HomeMy WebLinkAboutCape Fear Steam Station (4)NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, PE Dee Freeman
Governor Director Secretary
August 2, 2012
Mr. Randy Cox
Plant Manager
Cape Fear Steam Electric Power Plant
500 CP&L Rd
Moncure, NC 27559
Subject: NPDES Compliance Evaluation Inspection
NPDES Wastewater Discharge
Permit No. NC0003433
(Includes NPDES Stormwater requirements
in the expired September 2006 Permit)
NCS000550Application Received and
NPDES Individual Stormwater Permit Draft
dated October 11, 2011 not yet issued
Cape Fear Steam Electric Power Plant
Chatham County
Dear Mr. Cox:
On June 13, 2012, Autumn Romanski with the North Carolina Division of Water Quality,
accompanied conducted a Compliance Evaluation Inspection of the Cape Fear Steam Electric
Power Plant This inspection was conducted to verify that the facility is operating in
compliance with the conditions and limitations specified in NPDES Wastewater Permit No.
NC0038377
A summary of the findings and comments noted during this inspection is provided in Section D
on Page 2 of the attached copy of the complete inspection report titled "Water Compliance
Inspection Report".
If you have any questions concerning this report, please contact me at 919-791-4247 in the
Raleigh Regional Office.
Sincerely,
Autumn Romanski
Environmental Program Consultant
Page 2-1
Attachments
Cc: (w/attachments)
fi? 11, / 7
Mrs. Robyn Bryson
P.O Box 1551
PEB 4A
Raleigh, NC 27602
Raleigh Regional Office — File
DWQ/Raleigh — Central Files
Wetlands, Buffers, Stormwater Compliance & Permitting Unit
Mr Larry Baxley
P.O Box 1551
PEB 4A
Raleigh, NC 27602
Page 2-2
Section D Summary of Findings /Comments
1. Permit:
Your NPDES Individual Wastewater permit became effective September 1, 2011 and expires
on July 31, 2016. The facility is not currently under a Special Order by Consent.
The permittee submitted a NPDES Individual Stormwater Permit renewal application as
required in 2011. The draft NPDES Individual Stormwater Permit dated October 11, 2011 is
still in review and has not yet been issued as of the date of this inspection For this reason, the
stormwater conditions in the expired (Combined wastewater/stormwater discharge permit)
dated September, 2006 remain in effect until such time as the new stormwater permit is issued.
The permittee is reminded to read, understand and comply with all of the terms and conditions
contained in the permit(s). If you have questions concerning your responsibilities, please call
the Raleigh Regional Office to speak to a Division of Water Quality Surface Water staff
member.
The facility was compliant with the wastewater and stormwater requirements of the NPDES
permat(s) in effect the day of the inspection The permittee reported an approximate timeline
for a permanent shutdown of the coal fired boiler, and subsequent end to coal ash sluicing
operations at this facility A gas fired Combustion Turbine may continue to operate at the site
and current plans were reported to continue pumping resource water from the Cape Fear thru
the plant As operations chane the facility should report changes that may affect permit
related wastewater treatment units and effluent discharge This would include permit
modifications as appropriate
2. Compliance Schedules:
The permit does not have any outstanding compliance schedules for this facility.
3. Facility Site Review:
The overall condition of the plant site was satisfactory The appearance of the facility was in
acceptable condition indicating the current housekeeping practices are good.
4. Records/Reports:
a) A review of the daily monitoring data submitted during the previous 12 -month period
and a review of the permit conditions indicates the facility was in compliance with the
permit requirements and/or limitations
The fatality was issued no penalty assessments and no notices of violation for the 12 -
month period
Page 2-3
b) The facility must designate a certified Operator -in -Responsible -Charge (ORC) having
a certification level equal to or greater than the facility classification. A Back-up ORC
must also be designated with a minimum certification level at least one level less than
the facility classification.
The facility is currently in compliance lvith these requirements This facility is
classified as a Physical Chemical 1 (PC -1) and the Operator in Responsible Charge
(ORC) is Danny Hedgepath He holds a PGI (Cert No 27398) and a Wastewater II
(Cert No 1566)
The Division of Water Quality records indicate the Back-up ORC's are Norman
Barlow (PC -1 Cert No 989381 and James Reed (PC -1 Cert No 28680) Please
submit updated designation information (IF ORC's change over, or additional ORC's
are designated as operators — we discussed that Henry Gales is now a back-up ORC,
please send information to the attention of Steve Reid at
1618 Mail Service Center
Rateigh NC 27699 - 1618
The ORC designation form is located here http://PortaLncdenr.orQ/weblwg/tacu-
downloads
The facility is currently in compliance with these requirements
5. Self -Monitoring Program:
You are reminded that your monitoring samples must be collected, preserved, and analyzed by
appropriate procedures and methods You should maintain records of the sampler temperature,
and a certified laboratory must calibrate the sample thermometers annually.
Your operator is reminded that he/she must keep a logbook of all operation/maintenance
activities undertaken at the facility The logbook should include all daily process control
activities including any field measurements conducted for process control A visitation log for
the facility must also be maintained.
The facility is currently in compliance with these requirements, and the safety changes
implemented at outfalls 001 and 005 including 1) installation of hand rails and safety
fence at outfall 001, 2) use of personal protection equipment at outfall 005, and 3) review
of safety procedures with regards to sampling activities at these outfalls have signi icand
lessened the safety risks identified in the last inspection Thank you for Your prompt action
to resolve these concerns
Page 2-4
Rox
ISCO composite sampler- sample is ran thru an ice filled cooler to ensure proper cooling
of the samples New, clean sample tubing was in place the day of the inspection
6. Laboratory:
For all analytical data submitted for compliance monitoring purposes, a certified laboratory
must be utilized for all laboratory analysis Additionally, if field parameter testing is
conducted, an operator certified to perform the specified field parameter analysis is also
required. The operator needs to be sure to calibrate all meters/instrumentation before each use
and retain all calibration records
The facility is currently in compliance with these requirements and utilizes Tritest Inc
certified commercial laboratory #67 The tacility holds a current NC DWO Laboratory
Field Parameter Certification 95101 for pH and temperature measurements
Page 2-5
The Regional Field Inspectors checklist to be forwarded to the DWO Laboratory
Certification Program was completed the day of the inspection and reflects the extent of
laboratory items investigated by Regional inspectors DWO Lab inspections are
performed separately by the Lab Certification Program and an evaluation of Tritest Lab
was completed by the DWO Lab Certifcation Program on February 17 and February 18
2010 The Regional lab checklist results are attached
7. Flow Measurement:
If the permit requires a flow measurement device for determining the effluent flow, the
flow measurement device must be calibrated annually.
This facility is required to monitor and report effluent flow and the facility is in compliance
with this requirement They report effluent flow It appears from the recent NPDES
effluent outfall 007 flow data reported that flow may vary widely as the facility is off-line
more frequently and is entering a transition period that will work towards a permanent
shutdown of the coal fired boiler A jzas fired Combustion Turbine may continue to operate
at the site and current plans were reported to continue numpinz resource water from the
Cape Fear River thru the plant so the methods used to calculate effluent flow may need to
be reviewed in light of changing operations during this period of transition
8. Effluent/Receiving Waters:
The effluent discharge should be clear with a continuous flow with no visible changes to
the receiving waters.
The effluent discharge was clear and flow was continuous The receiving waters looked
clear with no visible changes from the effluent discharge
9. Pretreatment:
This facility currently has no pretreatment permit and does not accept or discharge
domestic or industrial waste to a sanitary sewer system Pre-treatment permits are
required, if applicable. by your NPDES Discharge Permit
10. Solids Hand ling/Disposa1:
The facility must dispose of solids by an acceptable method such as a landfill or utilize the
services of an approved solids hauling and disposal contractor, which requires the facility
to be included under the contractor's non -discharge permit (i e. land application) The
facility is reminded to maintain adequate records (i e. shipment dates, quantities, etc ) of
any solids hauling and/or disposal activities.
The facility is in compliance with these requirements and reports no transporting of ash or
wastewater sludge solids to off site locations In the past they did report some reuse of
ash in cement block The facility should address Coal Combustion Products management
as chrected by the NC Division of Solid Waste and/or cis directed by other state or federal
regulations as that apply to solids at this facility The capacity and ultimate disposal o
solids from the active 1985 ash pond is currently being reviewed and Progress Energy has
reported all ash ponds on-site will close as a result of the closure of the coal fired boiler
plant
Page 2-6
11. Sanitary Wastewater Treatment Plant
The sanitary wastewater treatment unit was not observed during this inspection However,
the plant should consider options for any future sanitary sewer needs for any limited
operations that continue at the plant after the closure of the current ash pond as the
sanitary sewer treatment unit discharges to this ash pond
12. Compliance Sampling:
Compliance sampling was conducted during the last inspection No compliance sampling
was conducted the day of this inspection
13 NPDES Combined Wastewater/Stormwater Permit dated September 2006
The fatality was compliant with the Stormwater permit conditions as set forth in the
NC0003433 combined wastewater/stormwater permit
The creek is known to back-up in storm pipe, Activity -Sluice Lane located upland of SW pipe
Page 2-7
SW Outfalls 004(above, by railroad) &006 (no photograph -drains to NPDES WW Outfall
007)was removed,in the NCS000550 Application Review Process
Page 2-8
SW Outfall 008- Inactive Ash Pond —Holding Capacity for 25 year storm
NPDES WW Outfall 001-1978 Ash Pond at capacity overflows to internal cooling water
canal and ultimately out NPDES WW Outfall 007
Page 2-9
It was confirmed that the facility should continue the stormwater requirements in the
NC0003.133 permit until such time as the new NCS000550 permit is issited It would appear
that closure of the some of the current plant activities may occur before the issitance of the
NCS000550 The SW outfall determinations made last year on the stormwater outfalls
#SWI #SW8 4SW2 (New Location) SW43 and activity descriptions may change as the
facility makes operational changes this Fall DW0 confirmed that SW96 discharges to the
wastewater discharge canal and then to the final NPDES wastewater ozrtfall 007 that is
already monitored through the NC0003.133 wastewater permit This will still be true as long
as the facility continues with NPDES wastewater discharge monitoring at outfall 007
With the variety of operational changes coming tip the facility may want to consider
updating the information provided in the application for the Individual Stormwater Permit
13. Operations & Maintenance:
The facility was in compliance with these requirements the day of the inspection
14. Compliance Status:
® Compliant
Name and Signature of Inspector:
Autufnn Romans i
Surface Water Protection Section
Raleigh Regional Office
❑ Non-compliant ❑ Neither
94� �ao /,;z
Date
Page 2-10
United States Environmental Protection Agency
Form Approved
EPA Washington, D C 20460
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 I ^I I 2 I s I 31 NC0003433 111 121 12/06/12 117 181 C I 191 C I 20U
J LJ IJ U
Remarks
2111111111111111111111111111111111 111111111111 1116
Inspection Work Days Facility Self -Monitoring Evaluation Rating 61 CA ---------------------------Reserved----------------------
671 169 701U 711 721 N � 73 � 74 751 I I I I I I 1 80
—�
Section B Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
09 00 AM 12/06/12
11/09/01
Cape Fear Steam Electric Power Plant
500 CP L Rd
Exit Time/Date
Permit Expiration Date
Moncure NC 27559
02 00 PM 12/06/12
16/07/31
Name(s) of Onsite Rep resentative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Danny L Hedgepeth/ORC/919-774-5237/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Hershell ccMcCarty,500 CP L Rd Moncure NC 27559/// No
r1 r1C—— QIa,1+ rLtAtto I oe-g
Section C Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Compliance Schedules
Effluent/Receiving Waters Laboratory Storm Water
Section D Summary of Find in /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
�v -C
Autumn H Romanski/'l2
rZI-7— �RRO WO//919-791-4247/
f
S natu of Manag ent O A ie er, Ag cy/Office/Phone and Fax Numbers Date t
llvjvx� lJ
EPA Form 60-3 (Rev 9-94) Previous editions are obsolete
Page # 1
NPDES yr/mo/day Inspection Type
3I NC0003433 I11 12, 12/06/12 117 18(C�
(cont )
Section D Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
The permittee was In compliance with the requirements of the current NC0003433 permit the day of this
Inspection
The NCS000550 Stormwater Permit has yet to be Issued, but the stormwater checklist was completed
based on teh requirements in the September 2006 combined wastewater/stormwater permit and is attached
to this inspection The facility was in compliance with the stormwater requirements the day of this
inspection
The facility reports the coal fired boiler Is scheduled to shut down this Winter 2012
The permittee should keep the NPDES Wastewater Permitting Unit Informed of process changes that effect
compliance with the current NC0003433 wastewater permit, as well as, update the Stormwater Permitting
Unit with cahnges as applicable to the NCS000550 Individual Stromwater permit currently under review
Page # 2
Permit- NC0003433
Inspection Date: 06/12/2012
Owner - Facility Cape Fear Steam Electric Power Plant
Inspection Type Compliance Evaluation
Permit
(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?
Comment
Compliance Schedules
Is there a compliance schedule for this facility?
Is the facility compliant with the permit and conditions for the review period?
Comment
Lagoons
Type of lagoons?
# Number of lagoons in operation at time of visit?
Are lagoons operated in?
# Is a re -circulation line present?
Is lagoon free of excessive floating materials?
# Are baffles between ponds or effluent baffles adjustable?
Are dike slopes clear of woody vegetation?
Are weeds controlled around the edge of the lagoon?
Are dikes free of seepage?
Are dikes free of erosion?
Are dikes free of burrowing animals?
# Has the sludge blanket in the lagoon (s) been measured periodically in multiple locations?
# If excessive algae is present, has barley straw been used to help control the growth?
Is the lagoon surface free of weeds?
Is the lagoon free of short circuiting?
Comment. The 1985 active ash pond is at capacity and scheduled to close later this
year (Winter 2012)
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping?
Yes No NA NE
❑ ❑ ■ ❑
■ ❑ ❑ ❑
❑ ❑ ■ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
Yes No NA NE
❑ ❑ ■ ❑
❑ ❑ ■ ❑
Yes No NA NE
Facultative
1
Yes No NA NE
0000
Page # 3
Permit. NC0003433
Inspection Date- 06/12/2012
Operations & Maintenance
Owner - Facility Cape Fear Steam Electric Power Plant
Inspection Type Compliance Evaluation
Yes No NA NE
Does the facility analyze process control parameters, for ex MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ p Q p
Judge, and other that are applicable?
Comment
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?
Comment This facility Is required to monitor and report effluent flow As reported in
last year's inspection the pump curves developed for Influent pump station are used to
calulate effluent flow. If effluent flow Is constant (less than 15% change In flow dally)
then effluent flow reported should be relatively accurate, however, If flows vary
significantly during the day due to mayor operations coming off line, but influent/canal
flow continues, the facility should review and ensure proportional flow measurement and
accurate effluent flow reporting
Effluent Sampling
Is composite sampling flow proportional?
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)?
Comment
0ui..,...* o.....
Yes No NA NE
Yes No NA NE
Yes No NA NE
Page # 4
Is right of way to the outfall properly maintained?
■
p
p
p
Are the receiving water free of foam other than trace amounts and other debris?
■
p
p
p
If effluent (diffuser pipes are required) are they operating properly?
p
p
■
p
Comment
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit9
■
p
p
p
Is all required information readily available, complete and current?
■
n
p
O
Are all records maintained for 3 years (lab reg required 5 years)?
■
p
p
Cl
Page # 4
Permit NC0003433
Inspection Date: 06/12/2012
Record Keeping
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?
Owner - Facility Cape Fear Steam Electric Power Plant
Inspection Type Compliance Evaluation
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?
Comment The facility Is currently classified as a PC -1 and was In compliance with the
permit requirements the day of this Inspection
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?
Comment The results of the Tritest Lab certlfcatlon were reviewed and a Field Lab
certifcation (#5101 check sheet was completed for pH and Temperature (attached and
forwarded to the DWQ Lab Certification Unit
Yes No NA NE
■000
■ 0 0 0
■ 0 0 0
0 0 11 ■
■ 0 0 0
■ 0 0 0
■ 0 0 0
■ Cl 0 0
0000
0 0 0 ■
Yes No NA NE
■ 0 0 0
■ 0 0 0
■ 0 0 0
■000
0 0 ■ 0
0 0 ■ 0
Page # 5
Regional Field Inspectors Check List for Field Parameters
Name of site to be Inspected
Date.
i� /
Field certification # (if applicable) t
Inspector
No
NPDES Region 2
I. Circle the parameter or parameters performed at this site.
Residual Chlorine, Settleable Solid H DO, Conductivit ,Temperature
II. Instrumentation:
A Does the facility have the equipment necessary to analyze field parameters as circled above?
1 A pH meter Yes No ,
2. A Residual Chlorine meter
, es
No
/1114
3 DO meter
Yes
No
,,ij
4. A Cone for settleable solids
Yes
No
/V�i�{'
5. A thermometer or meter that measures temperature
es,)
No
6 Conductivity meter
Yes
No
j,)14
III. Calibration/Analysis:
1. Is the pH meter calibrated with 2 buffers and
checked with a third buffer each day of use?
:Y:es
No
2. For Total Residual Chlorine, is a check standard
/ I�
analyzed each day of use?
Yes
No
'
/�' /
3. Is the air calibration of the DO meter performed
each day of use?
Yes
No
4 For Settleable Solids, is 1 liter of sample
settled for 1 hour?
Yes
No
4)���
5. Is the temperature measuring device calibrated --1
annually against a certified thermometer? Yes No
6 For Conductivity, is a calibration standard
analyzed each day of use? Yes No ��
d ICA
�NC c�003Y3 3�
Permit: NCS000550 Effective:
SOC: Effective:
County: Chatham
Region: Raleigh
��y cox
Contact Person:
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits*
Compliance Inspection Report
Expiration: Owner: Carolina Power and Light Company DBA
Progress Energy Inc
Expiration: Facility. Cape Fear Steam Electric Power Plant
500 CP L Rd
Title: Vice President
Certification.
Moncure NC 27559
Phone- 919-546-7661
Phone:
Inspection Date: 06/12/2012 Entry Time. 09 00 AM Exit Time: 02 00 PM
Primary Inspector: Autumn H Romanski- Phone. 919-791-4247
Secondary Inspector(s)•
Reason for Inspection. Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status ■ Compliant 0 Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Inspection Type, Compliance Evaluation
Page 1
Permit NCS000550 Owner - Facility. Carolina Power and Light Company DBA Progress
Energy Inc
Inspection Date 06/12/2012 Inspection Type Compliance Evaluation Reason for Visit Routine
Inspection Summary:
This Individual Permit has not yet been issued Requirements for stormwater remain in a combine wastewater/stormwater
NC0003433 permit dated Sept 2006 that has since expired
There is no Bims form to fill out - so the NCS application permit number was used until such time as the NCS permit gets
issued
The facility was in compliance with the NC0003433 stormwater permit requirements
Page 2
Permit NCS000550 Owner - Facility Carolina Power and Light Company DBA Progress
Energy Inc
Inspection Date: 06/12/2012 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 Monitoring
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?
Yes No NA NE
■000
■ Q ❑ Q
■ ❑ Q Q
■Q❑n
❑n■n
0000
■nnn
■000
■ Q Q 0
■000
■❑00
■ Q Q Q
0000
■nnn
■ 0 00
Yes No NA NE
■❑n❑
Yes No NA NE
❑000
nn■n
Yes No NA NE
Page 3
Permit- NCS000550 Owner - Facility Carolina Power and Light Company DBA Progress
Energy Inc
Inspection Date 06/12/2012 Inspection Type. Compliance Evaluation Reason for Visit- Routine
Comment. The facility reports the coal fired boiler will be shutdown this Fall 2012 and
subsequently all coal ash ponds will be closed
SW Outfalls currently Included In the expired (NC0003433) will change activities through
the operational changes expected at the facility The permittee should keep the NPDES
SW Permitting Unit updated with the changes, so that the SW Individual Permit
(NCS000550 currently in review) can be updated appropriately before issuance.
Page 4