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HomeMy WebLinkAboutCape Fear Steam Station (4)NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Charles Wakild, PE Dee Freeman Governor Director Secretary August 2, 2012 Mr. Randy Cox Plant Manager Cape Fear Steam Electric Power Plant 500 CP&L Rd Moncure, NC 27559 Subject: NPDES Compliance Evaluation Inspection NPDES Wastewater Discharge Permit No. NC0003433 (Includes NPDES Stormwater requirements in the expired September 2006 Permit) NCS000550Application Received and NPDES Individual Stormwater Permit Draft dated October 11, 2011 not yet issued Cape Fear Steam Electric Power Plant Chatham County Dear Mr. Cox: On June 13, 2012, Autumn Romanski with the North Carolina Division of Water Quality, accompanied conducted a Compliance Evaluation Inspection of the Cape Fear Steam Electric Power Plant This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES Wastewater Permit No. NC0038377 A summary of the findings and comments noted during this inspection is provided in Section D on Page 2 of the attached copy of the complete inspection report titled "Water Compliance Inspection Report". If you have any questions concerning this report, please contact me at 919-791-4247 in the Raleigh Regional Office. Sincerely, Autumn Romanski Environmental Program Consultant Page 2-1 Attachments Cc: (w/attachments) fi? 11, / 7 Mrs. Robyn Bryson P.O Box 1551 PEB 4A Raleigh, NC 27602 Raleigh Regional Office — File DWQ/Raleigh — Central Files Wetlands, Buffers, Stormwater Compliance & Permitting Unit Mr Larry Baxley P.O Box 1551 PEB 4A Raleigh, NC 27602 Page 2-2 Section D Summary of Findings /Comments 1. Permit: Your NPDES Individual Wastewater permit became effective September 1, 2011 and expires on July 31, 2016. The facility is not currently under a Special Order by Consent. The permittee submitted a NPDES Individual Stormwater Permit renewal application as required in 2011. The draft NPDES Individual Stormwater Permit dated October 11, 2011 is still in review and has not yet been issued as of the date of this inspection For this reason, the stormwater conditions in the expired (Combined wastewater/stormwater discharge permit) dated September, 2006 remain in effect until such time as the new stormwater permit is issued. The permittee is reminded to read, understand and comply with all of the terms and conditions contained in the permit(s). If you have questions concerning your responsibilities, please call the Raleigh Regional Office to speak to a Division of Water Quality Surface Water staff member. The facility was compliant with the wastewater and stormwater requirements of the NPDES permat(s) in effect the day of the inspection The permittee reported an approximate timeline for a permanent shutdown of the coal fired boiler, and subsequent end to coal ash sluicing operations at this facility A gas fired Combustion Turbine may continue to operate at the site and current plans were reported to continue pumping resource water from the Cape Fear thru the plant As operations chane the facility should report changes that may affect permit related wastewater treatment units and effluent discharge This would include permit modifications as appropriate 2. Compliance Schedules: The permit does not have any outstanding compliance schedules for this facility. 3. Facility Site Review: The overall condition of the plant site was satisfactory The appearance of the facility was in acceptable condition indicating the current housekeeping practices are good. 4. Records/Reports: a) A review of the daily monitoring data submitted during the previous 12 -month period and a review of the permit conditions indicates the facility was in compliance with the permit requirements and/or limitations The fatality was issued no penalty assessments and no notices of violation for the 12 - month period Page 2-3 b) The facility must designate a certified Operator -in -Responsible -Charge (ORC) having a certification level equal to or greater than the facility classification. A Back-up ORC must also be designated with a minimum certification level at least one level less than the facility classification. The facility is currently in compliance lvith these requirements This facility is classified as a Physical Chemical 1 (PC -1) and the Operator in Responsible Charge (ORC) is Danny Hedgepath He holds a PGI (Cert No 27398) and a Wastewater II (Cert No 1566) The Division of Water Quality records indicate the Back-up ORC's are Norman Barlow (PC -1 Cert No 989381 and James Reed (PC -1 Cert No 28680) Please submit updated designation information (IF ORC's change over, or additional ORC's are designated as operators — we discussed that Henry Gales is now a back-up ORC, please send information to the attention of Steve Reid at 1618 Mail Service Center Rateigh NC 27699 - 1618 The ORC designation form is located here http://PortaLncdenr.orQ/weblwg/tacu- downloads The facility is currently in compliance with these requirements 5. Self -Monitoring Program: You are reminded that your monitoring samples must be collected, preserved, and analyzed by appropriate procedures and methods You should maintain records of the sampler temperature, and a certified laboratory must calibrate the sample thermometers annually. Your operator is reminded that he/she must keep a logbook of all operation/maintenance activities undertaken at the facility The logbook should include all daily process control activities including any field measurements conducted for process control A visitation log for the facility must also be maintained. The facility is currently in compliance with these requirements, and the safety changes implemented at outfalls 001 and 005 including 1) installation of hand rails and safety fence at outfall 001, 2) use of personal protection equipment at outfall 005, and 3) review of safety procedures with regards to sampling activities at these outfalls have signi icand lessened the safety risks identified in the last inspection Thank you for Your prompt action to resolve these concerns Page 2-4 Rox ISCO composite sampler- sample is ran thru an ice filled cooler to ensure proper cooling of the samples New, clean sample tubing was in place the day of the inspection 6. Laboratory: For all analytical data submitted for compliance monitoring purposes, a certified laboratory must be utilized for all laboratory analysis Additionally, if field parameter testing is conducted, an operator certified to perform the specified field parameter analysis is also required. The operator needs to be sure to calibrate all meters/instrumentation before each use and retain all calibration records The facility is currently in compliance with these requirements and utilizes Tritest Inc certified commercial laboratory #67 The tacility holds a current NC DWO Laboratory Field Parameter Certification 95101 for pH and temperature measurements Page 2-5 The Regional Field Inspectors checklist to be forwarded to the DWO Laboratory Certification Program was completed the day of the inspection and reflects the extent of laboratory items investigated by Regional inspectors DWO Lab inspections are performed separately by the Lab Certification Program and an evaluation of Tritest Lab was completed by the DWO Lab Certifcation Program on February 17 and February 18 2010 The Regional lab checklist results are attached 7. Flow Measurement: If the permit requires a flow measurement device for determining the effluent flow, the flow measurement device must be calibrated annually. This facility is required to monitor and report effluent flow and the facility is in compliance with this requirement They report effluent flow It appears from the recent NPDES effluent outfall 007 flow data reported that flow may vary widely as the facility is off-line more frequently and is entering a transition period that will work towards a permanent shutdown of the coal fired boiler A jzas fired Combustion Turbine may continue to operate at the site and current plans were reported to continue numpinz resource water from the Cape Fear River thru the plant so the methods used to calculate effluent flow may need to be reviewed in light of changing operations during this period of transition 8. Effluent/Receiving Waters: The effluent discharge should be clear with a continuous flow with no visible changes to the receiving waters. The effluent discharge was clear and flow was continuous The receiving waters looked clear with no visible changes from the effluent discharge 9. Pretreatment: This facility currently has no pretreatment permit and does not accept or discharge domestic or industrial waste to a sanitary sewer system Pre-treatment permits are required, if applicable. by your NPDES Discharge Permit 10. Solids Hand ling/Disposa1: The facility must dispose of solids by an acceptable method such as a landfill or utilize the services of an approved solids hauling and disposal contractor, which requires the facility to be included under the contractor's non -discharge permit (i e. land application) The facility is reminded to maintain adequate records (i e. shipment dates, quantities, etc ) of any solids hauling and/or disposal activities. The facility is in compliance with these requirements and reports no transporting of ash or wastewater sludge solids to off site locations In the past they did report some reuse of ash in cement block The facility should address Coal Combustion Products management as chrected by the NC Division of Solid Waste and/or cis directed by other state or federal regulations as that apply to solids at this facility The capacity and ultimate disposal o solids from the active 1985 ash pond is currently being reviewed and Progress Energy has reported all ash ponds on-site will close as a result of the closure of the coal fired boiler plant Page 2-6 11. Sanitary Wastewater Treatment Plant The sanitary wastewater treatment unit was not observed during this inspection However, the plant should consider options for any future sanitary sewer needs for any limited operations that continue at the plant after the closure of the current ash pond as the sanitary sewer treatment unit discharges to this ash pond 12. Compliance Sampling: Compliance sampling was conducted during the last inspection No compliance sampling was conducted the day of this inspection 13 NPDES Combined Wastewater/Stormwater Permit dated September 2006 The fatality was compliant with the Stormwater permit conditions as set forth in the NC0003433 combined wastewater/stormwater permit The creek is known to back-up in storm pipe, Activity -Sluice Lane located upland of SW pipe Page 2-7 SW Outfalls 004(above, by railroad) &006 (no photograph -drains to NPDES WW Outfall 007)was removed,in the NCS000550 Application Review Process Page 2-8 SW Outfall 008- Inactive Ash Pond —Holding Capacity for 25 year storm NPDES WW Outfall 001-1978 Ash Pond at capacity overflows to internal cooling water canal and ultimately out NPDES WW Outfall 007 Page 2-9 It was confirmed that the facility should continue the stormwater requirements in the NC0003.133 permit until such time as the new NCS000550 permit is issited It would appear that closure of the some of the current plant activities may occur before the issitance of the NCS000550 The SW outfall determinations made last year on the stormwater outfalls #SWI #SW8 4SW2 (New Location) SW43 and activity descriptions may change as the facility makes operational changes this Fall DW0 confirmed that SW96 discharges to the wastewater discharge canal and then to the final NPDES wastewater ozrtfall 007 that is already monitored through the NC0003.133 wastewater permit This will still be true as long as the facility continues with NPDES wastewater discharge monitoring at outfall 007 With the variety of operational changes coming tip the facility may want to consider updating the information provided in the application for the Individual Stormwater Permit 13. Operations & Maintenance: The facility was in compliance with these requirements the day of the inspection 14. Compliance Status: ® Compliant Name and Signature of Inspector: Autufnn Romans i Surface Water Protection Section Raleigh Regional Office ❑ Non-compliant ❑ Neither 94� �ao /,;z Date Page 2-10 United States Environmental Protection Agency Form Approved EPA Washington, D C 20460 OMB No 2040-0057 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 I ^I I 2 I s I 31 NC0003433 111 121 12/06/12 117 181 C I 191 C I 20U J LJ IJ U Remarks 2111111111111111111111111111111111 111111111111 1116 Inspection Work Days Facility Self -Monitoring Evaluation Rating 61 CA ---------------------------Reserved---------------------- 671 169 701U 711 721 N � 73 � 74 751 I I I I I I 1 80 —� 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) 09 00 AM 12/06/12 11/09/01 Cape Fear Steam Electric Power Plant 500 CP L Rd Exit Time/Date Permit Expiration Date Moncure NC 27559 02 00 PM 12/06/12 16/07/31 Name(s) of Onsite Rep resentative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Danny L Hedgepeth/ORC/919-774-5237/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Hershell ccMcCarty,500 CP L Rd Moncure NC 27559/// No r1 r1C—— QIa,1+ rLtAtto I oe-g Section C Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program Sludge Handling Disposal Facility Site Review Compliance Schedules Effluent/Receiving Waters Laboratory Storm Water Section D Summary of Find in /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 �v -C Autumn H Romanski/'l2 rZI-7— �RRO WO//919-791-4247/ f S natu of Manag ent O A ie er, Ag cy/Office/Phone and Fax Numbers Date t llvjvx� lJ EPA Form 60-3 (Rev 9-94) Previous editions are obsolete Page # 1 NPDES yr/mo/day Inspection Type 3I NC0003433 I11 12, 12/06/12 117 18(C� (cont ) Section D Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) The permittee was In compliance with the requirements of the current NC0003433 permit the day of this Inspection The NCS000550 Stormwater Permit has yet to be Issued, but the stormwater checklist was completed based on teh requirements in the September 2006 combined wastewater/stormwater permit and is attached to this inspection The facility was in compliance with the stormwater requirements the day of this inspection The facility reports the coal fired boiler Is scheduled to shut down this Winter 2012 The permittee should keep the NPDES Wastewater Permitting Unit Informed of process changes that effect compliance with the current NC0003433 wastewater permit, as well as, update the Stormwater Permitting Unit with cahnges as applicable to the NCS000550 Individual Stromwater permit currently under review Page # 2 Permit- NC0003433 Inspection Date: 06/12/2012 Owner - Facility Cape Fear Steam Electric Power Plant Inspection Type Compliance Evaluation Permit (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 Compliance Schedules Is there a compliance schedule for this facility? Is the facility compliant with the permit and conditions for the review period? Comment Lagoons Type of lagoons? # Number of lagoons in operation at time of visit? Are lagoons operated in? # Is a re -circulation line present? Is lagoon free of excessive floating materials? # Are baffles between ponds or effluent baffles adjustable? Are dike slopes clear of woody vegetation? Are weeds controlled around the edge of the lagoon? Are dikes free of seepage? Are dikes free of erosion? Are dikes free of burrowing animals? # Has the sludge blanket in the lagoon (s) been measured periodically in multiple locations? # If excessive algae is present, has barley straw been used to help control the growth? Is the lagoon surface free of weeds? Is the lagoon free of short circuiting? Comment. The 1985 active ash pond is at capacity and scheduled to close later this year (Winter 2012) Operations & Maintenance Is the plant generally clean with acceptable housekeeping? Yes No NA NE ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Yes No NA NE ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Yes No NA NE Facultative 1 Yes No NA NE 0000 Page # 3 Permit. NC0003433 Inspection Date- 06/12/2012 Operations & Maintenance Owner - Facility Cape Fear Steam Electric Power Plant Inspection Type Compliance Evaluation Yes No NA NE Does the facility analyze process control parameters, for ex MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ p Q p Judge, and other that are applicable? Comment Flow Measurement - Effluent # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? Comment This facility Is required to monitor and report effluent flow As reported in last year's inspection the pump curves developed for Influent pump station are used to calulate effluent flow. If effluent flow Is constant (less than 15% change In flow dally) then effluent flow reported should be relatively accurate, however, If flows vary significantly during the day due to mayor operations coming off line, but influent/canal flow continues, the facility should review and ensure proportional flow measurement and accurate effluent flow reporting Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # 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 0ui..,...* o..... Yes No NA NE Yes No NA NE Yes No NA NE Page # 4 Is right of way to the outfall properly maintained? ■ p p p Are the receiving water free of foam other than trace amounts and other debris? ■ p p p If effluent (diffuser pipes are required) are they operating properly? p p ■ p Comment Record Keeping Yes No NA NE Are records kept and maintained as required by the permit9 ■ p p p Is all required information readily available, complete and current? ■ n p O Are all records maintained for 3 years (lab reg required 5 years)? ■ p p Cl Page # 4 Permit NC0003433 Inspection Date: 06/12/2012 Record Keeping Are analytical results consistent with data reported on DMRs? 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? Owner - Facility Cape Fear Steam Electric Power Plant Inspection Type Compliance Evaluation Has the facility submitted its annual compliance report to users and DWQ? (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified 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? Is the backup operator certified at one grade less or greater than the facility classification? Is a copy of the current NPDES permit available on site? Facility has copy of previous year's Annual Report on file for review? Comment The facility Is currently classified as a PC -1 and was In compliance with the permit requirements the day of this Inspection Laboratory Are field parameters performed by certified personnel or laboratory? Are all other parameters(excluding field parameters) performed by a certified lab? # Is the facility using a contract lab? # 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? Incubator (BOD) set to 20 0 degrees Celsius +/- 1 0 degrees? Comment The results of the Tritest Lab certlfcatlon were reviewed and a Field Lab certifcation (#5101 check sheet was completed for pH and Temperature (attached and forwarded to the DWQ Lab Certification Unit Yes No NA NE ■000 ■ 0 0 0 ■ 0 0 0 0 0 11 ■ ■ 0 0 0 ■ 0 0 0 ■ 0 0 0 ■ Cl 0 0 0000 0 0 0 ■ Yes No NA NE ■ 0 0 0 ■ 0 0 0 ■ 0 0 0 ■000 0 0 ■ 0 0 0 ■ 0 Page # 5 Regional Field Inspectors Check List for Field Parameters Name of site to be Inspected Date. i� / Field certification # (if applicable) t Inspector No NPDES Region 2 I. Circle the parameter or parameters performed at this site. Residual Chlorine, Settleable Solid H DO, Conductivit ,Temperature II. Instrumentation: A Does the facility have the equipment necessary to analyze field parameters as circled above? 1 A pH meter Yes No , 2. A Residual Chlorine meter , es No /1114 3 DO meter Yes No ,,ij 4. A Cone for settleable solids Yes No /V�i�{' 5. A thermometer or meter that measures temperature es,) No 6 Conductivity meter Yes No j,)14 III. Calibration/Analysis: 1. Is the pH meter calibrated with 2 buffers and checked with a third buffer each day of use? :Y:es No 2. For Total Residual Chlorine, is a check standard / I� analyzed each day of use? Yes No ' /�' / 3. Is the air calibration of the DO meter performed each day of use? Yes No 4 For Settleable Solids, is 1 liter of sample settled for 1 hour? Yes No 4)��� 5. Is the temperature measuring device calibrated --1 annually against a certified thermometer? Yes No 6 For Conductivity, is a calibration standard analyzed each day of use? Yes No �� d ICA �NC c�003Y3 3� Permit: NCS000550 Effective: SOC: Effective: County: Chatham Region: Raleigh ��y cox Contact Person: Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits* Compliance Inspection Report Expiration: Owner: Carolina Power and Light Company DBA Progress Energy Inc Expiration: Facility. Cape Fear Steam Electric Power Plant 500 CP L Rd Title: Vice President Certification. Moncure NC 27559 Phone- 919-546-7661 Phone: Inspection Date: 06/12/2012 Entry Time. 09 00 AM Exit Time: 02 00 PM Primary Inspector: Autumn H Romanski- Phone. 919-791-4247 Secondary Inspector(s)• Reason for Inspection. Routine Permit Inspection Type: Stormwater Discharge, Individual Facility Status ■ Compliant 0 Not Compliant Question Areas: 0 Storm Water (See attachment summary) Inspection Type, Compliance Evaluation Page 1 Permit NCS000550 Owner - Facility. Carolina Power and Light Company DBA Progress Energy Inc Inspection Date 06/12/2012 Inspection Type Compliance Evaluation Reason for Visit Routine Inspection Summary: This Individual Permit has not yet been issued Requirements for stormwater remain in a combine wastewater/stormwater NC0003433 permit dated Sept 2006 that has since expired There is no Bims form to fill out - so the NCS application permit number was used until such time as the NCS permit gets issued The facility was in compliance with the NC0003433 stormwater permit requirements Page 2 Permit NCS000550 Owner - Facility Carolina Power and Light Company DBA Progress Energy Inc Inspection Date: 06/12/2012 Inspection Type Compliance Evaluation Reason for Visit Routine Stormwater Pollution Prevention Plan Does the site have a Stormwater Pollution Prevention Plan? # Does the Plan include a General Location (USGS) map? # Does the Plan include a "Narrative Description of Practices"? # Does the Plan include a detailed site map including outfall locations and drainage areas? # Does the Plan include a list of significant spills occurring during the past 3 years? # Has the facility evaluated feasible alternatives to current practices? # Does the facility provide all necessary secondary containment? # Does the Plan include a BMP summary? # Does the Plan include a Spill Prevention and Response Plan (SPRP)? # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? # Does the facility provide and document Employee Training? # Does the Plan include a list of Responsible Party(s)? # Is the Plan reviewed and updated annually? # Does the Plan include a Stormwater Facility Inspection Program? Has the Stormwater Pollution Prevention Plan been implemented? Comment Qualitative Monitoring Has the facility conducted its Qualitative Monitoring semi-annually? Comment Analytical Monitoring Has the facility conducted its Analytical monitoring? # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? Comment Permit and Outfalls # Is a copy of the Permit and the Certificate of Coverage available at the site? # Were all outfalls observed during the inspection? # If the facility has representative outfall status, is it properly documented by the Division? # Has the facility evaluated all illicit (non stormwater) discharges? Yes No NA NE ■000 ■ Q ❑ Q ■ ❑ Q Q ■Q❑n ❑n■n 0000 ■nnn ■000 ■ Q Q 0 ■000 ■❑00 ■ Q Q Q 0000 ■nnn ■ 0 00 Yes No NA NE ■❑n❑ Yes No NA NE ❑000 nn■n Yes No NA NE Page 3 Permit- NCS000550 Owner - Facility Carolina Power and Light Company DBA Progress Energy Inc Inspection Date 06/12/2012 Inspection Type. Compliance Evaluation Reason for Visit- Routine Comment. The facility reports the coal fired boiler will be shutdown this Fall 2012 and subsequently all coal ash ponds will be closed SW Outfalls currently Included In the expired (NC0003433) will change activities through the operational changes expected at the facility The permittee should keep the NPDES SW Permitting Unit updated with the changes, so that the SW Individual Permit (NCS000550 currently in review) can be updated appropriately before issuance. Page 4