NC0003425_NOV-2019-MV-0130 Response_20190916

DUKE
ENERGY.
September 16, 20I9
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 NCO003425
Response to NOV-2019-MV-0130
Request for withdrawal of NOV
Dear Mr. Bolich:
Paul Draovitch
SVP Environmental Health & Safety
526 S. Church Street
Mail Code:EC3XP
Charlotte, NC 28202
W f lept of Environmental Quality
SEP 19 2019
P .deigh 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 71h, 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 23`d, 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 Iocation 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 Iocations 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 20I9 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(I2) 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 Tollie at 336.854.4916 or at [e-mail].
1 certify, cinder 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 ant aware that there are significant penalties
for submirting false information, including rite possibility of fines and intprisonment far knowing violations.
Environmental Health & Safety
Duke Energy

Mr. Rick Bolich
NOV-2019-MV-0130 Response
September 16, 2019
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---- Provisional Data Subject to Revision ----
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Daily maximum temperature — Daily mean temperature
—
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Certified Mail # 7017 0190 0000 9562 7213
Return Receipt RSguested
September 4, 2019
Pahl Draovitch, Senior VP
Duke Energy Progress LLC
526 S Church St - Ec3xp
Charlotte, NC 28202
SUBJECT: NOTICE OF VIOLATION & INT€NT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2019-MV-0130
Permit No. NCO003425
Roxboro Steam Electric Power Plant
Person County
Dear Permittee:
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SEP 0 J UN -
BY: T..:.I..1.. , i�
A review of the June 2019 Discharge Monitoring Report (DMR) for the subject facility revealed the violation(s)
indicated below:
MQnitorin4 wolatio0(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)
007A Effluent Temperature, Water Deg. 6/9/2019 Daily -- all days Frequency Violation
Centigrade (00010)
002-A Effluent Temperature, Water Deg. 6/10/2019 Daily -- all days Frequency Violation
Centigrade (00010)
002-A Effluent Temperature, Water Deg. 6/11/2019 Daily -- all days Frequency Violation
Centigrade (00010)
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Sample
Location Parameter Date
002A Effluent Temperature, Water Deg. 6/12/2019
Centigrade (00010)
Monitoring
Frequency Type of Violation
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
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.
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 A 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)
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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 4 businws d@y5 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,
ir
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
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