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HomeMy WebLinkAboutNCS000589_CEI_20200217ROY COOPER Governor MICHAEL S._REGAN Secretary BRIAN WRENN Acting Director Duke Energy Progress, LLC Attn: Paul Draovitch, Senior Vice President 526 South Church Street Office 03233 Charlotte, NC 28202 NORTH CAROLINA Environmental Quality February 17, 2020 Subject: COMPLIANCE EVALUATION INSPECTION NPDES Stormwater Permit NCS000589 Duke Energy Progress, LLC Weatherspoon Steam Electric Plant Robeson County Dear Mr. Draovitch: On February 11, 2020, a site inspection was conducted for the Weatherspoon Steam Electric Plant facility located at 491 Power Plant Road, Lumberton, Robeson County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Mr. Kent Tyndall, Lead EHS Professional, was also present during the inspection and his time and assistance is greatly appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater Permit NCS000589. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as an unnamed tributary to the Lumber River and the Lumber River, class C;Sw waters in the Lumber River Basin. As a result of the inspection, the facility was found to be compliant with the conditions of NPDES Stormwater Permit NCS000589. Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the inspection. Please be advised that violations of the NPDES Stormwater Permit are subject to a civil penalty assessment of up to $25,000 per day for each violation. If you or your staff have any questions, comments, or needs assistance with understanding any aspect of your permit, please contact me at (910) 433-3394 or via e-mail at mike.lawyer@ncdenr.gov. Sincerely, Michael Lawyer, CPSWQ Environmental Program Consultant DEMLR Enclosure: Compliance Inspection Report ec: Kent Tyndall, Lead EHS Professional Duke Energy Progress, LLC Joyce Dishman, Senior Environmental Specialist — Duke Energy Progress, LLC cc: FRO — DEMLR, Stormwater Files e:!ar,of NORMGAROLI EQ;// ow�m�marnvw_W'Ju,i1 North Carolina Department of Environmental Quality 1 Division of Energy, Mineral and Land Resources Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301 910.433.3300 Permit: NCS000589 SOC: County: Robeson Region: Fayetteville Contact Person: Kent Tyndall Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): On -site representative Related Permits: Compliance Inspection Report Effective: 02/01/17 Expiration: 01/31/22 Owner: Duke Energy Progress LLC - Effective: Expiration: Facility: Weatherspoon Steam Electric Plant 491 Power Plant Rd Title: Lead EHS Professional Certification: Kent Tyndall Inspection Date: 02/11/2020 EntryTime: 10:15AM Primary Inspector: Mike Lawyer/19 Secondary Inspector(s): ,[/ Reason for Inspection: Routine Permit Inspection Type: Stormwater Discharge, Individual Facility Status: Compliant Not Compliant Question Areas: Storm Water (See attachment summary) Lumberton NC 28358 Exit Time: 12:35PM Phone: 910-341-4775 Phone: 910-341-4775 Phone: 910-433-3394 Inspection Type: Compliance Evaluation Page 1 of 3 Permit: NCS000589 Owner - Facility: Duke Energy Progress LLC Inspection Date: 02/11/2020 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Met with Kent Tyndall, Lead EHS Professional, at the facility to conduct an inspection for compliance with the facility's individual stormwater permit. Reviewed facility's Stormwater Pollution Prevention Plan (SPPP), which contains all permit -required components as well as associated documentation pertaining to the annual review/update requirements of the permit. Monitoring conditions of the permit are required only during ash transport through specified drainage areas. The individual stormwater permit identifies three stormwater discharge outfalls (SW-1, SW-2 and SW-3) within the drainage areas along the ash haul route. According to Mr. Tyndall, ash hauling activities began in September 2017 and are on -going. . Reviewed monitoring records from third quarter 2017 up through the date of inspection. Records indicate'No Discharge' from SW-1 and SW-3. Drainage from the access road to what has been identified as SW-1 is primarily sheet flow into the road shoulder. Catch basins leading to SW-3 have been covered with a metal plate, virtually eliminating any flow/discharge to SW-3. Records for SW-2 show an exceedance of the benchmark value for TSS from the December 2018 sampling event. As required by the Tier One response actions in the individual permit, monthly monitoring began at SW-2 in January 2019. Monitoring events in November and December 2019 (no discharges recorded for previous months) resulted in the TSS value meeting the benchmark, however an exceeedance of the benchmark value for Zinc occurred with the December 2019 monitoring event. A discussion was held regarding a potential cause for Zinc exceedances being due to galvanized metals onsite such as roof gutters, building material, etc. and the possibility of requesting regulatory relief from monthly monitoring due to Zinc exceedances if it can be demonstrated that the exceedances are not associated with the industrial activity of ash hauling. The process for requesting Representative Outfall Status (ROS) was also discussed and a copy of the ROS Request Form was subsequently provided to Mr. Tyndall via e-mail. After the records review, ash hauling/transport activities that were occurring at the time of inspection were observed. Observations were also made of the stormwater catch basins and outfalls. At the time of inspection, facility appeared to be well operated/maintained and in compliance with permit conditions. Page 2 of 3 Permit: NCS000589 Owner - Facility: Duke Energy Progress LLC Inspection Date: 02/11/2020 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 Monitorinq 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? Comment: Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ■❑❑❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ■❑❑a Yes No NA NE ■❑❑❑ Yes No NA NE ■❑❑❑ ❑ ❑ ❑ Yes No NA NE ❑ ❑ ❑ ■❑❑❑ ❑❑■❑ ■❑❑❑ Page 3 of 3