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HomeMy WebLinkAboutNC0086665_Compliance Evaluation Inspection_20090205 A .74A NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary 5 February 2009 Duke Energy Carolinas, LLC Attn: Mr. Scott G. Trombley, Production Manager Rockingham CT Station 240 Ernest Drive Reidsville, NC 27320 SUBJECT: Compliance Evaluation Inspection NPDES Permit NC0086665 Rockingham CT Station Duke Energy Carolinas, LLC Rockingham County Dear Mr. Trombley: • 1. Mr. Ron Boone of the Winston-Salem Regional Office (WSRO) of the NC Division of Water Quality (DWQ or Division) conducted a compliance evaluation inspection (CEI) of Duke Energy's Rockingham CT Station on 9 January 2009. Your assistance and cooperation during the inspection, as well as that of Mr. David Brooks, Senior EHS Professional and backup Operator in Responsible Charge (ORC) of the wastewater system, were greatly appreciated. Inspection findings are summarized below and an inspection report is attached for your records. 2. The facility is located at 240 Ernest Road, in Reidsville, Rockingham County, North Carolina. Wastewater produced at the facility is discharged to an unnamed tributary to Little Jacobs Creek (East Prong Jacobs Creek), which is currently classified as Class C waters in the Roanoke River basin. The wastewater system at the facility consists of an oil/water separator and polishing filter. SITE REVIEW 3. The entire facility was very clean and well maintained. The treatment system was examined and also found to be fully operational and well maintained. No discrepancies were noted. The outfall was visited; there was no discharge at the time of the inspection but the receiving water was free of pollutant indicators and appeared to be in pristine condition. DOCUMENTATION REVIEW 4. Operator visitation logs, as well as operation and maintenance logs for the facility, were reviewed and found to meet all requirements. Documentation was complete and current. 5. Discharge monitoring reports (DMR) for January and December 2008 were reviewed and compared with laboratory reports. No mistakes or transcription errors were noted. The facility did get four monitoring violations in June 2008 for failure to monitor Benzene, Toluene, Ethylbenzene and Xylene (BTEX), as well as one monitoring violation for failure to monitor Naphthalene in January 2008. However, the records review revealed that the facility did in fact test for these North Carolina Division of Water Quality,Winston-Salem Regional Office Location:585 Waughtown St.Winston-Salem,North Carolina 27107 One Phone:336-771-50001 FAX:336-771-46301 Customer Service:1-877-623-6748 NorthCarolina Internet www.ncwaterquality.org tur !! An Equal Opportunity 1 Affirmative Action Employer Naturally " �"" F Duke Energy Carolinas,LLC Attn: Mr.Scott G.Trombley,Production Manager Rockingham CT Station NPDES Permit NC0086665 Page2 of 2 parameters in both January and July of 2008, but simply failed to enter the data on the DMR sheet that was submitted to the Division. Instead the facility sent copies of the original laboratory - reports for these tests, attached to the DMRs for January and July. Unfortunately, our system for monthly review can only examine data on actual DMR forms and cannot read laboratory reports. Thus the perceived absence of the required tests generated the five monitoring violations. Mr. Boone spoke with you about this during the inspection and directed you to simply report the parameters on the DMR, just as you do all other parameters. Editable DMR forms are available on our website at http://h2o.enr.state.nc.us/NPDES/documents.html#forms. You can customize the column headings on these DMR forms for specific parameters. Just be sure the parameter codes at the tops of the columns, as well as the parameter limits, at the bottom of the columns, match up with each specific parameter. The above-mentioned monitoring violations have been marked as inconsequential in our database and no further action is needed. Just be sure to follow the above procedures for submission of the required data in order to avoid future violations of this nature. 6. Research and Analytical Laboratories (R&A) does all required lab testing for the facility, including field parameters. All lab data, including chains of custody, was complete and current. 7. Chlorine is not being used in the waste stream for outfall 001, and therefore the facility does not currently measure for Total Residual Chlorine (TRC). If the facility does start using Chlorine in this waste stream in the future, you must immediately begin monitoring for TRC in the effluent. 8. Thank you for your efforts to operate this waste treatment system efficiently and to comply with all permit terms and conditions. If you have any questions regarding the inspection or this letter, please contact Mr. Boone or me at (336)771-5000. Sincerelyi..> Steve W. Tedder Water Quality Regional Supervisor Winston-Salem Region Division of Water Quality Attachments: 1. BIMS Inspection Checklist CC: Central Files w/atchs NPDES West Unit w/atchs WSRP/SWP Files w/atchs United States Environmental Protection Agency EPA Washington,D.C.20460 Form Approved. OMB No.2040-0057 Water Compliance Inspection Report 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 1�f 2 1 CI 31 NC0086665 111 121 09/01/09 117 1812_1 19u 201 I IJ U Remarks I LJ 211IIIIIIII111111IIIIII111IIIIIIIIIIIIIIIIIIII11166 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA — -------Reserved- 671 1 69 '°U '1U 72'N I 731 1 174 751 111111 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) Rockingham County Combustion Turbine Facility 09:00 AM 09/01/09 07/12/01 240 Ernest Dr Exit Time/Date Permit Expiration Date Reidsville NC 27320 10:30 AM 09/01/09 12/04/30 Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data /1/ • David Morton Brooks/ORC/336-637-1370/ Name,Address of Responsible OfficiaVTitle/Phone and Fax Number • Jim Doubek,240 Ernest Dr Reidsville NC 27320/Plant Contacted Manager/336-951-1772/3369510308 No Section C: Areas Evaluated During Inspection(Check only those areas evaluated) IN Permit Flow Measurement hi Operations&Maintenance fig Records/Reports •Self-Monitoring Program I Facility Site Review •Effluent/Receiving Waters •Laboratory Section D: Summary of Finding/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 Ron Boone WSRO WQ//704-663-1699 Ext.2202/ lv / 021‘,5-1.1 Signature of Ma gement Q A Revie Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3(Rev 9-94)Previous editions are obsolete. Page# 1 NPDES yr/mo/day Inspection Type 1 31 NC0086665 J11 121 09/01/09 117 181ls1 _ Section D: Summary of(Finding/Comments(Attach additional sheets of narrative and checklists as necessary) Please see attached inspection summary letter. • • • • Page# 2 Permit: NC0086665 Owner-Facility: Rockingham County Combustion Turbine Facility Inspection Date: 01/09/2009 inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? • 0 0 0 Is all required information readily available,complete and current? • 0 0 0 Are all records maintained for 3 years(lab.reg.required 5 years)? ■ 0 0 0 Are analytical results consistent with data reported on DMRs? • 0 0 0 Is the chain-of-custody complete? • 0 0 0 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? 0 • 0 0 Has the facility submitted its annual compliance report to users and DWQ? 0 0 • 0 (If the facility is=or>5 MGD permitted flow)Do they operate 24/7 with a certified operator on each shift? 0 0 ■ 0 Is the ORC visitation log available and current? ■ 0 0 0 Is the ORC certified at grade equal to or higher than the facility classification? ■ 0 0 0 Is the backup operator certified at one grade less or greater than the facility classification? • 0 0 0 Is a copy of the current NPDES permit available on site? ■ 0 0 0 Facility has copy of previous year's Annual Report on file for review? 0 0 ■ 0 Comment: Please see attached inspection summary letter. Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new application? 0 0 ■ 0 Is the facility as described in the permit? ■ 0 0 0 #Are there any special conditions for the permit? 0 • 0 0 Is access to the plant site restricted to the general public? II 0 0 0 Is the inspector granted access to all areas for inspection? ■ 0 0 0 Comment: Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? ■ 0 0 0 Page# 3 Permit: NC0086665 Owner-Facility: Rockingham County Combustion Turbine Facility _ Inspection Date: 01/09/2009 Inspection Type: Compliance Evaluation Laboratory Yes No NA NE Are all other parameters(excluding field parameters)performed by a certified lab? ■ 0 0 0 #Is the facility using a contract lab? ■ 0 0 0 #Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees Celsius)? 0 0 0 • Incubator(Fecal Coliform)set to 44.5 degrees Celsius+/-0.2 degrees? 0 0 ■ 0 Incubator(BOD)set to 20.0 degrees Celsius+/-1.0 degrees? 0 0 ■ ❑ Comment: R&A Labs Effluent Sampling Yes No NA NE Is composite sampling flow proportional? 0 0 ■ 0 Is sample collected below all treatment units? ■ 0 0 0 Is proper volume collected? ■ 0 0 0 Is the tubing clean? 0 0 • 0 #Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees Celsius)? 0 0 0 ■ Is the facility sampling performed as required by the permit(frequency,sampling type representative)? ■ 0 0 0 Comment: Flow Measurement-Effluent Yes No NA NE #Is flow meter used for reporting? 0 0 ■ 0 Is flow meter calibrated annually? 0 0 • 0 Is the flow meter operational? 0 0 ■ 0 (If units are separated)Does the chart recorder match the flow meter? 0 0 ■ 0 Comment: There is no flow meter; flow is measured from pumps that discharge the water from the treatment system. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? ■ 0 0 0 Are the receiving water free of foam other than trace amounts and other debris? ■ 0 0 0 If effluent (diffuser pipes are required) are they operating properly? 0 0 ■ 0 Comment: • Operations&Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? ■ 0 0 0 Does the facility analyze process control parameters,for ex:MLSS,MCRT,Settleable Solids,pH,DO,Sludge 0 0 0 ■ Judge,and other that are applicable? Comment: Page# 4