NCS000574_Email RE Duke Energy ISP Training Requirements_20171129

Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Wednesday, November 29, 2017 2:39 PM
To: 'Woodward, Tina'; Lucas, Annette
Subject: RE: [External] Duke Energy ISP Training Requirements
Thanks for the additional information, Tina, and thanks for bearing with me on the details here. When I noticed the
acknowledgement signature step after Q&A in the original training description, I thought it was straightforward to
interpret the requirement (no matter which way it was written in which permit) was essentially satisfied, even if just the
electronic record of employees trained is maintained in the SPPP. I take it that step in the course description is obsolete
or just not always included.
We concur that the intent of changing the language in later permits was to provide the flexibility of maintaining an
electronic record of employees trained instead of the signature documentation, and future renewals of permits without
that language should have the revision, barring any other objections during public notice. I think the information in the
spreadsheet you sent is sufficient for such a record. We will also incorporate consistent language regarding training in
future draft permits for Buck Steam Station and Buck CTCC sites.
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental (duality
919 807 6372 office
bethany.geor oulias _,ncdenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh, NC 27604 (location)
Website: http://deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwater
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From: Woodward, Tina [mailto:[e-mail]]
Sent: Wednesday, November 29, 2017 1:08 PM
To: Georgoulias, Bethany<[e-mail]>; Lucas, Annette <[e-mail]>
Subject: RE: [External] Duke Energy ISP Training Requirements
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The first meeting which is the onboarding is to discuss all permit requirements, required reoccurring tasks etc. The
onboarding is completed upon permit issuance but not subsequent to that initial session. The required tasks are
uploaded to our system that sends out compliance due dates to the task owners. This onboarding is held with those
individuals that are required to implement the permit conditions (field support, lab personnel etc.). We in the
germitting comoliance grour) are reguired to conduct onboarding for every i3ermit we receive including NPDES, ESC,

The spreadsheet I sent you is for the annual required training which is conduct via a computer based training for plant
personnel. In addition to the general objectives there is site specific training as well. Each employee is required to
complete this training annually and the field support professionals maintain a copy of this spreadsheet in the SPIPP.
Tina Woodward MBA, [EPSCl[S1
Sr. Envimnmenta|6peda|ist EHS CCPPenniffingand Comp|iance
Office: 704-382-4585
From: Georgoulias, Bethany
Sent: Wednesday, November 29, 2017 12:22 PIVI
To: Woodward, Tina; Lucas, Annette
Subject: RE: [External] Duke Energy ISP Training Requirements
Tina,
Thanks for the info, Tina. I'm still not clear if the signature you mentioned after the Q&A session is on paper or
electronic? And would this step happen regardless?
Thanks,
Bethany
Bethany Georgoulias
Environmental Engineer
Siurnnwa1orProgram, Division otEnergy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 807 6372 office
l6l2Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury Street, Raleigh, NC 27604 (location)
Website: http://deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwater
Email correspomYence to amY from this ad�ess isoubiect to the0odh Carolina Public ReomnYs
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From: Woodward, Tina
Sent: Wednesday, November Z9 20176:45AM
To: Georgou|ias,Bethany ; Lucas, Annette
Cc: Lucas, Annette
Subject: RE: [External] Duke Energy ISP Training Requirements

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Sorry I did not get this back to you yesterday. I needed to get a copy from one of the sites. Please see attached training
record.
Tina Woodward MPA, CEPSCI, CSI
Sr. Environmental Specialist E.:1 IS CCF1 Flermitting and Compliance
Office: 704-382-4585
From: Georgoulias, Bethany[mai Ito: bethanyaeoraouliasCa)ncdenr.gov]
Sent: Tuesday, November 28, 2017 2:18 PM
To: Woodward, Tina; Lucas, Annette
Cc: Lucas, Annette
Subject: RE: [External] Duke Energy ISP Training Requirements
Tina,
The signature of the trainees after the Q&A session — is that what is done electronically and then kept as a record of
trained employees? I'm just trying to understand what the electronic record of the training is. Or is this just an
electronic list of the employees that attended that session? In other words, if the language were consistent for all the
permits, what does Duke Energy interpret to be an electronic record of the training?
One I understand that better, we can definitely sort this out for the existing permits and make sure the language that
goes into the draft permit for Buck Steam Station is consistent, too.
Thanks,
Bethany
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental (duality
919 807 6372 office
bethany.geor oulias _,ncdenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh, NC 27604 (location)
Website: http://deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwater
Email correspon:tcncc to amY from this a:Y:Yres,s is ,subiect to the Nodh Carolina Public ReconYs
Law an:t n7a„y be :ti,scio,so:t to thins tsadies.
From: Woodward, Tina [mailto:[e-mail]]
Sent: Tuesday, November 21, 2017 7:59 AM
To: Lucas, Annette <[e-mail]>; Georgoulias, Bethany<[e-mail]>
Subject: RE: [External] Duke Energy ISP Training Requirements

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The training for SW begins when the permit is issued. The Permitting and Compliance SME conducts an onboarding of
the permit. This initial training isheld atthe site with the site employees. This isbasically adeconstructionofthe
permit explaining:
w SPPP requirements asdescribed inPart UAMonitoring, Controls, and Limitations
w All tasks required and frequency required From Part ||A, B,C
w Analytical monitoring
o Permitted Outfall locations
o Definitions
o Analytical monitoring requirements
o Benchmark discussion
o Requirements for each Tier Level
o Qualitative Monitoring requirements
This training includes providing copies ofDEQs NPDES Industrial Stormvvater Forms such as:
w Qua |-Monitoirng-Guide-2OO8O618-DVVQ-SPU
w Qualitative Monitoring Form
w StormvvaterData Monitoring Report
w Annual DIVIKForm
OBJECTIVES:
1. List basic pollutants that may be present instorm water runoff.
2. List sources ofstorm water pollution.
3. State the purpose ofa Storm Water Pollution Prevention Plan.
4. Identify the individual tocontact ifyou have further questions about storm water.
TARGET AUDIENCE: Duke Energy employees (permanent, part-time, contractors, and temporary employees) who are
assigned to Fossil and Nuclear Sites.
This training also provides site-specific information for each site in the fleet. The employees training istracked with
other required trainings. VVedonot have atest associated with either activity. The site FSP receives acopy ofthe
records from the training specialist tokeep inthe SPPP.
*

Tina Woodward MBA, CEPSCI, CSI
Sr. Environmental Specialist I:::I IS CCF1 Flermitting and Compliance
Office: 704-382-4585
From: Lucas, Annette[mailto:annette.lucasCa)ncdenr.Qov]
Sent: Monday, November 20, 2017 2:49 PM
To: Woodward, Tina; Georgoulias, Bethany
Subject: RE: [External] Duke Energy ISP Training Requirements
Good afternoon Tina,
Bethany and I just discussed your questions and we agree with you about the benefits of using computer-based training
to make the process more cost-effective. I was wondering though if you might be able to provide more details about
the format, topics and length of the training and how the electronic record is created. I was wondering if there were any
checks to see if the staff members had mastered the information provided in the training.
Thanks,
Annette
Annette Lucas, PE
Stormwater Program Supervisor
Division of Energy, Mineral and Land Resources
Department of Environmental Quality
919 807-6381 office
annette.lucas(ri ncdenr.gcav
h:ttrJs://deq. nc.gov/sw.. bmp..manual
512 N. Salisbury Street, Office 942-V, Raleigh, NC 27604
1612 Mail Service Center, Raleigh, NC 27699-1612
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From: Woodward, Tina [mailto:[e-mail]
Sent: Monday, November 20, 2017 2:38 PM
To: Georgoulias, Bethany<[e-mail]>; Lucas, Annette <[e-mail]>
Subject: RE: [External] Duke Energy ISP Training Requirements
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[e-mail].

We had a verbal concurrence that we could universally include the printout of the electronic record of the training. This
was the language from NCS000572
a .� •s .. � .rs • s s .. s ars ,,
If we could get concurrence that this covers acknowledgement of the training we could include the correspondence in
the SPPP.
Tina Woodward MBA, CEPSCI, CSI
Sr. Environmental Specialist I:::I IS CCF1 Flermitting and Compliance
Office: 704-382-4585
From: Georgoulias, Bethany[mai Ito: bethanyaeoraouliasCa)ncdenr.gov]
Sent: Monday, November 20, 2017 2:14 PM
To: Woodward, Tina; Lucas, Annette
Subject: RE: [External] Duke Energy ISP Training Requirements
Exercise
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Tina,
I remember this coming up, but I'm not sure which permits it got into and which it did not. It evolved after the initial
permits, as I see just the standard template language in Riverbend's (an early one) that only references signature. I've
included that excerpt here for reference:
From NCS000549:

. Empl yee l"raining,. Tm~aimii;ng lar"off auris sliali be devela ped armmd ti°,i�mrim'mg pl-oviided, at .a
mr�i.r�irnrrrmr on akar am�anrraa,l � �l fa�m•f�a;:il%ty pe,rmsonrrel �vltlr re��p�mnsfl�ilita�ps for°� �pifl
res^powlse And Cleanup, plVventative m°mmaintemlamymce actiivifies, and. for any of the faciiity's
operations that have the Potential to contamninate, stoimlwater, ninof. . The facility
per"sonrael Vv5por1sib1e for i 111ple Inenting, tl'G,e trailxing ,1101 be ldentl fled, and their,
rranllml rrafm"mlir°ag shall be documented by t9"a.e signawre of ad"I e1nP10ear tr ine&
When the language was modified in later -issued permits, I think the intent was to concur with a more flexible approach
in documenting training for employees. However, we won't be able to go back and modify the permits for this small
change in a very timely manner in the cases where it wasn't included. It's understandable that the company would want
the allowance to extend across all facilities.
Annette, do you suggest an interpretation to address the discrepancy? The permit language for some of these sites
requires a signature to document this training.
Bethany
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental (duality
919 807 6372 office
bethany.geor oulias _,ncdenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh, NC 27604 (location)
Website: http://deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwater
Email eorre,spoarmtence to aarmt from this amhlr'e,s,s is ,subieet to the Norttr Carolina Public fteeonls
Law aarmt n7ay be mttseto,semt to tt`inl parties.
From: Woodward, Tina [mailto:[e-mail]
Sent: Friday, November 17, 2017 8:31 AM
To: Georgoulias, Bethany<[e-mail]>; Lucas, Annette <[e-mail]>
Subject: [External] Duke Energy ISP Training Requirements
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
[e-mail].
Good Morning,
At Duke Energy we use computer based training for our employees annual certifications. We had requested DEQ to
include this allowance in our Stormwater Permits for the stations. While the highlighted text was included in some of
our permits it was not carried through to all of the permits. Can I please get concurrence to include in our SPPP
documents that the annual training can be documented either by the signature or electronically of each employee
trained?
1. Employee Training. Training programs shall be developed and training provided at a minimum on an annual
basis for facility personnel with responsibilities for: spill response and cleanup, preventative maintenance
activities, and for any of the facility's operations that have the potential to contaminate stormwater runoff. The

facility personnel responsible for implementing the training shall be identified, and their annual training shall
be documented by the signature or electronically of each employee trained.
Thankyou
Tina Woodward
t,%,DtJKE
,,' "ENERG"Y
Tina Woodward MBA, CEPSCI, CSI
Sr. Environmental Specialists 1::.:1 IS CCF' Flerrniffing and Compliance
526 Souffi Church S'tree't I ::.:C.13K I CharloUe, NC 28202
[e-mail]
Cell: 803-412-6875
Office: 704-382-4585