NCS000369_Staff Report_20080407

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Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Coleen H. Sullins Director
Division of Water Quality
Facility Name:
Public Works Commission of Fayetteville
NPDES Permit Number:
NCS000369
Facility Location:
Fayetteville, NC (Cumberland County) _
Type of Activity:
Power Plant
Receiving Stream:
UT to Locks Creek, See Figure 1
-57
River Basin:
Cape Fear River Basin, Sub -basin 03-06-15 ' _.
Stream Classification:C
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Proposed Permit Requirements:
See attached draft permit. W
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Monitoring Data:
See Table 1
Facility Location:
See Figure 1
Response Requested by (Date):
7 r.N 900-2
Central Office Staff Contact:
Kelly Johnson, [phone], ext. 376
Special Issues:
Issue
Rating Scale: 1 eas to 10 and
Compliance history
2
Benchmark exceedance
0
Location (TMDL, T&E
species, etc
0
Other Challenges:
• N/A
0
Difficulty Rating:
2/40
Special Issues Explanation:
• Compliance history: Site contains 25 -year storm. Previous permit was Written so that no analytical
sampling was required if the 10 -year storm was contained.
• Benchmark exceedance: N/A
• Location: No TMDL, no T&E, easy to find on map
Description of Onsite Activities:
Power generation plant:
• Power sources for steam are natural gas and fuel oil.
• 8 G.E. Turbines (25,000 kW) each; 65,000 kW Steam Turbine.
Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• Stormwater Permit File
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NCS000369
• 2005 Cape Fear Basinwide Plan
• Draft 2008 303(d) List
• EPA Sector -Specific Permit, 2006 draft
History:
• March 15, 2000: Permit first issued
• October 1, 2004: Permittee submitted renewal application.
• March 31, 2005: Permit expired
Figure 1: Map of Facility
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-; Public Works
Central Office Review Summary:
1. Owner's Other Permits: N/A
2. General Observations: This site appears to be fairly benign and the plant manager is well versed in the stormwater
requirements. This site is designed to drain to a pond which discharges only in response to a 25 -year event, and the
permit only required sampling if the 10 -year event could not be contained. The cover letter of the application
indicates that they had planned to do analytical sampling following the application period, and send in that
information. That information is not on file. At the time they were applying, they were in discussions with DWQ
and local officials to discuss a potential situation where they could choose to drawdown their pond before a potential
hurricane or other large storm in order to avoid erosion and failure of their earthen berm. The permittee chose not to
pursue that option, and samples were therefore not collected. The permittee would like to continue to have the
option of not sampling unless the ten-year storm can not be contained. I chose not to require sampling if the 25 -year
storm (rather than the 10 -year storm) could not be contained because the permittee did not appear interested in
discharging unless the water would cause berm failure. I think that this is a reasonable situation.
3. Impairment: Not 303(d) listed. Not rated in Basinwide Plan.
4. Industrial Changes Since Previous Permit: None
5. Analytical Monitoring Notes:
o Analytical monitoring was not required because the 10 -year storm can be contained.
o EPA Sector Specific permit requires testing for total recoverable iron and TSS. Add these to the permit
requirements if the pond is changed not to be able to contain the 10 -year storm.
6. Oualitative Monitoring Notes:
o The plant manager regularly performs qualitative monitoring.
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NCS000369
Revised Permit Recommendations: Analytical Monitoring:
1. Added total recoverable iron, per EPA's General Specific permit.
2. Added total suspended solids, per EPA's General Specific permit.
3. pH has been added to the analytical monitoring requirements.
4. All analytical monitoring has been set to semi-annually during a representative storm event as defined in Part II
Section B. The permittee must also document the total precipitation for each event. If no discharge occurs
during the sampling period, the permittee must submit a monitoring report indicating "No Flow" within 30 days
of the end of the six-month sampling period. Additionally, samples must be taken a minimum of 60 days apart,
as specified in Table 2.
5. Benchmarks for analytical monitoring have been added to this draft permit. Exceedances of benchmark values
require the permittee to increase monitoring, increase management actions, increase record keeping, and/or
install stormwater Best Management Practices (BMPs) in a tiered program. If the sampling results are above a
benchmark value, or outside of the benchmark range, for any parameter at any outfall then the facility shall
follow the Tier 1 guidelines which require a facility inspection within two weeks and implementation of a
mitigation plan within two months. If during the term of this permit, the sampling results are above the
benchmark values, or outside of the benchmark range, for any specific parameter at a specific discharge outfall
two times in a row (consecutive), then the facility shall follow the Tier 2 guidelines which require a repetition of
the steps listed for Tier 1 and also immediately institute monthly monitoring for all parameters at every outfall
where a sampling result exceeded the benchmark value for two consecutive samples.
6. The permittee is required to collect all of the analytical and qualitative monitoring samples during representative
storm events as defined in Part II Section B. Qualitative monitoring is required regardless of representative
outfall status.
7. The permittee is responsible for all monitoring until the renewal permit is issued. See Footnote I of Tables 1, 4,
and 5.
8. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall parameter is in
this permit, however.)
9. Vehicle maintenance monitoring has been revised to semi-annually in order to coincide with analytical and
qualitative monitoring.
Other Proposed Changes to the Previous Permit:
1. Additional guidance is provided about the Site Plan requirements. The site map must now identify if the
receiving stream is impaired and if it has a TMDL established. It must also describe potential pollutants in each
outfall. The map requirements are stated more explicitly. And, the site plan must contain a list of significant
spills that have occurred in the past three years and also must certify that the outfalls have been inspected to
ensure that they do not contain non-stormwater discharges. Additional information is provided in Part II Section
A.
2. Additional requirements for the Stormwater Management Plan have been specified in Part II Section A. More
details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part II Section A.
The plan must also be updated annually to include a list of significant spills and to certify that the outfalls do not
contain non-stormwater discharges.
4. The facility must now implement a semi-annual Facility Inspection Program of the site's stormwater
management controls as specified in Part II Section A.
5. Information regarding the No Exposure Exclusion has been added to this draft permit. If industrial materials and
activities are not exposed to precipitation or runoff as described in 40 CFR § 122.26(g), the facility may qualify
for a No Exposure Exclusion from NPDES stormwater discharge permit requirements. Additional information
is provided in Part I Section A.
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NC3000369
Discussions with permittee: Reggie Wallace, 4 April 2008, 910.223.4813, [e-mail]
1. Have there been any industrial changes since your previous permit?
a. ANSWER: No
2. How many outfalls do you have? Where are they? I do not see them listed on your site map.
a. ANSWER: One outfall at the overflow of the pond.
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Recommendations: Based on the documents reviewed, the application information submitted on October 6, 2004
sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) Date 0'4/q /6Z
Stormwater Permitting Unit Supervisor CIAJ Date
or Bradley Bentt
Concurrence by Regional Offic%%JJV�,��� /�-� � /j[ Date
Water Quality Supervisor �is�LCt� %(� ��2C� ✓ Date J v
Regional Office Staff Comments
3