';) L I,97bi1j(1 PC Grid ci,uwl;n;t'uS
l,course to whir they are tributary) (Exact location of point of diarhnrre)
.
The plans for the proposed works have been prepared by �EiGCtG ::rr\r1ce 9 inc.
rs (Engineering Firm)
rector �C li.iw Z, ' y
ei .y It is estimated that treatment i.oil. will provide
• (Address)
adequate capacity to serve the n',•boro tea:A 1.1ectric Platt for an indefinite
(City, town, s"•titary district or establirh,ent)
period Vi!:..^`• =47tVe, et aid' time it is estimated the average daily b'h?:: ::1;D'!t'svtre
flow will not esceedZ" ,i11LI." gallons. It is further expected that the treatment
worth will effect overall rcduetions in pollution as follows: R.D.D. (5-day
20°C i_.b, suspended solids 1i1 total solids)' ., coliftrm bacteria 11 g,
and toxic 'vterials ' e'^�. The cost of the proposed works is estimated to be:
sewers f.,--^1 , pumping stations i 'i{ treatment plant S +"4
• cools 3 pow oCs L,v;u,�:).) Th�works will be cotcpletrd and in operation on or before
a...� Jl, .iO
19�
i:aee attached ccl.:,•it,dum
The applicant hereby agrees that the proposed works will be constructed in ntrict
accordance with the approved ['tails and specifications or subsequently approved changes
therein and futthtr agrees to place its operation under the cate of a competent person
and to nnintein and opernt. :he plant according to the best accepted practice and in
accordance with the plats and specifications epptoted by the Committee..
Signature _._ .L �y4v-•����� ,,,
Title pce•1'rf:l:ide.%i _ Carolina 1't cur & Light Company
F+filc;;;;ia i:' rth Carolina
Mailing Address .._
e Specify percentage reduction fa: each toxic substanie. using additional sleet, if
• nct.asary.
(See instturtiuns on reverse aide)

•�_•i
E
AP LIC.11_c.r '?CI++rllry��"21.0 AL t._ i.7 4.'7t3�1 :D I^ ,12Z.: tom. _ f•+
I IC.w•.�i.�.IFICA E C. ..a._tCVAl..t• •V.\_ ',P..1=ITi. l,iJ C :ab•.• .—'�+ 1.+
T .r
•
Di�a,__.a.= vim...'.r9 L^l J..? .. ..._ _. r' �1� . �:.
...l LJ:." Ts INTO T:.2 t':^L s ' ,. L ^ ;
A. Lake Diseaarra Schedule A
1. t:i=•_: ra::cr:' inflow =G
e1evac io: :3 below full sur:7. elevation, only 20,0:0 ;".1 will
be permitted to flow dowest=eam uatil the lake T
full elevation. is re; o-cd to
Z. .:.; natural inflow e'::^,.,•;.. 2•D,CC0 ^F:.-t an2 the l..
kc hater will be permitted to spill m_.:c:_z?1y �s full,
reservoir and providics a : ::
_nimm f1c:i less than�..:,of not l
downstream. t �«E,<. ;)
3. t'ha� ratt:_at inf1c17 to the la
ke is tt an C��
entire inflow ::i1i be permitted r..
1..f surface C_oV.''.t1Gs..
•„� 4. Under alvers.•'- stream f1c:; co:.'.itL«.aa, the daily
Jy
pl_�r will ,^.CVcr �•_ iCr.3 ,' i 2e
the present time is 3,103 ;pm (7 c �) ,B. mnntL
Predicted n3e of Temperatures In sae La: -
Dice`er3e :e _:1 _T
c: . .:at r_L: Lak
e
.:e
1. It is anticipated tk^t ti;_ r -- .
n Lha lake will
the aoadanser water from +'.'.e ;l i...:t is ,
This tn"'S:..rc^..�.`L: �,^t expected i - •.._•• ��a..l C.1�'. `C?� i.:'.�G
this . xp o vary iron . low cf' is to a .__ A
i. -'hc to peraa:.re of t:: water t
s c.:ro.�ted to vary from ts., in the 'h..
.Z- winter S".vi:�/_ :O In th
a

•
NORTH C A^.OLIN A
SLATE STREAM SANITATION CO?ThliA rEE
RALEIGH
PERMIT
3_ — c)--
5 S For the Discharge of Sewage, LT:dustrial Wastes, or Other Wastes
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Caro-
lina as amended, and other applicable Laws, Rules and Regulations,
PERMISSION IS HE RERy GRANTED TO
Carolina Light�i fiLr.,, Company
j
Roxboro Steam lllectric Plant
Person County, ?:orth Carolina
FOR THE
operation of a 3,800 acre cooling pond for a design flow
of- 2,400,000,000 G.P.J., and the discharge of the efflu-
ent into the :Tyco River, a tributary in the Roanoke River
Basin,
•
in accordance with the application dated .Uri 1 i
the plans. specifications, and other su � � , and in conformity withpporting data, all of which are filed with the State Stream Sani-
• tation Committee and are considered a part of this Permit.
This Permit shall be effective from the date of its issuance until modified oz. =escinded, and
y,s shall be subject to the following specified conditions and limitations:
1. This Permit shall become void unless the facilities arc Ton-
structed in accordance with the approved Plans, Spec.if ica;;_;,__S
and other supporting data andare co.,.__eted and placed ,e_ -
' -,�� i:, o_�y
tion on or before Iia:i 1. 19EE6
by the State Stream Sanitation Comaitteeh s date may be amended
2. This Permit is effective only with respect to the nature of the
operations described in the application and other supporting data.
3. The cooling pond shall be operated in such a manner as to pro-
vide a minimum discharge of 7.0 cfs, or otherwise in keening with
the discharge schedules set forth in the application and other
supporting data.
4. The operation of the cooling pond shall result in the tempera-
ture of the lake discharge being substantially in keeping with those
set forth in the application and other cutportint; data, or othea.-
wise as to maintain applicable assigned water Quality standards.
Permit issued this the___4 daylray '
of z L , 1994_.
Signed rw1
Permit No. 522 -. C. :iubbard, Secretary
uwc..624m State Stream Sanitation Committee

v
fp
LE as
NORTH CAROLINA
BOARD OF WATER AND AIR RESOURCES
RALEIGH
CERTIFICATION
(Covering the issuance of "Certificate of Approval" or "Permit")
In accordance with the provisions of the General Statutes of North Carolina
(G.S. 105-122, 105-147, 105-294, 105-296, and 105-297), this is to certify
that:
Carolina Power and Light Company
Roxboro Steam Electric Plant
Person County, North Carolina
has been issued "Permit" No. 522 covering the construction and operation of
waste treatment facilities, and the discharge of the effluent into Hyco
River, a tributary in the Roanoke River basin, in accordance with the applica-
tion filed on April. 13, 1964, in the office of the Board of Water and Air
Resources and in conformity with the plans, specifications, and other data sub-
mitted in support of said application.
It is further certified that the following conditions have been met:
1. The facilities referred to above have been constructed and
placed into operation.
2. The facilities comply with the requirements of the Board of
Water and Air Resources with respect to such facilities, and
are being effectively operated in accordance with the terms
and conditions set forth in the "Permit".
•
3. The primary purpose of said facilities is to reduce pollution
in the Roanoke, resulting from the discharge of wastes.
Issued at Raleigh, North Carolina, this 1st day of October. 1971.
Signed
E. C. Hubbard, Assistan Director
Department of Water & Air Resources

S i '1: STREAM SANITATION COMM._ .I E CP&L EXHIBIT NO. 2
RALEIGII
FRE y
PERMIT
For the Discharge of Sewage, Industrial Waster, or Other Wastes
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Caro-
lina as amended, and other applicable Laws, Rules and Regulations,
PERMISSION IS IiEREL'Y GRANTED TO
Carolina Power & light Company
Roxboro Steven Electric PL nt
Person County, North Carolina
FOR THE
operation of a 3,800 acre cooling pond for a deli i flow
— of 2,400,000,000 G.P.D. , and the discharge of the efflu-
ent into the llyco River, a tributary in the P..ornoke River
Basin,
in accordance with the application dated April_13 , 19 64_, and in conformity with
the plans, specifications, and other supporting data, all of which are filed with the State Stream Sani-
; tation Committee and are considered a part of this Permit.
This Permit shall be effective from the date of its issuance until _:modified or rescinded, and
shall be subject to the following specified conditions and limitations:
1. This Permit shall become void unless the facilities are con-
structed in accordance with the approved plans, specifications,
and other supporting data and are completed and placed in opera-
tion on or before May 1, 1966 , or as this date may be amended
• by the State Stream Sanitation Committee.
2. This Permit is effective only with respect to the nature of the
operations described in the application and other supporting data.
3. The cooling pond shall be operated in such a manner as to pro- •
vide a minimum discharge of 7.0 ofs, or otherwise in keeping with
• the discharge schedules set forth in the application and other
supporting data.
•
4. The operation of the cooling pond shall result in the tempera--
- ture of the lake discharge being substantially in keeping with those
set forth in the application and other supporting data, or other-
wise as to maintain applicable assigned water quality standards.
•
Permit issued this the 4111 da3• of May
Signed e.. h-�; ;
E. C. Hubbard, Secretary
Permit No. _-)22__ State Stream. Sanitation Committee
10.15.53-I 1

'11. !%:,A4Ci
NORTH CAROLINA
ENVIRONMENTAL r to= COMMISSION
RALEIGH
C ER `f IF I 'CAT ION
(Coveri', t. - issuance of a Permit)
In accordance with the provisions of the General Statutes of North Carolina
(G.S. 105-275), this is to certify that:
Carolina Power and Light Company
' Roxboro Steam Electric Plant
Person County
has been issued Permit Number 2523 for the construction and operation of a 650 acre
afterbay reservoir below Roxboro Cooling Lake (Hyco Lake) with a final discharge
into Hyco River (Roanoke River Basin) at not less than a flow 'rate of 10 cfs and
the teinperatute at no time to exceed the allowable stream temperature limits for
Hyco River at this location.
it is further certified that the following conditions have been met:
1. The facilities reffered to above have been constructed and placed into
operation.
2. The facilities comply with the requirements of the Environmental Management
Commission with respect to such facilities, and are being effectively opera-
ted in accordance with the terms and conditions set forth in the Permit.
3. The primary purpose of said facilities is to reduce pollution in the Hyco
River, resulting from the discharge of'wastewater.
�, ,, �
Issued at Raleigh, North Carolina, this o?r,7C day of I,1 _� '. 9 1974.
Signed
E. C. Hubbard, Director
Division of Environmental Manageuent
TC-F-34