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HomeMy WebLinkAboutNCS000589_CEI_20221110ROY COOPER Governor ELIZABETH S. BISER Secretary BRIAN WRENN Director NORTH CAROLINA Environmental Quality November 10, 2022 Duke Energy Progress, LLC Attn: Jessica Bednarcik, Senior Vice President, EHS & CCP Mail Code EC13K, PO Box 1006 Charlotte, NC 28201 Subject: COMPLIANCE EVALUATION INSPECTION NPDES Stormwater Permit NCS000589 Duke Energy Progress, LLC Weatherspoon Steam Electric Plant Robeson County Dear Ms. Bednarcik: On November 2, 2022, a site inspection was conducted for the Weatherspoon Steam Electric Plant located at 491 Power Plant Road in Lumberton, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Mr. Kent Tyndall, Lead EHS Professional, and Mr. Ricky Stroupe, CCP Environmental Field Support, were present during the inspection and their 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 Division of Energy, Mineral and Land Resources Enclosure: Compliance Inspection Report ec: Kent Tyndall, Lead EHS Professional — Duke Energy Progress, LLC Elizabeth Glenn, Environmental Specialist — Duke Energy Progress, LLC DEMLR NPDES Stormwater Permit Laserfiche File cc: FRO — DEMLR, Stormwater Files North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources Fayetteville Regional Office 1 225 Green Street, Suite 7141 Fayetteville, North Carolina 28301 910.433.3300 Compliance Inspection Report Permit: NCS000589 Effective: 02/01/17 Expiration: 01/31/22 Owner: Duke Energy Progress LLC SOC: Effective: Expiration: Facility: Weatherspoon Steam Electric Plant County: Robeson 491 Power Plant Rd Region: Fayetteville Lumberton NC 28358 Contact Person: Kent Tyndall Title: Lead EHS Professional Phone: 910-341-4775 Directions to Facility: System Classifications: SWNC, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): On -site representative Kent Tyndall 910-341-4775 On -site representative Ricky Stroupe Related Permits: Inspection Date: 11/02/2022 Entry Time 10:08AM Primary Inspector: Mike Lawyer le 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) Exit Time: 01:06PM Phone: 910-433-3394 Inspection Type: Compliance Evaluation Page 1 of 3 Permit: NCS000589 Owner- Facility: Duke Energy Progress LLC Inspection Date: 11/02/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary Inspection conducted as part of the individual stormwater permit renewal process. Met with Kent Tyndall, Lead EHS Professional, and Ricky Stroupe, CCP Environmental Field Support. Application for permit renewal has been submitted as required. Based on review of the facility's monitoring records, facility was triggered into monthly monitoring of all parameters under the current permit's Tier One response actions due to an exceedance of the benchmark value for TSS at outfall SW-2 in December 2018. Additionally, there was an exceedance of the benchmark value for Zinc in December 2019, TSS and Copper in September 2020, and Copper in April 2022. Monthly monitoring has been conducted and recorded continuously since December 2018 as there has not been three consecutive monitoring events with all results below benchmarks. For several months in 2019 as well as late 2020 into most of 2021, 'No Flow' was recorded. It should be noted that there have been no consecutive exceedances of any parameter. Analytical monitoring has only been conducted at outfall SW-2 as outfall SW-1 has been determined to have only sheet flow and the drains leading to outfall SW-3 have been covered with metal plates. In an attempt to determine what might be causing the sporadic exceedances, facility staff have evaluated the weather conditions that occurred during the respective sampling events (large storms/hurricanes) and even tested the fines associated with the available gravel that was purchased to place on parking and roadways after large storm events. Results of the gravel fines testing, which were provided for review during the inspection, show extremely elevated levels of all parameters; not just TSS, Zinc and Copper. Facility's SWPPP contains all necessary components and is reviewed/updated on an annual basis. Documentation related to facility inspections, employee training, evaluations of the stormwater outfalls for the presence of any non-stormwater discharges, listing of significant spills (none), effectiveness of BMPs, and comparison of monitoring data to the benchmark values was also provided for review. Regarding the facility's ash hauling activities; approximately 25 trucks enter and exit the facility twice per day, five days per week. Facility staff estimate that ash hauling should be completed in approximately three more years. After the records review, observations were made of the ASTs and other containers with secondary containment Trucks hauling ash along the travel route as well as the catch basins leading to outfall SW-2 were also observed. Page 2 of 3 Permit: NCS000589 Owner - Facility: Duke Energy Progress LLC Inspection Date: 11/02/2022 Inspection Type: Compliance Evaluation Reason for Visit: Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? 0 ❑ ❑ ❑ # Does the Plan include a General Location (USGS) map? 0 ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices"? 0 ❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? E ❑ ❑ ❑ # Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? 0 ❑ ❑ ❑ # Does the facility provide all necessary secondary containment? 0 ❑ ❑ ❑ # Does the Plan include a BMP summary? 0 ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? 0 ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? E ❑ ❑ ❑ # Does the facility provide and document Employee Training? 0 ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? N ❑ ❑ ❑ # Is the Plan reviewed and updated annually? N ❑ ❑ ❑ # Does the Plan include a Stormwater Facility Inspection Program? ❑ ❑ ❑ Has the Stormwater Pollution Prevention Plan been implemented? ❑ ❑ ❑ Comment: Qualitative Monitorinq Yes No NA NE Has the facility conducted its Qualitative Monitoring? 0 ❑ ❑ ❑ Comment: Analytical Monitoring Yes No NA NE Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑ # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ N ❑ Comment: Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑ # Were all outfalls observed during the inspection? E ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ 110 ❑ # Has the facility evaluated all illicit (non stormwater) discharges? E ❑ ❑ ❑ Comment: Page 3 of 3