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HomeMy WebLinkAboutNC0003433_2023 Compliane Evaluation Inspection_20240104 January 4th, 2023 Jessica Bednarcik Duke Energy Progress, LLC 526 S Church Street Charlotte, NC 28201 Subject: Compliance Evaluation Inspection Cape Fear Steam Electric Power Plant NPDES Permit NC0003433 Chatham County Dear Ms. Bednarcik: On Wednesday, January 3rd, 2023, Kevin Fowler conducted a compliance evaluation inspection of the treatment systems located at the Cape Fear Steam Electric Power Plant, hereinafter referred to as the Cape Fear Plant. The purpose of this visit was to conduct an inspection of the subject NPDES facility. During the inspection, the presence and cooperation of Jacquelyn Leanne Wilson, Operator in Responsible Charge (ORC), and Joyce Dishmon, Permitting and Compliance Support for Duke Energy Progress, were helpful and appreciated. The Cape Fear Plant, located at 500 CP&L Road, Moncure North Carolina 27559 in Chatham County, began operation in 1923, and ceased commercial operations in October 2012, when the last 2 coal-fired units were retired. The Cape Fear Plant produced electricity from the burning of coal. Coal ash, created when coal is burned, is stored in five ash basins located on the plant’s site. Since October 2012, there has been no coal combustion at the plant and, therefore, no additional ash added to the ash basins. Duke Energy Progress is undergoing efforts to decommission the Cape Fear Plant and close the 5 coal ash basins at the site. Duke Energy Progress demolished the main plant structures, including the smokestacks and boilers. Efforts are still ongoing to remove the ash stored in the plant’s ash basins. This NPDES compliance evaluation inspection consisted of the following:  Review of the NPDES permit;  Review of the owner/facility information;  Review of July 2022 – December 2023 monitoring data.  Review of July 2022 – December 2023 compliance history.  On-site inspection of the treatment systems; and  On-site inspection of the internal and combined discharge outfalls. DocuSign Envelope ID: B0B9B20C-D7D5-43D9-B8A3-415DF72C1BC5 Page 2 of 3 Cape Fear Steam Electric Power Plant Compliance Inspection 2024 2 Findings during the pre-inspection file review were: 1. Through NPDES permit NC0003433, Duke Energy Progress is authorized to discharge treated wastewater from the Cape Fear Plant to the Cape Fear River and an unnamed tributary to the Cape Fear River, classified WS-IV waters in the Cape Fear River Basin. The current NPDES permit was issued effective October 1, 2020, and expired June 30, 2023. An application for renewal of this permit was submitted in December of 2022. The Division is in the process of renewing this NPDES permit. 2. The Cape Fear Plant provides treatment and discharge of combined wastewater through outfall pipe 008 to the Cape Fear River. The water prior to this outfall goes through treatment for pH and TSS. If any of these parameters are not met then then discharge must cease to outfall 008. Outfall 001, 005, 008A, and 008B are all designated as emergency discharge only. Outfall 009 has been permitted and if constructed would discharge episodic wastewater collected from isolated areas of the beneficiation operation. 3. For the review period July 2022 – December 2023, no valid violations were found. Three violations present were all BIMS errors. Findings during the inspection were: 4. The operator’s log and supporting analytical documentation were consistent and up to date. 5. The Cape Fear Plant lab (certification number 5101) was removed in September of 2022. Duke Energy Progress- HEEC (certification number 5710) now collects field samples. Pace Analytical Services provide sampling for instream samples (certification number 40), Instream and dewatering Mercury (certification number 329), Dewatering Field Samples (certification number 5342), and Oil and Grease (certification number 12.) ETT Environmental, Inc provides sampling for Cape Fear Toxicity (certification number 22.) 6. DMR reports from July 2023, and February 2023 were brought to be compared to laboratory analytical results. No discrepancies were found. 7. The observed treatment systems consisted of the 5 Ash Basins and the combined wastewater to the Cape Fear River. a) The inspector observed internal outfall 001 has been sealed and is no longer in operation. The on-site representatives stated outfall 001 is not in the renewal draft permit. b) The on-site representatives stated the water from each pond is pumped to the 1978 Basin for holding/settling. The water is then pumped from the 1978 Basin to the treatment system on site. The treatment system on site is used to treat pH and TSS. If release limits designated by the permit are met after treatment, then the wastewater is released to Outfall 008. If limits designated by the permits during discharge are not met, then valves will automatically engage, and the water is diverted back to the 1978 Basin. c) Outfall 008A is a Culvert which is used only for emergency discharge associated with eminent threat of 1963/1970 Ash Basin Overflow. i) Outfall OO8B is a spillway that was required to be put in place due to dam safety regulations. ii) Outfalls 005 and 007 are only used for emergency discharge in the event of potential overflow. DocuSign Envelope ID: B0B9B20C-D7D5-43D9-B8A3-415DF72C1BC5 Page 3 of 3 Cape Fear Steam Electric Power Plant Compliance Inspection 2024 3 iii) Outfall 009 has not been constructed. Its potential future use would be to discharge episodic waste water collected from isolated areas of the beneficiation operation. This wastewater is currently either pumped and hauled to Shamrock Environmental or used as dust suppression. d) The inspector did not observe any discharge from any outfalls. All outfall right of ways were properly maintained. 8. As required by Part II, Section E.9a of the subject NPDES permit, please be certain to notify this office within 24 hours of using the emergency discharge as its use may result in the discharge of significant amounts of wastes which would be abnormal in quantity. As indicated in item 8 above, please notify this office within 24 hours of operating the emergency discharges located at the ash basins. If you have questions or comments about the inspection, this report or the requirements to take corrective action (if applicable), please contact Kevin Fowler at 919-437-0047 or via email at kevin.fowler@deq.nc.gov Sincerely, Vanessa Manuel Water Quality Regional Assistant Supervisor Raleigh Regional Office Attachments: EPA Water Compliance Inspection Report Cc: Laserfische Jacquelyn Leanne Wilson (ORC) DocuSign Envelope ID: B0B9B20C-D7D5-43D9-B8A3-415DF72C1BC5 EPA United States Environmental Protection Agency Washington, D.C. 20460 Water Compliance Inspection Report Form Approved. 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 N 52 NC0003433 23/01/03 C S31112171819 20 21 66 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved------------------- N67707172 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Cape Fear Steam Electric Power Plant 500 Cp L Rd Moncure NC 27559 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:00AM 23/01/03 20/10/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Jacquelyn Leanne Wilson/ORC/336-504-2827/ Other Facility Data 12:48PM 23/01/03 23/06/30 Name, Address of Responsible Official/Title/Phone and Fax Number Joyce Dishmon,864 S Edgewood Rd Eden NC 27288/Permitting and Compliance/336-623-0238/ Contacted No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Operations & Maintenance Records/Reports Self-Monitoring Program Facility Site Review Effluent/Receiving Waters 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/Office/Phone and Fax Numbers Date Kevin Fowler DWR/RRO WQ/919-791-4200/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page#1 01/04/2024 DocuSign Envelope ID: B0B9B20C-D7D5-43D9-B8A3-415DF72C1BC5 1/5/2024 NPDES yr/mo/day 23/01/03 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Findings during the pre-inspection file review were: 1.Through NPDES permit NC0003433, Duke Energy Progress is authorized to discharge treated wastewater from the Cape Fear Plant to the Cape Fear River and an unnamed tributary to the Cape Fear River, classified WS-IV waters in the Cape Fear River Basin. The current NPDES permit was issued effective October 1, 2020, and expired June 30, 2023. An application for renewal of this permit was submitted in December of 2022. The Division is in the process of renewing this NPDES permit. 2.The Cape Fear Plant provides treatment and discharge of combined wastewater through outfall pipe 008 to the Cape Fear River. The water prior to this outfall goes through treatment for pH and TSS. If any of these parameters are not met then then discharge must cease to outfall 008. Outfall 001, 005, 008A, and 008B are all designated as emergency discharge only. Outfall 009 has been permitted and if constructed would discharge episodic wastewater collected from isolated areas of the beneficiation operation. 3.For the review period July 2022 – December 2023, no valid violations were found. Three violations present were all BIMS errors. Findings during the inspection were: 4.The operator’s log and supporting analytical documentation were consistent and up to date . 5.The Cape Fear Plant lab (certification number 5101) was removed in September of 2022. Duke Energy Progress- HEEC (certification number 5710) now collects field samples. Pace Analytical Services provide sampling for instream samples (certification number 40), Instream and dewatering Mercury (certification number 329), Dewatering Field Samples (certification number 5342), and Oil and Grease (certification number 12.) ETT Environmental, Inc provides sampling for Cape Fear Toxicity (certification number 22.) 6.DMR reports from July 2023, and February 2023 were brought to be compared to laboratory analytical results. No discrepancies were found. 7.The observed treatment systems consisted of the 5 Ash Basins and the combined wastewater to the Cape Fear River. a)The inspector observed internal outfall 001 has been sealed and is no longer in operation. The on-site representatives stated outfall 001 is not in the renewal draft permit. b)The on-site representatives stated the water from each pond is pumped to the 1978 Basin for holding/settling. The water is then pumped from the 1978 Basin to the treatment system on site. The treatment system on site is used to treat pH and TSS. If release limits designated by the permit are met after treatment, then the wastewater is released to Outfall 008. If limits designated by the permits during discharge are not met, then valves will automatically engage, and the water is diverted back to the 1978 Basin. c)Outfall 008A is a Culvert which is used only for emergency discharge associated with eminent threat of 1963/1970 Ash Basin Overflow. i)Outfall OO8B is a spillway that was required to be put in place due to dam safety regulations. ii)Outfalls 005 and 007 are only used for emergency discharge in the event of potential overflow. iii)Outfall 009 has not been constructed. Its potential future use would be to discharge episodic waste water collected from isolated areas of the beneficiation operation. This wastewater is currently either pumped and hauled to Shamrock Environmental or used as dust suppression. d)The inspector did not observe any discharge from any outfalls. All outfall right of ways were properly maintained. NC0003433 17 (Cont.) Page#2 DocuSign Envelope ID: B0B9B20C-D7D5-43D9-B8A3-415DF72C1BC5 Permit:NC0003433 Inspection Date:01/03/2023 Owner - Facility: Inspection Type: Cape Fear Steam Electric Power Plant 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? Permit expired June of 2023. Application submitted December of 2022.Comment: 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? 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? 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? ORC log included daily log as well as time spend on site.Comment: Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? Page#3 DocuSign Envelope ID: B0B9B20C-D7D5-43D9-B8A3-415DF72C1BC5 Permit:NC0003433 Inspection Date:01/03/2023 Owner - Facility: Inspection Type: Cape Fear Steam Electric Power Plant Compliance Evaluation Operations & Maintenance Yes No NA NE Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge, and other that are applicable? Facility takes temperature, pH, and TSS data for process control. (Performed by Duke Energy Lab from a different site.) Comment: Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? All right of ways properly maintained. Outfall 1 is potentially being taken out of permit (currently permit draft out for review.) Comment: Page#4 DocuSign Envelope ID: B0B9B20C-D7D5-43D9-B8A3-415DF72C1BC5