Division of Water Resources Water Quality Regional - State of North
From: To: Subject: Date: Attachments:
Davidson, Landon Moore, Andrew W; Campbell, Ted FW: NPDES Groundwater Monitoring Friday, January 17, 2014 8:25:08 AM NPDES GW59 List 2011-2013 mod Permits UPDATE.xls 030619 - Guidance for Selecting the Action Codes when Entering-Verifying Violations in BIMS.pdf
Fyi….we can discuss for some background. G. Landon Davidson, P.G. NCDENR - Division of Water Resources Water Quality Regional Operations Section Regional Supervisor - Asheville Regional Office 2090 U.S. Hwy. 70 Swannanoa, N.C. 28778 ph.: 828-296-4500 fax: 828-299-7043 email: [email protected] website: www.ncwaterquality.org Notice: Per Executive Order No. 150, all emails sent to and from this account are subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Watts, Debra Sent: Thursday, January 16, 2014 5:25 PM To: Davidson, Landon Subject: FW: NPDES Groundwater Monitoring
Landon Got your voicemail and will talk to Jay about whether Coal Ash should be an exception as far as putting in an “Action Code.” Guess I was thinking they could be coded as “No Action SOC Pending”. The other thought was that since they are subject to EPA review, wouldn’t they want us to show we are aware of the exceedances. The main thought was to get those erroneous reports to stop. Btw, Cliffside and Ashville both have Action Codes for their GW59 reports – they are listed as “No Action, Invalid Permit.” djw From: Watts, Debra Sent: Thursday, January 16, 2014 3:13 PM To: Basinger, Corey; Bolich, Rick; Cranford, Chuck; Davidson, Landon; Gregson, Jim; Henson, Belinda; King, Morella s; Knight, Sherri; May, David; Parker, Michael; Pitner, Andrew; Smith, Danny Cc: Wilcox, Betty; Zimmerman, Jay; Smith, Eric; Watts, Debra; Belnick, Tom; Risgaard, Jon; Scott, Michele Subject: NPDES Groundwater Monitoring
All Recently we had Regional staff call us about an NPDES permit that was generating erroneous reports for “Late/Missing GW59s”. Their concern was that since it was an NPDES permit, it was subject to
EPA scrutiny. In addition, it was an Ash Pond facility which made the issue even more sensitive. I asked Betty Wilcox to see if this was a broader problem, or applied only to this one particular permit, and of course it was a broader problem. I then asked her to generate a list of all the NPDES permits that have groundwater monitoring, which is the excel sheet that is attached. Don’t be alarmed – most Regions only have between 7 – 10 NPDES permits with groundwater monitoring. I have asked in the past that you help us clean up the well data to accurately reflect true requirements, but this time I have specific recommendations. First, to explain the excel sheet – the first tab is a list by Region of permits that have active monitoring and the sampling months for which they have submitted GW-59 reports. The second tab is a bit more complex – it lists permits with active monitoring and permits (shown in bold) that are not reporting any data, even though they may have active wells listed. This same tab lists the number of active wells, as well as inactive wells, and the date if they have suspended monitoring (for example, if a well is inactive or abandoned, monitoring should be suspended or BIMS will report missing data). Second, in order to stop erroneous violations that are reported from BIMS, you need to suspend monitoring for any well you don’t want a report from. If BIMS is reporting correctly, as far as I know, staff should be entering an “Action Code” to explain if they are taking action or why they are not (See DWQ policy attached). Although, in talking with Vanessa Manuel and finding out that groundwater data is not exported to EPA, it is still subject to EPA review. And finally, please let us know if you have verified monitoring data was received on time, but BIMS is reporting it late. According to most permits, permittees have 30 days to send in their data after the month of sampling. The Information Management staff have 60 days according to BIMS staff to key it in, and then BIMS runs the violations report 20 days after the 60 day entry time (essentially 80 days after the permit’s deadline). Although the Information Management have been doing a pretty good job to get data in on time, if this is an issue for your Region, please let us know and we can discuss with Info Mgmt staff to see if we need to change the BIMS timing on data entry. Well, that’s all I have. Please let me know if you have any questions or concerns. Or you can contact Betty Wilcox as well. Thanks everyone! Debra J. Watts, Supervisor Groundwater Protection Branch Water Quality Regional Operations Section 919-807-6338 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation.
From: Wilcox, Betty Sent: Wednesday, January 15, 2014 4:02 PM To: Watts, Debra Cc: Wilcox, Betty Subject: RE: Late/Missing GW59 ? Violation Action - None
Debra, I have included an updated spreadsheet (NPDES Permits with Wells2) in the attached workbook that includes additional NPDES permits and their status for facilities included in your hard copy historical list. Those facilities that are in bold did not report GW59 data in BIMS for the period 2011-2013. The spreadsheet has been updated with BIMS well/permit status information for all the NPDES facilities listed. I compared the list with your hard copy historical list provided; the attachment contains some additional newer facilities. Betty --Betty Wilcox Environmental Chemist Division of Water Resources Water Quality Regional Operations Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone: (919) 807-6348 Fax: (919) 807-6496 E-mail address: [email protected] E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Wilcox, Betty Sent: Tuesday, January 14, 2014 12:53 PM To: Watts, Debra Cc: Wilcox, Betty Subject: RE: Late/Missing GW59 ? Violation Action - None
Debra, Attached is the workbook with RRO and WaRO corrections on the spreadsheets. --Betty Wilcox Environmental Chemist Division of Water Resources Water Quality Regional Operations Section 1636 Mail Service Center Raleigh, NC 27699-1636
Phone: (919) 807-6348 Fax: (919) 807-6496 E-mail address: [email protected] E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Wilcox, Betty Sent: Tuesday, January 14, 2014 9:08 AM To: Watts, Debra Cc: Wilcox, Betty Subject: FW: Late/Missing GW59 ? Violation Action - None Importance: High
Corrections made to forwarded message. --Betty Wilcox Environmental Chemist Division of Water Resources Water Quality Regional Operations Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone: (919) 807-6348 Fax: (919) 807-6496 E-mail address: [email protected] E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Wilcox, Betty Sent: Tuesday, January 14, 2014 8:58 AM To: Watts, Debra Cc: Wilcox, Betty Subject: RE: Late/Missing GW59 ? Violation Action - None
Debra, I have attached a workbook with data extracted from BIMS (and modified) that contains a list of NPDES facilities that have reported GW59 well data between 2011 and 2013. Sheet 1 contains the list of facilities reporting data including the month the data was submitted: “NPDES Permits-GW59s 2011-2013” Sheet 2 is an abbreviated list from Sheet 1 that contains the permit numbers and facilities sorted by region: “NPDES Permits with Wells2” I also evaluated a sample of BIMS reports (specifically reports for the 14 coal ash facilities) to examine violations related to “Late/Missing Data” and “Missing Well or Missing Parameter”. My findings/comments include the following:
2011 Required GW59 reports for three times/year sampling were entered within 1 month of report received date, and no violations for “Late/Missing GW59s” for nearly all 14 coal ash facilities with the following exceptions: · Required GW59 reports for three times/year sampling were entered 2 or more months after the report received date for 3 facilities but no “Late/Missing GW59” violations were generated. Multiple “Late/Missing GW59” or “Missing Well or Missing Parameter” violations were listed for 1 facility, Roxboro, that had two wells still in BIMS from a previous permit version that pre-dated the current groundwater monitoring plans. · BIMS reported “Missing Well or Missing Parameter” violations at least once for 5 of the 14 facilities during 2011 but the GW59s were reported in BIMS as received on time, and no “Late/Missing GW59” violations were generated. This can occur if a GW59 is received on time, but all parameters or wells are not reported or all parameters or wells are not entered by the time BIMS runs the violations report. · Some reports for samples collected prior to the current approved groundwater monitoring plan schedule in BIMS were listed as “Late/Missing GW59”. 2012 Required GW59 reports for three times/year sampling were entered within 1 month of report received date, and no violations for “Late/Missing GW59s” for nearly all 14 coal ash facilities with the following exceptions: · Required GW59 reports for three times/year sampling were entered 2 or more months after the report received date for 3 facilities but no “Late/Missing GW59” violations were generated. Multiple “Late/Missing GW59” or “Missing Well or Missing Parameter” violations were listed for 1 facility, Roxboro, that had two wells still in BIMS from a previous permit version that pre-dated the current groundwater monitoring plans. · BIMS reported “Missing Well or Missing Parameter” violations at least once for 4 of the 14 facilities during 2012 but the GW59s were reported in BIMS as received on time and no “Late/Missing GW59” violations were generated. 2013 Required GW59 reports for three times/year sampling were entered within 1 month of report received date, and no violations for “Late/Missing GW59s” for all 14 coal ash facilities with the following exceptions: · Multiple “Late/Missing GW59” or “Missing Well or Missing Parameter” violations were listed for 1 facility, Roxboro, that had two wells still in BIMS from a previous permit version that pre-dated the current groundwater monitoring plans. · BIMS reported “Missing Well or Missing Parameter” violations at least once for 5 of the 14 facilities during 2013 but the GW59s were reported in BIMS as received on time and no “Late/Missing GW59” violations were generated. · Summary BIMS allows a grace period after the scheduled report due date to allow for data entry prior to running a scan for violations. Depending on the grace period, no “Late/Missing GW59” violation will
be generated if the report is submitted and logged into BIMS as received within that period. Even though no “Late/Missing GW59” violation is generated for a specific report, “Missing Well or Missing Parameter” violations are generated for the same report if data for all wells and all parameters has not been submitted and/or is not entered into BIMS before the violations scan is run. With the exception of Cliffside and Asheville, there were generally no “Action” codes or comments (such as “No Action, BPJ or “No Action, BIMS Calculation Error)listed in BIMS that addressed the reported violations. The status of the two wells in the Roxboro permit that pre-dated the current groundwater monitoring plans has been changed to “temporarily abandoned” in BIMS to prevent future “Late/Missing GW59” violations for that permit. According to Eric Rice in the RRO, John Toepfer reported that those two wells were installed after the ash pond was installed and are located on the slope of the ash pond within the compliance boundary. Please let me know if you need additional information. Betty --Betty Wilcox Environmental Chemist Division of Water Resources Water Quality Regional Operations Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone: (919) 807-6348 Fax: (919) 807-6496 E-mail address: [email protected] E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Watts, Debra Sent: Wednesday, January 08, 2014 3:58 PM To: Romanski, Autumn Cc: Zimmerman, Jay; Wilcox, Betty; Watts, Debra; Bolich, Rick; Smith, Danny Subject: FW: Late/Missing GW59 ? Violation Action - None
Autumn We did some follow up on your questions about the groundwater monitoring for the Roxboro Power Plant, and below is some information you may want to consider:
1.
When APS/CO first directed the Power Plants to put wells at their Compliance Boundary in 2010, it was directed state-wide, and the wells were put in BIMS by the former APS/CO staff. The entry of the wells in BIMS were not necessarily coordinated with when the wells were actually constructed or when they began sampling, and the monitoring plan actually changed quite a bit as we coordinated these actions with Progress Energy. This may have caused some of the issues you discussed and why BIMS reports missing data in 2011. My apologies! If you can tell us which wells you continue to have issues with, we can probably help you nail this down. 2. The CONV wells you found recorded under the Roxboro permit were wells in the system (BIMS) that we did not have any information on – they were transferred from the old Paradox system to BIMS and we did not know if they had been abandoned, etc., so we left them as is. As Betty told you in an earlier email, she went ahead and changed their status to temporarily abandoned in BIMS since we don’t require sampling from them in the permit and apparently they are causing BIMS to report violations. 3. Since late or missing data seemed to be a concern, we talked with Tom Moore with the BIMS IT staff and verified how the system works. Hopefully I can explain this since it’s pretty complicated. In the permit we give the permittee 30 days after the month of sampling to report the data. So, for example, if they sample in November, they have to report the data by the end of December. BIMS allows 60 days for data entry, so in this example they would have until the end of February to enter the data; a total of 90 days after being sampled. After the 90 days, BIMS runs an automatic report whether the data was received and if it has violations. If the data is entered after the 90 days allowed, BIMS will begin reporting if there are any violations, but will continue to report that it was late/missing. Betty is currently checking to see if the Regions are receiving late/missing reports for data received on time but is reported late due to late date entry. If so, we will talk with the data entry staff for resolution. 4. I believe you have a good point about staff not entering the resolution for the violations reported. After we finish our research, Jay wants me to address this with WQROS staff, specifically those NPDES permits that may have monitoring wells. I did check with Vanessa Manuel and our groundwater monitoring data is not electronically reported to EPA, although they are still subject to a file review by EPA. Either way, staff should be recording resolution for violations, and I don’t think most of the ash pond facilities have anything recorded. That’s all I have for now. If you have further questions, it may be easier to give me a call and we can continue to discuss. Or stop by and we can continue to research together. My phone number is below. Thanks! Debra J. Watts, Supervisor Groundwater Protection Branch Water Quality Regional Operations Section 919-807-6338
From: Wilcox, Betty Sent: Tuesday, January 07, 2014 3:33 PM To: Romanski, Autumn Cc: Watts, Debra; Wilcox, Betty Subject: FW: Late/Missing GW59 ? Violation Action - None
Autumn, I passed along the information we discussed this morning regarding the Roxboro plant and lack of listed violation actions in BIMS for EPA reports to Debra Watts, Groundwater Protection Branch Supervisor. Late/Missing violations in BIMS due to late data entry for data that has been received, but not entered by the deadline, can be addressed by entering the appropriate comment-code in the “Action” and comments column on the Violations screen. Legitimate missing/late reports will not require a code. I have also changed the status of the two wells you referenced as ”Missing Well” to “temporarily abandoned”, with a retroactive monitoring suspension date of 1/1/2011 in the current expired permit and the permit in review. I’m not sure that BIMS will reevaluate the violations based on a retroactive monitoring suspension date; however future “Missing Well” violations for those two wells should be prevented. I will check BIMS tomorrow to see if the violations have changed retroactively. Please let me know if I can be of further assistance regarding these issues. Betty --Betty Wilcox Environmental Chemist Division of Water Resources Water Quality Regional Operations Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone: (919) 807-6348 Fax: (919) 807-6496 E-mail address: [email protected] E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Watts, Debra Sent: Monday, January 06, 2014 3:08 PM To: Romanski, Autumn Cc: Hennessy, John; Poupart, Jeff; Scott, Michele; Manuel, Vanessa; Wilcox, Betty; Rice, Eric; Bolich, Rick; Watts, Debra Subject: RE: Late/Missing GW59 ? Violation Action - None
Hi Autumn Not sure what permit you are referring to – the Progress Cape Fear Power Plant is NC0003433 and the Progress Roxboro Power Plant is NC0003425. Either way, our staff monitor both of these closely due to the highly sensitive nature of coal plants these days. Staff involved include Betty Wilcox at the Central office and Eric Rice at the Raleigh Regional Office. I will copy Betty Wilcox on this message and have her get back with you. You may also want to talk to Eric. Thanks! Debra Watts From: Manuel, Vanessa Sent: Monday, January 06, 2014 2:38 PM To: Romanski, Autumn Cc: Barnhardt, Art; Hennessy, John; Poupart, Jeff; Scott, Michele; Watts, Debra Subject: RE: Late/Missing GW59 ? Violation Action - None
Autumn, I followed up with Jeff, and you should speak with Debra Watts regarding the GW monitoring issue. VEM From: Manuel, Vanessa Sent: Monday, January 06, 2014 2:00 PM To: Romanski, Autumn Cc: Barnhardt, Art; Hennessy, John; Poupart, Jeff; Scott, Michele Subject: RE: Late/Missing GW59 ? Violation Action - None
Autumn, I’m not sure who reviews the violations associated with the GW monitoring. Since this is a compliance/enforcement issue, I’ve copied John who may be able to provide some information on your question. My recommendation is to touch base with someone in the GW group. You may also want to touch base with Michele, to see if her group enters this data into BIMS … I’m not sure who inputs the data into BIMS. Sorry, I’m not much help on this issue. Vanessa From: Romanski, Autumn Sent: Monday, January 06, 2014 1:10 PM To: Manuel, Vanessa Cc: Barnhardt, Art Subject: Late/Missing GW59 ? Violation Action - None
Hi Vanessa,
I was recently reviewing the BIMs data for an inspection at Roxboro Power Plant NC0003433. Groundwater monitoring is required in the wastewater permit Condition A.9. In reviewing this data, it shows late missing GW-59 reports Jan,Feb,March-2011, the sampling started in April 2011. Late missing GW-59 also show for May, June, August, Sept, Oct, Nov 2011-the frequency for reporting is for March June and October (ONLY Months required)since April 2011 to present. See same pattern thru 2012 and 2013 with late missing GW reports. Do you check these? or is this done by someone in GW at the central office? I think we need to understand if there is a better way to set this up in BIMS so doesn’t record a late missing GW-59 in error. I copied Art – in case he knows. Art, there is also a well missing (2011-2013) data in BIMS (but has odd identifier) CONV004023 and 4397. Can this be removed or is the facility not reporting? Just like to clean up BIMs data and confirming for the permit condition that GW monitoring plan at Roxboro is being followed as required. Thank you both for your time and let me know if these questions need to go to someone else. Sincerely,
Autumn
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation.
Davidson, Landon Moore, Andrew W; Campbell, Ted FW: NPDES Groundwater Monitoring Friday, January 17, 2014 8:25:08 AM NPDES GW59 List 2011-2013 mod Permits UPDATE.xls 030619 - Guidance for Selecting the Action Codes when Entering-Verifying Violations in BIMS.pdf
Fyi….we can discuss for some background. G. Landon Davidson, P.G. NCDENR - Division of Water Resources Water Quality Regional Operations Section Regional Supervisor - Asheville Regional Office 2090 U.S. Hwy. 70 Swannanoa, N.C. 28778 ph.: 828-296-4500 fax: 828-299-7043 email: [email protected] website: www.ncwaterquality.org Notice: Per Executive Order No. 150, all emails sent to and from this account are subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Watts, Debra Sent: Thursday, January 16, 2014 5:25 PM To: Davidson, Landon Subject: FW: NPDES Groundwater Monitoring
Landon Got your voicemail and will talk to Jay about whether Coal Ash should be an exception as far as putting in an “Action Code.” Guess I was thinking they could be coded as “No Action SOC Pending”. The other thought was that since they are subject to EPA review, wouldn’t they want us to show we are aware of the exceedances. The main thought was to get those erroneous reports to stop. Btw, Cliffside and Ashville both have Action Codes for their GW59 reports – they are listed as “No Action, Invalid Permit.” djw From: Watts, Debra Sent: Thursday, January 16, 2014 3:13 PM To: Basinger, Corey; Bolich, Rick; Cranford, Chuck; Davidson, Landon; Gregson, Jim; Henson, Belinda; King, Morella s; Knight, Sherri; May, David; Parker, Michael; Pitner, Andrew; Smith, Danny Cc: Wilcox, Betty; Zimmerman, Jay; Smith, Eric; Watts, Debra; Belnick, Tom; Risgaard, Jon; Scott, Michele Subject: NPDES Groundwater Monitoring
All Recently we had Regional staff call us about an NPDES permit that was generating erroneous reports for “Late/Missing GW59s”. Their concern was that since it was an NPDES permit, it was subject to
EPA scrutiny. In addition, it was an Ash Pond facility which made the issue even more sensitive. I asked Betty Wilcox to see if this was a broader problem, or applied only to this one particular permit, and of course it was a broader problem. I then asked her to generate a list of all the NPDES permits that have groundwater monitoring, which is the excel sheet that is attached. Don’t be alarmed – most Regions only have between 7 – 10 NPDES permits with groundwater monitoring. I have asked in the past that you help us clean up the well data to accurately reflect true requirements, but this time I have specific recommendations. First, to explain the excel sheet – the first tab is a list by Region of permits that have active monitoring and the sampling months for which they have submitted GW-59 reports. The second tab is a bit more complex – it lists permits with active monitoring and permits (shown in bold) that are not reporting any data, even though they may have active wells listed. This same tab lists the number of active wells, as well as inactive wells, and the date if they have suspended monitoring (for example, if a well is inactive or abandoned, monitoring should be suspended or BIMS will report missing data). Second, in order to stop erroneous violations that are reported from BIMS, you need to suspend monitoring for any well you don’t want a report from. If BIMS is reporting correctly, as far as I know, staff should be entering an “Action Code” to explain if they are taking action or why they are not (See DWQ policy attached). Although, in talking with Vanessa Manuel and finding out that groundwater data is not exported to EPA, it is still subject to EPA review. And finally, please let us know if you have verified monitoring data was received on time, but BIMS is reporting it late. According to most permits, permittees have 30 days to send in their data after the month of sampling. The Information Management staff have 60 days according to BIMS staff to key it in, and then BIMS runs the violations report 20 days after the 60 day entry time (essentially 80 days after the permit’s deadline). Although the Information Management have been doing a pretty good job to get data in on time, if this is an issue for your Region, please let us know and we can discuss with Info Mgmt staff to see if we need to change the BIMS timing on data entry. Well, that’s all I have. Please let me know if you have any questions or concerns. Or you can contact Betty Wilcox as well. Thanks everyone! Debra J. Watts, Supervisor Groundwater Protection Branch Water Quality Regional Operations Section 919-807-6338 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation.
From: Wilcox, Betty Sent: Wednesday, January 15, 2014 4:02 PM To: Watts, Debra Cc: Wilcox, Betty Subject: RE: Late/Missing GW59 ? Violation Action - None
Debra, I have included an updated spreadsheet (NPDES Permits with Wells2) in the attached workbook that includes additional NPDES permits and their status for facilities included in your hard copy historical list. Those facilities that are in bold did not report GW59 data in BIMS for the period 2011-2013. The spreadsheet has been updated with BIMS well/permit status information for all the NPDES facilities listed. I compared the list with your hard copy historical list provided; the attachment contains some additional newer facilities. Betty --Betty Wilcox Environmental Chemist Division of Water Resources Water Quality Regional Operations Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone: (919) 807-6348 Fax: (919) 807-6496 E-mail address: [email protected] E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Wilcox, Betty Sent: Tuesday, January 14, 2014 12:53 PM To: Watts, Debra Cc: Wilcox, Betty Subject: RE: Late/Missing GW59 ? Violation Action - None
Debra, Attached is the workbook with RRO and WaRO corrections on the spreadsheets. --Betty Wilcox Environmental Chemist Division of Water Resources Water Quality Regional Operations Section 1636 Mail Service Center Raleigh, NC 27699-1636
Phone: (919) 807-6348 Fax: (919) 807-6496 E-mail address: [email protected] E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Wilcox, Betty Sent: Tuesday, January 14, 2014 9:08 AM To: Watts, Debra Cc: Wilcox, Betty Subject: FW: Late/Missing GW59 ? Violation Action - None Importance: High
Corrections made to forwarded message. --Betty Wilcox Environmental Chemist Division of Water Resources Water Quality Regional Operations Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone: (919) 807-6348 Fax: (919) 807-6496 E-mail address: [email protected] E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Wilcox, Betty Sent: Tuesday, January 14, 2014 8:58 AM To: Watts, Debra Cc: Wilcox, Betty Subject: RE: Late/Missing GW59 ? Violation Action - None
Debra, I have attached a workbook with data extracted from BIMS (and modified) that contains a list of NPDES facilities that have reported GW59 well data between 2011 and 2013. Sheet 1 contains the list of facilities reporting data including the month the data was submitted: “NPDES Permits-GW59s 2011-2013” Sheet 2 is an abbreviated list from Sheet 1 that contains the permit numbers and facilities sorted by region: “NPDES Permits with Wells2” I also evaluated a sample of BIMS reports (specifically reports for the 14 coal ash facilities) to examine violations related to “Late/Missing Data” and “Missing Well or Missing Parameter”. My findings/comments include the following:
2011 Required GW59 reports for three times/year sampling were entered within 1 month of report received date, and no violations for “Late/Missing GW59s” for nearly all 14 coal ash facilities with the following exceptions: · Required GW59 reports for three times/year sampling were entered 2 or more months after the report received date for 3 facilities but no “Late/Missing GW59” violations were generated. Multiple “Late/Missing GW59” or “Missing Well or Missing Parameter” violations were listed for 1 facility, Roxboro, that had two wells still in BIMS from a previous permit version that pre-dated the current groundwater monitoring plans. · BIMS reported “Missing Well or Missing Parameter” violations at least once for 5 of the 14 facilities during 2011 but the GW59s were reported in BIMS as received on time, and no “Late/Missing GW59” violations were generated. This can occur if a GW59 is received on time, but all parameters or wells are not reported or all parameters or wells are not entered by the time BIMS runs the violations report. · Some reports for samples collected prior to the current approved groundwater monitoring plan schedule in BIMS were listed as “Late/Missing GW59”. 2012 Required GW59 reports for three times/year sampling were entered within 1 month of report received date, and no violations for “Late/Missing GW59s” for nearly all 14 coal ash facilities with the following exceptions: · Required GW59 reports for three times/year sampling were entered 2 or more months after the report received date for 3 facilities but no “Late/Missing GW59” violations were generated. Multiple “Late/Missing GW59” or “Missing Well or Missing Parameter” violations were listed for 1 facility, Roxboro, that had two wells still in BIMS from a previous permit version that pre-dated the current groundwater monitoring plans. · BIMS reported “Missing Well or Missing Parameter” violations at least once for 4 of the 14 facilities during 2012 but the GW59s were reported in BIMS as received on time and no “Late/Missing GW59” violations were generated. 2013 Required GW59 reports for three times/year sampling were entered within 1 month of report received date, and no violations for “Late/Missing GW59s” for all 14 coal ash facilities with the following exceptions: · Multiple “Late/Missing GW59” or “Missing Well or Missing Parameter” violations were listed for 1 facility, Roxboro, that had two wells still in BIMS from a previous permit version that pre-dated the current groundwater monitoring plans. · BIMS reported “Missing Well or Missing Parameter” violations at least once for 5 of the 14 facilities during 2013 but the GW59s were reported in BIMS as received on time and no “Late/Missing GW59” violations were generated. · Summary BIMS allows a grace period after the scheduled report due date to allow for data entry prior to running a scan for violations. Depending on the grace period, no “Late/Missing GW59” violation will
be generated if the report is submitted and logged into BIMS as received within that period. Even though no “Late/Missing GW59” violation is generated for a specific report, “Missing Well or Missing Parameter” violations are generated for the same report if data for all wells and all parameters has not been submitted and/or is not entered into BIMS before the violations scan is run. With the exception of Cliffside and Asheville, there were generally no “Action” codes or comments (such as “No Action, BPJ or “No Action, BIMS Calculation Error)listed in BIMS that addressed the reported violations. The status of the two wells in the Roxboro permit that pre-dated the current groundwater monitoring plans has been changed to “temporarily abandoned” in BIMS to prevent future “Late/Missing GW59” violations for that permit. According to Eric Rice in the RRO, John Toepfer reported that those two wells were installed after the ash pond was installed and are located on the slope of the ash pond within the compliance boundary. Please let me know if you need additional information. Betty --Betty Wilcox Environmental Chemist Division of Water Resources Water Quality Regional Operations Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone: (919) 807-6348 Fax: (919) 807-6496 E-mail address: [email protected] E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Watts, Debra Sent: Wednesday, January 08, 2014 3:58 PM To: Romanski, Autumn Cc: Zimmerman, Jay; Wilcox, Betty; Watts, Debra; Bolich, Rick; Smith, Danny Subject: FW: Late/Missing GW59 ? Violation Action - None
Autumn We did some follow up on your questions about the groundwater monitoring for the Roxboro Power Plant, and below is some information you may want to consider:
1.
When APS/CO first directed the Power Plants to put wells at their Compliance Boundary in 2010, it was directed state-wide, and the wells were put in BIMS by the former APS/CO staff. The entry of the wells in BIMS were not necessarily coordinated with when the wells were actually constructed or when they began sampling, and the monitoring plan actually changed quite a bit as we coordinated these actions with Progress Energy. This may have caused some of the issues you discussed and why BIMS reports missing data in 2011. My apologies! If you can tell us which wells you continue to have issues with, we can probably help you nail this down. 2. The CONV wells you found recorded under the Roxboro permit were wells in the system (BIMS) that we did not have any information on – they were transferred from the old Paradox system to BIMS and we did not know if they had been abandoned, etc., so we left them as is. As Betty told you in an earlier email, she went ahead and changed their status to temporarily abandoned in BIMS since we don’t require sampling from them in the permit and apparently they are causing BIMS to report violations. 3. Since late or missing data seemed to be a concern, we talked with Tom Moore with the BIMS IT staff and verified how the system works. Hopefully I can explain this since it’s pretty complicated. In the permit we give the permittee 30 days after the month of sampling to report the data. So, for example, if they sample in November, they have to report the data by the end of December. BIMS allows 60 days for data entry, so in this example they would have until the end of February to enter the data; a total of 90 days after being sampled. After the 90 days, BIMS runs an automatic report whether the data was received and if it has violations. If the data is entered after the 90 days allowed, BIMS will begin reporting if there are any violations, but will continue to report that it was late/missing. Betty is currently checking to see if the Regions are receiving late/missing reports for data received on time but is reported late due to late date entry. If so, we will talk with the data entry staff for resolution. 4. I believe you have a good point about staff not entering the resolution for the violations reported. After we finish our research, Jay wants me to address this with WQROS staff, specifically those NPDES permits that may have monitoring wells. I did check with Vanessa Manuel and our groundwater monitoring data is not electronically reported to EPA, although they are still subject to a file review by EPA. Either way, staff should be recording resolution for violations, and I don’t think most of the ash pond facilities have anything recorded. That’s all I have for now. If you have further questions, it may be easier to give me a call and we can continue to discuss. Or stop by and we can continue to research together. My phone number is below. Thanks! Debra J. Watts, Supervisor Groundwater Protection Branch Water Quality Regional Operations Section 919-807-6338
From: Wilcox, Betty Sent: Tuesday, January 07, 2014 3:33 PM To: Romanski, Autumn Cc: Watts, Debra; Wilcox, Betty Subject: FW: Late/Missing GW59 ? Violation Action - None
Autumn, I passed along the information we discussed this morning regarding the Roxboro plant and lack of listed violation actions in BIMS for EPA reports to Debra Watts, Groundwater Protection Branch Supervisor. Late/Missing violations in BIMS due to late data entry for data that has been received, but not entered by the deadline, can be addressed by entering the appropriate comment-code in the “Action” and comments column on the Violations screen. Legitimate missing/late reports will not require a code. I have also changed the status of the two wells you referenced as ”Missing Well” to “temporarily abandoned”, with a retroactive monitoring suspension date of 1/1/2011 in the current expired permit and the permit in review. I’m not sure that BIMS will reevaluate the violations based on a retroactive monitoring suspension date; however future “Missing Well” violations for those two wells should be prevented. I will check BIMS tomorrow to see if the violations have changed retroactively. Please let me know if I can be of further assistance regarding these issues. Betty --Betty Wilcox Environmental Chemist Division of Water Resources Water Quality Regional Operations Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone: (919) 807-6348 Fax: (919) 807-6496 E-mail address: [email protected] E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.
From: Watts, Debra Sent: Monday, January 06, 2014 3:08 PM To: Romanski, Autumn Cc: Hennessy, John; Poupart, Jeff; Scott, Michele; Manuel, Vanessa; Wilcox, Betty; Rice, Eric; Bolich, Rick; Watts, Debra Subject: RE: Late/Missing GW59 ? Violation Action - None
Hi Autumn Not sure what permit you are referring to – the Progress Cape Fear Power Plant is NC0003433 and the Progress Roxboro Power Plant is NC0003425. Either way, our staff monitor both of these closely due to the highly sensitive nature of coal plants these days. Staff involved include Betty Wilcox at the Central office and Eric Rice at the Raleigh Regional Office. I will copy Betty Wilcox on this message and have her get back with you. You may also want to talk to Eric. Thanks! Debra Watts From: Manuel, Vanessa Sent: Monday, January 06, 2014 2:38 PM To: Romanski, Autumn Cc: Barnhardt, Art; Hennessy, John; Poupart, Jeff; Scott, Michele; Watts, Debra Subject: RE: Late/Missing GW59 ? Violation Action - None
Autumn, I followed up with Jeff, and you should speak with Debra Watts regarding the GW monitoring issue. VEM From: Manuel, Vanessa Sent: Monday, January 06, 2014 2:00 PM To: Romanski, Autumn Cc: Barnhardt, Art; Hennessy, John; Poupart, Jeff; Scott, Michele Subject: RE: Late/Missing GW59 ? Violation Action - None
Autumn, I’m not sure who reviews the violations associated with the GW monitoring. Since this is a compliance/enforcement issue, I’ve copied John who may be able to provide some information on your question. My recommendation is to touch base with someone in the GW group. You may also want to touch base with Michele, to see if her group enters this data into BIMS … I’m not sure who inputs the data into BIMS. Sorry, I’m not much help on this issue. Vanessa From: Romanski, Autumn Sent: Monday, January 06, 2014 1:10 PM To: Manuel, Vanessa Cc: Barnhardt, Art Subject: Late/Missing GW59 ? Violation Action - None
Hi Vanessa,
I was recently reviewing the BIMs data for an inspection at Roxboro Power Plant NC0003433. Groundwater monitoring is required in the wastewater permit Condition A.9. In reviewing this data, it shows late missing GW-59 reports Jan,Feb,March-2011, the sampling started in April 2011. Late missing GW-59 also show for May, June, August, Sept, Oct, Nov 2011-the frequency for reporting is for March June and October (ONLY Months required)since April 2011 to present. See same pattern thru 2012 and 2013 with late missing GW reports. Do you check these? or is this done by someone in GW at the central office? I think we need to understand if there is a better way to set this up in BIMS so doesn’t record a late missing GW-59 in error. I copied Art – in case he knows. Art, there is also a well missing (2011-2013) data in BIMS (but has odd identifier) CONV004023 and 4397. Can this be removed or is the facility not reporting? Just like to clean up BIMs data and confirming for the permit condition that GW monitoring plan at Roxboro is being followed as required. Thank you both for your time and let me know if these questions need to go to someone else. Sincerely,
Autumn
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation.
