NCG500594_Inspection_20111115

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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
Kimberly Kashmer, CSP
EHS Analyst
Progress Energy Carolinas, Inc.
198 Energy Way
Hamlet, NC 28345
Subject:
November 15, 2011
COMPLIANCE EVALUATION INSPECTION (CEI)
Richmond County Combustion Turbine Plant
Certificate of Coverage NCG500594
Richmond County
Dear Ms. Kashmer,
Dee Freeman
Secretary
Enclosed you will find a copy of the Compliance Evaluation Inspection report for the
routine inspection that was conducted on November 9, 2011 at the Richmond Plant. The purpose
of the inspection was to evaluate compliance with the requirements of the Wastewater General
Permit NCG500000 series. As part of the inspection, a tour of the plant was conducted. All
observations are in Section D. Summary of Findings/Comments of this inspection report. Please
notice the two recommendation in Section D. On the day of the inspection, this facility was
found to be in compliance with the requirements of the permit. You are commended for your
initiative and proactive approach for documentation, monitoring, and on -site SOP. Please keep
up the good work. I appreciate the time and professional courtesy that you and Steve Hammond
(Chemistry Technician. On -Site) extended during. the inspection. No additions" response is
necessary from your office to the DWQ-Fayetteville Regional Office concerning t_ais report. If
you have any questions, please feel free to contact me at [phone].
Dale Lopez
Environmental Specialist
Enclosures: EPA Water Compliance Inspection Report
Computer instructions for using NCDENR website for Chlorine 5-standard curve
Example of Chlorine Meter Calibration Curve Verification
Aerial view of Progress Energy and locations of 001, 002, and 003
CC:
ile eo Z
- 225 Green St, Suite 714, Fayetteville, NC 28301-5043
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal opportunity i Affirmative Action Employer
One
NorthCarolina
Naturally

United States Environmental Protection Agency
EPA Washington, D.C. 20460
Water CompIianr a 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
1 I NI 2 151 3"1NCG500594 1 11 121 11/11/09 117
Type Inspector Fac Type
181 C1 191 S 1 201 1
I I I .I I I I I 1 1 I 1 I 1 166
Remarks
211 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 .II I 1 I I I 11' 1 1
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA----------------Reserved---- ---
671 2.0 169 70141 71 I I 721 NI 731 1 1 74 751 1 1 1 1 1 1 1 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)
Richmond County Combustion Turbine Plant
198 Energy Way
Hamlet NC 28345
Entry Time/Date
10:30 AM 11/11/09
Permit Effective Date
07/08/01 -
Exit Time/Date
02:00 PM 11/11/09
Permit Expiration Date
12/07/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Brenda Brickhouse,P0 Box 1551 Raleigh NC 276021551//919-362-3588/9193623266 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Other
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Names) an Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers , Date
Dale Lopez \N ig4, FRO WQ//910=433-3300 Ext.712/ / / % °y �//
Signature of. nagement Q A Reviewer Agency/Office/Phone and Fax Numbers Date
G. 1 ,�.c vD 1111 i ,
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page #

3I
NPDES
NCG500594
111 121
yr/mo/day
11/11/09
I17
Inspection Type
181
CI
(cont.) 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Enclosed you will find a copy of the Compliance Evaluation Inspection report for the routine inspection that
was conducted on November 9, 2011 at the Richmond Plant. The purpose of the inspection was to
evaluate compliance with the requirements of the Wastewater General Permit NCG500000 series. As part
of the inspection, a tour of the plant was conducted. Please notice the two recommendations listed below
(at the end of this report).- On the day of the inspection, this facility was found to be in compliance with the
requirements of the permit. You are commended for your initiative and proactive approach for
documentation, monitoring, and on -site SOP. Please keep up the good work. I appreciate the time and
professional courtesy that you and Steve Hammond (Chemistry Technician On -Site) extended during the
inspection. No additional response is necessary from your office to the DWQ-Fayetteville Regional Office
concerning this report. If you have any questions, please feel free to contact me at [phone].
Description of the Outfalls:
Outfall 001---East Stormwater Retention Pond. The discharge water came from the evaporative coolers
where there was infrequent cooling water splash/drift. Also, there were incidental leaks with make-up water
and cooling tower water that occurred at the air inlets to the recently constructed east cooling tower. Plans
are that this cooling tower (PB5) will be infrequently drained for maintenance approximately once every two
to three years. The basin volume of PB5 was approximately 1.1 million gallons. The discharge flow rate
would be based upon pump rates. The discharge usually infiltrated into the ditch soil. When a large volume
would be present, it would discharge to an unnamed tributary, then it would flow to Marks Creek.
Outfall 002, --- Cooling Tower Water Blowdown from both PB4 and PB5 were discharged to Marks Creek
at an approximate flow rate of 168 gallons per minute ,(on June 8, 2011). The frequency of cooling tower
water blowdown depended upon the concentration of the cooling tower water conductivity. The discharge
flow meter was a Rosemont Model CD3A02A1AE5-12 (differential pressure orifice style flow meter). Since
June 2011, this flow meter had been off-line (but operational) during the construction of a blowdown pump
system that would more efficiently handle both PB4 and PB5 cooling tower blowdown waters. The
construction of the blowdown pump system was planned to be completed by the end of 2012. Presently, a
temporary transfer pump with flow meter was used for cooling tower water blowdown.
Outfall 003 --- Southwest Stormwater Retention Pond, cooling tower PB4 (on the south side of the facility)
was infrequently drained for maintenance approximately once every two to three years. The basin volume
of PB4 was approximately 0.85 million gallons, and it discharged to an unnamed tributary that flowed to
Marks Creek. The discharge flow rate would be based upon pump rates.
The following were general notes about the facility. No filter and filter backwash water was present or
discharged. Sodium hypochlorite (12% bleach) was used as a biocide in cooling tower water. The chlorine
was dechlorinated with ChemTreat BL-124 (Sodium Bisulfite). Compressed air was from three
Ingersoll-Rand Oil Free Air Compressors. Chillers, condensers, or refrigerant units were not used. The
Cooling Tower make-up water source was Richmond County Water Plant. Portable demineralizers on
trailers were used to prepare clean make-up water for the boilers of the Heat Recovery Steam Generators
Page # 2

a
Permit: NCG500594 Owner - Facility: Richmond County Combustion Turbine Plant
Inspection Date: 11/09/2011 Inspection Type: Compliance Evaluation
(HRSG). The regeneration backwash water from the demineralizers was taken off -site for disposal. The
aerial photograph attacted to this report indicated the locations of Outfalls 001, 002, & 003.
Recommendations
1. Annual flow meter calibration:
Recommend that, in order to calculate the % error, the calibration report sheet indicate the flow meter
reading before and after calibration. According to NCG500594, Part II, Section D, 2: "The devices shall be
installed, calibrated and maintained to ensure that the accuracy of the measurements are consistent with
the accepted capablity of that type of device. Devices selected shall be capable of measuring flows with a
maximum deviation of less than 10% from the true discharge rates throughout the range of expected
discharge volumes."
2. Annual five -standard chlorine curve that is established or verified at least every 12 months:
Please perform a five -standard series chlorine curve.for the total residual chlorine test. Presently, your
facility has performed a four -standard chorine curve. The curve must bracket the sample range, and_should
have a reporting limit low level calibration standard (a 15 pg/L standard low standard in the curve is
recommended when the permit limit is 17 pg/L). Please phone the DWQ Laboratory Certification (Tonja
Springer 919-733-3908 Ext. 241) with any questions concerning this recommendation. As a suggestion,
there are commercial laboratories that will perform the annual five -standard chlorine curve on your HACH
DR-2400 spectrophotometer for you. On the day of performing the analysis on the Outfall sample, please
analyze a blank in order to zero the instrument and please analyze a check standard on each day that the
samples are tested. A certified gel type standard may be used (good for approximately one year). It is
recommended that the check standard be within 10% of the known value. Ref: Std Methods, 20th Edition —
Method 1020E Quality Control (10) page 1-7.
The following are the computer instructions for using the NCDENR website for Chlorine 5-standard curve
Go to http://portal.ncdenr.org/web/wq/lab/cert/field/policy
Scroll down to the middle of the page to "Tools for Field Laboratories"
Click "Total Residual Chlorine Curve Verification Calculator" (Excel spreadsheet/worksheet)
Click "Open" on the toolbar at the bottom of the computer screen
Type in your values in the "Observed, pg/L" column
Print off your worksheet and keep it in your records file.
Page # 3

Permit: NCG500594 Owner - Facility: Richmond County Combustion Turbine Plant
Inspection Date: 11/09/2011 Inspection Type: Compliance Evaluation
Other
Comment:
Yes No NA NE
Page # 4

Computer instructions for using NCDENR website for Chlorine 5-standard curve
Go to http://portal.ncdenr.org/web/wq/lab/cert/field/policy
Scroll down to the middle of the page to "Tools for Field Laboratories"
Click —> Total Residual Chlorine Curve Verification Calculator (Excel spreadsheet/worksheet)
Click —*
Open
on the toolbar at the bottom of the computer screen
Type in your values in the Observed, µg/L column
Print off your worksheet and keep it in your records file

Date:
Analyst:
Chlorine Meter Calibration Curve Verification
Meter SIN:
Meter Program #:
Instructions: Fill in the information above. Enter the actual concentrations of the standards in your curve in cells Al 9
through A23. Enter the values that you observe on the meter in cells B19 through B23. The % Recovery and the
Correlation Coefficient will be automatically calulated.
For the curve to pass...
The Correlation Coefficient must be z 0.995
and...
Standard concentrations Tess than 50 pg/L must have a % Recovery between 75 -125 %.
and...
Standard concentrations of 50 pg/L or higher must have a % Recovery between 90 -110 %.
Actual, pg/L Observed, pg/L %o Recovery Std Pass/Fail
10 7 70 Failed
25 25 100 Passed
50 50 100 Passed
200 200 100 Passed
400 400 100 Passed
Corr. Coefficient =
slope
1.003
intercept
-1.077
1.000 Corr. Coefficient Passed
Gel/Sealed Liquid Standard Observed Concentration =
Gel/Sealed Liquid Standard Manufacturer:
Meter Program:
µg/L
Lot #:

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