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Home My WebLink AboutNC0004987_Compliance Evaluation Inspection_20230317ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Jeff Flanagan, Station Manager Duke Energy Carolinas, LLC Marshall Steam Station 8320 East NC Hwy. 150 Terrell, NC 28682 SUBJECT: Compliance Evaluation Inspection Marshall Steam Station NPDES Permit No. NC0004987 Catawba County Dear Mr. Flanagan: NORTH CAROLINA Environmental Quality March 17, 2023 Enclosed is a copy of the Compliance Evaluation Inspection (CEI) Report for the inspection conducted at the subject facility on March 14, 2023, by Mr. Wes Bell of this Office. Please advise the facility's Operator -in -Responsible Charge (ORC) of our findings by forwarding the enclosed report. Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at (704) 235-2192 or at wes.bell(a,ncdenr. gov. Enclosure: Inspection Report Cc: NPDES Program Files - Laserfiche Sincerely, EA DocuSigned by: �•�Guw N Nl-ft F161 F669A2D84A3... Andrew H. Pitner, P.G. Assistant Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources, NCDEQ North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115 704.663.1699 United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 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 IN 1 2 u 3 I NC0004987 111 121 23/03/14 I17 18 LC] I 19 I s I 20L] 21111I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 2.0 701d I 71 I„ I 72 I r., I 71 I 74 79 I I I I I I I80 L—I ty L-1 I I 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 Dermit Number) 09:20AM 23/03/14 22/05/01 Marshall Steam Station NC Hwy 150 Exit Time/Date Permit Expiration Date Terrell NC 28682 01:45PM 23/03/14 27/04/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Gregory Paul Ph ill ips/ORC/828-478-7647/ Joseph Scott La Sala/EHS Professional Sr// Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Jeff Flanagan,8320 E NC Hwy 150 Terrell NC 28682//828-478-7600/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran 0 Sludge Handling Dispo: Facility Site Review Effluent/Receiving Wate 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 ocuSigned by: Wes Bell DWR/MRO WQ/704-663-1699 Ext.2192/ 3/16/2023 2 re& E�D:,,, 96D90CC3437... Signature of Man geg(?15' "Aftviewer Agency/Office/Phone and Fax Numbers Date Andrew Pitn r A",� H P R/MRO WQ/704-663-1699 Ext.2180/ 3/16/2023 F161 FB69A2D84A3... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type NC0004987 I11 12I 23/03/14 117 18 i c i (Cont.) Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Permit Section cont'd: The FGD wet scrubber WTS (Internal Outfall 006) includes an influent sump, equalization, pH adjustment, coagulation, clarification, chemical addition, multi -stage bioreactors, ultrafiltration, flow measurement and pump station (to lined retention basin). The ash basin dewatering treatment system (Outfall 002) includes screening, pH adjustment, chemical addition, coagulation, clarification, filtration and flow measurement. Outfalls 005 and 010 are equipped with pH adjustment systems. Page# Permit: NC0004987 Owner -Facility: Marshall Steam Station Inspection Date: 03/14/2023 Inspection Type: Compliance Evaluation Permit Yes No NA NE (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: Ash basin dewatering was initiated in September 2020 and continues to date. No chlorine is added to any of the outfalls. The last compliance evaluation inspection at this facility was performed by DWR staff on 8/18/2021. See "Summary" Section for addtional comments. Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? ■ ❑ ❑ ❑ Is all required information readily available, complete and current? ■ ❑ ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? ■ ❑ ❑ ❑ 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? ■ ❑ ❑ ❑ 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? ❑ ❑ ■ ❑ Page# 3 Permit: NC0004987 Inspection Date: 03/14/2023 Owner -Facility: Marshall Steam Station Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Comment: The records reviewed durinq the inspection were organized and well maintained. Discharge Monitoring Reports (eDMRs) were reviewed from February 2022 through January 2023. No effluent limit and/or monitoring violations were reported. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? 0 ❑ ❑ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? 0 ❑ ❑ ❑ # Is the facility using a contract lab? 0 ❑ ❑ ❑ # 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: Duke Power's Analytical Laboratory and the contracted laboratory services of Pace Analytical Services and ETS, Inc. perform permit -required effluent analyses. The Duke Power Marshall Steam station has also been certified as a field laboratory (Certification #5155) to perform pH and temperature analyses on -site. Influent Sampling # Is composite sampling flow proportional? Is sample collected above side streams? 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 sampling performed according to the permit? Comment: The subject permit requires grab Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? s at internal Outfalls 006 and 010. 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)? Yes No NA NE ❑ ❑ ■ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ Yes No NA NE ❑ ❑ ■ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ Comment: The subject permit requires effluent grab samples at Outfalls 001, 002, 003 and 005. Page# 4 Permit: NC0004987 Owner - Facility: Marshall Steam Station Inspection Date: 03/14/2023 Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, ■ ❑ ❑ ❑ and sampling location)? Comment: Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ 0 ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: The NPDES facilities appeared to be properly operated and well maintained. ORC visitations, weekly inspections and operation & maintenance activities were being documented and maintained on -site. Treatment components, alarm conditions and in -line monitoring analyzers can be viewed on a computer monitoring system for Outfalls 001, 002, 005, 006, 010 and yard sumps. Equalization Basins Yes No NA NE Is the basin aerated? 0 ❑ ❑ ❑ Is the basin free of bypass lines or structures to the natural environment? 0 ❑ ❑ ❑ Is the basin free of excessive grease? 0 ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? 0 ❑ ❑ ❑ Are float controls operable? 0 ❑ ❑ ❑ Are audible and visual alarms operable? 0 ❑ ❑ ❑ # Is basin size/volume adequate? 0 ❑ ❑ ❑ Comment: Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? 0 ❑ ❑ ❑ Are weirs level? ❑ ❑ ❑ Is the site free of weir blockage? 0 ❑ ❑ ❑ Is the site free of evidence of short-circuiting? 0 ❑ ❑ ❑ Is scum removal adequate? 0 ❑ ❑ ❑ Is the site free of excessive floating sludge? 0 ❑ ❑ ❑ Page# 5 Permit: NC0004987 Owner - Facility: Marshall Steam Station Inspection Date: 03/14/2023 Inspection Type: Compliance Evaluation Secondary Clarifier Yes No NA NE Is the drive unit operational? 0 ❑ ❑ ❑ Is the return rate acceptable (low turbulence)? ❑ ❑ 0 ❑ Is the overflow clear of excessive solids/pin floc? ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) 0 ❑ ❑ ❑ Comment: The FGD wet scrubber and ash basin treatment systems were not treatinq wastewater at the time of the inspection. Pumps-RAS-WAS Yes No NA NE Are pumps in place? 0 ❑ ❑ ❑ Are pumps operational? 0 ❑ ❑ ❑ Are there adequate spare parts and supplies on site? ■ ❑ ❑ ❑ Comment: Chemical Feed Yes No NA NE Is containment adequate? ■ ❑ ❑ ❑ Is storage adequate? 0 ❑ ❑ ❑ Are backup pumps available? 0 ❑ ❑ ❑ Is the site free of excessive leaking? 0 ❑ ❑ ❑ Comment: Filtration (High Rate Tertiary) Yes No NA NE Type of operation: Cross flow Is the filter media present? 0 ❑ ❑ ❑ Is the filter surface free of clogging? 0 ❑ ❑ ❑ Is the filter free of growth? ❑ ❑ ❑ Is the air scour operational? ❑ ❑ 0 ❑ Is the scouring acceptable? ❑ ❑ ❑ Is the clear well free of excessive solids and filter media? ❑ ❑ ❑ Comment: Flow Measurement- Effluent Yes No NA NE # Is flow meter used for reporting? 0 ❑ ❑ ❑ Is flow meter calibrated annually? 0 ❑ ❑ ❑ Page# 6 Permit: NC0004987 Owner -Facility: Inspection Date: 03/14/2023 Inspection Type: Marshall Steam Station Compliance Evaluation Flow Measurement - Effluent Yes No NA NE Is the flow meter operational? 0 ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ 0 ❑ Comment: Outfalls 002, 005, 006 and 010 are equipped with maqnetic flow meters. The flow meters are verified annually and were last verified on 9/22/2022 (Outfalls 002, 005, 006) and 10/6/2022 (Outfall 010) by on -site staff. Outfall 001 flows are based on pump curves and Outfall 003 flows are based on pipe diameter/water level measurements and supporting flow calculations. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? 0 ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ Comment: Outfalls 001, 002, 003 and 005 were discharging at the time of the inspection. The effluents appeared clear with no floatable solids, foam and/or oil sheens. The receiving stream did not appear to be negatively impacted. Solids Handling Equipment Is the equipment operational? Is the chemical feed equipment operational? Is storage adequate? Is the site free of high level of solids in filtrate from filter presses or vacuum filters? Is the site free of sludge buildup on belts and/or rollers of filter press? Is the site free of excessive moisture in belt filter press sludge cake? The facility has an approved sludge management plan? Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ Comment: Two of three filter presses were operational; however, no dewaterinq activities were occurring during the inspection. Dewatered sludge, off -spec gypsum, bottom ash, and fly ash are disposed in the permitted on -site landfill. A small percentage of fly ash is reused in the ready -mix concrete industry (non -DOT related). The gypsum material from the FGD wet scrubber system is reused by an outside company (National Gypsum) in the dry wall market. Page# 7