NCS000349_Fact sheet binder_20181205

Bennett, Bradley
From: Lawyer, Mike
Sent: Wednesday, December 05, 2018 1:50 PM
To: Bennett, Bradley
Cc: Lucas, Annette; Georgoulias, Bethany
Subject: RE: [External] Stormwater Draft Permit NCS000349
Bradley,
As discussed, my thoughts on their comment#2 is that they would continue with monthly monitoring for outfall#5 and
begin semi-annual monitoring for outfalls#7 and #9 upon issuance of the new permit.This was my intention with the
last sentence in the inspection summary of my compliance evaluation report although that may not have been clear to
them. Certainly, they would be able to revert back to semi-annual monitoring for outfall#S upon getting three
consecutive monitoring results meeting the benchmarks. Likewise, they would need to comply with the Tier Two
monthly monitoring conditions for outfalls#7 and #9 should there be consecutive exceedances of the benchmark values.
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
910 433-3394 office
mike.lawyer(gncdenr.gav
225 Green Street, Suite 714
Fayetteville, NC 28301
Enjail con-espordence to af;,d turn this address is sub}eci 10 the
North Carolina Public Records Law and may be disclosed to third parties.
From: Bennett, Bradley
Sent:Thursday, November 29, 2018 6:29 PM
To: Lawyer, Mike<[e-mail]>
Subject: FW: [External] Stormwater Draft Permit NCS000349
Mike,
My temp assignment has come to an end at this point, but I am still closing out a few things. I probably won't be in the
office but may be able to check email for the next few days as long as they still give me access. I think we can deal with
most of their commetns pretty easily except maybe #2. Send me an email with your thoughts and maybe I can go ahead
and make some adjustments and get the permit ready for staff to issue after the notice process is completed.
Thanks for all your help!
BB
1

From: Leona Miles <[e-mail]>
Sent:Thursday, November 29, 2018 5:59 PM
To: Bennett, Bradley<[e-mail]>; Lawyer, Mike<[e-mail]>
Cc: Carey Davis<[e-mail]>; [e-mail];
rhouser eorgiarenewablepower.com; [e-mail];
[e-mail];Janet Hart<[e-mail]>
Subject: [External] Stormwater Draft Permit NC5000349
External email. Do not ekck links'ot open attkhments uniess verified.Send aff suspicious email as an attachment to
Hello Bradley:
On behalf of North Carolina Renewanle Power—Lumberton LLC, AEM is submitting the attached response/comments on
the Draft Stormwater Permit (NC5000349) for the facility located at 1866 Hestertown Road, Lumberton, NC.
We appreciate the opportunity to provide this response.
Please do not hesitate to contact us if you have any questions.
Best Regards
Leona
Sent from my iPhone
2

Bennett, Bradley
From: Leona Miles <[e-mail]>
Sent: Thursday, November 29, 2018 5:59 PM
To: Bennett, Bradley; Lawyer, Mike
Cc: Carey Davis; [e-mail]; [e-mail];
[e-mail];[e-mail]; Janet Hart
Subject: [External] Stormwater Draft Permit NCS000349
Attachments: 18-214 Cover Letter-Stormwater Draft Permit Response.pdf
............. .
;CAUTI
i
..
Hello Bradley:
On behalf of North Carolina Renewanle Power—Lumberton LLC, AEM is submitting the attached response/comments on
the Draft Stormwater Permit (NCS000349)for the facility located at 1866 Hestertown Road, Lumberton, NC.
We appreciate the opportunity to provide this response.
Please do not hesitate to contact us if you have any questions.
Best Regards
Leona
Sent from my iPhone

Atlanta Environmental Management, Inc.
Fnvirom nextul Consulting, Fngineering,Hydrogceologic.Serwces
November 30, 2018
Mr. Bradley Bennett
North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
Stormwater Permitting Program
Water Quality Permitting Section
512 North Salisbury Street
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Re: Draft Stormwater NPDES Permit No. NCS000349
North Carolina Renewable Power--Lumberton, LLC
1866 Hestertown Road, Lumberton, North Carolina 28358
AEM Project No. 1507-1801
Dear Mr. Bennett:
On behalf of North Carolina Renewable Power—Lumberton, LLC (NCRP—Lumberton),
Atlanta Environmental Management, Inc. (AEM) is providing this letter in response to the Draft
Stormwater NPDES Permit that was submitted for review on October 30, 2018. We appreciate
the opportunity to respond. As it relates to the Draft Permit conditions provided, NCRP—
Lumberton has the following comments:
1. Section B, Page 8—Foot note Item No. 3 states that SDO #5 is representative of
outfalls #1 through #6 and #8. Outfall #8 is no longer present. This outfall was closed
out due to high traffic causing damage to the outfall. Additionally, regrading of the area
has occurred and storm water flow is toward Outfall #7.
2. Section B, Table 1—states that semiannual monitoring is to be conducted. Under the
previous permit, NCRP—Lumberton initially started with semiannual monitoring but due
to exceedances has been sampling under the Tier II protocol. Please provide
clarification regarding the sampling frequency to be conducted upon issuance of the
new permit. Does NCRP—Lumberton start with semiannual sampling and, if any
exceedances are identified, follow the protocol for Tiered response actions?
3. The previous permit noted that if pH values outside the benchmark range are recorded
in sampled stormwater discharges, but ambient rainfall data indicate that precipitation
pH levels are within +1- 0.1 standard units of the measured discharge values or lower,
then the lower threshold of the benchmark range would not apply. Readings from an
on-site or local rain gauge (or local precipitation data) must be documented to
demonstrate that background pH readings were below the benchmark pH range. Does
this exemption no longer apply as it is not provided in the current draft permit?
2580 Northeast Expressway Atlanta.Georgia 30345
'telephone. [phone] + Fax:[phone]

Mr. Bradley Bennett—NCDEQ Stormwater NPDES Permitting
November 30, 2018
Page 2
If you have any questions, please do not hesitate to contact us at [phone] or via
e-mail at [e-mail].
Sincerely,
Atlanta Environmental Management, Inc.
Leona Miles, CHMM
Senior Project Manager �r^
Janet T. Hart
President
Ikrf
cc: Carey Davis (North Carolina Renewable Power) via e-mail
Ciaran McManus (North Carolina Renewable Power) via e-mail
Rick House (North Carolina Renewable Power) via e-mail
Art Picken (AEM) via e-mail
Attachment
-----_
18-214;COVER LETTER

A., . .
Stormwater Discharge Permits
Affidavit of Publication
STATE OF NORTH NC DIV. OF ENERGY, MINERAL AND LAND RESOURCES'INTENT
CAROLINA) SS DISCHARGE A STOR PERMIMWATER
COUNTY OF ROBESON ) Public comment or objection to the draft permit is invited.Submit written comments
to DE MLR at the address
below.All comments received through December 4, 2018 will be considered in the
final determination regarding permit issuance and permit provisions.
Tammy Oxendine, being duly sworn, Says: Application:NC Renewable Power—Lumberton LLC, 1866 Hestertown Rd,
Lumberton, NC 28358 has applied for
That she is Legal Advertising Clerk of the The an NPDES permit renewal to discharge stormwater from an industrial facility at this
address in Robeson County.
Robesonian, a daily newspaper of general circulation, The facility discharges to a UT to Lumber River in the Lumber River Basin.
printed and published in Lumberton, Robeson County, Permit NCS000349.
North Carolina; that the publication, a copy of which is Stormwater Program Contact:
attached hereto, was published in the said newspaper on Annette Lucas
the following dates: [phone]
[e-mail]
November 03, 2018 A copy of the draft permit is available at: https:11bit.ly/2JSf51s.Additional permit
documents are available for the
reproduction cost at:
DEMLR Stormwater Program
512 N.Salisbury Street
1612 Mail Service Center
Raleigh, NC 27699-1612
That said newspaper was regularly issued and circulated
on those dates.
SIGNED: RECEIVED
1
NOV
Legal Advertising Clerk DENR-LAND QUALITY
Subscribed to and sworn o me this 5th day of November STORAWATER PERMITTINr
2018.
y
Clarissa Jackson, Notary Publi , obeson County, North
Carolina ``��,,,,,, //
My commission expires: July 23, 2021 *., ,SSA JAC�S�`'�
NOTARY 2
PUBLIC
22030914 00949308
Alexander, Laura ci3Oiti►�+���
190-North Carolina Division of Energy
1612 Mail Service Center
Raleigh, NC 27699-1612

Last updated 10130118
NC Division of Energy, Mineral and Land Resources
Review of Permit Renewal—NCS000349
NC Renewable Power-Lumberton
• SIC 4911—Electrical Services—Steam electric power generation.
• Monitoring—The facility has been monitoring for 13 priority metals(Ag,As, Be,Cd,Cr,Cu, Hg, Ni, Pb,Sb,Se,TI,Zn),
Al, B,COD,TSS,Sulfate,and pH. Previous permit did have tier system. 2014 application indicted that the facility had
not been operating since 2009 when the last permit was issued. So,data submitted with renewal may not have
been characteristic of the facility. Also appears that there have been major process changes at the facility that may
impact monitoring. Need to talk with Facility contacts—see discussion below.
o Reviewed data from 2011 through 2013 from renewal. Reported numbers were below benchmark level
with the exception of Cu,Zn. Again,these numbers were from a facility that was not operating. Also
looked at DMR data in files and in Laserfiche through 2017. Metals numbers above benchmark on occasion
as well as TSS and COD, largely exceedances for Cu and Zn but a few others like Al.
o Reviewed online information related to poultry litter and wood ash. Found nutrients (N and P)are the main
issues for litter although some metals may be found as well. For wood ash the main parameters of concern
appear to be metals. The Pellet Fuels Institute(PFI)and ISO studies have established standards that include
the testing of eight metals(As,Cd,Cr,Cu,Pb,Hg,Ni and Zn). Wood ash can have higher concentrations of
metals as the burning process consolidates some components. The metals selected will provide
information if there are any contaminated wood sources. TSS and COD also valuable parameters where
wood and biomass material are onsite.
o Parameters proposed for the permit AI,As,Cd,Cr,Cu, Hg, Ni,Pb,Zn,COD,TSS,TP,TKN,Total Ammonia as
Nitrogen(TAN)and pH. Consider adding fecal coliform due to the poultry litter on site. Add fecal,also
Mike noticed Al not in draft and should be maintained since they continue to exceed.
o Tier structure adjusted to have the three levels as in current permits.
o Parameter codes added to permit.
• Discussed site issues with Mike Lawyer(FRO)6/13/2018. Mike confirmed that the facility has restarted and their
processes have changed. The facility is no longer coal fired. They have changed to the use of wood along with some
poultry litter. Mike noted that at one point during Hurricane Matthew the facility was flooded and they had issues
with DEMLR and DWM on the ash materials onsite that lead to some changes. Recently they have been hauling to
landfills and to farms. Need to get more info from them on their process now with this. Also need to look at how
they are handling poultry litter onsite. Mike provided another facility contact—Rick Houser—to contact.
Email to Bill Huggins—6/12/18. 6/13/2018-Called Rick Houser(910)733-0275 and forwarded email to him so he
could get other Corporate staff involved in discussions. Other calls and emails to Rick,he wants corporate staff to
participate but they have not responded to our emails and calls. 7/12/18—return email from Mark Fowler with
corporate office in Birmingham. 7/17/18—call with Mark—some ongoing legal issues with appropriate contact,
owner name will still be NC Renewable Energy. Apparently have been some changes with their consultants. He did
indicate they have added a fuel yard and they have monitored the use of the poultry materials. Poultry materials
and wood are mainly under roof. It was unclear exactly what he meant but he indicated AQ had designated some of
the materials as a non-waste? The facility no longer uses coal and does not have any coal ash onsite. They do have
a wood ash material. Asked him for updates on site plan, monitoring,etc. Sent Mark an email with information
needed. Also sent info on rescinding their permits(SW and W W)for their Elizabethtown facility which has been
closed and they no longer have access to the site.
Conference call with Leona Miles and Art Picken—8/21/2018. Mike also participated in call. See page 2 for email
that summarizes call and gives information about site. Leona provided responses and extra documents in email on
9/13/18. Copies in file and in Laserfiche folder.
• Facility drains to LIT to Lumber River in the Lumber River Basin,a class C;Sw stream. 2016 Assessment Report 11-
13(e)shows no impairment of concern for this facility in this area.
• NC National Heritage review—NHP report shows no aquatic resources in the project area. In the one mile radius
around the facility there are three fish species noted, but there is insufficient information to establish the viability
and accuracy of data is not high. No Federally listed species.
• FRO— Mike has site visit scheduled for September 13th -cancelled due to storm. Sent email to Mike with
questions/issues to consider with site visit. Site Visit—Oct 1"-See summary of discussion with Mike after site visit
—page 3.

Cast updated 10130118
From: Bennett, Bradley
Sent:Wednesday,August 22, 2018 11:36 AM
To: 'Leona Miles'
Cc: '[e-mail]';'Mark Fowler GRP';'[e-mail]'; Lawyer, Mike
Subject: RE: [External] RE: Permit Renewal for NC5000349 Stormwater NPDES Permit
Attachments: NCS000349 Contacts Report.pdf
Leona,
Thanks to you and Art for talking with us yesterday about the Lumberton facility.The information you provided was very
helpful in our process. I just wanted to touch base after the call to make sure we are on track with the things discussed and
that we outline some things that we know we might need. Please correct anything that isn't accurate and let me know about
the process you see moving forward to get the information we might need.
• The facility has changed from a coal fired plant and the fuel used now is a combination of wood/biomass chips and
poultry litter.
• All coal products and materials(ash,etc.) have been removed from the site.
• Facility is still following the same process otherwise—steam electric power generation.
• The facility purchased additional land and expanded north of the previous site boundary.This area now contains the
wood/biomass that is brought in,wood chipping operation,driers,conveyors for the wood chips, storage barn for
dried chips and other equipment.This area all drains to a new pond that was constructed with the expansion.There
is a new outfall(#9)from the pond. In this northern area of the property there was an area in the Google views that
showed storage of a black material,some covered with a blue tarp. Could you please provide information on what
this storage is and what material is there.
• It would be helpful to have a new site map that shows the expanded area,gives information on the material on the
site, locates all outfalls and gives drainage boundaries for the outfalls. It is likely that we will need to reevaluate the
representative outfall status as we get a better understanding of the outfalls and drainage areas, etc.This will be
handled as part of the site visit conducted by our Fayetteville Regional Office.
• Poultry litter is brought in and stored in the storage building that was previously onsite(near the NE part of the ditch
that divides the old and new property).Wood chips go from storage after drying to warehouse(built over the old
coal storage) near the wastewater basins.Wood goes from here on conveyor and mixes with poultry litter and
mixture goes to the facility as fuel for the process.There is an accumulation of material (wood and poultry litter)
that falls off the conveyor between the two buildings near the ditch.This material is collected and put back into the
process. It would help to know how long material stays on the ground here,etc.
• In the southeastern section of the facility by the plant there is a silo that collects the ash produced in the process.
The ash is removed from the site by truck on a daily basis. is any ash stored anywhere else on site?It seems that
there is a good bit of ash produced and the one silo seems small for this collection?Could you provide information
on where the ash material is taken?
• In the past few years there were some issues with ash material stored on site and material was removed to offsite
locations. Mike asked about this process and if all that material had been removed from that site and taken care of.
There was an August 1,2018 date given in the past for completion of this process.
• If there has been any monitoring data collected from Outfall 9(discharge from the pond)can you please provide the
results of that monitoring.
• As we go through our review it is possible that monitoring locations may change with the changes on site and the
addition of the pond and new discharge for the northern portion of the site.We will also look at the activities now
on site and consider needed adjustments in the monitoring parameters given the changes.This may eliminate some
parameters and add others.
• 1 think there may be some ongoing questions about the facility name(Georgia vs NC Renewable Power). We will
need to have that worked out so we know the correct entity for issuance of the permit. We will have to have an
owner that is a registered NC Corporation.
• 1 have also attached the owner/Facility contact information that we have in our database. Please review that and
make any updates/corrections needed and tell us any contacts that need to be removed.
Hopefully I captured everything here. Mike—please add anything I missed. I tried to underline the things that involve
information we may need from you guys.
Thanks again for your help!
BB

Last updated 10130118
Discussion with Mike after site visit—10/10/18:
• Bottom ash is deposited into a three-sided concrete pit(located in site map). They use a front-end loader to move
material to tractor trailer to be hauled off to either Carolina Gypsum or Craven Ag Services. Appears that this area is
contained. Could be some exposure where they load onto the trailer for haul off, Mike discussed with them. They may
have some piles in that area when the trailer is filled.
• Northern portion of the site(N of ditch)all drains to the new pond. A lot of exposure of materials in this drainage area,
mainly wood chips and saw dust. They don't chip on site and don't use the saw dust regularly. They screen the material
and large pieces become rejects and are hauled off. Outfall 9 at the pond should be monitored to establish
characteristics.
• Outfall 5 continues to have exceedances and monitoring should continue.
• Area where poultry litter and biomass are merged on conveyor. There is spillage and material remains on ground for
some period of time. Area drains to Outfall 7. Outfall 8 appears to be closed off now as the yard grate is closed off.
Should monitor 7 to get a feel for the characteristics of discharge here. Some area of bottom ash goes to 7 but most
drains to outfall 1.
• Mike recommends monitoring for Outfalls 5, 7 and 9 and adding fecal monitoring. Outfall 5 is representative of 1-8
excluding 7. They could look at change to ROS in the future if warranted.
• Facility is revising site map to show drainage with catch basins and drainage patterns etc.
• Fly ash silo didn't show much residual material. Material loaded and hauled off regularly.
• No coal remaining on site. Material was removed and excavated.
• Mike also road by the Pembroke facility where the wood ash debris was taken. They are a little behind on this but making
progress.
• Mike noted that the draft permit should include Cu and Al and these parameters were not in the draft he reviewed. Also
noted the need to add reference in the permit to the three outfalls as representative.
• Send Leona form for owner affiliation change.—emailed link to online process 10/15/18.

STATE Ye.
/mac
ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secrefory
WILLIAM E,(TOBY)VINSON,JR.
Interim Direcfor
DATE: October 30,2018
TO: [The Robesonian
EMAIL. [E-MAIL)
FROM: Bradley Bennett,DIVISION OF ENERGY,MINERAL,AND LAND RESOURCES
SUBJECT: PUBLIC NOTICE
PAGES: 1
Please publish only the information(Public Notice)attached,ONE TIME in the legal section of your paper by Sunday,
November 4,2018.Please fax a copy of the proof to Bradley Bennett at(919) 807-6494 for final approval prior to
publication.Within 10 days after publish date,please send the invoice and two copies of the original affidavit to:
Bradley Bennett
NCDEQ/DEMLR
512 N.Salisbury St.
1612 Mail Service Center
Raleigh,NC 27699-1612
NC DIV.OF ENERGY,MINERAL AND LAND RESOURCES'INTENT TO ISSUE A
STORMWATER DISCHARGE PERMIT
Public comment or objection to the draft permit is invited. Submit written comments to DEMLR at the address
below. All comments received through December 4,2018 will be considered in the final determination regarding
permit issuance and permit provisions.
Application: NC Renewable Power- Lumberton LLC, 1866 Hestertown Rd,Lumberton,NC 28358 has applied for
an NPDES permit renewal to discharge stormwater from an industrial facility at this address in Robeson County.
The facility discharges to a UT to Lumber River in the Lumber River Basin. Permit NCS000349.
Stormwater Program Contact:Annette Lucas
[phone]
[e-mail]
A copy of the draft permit is available at: https://bit.ly/2jSfS1s. Additional permit documents are available for the
reproduction cost at:
DEMLR Stormwater Program
512 N.Salishury Street
1612 Mail Service Center
Raleigh,NC 27699-1612
�QEQ��
ti'[���S�btt'������y�1 '1�V
REgGnMlM RI�v�M11n1esetW puyity
North Carolina Department of Environmental Quality ; Division of Energy,Mineral and Land Resources
512 North Salisbury Street 11612 Mail Service Center Paleigh.North Carolina 27699-1612
919.707.9200

W Gd SCg1�-
jc 60 g 0 ga G
C&036os'(.o
C 613ocs 'I
58
5`?
79
r r ,ham a,susP'O/ 0 �,
am^ /r
/} 1Cj d srir tZAV4 cLPS, S-&4V 4vs/7' IV/ ry
(Jv^a^ u 4LW .� fir FEIV9 ''
O..�j
�7 DIA�LA E atJ 4i-e-W ttVZ4.
cve Y. Dmd rs }a r7. 1 ! t rP f C At �.
pvj q J7
t,w S 4l-e4
C-> MA� Y-Zi- - 7,
GLtld
[ LN e(�► r aCIGSs I �j� (u7

/0� � SV'LO- zk�Ivj SU
rctoL4 , .
aL
c)
_ d Sri 1IxG�s dr,t;�. I54 ,�.
l ,� r c&(smJ tr�*ao3 arc c yr

Compliance Inspection Report
Permit: NCS000349 Effective: 11/01/09 Expiration: 10/31/14 Owner: North Carolina Renewable Power-Lumberton
LLC
SOC: Effective: Expiration: Facility: North Carolina Renewable Power Lumberton,LLC
County: Robeson 1866 Hestertown Rd
Region: Fayetteville
Lumberton NC 28358
Contact Person: Steven R Ingle Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
On-site representative Tim Cotner 910-887-6313
On-site representative Leona Miles 404-329-9006
On-site representative Art Picken 404-329-9006
On-site representative Bill Huggins 910-887-6313
Related Permits:
Inspection Date: 10/09/2018 Entry Time: 09:05AM Exit Time: 01:35PM
Primary Inspector: Mike Lawyer Phone: [phone] Ext.729
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge,Individual
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page: 1

Permit: NCS000349 owner-Facility:North Carolina Renewable Power-Lumberton LLC
Inspection Date: 1 010 912 0 1 8 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspection conducted as part of the permit renewal process. Reviewed information provided for renewal including changes to
facility operations from using coal to wood chips and poultry litter along with revised site map. Facility's Stormwater Pollution
Prevention Plan is complete and well-organized and has been reviewed and updated as necessary. Monitoring has been
conducted in accordance with permit requirements at stormwater outfall#5,which has Representative Outfall Status as
documented in the current/expired permit. Facility has been in Tier Two monthly monitoring due to consecutive exceedances
of the benchmark values for aluminum,copper and zinc. Based on existing monitoring records,current facility operations
and site observations made during the inspection, it is recommended that existing stormwater outfall#7 and new stormwater
outfall#9(retention pond)begin to be monitored on a semi-annual schedule upon permit renewal and stormwater outfall#5
continue to be monitored monthly.
Page: 2

Permit: NCS000349 Owner-Facility:North Carolina Renewable Power-Lumberton LLC
Inspection Date: 10/09/2018 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? 0 ❑ ❑ ❑
#Does the Plan include a General Location(LISGS)map? 0 ❑ ❑ ❑
#Does the Plan include a"Narrative Description of Practices"? 0 ❑ ❑ ❑
#Does the Plan include a detailed site map including outfall locations and drainage areas? E ❑ ❑ ❑
#Does the Plan include a list of significant spills occurring during the past 3 years? E ❑ ❑ ❑
#Has the facility evaluated feasible alternatives to current practices? 0 ❑ ❑ ❑
#Does the facility provide all necessary secondary containment? 0 ❑ ❑ ❑
#Does the Plan include a BMP summary? 0 ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan(SPRP)? 0 ❑ ❑ ❑
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? 0 ❑ ❑ ❑
#Does the facility provide and document Employee Training? 0 ❑ ❑ ❑
#Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑
#Is the Plan reviewed and updated annually? N ❑ ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑
Comment:
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment:
Permit and Outfalls Yes No NA NE
#Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
#Were all outfalis observed during the inspection? N ❑ ❑ ❑
#If the facility has representative outfall status,is it properly documented by the Division? 0 ❑ ❑ ❑
#Has the facility evaluated all illicit(non stormwater)discharges? 0 ❑ ❑ ❑
Comment:
Page: 3

/
� Fn<N,n ppq nMnnlpn orxe.s,neaea
\\ m \�
o e
ti e i
VZY Wootl Storage �.\
_—_— ---
l �11 ones-x I / l
I
un�ama�nP<tl wxr.wxet n<.tm�rennd,ne 1 tir IO 2 g � /
PrnPcnv I 4Vazle Water Pontl AVVLTRY §� /
LITTER
To"GE
II hVIL01NG
5 APProamure a<a el Fv.mer i —� ^
l �Buk Causlk/Adtl VnbMiN . .
11`I ar.r6pnrk' p au�nall i [
�yl Tr� aPno�h
I I �I�lora.e e p �
' wnwadPn m �
�•� � �,s MeltP.s<
r � �
LEGEND
-ApproarmareFrncea sae 9erinyry Q.Oind Asry ©.lnneim lFmpryl �. Canlprl Tower Trantln Wraps� SMxe WPieribw Pirarawn e Eat_
n.MOM Grolin,0.<n<waWe Oo..<rWml<non,to[snetwtv IE46nen<nown Woad
�-armnaer �.ranawx 1p.aateA.AaYsa.[xmn,uP.s � �wna.na w Fi:.rn
-Po4Aawnled n.r.la•wrw �.Wnt.xwnralPnlnA axY �./h.AaA Sdo l..e lmn _ .. R tl.. -. -_ Suhjeet PaP�Rrty$kltCA ^

� — 3q,
3 - 3�1, 3 s. a J ��', 5 9, 5 6)
L1 -, 3 t, 3s. �� / 7 . 59.
5 — 3q,35 az
3, 35, a 3 1 ?8, 5 7, W yy
3y, S, . -�6 / 79, 57, y'q
q - 3y.35.3 7/ ��?"5c�. 5ilf

1
8121l2018 � r i yy�SW S 7 1866 Hestertown Rd-G gle Maps y _ ] G �'T�}m �5 ;7►�e��tfi
(�'��C] �\- V ,,l ,S 1 +�cif` U rcrrs� �i•� G!%+ G Iti 1 1� W, G�o�V�. J ,
Go gle Maps 1866 Hestertown Rd R ;� Q� og
l
41
- ".
M ! - VsF"
F
k
r
9d�
€magery®2018 DigilalGlohe,USDA Fans Service Agency,Map data®2018 Goog€e 100 Q
L COt rLi r i
AA [c`Lev\ � W
C�P
P,
a WCrl� �u� s k �y'U��� �z1a7� �� �• [yyi/z'yd r
C. �Li� rL owed
CA
https://www.goog le.com/mapstplace/1866+Hestertown+Rd,+Lumberton,+NC+28358!@34.5927112,-78.9953998,466m/data=!3m 1!1 e3!4m5!3m4!1 sOx89aae7Oc4faa2c69:Oxcbfedda3Oe@3227O!8m2!3d34.5917621!z

5 _fir '•^�'�
8/21/2018 1866 Hestertown Rd-Google Maps �''�Y �f �! "
Go gle Maps 1866 stertown Rd �}�+� �'}}I ) G
T: 1
1
0
A � .
� _ l
1R
n ` imagery C2018 0ignalGlnl e.Map data 02018 Guogle 50 R
)Our �` 5� n� 5; t3 t�� CFI 4k4� t',w` vri 4 .TL+ -6drl1 A,'+.
6t �xs� ,� '1'y �� �' 6tS^
� �
https://www.goog!e.com/maps/p!ace/1866+Heste rtown+Rd,+Lumberton,+N C+28358/@ 34.5904833,-78.9957994,233mldata=!3m 1!1 e3!4 m5!3m4!1 sOx89aae70c4faa2c69:0xcbfedda30ea32270!8m2!3d 34.5917621!i

9/13/2018 [e-mail]
Re:[External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
Leona Miles <[e-mail]>
Thu 9/13/2018 11:32 AM
To:Bennett, Bradley <[e-mail]>;Lawyer,Mike <[e-mail]>;
cc:'Dan Sherman' <fisherman@georgiarenewable power.com>;'Rick Houser' <[e-mail]>;'Mark Fowler GRP'
<mfowler@georgia renewable power.com>;'Art Picken' <[e-mail]>;
U 2 attachments(602 KB)
Lumberton Site Plan.pdf; Revised Contact List.pdf;
CAUTION: External email, Do not click links or open attachments unless verified.Send all suspicious email as an attachment tc Report Spam.
Hello Bradley and Mike:
Below please find responses to questions you raised regarding the North Carolina Renewable Power, Lumberton LLC facility and
stormwater permit renewal application. I hope this information is helpful as an initial start to the renewal process. We can discuss
any additional questions once we meet at the site in the near future.
In addition,there was a question regarding aboveground black piping observed on a Google Earth aerial. The Black Pipes on the
West side of the Waste Water Treatment Plant as shown on the Google Earth Aerial are the hot water feed and recovery pipes to
and from the belt dryers.
Also provided are an updated site figure and facility contact list.
I hope you are both safe and ready for Florence. Take care.
Thank you,
Leona
LeO-Y r Ma", CifMM
Senior Project Manager
Atlanta Environmental Management, Inc.
2580 Northeast Expressway, NE
Atlanta, Georgia 30345
office: [phone]
Cell: [phone]
[e-mail]
www.AEM-net.com
^,��� pnnive�sar
^1km��cst�s
[h..�Y F:�rrrir�rnl[�p1�r+talwr"
https:/Ioutlook.office365.com/owa/?realm=nc.gov&path-lmaii/inbox 1113

9/13/2018 [e-mail]
From: Bennett, Bradley<bradley.bennettPncdenr.gov>
Sent:Wednesday,August 22, 2018 11:36 AM
To: Leona Miles<[e-mail]>
Cc: [e-mail]; Mark Fowler GRP<[e-mail]>; [e-mail];
Lawyer, Mike<[e-mail]>
Subject: RE: [External] RE: Permit Renewal for NCS000349 Stoomwater NPDES Permit
Leona,
Thanks to you and Art for talking with us yesterday about the Lumberton facility. The information you provided was very helpful in
our process. I just wanted to touch base after the call to make sure we are on track with the things discussed and that we outline
some things that we know we might need. Please correct anything that isn't accurate and let me know about the process you see
moving forward to get the information we might need.
• The facility has changed from a coal fired plant and the fuel used now is a combination of wood/biomass chips and poultry
litter. Yes, this plant no longer uses coal. The fuel source mixture is approximately 70%wood and 30%poultry litter.
• All coal products and materials(ash, etc.) have been removed from the site. The former coal piles and coal ash were
removed from the site in 2016 and are no longer present.
• Facility is still following the same process otherwise—steam electric power generation. The facility still produces steam
electric power.
• The facility purchased additional land and expanded north of the previous site boundary. This area now contains the
wood/biomass that is brought in,wood chipping operation, driers,conveyors for the wood chips, storage barn for dried chips
and other equipment. This area all drains to a new pond that was constructed with the expansion. Please see the attached
figure which shows the stormwater flow to all outfalls at the Plant, including the new outfall (Outfall #9). There is a new
outfall (#9)from the pond. In this northern area of the property there was an area in the Google views that showed storage
of a black material, some covered with a blue tarp. Could you please provide information on what this storage is and what
material is there. The material seen beneath the "blue tarp" in the 2017 google earth aerial was a one time storage of wood
ash from facility operations. The material was placed there following a temporary shutdown. The material was removed and
disposed offsite to Craven AG Services, Carolina Gypsum, or Sampson County Landfill.
• it would be helpful to have a new site map that shows the expanded area,-gives information on the material on the site,
locates all outfalls and gives drainage boundaries for the outfalls. It is likely that we will need to re-evaluate the
representative outfall status as we get a better understanding of the outfalls and drainage areas, etc. This will be handled as
part of the site visit conducted by our Fayetteville Regional Office. Please see the attached figure showing the overall site
drainage and stormwater outfalls.
• Poultry litter is brought in and stored in the storage building that was previously onsite (near the NE part of the ditch that
divides the old and new property). Wood chips go from storage after drying to warehouse (built over the old coal storage)
near the wastewater basins. Wood goes from here on conveyor and mixes with poultry litter and mixture goes to the facility
as fuel for the process. There is an accumulation of material (wood and poultry litter)that falls off the conveyor between the
two buildings near the ditch. This material is collected and put back into the process. It would help to know how long
material stays on the ground here, etc. Veolia, the facility manager, has a monthly PM schedule in place to clean up the fines
or large wood debris.
• In the southeastern section of the facility by the plant there is a silo that collects the ash produced in the process. The ash is
removed from the site by truck on a daily basis. Is any ash stored anywhere else on site? It seems that there is a good bit of
ash produced and the one silo seems small for this collection? Could you provide information on where the ash material is
taken?The wood ash is transported to Craven AG Services, Carolina Gypsum, or Sampson County Landfill. The fly ash is
currently stored in a silo and has several trucks removing the product on a daily basis. Bottom ash is emptied into a concrete
containment via the submerged and incline drag chains located on the north side of the power house.
• In the past few years there were some issues with ash material stored on site and material was removed to offsite locations.
Mike asked about this process and if all that material had been removed from that site and taken care of There was an
August 1, 2018 date given in the past for completion of this process. The Pembroke facility no longer receives the wood ash
from the Lumberton facility. The wood ash is disposed offsite to Craven AG Services, Carolina Gypsum, or Sampson County
Landfill. North Carolina Renewable Power, Lumberton LLC(NCRP-Lumberton) is in the process of conducting additional
cleanup of soil from previous stormwater runoff. This effort is anticipated to be completed by end of the year. NCRP-
Lumberton is working with Mr. Andrew Hammonds, NCDENR, to complete this effort.
• If there has been any monitoring data collected from Outfall 9 (discharge from the pond) can you please provide the results
of that monitoring. There has been no data collected to date from Outfall 9 as this portion of the facility is still under
https:lioutlook.offioe365.com/owal?realm=nc.gov&path=/maiUjnbox 2113

9/13/2018 [e-mail]
construction and monitored by the Stormwater Construction Permit. Visual observations are made as part of the
construction/ground disturbing storm water permit that was issued.
• As we go through our review it is possible that monitoring locations may change with the changes on site and the addition of
the pond and new discharge for the northern portion of the site. We will also look at the activities now on site and consider
needed adjustments in the monitoring parameters given the changes. This may eliminate some parameters and add others.
This is understood.
• I think there may be some ongoing questions about the facility name(Georgia vs NC Renewable Power). We will need to
have that worked out so we know the correct entity for issuance of the permit. We will have to have an owner that is a
registered INC Corporation. The owner and operator of the property is North Carolina Renewable Power, Lumberton LLC.
Georgia Renewable Power is the parent company. Veolia is the current O&M Company that is in charge of the daily
operations and maintenance of the Plant.
• I have also attached the owner/Facility contact information that we have in our database. Please review that and make any
updates/corrections needed and tell us any contacts that need to be removed. A revised contact list is attached.
Hopefully I captured everything here. Mike—please add anything I missed. I tried to underline the things that involve information
we may need from you guys.
Thanks again for your help!
BB
From: Leona Miles [mailto:[e-mail]]
Sent: Monday,August 20, 2018 10:45 AM
To: Bennett, Bradley<bradley.bennett6Dncdenr.gov>
Subject: RE: [External] RE: Permit Renewal for NCS000349 5tromwater NPDES Permit
CAUTION: External email. Do not click links or open aitachrrnents unless verified.send all suspicious email as an attachment to Re ar Uoam.
Hi Bradley
Would 2pm Tuesday work? We can tali you if that time is good.
Thanks
Leona
LeO�Mom; CHMM
Senior Project Manager
Atlanta Environmental Management, Inc.
2580 Northeast Expressway, NE
Atlanta, Georgia 30345
Office: [phone]
Cell: [phone]
[e-mail]
www.AEM-net.com
f �rai�
J
. �.
J J
"i'r+aR Muir[«
liniiy6 4..�Kiireinl Imli�mroiafxw+-
From: Bennett, Bradley<karadley.bennett@ncdenngov>
Sent: Monday,August 20, 2018 10:27 AM
To: Leona Miles<[e-mail]>
Subject: RE: [External] RE: Permit Renewal for NC5000349 Stromwater NPDES Permit
https:Iloutlook.offce365.com/owa/?realm=nc.gov&path=/maiIiinbox 3/13

9/13/2018 [e-mail]
Leona,
Sorry I'm just responding. I was out all last week, Anyway, I am in the office today and all day on Tuesday and Wednesday. Today I
could be available at 2:00, On Tuesday I'm available 1:00 through 4:00 and Wednesday I'm available all day.
Let me know what might work for you.
Thanks
BB
From: Leona Miles [mailto:[e-mail]]
Sent:Tuesday,August 14, 2018 2:53 PM
To: Bennett, Bradley<brad ley,[e-mail]>
Subject: Re: [External) RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
CAUTION: External email.Do not click links or open attachments unless verified.Send all suspicious email as an attachment to$gp2tUnam.
Hi Bradley
So sorry for the late response. Are you available on Monday,August 20th? I am available anytime from 7am til 3pm.
Thanks
Leona
Sent from my iPhone
On Aug 4, 2018,at 11:05 AM, Bennett, Bradley<brad I ey.bennett@ ncden r.gov>wrote:
Ms. Miles,
Thanks for getting in touch. What we really need as we start the renewal process is to have a better
feel far the operational changes at the facility. From some discussions we have had it is apparent that
the facility has switch from coal to other fuel sources and we would like to talk about the new set up,
materials that have changed, etc. After those discussions there may be additional information needed
to help with the renewal process. There are a couple of emails in this chain that have a brief
description of some areas we are interested in at this point. The information we have in house at this
point is the renewal application that came in back in 2014. There appear to be some major changes
since that time so a good bit if the information we have may need to be updated.
I work part time and I'm usually in the office Monday-Wednesday, If you are available to talk this week
let me know the day/time that works the best for you.
Thanks
Bradley Bennett Note New Ofce Phone
Stormwater Program Phone: [phone]
NC Division of Energy,Mineral&Land Resources Fax: [phone]
1612 Mail Service Center Email:brad [e-mail]
Raleigh,NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
https://outlook.office365.com/owa/?realm=nc.gov&path=/mail/inbox 4/13

9113/2018 [e-mail]
From: Leona Miles<[e-mail]>
Sent: Friday,August 3, 2018 1:21 PM
To: Bennett, Bradley
Subject: FW: (External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
iAUTION: External email. Do not click links or open attachments unless veriheo.Send all suspicious entail as an attachment to
Report Spam.
Hello Mr. Bennett
am working with GRP Lumberton regarding the renewal of Stormwater NPDES Permit NCS000349.
I am out of the office next week, but can be available by phone or email. I am not sure where in the process
we are with the renewal or what information you have received. Would you please give me a call on my cell
phone, [phone], to discuss what you need in order to process the renewal application.
Thank you,
Leona
Le,o,y c Maey, CIfMM
Senior Project Manager
Atlanta Environmental Management, Inc.
2580 Northeast Expressway, NE
Atlanta, Georgia 30345
Office: [phone]
Cell: [phone]
[e-mail]
www.AEM-net.com
<image001.jpg>
From: Mark Fowler GRP <[e-mail]>
Sent: Tuesday,July 31, 2018 12:07 PM
To: Leona Miles <[e-mail]>
https://outlook.office365.comiowa/?realm=nc.gov&path=/mail/inbox 5/13

9/13/201 B [e-mail]
Cc: 'Art Picken' <[e-mail]>; Rick Houser<[e-mail]>
Subject: FW: [External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
Here is correspondence with Mr. Bennett.
Thanks,
Mark
From: Bennett, Bradley [mailto:[e-mail]]
Sent: Wednesday,July 18, 2018 2:40 PM
To: Mark Fowler GRP<[e-mail]>
Subject: RE: [External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
Mr. Fowler,
Thanks for talking with me yesterday about your Lumberton facility. I hope you got the information I
forwarded about the process for rescinding permits for the Elizbethtown facility.
Please let me know when you and other appropriate staff can have a conference call to discuss changes to
the Lumberton site and how they might impact the permit renewal. Some areas for discussion are noted
below.
• I have attached a printout of contacts we have in our database for the facility. Can you please review
this and let me know if there are changes to contacts and if the owner/facility information is still
accurate?
• Federal regulations changed in the last few years to require electronic reporting of data. We are not
yet at the stage of being able to collect stormwater data this way, but we will have to work to get
accurate outfall location information in our system in order to meet federal requirements for
electronic reporting when our systems can handle the data. If you could provide the lat/long
coordinates for your facility's outfall points that would be helpful.
• If you can provide a summary of monitoring information since your application submittal in April 2014
that would be help as well.
• I am very interested in changes that have occurred in your facility and facility processes since your
application submittal. These will have an impact on pollutants discharged in stormwater runoff. It
appears that the facility may have been closed for a while but is reopened and using different fuel
sources, etc. Descriptions of these changes will be needed to help us in our review.
• With the changes a new site map showing the most up to date layout of activities, outfalls and
drainage will be needed. Looking at the google map of your site it appears that there are some
expanded areas from the site map that was submitted in the 2014 applications. That site plan was
dated 2010.
https:/Ioutlook.offce365.com/owa/?realm=nc,gov&path=/mail/inbox 6113

9/13/2018 [e-mail]
Next week I will be in the office Monday, Tuesday and Wednesday. Maybe we can schedule a day and time
for a call.
Thanks for your help.
Bradley Bennett
Stormwater Program
NC Division of Energy,Mineral&Land Resources Phone: [phone]
512 N.Salisbury Street Fax: [phone]
1612 Mail Service Center Email:bradley.benneft@ncdenr,gQv
Raleigh, NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
From: Bennett, Bradley
Sent:Tuesday,July 17, 2018 10:53 AM
To: Mark Fowler GRP<[e-mail]>
Subject: RE: [External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
HI Mr. Fowler,
Just wanted to touch base and see when you were available to talk about your facility in Lumberton?
also have some questions about a facility for NC Renewable Energy in Elizabethtown NC. This one might be
closed? It needs to either have a permit renewal application submitted or have a request for rescission.
https:lioutlook.office365.com/owa/?realm=nc.gov&path=/mail/inbox 7/13

9/13/2018 [e-mail]
Please let me know when you are available to talk. I will be in the office today and tomorrow and them out
until next Monday.
Thanks
BB
Bradley Bennett
Stormwater Program
NC Division of Energy,Mineral&band Resources Phone: [phone]
512 N,Salisbury Street Fax: [phone]
1612 Mail Service Center Email bradley.bennettftdlenr,gov
Raleigh,NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
From: Bennett, Bradley
Sent:Thursday,July 12, 2018 11.17 AM
To: Mark Fowler GRP <[e-mail]>
Subject: Re: [External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
Thanks for getting back with me. Next week I'll be in the office Monday through Wednesday. We can
set up a call any of those days that works for you and others that may need to be involved.
BB
Bradley Bennett
https:l/outlook.office365.com/owal?realm=nc.gov&path=/mail/inbox 8113

9/13/2018 [e-mail]
Stormwater Program Phone: [phone]
NC Division of Energy,Mineral&Land Resources Fax: [phone]
1612 Mail Service Center Email:[e-mail]
Raleigh,NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
From: Mark Fowler GRP <[e-mail]>
Sent: Wednesday,July 11, 2018 8:40 PM
To: Bennett, Bradley
Subject: [External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
CAUTION:External email. Do not click links or open attachments unless verified.Send all suspicious email as an attachment to
Report Spam.
Mr. Bennett,
I have been off, and then working in the field with no communication ability during the days, since the 4th. I
will be back in my office in Birmingham next week. Please let me know the best time to contact you.
Thank you,
Mark Fowler
From: Bennett, Bradley [mailto:bradley.bennettPncdenr,gov
Sent: Monday, July 02, 2018 2:42 PM
To: Mark Fowler GRP<[e-mail]>
Cc: [e-mail]; Rick Houser<[e-mail]>
Subject: FW: Permit Renewal for NCS000349 Stromwater NPDES Permit
Mr. Fowler,
https://outlook.office365.com/owa/?realm=nc.gov&path=/mail/inbox 9/13

9/13/2018 [e-mail]
1 wanted to touch base and try to set up a meeting to discuss renewal of the stormwater NPDES permit at
the NC Renewable Power facility in Lumberton. After talking with Rick Houser it appears that there have
been some changes at the facility over the last few years that will impact the permit. I think a call to discuss
these will help the process. Rick mentioned that it would be helpful to have you involved in this. If you look
at the original email I sent to William Huggins below you can see some of the items I'd like to discuss.
You can reach me at this email or at my office number—[phone].
1 work part time, my schedule this week is to be in the office today (July 2), tomorrow (July 3) and Thursday
(July 5).
Thanks for your help.
Bradley Bennett
Stormwater Program
NC Division of Energy,Mineral&Land Resources Phone: [phone]
512 N.Salisbury Street Fax: [phone]
1612 Mail Service Center Email:[e-mail]
Raleigh, NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
From: Bennett, Bradley
Sent: Monday, June 25, 2018 12:17 PM
To: 'rho use r@georgi are newablepower.com' <[e-mail]>
Subject: RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
Hi Mr. Houser. Just wanted to touch base and see if you guys have thought any about a day/time that we
could have a call about the permit renewal.
https:/Ioutlook.office365,com/awal?realm=nc.gov&path=/mail/inbox 10113

9/1 312 0 1 8 [e-mail]
Thanks
BB
From: Bennett, Bradley
Sent: Wednesday,June 13, 2018 3:13 PM
To: '[e-mail]' <[e-mail]>
Subject: FW: Permit Renewal for NCS000349 Stromwater NPDES Permit
Mr. Houser,
Thanks for talking with me today. Below is the email I sent to Mr. Huggins yesterday. As I mentioned, it
would be really helpful if we could have a conference call sometime early next week if that would work out
for you and others that need to be involved.
Thanks
BB
Bradley Bennett
Stormwater Program
NC Division of Energy,Mineral&Land Resources Phone: [phone]
512 N.Salisbury Street Fax: [phone]
1612 Mail Service Center Email:[e-mail]
Raleigh,NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
https://outlook.offce365.comlowaRrealm=nc.gov&path=lmaillinbox 11/13

9/1 312 0 1 8 [e-mail]
From: Bennett, Bradley
Sent: Tuesday, June 12, 2018 4:16 PM
To: 'wi Ilia [e-mail]' <[e-mail]>
Subject: Permit Renewal for NCS000349 Stromwater NPDES Permit
Hello, and first let me apologize for how long it has taken us to get going on your permit renewal. A number
of issues over the last few years have led to a backlog on renewal of our Individual permits. I would like to
set up a time where I can call and talk with you about the renewal. 1 will be working on this process. Since
the previous renewal application came in back in 2014 I'm guessing there may be some changes that we
should discuss and possibly have documented for the renewal. In addition, here are a few additional items
that would be helpful if you can provide updates:
• I have attached a printout of contacts we have in our database for the facility. Can you please review
this and let me know if there are changes to contacts and if the owner/facility information is still
accurate?
• Federal regulations changed in the last few years to require electronic reporting of data. We are not
yet at the stage of being able to collect stormwater data this way, but we will have to work to get
accurate outfall location information in our system in order to meet federal requirements for
electronic reporting when our systems can handle the data. If you could provide the lat/long
coordinates for your facility's outfall points that would be helpful.
• If you can provide a summary of monitoring information since your application submittal in April 2014
that would be help as well.
• I am very interested in any changes that may have occurred in your facility or processes since your
application submittal that could affect pollutants discharged in stormwater runoff. It appears that the
facility may have been closed for a while but is now reopened and may be using different fuel sources,
etc. Descriptions of any changes will be needed to help us in our review.
• If there have been changes, a new site map showing the most up to date layout of activities, outfalls
and drainage will be needed. Looks at the google map of your site it appears that there are some
expanded areas from the site map that was submitted in the 2014 applications. That site plan was
dated 2010.
1 work part time and I am generally in the office three days a week. I will be in the office tomorrow (June
13th) and then out the rest of the week. I'll be back in the office Monday—Wednesday of next week.
Maybe we can find a day/time that works over the next week to talk.
Thanks
Bradley Bennett
Stormwater Program
NC Division of Energy,Mineral&Land Resources Phone: [phone]
512 N.Salisbury Street Fax: [phone]
1612 Mail Service Center Email:brad [e-mail]
https://outlook.office365,com/owa/?realm=nc.gov&path=/mail/inbox 12/13

9/13/2018 [e-mail]
Raleigh,NC 27699-1612
Email correspondence to and from this address may be subject to public records taws
https://outlook.office365.com/owal?realm=nc.gov&path=/maiYinbox 13/13

8128/2018 Metals Testing Questions Answered I Biomassmagazine.com
LA
Metals Testing Questions Answered
In November 2017, the PFI Standards Program was updated to include the testing of the same metals that are
referenced in the international pellet specifications Published under ISO 17225-2, and referenced in wood pelt(­t.
quality certification schemes.
By Chris Wiberg I March 24,2018
In November 2017, the PH Standards Program was updated to
include the testing of metals.The minimum requirements are
to conduct a metals test at least annually, using a recently
published ISO test method(150 16968), and to test for eight
specific metals: arsenic,cadmium,chromium, copper, lead
mercury, nickel and zinc.These are the same metals that a�e
referenced in the international pellet specifications published T rJJ C,�J
under ISO 17225-2,and referenced in wood pellet quality
certification schemes ENpIus, CANp(us and DINptus. The new tt
metals testing provisions are being implemented in 2018, and
have resulted in many questions,including:Why test for these
specific metals?What are the baseline levels for these metals C
in wood?What type of instances could lead to a failure of the
metals testing, and why are we adopting ISO test methods?In
this column, I will try to answer these questions. Pejkf Fr 6�xJuL
The original list of metals and the test method itself was 9.1;6­2 �4�
developed by a European initiative to develop standards for Cu P b H5 N; ZA
solid biofuets, in the early 2000s.The European Committee for do . "
Standardization(CEN)created Technical Committee 335 to Wiberp,
spearhead this work, and as part of the initiative, two research
projects were funded(BioNorm I and BioNorm 11), to answer
technical questions about biomass and the appropriateness of
various testing methodologies available at that time.The
result was information that allowed technical experts to
develop specifications and test methods specific to solid biofuels.These were originally published as European
National(EN)standards between 2000 and 7008, but subsequently moved to ISO to allow for their development
into ISO standards,and to facilitate global adoption. It was this research that led to the adoption of the current
testing method, and the focus on the eight metals listed above.
Regarding the development of a specific list of metals, during the BioNorm I and BioNorm 11 projects,studies
were performed to assess metals levels in wood, including baseline levels present in virgin wood, metals levets
commonly found in various nonvirgin streams of recycled wood,as well as wood recovered from construction and
demolition activities.Additionally,wood treatments were assessed for metal components. As a result,the list of
metals provided in ISO 17225.2 were determined to be key indicators of the use of contaminated wood and/or
wood that contains chemicals commonly found in wood treatments.
Regarding the specific limits provided for each metal, the intent of the ISO standard is to provide a limit that is
above the highest amount observed in virgin wood. In theory, the metals limits can't be exceeded unless the
feedstock materials used for wood pellet production contain some form of recycled wood that has been
contaminated, construction and/or demolition waste, or chemically treated materials. It is noteworthy that the
primary research behind the creation of the 150 limits was based on studies of European wood.A review of North
American-based studies of metals in wood does provide a basis for comparison. While metals research data on the
North American wood basket is not as extensive as the information available in Europe, I will note that the North
American data supported the European findings, hence the adoption of the ISO-listed metals and their associated
limits.
But that still does not answer the question as to what is normal for virgin wood in the North American wood
basket. For this knowledge, I can only speak based on our own experience. our lab in Conyers, Georgia,regularly
tests for metals in wood pellet samples from across North America.Test data is provided to numerous clients,but
specific test data is confidential, and can't be shared in a public format such as this, so I will generalize. From
our experience, metals such as chromium, copper, mercury and nickel are rarely found in virgin wood at
concentrations above our detectable limits for these metals, Baseline levels of arsenic are typically below our
detection limit of 0.04 milligrams(mg)per kilogram(kg), but can be found up to about 0.16 mg/kg. Cadmium
typically ranges between 0.04 and 0.12 mg/kg. In some instances,we have seen cadmium approach 0.3 mg/kg,
but not above the limit of 0.5 mg/kg. Lead commonly ranges between 0.05 and 0.7 mg/kg. Zinc ranges between 6
and 13 mg/kg, but we have seen instances where it can be as high as 30 mg/kg,which is still well below the zinc
limit of 100 mg/kg. In our experience, these ranges are typical of both hardwoods and softwoods from diverse
areas across North America.
The final question is,what could trigger a failure?Essentially,the answer is easy—don't use contaminated or
chemically treated wood. Copper,chrome,arsenic and zinc are readily found in pressure treated lumber
(especially copper),so steer clear of residuals that may have pressure-treated wood residuals as part of the mix.
Cadmium, lead, nickel, mercury and zinc are largely the result of making use of recycled wood that has been
contaminated.
I realize that metals testing is complex,and creates a sense of uneasiness. I can only say that you should have no
problem passing these new requirements if you are running a clean operation,and do a good job of screening
your suppliers to be sure nothing that can risk failing a metals test is being introduced into the raw material
http://biDmassmagazine.com/ar(icles/1 5152/metals-testing-questions-answered V2

NC Division of Energy, Mineral and Land Resources
NPDES Stormwater Permit Contacts Summary
NC DEAILR has the following contact information in our Permit Database for your Permit as of 6/9/2018.
Permit Number: NCS000349
Permit Type: Stormwater Discharge,Individual
Facility Name: North Carolina R newable Power Lumberton,L
Facility Addressl: 1866 Hestertown Rd
Facility Address2:
City,State&Zip: Lumberton,NC 28358
Owner Information Details:
MUST submit a Change of Name/ownership form to DEMLR to make any changes to this Owner information.
(ClicAr Here for'Change of NameJownershPn"Form)
Owner Name: North Carolina Renewable power-Lumberton LLC
Owner Type: Non-Government Owner Type 6roup; Organization
***Legally Responsible for Permit***
(Responsible corporate officer/principle executive officer or ranking elected official/general partner or proprietor;
or any other person with delegated signatory authority from the legally responsible person.)
Owner Affiliation: Rf Carey Davis Title: VimPiesmdentizifE
Addressi: ^�^^gym 2100 Southbridge Pkwy, Suite 540 Executive Vice President
Address2:
City,State&Zip: Birmingham,AL 35217 35209
Work Phone: 2B5-Pst299 205-403-5273 Fax: [phone]
Email Address: cdavisC�georgiarenewablepower.com
***Permit Annual Fee Billing***
Billing Month; A2I
Invoice Number Inyoice_Date Invoice Due Date Invoice Amount Imyoice_Status
Owner Contact Person(s)
Contact Name Tit g Address Phone Fax Email
Facility Contact Person(s)
n M N m Ti A ix Address Phone F Email
Ciaran McManus, O&M Manager 1866 Hestertown Road, Lumberton NC 28358 984-218-6300 cmcmanusVgeorgiarenewablepower,cam
unit contact Persons)
Contact Name Ilft Address Phone F l:IIl�1l
Carey Davis,Executive Vice President 2100 Southbridge Pkwy, Suite 540 205-403-5273 cdavisOgeorgiarenewablepower.com
Permit Billing Contact
Contact Name Title Address Phone Email
Carey Davis.Executive Vice President 2100 Southbridge Pkwy, Suite 540 205-403-5273 [e-mail]
l.7 4-o De
6/9/2016 Page 1

Bennett, Bradley
From: Bennett, Bradley
Sent: Wednesday,August 22,201811:36 AM
To: 'Leona Miles'
Cc: '[e-mail]';'Mark Fowler GRP'; '[e-mail]';Lawyer, Mike
Subject: RE: [External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
Attachments: NCS000349 Contacts Report.pdf
Leona,
Thanks to you and Art for talking with us yesterday about the Lumberton facility. The information you provided was
very helpful in our process. I just wanted to touch base after the call to make sure we are on track with the things
discussed and that we outline some things that we know we might need. Please correct anything that isn't accurate and
let me know about the process you see moving forward to get the information we might need.
• The facility has changed from a coal fired plant and the fuel used now is a combination of wood/biomass chips
and poultry litter.
• All coal products and materials (ash,etc.) have been removed from the site.
• Facility is still following the same process otherwise—steam electric power generation.
• The facility purchased additional land and expanded north of the previous site boundary. This area now
contains the wood/biomass that is brought in,wood chipping operation,driers,conveyors for the wood chips,
storage barn for dried chips and other equipment. This area all drains to a new pond that was constructed with
the expansion. There is a new outfall (#9)from the pond. In this northern area of the property there was an
area in the Google views that showed storage of a black material,some covered with a blue tarp. Could you
Please provide information on what this storage is and what material is there.
• It would be helpful to have a new site map that shows the expanded area,gives information on the material on
the site, locates all outfalls and gives drainage boundaries for the outfalls. It is likely that we will need to re-
evaluate the representative outfall status as we get a better understanding of the outfalls and drainage areas,
etc. This will be handled as part of the site visit conducted by our Fayetteville Regional Office.
• Poultry litter is brought in and stored in the storage building that was previously onsite(near the NE part of the
ditch that divides the old and new property). Wood chips go from storage after drying to warehouse(built over
the old coal storage)near the wastewater basins. Wood goes from here on conveyor and mixes with poultry
litter and mixture goes to the facility as fuel for the process. There is an accumulation of material (wood and
poultry litter)that falls off the conveyor between the two buildings near the ditch. This material is collected and
put back into the process. It would help to know how long material stays on the ground here,etc.
• In the southeastern section of the facility by the plant there is a silo that collects the ash produced in the
process. The ash is removed from the site by truck on a daily basis. Is any ash stored anywhere else on site? It
seems that there is a good bit of ash produced and the one silo seems small for this collection? Could you
provide information on where the ash material is taken?
• In the past few years there were some issues with ash material stored on site and material was removed to
offsite locations. Mike asked about this process and if all that material had been removed from that site and
taken care of. There was an August 1, 2018 date given in the past for completion of this process.
• If there has been any monitoring data collected from Outfall 9 (discharge from the pond) can you please provide
the results of that monitoring.
• As we go through our review it is possible that monitoring locations may change with the changes on site and
the addition of the pond and new discharge for the northern portion of the site. We will also look at the
activities now on site and consider needed adjustments in the monitoring parameters given the changes. This
may eliminate some parameters and add others.
i

• 1 think there may be some ongoing questions about the facility name (Georgia vs NC Renewable Power). We will
need to have that worked out so we know the correct entity for issuance of the permit. We will have to have an
owner that is a registered INC Corporation.
• I have also attached the owner/Facility contact information that we have in our database. Please review that
and make any updates/corrections needed and tell us any contacts that need to be removed.
Hopefully I captured everything here. Mike—please add anything I missed. I tried to underline the things that involve
information we may need from you guys.
Thanks again for your help!
BB
From: Leona Miles [mailto:[e-mail]]
Sent: Monday,August 20, 2018 10:45 AM
To: Bennett, Bradley<[e-mail]>
Subject: RE: [External} RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
1 1e`r'nail. . . •
Hi Bradley
Would 2pm Tuesday work? We can call you if that time is good.
Thanks
Leona
Leo-v Ma,?* C74MM
Senior Project Manager
Atlanta Environmental Management, Inc.
2580 Northeast Expressway, NE
Atlanta, Georgia 30345
Office: [phone]
Cell: [phone]
[e-mail]
www.AEM-net.com
P. EiFr
1 lirnss�4 k'r Ncnrmrad tm�r.rua.ciili..w"
From: Bennett, Bradley<[e-mail]>
Sent: Monday,August 20, 2018 10:27 AM
To: Leona Miles<leona-miles aem-net.com>
Subject: RE: [External) RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
Leona,
2

C V JUG �gNtkrtbb PAAler
�v►
-- cej r .e �-�j p►IV14
�ji(J ytis�.[s S' d cP r'��7• ck,� j G`4r,,p/ d j
Cam;
ftt -- VI-M c�( &V cam. v"JO�.
WAV
t Sj, �e S . .. f�� ,, r S7r.e czar
DV,� i r PPi► ,1'yiG � n

Bennett, Bradley
From: Bennett, Bradley
Sent: Wednesday,July 18, 2018 3:40 PM
To: 'Mark Fowler GRP'
Subject: RE: [External] RE: Permit Renewal for NCSO00349 Stromwater NPDES Permit
Attachments: NCSO00349 Contacts Report.pdf
Mr. Fowler,
Thanks for talking with me yesterday about your Lumberton facility. I hope you got the information I forwarded about
the process for rescinding permits for the Elizbethtown facility.
Please let me know when you and other appropriate staff can have a conference call to discuss changes to the
Lumberton site and how they might impact the permit renewal. Some areas for discussion are noted below.
• 1 have attached a printout of contacts we have in our database for the facility. Can you please review this and
let me know if there are changes to contacts and if the owner/facility information is still accurate?
• Federal regulations changed in the last few years to require electronic reporting of data. We are not yet at the
stage of being able to collect stormwater data this way, but we will have to work to get accurate outfall location
information in our system in order to meet federal requirements for electronic reporting when our systems can
handle the data. If you could provide the lat/long coordinates for your facility's outfall points that would be
helpful.
• If you can provide a summary of monitoring information since your application submittal in April 2014 that
would be help as well.
• 1 am very interested in changes that have occurred in your facility and facility processes since your application
submittal. These will have an impact on pollutants discharged in stormwater runoff. It appears that the facility
may have been closed for a while but is reopened and using different fuel sources, etc. Descriptions of these
changes will be needed to help us in our review.
• With the changes a new site map showing the most up to date layout of activities,outfalls and drainage will be
needed. Looking at the google map of your site it appears that there are some expanded areas from the site
map that was submitted in the 2014 applications. That site plan was dated 2010.
Next week I will be in the office Monday,Tuesday and Wednesday. Maybe we can schedule a day and time for a call.
Thanks for your help.
Bradley Bennett
Stormwater Program
NC Division of Energy,Mineral&Land Resources Phone: [phone]
512 N.Salisbury Street Fax: [phone]
1612 Mail Service Center Email:bradley.ben nettAncdenr.gov
Raleigh, NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
From: Bennett, Bradley
Sent:Tuesday,July 17, 2018 10:53 AM
1

To: Mark Fowler GRP<[e-mail]>
Subject: RE: [External] RE: Permit Renewal for NC5000349 Stromwater NPDES Permit
Hi Mr. Fowler,
Just wanted to touch base and see when you were available to talk about your facility in Lumberton?
I also have some questions about a facility for NC Renewable Energy in Elizabethtown NC. This one might be closed? It
needs to either have a permit renewal application submitted or have a request for rescission.
Please let me know when you are available to talk. I will be in the office today and tomorrow and then out until next
Monday.
Thanks
BB
Bradley Bennett
Stormwater Program
NC Division of Energy,Mineral&Land Resources Phone: [phone]
512 N.Salisbury Street Fax: [phone]
1612 Mail Service Center Email:brad ley.bennett(c ncdenr.gov
Raleigh,NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
From: Bennett, Bradley
Sent:Thursday,July 12, 2018 11:17 AM
To: Mark Fowler GRP<[e-mail]>
Subject: Re: [External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
Thanks for getting back with me. Next week I'll be in the office Monday through Wednesday. We can set up a
call any of those days that works for you and others that may need to be involved.
BB
Bradley Bennett
Stormwater Program Phone: [phone]
NC Division of Energy, Mineral&Land Resources Fax: [phone]
1612 Mail Service Center Email:bradlev.bennett@ncdenr,gov
Raleigh,NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
2

From: Mark Fowler GRP <[e-mail]>
Sent: Wednesday,July 11, 2018 8:40 PM
To: Bennett, Bradley
Subject: [External] RE: Permit Renewal for NC50O0349 Stromwater NPDES Permit
• • or open attachments unless verified. suspicious
Mr. Bennett,
1 have been off, and then working in the field with no communication ability during the days, since the 4"'. 1
will be back in my office in Birmingham next week. Please let me know the best time to contact you.
Thank you,
Mark Fowler
From: Bennett, Bradley [mailto:[e-mail]]
Sent: Monday, July 02, 2018 2:42 PM
To: Mark Fowler GRP <[e-mail]>
Cc: [e-mail]; Rick Houser<rhouser(cDReorgiarenewablepower.com>
Subject: FW: Permit Renewal for NC5O00349 Stromwater NPDES Permit
Mr. Fowler,
I wanted to touch base and try to set up a meeting to discuss renewal of the stormwater NPDES permit at the
NC Renewable Power facility in Lumberton. After talking with Rick Houser it appears that there have been
some changes at the facility over the last few years that will impact the permit. I think a call to discuss these
will help the process. Rick mentioned that it would be helpful to have you involved in this. If you look at the
original email I sent to William Huggins below you can see some of the items 1'd like to discuss.
You can reach me at this email or at my office number— [phone].
1 work part time, my schedule this week is to be in the office today (July 2), tomorrow (July 3) and Thursday
(July 5).
Thanks for your help.
Bradley Bennett
Stormwater Program
NC Division of Energy, Mineral&Land Resources Phone: [phone]
512 N. Salisbury Street Fax: [phone]
1612 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
3

From: Bennett, Bradley
Sent: Monday, June 25, 2018 12:17 PM
To: '[e-mail]' <[e-mail]>
Subject: RE: Permit Renewal for NCSO00349 Stromwater NPDES Permit
Hi Mr. Houser. Just wanted to touch base and see if you guys have thought any about a day/time that we
could have a call about the permit renewal.
Thanks
BB
From: Bennett, Bradley
Sent: Wednesday,June 13, 2018 3:13 PM
To: '[e-mail]' <[e-mail]>
Subject: FW: Permit Renewal for NCSO00349 Stromwater NPDES Permit
Mr. Houser,
Thanks for talking with me today. Below is the email I sent to Mr. Huggins yesterday. As I mentioned, it would
be really helpful if we could have a conference call sometime early next week if that would work out for you
and others that need to be involved.
Thanks
BB
Bradley Bennett
Stormwater Program
NC Division of Energy,Mineral&Land Resources Phone: [phone]
512 N, Salisbury Street Fax: [phone]
1612 Mail Service Center Email:bradley.bennett(cDncdenr.gov
Raleigh,NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
From: Bennett, Bradley
Sent: Tuesday, June 12, 2018 4:16 PM
To: '[e-mail]' <[e-mail]>
Subject: Permit Renewal for NCSO00349 Stromwater NPDES Permit
Hello, and first let me apologize for how long it has taken us to get going on your permit renewal. A number
of issues over the last few years have led to a backlog on renewal of our Individual permits. I would like to set
up a time where I can call and talk with you about the renewal. I will be working on this process. Since the
previous renewal application came in back in 2014 I'm guessing there may be some changes that we should
4

discuss and possibly have documented for the renewal. In addition, here are a few additional items that
would be helpful if you can provide updates:
• I have attached a printout of contacts we have in our database for the facility. Can you please review
this and let me know if there are changes to contacts and if the owner/facility information is still
accurate?
Federal regulations changed in the last few years to require electronic reporting of data. We are not
yet at the stage of being able to collect stormwater data this way, but we will have to work to get
accurate outfall location information in our system in order to meet federal requirements for
electronic reporting when our systems can handle the data. If you could provide the lat/long
coordinates for your facility's outfall points that would be helpful.
• If you can provide a summary of monitoring information since your application submittal in April 2014
that would be help as well.
1 am very interested in any changes that may have occurred in your facility or processes since your
application submittal that could affect pollutants discharged in stormwater runoff. It appears that the
facility may have been closed for a while but is now reopened and may be using different fuel sources,
etc. Descriptions of any changes will be needed to help us in our review.
• If there have been changes, a new site map showing the most up to date layout of activities, outfalls
and drainage will be needed. Looks at the google map of your site it appears that there are some
expanded areas from the site map that was submitted in the 2014 applications. That site plan was
dated 2010.
1 work part time and I am generally in the office three days a week. I will be in the office tomorrow (June 13th)
and then out the rest of the week. I'll be back in the office Monday—Wednesday of next week. Maybe we
can find a day/time that works over the next week to talk.
Thanks
Bradley Bennett
Stormwater Program
NC Division of Energy, Mineral&Land Resources Phone: [phone]
512 N.Salisbury Street Fax: [phone]
1612 Mail Service Center Email:brad ley.bennett(a.ncdenr.gov
Raleigh, NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
5

H
10) 7 33— 0) hksix-:�
• TM I ' ...
S }u u AA,- 1 S Sur ltdw.
T44 a CAeAj
Cad
�rcjll_v - u-r i k C'16 r C,"
3 s } a U)o �v !

4
Mq k 7
Gt R144.�t+'
North Carolina Department of Natural and Cultural Resources
Natural Heritage Program
Govemor Roy Cooper Secretary Sus!H. Hamilton
NCNHDE-6216
June 10, 2018
Bradley Bennett
NCDEQ
512 N. Salisbury Street
Raleigh, NC 27604
RE: N.0 Renewable Power-Lumberton; NCS000349
Dear Bradley Bennett:
The North Carolina Natural Heritage Program (NCNHP)appreciates the opportunity to provide information
about natural heritage resources for the project referenced above.
Based on the project area mapped with your request, a query of the NCNHP database, indicates that there are
no records for rare species, important natural communities, natural areas, and/or conservation/managed areas
within the proposed project boundary. Please note that although there may be no documentation of natural
heritage elements within the project boundary, it does not imply or confirm their absence;the area may not have
been surveyed. The results of this query should not be substituted for field surveys where suitable habitat exists.
In the event that rare species are found within the project area, please contact the NCNHP so that we may
update our records.
The attached `Potential Occurrences'table summarizes rare species and natural communities that have been
documented within a one-mile radius of the property boundary. The proximity of these records suggests that
these natural heritage elements may potentially be present in the project area if suitable habitat exists.Tables of
natural areas and conservationlmanaged areas within a one-mile radius of the project area, if any, are also
included in this report.
If a Federally-listed species is found within the project area or is indicated within a one-mile radius of the project
area, the NCNHP recommends contacting the US Fish and Wildlife Service (USFWS)for guidance. Contact
information for USFWS offices in North Carolina is found here:
tt fw v ffi i ff ices,cfm? t e =3 7.
Please note that natural heritage element data are maintained for the purposes of conservation planning, project
review, and scientific research, and are not intended for use as the primary criteria for regulatory decisions.
Information provided by the NCNHP database may not be published without prior written notification to the
NCNHP, and the NCNHP must be credited as an information source in these publications. Maps of NCNHP
data may not be redistributed without permission.
The NC Natural Heritage Program may follow this letter with additional correspondence if a Dedicated Nature
Preserve, Registered Heritage Area, Clean Water Management Trust Fund easement, or Federally-fisted
species are documented near the project area.
If you have questions regarding the information provided in this letter or need additional assistance, please
contact Rodney A. Butler at rodney.butler mcdcr_4oy or 919-707-8603.
Sincerely,
NC Natural Heritage Program
MAILING ADDRESS: Telephone: [phone] LOCATION:
1651 Mail Service Center wriw,ncnhp.org 121 West Jones Street
Raleigh,NC 27699 1651 Raleigh,NC 276D3

Natural Heritage Element Occurrences, Natural Areas, and Managed Areas Within a One-mile Radius of the Project Area
N.0 Renewable Power-Lumberton
Project No. NCS000349
June 10, 2018
NCNHDE-6216
Element Occurrences Documented Within a One-mile Radius of the Project Area
Taxonomic EO ID Scientific Name Common Name Last Element Accuracy Federal State Global State
Group Observation Occurrence Status Status Rank Rank
Date Rank
Dragonfly or 33769 Somatochlora georgiana Coppery Emerald 2004-Pre H? 5-Very --- Significantly G3G4 S2?
Damselfly Low Rare
Dragonfly or 33360 Stylurus ivae Shining Clubtail 1992-09-08 E 2-High --- Significantly G4 S2S3
Damselfly Rare
Dragonfly or 33789 Triacanthagyna trifida Phantom Darner 2004-Pre H? 5-Very --- Significantly G5 S1?
Damselfly Low Rare
Freshwater Fish 31837 Enneacanthus chaetodon Blackbanded Sunfish 2012-07-12 E 3-Medium --- Significantly G3G4 33
Rare
Freshwater Fish 32369 Enneacanthus obesus Banded Sunfish 1998-12-21 E 3-Medium - Significantly G5 S3
Rare
Freshwater Fish 36964 Notropis chalybacus Ironcolor Shiner 1999-04-12 E 3-Medium --- Significantly G4 S2S3
Rare
Natural 27990 Dry Oak--Hickory Forest --- 2010 CD 2-High --- -- G4? S3
Community (Coastal Plain Subtype)
Natural 27992 Low Elevation Seep --- 2007-09-21 C 2-High --- --- G4 S2
Community (Floodplain Subtype)
Natural 27991 Mesic Mixed Hardwood --- 2007-09-21 C 2-High -- -- G3 S3
Community Forest(Coastal Plain
Subtype)
Vascular Plant 26673 Ditrysinia fruticosa Sebastian-bush 2007-09-21 B 3-Medium --- Special G5 S2
Concern
Vulnerable
Vascular Plant 17562 Macbridea caroliniana Carolina Bogmint 2004-08-29 F 4-Low Species of Endangered G2G3 S2
Concern
Vascular Plant 19463 Xyris floridana Florida Yellow-eyed- 1963-08-27 H 4-Low --- Threatened G5T4T S1
grass 5
Natural Areas Documented Within a One-mile Radius of the Project Area
Site Name Representational Rating Collective Rating
Lumber River/High Hill R3 (High) C4 (Moderate)
Page 2 of 4

Managed Areas Documented Within a One-mile Radius of the Project Area
Managed Area Dame Owner Owner Type
NC Clean Water Management Trust Fund Easement NC DNCR, Clean Water Management Trust State
Fund
Lumber State Natural and Scenic River NC DNCR, Division of Parks and Recreation State
Lumber National Wild and Scenic River US National Park Service Federal
Robeson County Open Space Robeson County: multiple local government Local Government
Definitions and an explanation of status designations and codes can be found at bans:/!ncnhde.natureserve_orglcontentlhelp.Data query generated on June 10,2018:source:NCNHP,Q2 April 2018.Please resubmit your
information request if more than one year elapses before project initiation as new information is continually added to the NCNHP database.
Page 3 of 4

NCNHDE-6216: N.0 Renewable Power - Lumberton
. ... .........
z%
!p
..........
..........
...........
M.
.. ........
ji.
June 10.2018 1:22,435
❑ 0 0.175 0.35
Project Boundary E] Managed Area(MAREA) 1 % . . .. 0.7 mi
Try . I
❑ Buffered Project Boundary 0 0.3 0-6 1.2 km
E) Natural Heritage Element Occurrence(NHEO) S-:Em.HERE,�.-hfl.,np.�P Gap.GEDCO.U&GS.
FAO.NPS,NRCAN.GWS�I.GN.KadmW NL.Ord-Survey,W Japan.
MF-n.FW Clikis(FkMQ Kxe)� CVWWSU*eIWp�Wbutom.2rd
NHP Natural Area(NHNA) ft GIs UW CWFMAWY
Page 4 of 4

q 10 & Eks�c kw y� 7J - Luwtla.4 NCS 3�<t
4 r"f MG i�irv►,yr�. R�ur r
U I -t-o Lu m 15*r Rvr r ly C hiss C- 5 w
icviw cAsw.?, � Lumk*r 4w t or )z) J'Gcatis Brry,+< -- HVC Jru:j,
ft•p Cep►�-fvns drO�k'll � 1)7- -to two,6, a;vrr
a01� lvitleglow 1404 - ]u-- (6) e, sows r+Q i ►rw
`-d+C- 5pec;es - Pzod rw rr-Saurips
Ty, 0 nu wv�U fWU4 4I„Yc an pw ay.,A-c �tci,� a�rCyl
nff,�A, sDeLrfs lkv 4 '�rs� r Ly1D 40 eub"
�e o 9 s-" v� 4a --o dry- + sa4 )6" J
use . d 5a,-ItL� 005 4 4&1, Ae< OJT Jts
�QI�} �A �►nc i{aP'S d�c,�h c4.Sd .Si re- �2009 ? Oporah uav
1,� X01 aprrr Aj 7
w„IV)avh. 65,3 ns @ V eohei .cam
�j1�11�a1�d� C�}1ac C� S PL� OVM�; j kbA OAJ 61L4CLyJ Mte it, 1044
1 Ct, L I(q) 7 ko tL o r X X r C cv►«.3�. Ik�� -Y,� ma, !w nAAJna,J
c C�if�c (,cx�t wr�-r ��ss�a' C�LtA l Yard — r rw� .l 6>64)
NutO * t � ash s s 3Artc

)I s 6 ra�i ,cc3/a,�,�r t- +ANtlivr'I '
jf
Af
�1CoU�83o1 !' vt tow

8/21/2018 1866 Hestertawn Rd-Googie Maps
Go gle Maps 1866 Hestertown Rd
, V f
VF
r• ���A ; � � s Yi� I+
r Y,y
Imagery 02018 DigitalGfobe,USDA Farm Service Agency,Map data*2018 Goggle 200 ft
https://www.google,com/maps/place/l 866+Hestertown+Rd,+Lumberton,+NC+283581@34.591894,-78.9947731,932m/data=!3ml!1 e3!4m5!3m4!1 sOx89aae7Oc4faa2c69:Oxcbfedda3Oea32270!8m2!3d34.5917621!4(

910- 433- 339q
q 0406
�'►sc�ss pc'oeeSs Cs
S;�c _ c6l ~- wn.ri oh - y -es
rLtw yes
1ruc� o &1 a 1 Asa�r Q 11S, owI 1K►�u;r�i�.c &°
..r
be cep�o4 4o WtJ xCoo"58 3 o 1,
sc-us do�c ►-fir + oq j s Ar L a�s 11
_
., GS u r.,fC4 Is'
dnaw� �r? co
-- dusk 6 &w nw 4 64 O rc4 ar=n5 ? Nvs ---
OUrr
G�� 5�ru� r-cyh.a,;ne� �S��r ? - hA r�{ �c,�,,,,•�.�ij.

i
Nl—
AIV
35,217
- •F
r
i
s�