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Home My WebLink AboutNCS000571_Tier III Action Plan_20221229DUKE December 15, 2022 NC Department of Environmental Quality Division of Energy, Mineral, and Land Resource 610 East Center Avenue, Suite 301 Mooresville, NC 28115 Subject: Rogers Energy Complex NPDES Permit NCS000571 Action Plan: Tier III Exceedances for SWO04 & SWO16 Dear Mr. Kahn: Rogers Energy Complex 573 Nuke Power Road Mooresboro, NC 28114 Duke Energy respectfully submits the Action Plan, required as by Part D, Section D-7 of the subject permit. If you have questions, please contact Elizabeth Glenn at (980) 373-0530 or elizabeth.glenn@duke-energy.com. I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete./ am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. Sincerely, Brandon K. Sipe General Manager III Rogers Energy Complex Enclosures USPS 7020 1810 0001 1930 9673 Action Plan: Tier III Benchmark Exceedances Rogers Energy Complex — Mooresboro, NC Table of Contents 1 Exceedance Documentation............................................................................................................1 1.1 SWO04.................................................................................................................................1 1.2 SW016-42............................................................................................................................1 2 Inspection Report ..............................................................................................................................1 3 Review................................................................................................................................................2 3.1 SWO04.................................................................................................................................2 3.2 SWO16-42............................................................................................................................2 4 Action Plan.........................................................................................................................................2 4.1 SWO04................................................................................................................................. 2 4.2 SWO16-42............................................................................................................................2 5 Monitoring Plan................................................................................................................................. 3 5.1 SWO04................................................................................................................................. 3 5.2 SW016-42............................................................................................................................3 Appendices Appendix A — Best Management Practices November 2022 Action Plan: Tier III Benchmark Exceedances Rogers Energy Complex (Cliffside) - Mooresboro, NC 1 Exceedance Documentation 11 SWO04 Outfall SWO04 exceeded the benchmark standard for copper and zinc for the October 31, 2022 stormwater sample collection. Laboratory results from this sampling event were received on November 17, 2022. SWO04 entered into Tier III status for copper on 10/10/2018 and zinc on 4/19/2017. Most recent benchmark exceedances for zinc and copper at SWO04 are included below. Zn (mg/L) Date Value': Benchmark March 16, 2022 1, 0.156 0.126 5, 2022 0.162 0.126 May 23, 2022 0.199 0.126 October 31, 2022 0.253 0.126 1.2 SWO16-42 Outfall SW016 exceeded the benchmark standard for total suspended solids (TSS) for the October 31, 2022 stormwater sample collection. Laboratory results from this sampling event were received on November 17, 2022. SWO16-42 entered into Tier III status for TSS on 4/5/2022. Most recent benchmark exceedances for SWO16-42 are included below. TSS (mg/L) Date Value;; Benchmark February 23, 2022 150 100 March 13, 2022 130 100 April 5, 2022 140 100 October 31, 2022 2700 100 November 2022 CliHslde_Tter III_Acdon Plan_November Sampling Action Plan: Tier III Benchmark Exceedances Rogers Energy Complex (Cliffside) - Mooresboro, NC Inspection Report A SPCC Plan inspection was performed for the drainage area of SWO04 on November 30, 2022 and the outfall was surveyed. A thorough inspection was performed by Cardno and Duke staff on December 8, 2022 due to 3rd party inspector availability. Duke staff and WSP staff conducted an inspection of SW016- 42 drainage basins on November 9, 2022. 3 Review 3.1 SWO04 The drainage area for SWO04 is comprised mostly of the Units 1-4 switchyard. The switchyard is covered with gravel. It is slightly elevated from the surrounding grade and surrounded by concrete curbing, except on the northwest end. Less than five percent of this drainage area is paved. The switchyard is used for transmission only. This outfall is connected to a galvanized tank. Switchyards containing oil-bearing equipment must be properly maintained according to the Best Management Practices (BMPs) detailed in Appendix A, Best Management Practices. 3.2 SWO16-42 The drainage area for SWO16 includes runoff from approximately 5,000 feet of railroad tracks, dirt stock piles, a portion of the haul road to the fly ash/gypsum landfill, part of Duke Power Road and the largely vegetated area east of the entrance to the plant. Runoff is conveyed into sediment basins RD-1, RD-5, SB-5, and SB-6 and is discharged via pipes to Suck Creek. SW016 has 5 stormwater outlets. SW016-42 represents the other 4 outfalls located in the SW016 drainage area. On 10/31/2022 a stormwater inlet between the rail road track and haul road was identified with no additional BMPs present. Before the November 9, 2022 inspection, it was noted that haulage and construction activities were causing damage to the paved haul road. On 10/28/2022 the north side of the haul road had material removed from the shoulder to allow run-off of the paved road to enter the side ditch. Crush and run gravel was added to the shoulder and part of the degraded paved road. The rain event on 10/31/2022 carried some of this material into the stormwater conveyance system. Ash and soil are transported through this drainage basin. Duke Energy enforces procedures to minimize tracking of fugitive dust. BMP details are outlined in Appendix A. Action Ir 4.1 SWO04 Sediment and stormwater samples should be collected and analyzed from the inlet to determine if elevated metals constituents are present before entering the galvanized tank. An XRF study was performed on December 8, 2022 and results are pending. Due to the drainage area consisting of an active switchyard containing structural steel and copper components, requesting tier relief may be an alternative solution. 4.2 SW016-42 Filter stone and socks were installed on the stormwater inlet located in the grass drainage ditch between the railroad and haul road. Rip -rap was placed in the north side haul road drainage ditch. A construction November 2022 Action Plan: Tier III Benchmark Exceedances Rogers Energy Complex (Cliffside) - Mooresboro, NC exit was installed on the exit side of the haul road from the landfill. A construction exit was installed at the intersection of the haul road and the gravel road coming from the AAB. Additional filter socks designed to capture metals were added to the inlets of the stormwater piping along the haul road. On November 9, 2022, the Engineer of Record (EOR) for the landfill project design reviewed the haul road and surrounding areas for possible redesign and BMP improvements. 5 Monitoring Plan 5.1 SWO04 Following determination of switchyard components directly contributing to copper and zinc inputs, stormwater samples should be collected monthly as required under Tier III status to monitor impacts (if any) to stormwater discharge. 5.2 SWO16-42 Implementation of BMPs noted in the action plan should limit sediment inputs. FOR recommendations will be reviewed and implemented if deemed effective for controlling deposition. Stormwater samples should be collected monthly to confirm benchmarks are not exceeded. November 2022 Cliffside_Tier III_Acgon_Plan November Sampling Location: Rogers Energy Complex Yard Drainage Basin Narrative Description and BMP Summary Permit No. NCS000571 Outfall ID SWO04 '{ Discharge Structure 24" CMP r Location Broad River at Units 1-4'' Switchyard Latitude - Longitude 350 13' 15.88" N 810 45' 32.22" W Drainage Area 2.4 acres Percent Impervious 50% Permit Monitoring Table 1 += Industrial Activities and This drainage basin is comprised mostly of the Units 1-4 switchyard. The Description switchyard is covered with gravel. It is slightly elevated from the surrounding grade and surrounded by concrete curbing, except on the northwest end. Less than five percent of this drainage area is paved. The switchyard is used for transmission only. Significant Materials/Potential Pollutants Oil: Switchgear equipment in this drainage basin contains 16,711 gallons of mineral oil. Stormwater runoff from this drainage area is processed through a 20,000 gallon oil trap tank. BMP Summary Oil bearing equipment switchyards • Maintain level grades and gravel surfaces to retard flows and limit the spread of spills. • Collect stormwater runoff in perimeter ditches and route around switchyard. Divert upland runoff with curbs. • Inspect transformers for failures or leaks and perform preventive maintenance. Use dry cleanup methods for spills. • Train employees in spill response protocols. Equipment maintenance • Promptly transfer used fluids to the proper container; do not leave full drip pans or other open containers around the shop. Empty and clean drip pans and containers. Location: Rogers Energy Complex Yard Drainage Basin Narrative Description and BMP Summary Permit No. NCS000571 Outfall ID SWO16 5 CMP's beneath the Discharge Structure railroad Suck Creek 350 12' 17.94" N Location Latitude - Longitude 810 45' 43.03" W 70 acres. 0%- n/a Drainage Area Percent Impervious Permit Monitoring Table Industrial Activities and _ Drainage area includes runoff from approximately 5,000 feet of railroad Description tracks, dirt stock piles, a portion of the haul road to the fly ash/gypsum landfill, part of Duke Power Road and the largely vegetated area east of the entrance to the plant. Runoff is conveyed into sediment basins RD-1, RD-5, SB-5, and SB-6 and is discharged via pipes to Suck Creek. Significant Oil: Heavy equipment operate in this drainage area as Materials/Potential part of ash basin closure. There is a service Pollutants transformer at the security building. It contains 152- gallons of mineral oil. Inert Laydown: The site is vacant now. Spare equipment, parts, steel, cable, and miscellaneous supplies may be stored in laydown areas throughout the drainage area. The equipment and supplies generally do not contain liquids. Ash Hauling: The drainage area includes regular fly ash and bottom ash haul routes. Coal and Limestone: Rail cars carrying coal and limestone use the rail lines that pass through this drainage area. BMP Summary Large Bulk Fuel Storage • Maintain double -walled tanks or secondary containment. • Inspect storage tanks and piping systems (pipes, pumps, flanges, couplings, hoses, and valves) for failures or leaks and perform preventive maintenance. • Implement spill plans or spill prevention, containment, and countermeasure (SPCC) plans. Fugitive Dust Emission • Utilize dust suppression control technologies to minimize offsite tracking of spilled ash and coal dust. • Wash vehicles or brush off residue in a designated area where AA ash water and residue can be controlled.