NC0004987_Inspection_20181003

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NORTH CAROUNA
ROY COOPER Enpiro►mentalQuarrty
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MI HAEL S.RE AN
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LINDA CULPEPPER
InImm Director
3 October 2018
Mr. Rick Roper, Station Manager
Duke Energy Carolinas,LLC
8320 E NC 150 Hwy.
Terrell,North Carolina 28682
Subject: Compliance Evaluation Inspection
Duke Energy Carolinas/Marshall Steam Station
NPDES Permit No.NC0004987
Catawba County
Dear Mr. Roper:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on
September 27,2018,by Mr.Wes Bell of this Office. Please inform the facility's Operator-in-Responsible Charge(ORC)of our
findings by forwarding a copy of the enclosed report.
Should you have any questions concerning this letter,please do not hesitate to contact Mr. Bell at(704) 235-2192, or via
email at [e-mail].
Sincerely,
Docu'SiignnJeed by:
A14CC681 AF27425...
W. Corey Basinger,Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources,NCDEQ
Enclosure:
Inspection Report
E11-�
North Carolina Department of Environmental Quality I Division of Water Resources
610 East Center Avenue I Suite 301 I 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 2 15 1 3 I NC0004987 111 12 I 18/09/27 I17 18 I S i 19 i G i 201 I
21I111II IIIIIIIIIII III IIII I IIIIII IIIIIIIII1 f6
Inspection Work Days Facility Self-Monitoring Evaluation Rating 131 QA ----------------------Reserved-------------------
67 2.0 70 71 [.. I 72 73 L_LJ74 751 I I I I I I I80
u Section B: Facility Data u
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also include Entry Time/Date Permit Effective Date
POTW name and NPDES oermit Number) 09:30AM 18/09/27 18/05/01
Marshall Steam Station
NC Hwy 150 Exit Time/Date Permit Expiration Date
Terrell NC 28682 02:25PM 18/09/27 21/09/30
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
Gregory Paul Phillips/ORC/828-478-7647/
Joseph Scott La Sala/EHS Professional Sr/828-478-7820/8284787776
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Rick Roper,8320 E NC 150 Hwy Terrell NC 28682/Station Manager/828-478-7600/
No
Section C:Areas Evaluated During Inspection(Check only those areas evaluated)
Permit 0 Flow Measurement Operations&Maintenance Records/Reports
Self-Monitoring Program Sludge Handling Disposal Facility Site Review Compliance Schedules
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
EDocuSigned by:
Wes Bell D� MRO WQ//704-663-1699 Ext.2192/ 10/3/2018
A61 e96D90CC3437...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
W. Corey Basinger MRO WQ//704-235-2194/
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete.
DocuSigned by:
-- 10/4/2018
AtaccsatAFvazs... Page# 1

NPDES yr/mo/day Inspection Type 1
31 NC0004987 I11 121 18/09/27 117 18 I C
Section D:Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
Page# 2

Permit: NC0004987 Owner-Facility: Marshall Steam Station
Inspection Date: 09/27/2018 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 ❑ ❑ 0 ❑
application?
Is the facility as described in the permit? 0 ❑ ❑ ❑
#Are there any special conditions for the permit? 0 ❑ ❑ ❑
Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑
Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑
Comment: The Division issued a major permit modification on April 2, 2018 that included changes to
the following: dates of compliance with 40 CFR 423 for bottom ash transport wastewater
and FGD wastewater; language for compliance with turbidity limit; TSS and Oil & Grease
limits (from Internal Outfall 010 to Outfall 005); physical/chemical treatment requirement;
rate for lowering the liquid level per latest guidance from DEMLR; and instream monitoring
frequency during decanting and dewatering.
The facility currently discharges from Outfalls 001, 002, 003, 004 (internal) and
non-constructed seeps (S-01 and S-02). No chlorine is added to the discharges at any of
the outfalls.
The last compliance evaluation inspection was performed at the facility on 6/1/17 by DWR
staff.
Compliance Schedules Yes No NA NE
Is there a compliance schedule for this facility? 0 ❑ ❑ ❑
Is the facility compliant with the permit and conditions for the review period? 0 ❑ ❑ ❑
Comment: Duke Energy Carolinas, LLC and the NC Environmental Management Commission entered
into a SOC (EMC SOC WQ S17-009)to address issues related to the elimination of seeps
from Duke Energy's coal ash basins during the separate and independent process of basin
closure under the Coal Ash Management Act (CAMA) and the Federal Coal Combustion
Residuals Rule. The SOC became effective on April 12, 2018.
Construction activities are on-going for the lined retention basin (Outfall 005), yard sump
(Internal Outfall 001/001A), FGD wet scrubber wastewater treatment facility(Internal Outfall
006), and holding basins (Internal Outfall 010).
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit? 0 ❑ ❑ ❑
Is all required information readily available, complete and current? 0 ❑ ❑ ❑
Are all records maintained for 3 years(lab. reg. required 5 years)? 0 ❑ ❑ ❑
Are analytical results consistent with data reported on DMRs? 0 ❑ ❑ ❑
Is the chain-of-custody complete? 0 ❑ ❑ ❑
Dates,times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Page# 3

Permit: NC0004987 Owner-Facility: Marshall Steam Station
Inspection Date: 09/27/2018 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
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? ❑ ❑ 0 ❑
Comment: The records reviewed during the inspection were organized and well maintained. Discharge
Monitoring Reports (eDMRs)were reviewed for the period August 2017 through July 2018. A
daily maximum and monthly average effluent TSS violations were reported at Outfall 002B
(yard sump overflow) in July 2018. The Division will separately address these limit
violations.
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 E ❑ ❑ ❑
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: The facility is certified to perform on-site field analyses (pH and temperature) under field
laboratory certification#5155. Duke Energy's Analytical Laboratory (Certification#248) and
the contracted services of Pace Analytical Services and ETS, Inc. also provide analytical
support for all permit-required analyses.
Influent Sampling Yes No NA NE
#Is composite sampling flow proportional? ❑ ❑ 0 ❑
Is sample collected above side streams? ❑ ❑ 0 ❑
Is proper volume collected? 0 ❑ ❑ ❑
Is the tubing clean? ❑ ❑ 0 ❑
Page# 4

Permit: NC0004987 Owner-Facility: Marshall Steam Station
Inspection Date: 09/27/2018 Inspection Type: Compliance Evaluation
Influent Sampling Yes No NA NE
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees ❑ ❑ 0 ❑
Celsius)?
Is sampling performed according to the permit? 0 ❑ ❑ ❑
Comment: The subject permit requires grab sampling at internal Outfall 004.
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? ❑ ❑ 0 ❑
Is sample collected below all treatment units? 0 ❑ ❑ ❑
Is proper volume collected? 0 ❑ ❑ ❑
Is the tubing clean? ❑ ❑ 0 ❑
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees ❑ ❑ 0 ❑
Celsius)?
Is the facility sampling performed as required by the permit(frequency, sampling type 0 ❑ ❑ ❑
representative)?
Comment: The subject permit requires effluent grab samples.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit(frequency, sampling type, and 0 ❑ ❑ ❑
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 ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: The NPDES facilities appeared to be properly operated and well maintained. The FGD
treatment system components (prior to wetland treatment system)are connected to a
computer monitoring system to assist the wastewater staff in the operation of the treatment
processes including any alarm conditions. The high water alarms (yard sumps and
domestic wastewater pump station)and FGD alarm notifications are connected to the
facility's control rooms that are staffed 24/7.
Flow Measurement- Effluent Yes No NA NE
#Is flow meter used for reporting? ❑ ❑ 0 ❑
Is flow meter calibrated annually? ❑ ❑ 0 ❑
Is the flow meter operational? ❑ ❑ 0 ❑
(If units are separated) Does the chart recorder match the flow meter? ❑ ❑ 0 ❑
Page# 5

Permit: NC0004987 Owner-Facility: Marshall Steam Station
Inspection Date: 09/27/2018 Inspection Type: Compliance Evaluation
Flow Measurement- Effluent Yes No NA NE
Comment: Outfall 001 flows are measured by pump curves/lops. Outfall 002 flows are measured by
staff quage/elevation readings and supporting flow calculations. The flows for Outfalls 003
and 004 are based on staff gauge measurements and supporting flow calculations based on
pipe diameter(Outfall 003) and flume throat (Outfall 004).
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: The effluent discharges from Outfalls 001, 002, 003, and the non-engineered seeps (S-01
and S-02)appeared clear with no floatable solids and/or foam. The receiving stream did not
appear to be negatively impacted.
Solids Handling Equipment Yes No NA NE
Is the equipment operational? 0 ❑ ❑ ❑
Is the chemical feed equipment operational? 0 ❑ ❑ ❑
Is storage adequate? 0 ❑ ❑ ❑
Is the site free of high level of solids in filtrate from filter presses or vacuum filters? 0 ❑ ❑ ❑
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? 0 ❑ ❑ ❑
Comment: The FGD wastewater treatment system (WTS) is equipped with multiple filter presses. The
dewatered sludge, off-spec gypsum, bottom ash, and fly ash are disposed into the permitted
on-site landfill. Note: A small percentage of the fly ash is also reused in the concrete
industry. The gypsum material from the FGD WTS is reused by an outside company
(National Gypsum) in the dry wall market.
Page# 6