NC0024406_Operation Plan Review Request Response_20071219

OF W ArFR Michael F. Easley, Governor
William G. Ross Jr., Secretary
` y North Carolina Department of Environment and Natural Resources
r-
> -1 Paul E. Rawls, Chairman
Water Pollution Control System Operators Certification Commission
December 19, 2007
Mr. Thomas 1 Guthrie _ - -
Duke Energy -
Belews Creek Steam Station
3195 Pine Hall Road
Belews Creek, NC 27009
Subject: Duke Energy Carolinas, LLC
Belews Creek Steam Station
NPDES Permit: NCO024406
Operator In Responsible Charge
Dear Mr. Guthrie:
This is to respond to your request for the Division of Water Quality to review and comment regarding the
operations plan for Duke Energy's Belews Creek Steam Station Wastewater facilities presented in your
letter to Paul Rawls dated December 3, 2007. The Technical Assistance and Certification Unit (TACU)
staff has reviewed your proposal with the Water Pollution Control System Operators Certification
Commission Chairman, Paul Rawls.
The observation schedule and Operator in Responsible Charge (ORC) designations as outlined in your
letter is in agreement with the suggestions James Pugh of the TACU staff presented to Duke Energy in his
letter to Robert Wylie on October 16, 2007. The WPCSOCC and TACU staff concurs with your
operations plan. We feel this will insure the attention needed to continue proper operations of the
wastewater treatment facilities at this site.
You letter captures the role of the ORC, which is to be the person responsible for operations and
supervising the operators of the system. The Permit NCO024406 system will be classified as PC -Grade 2
due to the addition of the Flue Gas Desulphurization System. The ORC must hold a PC Grade 2
certification. A Temporary Certification is available to your ORC during the interim between the time of
PC -2 classification and the ORC gaining certification as PC -2 Operator. The procedures are attached to
this letter. All this information is available at our web page (4ttp://h2o.enr.state.nc.us/tacu).
Thank you for your efforts to insure that the wastewater treatment facilities are properly operated and
monitored. This will help in all our efforts to protect the waters of North Carolina.
If you have any further questions, please contact me at (9190 733-0026 extension 309.
Sincerely, _
D C E
FO
rry F. 'mmer, Supervisor
Technical Assistance and Certification Unit DEC 1 9 2007
/Attachment
cc: Robert Wylie, Duke Energy
Marc Stokes, WSRO
Paul Rawls, WPCSOCC Chairman
OENR WATER P O TAON SECTION
SURFACE
Technical Assistance & Certification Unit Internet: http://h20.enr.state.nc.us/tacu
1618 Mail Service Center, Raleigh, NC 27699-1618 Telephone [phone] Fax [phone]
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durally

7
Mr. RobertWylie
Environmental Manager
Duke Power Belews Creek
3195 Pine Hall Rd.
Belews Creek, NC 27009
Re: Permit No. NCO024406
Stokes County
Facility Classification
Dear Mr. Wylie:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
The Water Pollution Control System Operators Certification Commission (WPCSOCC) wishes
to inform you that the Belews Creek Steam Station ash basin discharge (Outfall 003) has been
classified as both a Grade II Physical Chemical System and a Grade I Biological System. This
classification is based upon the following.
Under 15A NCAC 08G .0306 (b), the pollution control system for the FGD system utilizes a
chemical process to primarily treat the generated wastewater. A Grade II Physical Chemical
system.
Under 15A NCAC 08G.0306 (c) and .0302 (a) (2), an aerated biological lagoon system,
followed by chlorination, is being utilized for domestic wastewater treatment. A Grade I
Biological Treatment system.
Both of these treatment systems discharge through the conveyance listed as Outfall 003 on the
Belews Creek permit.
As this constitutes an alteration in classification, you must designate and notify the WPCSOCC
of an Operator in Responsible Charge and Back-up Operator in Responsible Charge of the
appropriate type and grade. You must do so 60 days prior to the system initial operation.
If there are concerns or questions, please contact me at [phone].
Sincerely
James Pugh, Education and Training Specialist
Tpchnirnl Assistance and Certification
None Carolina
Niura!!y
North Carolina Division of Water Quality 585 Waughtown Street Winston-Salem, NC 27107 Phone [phone].. Fax [phone]
Internet h2o.enr.state.nc.us
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Duke
IEnergy@
December 3, 2007
Mr. Paul Rawls
North Carolina Department of Environment
And Natural Resources
Surface Water Protection Section
512 N. Salisbury Street
Raleigh, North Carolina 27604
Subject: Duke Energy Carolinas, LLC
Belews Creek Steam Station
NPDES Permit: NC0024406
Operator in Responsible Charge
Dear Mr. Rawls:
Duke Energy
Belews Creek Steam Station
3195 Pine Hall Road
Belews Creek, NC 27009
[phone] OFFICE
[phone] FAX
®
E C E WE
O EC - 5 2007
DENR -WATER QUALITY
SURFACE WATER PROTECTION SECTION
With reference to your recent conversation with Duke Energy Corporation employees George Everett,
Melonie Martin and Robert Wylie on the ORC site responsibilities for Belews Creek Steam Station this
letter is being sent to you for further clarification. After your review and comments DukeEnergy will
work to develop a final understanding that NCDENR concurs with, so the operating structure is clearly
understood..
In January 2008 an additional wastewater treatment system (WWTS) is going to be placed on-line in
order to treat the wastewater that will be generated in the Flue Gas Desulfurization. (FGD) process. The
FGD WWTS discharges into the ash basin wastewater treatment system by way of internal NPDES
outfall. 002. Preliminary review by the NC DENR Technical Assistance and Certification Unit (TACU)
indicates that this system will be classified as a Physical / Chemical (P/C) H system.
The station also has a lagoon aeration system that treats its domestic wastewater. This system
discharges into the ash basin. TACU indicates that this system is classified as a
Biological (B) I.
Therefore the site WWTS' are being changed in classification from P/C I to P/C II and B I. This change
in classification affects the system visitation requirement of the ORC from what has historically
occurred at Belews Creek Steam Station. The visitation requirements change from one day per week to
five days per week. Additionally since outfall 002 and the sanitary aeration lagoon discharge into the
ash basin the ash basin's classification is changing to a P/C II and B I.
The site has operators that are routinely involved with each NPDES related treatment system. The
following provides an understanding of the operators visitation to the systems:
1. NPDES outfall 001 is a once through cooling water system. Station operators visit this system's
intake and outfall at least once per day to ensure there is not any unusual situations. In addition, this,
system's operation is continuously monitored the control room.
RECEIVED
DEC 10 2007-

Duke
IEnergy�
Duke Energy
Belews Creek Steam Station
3195 Pine Hall Road
Belews Creek, NC 27009
[phone] OFFICE
[phone] FAX
2. NPDES outfall 002 carries the effluent from the future FGD WWTS. The operators for this system
will be contracted. The contracted operators will be at this system seven days per week.
3. The sanitary lagoon system is visited by station operators at least once per week.
4. The ash basin will be visited by station operators and/or a contracted company at least five days per
week.
The current ORC at Belews Creek Steam Station is a Duke Energy employee. The following highlights
Duke's proposal for the ORC responsibilities:
1. The ORC will possess a valid certificate of the appropriate type and grade. (A temporary
certification will likely be needed for 2008.)
2. The ORC and/or the ORC back-up are to be on-site daily (five days per week excluding holidays).
3. Visits to the various above mentioned systems are being delegated to the operators as described
above. The ORC and/or the ORC back-up will receive daily updates from the operators of the site's
treatment systems.
4. The ORC and/or the ORC back-up are to be notified by the operators immediately if there an upset
condition of the WWTS.
5. The ORC will have the authority to coordinate the work of the operators as needed to ensure proper
system operation.
6. The ORC will be responsible for certifying the validity of the NPDES data and signing the discharge
monitoring reports.
Your review and comments on this letter is appreciated. Belews Creek Steam Station is committed to
ensuring that all of its WWTS are operated to ensure that outstanding performance is achieved. If you
have any questions or need additional information please contact Robert Wylie at 704 3 82-4669.
Sincerely,
Thomas J. Guthrie
General Manager III
Belews Creek Steam Station