NCS000348_Outfall Letter_20180417

Energy, Mineral &
Land Resources
ENVIRONMENTAL QUALITY
April 17, 2018
CPI USA North Carolina, LLC
Attn: Virginia Grace
1281 Powerhouse Drive
Southport, NC 28461
Subject: NPDES Stormwater Permit No. NCS000348
Representative Outfall Status Request
CPI USA North Carolina LLC Southport Facility
Brunswick County
Dear Ms. Grace:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
WILLIAM E. (TOBY) VINSON, JR.
Interim Director
The Wilmington Regional Office staff of the Division of Energy, Mineral, and Land Resources has
reviewed your request received March 22, 2018 for determination that Outfall 1C be granted
representative outfall status for Outfalls 1-6. Based on Mr. James and Mr. Lambe's site inspection on
April 17, 2018, we are approving this request. In accordance with 40 CFR §122.21(g)(7), you are
authorized to sample Outfall 1C as the representative outfall. This approval is effective with the next
sampling event. However, this approval is contingent on the following requirements:
(1) All outfalls, regardless of representative status, must have a cleared path and the right of way to
the outfall must be properly maintained.
(2) The permit still requires that Qualitative Monitoring be performed at all Stormwater Discharge
Outfalls, regardless of representative status.
(3) Revise the site map to accurately depict all sampling points. Sampling points should be defined
with GPS data, pictures, and site labels.
(4) Ensure that the Outfall 1C is within CPI USA North Carolina LLC leased property. Define leased
area on site map. Please submit the site map for our files.
In addition, please remember that any actions you initiate in response to benchmark exceedences as
directed in the tiered response provisions of your permit must address all drainage areas represented by
Outfall 1C, where appropriate.
Please append this letter to your Stormwater Pollution Prevention Plan or permit to document that
representative outfall status has been approved. If changes in drainage areas, structures, processes,
storage practices, or other activities occur that significantly alter the basis of this approval,
representative outfall status may no longer be valid. You should either resume sampling at all storm
water discharge outfalls, or reapply to this office for representative outfall status based on updated
information.
State of North Carolina I Environmental Quality 1 Energy. Mineral and Land Resources
Wilmington Regional Office 1 127 Cardinal Drive Extension I Wilmington, NC 28405
910 7967215

CPI USA North Carolina Southport Facility
Page 2 of 2
I
If you have any questions or concerns concerning this letter and the attached report, please contact
Brian Lambe or me at 910-796-7215.
Sincerely,
Trent James
Environmental Specialist
Land Quality Section
Attachments:
1. BIMS Inspection Checklist)
cc: WiRO Files — Land Quality
Stormwater Permitting Unit
DWR — Central Files, NPDES Permit NCS000348
State of North Carolina I Environmental Quality Energy. Mineral and Land Resources
Wilmington Regional: Office i 127 cardinal Drivc Extension Wilmington. NC 28405
L) K' 7`?6 2!5

Y
Permit: NCS000348
SOC:
County: Brunswick
Region: Wilmington
Compliance Inspection Report
Effective: 05/01/10
Effective:
Contact Person: Virginia Grace
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Expiration: 04/30/15 Owner: CPI USA North Carolina LLC
Expiration: Facility: Southport Power Plant
1281 Power House Dr SE
Aka Cogentrix Dr
Southport NC 28461
Title: Phone: [phone]
Inspection Date: 04/17/2018 EntryTime: 10:OOAM
Primary Inspector: Elsie C James --
Secondary Inspector(s):
Brian P Lambe
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant E] Not Compliant
Question Areas:
M Storm Water
(See attachment summary)
Certification:
Phone:
Exit Time: 12:OOPM
Phone:
Phone:
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCSOCC348 Owner - Facility: CPI USA North Carolina LLC •'+
Inspection Date: 04/17/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Trent James and Brian Lambe inspected the Southport Power Plant in response to a request for representative outfall status.
The site is surrounded by a ditch on three sides with all outfalls 1-6 discharging at outfall 1C. Outfall 5 is not located as per
submitted documents, rather outfall 5 has been sampled at the location of 1 C. All outfalls should be clearly labeled on site
and documented in the SWPPP. Please take pictures of the locations and take GPS data points to avoid any confusion in
the future. Please provide details of all sampling points to this office.
All sampling points did not have corresponding records, assumedly for no flow conditions. These must be documented for
submitted sampling dates in the future.
Representative Outfall Status (ROS) is granted. ALL outfalls are still subject to the qualitative monitoring requirements of
the facility's permit. The ROS approval letter from DEQ must be kept on site with the facility's Stormwater Pollution
Prevention Plan. The facility must notify DEQ in writing if any changes affect representative status.
Please clarify the definition of the site in terms of lease agreements. The question arose if the outfall 1C is within the lease
boundaries due to a November 24; 2014 map submitted with the ROS request. Submit a revised map indicating leased area.
During the inspection, a concern was raised of the bottom ash being uncovered and able to drain to the stormwater system.
This material should be undercover with containment.
Greater attention to housekeeping regarding the TDF is needed. There is scrap TDF throughout the yard. The TDF
stockpile is over the containment walls.
The site is granted representative outfall status to sample at one location, Outfall 1C (formally named outfall 5). This is
contingent on the concerns expressed previously.
Page: 2

M
Permit: NCS000348 Owner - Facility: CPI USA North Carolina LLC
Inspection Date: 04/17/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
0
❑ ❑ ❑
# Does the Plan include a General Location (LISGS) map?
0
❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices'?
0
❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
0
❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
0
❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
0
❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
N
❑ ❑ ❑
# Does the Plan include a BMP summary?
0
❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
E
❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
0
❑ ❑ ❑
# Does the facility provide and document Employee Training?
0
❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
0
❑ ❑ ❑
# Is the Plan reviewed and updated annually?
0
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
0
❑ 1:11:1
Comment
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ❑ ❑ ❑
Comment.-
Analytical
omment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ N ❑
Comment: Analytical monitoring data must include all sampling points in all recorded events, documenting
no flow if applicable.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? E 111:1 ❑
# Were all outfalls observed during the inspection? N ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ E ❑
# Has the facility evaluated all illicit (non stormwater) discharges? E ❑ ❑ ❑
Comment:
Page: 3