NCS000349_Review Document_20181030

Last updated 10130118
NC Division of Energy, Mineral and Land Resources
Review of Permit Renewal — NCS000349
NC Renewable Power - Lumberton
• SIC 4911— Electrical Services — Steam electric power generation.
• Monitoring —The facility has been monitoring for 13 priority metals (Ag, As, Be, Cd, Cr, Cu, Hg, Ni, Pb, Sb, Se, TI, Zn),
Al, B, COD, TSS, Sulfate, and pH. Previous permit did have tier system. 2014 application indicted that the facility had
not been operating since 2009 when the last permit was issued. So, data submitted with renewal may not have
been characteristic of the facility. Also appears that there have been major process changes at the facility that may
impact monitoring. Need to talk with Facility contacts — see discussion below.
o Reviewed data from 2011 through 2013 from renewal. Reported numbers were below benchmark level
with the exception of Cu, Zn. Again, these numbers were from a facility that was not operating. Also
looked at DMR data in files and in Laserfiche through 2017. Metals numbers above benchmark on occasion
as well as TSS and COD, largely exceedances for Cu and Zn but a few others like Al.
o Reviewed online information related to poultry litter and wood ash. Found nutrients (N and P) are the main
issues for litter although some metals may be found as well. For wood ash the main parameters of concern
appear to be metals. The Pellet Fuels Institute (PFI) and ISO studies have established standards that include
the testing of eight metals (As, Cd, Cr, Cu, Pb, Hg, Ni and Zn). Wood ash can have higher concentrations of
metals as the burning process consolidates some components. The metals selected will provide
information if there are any contaminated wood sources. TSS and COD also valuable parameters where
wood and biomass material are onsite.
o Parameters proposed for the permit Al, As, Cd, Cr, Cu, Hg, Ni, Pb, Zn, COD, TSS, TP, TKN, Total Ammonia as
Nitrogen (TAN) and pH. Consider adding fecal coliform due to the poultry litter on site. Add fecal, also
Mike noticed Al not in draft and should be maintained since they continue to exceed.
o Tier structure adjusted to have the three levels as in current permits.
o Parameter codes added to permit.
• Discussed site issues with Mike Lawyer (FRO) 6/13/2018. Mike confirmed that the facility has restarted and their
processes have changed. The facility is no longer coal fired. They have changed to the use of wood along with some
poultry litter. Mike noted that at one point during Hurricane Matthew the facility was flooded and they had issues
with DEMLR and DWM on the ash materials onsite that lead to some changes. Recently they have been hauling to
landfills and to farms. Need to get more info from them on their process now with this. Also need to look at how
they are handling poultry litter onsite. Mike provided another facility contact — Rick Houser — to contact.
Email to Bill Huggins — 6/12/18. 6/13/2018 - Called Rick Houser [phone] and forwarded email to him so he
could get other Corporate staff involved in discussions. Other calls and emails to Rick, he wants corporate staff to
participate but they have not responded to our emails and calls. 7/12/18 — return email from Mark Fowler with
corporate office in Birmingham. 7/17/18 — call with Mark — some ongoing legal issues with appropriate contact,
owner name will still be NC Renewable Energy. Apparently have been some changes with their consultants. He did
indicate they have added a fuel yard and they have monitored the use of the poultry materials. Poultry materials
and wood are mainly under roof. It was unclear exactly what he meant but he indicated AQ had designated some of
the materials as a non -waste? The facility no longer uses coal and does not have any coal ash onsite. They do have
a wood ash material. Asked him for updates on site plan, monitoring, etc. Sent Mark an email with information
needed. Also sent info on rescinding their permits (SW and WW) for their Elizabethtown facility which has been
closed and they no longer have access to the site.
Conference call with Leona Miles and Art Picken — 8/21/2018. Mike also participated in call. See page 2 for email
that summarizes call and gives information about site. Leona provided responses and extra documents in email on
9/13/18. Copies in file and in Laserfiche folder.
• Facility drains to UT to Lumber River in the Lumber River Basin, a class C; Sw stream. 2016 Assessment Report 11-
13(e) shows no impairment of concern for this facility in this area.
• NC National Heritage review — NHP report shows no aquatic resources in the project area. In the one mile radius
around the facility there are three fish species noted, but there is insufficient information to establish the viability
and accuracy of data is not high. No Federally listed species.
• FRO — Mike has site visit scheduled for September 13th - cancelled due to storm. Sent email to Mike with
questions/issues to consider with site visit. Site Visit —Oct 15t -See summary of discussion with Mike after site visit
— page 3.

Last updated 10130118
From: Bennett, Bradley
Sent: Wednesday, August 22, 2018 11:36 AM
To: 'Leona Miles'
Cc: '[e-mail]'; 'Mark Fowler GRP'; '[e-mail]'; Lawyer, Mike
Subject: RE: [External] RE: Permit Renewal for NCS000349 Stormwater NPDES Permit
Attachments: NCS000349 Contacts Report.pdf
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.
• All coal products and materials (ash, etc.) have been removed from the site.
• Facility is still following the same process otherwise — steam electric power generation.
• 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. 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.
• It would be helpful to have a new site map that shows the expanded area, 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 reevaluate 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.
• 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.
• 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?
• 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.
• If there has been any monitoring data collected from Outfall 9 (discharge from the pond) can you please provide the
results of that monitoring.
• 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.
• 1 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.
• 1 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.
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!
BB

Last updated 10130118
Discussion with Mike after site visit—10/10/18:
• Bottom ash is deposited into a three -sided concrete pit (located in site map). They use a front-end loader to move
material to tractor trailer to be hauled off to either Carolina Gypsum or Craven Ag Services. Appears that this area is
contained. Could be some exposure where they load onto the trailer for haul off, Mike discussed with them. They may
have some piles in that area when the trailer is filled.
• Northern portion of the site (N of ditch) all drains to the new pond. A lot of exposure of materials in this drainage area,
mainly wood chips and saw dust. They don't chip on site and don't use the saw dust regularly. They screen the material
and large pieces become rejects and are hauled off. Outfall 9 at the pond should be monitored to establish
characteristics.
• Outfall 5 continues to have exceedances and monitoring should continue.
• Area where poultry litter and biomass are merged on conveyor. There is spillage and material remains on ground for
some period of time. Area drains to Outfall 7. Outfall 8 appears to be closed off now as the yard grate is closed off.
Should monitor 7 to get a feel for the characteristics of discharge here. Some area of bottom ash goes to 7 but most
drains to outfall 1.
• Mike recommends monitoring for Outfalls 5, 7 and 9 and adding fecal monitoring. Outfall 5 is representative of 1-8
excluding 7. They could look at change to ROS in the future if warranted.
• Facility is revising site map to show drainage with catch basins and drainage patterns etc.
• Fly ash silo didn't show much residual material. Material loaded and hauled off regularly.
• No coal remaining on site. Material was removed and excavated.
• Mike also road by the Pembroke facility where the wood ash debris was taken. They are a little behind on this but making
progress.
• Mike noted that the draft permit should include Cu and Al and these parameters were not in the draft he reviewed. Also
noted the need to add reference in the permit to the three outfalls as representative.
• Send Leona form for owner affiliation change. — emailed link to online process 10/15/18.