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HomeMy WebLinkAboutBuck Steam Station (2)NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary August 18, 2010 Mr. Allen Stowe, Water Management Duke Energy Post Office Box 1006/EC13K Charlotte, North Carolina 28201 -1006 Subject: Compliance Evaluation Inspection Buck Steam Station NPDES Permit No. NC0004774 Rowan County, N.C. Dear Mr. Stowe: Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on August 6, 2010 by Mr. Wes Bell of the Mooresville Regional Office. Please advise the facility's Operator -in- Responsible Charge of our findings by forwarding a copy of the enclosed report. The facility has several stormwater outfalls that discharge into waters of the State. Although the facility operates under an internal stormwater management program, potential exposures to the stormwater runoff as a result of the facility's operations exist. Following discussions with the Division's Stormwater Permitting Unit (SPU), the stormwater discharges will need to be covered under an individual stormwater permit. A completed permit application and supporting documentation (including fee) should be mailed to the attention of Mr. Bradley Bennett, Supervisor, DWQ /Stormwater Permitting Unit, 1617 Mail Service Center, Raleigh, N.C. 27699 -1617, unless otherwise directed by Mr Bennett and/or SPU staff. The permit application and supporting information can be found at the following website address: hLV:Hportal.ncdenr.orp /web /M /ws /su/npdessw#General Permits NPDES. The permitting of the stormwater outfalls should be initiated by Duke Energy within 30 days following receipt of this report. Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663 -1699 \ Fax: VO4) 663-Mb 1 Customer Service: 1- 877 -623 -6748 Internet httpJlportal.ncdenr.orgAvebtwq An Equal Opportunity 1 Affirmarrve Actlon Employer - 50% Recycled110% Post consumer PaPer NorthCarolina NWIM711lf Mr Allen Stowe Page Two August 18, 2010 Should you have questions concerning this report, please do not hesitate to contact Mr Bell at (704) 663 -1699 or Mr Bennett at (919) 807 -6378 Sincerely, i . M 0- � I r Robert B Krebs Regional Supervisor Surface Water Protection Enclosure Inspection Report cc Kreig Leuschner, Duke Energy Rowan County Health Department Permit NCO064774 Owner - Facility Buck Steam Station Inspection Date 08/06/2010 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 (DMRs) were reviewed for the period June 09 through May 10 No effluent limit violations were reported and all monitoring frequencies were correct Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? ■ CI n n Are all other parameters(excluding field parameters) performed by a certified lab? ■ 0 n n ■, n n n # 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)? ■ o o n Incubator (Fecal Coliform) set to 44 5 degrees Celsius + /- 0 2 degrees? n n ■ n 'Incubator (BOD),set to 20 0 degrees Celsius +/- 1 0 degrees? ❑ ❑ ® n Comment On -site field analyses (temperature, pH) are performed under laboratory certification #5151 Duke Energy's Certified Laboratory ( #248) and the contracted services of ETS, Inc and Prism Laboratories, Inc provide analytical support The pH meter appeared to be properly calibrated (and documented) Effluent Sampling Yes No NA NE Is composite sampling flow proportional? n Q ■ n Is sample collected below all treatment - units? ■ n n n Is proper volume collected? n n ■ n n n ■ 0 Is the tubing clean? # Is proper temperature set for sample storage (kept at,less than or equal to 6 0 degrees Celsius)? ■ n n n Is the facility sampling performed as required by the permit (frequency, sampling type representative)j ■ 0 0 n Comment The subject permit requires effluent grab samples Upstream Mownstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? n n ■ Comment The Division has conditionally waived the Instream monitoring requirements due to Duke Energy's participation In the Yadkin -Pee Dee River Basin Association Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? ■ n n n Does the facility analyze, process,coritrol parameters, fonex MLSS, MCRT, Settleable Solids; pH, DO, Sludge n 0 ■ n Judge, and other that are applicable? Page # 4 Permit NC0004774, Owner - Facilq Buck Steam Station Inspection Date 08!0612010 Inspection Type Compliance Evaluation r ar Operations & Maintenance Yes No NA NE Comment The facility appeared to be properly operated and well maintained No chlorine Is added to the once - through non - contact cooling water ( Outfall 001) The results of the pH and temperature measurements performed (by DWQ staff) at the outlet of each ash basin cell were as follows 7 80 s u /29 2 degrees celslus (cell #1) and 6 67 s'u /28 8 degrees�celsius (cell #2) See Effluent/Receiving Stream Section regarding the results oficell #3 %effluent discharge Monthly dike Inspections are performed by the on -site staff and the annual dike Inspections are performed by either Duke Energy personnel (engineers) or a third party Chemical Feed Yes No NA NE Is,contamment adequate ■, n `n n Is storage adequate? C I! 0 0 Are backup pumps available? n n n ■ Is the site free of excessive leaking? ■ n n n Comment Sulfuric Acid is added on,an as- needed basis near�the tower�(outlet) of cell, #3 The sulfuric acid is housed lin tote, bins,equlppedwith spill containment Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? n n ■ n Is flow meter calibrated annually? 00 ■ n 'Is the flow meter operational? n n ■ n (If units are separated) Does the chart,recorder match the flow meter? 01 n ■ 0 Comment Effluent flows from Outfall 001 are based on pump curves and Outfall 002 flows are measured by a staff guage and weir (with supporting calculations) Outfall 002A (yard sump overflows) flows would be based on calculations ,involving discharge volume measured over specified time Intervals Outfall 002A is equipped with ultrasonic and float -type alarrnzystems to ndtify,on -site personnel (via central room) of high water conditions Effluent Pipe Yes No NA NE Is nght of way to the outfall properly maintained? ■ n n n Are the receiving water free,of,foam other,than trace amounts and other debris? ■ n n, n If effluent (diffuser,pipes are required) are they operating properly? n ❑ ■ 'n Comment No foam or sheens'were observed In the receiving stream at Outfall 001 Outfall 002 effluent appeared clear with no floatable solids or foam The pH and' temperature at the outlet of cell #3 /Outfall 002 were measured of 7 27 s u and 28 7 degrees Celsius The receiving stream did not appear to be negatively impacted Page # 5 Comments from MRO reaardina new draft permits for Allen. Marshall. and Riverbend Comments from Wes and Donna following inspections at Allen and Marshall Steam stations on 6/7 and 6/8 (clarification given by Marcia): • They need a stormwater permit. (None of the Duke facilities have individual stormwater permits. Since stormwater is mentioned in two of the permits already should the permit become a combined wastewater /stormwater permit for all discharges of stormwater ?) 1 Marshall — no mention of stormwater discharges in NC0004987 o Allen — Stormwater is mentioned as a discharge through Outfall 002 in NC0004979) o Riverbend — Stormwater is mentioned as a discharge through Outfall 002 in NC0004961 • Sampling should be more than quarterly, ideally weekly. (This is sampling at Outfall 002 [final effluent] and applies to both facilities that were inspected) • Sampling should be composite, if it can't be flow proportional, then at least time based. o '(This is sampling at Outfall 002 [final effluent] and applies to both facilities that were inspected- this comment would also apply to Riverbend (M. Allocco comment). From inception of permit (1977 copy available at MRO) until 1989 samples except for Oil & grease were composite samples. No information in permit files (fact sheets, staff reports, etc.) detailing why the change was made. In the 2001 version of the permit all parameters except Oil & Grease and TSS, and sulfate are composite samples. 2002 permit notes that the monitoring has been changed from composite to grab due to the large size and consistent effluent out of the ash basin, grab sampling is considered to be equally representative of the discharge (how was this determination made ?). • Sumps outfalls (2a /b) should be sealed off, but if not they should be sampled regardless of the length of the discharge event (no hour limitation) and, yes, they can be easily sampled. (Sampling was conducted using the telescoping sampling pole owned by MRO) o Depending on the analysis results for samples collected by MRO staff there may be a need to add more analytes to the sampling requirements. MRO will forward to permitting the results of the analyses at Marshall and Allen. Facilities should have dual classification. Marshall is currently classified as PC -1; should be PC -1 and WW -1 as per D. Hood communication to M. Allocco o Allen is currently classified as PC -1; should be PC -2 and WW -2 as per D. Hood communication to M. Allocco lo Classification of Riverbend was not reviewed; currently PC -1 Use TPH, not oil and grease, if petroleum is a cause of concern. Comments from Marcia Riverbend • Section A. (5.) Biocide Condition — Line 3 "any" is misspelled as "nay ". • Section A. (5.) Biocide Condition - This section states that a biocide worksheet is not needed when introducing a new biocide to an outfall being currently tested for toxicity. Is 6his an adequate test of toxicity? The quarterly toxicity testing is a grab sample once a quarter and would not correspond to the detailed review by DWQ personnel a biocide sheet submission would afford. Section (6.) Special Conditions bullet #1 states, "There shall be no discharge of polychlorinated bi phenyl compounds." From a compliance standpoint how do we assure this? Is it through the one analysis completed for permit renewal? What is the inspector to review? Section (6.) Special Conditions bullet #3 states, "If the permittee, after monitoring for at least six months, determines that he /she is consistently meeting the effluent limits contained herein, the permittee may request of the Director that the monitoring requirement be reduced to a lesser frequency." While this text has appeared in the permit since 1977 (oldest permit at MRO) I question whether 6 months of data is enough to determine if a constituent is absent from a discharge. Is this the timeframe given to all permittees or something special to power plants? If it is not consistent with DWQ procedures and other permits then it should be changed. Should there be a caveat that any changes to a treatment system or chemicals used in a treatment system the frequency will be increased. Section (6.) Special Conditions bullet #5 "waters" is misspelled as "wasters" Section (6.) Special Conditions bullet #5 states, "Discharge of chlorine from the use of chlorine gas, sodium hypochlorite, or other similar chlorination compounds for disinfection in the plant potable and service water systems and in sewage treatment is authorized." At what level is the chlorine discharge authorized? We are making all other permittees meet a 50 Ftg /L TRC compliance level with permit limits of either 17 pg /L or 28 ftg /L. This includes Water Treatment Plants that chlorinate the water they provide and then dechlorinate or otherwise strip chlorine before discharge. Section (6.) Special Conditions bullet #5 states, "Use of restricted use pesticides for lake management purposes by applicators licensed by the NC Pesticide Board is allowed." The EPA has just promulgated regulations that require a permit when pesticides are applied to waters of the US. I assume this requirement may be permitted by DWQ but it might also be given to the NC Pesticide Board. Need to ensure we are not providing conflicting authorizations and we may not know for —2 years. Section (7.) Permit Terms bullet #2 states, "Chemical metal cleaning will be conducted according to Duke Power approved equivalency demonstration." The Duke Power approved equivalency demonstration was submitted at some point in the past and is stored in the permit files. This does not give the inspector anything to verify when inspecting the plant. Section (7.) Permit Terms bullet #3 states, "It has been determined from information submitted that the plans and procedures in place at Riverbend Steam Station are equivalent to that of a BMP." What does this statement refer to? Somewhere between 1980 and 1984 the following caveat was removed from the permit general text and may be what this statement refers to. If so, the language in this bullet needs to be tightened to require the plans and procedure be updated on a specific schedule and available for review by DWQ inspectors or is this something that is more appropriate in a stormwater permit? To me it implies that this is currently a wastewater / stormwater permit. "The Permittee shall develop and implement a Best management practices (BMP) Plan to identify and control the discharge of oils and the Hazardous and toxic substances listed in 40 CFR, part 117 and Tables II and II of Appendix D to 40 CFR, Part 122. The plan shall include a listing of all potential sources of spills or leaks of these materials, a method for containment, a description of training, inspection and security procedures, and emergency response measures to be taken in the event of a discharge to surface waters. Sources of such discharges may include but are not limited to, materials storage areas; in -plant transfer, process and material handling areas; loading and unloading operations; plant site runoff; and sludge and waste disposal areas. The BMP plan shall be developed in accordance with good engineering practices, shall be documented in narrative form; and shall include any necessary plot, plans, drawings, and maps. The BMP Plan shall be developed no later than six months after issuance of the final permit (or modification), and shall be implemented no later than one year after issuance of the final permit (or modifications). The BMP Plan shall be maintained at the plant site and shall be available for inspection by EPA and DEM personnel." Section (8.) Special Condition for Discharge of Wastewater discusses the need for Duke to ensure there is adequate room in the ash basin for the solids and associated water generated at the plant along with stormwater runoff. It requires annual reporting to DWQ unless Duke can certify before issuance of the permit they have adequate room for the life of the permit. However, the following statement in this section is unclear or confusing. "Present information indicates a needed volume of 86.2 acre -feet in addition to solids that will be deposited to the ash pond; any change to plant operations affecting such certification shall be reported to the Director within five days." Does this statement mean that Duke needs to clear out 86.2 acre -feet before the permit is issued; need to clarify language? They must notify us within 5 days of what; first knowledge of the change in the plant operations? Since the ash basins are now high- hazard dams inspected by DLR does DLR have a say in how much solids and water are maintained in the pond? Section (9.) Special Condition — Boiler Cleaning Wastes third paragraph "at" is misspelled as "oat" and in Item #4 "has" has been misspelled as "ahs ". Section A. (2.) Effluent Limitations and Monitoring Requirements for Outfall 001 — Note #1 states, "Downstream sampling point: down stream at Mountain Island lake." This does not describe where in Mountain Island Lake the downstream sample should be collected. Should this be worded "downstream at Mountain Island Lake dam "? Section A. (2.) Effluent Limitations and Monitoring Requirements for Outfall 002 - Note #2 under the table states, "Total metals are defined by 40 CFR 136. Any method specified by 40 CFR is considered acceptable for analysis." This is too vague of a statement. 40 CFR 136 allows for atomic absorption analysis of metals that will only obtain a detection limit in the mg /L range. Although Duke is analyzing via ICP -MS this statement allows them to backtrack and use a method with a lower detection limit. Although I doubt this will happen we should tighten up our requirements; either require a specific method such as ICP -MS or require that they detect below the applicable water quality standard. Section A. (2.) Effluent Limitations and Monitoring Requirements for Outfall 002 - there is no monitoring for mercury at Outfall 002. Since all waters within North Carolina are impaired for mercury due to fish tissue concentrations (not noted in the fact sheet) Duke should have to monitor for mercury especially since coal -fired power plants are a major source of mercury in the environment. They should be required to use Method 1631 E with a detection limit of 12 ng /L. Due to the recent release of monitoring data for Mountain Island Lake from the Catawba Riverkeeper the permit should not be released until the data has been reviewed. It is unclear whether the Duke data collected during the 316(a) variance request can be compared to the Riverkeeper's data. Duke is only performing sediment analyses on sediment fines and it appears the Riverkeepr's results are for all sediment within a sediment core. We need to be able to compare. The 2004 study by Duke appears to show an increase in arsenic in sediment directly down stream of the cove where Outfall 002 discharges (their statement). No data in MRO files regarding 316(a) data since 2004. In addition, no data has ever been collected by Duke in the discharge cove. It may be appropriate to request additional sampling by Duke in this cove for water quality (including metals), sediment, and fish in light of the recent Mecklenburg County arsenic data. Original permit in 1977 required metals sampling in mountain Island Lake downstream of the discharge which had to meet water quality standards. New Comments added - Marcia Marshall • Section A. (2.) Effluent Limitations and Monitoring Requirements for Outfall 002 — DWQ asks permittee to monitor and report multiple metals. We should provide the level to which we require Duke to analyze and with respect to mercury we should note we want it analyzed via Method 1631 E which obtains a detection limit of 12 ng /L.