HomeMy WebLinkAboutNCS000572_Dan River Draft Permit Fact Sheet_20150731NC Division of Energy, Mineral, and Land Resources
FACT SHEET FOR NPDES STORMWATER PERMIT DEVELOPMENT
NPDES Stormwater Permit NCS000572
BACKGROUND
Duke Energy's Dan River Combined Cycle Station is a 620 -megawatt natural gas electricity
generating plant in Rockingham County. The Combined Cycle Station came on line in 2012.
Beginning in 1949 the site previously generated electricity with a coal-fired steam electric plant
and a combustion turbine installation.
In addition to NPDES wastewater discharge permit NC0003468, the facility also holds air permit
#03455T30 and hazardous wastes permit NCD024668535. The facility is subject to federal NPDES
stormwater discharge permit requirements per 40 CFR §122.26 (b)(14)(vii).
The company applied to the NC Division of Energy, Mineral, and Land Resources Stormwater
Permitting Program (SPP) for a separate NPDES stormwater discharge permit for this facility in
August 2014, with additional amended information in September and December 2014.
This facility discharges to the Dan River, a class C water in the Roanoke River Basin. Stormwater
discharges will enter the Dan River in a stretch that is subject to a TMDL for fecal coliform and to
the statewide TMDL for mercury. No specific reductions or Hg limits are required for NPDES
stormwater permittees at this time.
WHY THIS FACILITY IS SUBIECT TO A PERMIT
Federal NPDES regulations define stormwater discharge associated with industrial activity in
40 CFR §122.26 (b)(14) as:
"...the discharge from any conveyance that is used for collecting and conveying storm water and that
is directly related to manufacturing, processing or raw materials storage areas at an industrial plant.
The term does not include discharges from facilities or activities excluded from the NPDES program
under this part 122. For the categories of industries identified in this section, the term includes, but
Fact Sheet
NI11_)LS S1onw qm Pctmit NCS00054
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Facility Information
Applicant/Facility Name:
Duke Energy Carolinas, LLC/Dan River Combined Cycle Station
Applicant Address:
P.O. Box 1006, Mail Code EC13K; Charlotte, North Carolina 28201
Facility Address:
864 South Edgewood Drive, Eden, North Carolina 27288
Permitted Flow:
Not applicable (stormwater discharges only)
Industrial Activities:
Primary SIC Code: 4911 - Electric Services
Permit Status:
New NPDES stormwater permit
County:
Rockingham Count
Miscellaneous
Receiving Stream:
Dan River Regional Office: Winston-Salem
Stream Classification:
C State Grid / USGS Quad: Southeast Eden
303(d) List/ TMDL?
No/Hg, fecal colif. Permit Writer: K. Pickle
Subbasin, Stream Index #:
03-02-03, 22-(39)a Date: May 4, 2015
Facility Location: Lat. 36 29' 18" N Long. 79 43'17"W
BACKGROUND
Duke Energy's Dan River Combined Cycle Station is a 620 -megawatt natural gas electricity
generating plant in Rockingham County. The Combined Cycle Station came on line in 2012.
Beginning in 1949 the site previously generated electricity with a coal-fired steam electric plant
and a combustion turbine installation.
In addition to NPDES wastewater discharge permit NC0003468, the facility also holds air permit
#03455T30 and hazardous wastes permit NCD024668535. The facility is subject to federal NPDES
stormwater discharge permit requirements per 40 CFR §122.26 (b)(14)(vii).
The company applied to the NC Division of Energy, Mineral, and Land Resources Stormwater
Permitting Program (SPP) for a separate NPDES stormwater discharge permit for this facility in
August 2014, with additional amended information in September and December 2014.
This facility discharges to the Dan River, a class C water in the Roanoke River Basin. Stormwater
discharges will enter the Dan River in a stretch that is subject to a TMDL for fecal coliform and to
the statewide TMDL for mercury. No specific reductions or Hg limits are required for NPDES
stormwater permittees at this time.
WHY THIS FACILITY IS SUBIECT TO A PERMIT
Federal NPDES regulations define stormwater discharge associated with industrial activity in
40 CFR §122.26 (b)(14) as:
"...the discharge from any conveyance that is used for collecting and conveying storm water and that
is directly related to manufacturing, processing or raw materials storage areas at an industrial plant.
The term does not include discharges from facilities or activities excluded from the NPDES program
under this part 122. For the categories of industries identified in this section, the term includes, but
Fact Sheet
NI11_)LS S1onw qm Pctmit NCS00054
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is not limited to, storm water discharges from industrial plant yards; immediate access roads and rail
lines used or traveled by carriers of raw materials, manufactured products, waste material, or by-
products used or created by the facility; material handling sites; refuse sites; sites used for the
application or disposal of process waste waters (as defined at part 401 of this chapter); sites used for
the storage and maintenance of material handling equipment; sites used for residual treatment,
storage, or disposal; shipping and receiving areas; manufacturing buildings; storage areas (including
tank farms) for raw materials, and intermediate and final products; and areas where industrial
activity has taken place in the past and significant materials remain and are exposed to storm water.
For the purposes of this paragraph, material handling activities include storage, loading and
unloading, transportation, or conveyance of any raw material, intermediate product, final product,
by-product or waste product. The term excludes areas located on plant lands separate from the
plant's industrial activities, such as office buildings and accompanying parking lots as long as the
drainage from the excluded areas is not mixed with storm water drained from the above described
areas."
As a result of the significant exposed materials and industrial activities at the Dan River facility, all
stormwater-only discharges from the above named areas at the facility meet the definition of
stormwater discharge associated with industrial activity.
PROPOSED MONITORING FOR STORMWATER DISCHARGES
The Division considered potential pollutants from the regulated industrial activities as well as
analytical data submitted as part of the permit application in August 2014. Single samples at ten
on-site locations included measurements of 0&G, COD, Cl, Fl, SO4, Hg, Al, As, Ba, B, Ca, Cd, Cr, Cu, Fe,
Mg, Mn, Mo, Ni, Pb, Se, Sb, Tl, Zn, TDS, TSS, conductivity, hardness, temperature, and pH. See
attached information for sampling results.
Unlike most stormwater permits in its program, the Division is proposing a permit structure with
outfall -specific monitoring for discharges. The Division considered including parameters based on
anticipated potential pollutants in the drainage area and on the sampling results. The Division is
proposing the monitoring parameters for each outfall as shown in the table below. All outfalls
discharge to the Dan River directly, or to the Service Water Settling Pond, which is tributary to the
Dan River.
Proposed Stormwater Discharge Outfall (SDO) Monitoring
SW001
Draining the combined cycle station and substation.
Plant roads with potentialfor ash -hauling traffic cross the drainage area.
Polychlorinated Biphenyls (PCBs)
Semi-annual monitoring; may be discontinued after the first year
(two samples) if not detected. BASIS: Permit application reports the
past potential for PCBs in the drainage area. PCBs persist in the
environment if ever released. If all PCBs have been removed and past
releases cleaned up, these compounds should not be detected.
Total Suspended Solids (TSS)
Semi-annual monitoring. BASIS: Potential pollutant from all areas and
BMP effectiveness indicator.
Non -polar Oil & Grease (EPA 1664
Semi-annual monitoring. BASIS: Potential pollutant from lubricants;
SGT -HEM)
Method 1664 SGT -HEM targetspetroleum-based 0&G.
Total Nitrogen
Semi-annual monitoring. BASIS: Aqueous ammonia storage in the
drainage area, with containment draining to the stormwater system.
pH
Semi-annual monitoring. BASIS: Pollutant indicator and important to
interpreting toxicity potential of metals.
Priority Pollutant Metals Ag, As,
Semi-annual monitoring only if coal or coal ash is transported through
Be, Cd, Cr, Cu, Hg, Ni, Pb, Sb, Se, Tl,
this drainage area. BASIS: Coal combustion waste (CCW) constituents
and Zn.
may be transported on roads crossing the drainage area.
Boron
Semi-annual monitoring only if coal or coal ash is transported through
this drainage area. BASIS: CCW constituent coal tracer.
Fact Sheet
NPDES Stormwater Permit NCS000548
Page 2
Proposed Stormwater Discharge Outfall (SDO) Monitoring
SWO02
Previously identified by Duke as a stormwater outfall. Draining a portion of the combined cycle station.
Now discharging to the ash basins. No longer a regulated stormwater-onlyoutfall.
The permit application reports that runoff from this drainage area will eventually enter new outfall SWO09
once CCW are no longer present in the drainage area.
SW003, SW003A, SW003B(3 adjacent 12"culverts), SW004, SW005, SW006, and SW011
Draining the la down area west of the Powerhouse, currently used in support of its on-going demolition.
Polychlorinated Biphenyls (PCBs)
Semi-annual monitoring; may be discontinued after demolition is
complete, the area is stabilized, and two subsequent consecutive
tests are below detection. BASIS: Electrical equipment in the adjacent
Powerhouse, or these areas, may have contained PCBs, which persist in
the environment if ever released. If all PCBs have been removed and
past releases cleaned up, these compounds should not be detected.
Total Suspended Solids (TSS)
Semi-annual monitoring. BASIS: Potential pollutant from drainage area
and BMP effectiveness indicator.
pH
Semi-annual monitoring. BASIS: Pollutant indicator and important to
interpreting toxicity potential of metals.
Non -polar Oil & Grease (EPA 1664
Semi-annual monitoring. BASIS: Potential pollutant from lubricants;
SGT -HEM)
Method 1664 SGT -HEM targetspetroleum-based 0&G.
Priority Pollutant Metals Ag, As,
Semi-annual monitoring. BASIS: Coal and CCW constituents are
Be, Cd, Cr, Cu, Hg, Ni, Pb, Sb, Se, TI,
present in the drainage areas, and may also be exposed during
and Zn.
demolition of the adjacent powerhouse.
Boron
Semi-annual monitoring. BASIS: CCW constituent coal tracer.
SWO07
Draining a portion of the plant construction staging area north of the combined cycle station.
Plant roads with potentialfor ash -hauling traffic cross the drainage area.
Total Suspended Solids (TSS)
Semi-annual monitoring. BASIS: Potential pollutant from drainage area
and BMP effectiveness indicator.
pH
Semi-annual monitoring. BASIS: Pollutant indicator and important to
interpreting toxicity potential of metals.
Priority Pollutant Metals Ag, As,
Semi-annual monitoring only if coal or coal ash is transported through
Be, Cd, Cr, Cu, Hg, Ni, Pb, Sb, Se, Tl,
this drainage area. BASIS: Coal combustion waste (CCW) constituents
and Zn.
may be transported on roads crossing the drainage area.
Boron
Semi-annual monitoring only if coal or coal ash is transported through
this drainage area. BASIS: CCW constituent coal tracer.
SWO08
Draining a portion of the plant construction staging area north of the combined cycle station.
Total Suspended Solids (TSS)
Semi-annual monitoring. BASIS: Potential pollutant from drainage area
and BMP effectiveness indicator.
pH
Semi-annual monitoring. BASIS: Pollutant indicator.
SWO09
Draining the powerhouse, coal yard, switchyard, combustion turbine area, and a portion of the combined cycle
plant. Additionally, this large drainage area has the potential for ash -hauling traffic. Re -grading portions of the
drainage area is likely. Prior to the initial discharge via new SWO09 the permittee must obtain the Division's
release to discharge based on the Division's inspection of the outfall structures and contributing drainage areas.
Polychlorinated Biphenyls (PCBs)
Semi-annual monitoring; may be discontinued after all demolition
and grading is complete, the areas are stabilized, and two
subsequent tests are below detection for the entire new
contributing drainage area directed to SW009. BASIS: Switchyard
and powerhouse equipment contained PCBs, which persist in the
environment if ever released. Other areas of this large drainage area
may be re -graded, potentially exposing contaminated soils. If all PCBs
have been removed and past releases cleaned up, these compounds
should not be detected. Applicant reports the potential for past PCB
discharges from SW002, eventually to be discharged via new outfall
SWO09.
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NPDES Stormwater Permit NCS000548
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Proposed Stormwater Discharge Outfall (SDO) Monitoring
Total Suspended Solids (TSS)
Semi-annual monitoring. BASIS: Potential pollutant from drainage area
and BMP effectiveness indicator.
H
Semi-annual monitoring. BASIS: Pollutant indicator.
Non -polar Oil & Grease (EPA 1664
Semi-annual monitoring. BASIS: Potential pollutant from lubricants;
SGT -HEM)
Method 1664 SGT -HEM targets petroleum-based 0&G. Applicant
reports oil water separators in the contributing drainage areas.
Priority Pollutant Metals Ag, As,
Semi-annual monitoring. BASIS: Coal and CCW constituents are
Be, Cd, Cr, Cu, Hg, Ni, Pb, Sb, Se, Tl,
present in the drainage areas, and may also be exposed during
and Zn.
Powerhouse demolition.
Boron
Semi-annual monitoring. BASIS: CCW constituent coal tracer
SWO10
Draining the dry ash stacks, the gravel construction staging area, and a substation via a new outfall.
Currently runoff from these areas enters the ash basins. This large drainage area will see significant ash removal
activities. Permittee may not begin discharging via new SWO10 except upon the Division's written release after
inspection of the new outfall structures and contributing drainage areas.
Polychlorinated Biphenyls (PCBs)
Semi-annual monitoring; may be discontinued after the first year
(two samples) if not detected. BASIS: PCBs persist in the
environment if ever released. If all PCBs have been removed and past
releases cleaned up, these compounds should not be detected.
Total Suspended Solids (TSS)
Semi-annual monitoring. BASIS: Potential pollutant from drainage area
and BMP effectiveness indicator.
pH
Semi-annual monitoring. BASIS: Pollutant indicator and important to
interpreting toxicity potential of metals.
Priority Pollutant Metals Ag, As,
Semi-annual monitoring. BASIS: CCW constituents are present in the
Be, Cd, Cr, Cu, Hg, Ni, Pb, Sb, Se, Tl,
drainage area.
and Zn.
Boron
Semi-annual monitoring. BASIS: CCW constituent coal tracer.
STORMWATER BENCHMARKS AND TIERED RESPONSE
Rather than limits, North Carolina NPDES Stormwater permits contain benchmark concentrations.
Stormwater benchmarks are numerical action levels for stormwater monitoring. Benchmarks are
not effluent limits, and benchmark exceedances are not permit violations. Benchmarks
provide facilities a tool for assessing the significance of pollutants in stormwater discharges and the
effectiveness of best management practices (BMPs). Benchmark concentrations are intended as
guidelines for the facility's development and implementation of the Stormwater Pollution
Prevention Plan (SPPP).
Benchmark exceedances require the permittee to increase monitoring, increase management
actions, increase record keeping, and/or install stormwater BMPs in a tiered program. The permit
establishes a tiered approach to specify actions the permittee must take in response to analytical
results above benchmark concentrations (Part II, Section B., following Table 11 in the permit). The
tiered structure of the permit provides the permittee and NCDEMLR wide flexibility to address
issues that may arise with one or more parameters and/or outfalls.
Metals benchmarks are calculated to mimic acute water quality standards and with the guidance of
NC's Division of Water Resources (DWR). NC DWR follows established federal procedures for
calculating acute standards when developing the benchmarks. Just like the acute standards, metals
benchmarks normally reflect one half of the calculated Final Acute Value (the "1/z FAV"). In most
cases, translation into total recoverable values is based on an assumed hardness of 25 mg/1 and a
total suspended solids (TSS) concentration of 10 mg/L. Acute standards protect aquatic life from
negative impacts of short-term exposure to higher levels of chemicals where the discharge enters a
Fact Sheet
NPDES Stormwater Permit NCS000548
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waterbody. The Stormwater Permitting Program applies this approach because of the ephemeral
nature of rainfall events and the associated discharges.
The Division may evaluate results to determine if a smaller suite of parameters for some outfalls is
adequate to characterize potential pollution or BMP effectiveness. For example, one or more metals
or other parameters may serve as an adequate tracer for the presence of ash pollution during
disturbance or ash removal in specific drainage areas at this site. For parameters that do not have a
stormwater benchmark, the Division may develop a benchmark value if appropriate toxicity data
become available or if rising trends in concentrations suggest a persistent source.
A summary of the benchmarks in the draft permit, and their basis, is below:
Parameter
Benchmark
Basis
Antimony (Sb), m L Total
0.09
Acute Aquatic Criterion, 1/2 FAV
Arsenic (As), m L Total
0.34
Acute Aquatic Criterion, 1/2 FAV
Beryllium (Be), m L Total
0.065
Acute Aquatic Criterion, 1/2 FAV
Cadmium (Cd), m L Total
0.003
Acute Aquatic Criterion, 1/2 FAV
1/2 FAV, based on (Cr III + Cr VI) acute thresholds
Chromium (Cr), mg/L (Total)
0.9
and assumption that industrial activities here are
not a source of hexavalent chromium.
Copper (Cu), m L Total
0.010
Acute Aquatic Criterion, 1/2 FAV
Lead (Pb), m L Total
0.075
Acute Aquatic Criterion, 1/2 FAV
Monitoring only, CCW/Coal Constituent. Hg
influenced by regional transport and wet
Mercury (Hg), ng/L (Total)
N/A
deposition. Values above 12 ng/L (NC WQ
standard) should be noted on the DMR but do not
trigger Tier Responses.
Nickel (Ni), m L Total
0.335
Acute Aquatic Criterion, 1/2 FAV
Polychlorinated biphenyl
Detected
NC Water Quality Standards vs. present Arochlors
compounds (PCBs), g/L
quantitation levels (higher than standard)
1/2 FAV, NC -specific, based on 1986 Study on Se
Selenium (Se), mg/L (Total)
0.056
impacts in North Carolina
Acute Aquatic Criterion, 1/2 FAV. (The Division
Silver (Ag), mg/L (Total)
0.0003
notes this value is below the practical quantitation
level (PQL) of 1 g/L of EPA Method 200.8)
Monitoring only, CCW/Coal Constituent. Narrative
Boron (B), mg/L
N/A
National Recommended Water Quality Criterion.
Monitoring Only, CCW/Coal constituent. National
Thallium (Tl), mg/L (Total)
N/A
Recommended Human Health Criterion.
Zinc (Zn), m L Total
0.126
Acute Aquatic Criterion, 1/2 FAV
Total Suspended Solids (TSS),
National Urban Runoff Program (NURP) Study,
mg/L
100
1983
Non -Polar Oil & Grease, EPA
Review of other state's daily maximum benchmark
Method 1664 (SGT -HEM),
15
concentration for this more targeted 0&G; NC WQ
mg/L
Standard that does not allow oil sheen in waters.
pH
6-9
NC Water Quality Standard (Range)
Fact Sheet
NPDES Stormwater Permit NCS000548
Page 5
STORMWATER POLLUTION PREVENTION PLAN
The proposed permit conditions reflect the Environmental Protection Agency's (EPA) and North
Carolina's pollution prevention approach to stormwater permitting. The Division's maintains that
implementation of Best Management Practices (BMPs) and traditional stormwater management
practices that control the source of pollutants meets the definition of Best Available Technology
(BAT) and Best Conventional Pollutant Control Technology (BCT). The permit conditions are not
numeric effluent limitations but are designed to be flexible requirements for implementing site-
specific plans to minimize and control pollutants in stormwater discharges associated with the
industrial activity. Title 40 Code of Federal Regulations (CFR) §122.44(k)(2) authorizes the use of
BMPs in lieu of numeric effluent limitations in NPDES permits when the agency finds
numeric effluent limitations to be infeasible. The agency may also impose BMP requirements
which are "reasonably necessary" to carry out the purposes of the Act under the authority of 40
CFR 122.44(k) (3). The conditions proposed in this draft permit are included under the authority of
both of these regulatory provisions. In essence, the pollution prevention and BMP requirements
operate as limitations on effluent discharges that reflect the application of BAT/BCT.
Determining specific BMPs that are appropriate for the site and activities are the permittee's
responsibility and the permit strives not to limit what BMPs can be used. The permittee should also
refer to the BMPs described in both EPA's Multi -Sector Permit (MSGP) and Industrial Stormwater
Fact Sheet for Steam Electric Power Generating Facilities (Sector 0) for guidance on pollution
prevention measures.
MERCURY MONITORING REQUIREMENTS
The proposed permit requires mercury to be measured in stormwater samples by EPA Method
1631E, which can detect levels as low as 0.5 ng/L. This requirement is consistent with recent
federal rule-making that requires NPDES permittees to monitor discharges with sufficiently
sensitive test procedures approved under 40 CFR §136. Modifications to 40 CFR §122.44(i) require
a method that has a minimum level (ML) at or below the effluent limit (not applicable here), or the
lowest minimum level (ML) of EPA approved analytical methods for the measured parameter.
Based on results, Method 1631E will be required to quantify levels in these discharges. NC DEMLR
understands that this method is more costly and requires a more intensive sampling protocol than
most other parameters, and that fish tissue sampling will be provided during the permit cycle.
Therefore, no benchmark applies that would trigger tiered response actions. Proposed permit
provisions also allow the permittee to use field blank and/or method blank concentrations to adjust
reported mercury levels as long as documentation is submitted with the Discharge Monitoring
Report (DMR).
FLEXIBILITY IN TIER RESPONSES
Tier Two actions (upon two consecutive benchmark exceedances at an outfall) proposed in this
draft permit differ slightly from the Program's standard template and includes step 5. That step
provides an opportunity for the permittee to propose an alternative monitoring plan for
approval by the Region:
4. Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive exceedances,
exercise the option of contacting the DEMLR Regional Engineer as provided below in Tier
Three. The Regional Engineer may direct the response actions on the part of the permittee
as provided in Tier Three, including reduced or additional sampling parameters or
frequency.
Fact Sheet
NPDES Stormwater Permit NCS000548
Page 6
S. If pursuing the alternative above after two consecutive exceedances, the permittee may
propose an alternative monitoring plan for approval by the Regional Engineer.
The permit therefore allows the permittee to petition the Regional Office for monitoring changes
sooner than Tier Three (upon any four benchmark exceedances) and gives guidance on one option
to take. For example, the permitttee may request that mercury only be monitored semi-annually
under the tiers, or that only parameters over the benchmark be monitored more frequently. In this
way, changes to the monitoring scheme for any outfall could be handled outside of a permit
modification.
OTHER PROPOSED REQUIREMENTS
It is standard for Stormwater Pollution Prevention Plan (SPPP) requirements to include an
annual certification that stormwater outfalls have been evaluated for the presence of non-
stormwater discharges, and if any are identified, how those discharges are permitted or
otherwise authorized. The draft permit requires this facility to submit the first
certification to DEMLR no later than 90 days after the effective date of the permit
(Part II, Section A.).
Requirement to submit a request for permit modification if the facility identifies or creates
any new outfalls, removes outfalls, or alters any drainage area that changes potential
pollutants.
Proposed federal regulations will require electronic submittal of all discharge monitoring
reports (DMRs). If a state does not establish a system to receive such submittals, then
permittees must submit DMRs electronically to the Environmental Protection Agency (EPA).
The Division anticipates that these regulations will be adopted and is beginning
implementation. Permit provisions addressing this impending requirement is included in
Part III, Section B. (General Conditions), 3.e.
Quarterly Qualitative/Visual Monitoring to assure regular observation of outfalls
throughout year.
FISH TISSUE MONITORING
Proposed wastewater permit NC0003468 requires fish tissue monitoring for As, Se, and Hg near the
ash pond discharge once every five years. The proposed stormwater permit requires the permittee
to submit a copy of monitoring results to the DEMLR Stormwater Permitting Program
(Central Office) within 30 days of receiving results and indicate the location of sampling in relation
to stormwater discharge outfalls. DEMLR is requiring the fish tissue analysis results be submitted
separately because the proposed NC0003468 permit does not require submittal to DWR until
application for permit renewal.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: August 3, 2015
Permit Scheduled to Issue: October 1, 2015
STATE CONTACT:
If you have any questions about any of the above information or the attached permit, please contact
Ken Pickle at (919) 807-6376 or ken.pickle@ncdenr.gov.
Fact Sheet
NPDES Stormwater Permit NCS000548
Page 7
STORMWATER SAMPLING RESULTS FROM DAN RIVER (SUBMITTED AUGUST 2014
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Fact Sheet
NPDES Stormwater Permit NCS000548
Page 8