NCS000349_Draft Permit Cover Letter_signed_20181102

ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S. REGAN
Secretary
WILLIAM E. (TOBY) VINSON, JR.
Interim Director
November 2, 2018
Mr. Carey Davis
NC Renewable Power
2100 Southbridge Pkwy, Suite 540
Birmingham, Al 35209
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000349
N.C. Renewable Power - Lumberton, LLC
Robeson County
Dear Mr. Davis:
Enclosed with this letter is a copy of the draft stormwater permit for your facility. Please review the draft
carefully to ensure thorough understanding of the conditions and requirements it contains.
The draft permit contains the following significant changes from the facility's current permit:
1. You are required to collect analytical and qualitative monitoring samples during "measurable storm
events" as defined in Part II, Section B. This term is different from the "representative storm event"
in earlier permits.
2. Requirements for the Stormwater Pollution Plan (SPPP) have been updated in Part II, Section A.
3. Monitoring requirements in the draft permit have changed from the previous permit. Your
previous permit was issued when your facility was a coal fired facility. With your facility's fuel
changes to wood and other biomass the permit monitoring requirements have been adjusted to
better characterize the stormwater discharges from the site. With the wood debris and wood ash
onsite our review has indicated that a number of metals should continue to be monitored in addition
to total suspended solids, chemical oxygen demand and pH. With the addition of poultry waste in
your process the permit draft also includes monitoring for nutrients and fecal coliform. We have also
considered recent monitoring results that continue to show benchmark exceedances for some
parameters. The draft permit requires analytical monitoring at three outfalls - #5, #7 and new outfall
#9.
Monitoring is proposed for Total Suspended Solids (TSS), Chemical Oxygen Demand (COD), Total
Aluminum (Al), Total Arsenic (As), Total Cadmium (Cd), Total Chromium (Cr), Total Copper (Cu),
Mercury (Hg), Total Nickel (Ni), Total Lead (Pb), Total Zinc (Zn), Total Phosphorous (TP), Total
Kjeldahl Nitrogen (TKN), Total Ammonia as Nitrogen (TAN), Fecal Coliform and pH. You will also
notice that a number of parameters (Antimony, Beryllium, Boron, Selenium, Silver and Thallium)
have been proposed for removal in the draft permit due to previous monitoring results and changes
ROUNA
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North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh, North Carolina 27699-1612
919.707.9200

Draft Permit NCS000349
Page 2
to your activities onsite. Comments received during the notice process could result in changes to
parameters if it is determined that your facility has the potential to discharge other pollutants
through stormwater.
Please note that for several of the metals parameters the benchmark values have changed since the
last permit. The table below shows the changes.
Parameter
2009 Benchmark
m L
2018 Benchmark
m L
Arsenic
0.36
0.34
Cadmium
0.001
0.003
Copper(Cu)
0.007
0.010
Lead Pb
0.030
0.075
Nickel Ni
0.260
0.335
Zinc Zn
0.067
0.126
Stormwater benchmarks remain in the permit as before. Keep in mind that benchmarks are not
permit limits, but rather guidelines for implementing the Stormwater Pollution Prevention Plan
(SPPP). A benchmark exceedance is not a permit violation; however, the permittee must respond to
exceedances. The draft permit has modified the tiered response process for benchmark
exceedances consistent with other permits in our program. Please become familiar with the tiered
process as proper response under the tiers may be enforceable items under your permit. Response
to the tiered process may include review of onsite conditions, installation of BMPs or requirements
for more frequent monitoring.
4. Vehicle maintenance monitoring parameters have been revised. Non -Polar Oil & Grease [EPA
Method 1664 (SGT-HEM)] replaces Oil & Grease/TPH. The benchmark for Non -polar Oil & Grease
using this method is 15 mg/L. This requirement appears in all individual stormwater permits;
however, it only applies to facilities that perform onsite vehicle maintenance activities. If the facility
begins vehicle maintenance during the permit cycle, the requirements shall apply. Also, pH
monitoring is no longer required for discharges only associated with vehicle maintenance activities.
The vehicle maintenance language in the permit has also been modified to clarify that these activities
include not just vehicles, but also other similar equipment maintenance activities that may be
exposed to stormwater. This has always been the Division's implementation of this requirement, but
hopefully the adjusted language is a little clearer about this process.
5. Language has been added under Part II Section D to address potential responses to qualitative
monitoring issues.
6. A new section on Special Conditions has been added in Part II, Section E to comply with federal
regulations requiring electronic submittal of discharge monitoring reports. Our electronic
submittal process is not available for use at this time, but we will continue to provide feedback on
when this process will be available.
7. Civil and administrative penalty amounts have been updated to reflect current federal law in Part
III, Section A, 2(b) and (g).
8. The definition of Bulk Storage of Liquid Materials was revised in Part IV Definitions to omit the
language "located in close proximity to each other" as it applies to multiple above ground storage
containers having a combined storage of 1,320 gallons.

Draft Permit NCS000349
Page 3
Please review the draft permit and submit any comments to me no later than 30 days following your
receipt of the draft. Comments maybe emailed to Annette Lucas atannette.lucas(@ncdenr.gov or mailed
to her attention at NC DEMLR, Stormwater Permitting Program, 1612 Mail Service Center, Raleigh, NC
27699-1612. With this notification the Division will solicit comment on this draft by publishing a notice
in a local newspaper. Following the 30 day public comment period, the Division will review comments
and take appropriate action prior to issuance of the final permit.
If you have any questions, please contact me at [phone] or Annette Lucas at [phone].
Sincerely,
Original Signed by Bradley Bennett
Bradley Bennett
Stormwater Permitting Program
Attachment: Draft Permit NCS000349
cc: Tim LaBounty, DEMLR Fayetteville Regional Office - via email
Stormwater Permitting Program Files