NCS000349_Facility Comments on Draft_20181129

4WAtlanta Environmental Management, Inc.
Environmental Consulting, Engineering, Hydrogeologic Services
November 30, 2018
Mr. Bradley Bennett
North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
Stormwater Permitting Program
Water Quality Permitting Section
512 North Salisbury Street
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Re: Draft Stormwater NPDES Permit No. NCS000349
North Carolina Renewable Power —Lumberton, LLC
1866 Hestertown Road, Lumberton, North Carolina 28358
AEM Project No. 1507-1801
Dear Mr. Bennett:
On behalf of North Carolina Renewable Power —Lumberton, LLC (NCRP—Lumberton),
Atlanta Environmental Management, Inc. (AEM) is providing this letter in response to the Draft
Stormwater NPDES Permit that was submitted for review on October 30, 2018. We appreciate
the opportunity to respond. As it relates to the Draft Permit conditions provided, NCRP—
Lumberton has the following comments:
1. Section B, Page 8—Foot note Item No. 3 states that SDO #5 is representative of
outfalls #1 through #6 and #8. Outfall #8 is no longer present. This outfall was closed
out due to high traffic causing damage to the outfall. Additionally, regrading of the area
has occurred and storm water flow is toward Outfall #7.
2. Section B, Table 1—states that semiannual monitoring is to be conducted. Under the
previous permit, NCRP—Lumberton initially started with semiannual monitoring but due
to exceedances has been sampling under the Tier II protocol. Please provide
clarification regarding the sampling frequency to be conducted upon issuance of the
new permit. Does NCRP—Lumberton start with semiannual sampling and, if any
exceedances are identified, follow the protocol for Tiered response actions?
3. The previous permit noted that if pH values outside the benchmark range are recorded
in sampled stormwater discharges, but ambient rainfall data indicate that precipitation
pH levels are within +/- 0.1 standard units of the measured discharge values or lower,
then the lower threshold of the benchmark range would not apply. Readings from an
on -site or local rain gauge (or local precipitation data) must be documented to
demonstrate that background pH readings were below the benchmark pH range. Does
this exemption no longer apply as it is not provided in the current draft permit?
2580 Northeast Expressway • Atlanta, Georgia 30345
Telephone: [phone] Fax: [phone]

Mr. Bradley Bennett—NCDEQ Stormwater NPDES Permitting
November 30, 2018
Page 2
If you have any questions, please do not hesitate to contact us at [phone] or via
e-mail at [e-mail].
Sincerely,
Atlanta Environmental Management, Inc.
"Leona Miles, CHMM
SenioManager r
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Janet T. Hart
President
/krf
cc: Carey Davis (North Carolina Renewable Power) via e-mail
Ciaran McManus (North Carolina Renewable Power) via e-mail
Rick House (North Carolina Renewable Power) via e-mail
Art Picken (AEM) via e-mail
Attachment
182141COVER LETTER