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Home My WebLink AboutNC0004987_Compliance Evaluation Inspection_20210820ROY COOPER Governor ELIZABETH S. BISER Secretary S. DANIEL SMITH Director Jeff Flanagan, Plant Manager Duke Energy Carolinas, LLC. 8320 East NC Hwy. 150 Terrell, North Carolina 28682 Dear Mr. Flanagan: NORTH CAROLINA Environmental Quality August 20, 2021 Subject: Compliance Evaluation Inspection Duke Energy Carolinas/Marshall Steam Station NPDES Permit No. NC0004987 Catawba County Enclosed is a copy of the Compliance Evaluation Inspection (CEI) Report for the inspection conducted at the subject facility on August 18, 2021, by Mr. Wes Bell of this Office. Please advise the facility's Operator -in -Responsible Charge (ORC) of our findings by forwarding a copy of the enclosed report. Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at (704) 235-2192, or via email at wes.bell@ncdenr.gov. Enclosure: Inspection Report NORTH Dep®rlmont of Environmental Onolit Sincerely, EoocuSigned by: A14CC681AF27425... W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ North Carolina Department of Environmental Quality 1 Division of Water Resources Mooresville Regional Office 1610 East Center Avenue, Suite 301 I Mooresville, North Carolina 28115 704.663.1699 United States Environmental Protection Agency EPA 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 1 IN I 2 I5 I 21 1 1 1 1 1 NPDES yr/mo/day Inspection 3 I NC0004987 111 121 21/08/18 117 Type 18 i i I I 1 1 1 Inspector Fac Type 191 S I 201 1 1 1 1 11 1 1 1 I I I 1 1 1 1 1 1 I I I I I 1 11 1 1 1 I 1 P6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved 67I2.0 I 70I4 I 71IN I 72 I N I 731 I 74 751 I I 1 I I I I I I 180 l Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Marshall Steam Station NC Hwy 150 Terrell NC 28682 Entry Time/Date 08:45AM 21/08/18 Permit Effective Date 21/06/01 Exit Time/Date 01:25PM 21/08/18 Permit Expiration Date 21/09/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Gregory Paul Phillips/ORC/828-478-7647/ Joseph Scott La Sala/EHS Professional Sr/828-478-7820 /8284787776 Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Jeff Flanagan,8320 E NC Hwy 150 Terrell NC 28682/Station Manager/828-478-7600/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran Sludge Handling DispoFacility Site Review Effluent/Receiving Wate Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) Bell of Inspector(s) Agency/Office/Phone and Fax Numbers Date DocuSigned by: 8/20/2021 Lle, 3ditWes DWR/MRO WQ/704-663-1699 Ext.2192/ art A61696D90CC3437... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date W. Corey Basinger DWR/Division of Water Quality/704-235-2194/ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. DocuSigned by: 8/20/2021 -A14CC681AF27425... Page# 1 NPDES yr/mo/day 31 NC0004987 111 121 21/08/18 I17 Inspection Type 18 [j 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Page# 2 Permit: NC0004987 Inspection Date: 08/18/2021 Owner - Facility: Marshall Steam Station Inspection Type: Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new MODE 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: The Division received Duke Energy's permit renewal package on 1/12/21. Ash Basin dewatering was initiated in September 2020. Additional physical/chemical treatment units (clarifier, filters, etc.) for the ash basin dewatering treatment system were commissioned in November 2020. No chlorine is added to any of the outfalls. The last compliance evaluation inspection at this facility was performed by DWR staff on 11/19/19. 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)? • ❑ El El Are analytical results consistent with data reported on DMRs? • El El El Is the chain -of -custody complete? • El ❑ ❑ 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? • El El El Has the facility submitted its annual compliance report to users and DWQ? • El ❑ ❑ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified El El • El operator on each shift? Is the ORC visitation log available and current? • El ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? • El El El 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? • El El El Facility has copy of previous year's Annual Report on file for review? El El • El Page# 3 Permit: NC0004987 Inspection Date: 08/18/2021 Owner - Facility: Marshall Steam Station Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Comment: The records reviewed during the inspection were organized and well maintained. Discharge monitoring reports (eDMRs) were reviewed for the period July 2020 through June 2021. No effluent limit violations were reported. The May 2021 eDMR will be revised and resubmitted to include a missing effluent selenium result (Outfall 002) during the week of 5/23/21 — 5/29/21. Following the revision of the May 2021 eDMR, the facility complied with all monitoring frequencies. 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? Yes No NA NE • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Comment: Permit -required analyses are performed by Duke Energy's Analytical Laboratory, Pace Analytical Services and ETS, Inc. Duke Energy/Marshall Steam Station has also been certified for field analyses (pH and temperature) under Certification No. 5155. Influent Sampling # Is composite sampling flow proportional? Is sample collected above side streams? 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 sampling performed according to the permit? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ Comment: The subject permit requires sampling (grab) at internal Outfalls 003, 006 and 010. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ ❑ IN ❑ 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)? Page# 4 Permit: NC0004987 Inspection Date: 08/18/2021 Owner - Facility: Marshall Steam Station Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE Comment: The subject permit requires effluent grab samples at all effluent discharge outfalls (001, 002, and 005). Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, ▪ ❑ ❑ ❑ and sampling location)? Comment: Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? • ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ • ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: The NPDES facilities appeared to be properly operated and well maintained. The FGD wet scrubber wastewater treatment system (WTS) is staffed 24/7 with certified operators while the facility is in operation. The facility is equipped with a computer monitoring system that allows on -site staff to oversee the operational status of the treatment components at Outfalls 002, 005, 006 and 010 and yard sumps including alarm conditions, flow, pH, temperature, TSS, etc. Equalization Basins Is the basin aerated? Is the basin free of bypass lines or structures to the natural environment? Is the basin free of excessive grease? Are all pumps present? Are all pumps operable? Are float controls operable? Are audible and visual alarms operable? # Is basin size/volume adequate? Yes No NA NE ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ▪ ❑ ❑ ❑ Comment: The FGD wet scrubber WTS has two equalization tanks equipped with mixers (all operational). The wastewater from the equalization tanks is pumped to three reaction tanks (pH adjustment, settling aids) prior to entering the secondary clarifiers. All reaction tanks (equipped with mixers) were operational and in service. Secondary Clarifier Is the clarifier free of black and odorous wastewater? Is the site free of excessive buildup of solids in center well of circular clarifier? Are weirs level? Yes No NA NE • ❑ ❑ ❑ Page# 5 Permit: NC0004987 Inspection Date: 08/18/2021 Owner - Facility: Marshall Steam Station Inspection Type: Compliance Evaluation Secondary Clarifier Is the site free of weir blockage? Is the site free of evidence of short-circuiting? Is scum removal adequate? Is the site free of excessive floating sludge? Is the drive unit operational? Is the return rate acceptable (low turbulence)? Is the overflow clear of excessive solids/pin floc? Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) Comment: Both secondary clarifiers were operational and in service. Pumps-RAS-WAS Are pumps in place? Are pumps operational? Are there adequate spare parts and supplies on site? Comment: Chemical Feed Is containment adequate? Is storage adequate? Are backup pumps available? Is the site free of excessive leaking? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: Chemical addition facilities have been installed at the treatment systems for Outfall 002, 005, 006 and 010. Filtration (High Rate Tertiary) Yes No NA NE Type of operation: Up flow Is the filter media present? ■ ❑ ❑ ❑ Is the filter surface free of clogging? • El ❑ ❑ Is the filter free of growth? • El El El Is the air scour operational? ❑ ❑ • ❑ Is the scouring acceptable? ■ El El El Is the clear well free of excessive solids and filter media? ■ ❑ El El Page# 6 Permit: NC0004987 Inspection Date: 08/18/2021 Owner - Facility: Marshall Steam Station Inspection Type: Compliance Evaluation Filtration (High Rate Tertiary) Yes No NA NE Comment: Following clarification, the wastewater is conveyed through sand filtration, two -stage bioreactors and ultrafiltration prior to being pumped to the first cell of the lined retention basin (Outfall 005). All treatment processes were operational and in service. 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: Outfalls 002, 005, 006 and 010 are equipped with magnetic flow meters. All flow meters are verified annually and were last verified on 9/4/20 by on -site staff. Outfall 001 flows are based on pump curves and Outfall 003 flows are based on pipe diameter/water level measurements and supporting flow calculations. Effluent Pipe 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? Yes No NA NE • ❑ ❑ ❑ Comment: Outfalls 001, 002, 003 and 005 were discharging at the time of the inspection. No floatable solids, foam and/or oil sheens were observed at the discharge outfalls and receiving stream. Solids Handling Equipment Is the equipment operational? Is the chemical feed equipment operational? Is storage adequate? Is the site free of high level of solids in filtrate from filter presses or vacuum filters? Is the site free of sludge buildup on belts and/or rollers of filter press? Is the site free of excessive moisture in belt filter press sludge cake? The facility has an approved sludge management plan? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: The FGD wet scrubber WTS is equipped with three filter presses. No sludge dewatering was occurring at the time of the inspection. Dewatered sludge, off -spec gypsum, bottom ash, and fly ash are disposed in the permitted on -site industrial landfill. The gypsum material from the FGD wet scrubber system is reused by an outside company (National Gypsum) in the dry wall market. Page# 7