NCS000349_Add Info Email_20180913

9/13/2018
Mail - brad [e-mail]
Re:[External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
Leona Miles <[e-mail]>
Thu 9/13/2018 11:32 AM
To:Bennett, Bradley <[e-mail]>; Lawyer, Mike <[e-mail]>;
cc -'Dan Sherman'<[e-mail]>; 'Rick Houser' <rhouser@georgiarenewablepowercom>; 'Mark Fowler GRP'
<mfowler@georgiarenewablepowercom>; 'Art Picken' <[e-mail]>;
9 2 attachments (602 KB)
Lumberton Site Plan.pdf; Revised Contact List.pdf;
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Hello Bradley and Mike:
Below please find responses to questions you raised regarding the North Carolina Renewable Power, Lumberton LLC facility and
stormwater permit renewal application. I hope this information is helpful as an initial start to the renewal process. We can discuss
any additional questions once we meet at the site in the near future.
In addition, there was a question regarding aboveground black piping observed on a Google Earth aerial. The Black Pipes on the
West side of the Waste Water Treatment Plant as shown on the Google Earth Aerial are the hot water feed and recovery pipes to
and from the belt dryers.
Also provided are an updated site figure and facility contact list.
I hope you are both safe and ready for Florence. Take care.
Thank you,
Leona
Le,o�MLA; CHMM
Senior Project Manager
Atlanta Environmental Management, Inc.
2580 Northeast Expressway, NE
Atlanta, Georgia 30345
Office: [phone]
Cell: [phone]
[e-mail]
www.AEM-net.com
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'IhmuFp E:i�rirrrr.l Im�lEvrcia7ion"
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9/13/2018
Mail - brad [e-mail]
From: Bennett, Bradley <[e-mail]>
Sent: Wednesday, August 22, 2018 11:36 AM
To: Leona Miles <[e-mail]>
Cc: [e-mail]; Mark Fowler GRP<[e-mail]>; [e-mail];
Lawyer, Mike <[e-mail]>
Subject: RE: [External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
Leona,
Thanks to you and Art for talking with us yesterday about the Lumberton facility. The information you provided was very helpful in
our process. I just wanted to touch base after the call to make sure we are on track with the things discussed and that we outline
some things that we know we might need. Please correct anything that isn't accurate and let me know about the process you see
moving forward to get the information we might need.
• The facility has changed from a coal fired plant and the fuel used now is a combination of wood/biomass chips and poultry
litter. Yes, this plant no longer uses coal. The fuel source mixture is approximately 70% wood and 30% poultry litter.
• All coal products and materials (ash, etc.) have been removed from the site. The former coal piles and coal ash were
removed from the site in 2016 and are no longer present.
• Facility is still following the same process otherwise — steam electric power generation. The facility still produces steam
electric power.
• The facility purchased additional land and expanded north of the previous site boundary. This area now contains the
wood/biomass that is brought in, wood chipping operation, driers, conveyors for the wood chips, storage barn for dried chips
and other equipment. This area all drains to a new pond that was constructed with the expansion. Please see the attached
figure which shows the stormwater flow to all outfalls at the Plant, including the new outfall (Outfall #9). There is a new
outfall (#9) from the pond. In this northern area of the property there was an area in the Google views that showed storage
of a black material, some covered with a blue tarp. Could you please provide information on what this storage is and what
material is there. The material seen beneath the "blue tarp" in the 2017 google earth aerial was a one time storage of wood
ash from facility operations. The material was placed there following a temporary shutdown. The material was removed and
disposed offsite to Craven AG Services, Carolina Gypsum, or Sampson County Landfill.
• It would be helpful to have a new site map that shows the expanded are _gives information on the material on the site,,
locates all outfalls and gives drainage boundaries for the outfalls. It is likely that we will need to re-evaluate the
representative outfall status as we get a better understanding of the outfalls and drainage areas, etc. This will be handled as
part of the site visit conducted by our Fayetteville Regional Office. Please see the attached figure showing the overall site
drainage and stormwater outfalls.
• Poultry litter is brought in and stored in the storage building that was previously onsite (near the NE part of the ditch that
divides the old and new property). Wood chips go from storage after drying to warehouse (built over the old coal storage)
near the wastewater basins. Wood goes from here on conveyor and mixes with poultry litter and mixture goes to the facility
as fuel for the process. There is an accumulation of material (wood and poultry litter) that falls off the conveyor between the
two buildings near the ditch. This material is collected and put back into the process. It would help to know how long
material stays on the ground here, etc. Veolia, the facility manager, has a monthly PM schedule in place to clean up the fines
or large wood debris.
• In the southeastern section of the facility by the plant there is a silo that collects the ash produced in the process. The ash is
removed from the site by truck on a daily basis. Is any ash stored anywhere else on site? It seems that there is a good bit of
ash produced and the one silo seems small for this collection? Could you provide information on where the ash material is
taken? The wood ash is transported to Craven AG Services, Carolina Gypsum, or Sampson County Landfill. The fly ash is
currently stored in a silo and has several trucks removing the product on a daily basis. Bottom ash is emptied into a concrete
containment via the submerged and incline drag chains located on the north side of the power house.
• In the past few years there were some issues with ash material stored on site and material was removed to offsite locations.
Mike asked about this process and if all that material had been removed from that site and taken care of. There was an
August 1, 2018 date given in the past for completion of this process. The Pembroke facility no longer receives the wood ash
from the Lumberton facility. The wood ash is disposed offsite to Craven AG Services, Carolina Gypsum, or Sampson County
Landfill. North Carolina Renewable Power, Lumberton LLC (NCRP-Lumberton) is in the process of conducting additional
cleanup of soil from previous stormwater runoff. This effort is anticipated to be completed by end of the year. NCRP-
Lumberton is working with Mr. Andrew Hammonds, NCDENR, to complete this effort.
• If there has been any monitoring data collected from Outfall 9 (discharge from the pond) can you please provide the results
of that monitoring. There has been no data collected to date from Outfall 9 as this portion of the facility is still under
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9/13/2018
Mail - brad [e-mail]
construction and monitored by the Stormwater Construction Permit. Visual observations are made as part of the
construction/ground disturbing storm water permit that was issued.
As we go through our review it is possible that monitoring locations may change with the changes on site and the addition of
the pond and new discharge for the northern portion of the site. We will also look at the activities now on site and consider
needed adjustments in the monitoring parameters given the changes. This may eliminate some parameters and add others.
This is understood.
I think there may be some ongoing questions about the facility name (Georgia vs NC Renewable Power). We will need to
have that worked out so we know the correct entity for issuance of the permit. We will have to have an owner that is a
registered NC Corporation. The owner and operator of the property is North Carolina Renewable Power, Lumberton LLC.
Georgia Renewable Power is the parent company. Veolia is the current 0&M Company that is in charge of the daily
operations and maintenance of the Plant.
I have also attached the owner/Facility contact information that we have in our database. Please review that and make any
updates/corrections needed and tell us any contacts that need to be removed. A revised contact list is attached.
Hopefully I captured everything here. Mike — please add anything I missed. I tried to underline the things that involve information
we may need from you guys.
Thanks again for your help!
�3 3
From: Leona Miles [mailto:[e-mail]]
Sent: Monday, August 20, 2018 10:45 AM
To: Bennett, Bradley <[e-mail]>
Subject: RE: [External] RE: Permit Renewal for NCS000349 Stromwater NPDES, Permit
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Hi Bradley
Would 2pm Tuesday work? We can call you if that time is good.
Thanks
Leona
le na,Mapak, CHMM
Senior Project Manager
Atlanta Environmental Management, Inc.
2580 Northeast Expressway, NE
Atlanta, Georgia 30345
Office: [phone]
Cell: [phone]
[e-mail]
www.AEM-net.com
TVs_ 5o,17
ZhmuRh E:i�r:,r�r.l lee�mreiaiiun"
From: Bennett, Bradley <[e-mail]>
Sent: Monday, August 20, 2018 10:27 AM
To: Leona Miles <[e-mail]>
Subject: RE: [External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
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9/13/2018
Leona,
Mail - brad [e-mail]
Sorry I'm just responding. I was out all last week. Anyway, I am in the office today and all day on Tuesday and Wednesday. Today I
could be available at 2:00. On Tuesday I'm available 1:00 through 4:00 and Wednesday I'm available all day.
Let me know what might work for you.
Thanks
7:3
From: Leona Miles [mailto:[e-mail]]
Sent: Tuesday, August 14, 2018 2:53 PM
To: Bennett, Bradley <[e-mail]>
Subject: Re: [External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment t( Report Spam.
Hi Bradley
So sorry for the late response. Are you available on Monday, August 20th? I am available anytime from 7am til 3pm.
Thanks
Leona
Sent from my iPhone
On Aug 4, 2018, at 11:05 AM, Bennett, Bradley <[e-mail]> wrote:
Ms. Miles,
Thanks for getting in touch. What we really need as we start the renewal process is to have a better
feel for the operational changes at the facility. From some discussions we have had it is apparent that
the facility has switch from coal to other fuel sources and we would like to talk about the new set up,
materials that have changed, etc. After those discussions there may be additional information needed
to help with the renewal process. There are a couple of emails in this chain that have a brief
description of some areas we are interested in at this point. The information we have in house at this
point is the renewal application that came in back in 2014. There appear to be some major changes
since that time so a good bit if the information we have may need to be updated.
I work part time and I'm usually in the office Monday -Wednesday. If you are available to talk this week
let me know the day/time that works the best for you.
Thanks
Bradley Bennett Note New Office Phone
Stormwater Program Phone: [phone]
NC Division of Energy, Mineral & Land Resources Fax: [phone]
1612 Mail Service Center Email: brad ley. [e-mail]
Raleigh, NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
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9/13/2018
Mail - brad [e-mail]
From: Leona Miles <[e-mail]>
Sent: Friday, August 3, 2018 1:21 PM
To: Bennett, Bradley
Subject: FW: [External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
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Report Spam.
Hello Mr. Bennett
I am working with GRP Lumberton regarding the renewal of Stormwater NPDES Permit NCS000349.
I am out of the office next week, but can be available by phone or email. I am not sure where in the process
we are with the renewal or what information you have received. Would you please give me a call on my cell
phone, [phone], to discuss what you need in order to process the renewal application.
Thank you,
Leona
LeavewMice; CHMM
Senior Project Manager
Atlanta Environmental Management, Inc.
2580 Northeast Expressway, NE
Atlanta, Georgia 30345
Office: [phone]
Cell: [phone]
[e-mail]
www.AEM-net.com
<image001.jpg>
From: Mark Fowler GRP<[e-mail]>
Sent: Tuesday, July 31, 2018 12:07 PM
To: Leona Miles <[e-mail]>
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9/13/2018
Mail - brad ley. [e-mail]
Cc: 'Art Picken' <[e-mail]>; Rick Houser<[e-mail]>
Subject: FW: [External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
Here is correspondence with Mr. Bennett.
Thanks,
Mark
From: Bennett, Bradley[mailto:[e-mail]]
Sent: Wednesday, July 18, 2018 2:40 PM
To: Mark Fowler GRP<[e-mail]>
Subject: RE: [External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
Mr. Fowler,
Thanks for talking with me yesterday about your Lumberton facility. I hope you got the information I
forwarded about the process for rescinding permits for the Elizbethtown facility.
Please let me know when you and other appropriate staff can have a conference call to discuss changes to
the Lumberton site and how they might impact the permit renewal. Some areas for discussion are noted
below.
• I have attached a printout of contacts we have in our database for the facility. Can you please review
this and let me know if there are changes to contacts and if the owner/facility information is still
accurate?
• Federal regulations changed in the last few years to require electronic reporting of data. We are not
yet at the stage of being able to collect stormwater data this way, but we will have to work to get
accurate outfall location information in our system in order to meet federal requirements for
electronic reporting when our systems can handle the data. If you could provide the lat/long
coordinates for your facility's outfall points that would be helpful.
• If you can provide a summary of monitoring information since your application submittal in April 2014
that would be help as well.
• I am very interested in changes that have occurred in your facility and facility processes since your
application submittal. These will have an impact on pollutants discharged in stormwater runoff. It
appears that the facility may have been closed for a while but is reopened and using different fuel
sources, etc. Descriptions of these changes will be needed to help us in our review.
• With the changes a new site map showing the most up to date layout of activities, outfalls and
drainage will be needed. Looking at the google map of your site it appears that there are some
expanded areas from the site map that was submitted in the 2014 applications. That site plan was
dated 2010.
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9/13/2018
Mail - brad [e-mail]
Next week I will be in the office Monday, Tuesday and Wednesday. Maybe we can schedule a day and time
for a call.
Thanks for your help.
Bradley Bennett
Stormwater Program
NC Division of Energy, Mineral & Land Resources Phone: [phone]
512 N. Salisbury Street Fax: [phone]
1612 Mail Service Center Email: brad ley. [e-mail]
Raleigh, NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
From: Bennett, Bradley
Sent: Tuesday, July 17, 2018 10:53 AM
To: Mark Fowler GRP<[e-mail]>
Subject: RE: [External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
Hi Mr. Fowler,
Just wanted to touch base and see when you were available to talk about your facility in Lumberton?
I also have some questions about a facility for NC Renewable Energy in Elizabethtown NC. This one might be
closed? It needs to either have a permit renewal application submitted or have a request for rescission.
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9/13/2018
Mail - brad ley. [e-mail]
Please let me know when you are available to talk. I will be in the office today and tomorrow and then out
until next Monday.
Thanks
Bradley Bennett
Stormwater Program
NC Division of Energy, Mineral & Land Resources Phone: [phone]
512 N. Salisbury Street Fax: [phone]
1612 Mail Service Center Email: brad ley. [e-mail]
Raleigh, NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
From: Bennett, Bradley
Sent: Thursday, July 12, 2018 11:17 AM
To: Mark Fowler GRP<[e-mail]>
Subject: Re: [External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
Thanks for getting back with me. Next week I'll be in the office Monday through Wednesday. We can
set up a call any of those days that works for you and others that may need to be involved.
Bradley Bennett
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9/13/2018
Mail - brad ley. [e-mail]
Stormwater Program Phone: [phone]
NC Division of Energy, Mineral & Land Resources Fax: [phone]
1612 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
From: Mark Fowler GRP <mfowler@ georgiarenewablepower.com>
Sent: Wednesday, July 11, 2018 8:40 PM
To: Bennett, Bradley
Subject: [External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
CAUTION: External email. Do not click links or open attachments unless verified. Send all suspicious email as an attachment to
Report Spam.
Mr. Bennett,
I have been off, and then working in the field with no communication ability during the days, since the 4th. I
will be back in my office in Birmingham next week. Please let me know the best time to contact you.
Thank you,
Mark Fowler
From: Bennett, Bradley[mailto:[e-mail]]
Sent: Monday, July 02, 2018 2:42 PM
To: Mark Fowler GRP <mfowler@ georgiarenewablepower.com>
Cc: [e-mail]; Rick Houser<[e-mail]>
Subject: FW: Permit Renewal for NCS000349 Stromwater NPDES Permit
Mr. Fowler,
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9/13/2018
Mail - brad ley. [e-mail]
I wanted to touch base and try to set up a meeting to discuss renewal of the stormwater NPDES permit at
the NC Renewable Power facility in Lumberton. After talking with Rick Houser it appears that there have
been some changes at the facility over the last few years that will impact the permit. I think a call to discuss
these will help the process. Rick mentioned that it would be helpful to have you involved in this. If you look
at the original email I sent to William Huggins below you can see some of the items I'd like to discuss.
You can reach me at this email or at my office number — [phone].
I work part time, my schedule this week is to be in the office today (July 2), tomorrow (July 3) and Thursday
(July 5).
Thanks for your help.
Bradley Bennett
Stormwater Program
NC Division of Energy, Mineral & Land Resources Phone: [phone]
512 N. Salisbury Street Fax: [phone]
1612 Mail Service Center Email: brad ley. [e-mail]
Raleigh, NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
From: Bennett, Bradley
Sent: Monday, June 25, 2018 12:17 PM
To:'[e-mail]' <[e-mail]>
Subject: RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
Hi Mr. Houser. Just wanted to touch base and see if you guys have thought any about a day/time that we
could have a call about the permit renewal.
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9/13/2018
Thanks
Mail - brad [e-mail]
m
From: Bennett, Bradley
Sent: Wednesday, June 13, 2018 3:13 PM
To:'[e-mail]'<[e-mail]>
Subject: FW: Permit Renewal for NCS000349 Stromwater NPDES Permit
Mr. Houser,
Thanks for talking with me today. Below is the email I sent to Mr. Huggins yesterday. As I mentioned, it
would be really helpful if we could have a conference call sometime early next week if that would work out
for you and others that need to be involved.
Thanks
Bradley Bennett
Stormwater Program
NC Division of Energy, Mineral & Land Resources Phone: [phone]
512 N. Salisbury Street Fax: [phone]
1612 Mail Service Center Email: brad ley. [e-mail]
Raleigh, NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
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9/13/2018 Mail - brad [e-mail]
From: Bennett, Bradley
Sent: Tuesday, June 12, 2018 4:16 PM
To:'[e-mail]' <[e-mail]>
Subject: Permit Renewal for NCS000349 Stromwater NPDES Permit
Hello, and first let me apologize for how long it has taken us to get going on your permit renewal. A number
of issues over the last few years have led to a backlog on renewal of our Individual permits. I would like to
set up a time where I can call and talk with you about the renewal. I will be working on this process. Since
the previous renewal application came in back in 2014 I'm guessing there may be some changes that we
should discuss and possibly have documented for the renewal. In addition, here are a few additional items
that would be helpful if you can provide updates:
• I have attached a printout of contacts we have in our database for the facility. Can you please review
this and let me know if there are changes to contacts and if the owner/facility information is still
accurate?
• Federal regulations changed in the last few years to require electronic reporting of data. We are not
yet at the stage of being able to collect stormwater data this way, but we will have to work to get
accurate outfall location information in our system in order to meet federal requirements for
electronic reporting when our systems can handle the data. If you could provide the lat/long
coordinates for your facility's outfall points that would be helpful.
• If you can provide a summary of monitoring information since your application submittal in April 2014
that would be help as well.
• I am very interested in any changes that may have occurred in your facility or processes since your
application submittal that could affect pollutants discharged in stormwater runoff. It appears that the
facility may have been closed for a while but is now reopened and may be using different fuel sources,
etc. Descriptions of any changes will be needed to help us in our review.
• If there have been changes, a new site map showing the most up to date layout of activities, outfalls
and drainage will be needed. Looks at the google map of your site it appears that there are some
expanded areas from the site map that was submitted in the 2014 applications. That site plan was
dated 2010.
I work part time and I am generally in the office three days a week. I will be in the office tomorrow (June
13th) and then out the rest of the week. I'll be back in the office Monday — Wednesday of next week.
Maybe we can find a day/time that works over the next week to talk.
Thanks
Bradley Bennett
Stormwater Program
NC Division of Energy, Mineral & Land Resources Phone: [phone]
512 N. Salisbury Street Fax: [phone]
1612 Mail Service Center Email: brad ley. [e-mail]
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Raleigh, NC 27699-1612
Email correspondence to and from this address may be subject to public records laws
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