NCS000369_Email RE FRO Site Visit_20180411

Bennett, Bradley
From: Lawyer, Mike
Sent: Wednesday, April 11, 2018 11:58 AM
To: Bennett, Bradley
Cc: [e-mail]; [e-mail]
Subject: RE: Permit Renewal Draft for Review and Site Inspection
Attachments: Compliance Evaluation Inspection_Butler Warner Generation Plant_NCS000369_
4-10-18.pdf
Bradley,
Conducted inspection at the Butler/Warner Generation Plant yesterday. A copy of my inspection report is attached for
your review and files. Facility is in compliance with the current/expired permit. Please see comments regarding draft
permit renewal below.
• no objections to removal of Iron from their analytical monitoring requirements
• based on the amount/capacity of #2 fuel oil storage at the facility (five million gallons) and a few historical oil
spills, the addition of Non -Polar Oil & Grease to their analytical monitoring requirements might be warranted;
they do however have a robust spill prevention and response plan and visually check their ASTs and associated
piping as well as their large (5 -acre) stormwater pond on a daily basis
• secondary containment for the fuel oil tanks is in the form of earthen/vegetated dikes without a liner
• as referenced in my inspection report, there have been no exceedances of benchmark values from 2013 to 2017
and the facility is very well operated and maintained
Please let me know if you need more detail on the comments above or any further information about the facility.
Michael Lawyer, CPSWQ
Environmental Program Consultant
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
910 433-3394 office
mike.lawyerOa ncdenr.gov
225 Green Street, Suite 714
Fayetteville, NC 28301
_�Nathtng Compares
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From: Bennett, Bradley
Sent: Wednesday, March 14, 2018 1:03 PM
To: La Bounty, Tim L <[e-mail]>; Lawyer, Mike <[e-mail]>
Subject: Permit Renewal Draft for Review and Site Inspection

Tim and Mike
Hey Guys! If you haven't heard yet (Mike we've talked so I know you've heard), I'm back working part time on individual
stormwater permit renewals. My schedule is generally Tuesday—Thursday but I modify it some based on how the
weather looks and what I'd rather be doing!
I'm asking for your comments on the attached draft individual NPDES Stormwater permit renewal for Butler/Warner
Generation Plant (Fayetteville PWC) — NCS000369.
Attached are the following documents for your review:
1. Draft permit NCS000369
2. Cover letter to permittee —outlines the major changes from the previous permit
3. NCS000369 Renewal application from permittee
4. Some supplemental monitoring data for the last few years since the application.
The last inspection of their facility that we did looks to have been in 2008. Fayetteville is doing regular inspections under
their MS4 program and I think Mike said they usually copy you on their reports. We are proposing to modify their
monitoring just slightly because the data over the last 10 years is coming in under the benchmarks (see cover letter for
info on the specific changes). We are maintaining some base parameters in the draft permit. I would appreciate your
feedback on this to see if you feel monitoring should be different in any way. I've also adjusted the draft a little with
regards to the footnote that addresses their manual release from their onsite detention pond.
I'm sending the draft permit to the permittee today or tomorrow by mail and the permit is going out to public notice the
first of next week. I would appreciate it if you could schedule a site visit and get me any comments you may have within
the next 30 days. Let me know if that is a problem.
The facility contact person is Ace May — [e-mail] [phone]
Thanks
m
Bradley Bennett Phone: [phone]
Stormwater Permitting Program Fax: [phone]
NC Division of Energy, Mineral and Land Resources Email: [e-mail]
1612 Mail Service Center
Raleigh, NC 27699-1612