NC0086665_Permit Issuance_19991119

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
A Ti�
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
November 19, 1999
Ms. Starla Lacy. Environmental Specialist
Rockingham Power LLC
1000 Louisiana, Suite 5800
Houston, Texas 77002-5050
Subject: NPDES Permit Issuance
Permit Number NC0086665
Combustion Turbine Facility
Rockingham County
Dear Ms. Lacy
In accordance with the application for discharge permit received March 9, 1999, the Division
is forwarding herewith the subject state - NPDES permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the U.S. Environmental Protection Agency dated December 6, 1983.
The Division is currently developing an operator training and certification program for
physical/chemical treatment systems. This includes oil/water separators. The subject facility will be
required to employ a certified operator once the training program has been completed. You will be
contacted by the Division's Technical Assistance and Certification Unit in the future regarding this
matter.
IF any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you. you have the right to an adjudicatory hearing upon written request within thirty
(30) days following receipt of this letter. This request must be in the form of a written petition,
conforming to Chapter 150B of the North Carolina General Statutes, and filed with the office of
Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611-7447. Unless
such a demand is made, this permit shall be final and binding.
This permit does not affect the legal requirements to obtain other permits which may be
required by the Division of Water Quality or permits required by the Division of Land Resources,
Coastal Area Management Act. or any other Federal or Local governmental permits which may be
required.
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617 - TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/ 1 0% POST -CONSUMER PAPER
VISIT US ON THE INTERNET AT http://h20.enr.statc.nc.us/NPDES

if you have any questions or comments regarding these speculative limitations, please do not
hesitate to contact Mark McIntire at telephone number [phone], extension 553.
Sincerely
Original Signed By
David A. Goodrich
Kerr T. Stevens
Cc: Central Files
NPDES Permit File
Winston-Salem Regional Office, Water Quality
Technical Assistance and Certification Unit
Aquatic Toxicology Unit
EPA, Roosevelt Childress

Permit No. NC0086665
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Dynegy, Incorporated
is hereby authorized to discharge wastewater from a facility located at
Rockingham Power L.L.C.
Off of Highway 65
Reidsville
Rockingham County
to receiving waters designated as an unnamed tributary to Jacob's Creek in the Roanoke River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, II, 1II and IV hereof.
This permit shall become effective January 1, 2000.
This permit and authorization to discharge shall expire at midnight on April 30, 2002.
Signed this day November 19, 1999.
Original Signed By
David A. Goodrich
Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit No. NC0086665
SUPPLEMENT TO PERMIT COVER SHEET
Dynegy, Incorporated
is hereby authorized to:
1. Operate a treatment system. consisting of an oil/water separator and a polishing filter, at the
Rockingham Power L.L.C. combustion turbine facility located in Reidsville, Rockingham County; and
2. Discharge contact stormwater from the above mentioned treatment system and evaporative cooling
water at the location specified on the attached map into an unnamed tributary to Jacob's Creek, a class
C stream in the Roanoke River Basin.

Latitude:
Longitude:
Ouad #:
Stream Class:
Receiving Stream:
Permitted Flow:
SCALE 1:24000
36°19'42" Sub -Basin:
79°49'45"
B19SE
C
Unnamed Tributary to Jacob's Creek
Not Limited
03-02-03
D}megy, Incorporated
NC0086665
Rockingham Power Combustion Turbine Facility

A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL
Permit No. NC0086665
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number 001
- Evaporative Cooling Water and Contact Stormwater. Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
DISCHARGE LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Weekly Average
Daily Maximum
Effluent Measurement
Frequency
Sample
Type
Sample
Location'
Flow (MGD)
Monthly
See Note 1
Effluent
Total Suspended Solids
45.0 mg/L
Monthly
Grab
Effluent
Total Residual Chlorine
17 µg/L
Monthly
Grab
Effluent
Turbidity
Monthly
Grab
Effluent
Temperature2
Monthly
Grab
Effluent
Oil and Grease`'
Monthly
Grab
Effluent
EPA Methods 624/6254
Semi -Annually
Grab
Effluent
Chronic Toxicity'
Annually
Grab
Effluent
pH6
Monthly
Grab
Effluent
THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS.
NOTES:
1 Sample Locations: Effluent shall be defined as a point after combination of the evaporative cooling water and the contact stormwater prior to discharge to the unnamed tributary to
Jacob's Creek. Where no measurable discharge occurs, "no discharge" should be clearly noted on the submitted monthly discharge monitoring report. Flow may be monitored in
one of the four following ways:
a) Measure flow continuously:
b) Calculate flow based on the area draining to the outfall, the built upon area, and the total rainfall:
c) Estimate by flow measurement at 20 minute intervals during the entire discharge event: or
d) Base flow on pump logs.
2 The temperature of the effluent shall not cause the temperature of the receiving stream to increase by more than 2.8 degrees C above natural water temperature, and in no case
cause the temperature of the receiving stream to exceed 32 degrees C.
b Where possible. the grab sample for oil and grease shall be skimmed from the surface of a quiescent zone.
4 After a compliance history associated with 8 to 12 sampling events has been established. the permittee may request relaxation or deletion of this monitoring requirement.
5 Chronic Toxicity (Ceriodaphnia) @ 90% during January, April, July, and October: see Condition A(2) of this permit.
6 The pH shall not be less than 6.0 standard units or greater than 9.0 standard units.

Permit No. NC0086665
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A (2). CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 90.0%.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the
"North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent
versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February
1998) or subsequent versions. The tests will be performed during the months of January, April, July, and
October. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent
discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the
permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following
months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -
February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that
does have a detectable impairment of reproduction or survival. The definition of "detectable impairment,"
collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina
Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B for
the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent
to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Water Quality
1621 Mail Service Center
Raleigh. North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,
the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating
the facility name, permit number, pipe number, county, and the month/year of the report with the notation of
"No Flow" in the comment area of the form. The report shall be submitted to the Environmental Sciences
Branch at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will
be required during the following month.

Permit No. NC0086665
r
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS - Continued
A (2). CONTINUED...
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of
Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and modified to
include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival, minimum control organism reproduction, and appropriate environmental controls, shall
constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day
of the month following the month of the initial monitoring.

ir
MEMORANDUM
TO:
FROM:
PERMIT FILE
MARK MCINTIRE
NCDENR/DIVISION OF WATER QUALITY
WATER QUALITY SECTION/NPDES UNIT
NOVEMBER I5, 1999
SUBJECT: DYNEGY/ROCKINGHAM POWER LLC — COMBUSTION TURBINE FACILITY
NPDES PERMIT NUMBER NC0086665
ROCKINGHAM COUNTY
As is summarized in other correspondence in the permit file, a request for public hearing was received for the
above referenced facility. 1 forwarded a package summarizing public comment upwards through Division
management on September 30, 1999. 1 received that package back on November 15, 1999. The decision was
made not to hold a public meeting. As such, the NPDES permit was prepared with an issuance date of
November 19, 1999.
The information for the Authorization to Construct was reviewed and found to be satisfactory. As such, the ATC
approving installation of an oil/water separator, bag filter, and piping and appurtenances was prepared and dated
for November 19, 1999.
NOTE: David Russell of the Winston-Salem Regional Office reviewed the draft
documents and signed off on the project on August 3, 1999.
Cc: Central Files
NPDES Permit File

PAI
STATE OF NORTH CAROLINA l'
ROCKINGHAM COUNTY
David Clevenger being duly sworn, deposes and says: That he is Publisher of Media General
Newspapers, Inc. with it principal place of business located in the City of Reidsville, County of
Rockingham, State of North Carolina; that the foregoing or attached newspaper notice was published in
The Reidsville Review, once a week for 1 successive week beginning with its issue of 30th day of July
1999, and ending with its issue of 30th clay of July 1999; that Media General Newspapers, Inc. is the sole
owner and publisher of said newspaper, The Reidsville Review.
A (Affiant)
Sworn to and subscribed before me,
this the —day of
u Notary Public
My commission expires the 5th clay of March 2000
The Reidsville Review -
PO Box 2157
�r-
Reidsville NC 27323-2157 -Z
atigiSt 19

PUE 3 NOTICE
STATI OF NORTH
CA3OUNA •
ENVIRONMENTAL
MANAGEMENT
COMMISSION
POST OFFICE BOX
29535
RALEIGH, NORTH
• CAROLINA 27626-0535
NOTIFICATION OF
INTENT TO ISSUE A
STATE NPDES PERMIT
On the basis of thorough
staff review and application
3 of Article 21 of Chapter 143,
General Statutes of North
Carolina, Public Law 92-500
and other lawful standards
and regulations, the North
Carolina Fnvironmental
Management Commission
proposes to icue a permit to
discharge to the persons
listed below effective 9/13/99
and subject to special
conditions.
Persons wishing to
comment upon or object to
the proposed determinations
are invited to submit same in
writing to the above address
no later than 8/30/99. All
comments received prior to
that date will be considered
in the formulation of final
determinations regarding the
proposed permit. A public
meeting may be held where
the Director of Division of
Environmental Management
finds a significant degree of
of public interest in a proposed
permit.
A copy of the draft permit
— is available by writing or
calling the Division of
Environmental Management,
P.O. Box 29535, Raleigh,
North Carolina, 27626-0535
919-733-7015.
The application and other
information may be inspected
at theses locations during
normal office hours. Copies
of the information may -be
inspected at these locations
during normal office hours.
Copies of the information on
file are available upon request
and payment of the costs of
reproduction. All such
comments or requests
regarding a proposed permit
should make reference to
the NPDES permit number
listed below.
July 26, 1999 '
David A. Goodrick for Ken T.
Stevens, Director
Division of Environmental
MananPmant
Public notice of intent to issue
a State NPDES permit to
the following:
1. NPDES No. NC0086665.
Dynegy, Incorporate, 1000
Louisiana, Suite 5800
Houston, TX 77002 has
applied for a new permit for
a combustion turbine power
generation facility operated
by Rockingham Power LLC
located in Rockingham
County. The facility proposes
to discharge cooling water
and stomiwater from 1 outfails
into UT to Jacob's Creek, a
Class C stream in the
Roanoke River Basin which
has a 7Q 10 flow of 0 cfs and
a 30Q2 flow of 0 cfs. Although
no parameters are water
quality limited, this discharge
may affect future allocations
into the potions of the
receiving stream.
July 30, 1999

r
NCDENR/DIVISION OF WATER QUALITY
WATER QUALITY SECTION/NPDES UNIT
SEPTEMBER 30, 1999
MEMORANDUM
To: Dave Goodrich
FROM: MARK MCINTIRE 41_
SUBJECT: DYNEGY INC./ROCKINGHAM POWER LLC
NC0086665
ROCKINGHAM COUNTY
Dynegy Inc., doing business in Rockingham County as Rockingham Power, LLC, requested an NPDES permit for
a new combustion turbine facility on March 9, 1999. The pending permit is for a proposed power generation
facility utilizing five natural gas/fuel oil combustion turbines for supporting peak power demand in the
Rockingham County area. This facility is not unlike Duke Energy's Lincoln Combustion Turbine facility in Lincoln
County.
The primary fuel source for the combustion turbines is natural gas, though fuel oil can be used on an as needed
basis. Natural gas will be delivered to the site via pipeline while fuel oil will be stored on -site in two 2.25 million
gallon tanks constructed within a secondary containment structure.
The attached draft NPDES permit contains a single outfall. This outfall will discharge the following types of
wastewater:
• Evaporative cooling water; and
• Contact stormwater.
Other types of wastewater generated by this facility include turbine sump wastewater (including turbine wash
water) and domestic wastewater. The turbine sump wastewater will be hauled off -site for treatment and disposal.
Domestic wastewater will be treated and disposed of using a septic tank drain field.
On August 23, 1999, I received a phone call from Dr. Donald E Matthieu, Jr., M.D. He indicated to me that he
had concerns with the proposed power generation facility and wanted to offer comments on the draft NPDES
permit. I indicated that he should e-mail me his concerns and attach any letters he had written. I received such
an e-mail on August 24 (attached documents). In his e-mail he asked that we consider holding a public hearing
for this permit. Dr. Matthieu's comments are concerned primarily with issues related to growth, but also with
potential long-term environmental impacts such as contaminated groundwater and PCBs.

In Tight of the Unit's current staff shortage, I spent the ensuing month facilitating an effort to resolve Dr.
Matthieu's concerns outside of a public hearing. I corresponded on a frequent basis with Starla Lacy of Dynegy
and Dr. Matthieu. Much of his concern centers around information he has read on the Internet regarding natural
gas pipelines. He is concerned that mercury and PCBs will be present in the pipeline in significant
concentrations. After speaking with Starla Lacy about this, it's my impression that these constituents would be
present only in very rare cases resulting from something other than normal operation. Further, I think Dr.
Matthieu's comments may have a secondary motive, namely to curb growth and development in his community.
A new water line was laid by the county for Dynegy's use. For Dr. Matthieu, this appears to be a harbinger of
unwanted sprawl.
A public hearing for the air permit was held at Dr. Matthieu's request (hearing officer's report is attached). It is
evident from the report that most if not all of the public concern lies outside the scope of the NPDES permit as
the issues raised to me since late August have largely mirrored those presented to staff of the Division of Air
Quality at the aforementioned public hearing.
I have received agreement from Dynegy to conduct 40 CFR 122 Appendix D sampling upon startup to establish
a baseline. Thereafter, Appendix D analytical results will be provided with each application for permit renewal.
asked the facility whether or not they had considered sinking some groundwater monitoring wells on the site.
Starla Lacy indicated to me that they had considered it, but because of the cost and the small possibility of a
persistent groundwater contamination problem outside of some catastrophic event, there seemed little
justification. 1 am inclined to agree as long as the facility manages its site properly.
Based on my discussions with the public, I don't feel that a public hearing would offer any additional opportunity
for public comment. Comments received to date are not relevant to the NPDES permit. However, concessions
have been made by the facility (namely Appendix D sampling) in an effort to belay public concern.
Let me know ifyou have any questions.
Cc: NPDES Permit File

REPORT OF PROCEEDINGS
Introduction
A public hearing was held by the Department of Environment and Natural Resources,
Division of Air Quality on June 21, 1999, at 6:00 p.m. in Reidsville, North Carolina. The
hearing was conducted to obtain public comment on the proposed Prevention of Significant
Deterioration (PSD) permit for Dynegy, Inc. d.b.a. Rockingham Power, L.L.C. Power Generating
Facility, Reidsville, North Carolina.
A completed application for a permit to construct the facility was received by the
Division of Air Quality on December 28, 1998. The facility proposes to construct and operate a
new electrical power plant consisting of 5 new natural gas and fuel oil -fired simple -cycle internal
combustion turbines, two new fuel oil storage tanks and associated equipment.
A Public Notice announcing the hearing was published in the Reidsville Review and
Greensboro News and Record newspapers at least 30 days prior to the hearing.

l
HEARING RECORD AND COMMENTS
Attendees
A list of those attending the hearing follows:
Hearing Officer:
Wayne Cook, DAQ Regional Supervisor, Wilmington Regional Office
Staff Members:
Mr. Ed Martin, DAQ, Raleigh Central Office Permits Section
Mr .Charles Buckler, DAQ, Raleigh Central Office Permits Section
Mr. Jim Kinghorn, DAQ, Raleigh Central Office Permits Section
Mr. Myron Whitley, DAQ, Winston-Salem Regional Supervisor
Mr. Eric Hudson, Winston-Salem Regional Office
Members of the General Public:
Ms. Starla Lacy, Environmental Specialist, Dynegy-Rockingham Power Project
Dr. Don Matthieu, M.D., Summerfield, NC
Mr. Wayman Wheeler, Reidsville, NC
Mr. Bob Sharpe, Summerfield, NC
Ms. Pat Bush, Reidsville, NC
Mr. Brian Bush, Reidsville, NC
Mr. N.J. Owens, Reidsville, NC
Ms. Margaret S. Perkins, Reidsville, NC
Mr. Bill Stanley, Reidsville, NC
Ms. Mary K. Stanley, Reidsville, NC
Mr. Douglas J. Gels, Planner II, Rockingham County Planning Dept.
Mr. Craig Hughes, Planner, Rockingham County Planning Dept.
Ms. Faye Scearce, Planning Director, Rockingham County Planning Dept.
Mr. Richard Moore, Dynegy VP of Public Relations
Ms. Debbie Moore, Reidsville, NC
Mr. Jim Doubek, Plant Manager, Dynegy, Bakersville, CA
Ms. Claudine Doubek, Bakersville, CA
Mr. Doug Daniel, Project Engineer, Dynegy-Rockingham Power, Houston, TX
Ms. Jeanne Benedetti, Project Development, Dynegy, Houston, TX

1
Transcript of Hearing
Dynegy, Inc. Public Hearing - June 21, 1999 - 6:00 p.m.
The full record of the hearing can be heard from the Internet at:
http://internal.aq.ehnr.state.nc.us/Permits/Audio/
Eight people spoke at the public hearing. None of those who spoke opposed the project,
but all expressed a desire to have more information or clarification on the extent of the impact of
the project and subsequent development of the area. At least three commentors asked if the
company would be willing to scale back the request to burn No. 2 fuel oil (diesel) from 1000
hours per turbine per year to 500 hours. This was based on their belief that the maximum PSD
increment consumption predicted by modeling (65.9% of allowable for PM-10, 24-hour
increment) would be better protected with less allowable fuel oil.
Others expressed clarification of the modeling results or interpretation of the data. These
concerns were answered at the hearing.

r
Written Comments
The Division of Air Quality received one written letter (re -submitted at the hearing and
attached to this report). While the comments were not in opposition to the project, they did
request many studies and safeguards which are beyond the scope of the Division of Air Quality
to address. Some of those concerns however have been addressed through PSD and NSPS
monitoring and testing requirements which have appeared in the draft PSD permit.
Discussion
The only issue consistently raised at hearing was the request to limit the turbines to no
more than 500 hours per turbine while burning No. 2 fuel oil. Although the company has to burn
oil having no more than 0.047 % sulfur to meet PSD requirements for BACT, the commentors
felt that a 1000 hour limitation would not be protective enough. This argument was based on the
fact that worst case modeling using low sulfur oil still resulted in 66% of the available 24-hour
increment for PM-10 being consumed. No regulatory authority for limiting the fuel oil to 500
hours can be found. The company is unwilling to voluntarily limit fuel oil consumption to this
level.
The other issues raised at hearing were beyond the scope of the PSD permit and were
more related to secondary impacts of development in the area.
Recommendations
It is my recommendation that the PSD permit be issued to Dynegy, Inc. d.b.a.
Rockingham Power, L.L.C. Power Generating Facility.
Wayne Cook
DAQ Regional Supervisor

I5ynegy power plant NPDES permit
Subject: Dynegy power plant NPDES permit
Date: Tue, 24 Aug 1999 08:53:22 -0700
From: "Matthieu" <[e-mail]>
To: "Mark McIntire" <[e-mail]>
MM - We Bethany residents remain concerned about potential long term problems and request DENR to take every action to
assure the new plant will not become a remediation site in the future. As discussed in various attached communications,
some of the owners of Dynegy and at least two corporations which will do business with Dynegy in the Bethany area have
had significant environmental difficulties in the past. We ask for an impartial evaluation of the issues we have brought to the
attention of DENR.
We worry that groundwater will become contaminated as has happened at similar industrial facilities that use high volumes
of petroleum products. We are very concerned that repeated small spills of petroleum products and their associated additives
occurring over the life of the plant will significantly contaminate groundwater. We emphasize that some utilities (e.g., Duke
Energy and The Williams Company) have already reported problems with mercury or PCB contamination at some of their
facilities. We want assurances that such occurrences will not occur at the Duke Energy-Dynegy-Transco "complex"
consisting of Duke's transmission substation, Dynegy's duel fueled turbine generation plant, and Transco's natural gas
pipeline substation located in our community.
We also want operational procedures, quality control policies, and state -of- the -art analytical instrumentation in place to
detect contamination known to occur at these types of plants so that remedial action can be implemented quickly if problems
are identified. As discussed, groundwater monitoring wells have been used by the US EPA at some sites. It is my
understanding that instrumentation to detect PCB is also commercially available.
Thank you for your consideration and help. Please contact me if you need additional information, and please consider
holding a hearing at the Bethany Civic Center. DEM
P. S. I should have used the term "fuel oil" rather than "diesel fuel" in my 6/26/99 letter to Dr. van der Vaart.
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1 of 1 09/02/1999 9:38 AM

201 Spring Creek Road
Summerfield, North Carolina 27358
[phone]
June 26, 1999
Donald R. van der Vaart, Ph.D., P. E.
Supervisor, PSD/Title V Permitting
North Carolina Division of Air Quality
Post Office Box 29580
Raleigh, North Carolina 27626-0580
Dear Dr van der Vaart:
As Vice -Chairman of the Bethany Future Planning Committee (BFPC), I write to make certain that
concerns expressed both in my 3/28/99 letter to Mr. Clayton and in my brief oral presentation at the
6/21/99 public hearing are addressed. I am especially disturbed to learn that apparently little has
been done to investigate some of the issues first brought to DENR's attention in March.
I reiterate that neither I nor the BFPC oppose construction of the plant, but we have legitimate
doubts that proper controls will be implemented to prevent degradation of the quality of life in our
community over the long haul. Our concerns are based on the environmental records of the
industries involved, the corporate histories of some owners or former owners of Dynegy (or owners
of subsidiaries merged to form Dynegy), and the documented difficulties of some natural gas
vendors. We are also influenced by past failures of DENR to prevent major environmental problems
due to inadequate funding and staffing and because of ineffective state and local laws and
regulations that do not aggressively promote proper control of environmental pollution. We see in
Bethany what many citizens throughout North Carolina see. The quality of life in our State is
rapidly deteriorating because governmental representatives fail to acknowledge that the State's
current growth rate cannot be sustained without serious long-term detrimental consequences. We
citizens recognize that the very assets that attract individuals and corporations to North Carolina
are now being frittered away because the State lacks the necessary rules, regulations, and laws to
properly manage long-term growth for the benefit of all. We ask DENR to make a special effort
beyond what has been done in the past to assure that the generation facility soon to be permitted in
our community incorporates state of the art technology to prevent long-term environmental
problems.
Several concerns among those voiced at the 6/21/99 public hearing and those discussed in the
documents and references I have provided you need special emphasis. We again ask DENR to lower
the permitted hours for diesel fuel from 1000 hours per generator per year to 500 hours. We worry
that the proposed DENR permit creates an unreasonable and unfair incentive for Dynegy to use
diesel fuel. Spot prices for natural gas frequently rise when public utilities in the Northeast demand
more natural gas during cold winters. According to Utility Commission filings, Duke Energy by
contract can direct Dynegy to switch from natural gas to diesel fuel at times when economic
conditions warrant. We believe the switch to the alternative fuel may occur far more often than we
have been led to believe. We ask that DENR examine more carefully the financial incentives for
firing diesel fuel at the Rockingham County facility to make certain that business costs and risks are
not unfairly shifted to the public, to the Bethany community, and to the environment. It is clear to
even the lay citizen that use of diesel fuel converts a relatively clean generating facility into one that
is not. Other recently constructed generating facilities fire only natural gas. I suspect Dynegy itself
operates similar "gas only" plants. We only ask for a compromise.
Also, we do not accept Dynegy's proclamation that the oil pipeline that serves the area cannot
provide fuel directly to the site. We believe that lower delivery costs via the pipeline may eventually
serve as yet another financial incentive to use diesel fuel far more than we have been told.

We also emphatically disagree that the Dynegy plant will have minimal impact on the area. The 16-
inch water line that is being provided for the site will accelerate both residential and industrial
growth. Furthermore, we suspect that sewer lines are likely to follow in a relatively short period of
time. DENR must seriously consider the additional emissions that will most certainly occur from
growth stimulated by the new infrastructure provided for the generating plant. We ask for DENR to
reevaluate the impacts that the Dynegy plant will have on our community.
We also express concerns that Dynegy's acoustic engineering goal (<55 dBA Ldn at nearest
residences) for the new plant may not be the industry standard and ask DENR to investigate. Other
heavy industries (e.g., TransCanada PipeLines Ltd. that merged with Nova, a part owner of Dynegy)
seems to achieve noise levels of < 50 dBA Ldn at its facilities. Some states also have more stringent
noise abatement objectives. While Dynegy indicates it has no plans to operate the facility at night,
plans can change. The community would prefer to have a plant with state of the art acoustic
engineering design so that noise levels as measured during actual operation both at startup and in
the future are compatible with the community. Please understand that the 1974 US EPA "standard"
(< 55 dBA Ldn) that Dynegy seeks to achieve is an averaging metric that can be influenced by periods
of relative quiet. An unreasonably noisy plant operating only part time may produce an average
noise level that hides the true character of the problem. We also ask DENR to address in its studies
the additional noise generated by the tanker trucks that will deliver the 4. 5 million gallons of diesel
fuel.
As discussed at the hearing, we remain concerned about potential PCB problems and again formally
request that DENR make certain the present Williams Company site that will serve the new Dynegy
plant has no such natural gas pipeline contamination. If it does, we ask DENR to develop a plan to
remediate the site and to prevent any contamination from spreading to the Dynegy plant. As you
know, inadequate incineration of PCBs can produce dioxins. Dynegy has indicated that it has never
experienced any PCB problems. but I suspect some of its natural gas suppliers or distributors have.
Apparently, it is or has been a relatively common problem. Even one of Duke Energy's subsidiaries
has encountered PCB pipeline contamination (Refer to page 97 of 1997 Duke Energy annual report).
Also, be advised that, according to long time Bethany residents, spent oil from compressors was at
one time dumped into an open pit on the Williams Company (Transco) site. The practice was
stopped some years ago, the site was "cleaned up", and the contaminated soil was trucked away.
Prudence dictates that DENR investigate the site before granting a permit to allow the Dynegy plant
to go forward. There may be no problem, but we Bethany residents have a right to know what risks
and hazards we may face as yet another heavy industry is located in our rural community.
As 1 presented at the hearing, the following verbatim quotes from several recent references should
help you understand our concerns:
From recently implemented US EPA regulations (Federal Register: June 29, 1998, Volume 63,
Number 124, p.35395) addressing the manufacture, processing, distribution in commerce,
use, cleanup, storage and disposal of polychlorinated biphenyls:
"Natural gas pipeline systems. EPA has worked for several years to address PCB
contamination in natural gas pipelines and associated equipment, such as air
compressors. The reasons for the presence and movement of PCBs in gas pipelines
are not well understood, but it may have occurred through use of PCB -containing
lubricating oils in compressors, fogging of pipeline systems with PCB -containing oil
vapor, and PCB migration from contaminated natural gas pipeline systems. PCBs
primarily move with the condensate liquids that form in the pipelines. Some natural
gas pipeline systems still contain PCBs in liquid condensate despite repeated attempts
to rid the systems of PCBs. (See, for example, comments of Interstate Natural Gas
Association of America, May 1, 1995, C1-134). In response to these contamination
issues, EPA initiated a compliance monitoring program for companies with >50 ppm
PCBs in their pipelines, where EPA presumed that any pipeline showing PCB
contamination >50 ppm was contaminated along its whole length. As a result, EPA
2

has used various administrative mechanisms to declassify or decontaminate pipeline
and pipeline system components."
From the 1997 Williams Company annual report:
"Transcontinental Gas Pipeline, Texas Gas and Central have identified
polychlorinated biphenyl (PCB) contamination in air compressor systems, soils, and
related properties at certain compressor station sites. Transcontinental Gas Pipeline,
Texas Gas and Central have also been involved in negotiations with the U. S.
Environmental Protection Agency (EPA) and state agencies to develop screening,
sampling, and cleanup programs. In addition, negotiations with certain
environmental authorities and other programs concerning investigative and
remedial actions relative to potential mercury contamination at certain gas metering
sites have been commenced by Central, Texas Gas, and Transcontinental Pipe Line."
Finally, we are pleased that Dynegy voluntarily requested that DENR hold a public hearing to allow
citizen input on its project, but we are disturbed that the hearing was held in Reidsville rather than
at our own community civic center. We also wonder why Dynegy did not aggressively and
proactively seek to inform citizens about the 6/21/99 hearing as it did for an initial informational
meeting held at the Bethany Civic Center on 9/28/98. Please refer to the enclosed newspaper
announcement. No one noticed such a newspaper advertisement for DENR's public hearing on the
Dynegy PSD permit!
Thank you for your time and consideration.
cc: Mr. J. W. Pearman, Co-chairman
Bethany Future Planning Committee
Sincerely,
Donald E. Matthieu, Jr. M.D.
3

201 Spring Creek Road
Summerfield, North Carolina 27358
[phone]
March 28, 1999
Mr. Jerry Clayton
Division of Air Quality
Post Office Box 29580
Raleigh, North Carolina
Dear Mr. Clayton:
As I have discussed with you earlier, I have serious concerns about the Dynegy plant that is to be
constructed in Rockingham County a few miles North of the Guilford County line and an estimated
15 to 20 miles from the PTI airport and the proposed FedEx hub. I have previously presented much
of the enclosed information to the Rockingham County Planning Board and to the Rockingham
County Board of Commissioners in the Fall of 1998. Most of the references I cited were never
seriously discussed, studied, or considered in any way. The County indicated at one of the rezoning
hearings that it does not have the expertise to evaluate the potential environmental problems
associated with power plants and deferred essentially all responsibility for evaluation of the
proposed project to State government, to Dynegy, and to Duke Energy (Duke). While I do not
oppose the construction of the plant, I remain deeply worried that the operational impacts of
the combined natural gas and fuel oil fired turbine generating facility have not been
adequately considered and that proper management and operational tools will not be
implemented to either prevent some of the known problems that have occurred at other similar
facilities or to quickly identify and remedy difficulties that may occur in the future. As I have
documented in my enclosed letters to Rockingham County and in the references listed below, some of
the corporations that may be involved in the operation of this project (as suppliers of fuel, as
owners, as managers, etc.) have made serious errors in judgment in the past. Internet references
that are bolded may be the ones that you will find most useful to better understand my concerns;
the others relate to the ownership of Dynegy and the interconnections and relations of the various
corporations, some of which are based in Canada and in the United Kingdom.
For your understanding, the plant was originally presented to the community as a natural gas fired
600 megawatt peaking facility that would produce essentially no pollution whatsoever and that
would supply Duke's needs. In early August and again in September of 1998, I requested that
Dynegy provide our community with copies of all documents filed with State agencies so that we
might evaluate the proposal. As time progressed, the project metamorphosed into an 800 MW plant
that would use both natural gas transmitted by the Transco plant and fuel oil supplied by tanker
trucks. The facility would supply not only Duke's needs, but also other customers including some
located outside of the state. We were also told that the plant might be used for grid support and
balancing that might be needed if American Electric Power's 765 kv Wyoming -Cloverdale
transmission line is constructed. I received the requested documents for review only a few days prior
to the Planning Board rezoning hearing.
Of particular concern is the groundwater and site contamination that has occurred at some natural
gas pumping stations and electric generation facilities. The presence of PCBs (possibly due to oil
fogging with PCB contaminated oils) within some natural gas pipelines suggests that inadequate
combustion of contaminated natural gas may result in the emission of dioxins that may accumulate
in the "environmental footprint" of the facility over its estimated 25 to 50 year life span. I am not
convinced the turbines will operate (temperature and retention time) such that any PCBs that might
be present will be properly incinerated. Dynegy has denied ever having such a PCB problem at their
facilities, but as I have documented, both Duke Energy and The Williams Company have. The
nationwide interconnections between the various gas transmission pipelines make me suspicious
that PCBs may have migrated into other pipelines. including the ones that will supply the Dynegy

plant. As you may know, Transco, a subsidiary of The Williams Company, is almost next door to the
Dynegy site and will transmit natural gas to the new electric generating facility. I suspect that some
corporations may not unilaterally carefully investigate for the presence of such PCB contamination
because of the obvious financial consequences and the potential for a publicity nightmare.
Therefore, I ask the State to investigate the Transco facility to make certain that no PCB
contamination of the actual pipeline and the site has occurred. Also, if no problem exists now, I
suggest that Dynegy and/or Transco be required to establish a monitoring program to make certain
PCB contamination can be quickly detected and corrected if problems should occur in the future.
Cooperation from Transco may be required. In addition, groundwater monitoring via on -site wells
should be required so that remedial action can be quickly taken if such problems arise. The current
groundwater contamination crisis in the nearby Guilford County community of Stokesdale serves
notice that citizens who depend on private wells for their drinking water are very vulnerable. It is
much easier and less costly for the State to prevent groundwater contamination than to remediate
it. I also suggest that the State require BMP's for both Transco and Dynegy if mercury
contamination is likely. Facilities such as the ones under consideration have apparently suffered
serious mercury contamination problems in the past.
To assure adequate safety, oil tanker truck traffic (which will be significant since the 4.5 million
gallon on -site storage tanks will be serviced by truck, not by pipeline) serving the Dynegy plant must
be required to use only highways (e.g., U. S. 220, N. C. 704, N. C. 65, etc.) to access the site. No truck
traffic should be allowed on school bus routes during the morning and afternoon hours of school
bus operation. Dynegy verbally agreed to some of these requirements at a Rockingham County
Public Hearing, but I would prefer to see any such requirements placed in some type of MOA, as I
discussed in my letter to the County.
I am also concerned that all of the factors that may lead to long term air quality deterioration in our
area have not been considered. Please refer to the enclosed photograph of the plume from Duke's
Belews Creek (75,000 tons of NOx emitted annually) coal fired plant; the photo was taken from my
house that is located close to the Guilford County -Rockingham County line. Also, please review the
data cited by the Piedmont Quality of Life Coalition in its discussions about the effect of the
proposed FedEx hub at PTI airport on the region's air quality:
The 60 nightly cargo flights and 120 trucks will add 60 tons per year of VOC (volatile organic
compounds) and 200 tons per year of NOx (nitrogen oxides). VOCs and NOx are ground level
ozone precursors.
Please understand that growth exploding out of Guilford County into the Southwest quadrant of
Rockingham County where the Dynegy plant will be sited will continue to add to the numbers of
commuters who travel to and from Greensboro each day. Have you considered the additional air
pollution incurred from the increased truck and commuter traffic? Have you considered the
additional residential and industrial growth that will occur in our areas because of placement of a
16-inch water line from Reidsville to the Dynegy site and because Greensboro currently has serious
water supply problems? Also, the 501 F turbine has not as yet delivered the performance level that
has been documented in the Dynegy permit. What happens if Westinghouse does not achieve the
NOx performance levels it has quoted? Why was the GE dual fueled DLN combustors capable of 9
ppmvd NOx not chosen? Are there limits on the allowable time that the Dynegy plant may run
below baseload (when pollution is significantly greater)? If so, who will make certain the limits are
followed?
For these reasons, I ask that the State seriously consider limiting the operational permit of the
Dynegy plant to 500 hours per year for fuel oil (rather than the requested 1000 hrs). It is clear that
use of fuel oil converts a relatively clean burning plant into one that is not. Furthermore, since SO2
emissions will be controlled within allowable limits by using fuel oil with a very small percentage
decrease in its sulfur content (.050% to.047%) as originally proposed and by limiting heat input,
accurate, precise, and frequent analytical certification of the fuel oil sulfur content and heat input
should be mandatory.
2

Noise concerns are probably the least serious because no residential areas are presently close to the
relatively secluded site. However, I point out that owners of undeveloped property that abuts on the
Dynegy site may not agree if the noise level ultimately devalues their property. 1 have not been able
to review the noise data collected by Dynegy, but at one Public Hearing, a chart was shown that
purported to show about 51 dB Ldn as the typical noise level in a residential area. The predicted
noise level of the Dynegy plant at the nearest residence was also expected to be <55dBA or around
51 dBA. I assume the quoted values represent Ldn values, but it is not clear from the documents
available to me. I am worried that the acoustic engineering design of the Dynegy plant may not
have been conducted as carefully and professionally as that described in the two internet references
(under "Noise"). I also point out that Dynegy's standard of acceptability (55 dB Ldn) was taken from
a 25 year old study that was not intended to serve a regulatory function. Furthermore, the same
study states the following:
Most Americans live in areas with a much smaller range of outdoor noise levels. Figure 5
shows that for urban dwellers (roughly 135 million people, more than half of the U. S.
population), 87% live in areas of Ldn = 48 and higher from traffic noise alone. Most of the
other 13% of the urban population experience lower noise levels than those of Figure 5.
Figure 5 also shows that nearly half of the urban population lives in areas exposed to traffic
sounds that range over only 5 dB (Ldn = 55 to 60 dB). Rural populations enjoy average
outdoor sound levels generally lower than Ldn = 50dB.
I wonder if an Ldn of < or = 50 dB should be considered for the Dynegy plant?
Thank you for your time and consideration.
Sincerely,
Donald E. Matthieu, Jr. M.D.
cc: Mr. J. W. Pearman, Co-chairman
Bethany Future Planning Committee
Topics and Websites
Dynegy
http://www.sec.gov/Archives/edgar/data/879215/0000899243-98-000507.txt 1997 annual report of NGC
Corporation (now Dynegy, Inc.). Use find command to locate "The Company", and read about the
various mergers of subsidiaries of Nova, Chevron, and British Gas.
htty://www.sec.gov/Archives/edgar/data/879215/0000899243-98-000507.txt 1997 annual report of NGC
Corporation (now Dynegy, Inc.). Use find command to locate "Environmental matters", and read
about permitting costs and environmental monitoring and remediation costs.
http://www.sec.gov/Archives/edgar/data/866282/0000912057-97-010480.txt 1996 annual report of Destec Energy,
Inc. indicates Dow Chemical once owned portions of the company now know as Dynegy. Use find
command to locate "Overview".
3

http://www.sec.gov/Archives/edgar/data/1066165/0000899243-98-001430.txt Use find command to locate
"Guaranteed as set forth". and read about Dynegy Capital Trust II
http://www.chevron.com/about/aas liauid/main.html NGC Corporation (now Dynegy) merged with Chevron's
Natural Gas Business Unit and Chevron's Warren Petroleum Company.
http://www.sec.gov/Archives/edgar/data/93410/0000093410-97-000004.txt 1996 annual report of Chevron. To
see more about Warren Petroleum Company. use find command to locate "Warren".
http://www.nova.ca/vress/012296.htm NGC Corporation (now Dynegy) and Chevron negotiate merger.
http://www.nova.ca/press/031695.htm Nova Corporation affiliate, Natural Gas Clearinghouse, merged
with Trident NGL of Woodlands. Texas to create the new company. NGC Corporation.
http://www.thestandard.net/comvanies/comvanv display/0.1223.40335.00.htm1 NGC Corporation subsidiaries
listed before name change to Dynegy, Inc.
The Williams Company
http://www.triadbusiness.com/pipeline.html Discusses the Transco pipeline plant on NC 65 that now has
fifteen compressors to move the natural gas.
http://www.sec,gov/Archives/edgar/data/107263/0000950134-98-002643.txt Use find command to locate
"Expansion Projects", and read about the Pine Needle Liquefied Natural Gas Company (jointly owned
by Transco and several major customers including Piedmont Natural Gas) that is building a four Bcf
(billion cubic feet) liquefied natural gas storage facility along NC 68 between Stokesdale and
Oakridge.
http://www.twc.com/97annual/ncfs2.htm 1997 annual report of The Williams Company with discussion
about PCB and mercury contamination at Transco sites. Use find command to locate
"Environmental matters".
http://www.twc.com/95annul/$conl7sm.html 1995 annual report of The Williams Company. Use find
command to locate "Environmental matters". Both Transco and Texas Gas subsidiaries of The
Williams Company have studies underway in 1995 to test facilities for toxic and hazardous
substances.
Chevron
http://www.sec.gov/Archives/edgar/data/93410/0000093410-98-000003.txt 1997 annual report of Chevron.
Use find command to locate "Environmental protection", "superfund", or "PRP" to see Chevron's past
history.
Nova
http://www.nova.ca/vcr/redunatl.htm Nova describes some of its operations that include routine venting
of natural gas. See "engineered" leaks, "fugitive" emissions, hydrogen sulfide analysis, natural gas
composition testing, orifice plate inspection, dew point testing, etc., that result in natural gas
release to the atmosphere.
http://www.sec.gov/Archives/edgar/data/879215/0000929624-98-001440.txt 8/24/98 report of Nova filed with
Securities and Exchange Commission describing intent to sell its stake in Dynegy. Use find command
to locate "July 2".
Duke Energy
http://www.sec.gov/Archives/edgar/data/30371/0000950168-98-000916.txt 1997 annual report of Duke
Energy. Use find command to locate "polychlorinated" on pages 25 and 52, and read about Duke's
4

PCB problems at Texas Eastern Transmission Corporation (TETCO), Panhandle Eastern Pipe Line
Company (PEPL), and Trunkline Gas Company (Trunkline) natural gas pipeline compressor station
sites. Notice that on- and off -site assessment, installation of on -site source control equipment,
and groundwater monitoring wells have been required. See also superfund site discussion on
page 25.
http://www.epa.gov/airs/rvt3ono2.gif Duke's Belews Creek station has been ranked by the US EPA as the
seventh most polluting power plant for NOx in the United States at 75,000 tons per year.
Mercury
http://www.anachem.umu.se/aas/mercurv.htm From a Swedish university chemistry department
http://www.twc.com/97annual/ncfs2.htm About potential mercury contamination of Transco gas
metering sites as stated in The Williams Company 1997 annual report. Use find command to locate
"mercury contamination".
http://www.ari.orq Gas Research Institute home page. Search under the category "mercury, natural
gas pipe" for 300 + technical bulletins dealing with mercury contamination. Use the find command
to locate "mercury" in several technical bulletins discussing mercury problems associated with
natural gas pipelines.
http://www.epa.gov/oar/merwhite.html US EPA summary of Mercury Study Report to Congress
http:I/www.twc.com/97annual/ncfs2.htm 1997 annual report of The Williams Company with discussion
about potential mercury contamination at Transco sites. Use find command to locate
"Environmental matters".
PCB history (polychlorinated biphenyls)
List of Rachel's Hazardous Waste News articles on PCB history and toxicity. Select the following four
websites for interesting discussions about PCBs.
1. r856: rehw144: Thanks to Monsanto [PCBsj
2. r829: rehw171: Dioxins And Cancer: Fraudulent Studies
3. r705: rehw295: As The Story Of PCBs Unfolds
4. r673: rehw327: The History Of Chlorinated Diphenyl 'PCBs)
5. r671: rehw329: Who is Responsible For PCB Mess?
PCB and Dioxin (includes health effects)
http://www.epa.gov/oamsrpod/medlin/hg9814204/pcb.txt Use find command to locate "Unreasonable Risk
Standard".
http://www.cnie.org/nle/pest-7.html 1995 Congressional Research Report on Dioxin.
http://www.apo.ucon.edu Nowselect `database by title'; then select "GAO reports" under "scroll to view
list of titles" and click on "select"button. Next, under 'access to full text'; select "search this
database': then under '"search full -text on word or phrase'; type in "dioxin'," and click the "run
search "button. Finally, select option I = JRCED-96-131 Superfund: EPA Has Identified Limited Alternatives To
Incineration for Cleaning Up PCB And Dioxin Contamination Use find command to search on "incineration"
or "dioxin and polychlorinated biphenyls contamination".
PCBs associated with natural gas pipelines
http://www.epa.qov/pcb EPA PCB site.
http://www.gri.orq Gas Research Institute home page. Search under the category "PCB, natural gas
pipe" (PCB is case sensitive) for 50 + technical bulletins dealing with PCB contamination and natural
5

gas pipelines! Use the find command to locate the following four topics (in the 50 + technical
bulletin list) related to PCB natural gas pipeline contamination:
1. gas transmission
2. contaminated
3. PCB migration
4. PCB removal
http://www.gascave.org/index%20/PCB%201NDEX.html The entire gascape.org website may be reviewed for
information related to PCBs associated with natural gas use.
http://www.gascape.orq/index%20/PCB%20Work%20at%20Penn%20State%2011ni.html PCB Work at Penn State
University briefly describes the PCB problem in natural gas pipelines.
http://www.gascape.orq/index%20/PCB's%20in%2ONatural%2OGas.html PCB'S in Natural Gas also discusses
PCB problem in natural gas pipelines. Use find command to locate "fogging", and read about oil
fogging of pipelines with PCB contaminated oil in the past.
http://www.psig.org/Conf-1993.html October 1993 "industry pipeline conference" agenda shows professors
from Pennsylvania State University and from the University of Tulsa discuss PCB migration in
natural gas pipelines.
Potential asbestos problems in natural gas pipelines
http://www.ari.orq Gas Research Institute home page. Search under the category "asbestos, natural
gas pipe". Use the find command to locate "asbestos" in multiple technical bulletins discussing
asbestos within natural gas pipelines.
Natural gas pipeline
http://www.epa.qov/oamsrpod/medlin/ha9814204/pcb.txt EPA PCB "mega rule". Use find command to locate
"Natural gas pipeline systems".
http://www.aga.org/naturalgas/well2bur.html Brief description of how natural gas pipelines work.
Interconnection of pipeline systems and supply
http://www.epenergy.com/epng/bullet/tgp.htm List of customers of Tennessee Gas Pipeline, a business unit of El
Paso Energy Corp, includes Duke, Piedmont Natural Gas, and many others from Louisiana to the
New England states.
http://www.epa.qov/docs/epairnallfal194/02.txt.html Use find command to locate "PCB " and to find that
Tennessee Gas Pipeline was fined $6.4 million for PCB violations.
http://www.aasandoil.com/aoc/company/cnn75057.htm NGC Corporation (now Dynegy) contracts for 1.3
billion cfpd of capacity from El Paso Natural Gas. El Paso Gas owns Tennessee Gas Pipeline.
http://www.gasandoil.com/gocicompanv/cnn74319.htm Subsidiaries of NGC Corporation, Chevron, and
others join forces. Note that Duke's TETCO pipelines (with past PCB problems) may be used.
http:/lwww.sec.aov/Archives/edgar/data/107263/0000950134-98-002643.txt Use find command to locate
"MarketLink", and read about Transco's plans to provide the final link for several pipeline projects to
transport western gas supplies to eastern markets.
New 6/29/98 EPA PCB "mega rule"
6

http://www.epa.Qov/oamsrpod/medlin/ha9814204/pcb.txt Entire EPA PCB "mega rule" from Federal Register.
Use find command to locate "fogging", and read about oil fogging of pipelines with PCB
contaminated oil in the past.
http://www.aga.org/aboutaaa/aboutaga.html Select search and search under the category "PCB" to see
multiple brief summaries of the PCB problem and the "mega rule" from the perspective of the natural
gas industry.
Natural gas
http://www.nwng.com/a bout us/science/msds.html Material safety data sheet (MSDS) of natural gas.
Explosions and fires
http://www.mostnewyork.com/1998-10-11/News and Views/City Beata-7605.asv A transformer fire in New York
exposed dozens of firefighters and utility employees to dangerous PCB levels.
Noise
http://www.aulfpub.com/nlq/pla.html Select Archive, then July, 1998, and then scroll down to article
entitled "Careful Design and Evaluation Required to Reduce Station Noise", and select. A program to
control sound in a proposed plant must properly identify acoustic goals, must clearly define noise
control specifications and must establish clear acoustic measurement procedures to evaluate
acoustic performance.
http://www.gulfpub.com/plq/plg.html Select Archive, then September, 1998, and then scroll down to
article entitled "TransCanada Implements Strict Acoustic Standards for Stations", and select. To
meet regulations and target noise levels, requires investigation of all noise sources and planning for
noise reduction before construction begins.
http://www.nonoise.orallibrarv.htm Use find command to locate "Protective Noise Levels" and select to view a
condensed version of US EPA's 1974 Levels document on noise.
7

October 21, 1998
Clarence Tucker, Chairman
Rockingham County Board of Commissioners
Rockingham County Governmental Center
371 NC 65
Wentworth, North Carolina 27375
Dear Mr. Tucker and other Members of the Board of Commissioners:
1 have enclosed for your consideration a copy of a document presented to the Planning Board on
10/20/98. The County must take action now to assure problems do not occur in the future in the
Dynegy/Duke/Transco plant areas of the Bethany community. Please understand that Dynegy, Inc. is
a multinational corporation that is majority owned by companies who have exhibited significant
operational problems in the past. Also, remember that Dynegy Power, Inc. was at one time owned by
Dow Chemical Company. The natural gas burned in the turbine generators may be supplied by
companies and gas pipelines that have incurred problems similar to those described by industry
experts, industry associations, and the US EPA. While corporate relationships do not necessarily
indicate problems will occur, prudence dictates that the County should proactively address in a
formal manner the environmental issues discussed in the listed website references. A memorandum
of agreement (MOA) negotiated with Duke Energy, Transco, and Dynegy may be necessary. Such
MOAS might assure that the corporations make every effort to prevent groundwater and surface
contamination while operating in the Bethany area. In similar situations in other areas of the
country. corporations have installed onsite monitoring equipment and groundwater monitoring
wells. Others have performed onsite/offsite assessments and cleanups to identify and remediate
environmental contamination. I believe both Duke Energy and The Williams Company have
experience in managing these types of problems.
The Dynegy plant will most certainly pollute; various State and Federal agencies will license it to do
so. I suspect that the plant will burn far more fuel oil than we have been led to believe if the spot
price of natural gas rises as it often does in the winter. The amount of pollution increases
drastically if the proposed plant uses fuel oil rather than natural gas. So that you may better
understand the level of pollution that we may expect, I have listed below information taken from
directly one of Dynegy's preliminary filings with the North Carolina Department of Environment,
Health, and Natural Resources (Division of Air Quality). The air pollution levels listed are the worst
case scenarios. The identities of the 45 to 493 tons of the various volatile organic compounds that
will be discharged into the air annually are not given.
I emphasize that the County is obligated by law (e.g.. general "police powers" and planning and
zoning authority under G. S. Chapter 153A) to protect the public health, safety, and general welfare.
Action can and must be taken by local government; we cannot and must not rely on State
government or the US EPA to think for us. As an example I cite various Federal and State agencies
and concerned officials that have been working "to solve" the "PCB problem" at least 30 years! As
you should know, it is far cheaper over the long haul to prevent rather than to remediate
environmental problems.
Please distribute copies of the enclosed document to all members of the Board of Commissioners for
their understanding and consideration.
As a separate issue, 1 am especially intrigued to find that Dynegy has filed a 10/1/98 Certificate of
Need with the N. C. Utilities Commission in Raleigh that includes the following discussion about
water supply for their plant site:

"At the present time, municipal potable water supplies are not available to the property
owners in the vicinity of the Site, and therefore they rely on private wells for potable
supplies, as well as septic system for sanitary disposal. Negotiations are currently
underway with Rockingham County with respect to potential provision of municipal
water and sewage disposal lines to the Site. Current plant design assumes the provision
of those facilities."
Mr. Tucker, are you aware of the negotiations to which Dynegy refers?
Thank you for your time.
Sincerely,
Donald E. Matthieu, Jr. M.D.
Bethany
Air Emissions of Proposed Dynegy Plant
Pollutant
Natural gas
alone ears per
Natural gas & fuel
oil tons per year'
Sulfur dioxide
SO2)
15
240
Particulate matter
(10u)
45
92 - 109
Nitrogen oxides
(NOx)
780 - 10352
1255 - 1425
Carbon monoxide
(CO)
780 - 1260
1053 - 2053
Volatile organic
compounds
(VOCs)
45
78 - 493
Lead
(Pb)
0
0.25
Beryllium
(Be)
0
0.013
Mercury
(Hg)
0
0.03
1. One ton is 2000 pounds.
2. Ranges indicate emissions are variable and depend on the operational efficiency of the plant during a given time
period.
2

October 20, 1998
The Dynegy Rezoning Decision Must Be Delayed
The listed websites and associated brief comments provide substantial additional information
dealing with potential health and safety concerns that must be reviewed by the Planning Board
before rezoning the property in question. As you know, North Carolina general statutes that enable
County planning and zoning regulatory actions do so under the so-called general police powers to
protect the public health, safety, and welfare. Therefore, the Planning Board must carefully
examine current information on significant potential health and safety issues as discussed by experts
in the electric generation and gas pipeline industries, by the US EPA, and by industry associations.
Please understand that The Williams Company owns the pumping station that will supply natural
gas to the combustion turbine generation plant that will sell electricity to Duke Energy. Also,
remember that Dynegy is ultimately majority owned by Chevron, BG plc, and Nova. BG plc and Nova
are both corporations that are based in foreign countries. Nova has announced its intent to sell its
ownership stake in Dynegy; the new owner remains unknown. Williams, Duke Energy, and Chevron
all have been involved in multiple environmental catastrophes as documented in their respective
annual reports submitted to the Securities and Exchange Commission. Millions of dollars have been
spent and will be spent by all three corporations to remedy errors in judgment.
In the presentation at the Bethany Civic Center, Dynegy has offered little or no discussion on the
potential environmental and health problems that may be associated with the operation of a
natural gas generation plant. Prudence dictates that the County Planning Board must delay
rezoning the property for the proposed Dynegy plant site until concerned citizens have had ample
opportunity (at least three full weeks) to review Dynegy's recent voluminous required filings with
State agencies as well as other sources of information. In addition, Dynegy should make additional
Public presentations to residents of the Bethany area to address possible solutions to the potential
problems discussed in the references listed below. Duke Energy and Transco should also make Public
presentations at the same meetings.
Topics and Websites
Dynegy
http://www.sec.aov/Archives/edgarldata/879215/0000899243-98-000507.txt 1997 annual report of NGC
Corporation (now Dynegy, Inc.). Use find command to locate "The Company", and read about the
various mergers of subsidiaries of Nova, Chevron, and British Gas.
http://www.sec.gov/Archives/edgar/data/879215/0000899243-98-000507.txt 1997 annual report of NGC
Corporation (now Dynegy, Inc.). Use find command to locate "Environmental matters". and read
about permitting costs and environmental monitoring and remediation costs.
http://www.sec.gov/Archives/edgar/data/866282/0000912057-97-010480.txt 1996 annual report of Destec Energy,
Inc. indicates Dow Chemical once owned portions of the company now know as Dynegy. Use find
command to locate "Overview".
http://www.sec.gov/Archives/edgar/data/1066165/0000899243-98-001430.txt Use find command to locate
"Guaranteed as set forth", and read about Dynegy Capital Trust II
http://www.chevron.com/about/aas liquid/main.html NGC Corporation (now Dynegy) merged with Chevron's
Natural Gas Business Unit and Chevron's Warren Petroleum Company.
http://www.sec.gov/Archives/edgar/data/93410/0000093410-97-000004.txt 1996 annual report of Chevron. To see
more about Warren Petroleum Company, use find command to locate "Warren".

http://www.nova.ca/press/012296.htm NGC Corporation (now Dynegy) and Chevron negotiate merger.
http://www.nova.ca/vress/031695.htm Nova Corporation affiliate, Natural Gas Clearinghouse, merged
with Trident NGL of Woodlands, Texas to create the new company, NGC Corporation.
http://www.thestandard.net/companies/company display/0.1223,40335.00.html NGC Corporation subsidiaries
listed before name change to Dynegy, Inc.
The Williams Company
http://www.triadbusiness.com/pipeline.html Discusses the Transco pipeline plant on NC 65 that now has
fifteen compressors to move the natural gas.
http://www.sec.gov/Archives/edgar/data/107263/0000950134-98-002643.txt Use find command to locate
"Expansion Projects". and read about the Pine Needle Liquefied Natural Gas Company (jointly owned
by Transco and several major customers including Piedmont Natural Gas) that is building a four Bcf
(billion cubic feet) liquefied natural gas storage facility along NC 68 between Stokesdale and
Oakridge.
http://www.twc.com/97annual/ncfs2.htm 1997 annual report of The Williams Company with discussion
about PCB contamination at Transco sites. Use find command to locate "Environmental matters".
htto://www.twc.com/95annul/$con17sm.html 1995 annual report of The Williams Company. Use find
command to locate "Environmental matters". Both Transco and Texas Gas subsidiaries of The
Williams Company have studies underway in 1995 to test facilities for toxic and hazardous
substances.
Chevron
http://www.sec.gov/Archives/edgar/data/93410/0000093410-98-000003.txt 1997 annual report of Chevron. Use
find command to locate "Environmental protection", "superfund", or "PRP" to see Chevron's past
history.
Nova
http://www.nova.ca/vcr/redungtl.htm Nova describes some of its operations that include routine venting of
natural gas. See "engineered" leaks, "fugitive" emissions, hydrogen sulfide analysis. natural gas
composition testing. orifice plate inspection, dew point testing. etc., that result in natural gas
release to the atmosphere.
http://www.sec.gov/Archives/edgar/data/879215/0000929624-98-001440.txt 8/24/98 report of Nova filed with
Securities and Exchange Commission describing intent to sell its stake in Dynegy. Use find command
to locate "July 2".
BG plc (British Gas)
http://www.baplc.com/databooWusa.html BG, plc holds about 25% of the shares of Dynegy, Inc. (formerly
NGC Corporation).
Duke Energy
http://www.sec.gov/Archives/edgar/data/30371/0000950168-98-000916.txt 1997 annual report of Duke Energy.
Use find command to locate "ENVIRONMENTAL" on page 25, and read about Duke's PCB problems at
Texas Eastern Transmission Corporation (TETCO), Panhandle Eastern Pipe Line Company (PEPL), and
Trunkline Gas Company (Trunkline) natural gas pipeline compressor station sites. See also
superfund site discussion on page 25.
Mercury
http://www.anachem.umu.se/aas/mercurv.htm From a Swedish university chemistry department
2

httv://www.twc.com/97annual/ncfs2.htm About potential mercury contamination of Transco gas metering
sites as stated in The Williams Company 1997 annual report. Use find command to locate "mercury
contamination".
http://www.ciri.orq Gas Research Institute home page. Search under the category "mercury, natural
gas pipe" for 300 + technical bulletins dealing with mercury contamination. Use the find command
to locate "mercury" in several technical bulletins discussing mercury problems associated with
natural gas pipelines.
PCB history (polychlorinated biphenyls)
List of Rachel's Hazardous Waste News articles on PCB history and toxicity. Select the following four
websites for interesting discussions about PCBs.
1. r856: rehw144: Thanks to Monsanto (PCBs'
2. r829: rehw171: Dioxins And Cancer: Fraudulent Studies
3. r705: rehw295: As The Story Of PCBs Unfolds
4. r673: rehw327: The History Of Chlorinated Diphenvl IPCBsl
5. r671: rehw329: Who is Responsible For PCB Mess?
PCB and Dioxin (includes health effects)
http://www.epa.gov/oamsrpod/medlin/ha9814204/pcb.txt Use find command to locate "Unreasonable Risk
Standard".
htty://www.cnie.org/nle/pest-7.html 1995 Congressional Research Report on Dioxin.
http://www.gpo.ucop.edu Nowselect 'database by title'; then select 'GAO reports" under "scroll to view
list of titles" and click on "select" button. Next, under 'access to full text'; select "search this
database'; then under "search full -text on word or phrase'; type in 'dioxin '; and click the "run
search "button. Finally, select option 1 = JRCED-96-131 Superfund: EPA Has Identified Limited Alternatives To
Incineration for Cleaning Up PCB And Dioxin Contamination Use find command to search on "incineration" or
"dioxin and polychlorinated biphenyls contamination".
PCBs associated with natural gas pipelines
http://www.epa.gov/pcb EPA PCB site.
http://www.aaa.com/qio/membmatters/advocacvlist.html Notice that a poll of American Gas Association
members indicates PCBs are one of the high priority environmental "advocacy issues".
http://www.gri.orq Gas Research Institute home page. Search under the category "PCB, natural gas
pipe" (PCB is case sensitive) for 50 + technical bulletins dealing with PCB contamination and natural
gas pipelines! Use the find command to locate the following four topics (in the 50 + technical
bulletin list) related to PCB natural gas pipeline contamination:
1. gas transmission
2. contaminated
3. PCB migration
4. PCB removal
http://www.gascape.ora/index%20/PCB%20INDEX.html The entire gascape.org website may be reviewed for
information related to PCBs associated with natural gas use.
http://www.gascape.org/index%20/PCB%20Work%20at%20Penn%20State%20Uni.html PCB Work at Penn State
University briefly describes the PCB problem in natural gas pipelines.
http://www.aascape.org/index%20/PCB's%20in%2ONatural%2OGas.html PCB'S in Natural Gas also discusses PCB
problem in natural gas pipelines.
3

http://www.psig.ora/Conf-1993.html October 1993 "industry pipeline conference" agenda shows professors
from Pennsylvania State University and from the University of Tulsa discuss PCB migration in
natural gas pipelines.
Potential asbestos problems in natural gas pipelines
http://www.gri.orq Gas Research Institute home page. Search under the category "asbestos, natural
gas pipe". Use the find command to locate "asbestos" in multiple technical bulletins discussing
asbestos within natural gas pipelines.
Natural gas pipeline
http://www.epa.qov/oamsrpod/medIin/hg9814204/pcb.txt EPA PCB "mega rule". Use find command to locate
"Natural gas pipeline systems".
http://www.aaa.com/gio/well2bur.html Brief description of how natural gas pipelines work.
Interconnection of pipeline systems and supply
http://www.sga-aso.com/SGA/HOT/hot7.html Tennessee Gas Pipeline, a business unit of El Paso Energy
Corp., will build a interconnection to deliver 200 MMcfd to Texas Eastern Transmission Company's
system (TETCO) owned by Duke Energy.
http://www.epa.qov/docs/epairnal/fa1194/02.txt.html Use find command to locate "PCB " and to find that
Tennessee Gas Pipeline was fined $6.4 million for PCB violations.
http://www.gasandoil.com/qoc/companv/cnn75057.htm NGC Corporation (now Dynegy) contracts for 1.3
billion cfpd of capacity from El Paso Natural Gas. El Paso Gas owns Tennessee Gas Pipeline.
http://www.gasandoil.com/goc/company/cnn74319.htm Subsidiaries of NGC Corporation, Chevron, and
others join forces. Note that TETCO pipelines may be used.
http://www.secgov/Archives/edgar/data/107263/0000950134-98-002643.txt Use find command to locate
"MarketLink", and read about Transco's plans to provide the final link for several pipeline projects to
transport western gas supplies to eastern markets.
New 6/29/98 EPA PCB "mega rule"
http://www.epa.gov/oamsrpod/medlin/ha9814204/pcb.txt Entire EPA PCB "mega rule" from Federal Register.
http://www.infoinc.com/newaio/aio/ag8 98roi.html American Gas Association article commenting on new
EPA PCB "mega rule".
http://www.aga.com/gio/pr114.html American Gas Association article commenting on new EPA PCB "mega
rule"
Natural gas
http://www.nwng.com/about us/science/msds.html Material safety data sheet (MSDS) of natural gas.
Explosions and fires
http://www.aaa.com/aio/ag9news.html Use find command to locate "Indiana".
http://www.mostnewvork.com/1998-10-11/News and Views/Citv Beat/a-7605.asp A transformer fire in New York
exposed dozens of firefighters and utility employees to dangerous PCB levels.
4

MEMORANDUM
6'PA �jT1
NCDENR/DIVISION OF WATER QUALITY
WATER QUALITY SECTION/NPDES UNIT
JULY I S, 1999
DAVID RUSSELL
WINSTON-SALEM REGIONAL OFFICE
I MARK MCINTIRE 12'4j-z---
DWQ— NPDES UNIT
SUBJECT: DRAFT NPDES PERMIT
DYNEGY, INC./ROCKINGHAM POWER LLC — NC0086665
ROCKINGHAM COUNTY
Attached is a copy of the draft permit for the proposed combustion turbine facility in Rockingham County.
Please forward any comments to me atyour earliest convenience.
Thanks so much foryou help.
i
0 d 1
DENR - WATER QUALITY
POINT SOURCE BRANCH
DUE DATE 54 3 9

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0086665
Facility Information
Applicant/Facility Name:
Dynegy, Inc. — d.b.a. Rockingham Power LLC
Applicant Address:
1000 Louisiana. Suite 5800. Houston. TX 77002-5050
Facility Address:
240 Ernest Drive, Reidsville, NC 27320
Permitted Flow
No Limit
Type of Waste:
100% Industrial — Evaporative Cooling Water ? Stormwater
Facility/Permit Status:
New/Proposed
County:
Rockingham
Miscellaneous
Receiving Stream:
LIT to Jacob Creek
Regional Office:
Winston-Salem
Stream Classification:
C
USGS Topo Quad:
B 19SE
303(d) Listed?:
NO
Permit Writer:
Mark McIntire
Subbasin:
03-02-03
Date:
July 8, 1999
Drainage Area (mi2):
NA
Summer 7Q 10 (cis)
NA
Winter 7Q10 (cfs):
NA
Average Flow (cfs):
NA
IWC (%):
100%
Primary SIC Code:
491 1
SUMMARY
Dynegy. Incorporated out of Houston. Texas has applied for a new discharge permit for a combustion
turbine power plant to be located in the City of Reidsville and operated by Rockingham Power L.L.C.
This facility will be similar to the Lincoln Combustion Turbine facility operated by Duke Power under
permit number NC0080781. Power will be generated by 5 combustion turbines using natural gas as
a primary fuel and distillate fuel oil as a backup. The five turbines will generate a total of 800
megawatts of electricity.
Each combustion turbine will be equipped with an evaporative cooling water system. These systems
will be used to cool the combustion turbine inlet air. As the inlet air passes through the evaporative
cooler. water is evaporated into the air stream, reducing the air temperature and improving the
performance and efficiency of the turbine. Evaporative cooling is most effective during periods of low
relative humidity (water won't evaporate when the relative humidity is too high). During periods of
high relative humidity. such as at night and early morning, the effect of evaporative cooling is
reduced. Also, at temperatures below 45° F. ice crystals can form causing damage to the turbine.
Therefore. the evaporative cooling system will only be used during the warmer months. Although the
evaporative cooling water will be recirculated, some water must be removed to prevent solids
precipitation. The evaporative cooling water not recirculated will be discharged (19,200 gallons per
day maximum) to the receiving stream.
The evaporative coolers will utilize water provided by the City of Reidsville via pipeline. This water
will be demineralized using portable ion exchangers. These exchangers, once exhausted, will be
regenerated off -site. Therefore, no regeneration wastewater will be present in this facility's
wastewater. However, because of the potential for residual chlorine to be present in the city water
used for cooling. a 17 µg/L limit and monthly sampling have been installed.
Rockingham Power LLC Fact Sheet
NPDEti Permit \umber NC00S6665
Page 1

Turbine sump wastewater. including turbine wash water. component leakage. etc.. will be pumped to
a tanker and hauled off -site for treatment and disposal. Domestic wastewater will be treated and
disposed of using a septic tank drain field.
The only other wastewater generated by this facility will be so-called contact stormwater. The facility
will operate two 2.25 million gallon fuel oil tanks housed in a secondary containment structure.
Stormwater collected from the secondary containment structure, stacks, turbines, mechanical
packages, diesel driven fire pump area. fuel oil unloading area, main step-up transformers and
auxiliary transformers will be routed through a stormwater treatment system. This system will
comprise an oil/water separator and a particulate filter. Authorization to Construct this system will
be issued concurrently with the NPDES permit.
The contact stormwater generated by this facility will likely be quite similar to discharges from oil
terminal facilities. As such, the permitting strategy for oil terminal discharges has been used
extensively in the development of this permit. Additionally, parameters typical to cooling water
discharges such as turbidity and temperature have been added. I requested analytical data from a
similar discharge and was subsequently provided the results of an EPA 624/625 scan conducted on
the effluent from a similar combustion turbine facility in Georgia operated by Dynegy. The results of
that scan were excellent. As such, I have included a footnote regarding the potential elimination of
the 624/625 monitoring requirement after a compliance history has been established.
En engineering alternatives analysis was provided with the permit application illustrating that surface
water discharge is the most cost effective alternative. In light of the type of wastewater to be
discharged, this facility will likely have little to no impact on the water quality of the receiving stream.
TOXICITY TESTING:
24-hour Episodic Acute Monitoring using Fathead Minnow; the facility will conduct five episodic
toxicity tests before changing the test condition to annual.
COMPLIANCE SUMMARY:
None; this is a new permit.
INSTREAM MONITORING:
Non(
PROPOSED CHANGES:
None; this is a new permit.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: July 28. 1999
Permit Scheduled to Issue: September 13, 1999
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please contact
Mark Mclntire at [phone] ext. 553.
Rockingham Pcn'er LLC Fact Sheet
NPDES Permit \umber \COOS666S
Page 2

REGIONAL OFFICE COMMENT:
NAME: CD& I
ton-h-
DATE:
Rockingham Power LLC fat Sheet
\PLIES Permit \umber \C008666=3
Page 3

Permit No. NC0086665
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Dynegy, Incorporated
is hereby authorized to discharge wastewater from a facility located at
Rockingham Power L.L.C.
Off of Highway 65
Reidsville
Rockingham County
to receiving waters designated as an unnamed tributary to Jacob's Creek in the Roanoke River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, II, III and IV hereof.
This permit shall become effective
This permit and authorization to discharge shall expire at midnight on April 30, 2002.
Signed this day
Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit No. NC0086665
SUPPLEMENT TO PERMIT COVER SHEET
Dynegy, Incorporated
is hereby authorized to:
1. Operate a treatment system. consisting of an oil/water separator and a polishing filter. at the
Rockingham Power L.L.C. combustion turbine facility located in Reidsville. Rockingham County: and
2. Discharge contact stormwater from the above mentioned treatment system and evaporative cooling
water at the location specified on the attached map into an unnamed tributary to Jacob's Creek. a class
C stream in the Roanoke River Basin.

A (1). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - DRAFT
Permit No. NC0086665
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from outfall(s) serial number 001
- Evaporative Cooling Water and Contact Stormwater. Such discharges shall be limited and monitored by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
DISCHARGE LIMITATIONS
MONITORING REQUIREMENTS
Monthly
Average
Weekly Average
Daily Maximum
Effluent Measurement
Frequency
Sample
Type
Sample
Locations
Flow (MGD)
Monthly
See Note 1
Effluent
Total Suspended
-Solids
45.0 mg/L
-- Monthly
Grab—
ffluent
Total Res
dual(Chlorin�'
1
17 µg/L
Monthly
Gr b
ffluent
Turbidity
'
\
Monthly'
Grob
Effluent
Temperatiire'
'
1/
,
Monthly
Grab
Effluent
Oil and Grease'A._.
Gib
Effluent
__..M�t,thly
EPA Methods
624/6254Y,,,,,
Semi-Annually
Gr b
Effluent
Actrte'roxicity
\
Annually
Gr b
Effluent
pH6
(
\
) j Monthly
Gr b
Effluent
toPP `'
THERE 5 L B NO DISC RiFLOATING SOLIDS VISIBLE FO
NOT
2
TRACE AMOUNTS. \ c
Sample Locations: Effluent shall be defined as a point after combination of the evaporative cooling water and the contact stormwater prior to discharge to the unnamed tributary to
Jacob's Creek. Where no measurable discharge occurs. "no discharge" should be clearly noted on the submitted monthly discharge monitoring report. Flow may be monitored in
one of the four following ways:
a) Measure flow continuously;
b) Calculate flow based on the area draining to the outfall, the built upon area, and the total rainfall;
c) Estimate by flow measurement at 20 minute intervals during the entire discharge event; or
d) Base flow on pump logs.
The temperature of the effluent shall not cause the temperature of the receiving stream to increase by more than 2.8 degrees C above natural water temperature, and in no case
cause the temperature of the receiving stream to exceed 32 degrees C.
3 Where possible, the grab sample for oil and grease shall be skimmed from the surface of a quiescent zone.
4 After a compliance history associated with 8 to 12 sampling events has been established, the permittee may request relaxation or deletion of this monitoring requirement.
5 Acute Toxicity (Fathead Minnow. 24-hour) Monitoring, Episodic; see Condition A(2) of this permit.
6 The pH shall not be Tess than 6.0 standard units or greater than 9.0 standard units.

Permit No. NC0086665
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A (2). ACUTE TOXICITY MONITORING (EPISODIC)
The permittee shall conduct FIVE acute toxicity tests using protocols defined in EPA Document EPA/600/4-
90/027 entitled "Methods for Measuring the Acute Toxicity of Effluents to Freshwater and Marine
Organisms." The monitoring shall be performed as a Fathead Minnow (Pimephales prome/as) 24 hour static
test. Effluent samples for self -monitoring purposes must be obtained below all waste treatment. Sampling and
subsequent testing will occur during the first five discrete discharge events after the effective date of this
permit. After monitoring of the first five toxicity tests, the permittee will conduct one test annually, with the
annual period beginning in January of the next calendar year. The annual test requirement must be performed
and reported by June 30. If no discharge occurs by June 30, notification will be made to the Division by this
date. Toxicity testing will be performed on the next discharge event for the annual test requirement.
The parameter code for this test is TAE6C. All toxicity testing results required as part of this permit condition
will be entered on the Effluent Discharge Form (MR-1) for the month in which it was performed. using the
appropriate parameter code. Additionally. DWQ Form AT-1 (original) is to be sent to the following address:
Attention: Environmental Sciences Branch
North Carolina Division of
Water Quality
4401 Reedy Creek Rd.
Raleigh, N.C. 27607
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the
effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste
stream.
Should any test data from either these monitoring requirements or tests performed by the North Carolina
Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re -opened and
modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document. such as minimum control
organism survival and appropriate environmental controls, shall constitute an invalid test and will require
immediate follow-up testing to be completed no later than the last day of the month following the month of the
initial monitoring.

Dynegy Inc.
woo Louisiana Street, Suite 5800
Houston, Texas 77002
Phone 713.507.640o
www.dynegy.com
AVE�R
RD�a11
14
OE�X f5
June 1, 1999
Mr. Mark McIntire
NCDENR Division of Water Quality-NPDES Unit
2728 Capital Blvd
Raleigh, NC 27626
VIA Fed Ex Delivery
Dear Mr. McIntire:
DYNEGY
•
Alk
As per your request, I am enclosing the analytical results from EPA methods 624 and 625 performed on a
stormwater sample collected from the No. 2 fuel oil containment berm located at our Hartwell Energy facility,
located in Hartwell, Georgia. You requested that we sample potential contact stormwater from a bermed fuel
tank area at one of our similarly designed facilities to ensure that, under normal circumstances, contact
stormwater from within a bermed fuel tank area would not contain organic substances that may miss detection
with a visual screen. The Hartwell Energy power generation facility is of similar configuration as the proposed
Rockingham Power project, in that it is dual fueled (natural gas and fuel oil) and maintains two, 2.1 million
gallon No. 2 fuel oil storage tanks within a bermed containment area. A drawing of the Hartwell Energy
Facility is presented for your reference.
The results of the tests indicated that all volatile and semivolatile compounds were below reporting limits in the
submitted stormwater sample. Rockingham Power proposed in its NPDES application, currently under review
by your office, to visually screen the stormwater in its containment berm, and if no sheen was noted, it would
then discharge the water directly to the NPDES outfall point. In the event a sheen was noted, Rockingham
Power proposed to direct the water through an oil/water separator and polishing filter prior to discharge to the
outfall point. We request that you consider allowing Rockingham to handle the stormwater collected in the
containment berm as proposed, given the clear analytical results obtained from the Hartwell facility.
Your other outstanding request involved a question on the relationship between Rockingham Power L.L.C. and
its parent company, Dynegy. Rockingham Power L.L.C. was formed specifically to develop and own the
Rockingham Power project and will also serve as the pennit holder for the facility.
I sincerely appreciate your assistance in reviewing Rockingham Power's permit application. Please do not
hesitate to call me if you have any questions at [phone].
8764
Sincerely,
Starla Lacy
Environmental Specialist

`Z.
TGPL
METERING
STATION
Fenced
(-7D IIIIL
Illlillll1I r
ADMIN
BLDG.
r-
RAW WATER
STORAGE TANK
FIRE
PUMP 04
HOUSE
aved Road
DEMIN
SKID
H201
H2
SKID
H101
FOAM
HOUSE
•
•
REVISIONS
ZONE
REV
DESCRIPTION
DATE
APPROVED
DEMIN WATER
TANK
FUEL OIL
TANK #2
FUEL OIL
TANK #1
Not To Scale
Alt roads paved inside fenced area
Unpaved areas contain gravel
Unpaved Road
STORM
WATER
BASIN
FIGURE 1
THIS DRAWING IS TIE PROPERTY OF THE
HARTWELL ENERGY FACILITY AND MUST
NOT BE REPRODUCED, DISTRIBUTER. OR
USED 1N ANY MANNER WITHOUT PRIOR
WR1TTEN CONSENT OF AN AUTHORIZED
REPRESENTATIVE OF THE MART WELL
ENERGY FACILITY.
ORAWN
TBR
DATE
09/08/96
HARTWELL ENERGY FACILITY
BUILDING LAYOUT
CHECKED
RSD
SIZE
B
SCALE
NTS
DWG NO.
REV
A
DESIGN
FLE TITLV1.DWG
SHEET 1 OF 1

AES
May 14, 1999
Starla Lacy
DYNEGY POWER CORP
1000 Lousiana St
Suite 5800
Houston, TX 77002
TEL: [phone]
FAX [phone]
RE: Hartwell
Dear Starla Lacy,
ANALYTICAL ENVIRONMENTAL SERVICES, INC.
Order No.: 9905073
Analytical Environmental Services, Inc. received 1 sample on 5/7/99 3:25:00 PM for the
analyses presented in the following report.
There were no problems with the analyses and all data for associated QC met EPA or laboratory
specifications except where noted in the Case Narrative.
If you have any questions regarding these tests results, please feel free to call.
Sincerely,
//f
Michael Salum
Laboratory Director
CC:
3781 PRESIDENTIAL PARKWAY, SUITE 111 • ATLANTA, GEORGIA 30340 • TEL: [phone] • FAX: [phone]

Analytical Environmental Services, Inc.
CLIENT:
Lab Order:
Project:
Lab ID:
Analyses
DYNEGY POWER CORP
9905073
Hartwell
9905073-001A
Date: 14-May-99
Client Sample ID: 1
Tag Number:
Collection Date: 5/7/99 1:00:00 PM
Matrix: AQUEOUS
Result Limit Qual Units
DF Date Analyzed
PP-VOLATILES
1,1,1-Trichooroethane
1,1,2,2-Tetrachloroethane
1,1,2-Trichooroethane
1,1-Dichloroethane
1,1-Dichloroethene
1,2-Dichlorobenzene
1,2-Dichloroethane
1,2-Dichloropropane
1,3-Dichlorobenzene
1,4-Dichlorobenzene
2-Chloroethyl vinyl ether
Acrolein
Acrylonitrile
Benzene
Bromodichloromethane
Bromoform
Bromomethane
Carbon tetrachloride
Chlorobenzene
Chloroethane
Chloroform
Chloromethane
cis-1,3-Dichloropropene
Dibromochloromethane
Ethylbenzene
Methyl tert-butyl ether
Methylene chloride
Tetrachloroethene
Toluene
trans-1,2-Dichloroethene
trans-1,3-Dichloropropene
Trichloroethene
Trichlorofluoromethane
Vinyl chloride
Surr: 4-Bromofluorobenzene
Surr: Dibromofluoromethane
Surr: Toluene-d8
Qualifiers:
E624
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
BRL
84.2
94.2
96.3
5
5
5
5
5
5
5
5
5
5
5
50
50
5
5
5
5
5
5
5
5
5
5
5
5
5
10
5
5
5
5
5
5
2
70-112
67-133
80-121
BRL - Below Reporting Limit
J - Analyte detected below quantitation limits
B - Analyte detected in the associated Method Blank
* - Value exceeds Maximum Contaminant Level
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
pg/L
%REC
%REC
%REC
Analyst: MJL
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
5/13/99 4:47:00 AM
S - Spike Recovery outside accepted recovery limits
R - RPD outside accepted recovery limits
E - Value above quantitation range
1

Analytical Environmental Services, Inc.
Date: 14-Mav-99
CLIENT: DYNEGY POWER CORP Client Sample ID: 1
Lab Order: 9905073 Tag Number:
Project: Hartwell Collection Date: 5/7/99 1:00:00 PM
Lab ID: 9905073-001B Matrix: AQUEOUS
Analyses Result Limit Qual Units DF Date Analyzed
PP-SEMIVOLATILE ORGANICS E625 Analyst: JZ
1,2,4-Trichlorobenzene BRL 10 pg/L 1 5/12/99 8:26:00 PM
1,2-Dichlorobenzene BRL 10 pg/L 1 5/12/99 8:26:00 PM
1,3-Dichlorobenzene BRL 10 pg/L 1 5/12/99 8:26:00 PM
1,4-Dichlorobenzene BRL 10 pg/L 1 5/12/99 8:26:00 PM
2,4,6-Trichlorophenol BRL 10 pg/L 1 5/12/99 8:26:00 PM
2,4-Dichlorophenol BRL 10 pg/L 1 5/12/99 8:26:00 PM
2,4-Dimethylphenol BRL 10 pg/L 1 5/12/99 8:26:00 PM
2,4-Dinitrophenol BRL 50 pg/L 1 5/12/99 8:26:00 PM
2,4-Dinitrotoluene BRL 10 pg/L 1 5/12/99 8:26:00 PM
2,6-Dinitrotoluene BRL 10 pg/L 1 5/12/99 8:26:00 PM
2-Chloronaphthalene BRL 10 pg/L 1 5/12/99 8:26:00 PM
2-Chlorophenol BRL 10 pg/L 1 5/12/99 8:26:00 PM
2-Nitrophenol BRL 50 pg/L 1 5/12/99 8:26:00 PM
3,3"-Dichlorobenzidine BRL 20 pg/L 1 5/12/99 8:26:00 PM
4,6-Dinitro-2-methylphenol BRL 50 pg/L 1 5/12/99 8:26:00 PM
4-Bromophenyl phenyl ether BRL 10 pg/L 1 5/12/99 8:26:00 PM
4-Chloro-3-methylphenol BRL 10 pg/L 1 5/12/99 8:26:00 PM
4-Chlorophenyl phenyl ether BRL 10 pg/L 1 5/12/99 8:26:00 PM
4-Nitrophenol BRL 50 pg/L 1 5/12/99 8:26:00 PM
Acenaphthene BRL 10 pg/L 1 5/12/99 8:26:00 PM
Acenaphthylene BRL 10 pg/L 1 5/12/99 8:26:00 PM
Anthracene BRL 10 pg/L 1 5/12/99 8:26:00 PM
Benz(a)anthracene BRL 10 pg/L 1 5/12/99 8:26:00 PM
Benzo(a)pyrene BRL 10 pg/L 1 5/12/99 8:26:00 PM
Benzo(b)fluoranthene BRL 10 pg/L 1 5/12/99 8:26:00 PM
Benzo(g,h,i)perylene BRL 10 pg/L 1 5/12/99 8:26:00 PM
Benzo(k)fluoranthene BRL 10 pg/L 1 5/12/99 8:26:00 PM
Bis(2-chloroethoxy)methane BRL 10 pg/L 1 5/12/99 8:26:00 PM
Bis(2-chloroethyl)ether BRL 10 pg/L 1 5/12/99 8:26:00 PM
Bis(2-chloroisopropyl)ether BRL 10 pg/L 1 5/12/99 8:26:00 PM
Bis(2-ethylhexyl)phthalate BRL 10 pg/L 1 5/12/99 8:26:00 PM
Butyl benzyl phthalate BRL 10 pg/L 1 5/12/99 8:26:00 PM
Chrysene BRL 10 pg/L 1 5/12/99 8:26:00 PM
Di-n-butyl phthalate BRL 10 pg/L 1 5/12/99 8:26:00 PM
Di-n-octyl phthalate BRL 10 pg/L 1 5/12/99 8:26:00 PM
Dibenz(a,h)anthracene BRL 10 pg/L 1 5/12/99 8:26:00 PM
Diethyl phthalate BRL 10 pg/L 1 5/12/99 8:26:00 PM
Dimethyl phthalate BRL 10 pg/L 1 5/12/99 8:26:00 PM
Fluoranthene BRL 10 pg/L 1 5/12/99 8:26:00 PM
Fluorene BRL 10 pg/L 1 5/12/99 8:26:00 PM
Qualifiers:
BRL - Below Reporting Limit
1 - Analyte detected below quantitation limits
B - Analyte detected in the associated Method Blank
* - Value exceeds Maximum Contaminant Level
S - Spike Recovery outside accepted recovery limits
R - RPD outside accepted recovery limits
E - Value above quantitation range
2

Analytical Environmental Services, Inc.
Date: 14-May-99
CLIENT: DYNEGY POWER CORP Client Sample ID: 1
Lab Order: 9905073 Tag Number:
Project: Hartwell Collection Date: 5/7/99 1:00:00 PM
Lab ID: 9905073-OO1B Matrix: AQUEOUS
Analyses Result Limit Qual Units DF Date Analyzed
Hexachlorobenzene BRL 10 pg/L 1 5/12/99 8:26:00 PM
Hexachlorobutadiene BRL 10 pg/L 1 5/12/99 8:26:00 PM
Hexachloroethane BRL 10 pg/L 1 5/12/99 8:26:00 PM
Indeno(1,2,3-cd)pyrene BRL 10 pg/L 1 5/12/99 8:26:00 PM
lsophorone BRL 10 pg/L 1 5/12/99 8:26:00 PM
N-Nitrosodi-n-propylamine BRL 10 pg/L 1 5/12/99 8:26:00 PM
Naphthalene BRL 10 pg/L 1 5/12/99 8:26:00 PM
Nitrobenzene BRL 10 pg/L 1 5/12/99 8:26:00 PM
Pentachlorophenol BRL 20 pg/L 1 5/12/99 8:26:00 PM
Phenanthrene BRL 10 pg/L 1 5/12/99 8:26:00 PM
Phenol BRL 10 pg/L 1 5/12/99 8:26:00 PM
Pyrene BRL 10 pg/L 1 5/12/99 8:26:00 PM
Surr: 2,4,6-Tribromophenol 66.5 10-123 %REC 1 5/12/99 8:26:00 PM
Surr. 2-Fluorobiphenyl 46.6 43-116 %REC 1 5/12/99 8:26:00 PM
Surr: 2-Fluorophenol 22.8 21-110 %REC 1 5/12/99 8:26:00 PM
Surr: 4-Terphenyl-d14 85.3 33-141 %REC 1 5/12/99 8:26:00 PM
Surr: Nitrobenzene-d5 37.0 35-114 %REC 1 5/12/99 8:26:00 PM
Surr phenol-d5 15.1 10-94 %REC 1 5/12/99 8:26:00 PM
Qualifiers:
BRL - Below Reporting Limit
.1 - Analyte detected below quantitation limits
B - Analyte detected in the associated Method Blank
* - Value exceeds Maximum Contaminant Level
S - Spike Recovery outside accepted recovery limits
R - RPD outside accepted recovery limits
E - Value above quantitation range
3

ANALYTICAL tNVIRONMENTAL SERVICES, INC.
3781 Presidential Parkway, Suite 111, Atlanta, GA 30340
[phone] / Toll -Free [phone] / fax: [phone]
CHAIN OF CUSTODY RECORD
CHEMICAL ANALYSIS
Company Name:
Address:
City, State, Zip:
Contact Person:
Sampler's Name:
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Phone Number:f
Fax Number:
Project Name:
Project Number:
Purchase Order #:
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Turnaround Time
Requested
0
0
0
Standard-3-5 Business Days
(or most analyses)
Same Day Rush
Next Business Day Rush
2 Business Day Rush
Other
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Sample ID #
Sample Description/Location
Collected:
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1
No. of Containers
Analysis/Method Required
Comments/Special Instructions
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Date Time
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Relinquished By:
Received By:
Relinquished By:
Received By:
DatelTime:
Date/Time:
Date/Time:
Date/Time:
Received for Lab By: C
p"_
(Circle One)
ethod of S
Hand-dellvered
Courier Service:
ent:
FEDEX
DatelTime:-7-`9-72;1s,•
UPS U.S.Mail
Other:

Analytical Environment
Sample Receipt Checklist
Client Name DYNEGY
Work Order Numbe 9905073
Checklist completed by [h� _ kaleckf
Signature
Matrix Carrier name Courier
Date and Time Receive 5/7/99 3:25:00 PM
Received by JB
Reviewed by
Shipping container/cooler in good condition? Yes 'mil No E Not Presen ❑
Custody seals intact on shippping container/cooler? Yes ❑ No ❑ Not Presen 1
Custody seals intact on sample bottles? Yes ❑ No ❑ Not Presen 1,2
Chain of custody present? Yes (] No ❑
Chain of custody signed when relinquished and received? Yes No ❑
Chain of custody agrees with sample labels? Yes n No ❑
Samples in proper container/bottle? Yes ] No ❑
Sample containers intact? Yes C No ❑
Sufficient sample volume for indicated test? Yes No ❑
All samples received within holding time? Yes No ❑
Container/Temp Blank temperature in compliance? Yes k No ❑
Water - VOA vials have zero headspace? No VOA vials submitted ❑ Yes © No 70
Water - pH acceptable upon receipt? Yes �] No ❑
Adjusted Checked b
Any No and/or NA (not applicable) response must be detailed in the comments section bel
Client contacted
Contacted by:
Comments:
Corrective Action
Date contacted:
Regarding
Person contacted
Date

cc: Permits and Engineering
Technical Support Branch
County Health Dept.
Central Files
WSRO
SOC PRIORITY PROJECT: Yes NoX
If Yes, SOC No.
To: Permits and Engineering Unit
Water Quality Section
Attention: Mark McIntire
Date: April 26, 1999
NPDES STAFF REPORT AND RECOMMENDATION
County Rockingham
Permit No. NC0086665
PART I - GENERAL INFORMATION
Facility and Address: Rockingham County LC Combustion Turbine Facility (Dynegy)
Applicant Address: 1000 Louisiana, Suite 5800
Houston Texas 77002-5050
Facility Location: 240 Ernest Drive
Reidsville N.C. 27320
2. Date of Investigation: 99/04/19 (via telephone to Starla Lacy)
3. Report Prepared by: David Russell, WSRO
4. Persons Contacted and Telephone Number: Starla Lacy [phone]
5. Directions to Site: From Hwy 220 in Rockingham County travel Hwy 65 NE
approximately 8 1/2 miles. Site is on the left on Ernest Drive.
6. Discharge Points(s), List for all discharge points:
001: Latitude: 36° 19' 42" Longitude: 79° 49' 45"
002: Latitude: 36° 19' 41" Longitude: 79° 49' 46"
U.S.G.S. Quad No. B19SE U.S.G.S. Quad Name Bethany
7. Site size and expansion area consistent with application? X Yes No If No, explain:

8. Topography (relationship to flood plain included): Well above the flood plain.
9. Location of nearest dwelling: None within 1000 feet.
10. Receiving stream or affected surface waters: UT to Jacob's Creek
a. Classification C
b. River Basin and Subbasin No.: Roanoke
c. Describe receiving stream features and pertinent downstream uses: Rural area;
woodland; fish and wildlife propagation.
Part II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater to be permitted: MGD (Ultimate Design Capacity)
20,640 gpd average; 163,200 gpd maximum (combination of cooling water and
stormwater)
b. What is the current permitted capacity of the Waste Water Treatment facility? NA
c. Actual treatment capacity of the current facility (current design capacity)?
163,200 gpd max.
d. Date(s) and construction activities allowed by previous Authorizations to
Construct issued in the previous two years. NA
e. Please provide a description of existing or substantially constructed wastewater
treatment facilities; NA
f. Please provide a description of proposed wastewater treatment facilities.
Contact stormwater - oil/water separator, polishing filter; 002 non -contact cooling
water - discharged untreated to the U.T. (two discharge points)
g'
Possible toxic impacts to surface waters: None known
h. Pretreatment Program (POTWs only):
in development _ approved
should be required not needed
2. Residuals handling and utilization/disposal scheme: NA
a. If residuals are being land applied, please specify DWQ Permit No.
NPDES Permit Staff Report
Version 10/92
Page 2

Residuals Contractor
Telephone No.
b. Residuals stabilization: PSRP PFRP
Other
c. Landfill:
d. Other disposal/utilization scheme (Specify):
3. Treatment plant classification (attach completed rating sheet). Class I
4. SIC Code(s):
Primary 14 Secondary 73
Main Treatment Unit Code: 5 3 6 = 0
PART HI - OTHER PERTINENT INFORMATION
1 Is this facility being constructed with Construction Grant Funds or are any public monies
involved. (municipals only)? NA
2. Special monitoring or limitations (including toxicity) requests: NA
3. Important SOC, JOC or Compliance Schedule dates: (Please indicate)NA
Date
Submission of Plans and Specifications
Begin Construction
Complete Construction
4. Alternative Analysis Evaluation: Has the facility evaluated all of the non -discharge
options available. Please provide regional perspective for each option evaluated. This is a
non-BOD laden wastewater. The flow will be stormwater and cooling water. Surf -are
�,�•,.,../JiC2�r ; L. --., cL-Cb•� ./L.w.--(- c .--�— `.�2vf Y
Spray Irrigation:
Connection to Regional Sewer System: None available.
NPDES Permit Staff Report
Version 10/92
Page 3

Subsurface:
Other disposal options:
5. Other Special Items:
PART IV - EVALUATION AND RECOMMENDATIONS
This proposed facility would generate electricity during peak load demands. Turbines
fueled by natural gas or fuel oil would be used. Cooling water (non -contact) would be generated
by the turbines, as well as stormwater from the area. Contaminated stormwater (001) would go
through an oil/grease separator and filter before being discharged into an UT to Jacob's Creek.
Cooling water and noncontaminated stormwater 9002) would blow into the UT to Jacob's Creek.
These are non D.O. demanding mstwater. There would be two discharge points, 001 and 002.
There are some (Dints of concern that were not addressed in the application package.
They are as follows: (1) Temperature - what will be the effluent temperature? What, if any,
change in receiving stream temperature would occur? (2 Asti - would 401/404 permits be
required? (3) Cost estimates - no cost estimate was give for the discharge alternative to
compare with the non -di harge alternatives. . f (: ,s
These items need to be addressed before WSRO recommends issuance of the permit.
C 1 iX qs2 `>7
Signature of report preparer
Water Qu ity Regional Supervisor
Date
NPDES Permit Staff Report
Version 10/92
Page 4

Dynegy Rockingham Co. CT Project
Subject: Dynegy Rockingham Co. CT Project
Date: Mon, 19 Apr 1999 09:53:25 -0400
From: "Tamara S Carpenter" <[e-mail]>
To: Mark [e-mail]
04/19/99 09:52
(Embedded
image moved
to file:
pic19105.pcx)
AM
Forwarded by Tamara S Carpenter/Corp/DukePower on
Tamara S Carpenter
04/19/99 08:58 AM
(Embedded image moved to file:
pic28385.pcx)
To: [e-mail]
cc: [e-mail]
Subject: Dynegy Rockingham Co. CT Project
Dear Mark,
Per our discussion on Monday, April 12, 1999, the plan was originally for the
sediment basin to remain after construction of the project is complete. Dynegy
has met with the Corp of Engineers and determined that they do not need a permit
for the installation of the dam of the sediment basin. The original intent for
keeping the basin after construction was to regulate the flow from the cooling
water system into the unnamed tributary of Jacob's Creek. Our concern with a
monitoring point at the spillway of this basin is as follows:
This basin will continue to receive stormwater from around the site. This is
due to the topography of the surrounding area. During periods of heavy
rainfall, the solids level in the basin could be higher than that coming from
the polishing filter and from the cooling water system. This would be due to
general site runoff associated with non -contact stormwater and not in any way
related to the regulated wastestreams.
During periods of low flow and warm weather, this basin could also experience
an algae bloom due to natural conditions and that again would effect the
solids level and the pH and this would be due to causes other than the
regulated wastestreams being discharged from the facility.
As we discussed Monday, Dynegy would prefer to monitor at the effluent of the
polishing filter and the cooling water discharge line with two separate outfalls
(monitoring points A and B on Figure 5 of the permit application). Dynegy has
agreed to lower the spillway to the original elevation after completion of
construction such that no water will be retained in the sediment basin.
Please call me at [phone] or Starla Lacy with Dynegy at [phone] if
you have questions or would like to discuss this further.
Sincerely,
1 of 2 4/19/99 2:01 PM

March 26, 1999
Mr. Mark McIntyre
North Carolina Department of Environment
And Natural Resources
Division of Environmental Management
NPDES Permit Group
PO Box 29535
Raleigh, NC 27626-0535
Re: Rockingham Power LLC Combustion Turbine Facility
Dear Mr. McIntyre:
On March 3, 1999, Duke Engineering and Services submitted a NPDES Permit Application on
behalf of Dynegy Power Corporation for a combustion turbine project to be located in
Rockingham County. Attached are corrected Figures, which reflect several minor modifications,
made since the original submittal. Below is an explanation of the changes:
Corrected Figure 4: This water balance shows the correct diagram for the project. The
only change affecting the discharge permit is general maintenance washdown, which
includes the hosing down of equipment areas and walkways with the municipal water
supply. This will be routed to the oil water separator system.
Corrected Figure 5: This figure reflects the relocation of the oily water separator to the
west end of site in order to reduce the drain distance between unit No. 1 and the
separator. The previous location would have required drain slopes that would have
positioned the separator 10 feet underground. Other plant layout changes which do not
directly affect the NPDES Permit application include the repositioning of the municipal
water & demineralizer water storage tanks (north/south space limitations necessitated
relocating these tanks east/west). A second mobile demineralizer filtered water skid
trailer parking location was added. The fuel oil truck unloading positions were relocated
due to space limitations between the road and berm. This relocation reduces the amount
of rainwater drained to the oily water separator and allows for easier truck access to
unloading stations.
Also in the original application, we discussed how the regeneration of the demineralizers
were to be handled offsite, thus minimizing the wastewater discharge from this facility.
Information obtained after the submittal of the application from the vendor of the mobile units
has determined that a volume of wastewater generated with the regeneration of each trailer is
43,500 gallons. When the facility is running on fuel oil, thus requiring water injection, a mobile
unit will be required every two days. The facility is permitted to run 1000 hours/year on fuel oil
and this will be done primarily in the winter when natural gas is not available. Therefore, this
wastestream could generate as much as 2,700,000 gallons of wastewater that will be taken off -site
and thus, handled alternatively to onsite treatment and discharge. Again minimizing the effluent
discharge from this facility.

Please call Ms. Starla Lacy with Dynegy at [phone] or myself at [phone] if you
have any questions or require additional information.
Sincerely,
%5
amara Carpenter, Enginee
Duke Engineering and Services
xc; Starla Lacy

A/Coo544c5
• # 0o /7,05
17is a�
March 3, 1999
Mr. Charles Weaver
North Carolina Department of Environment
And Natural Resources
Division of Environmental Management
NPDES Permit Group
PO Box 29535
Raleigh, NC 27626-0535
Re: Rockingham Power LLC Combustion Turbine Facility
Dear Mr. Weaver:
Please find attached the re -submittal of the NPDES discharge permit application for the Dynegy
Power Corporation 800-megawatt combustion turbine facility in Rockingham County. This
project is to be located approximately 7 miles west of Reidsville, NC. Attached is the NPDES
application as well as the application fee of $715.00.
Construction of this facility is scheduled to begin in late April 1999 with the clearing of the land.
The wastewater discharge from this facility has been minimized in that the demineralized filter
regeneration process is being handled off -site along with the wastewater generated in the turbine
sumps. The wastestreams associated with this application consist of an evaporative cooling water
discharge with no added biocides and the discharge of contact stormwater through an oil water
separator system.
The original submittal of this application requested the concurrent application of the discharge
permit and the Authorization to Construct. I discussed this with Mark McIntyre of your staff on
Friday, February 28, 1999 and requested approval to submit the discharge permit application first
to avoid holding up the process. We will follow-up with the ATC as soon as the information is
complete, which will be within the next month. This will allow your staff the opportunity to
familiarize themselves with the discharge information prior to receiving the ATC information.
Per your request, Duke Engineering and Services is acting as a consultant for Dynegy, Inc and
has been contracted to do the permitting for the project along with some of the site investigation
work. I can be reached at [phone] if you have questions or require additional information.
You may also contact Ms Starla Lacy of Dynegy at [phone]. We very much appreciate
your cooperation.
Sincerely,
Tamara Carpenter, En_ineer
Duke Engineering and Services
xc: Starla Lacy
Dwight Hollifield

1
RAW WATER
NOTES:
1. FLOWS ARE IN GPM
2. USED ONLY WHEN FIRING FUEL OIL
RAW WATER
STORAGE
EVAPORATION
• GENERAL MAINTENANCE
WASHDOWN: THIS WOULD INCLUDE HOSING DOWN OF
EQUIPMENT AREAS, WALKWAYS, ETC.
POTABLE
WATER
SYSTEM
SEPTIC
SYSTEM
CONTAMINATED
STORM WATER
STORM WATER
INT.
SERVICE
WATER
SYSTEM
INT.
GENERAL
MAINTENANCE
WASHDOWN *
1
OIL WATER
SEPARATOR
SUMP
INT.
INT.
TURBINE
WASH
WAILH
INT.
OFFSI TE
DISPOSAL
l
POLISHING
1 (<10 PPM OIL + GREASE)
BATTERY
ROOM
AND SHOP
DRAINS
300 125
RENTAL
DEMIN.
SYSTEM
300
1
NOX INJECTION
WATER
(SEE NOTE 2)
105
EVAPORATIVE
COOLER
1
RETENTION
BASIN
20
PLANT
OU TFALL
0 YNEDY CONFIDENTIAL
ThW truiE b V* rygrty o1
011ECY POWER CORP. IMMW
Rai Wooing. .v rvatrr.+ra.
N R, nor blonnnllT owned
tam A M b ohms to Oho,
',haft as cansM sr Elan
cannot of 011EGT POSER CORP.
No uss b lob rands of
W NAi A ar mq Is. Injriws
to 01K0Y POWER COW.
REFERENCE DRAWINGS
NO. DATE
REVISION
BY
APPROVED
NO. DATE
REVISION
BY
APPROVED
SCALE:NONE
DON. SATE
Mal 11/02/98
CNN
C
02/18/99
ISSUED KOR REFERENCE
AMU
APPV.
]ATE
DATE
611 DYNEGY FOR REFERENCE ONLY
B 1/25/99
ISSUED FOR REFERENCE
AIM
ROCKINGHAM POWER PROJECT
WATER BALANCE DIAGRAM
FIGURE 4
PROJECT NO.: 1391
CLIENT:
DOG. NO.:
1391-M-201.01
A 11/02/98 ISSUED FOR PROPOSAL
AMU

r
OUTFALL
NONIIDR A
MA51.15I10N j.
1UIOINE 3
TO STORMWATER EVAPORATNE COOLER SLOWDOWN
RETENTION POND,- a y
OVIFALL
MONITOR 8
I LJ
MR MET FILTER
--�i 1
1�'
I
S01F T
URBINEE 4I i 1
11
IT
11I
Jl
n
II
NORMALLY
4 CLOSED
IVALVE
L.
NORMALLY
CLOSED
VALVE
r
)
REF
NO
DESCRIPTION
1
OILY WATER SEPARATOR
2
OILY WATER FILTER
3
FUEL OIL STORAGE TANK
4
FUEL OIL TRUCK UNLOADING AREA
5
FUEL OIL PUMP AREA
6
EMERGENCY DIESEL AREA
7
FIRE PUMP AREA
8
DEMINERALIZED WATER TRUCK AREA
9
STACK AREA
10
COMBUSTION TURBINE MECHANICAL AREA
11
MAIN STEP UP TRANSFORMER
12
STATION AUXILIARY TRANSFORMER
50' 25' 0 50' 100'
1'r50'
DYNEOY CONFIDENTIAL
111B dumb- It the FmOeete al
9* Y INC. Miler
«�*mew ,eamelmMer
—
el IL nor Meoweon NNW
aae. R WM 1. Owe b sere
.1Fne1 Me mimeo' eMWI
oSa/A al MUM MG
IN Me Is N M "tale el
DAWN Mt
REFERENCE DRAWINGS
NO.
DATE
REVISION
MY
APPROVE)
NO.
DATE
REVISION
BY
APPROVED
SCALE
NONE
AMA
DATE
12/21/28
D
03/24/98
REVISED PER UPDATED PLOT PLAN
ANM
auc
APPL
DATE
DATE
DYNEGY
FOR REFERENCE ONLY
C
P2/13/99
ISSUED FOR REFERENCE
AMM
S
A
1/25/92
12/21/28
ISSUED FOR REFERENCE
ISSUED FOR REFERENCE
PAW
ANM
ROCKINGHAM POWER PROJECT
WATER DISCHARGE SCHEMATIC
FIGURE 5
PROJECT NO.: 1891
CUENT:
DWG. NO.:
1391-C-101.04
REV.
0