NCS000350_FINAL PERMIT_20091014

" »___.__ STORMWATER^DIVISI-ON-CODING"SHEET—
PERMIT NO.
�Soc)03�0
DOC TYPE
�P FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
❑ COMPLIANCE
❑ OTHER
DOC DATE
❑ 1 (o I y
YYYYMM DD

Cogentrix
Edgecombe Genco, LLC October 14, 2009
An Affiliate of Cogentrix Energy, hoc.
Mr. Dave Parnell
North Carolina Division of Water Quality
Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-1628
OCT 1 6 2099
s L_ -
i DENR RAI.EI JH .9EGi0;n,11L C r"
RO. Box 370
6358 Old Battlehoro Road
Battlehoro, NC 27809
252442-0708
Fax [phone]
Subject: Response to Compliance Evaluation Inspection (CEI) dated 10.2.09
For Edgecombe Genco LLC, Storm Water Permit NCS000350
Edgecombe County
Dear Mr. Parnell:
In regards to the CEI conducted by yourself and Autumn Hoban of the Raleigh
Regional Office on May 20, 2009 for NPDES permit compliance, Edgecombe wishes to
respond to three listed action items from the Inspection Summary:
The Individual Sto►mwater Permit expired on April 30, 2007 and the Sformwater
Permitting Unit has not received an application for renewal. Please note that an
application for renewal is required 6 months prior to the expiration of the permit.
Neglecting to apply for the renewal of the permit is a violation of North Carolina
General Statue 143-215-1....
Edgecombe Genco response:
Edgecombe has on file (EHS 1.8.2) a copy of the permit renewal application submitted to
NCDENR-DWQ on October 25, 2006. The permit application was submitted via certified
mail. Attached to this letter are copies of the original submittal and of the certified mail
receipt.
2. SDO 001was visited during the inspection. As noted above, SDO 001 has
continuous flow, and therefore, both qualitative and analytical monitoring is
required.... Qualitative monitoring is currently being conducted at SDO 001, but
analytical monitoring results were not produced. Please begin sampling the
discharge from the storm wailer pond immediately as required by your permit
There was some discrepancy in the SDO numbering shown on the SPP plan (SDO
001) and DWQ records (SDO 005) which creates confusion. Please notify this office
of the correct SDO number.
Edgecombe Genco response:
In regards to analytical testing of the Storm Water Outfall, our decision not to conduct the
analytical portion was based on Section B; Analytical Monitoring Requirements Footnote 2
to Table 1 which says:

•
• Page 2
0 October 15, 2009
If the storm water runoff` is controlled by a storm water detention pond, a grab sample
of the discharge from the pond shall be collected within the fast 30 minutes of
discharge. If the detention pond discharges only in response to a storm event
exceeding a ten year design storm, then no analytical monitoring is required and only
qualitative monitoring shall be performed.
A letter was submitted to Mr. Chuck Wakild of NCDENR-DWQ on March 16, 2007 detailing
the specifics for our determination that this pond was a storm water detention pond, and,
therefore, exempt from the analytical monitoring required by the permit. In Mr. Wakild's
response dated April 30, 2007, while accepting that the pond's status changed from a storm
water detention pond to a wet detention pond with the addition of an orifice to release
ground water collected by the pond, he stated the pond was NOT a storm water detention
pond but a wet detention pond and analytical monitoring was required. However, at that
point in time the time period encompassed by the storm water permit had expired (April 30,
2006 was the latest time period covered for analytical monitoring).
Based on Mr. Wakild's response, Edgecombe did pull analytical samples from the storm
water detention pond discharge. These samples were analyzed for Total Suspended Solids
and Chemical Oxygen Demand along with the speck rainfall event data. Edgecombe
submitted these results to Central Files on three occasions dated: 04/16/07, 10/25/07, and
03/05/08. If those results cannot be found, we will resubmit them.
Since seven sampling events were required by the now -expired permit, Edgecombe Genco
will conduct four more quarterly sampling events to complete the requirement for SDO 5
(Stormwater Outfall 5) flow and rainfall permitting. The results of the analysis will be
submitted to NCDENR-DWQ once received. As indicated, we will designate this outfall as
SDO 5. Once the new Stormwater Permit is issued, we will conduct all of the required
monitoring per the permit requirements.
3. Lastly, the now -expired permit listed the discharge location as Beech Creek and that
is the terminology used in the narrative of our SPPP plan. However, based on your
letter, we will change the description to Beech Branch.
While your letter stated that we should respond by September 15, 2009, it seemed apparent
that October 15, 2009 was the intended response date since your letter was dated 10.2.09.
Should you require any more information, please do not hesitate to contact me at: (252)
442-0708 or via email ([e-mail]).
Bill Maiden
General Manager, Edgecombe Genco, LLC

• Page 3 0
0 October 15, 2009
Cc: Rick Neff, VP Environmental Affairs
Cheryl Sawyer, a -copy
David Herring, Environmental Manager
EHS File (1.4)

�ocv,�rFAoc ,RMIT COVERAGE
RENEWAL APPLICATION FORM
National Pollutant Discharge Elimination System
Stormwater Discharge Permit
Permit Number
NCS000350
THIS APPLICATION MUST HE SIGNED AND RETURNED ALONG WITH THE REQUESTED SUPPLEMENTAL
INFORMATION TO THE DIV.OF WATER QUALITY IN ORDER FOR YOUR FACILITY TO QUALIFY FOR
RENEWAL OF YOUR STORNIWATER PERMIT NCS000350
The following is the information currently in our database for your facility. Please review this information carefully
and make all corrections as necessary in the space provided to the right of the current information.
OWNER INFORMATION
Owner/Org.'Name: EDGECOMBEGC"NCOLLC
O%%mer Contact:
Mailing Address:
Phone Number:
Fax Number
E-mail address:
FACILITY INFORMATION
Facility Name: EDGECOMBE GENCO, LLC-RATrLEBORO
Facility Contact:
Facility Address: 6358 OLD BATTLEBORO RD
BATTLEBORO. NC 27809
Phone Number:
Fax Number
E-mail address:
PERMIT INFORMATION .
Permit Contact: ate
Mailing Address: PO BOX 370
BA17LEBORO, NC 27809
Phone Number: 2524420905
Fax Number:
E-mail address:
DISCHARGE INFORMATION
Discharge Receiving Water:
Stream Class:
Basin:
Sub -Basin #:
Number of outfalls:
CERTIFICATION
Q daem l S. F -do--m e r
P. 0. Bck 310
6—'-- 1-4 n_
75214442• 0-708
Sd'ir fto Arc 5, Per- %I►lixr
(Zs214yz• o1alc Cur. 401
44 .
(Z52) 44Z . Ot'iV p Ck T. 402
azz 6%
—f'ra►� �h►wn�: tea_ Q.:a�t_
I certify that 1 am fa 'liar with the informat' n contained in the application and that to the best of my knowledge and
belief such inform n is t , complete a accurate.
Signature Date
n O d
C_ A Aar Jr FnYrn v E2 C� G•�taxl "1At _
Print or type name of person signing ab6ve Title
Please return this completed renewal application form to: ,
r'n—n t 1 '.- , t
nf=
Individual Permit Renewal y=' J
Attn: Mr. Mike Randall '^`
Stormwater and General Permits Unit �141� OCT 16
1617 Mail Service Center
Raleigh, North Carolina 27699-1617 I
OE1V4i

0
SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL NPDES
STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application to be
considered complete:
(Do not submit the site Stormwater Pollution Prevention Plan)
Initials
r7t.4i 1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of materials, disposal areas, process areas and
loading and unloading areas), drainage structures, drainage areas for each outfall, building
locations and impervious surfaces should be clearly noted.
't>-A- 2. A summary of Analytical Monitoring results during the term of the existing permit (if your
permit required analytical sampling). Do not submit individual lab reports. The summary
can consist of a table including such items as outfall number, parameters sampled, lab
results, date sampled, and storm event data. *
1_ 3. A summary of the Visual Monitoring results. Do not submit individual monitoring reports.
The summary can consist of a table including such items as outfall number, parameters
surveyed, observations, and date monitoring conducted.
4. A summary of the Best Management Practices utilized at the permitted facility. Summary
should consist of a short narrative description of each BMP's in place at the facility. If the
implementation of any BMP's is planned, please include information on these BMP's.
5. A short narrative describing any significant changes in industrial activities at the permitted
facility. Significant changes could include the addition or deletion of work processes,
changes in material handling practices, changes in material storage practices, and/or
changes in the raw materials used by the facility.
6. Certification of the development and implementation of a Stormwater Pollution Prevention
Plan for the permitted facility (Sign and return attached form).
* If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal, then the last years monitoring results should be
submitted within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal
submittal waiting on lab results)
Representative storm sampling may now be conducted anytime during the year (the April to
November window has been eliminated) and the representative rainfall event is now
defined as a storm event that measures greater than 0.1 inches and is preceded by at least 72
hours in which no storm event measuring greater than 0.1 inches has occurred.

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Dranage Area 1
00A NO
Outal No 1
Drainage Area 1
Drainage Area J �r--____+_..._---, ...• '
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J /;• .. Drainage
J
L_T"
. a
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u v Drainage Area 3
ro BrdlA > ushMu • Cum {g1°ns7
Q eider Buadi ng HP54414 2 at 1,000 and 100
OS1292 100: 150; and 2 ■! 400
' Sodium hydrondda 100: 150
Q Turbine BusdinQ Lubncati0n W tanks 2 at 2,000
' ••_® -r-�- Continuum 3153 1.625
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no FGO SyWm Lana N!A (sold)
a Blip Houses Ash WA (solcQ
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_
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WA
r Trandormar yards
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r 01 Trap Pe
Mist. 01 Products
t1
a Admilmisbution Dole@
WA
L Dannaaerlezer BrAidkg
Sulfuric
130; and
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SodKn h�N�d10%(df
280; am {.BOO
dawn kill
300
r DmIYa Tank
Mils sastswelor
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ETE=
Wastewater
36,WO
FP. Trmw
7nmbmwr 0s
125
r E>•rctnChemkah
BD1500
400
G Unloading 8ry
WA
WA
Drainage Area 9
e Raw wrier Tanks
WA
WA
(dram s wa;arraar 8")
■ Dumpaters/Unly, Wade
WA
WA
* CoWft Taxers
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WA
u wafNwdar Onskns
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- \
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V wadewew sold ft
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og
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a
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w wanhoure r shop
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WA
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WA
WA
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1.Y500
Drainage Area 7 _ d
01�ose1 TanNo. 2
Kerosene Tank
300
•
Trw*INT r al
990
Legend
Paved Surface > Stamlwater Flow Direction
Gravel sulfate -------- SWmmater Sewer (buried)
- Drainage Area Boundary 0 Drainage Catch Basin
Stern anoint b sbnnwatBrGUtfall
_ = Drainage Swale ® PalantiaSly Exposed AllaterM
„�^• Storlmwator overland Fbw Aree Drainiry b wastewater System
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fterriars'
Amia Woft.- • Arsn
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saw Bain
No.1
14.75
240
12..35
4.56
31%
16% 0A2.0A3,Ma,DAS
Ne.2
US
_
1.75
1.20
69%
0% BAr
Ne.3
1.41
1.41
0.42
30%
o% av
No.4
1.61
1.01
0,47
29%
9% 0A10
No.5
1.C2
-
1.02
0,24
21%
0% OAS
Drslard Floe
S.76
-
5.75
1,54
32%
0% OAi
No Orard
Z70
2.70
-
100% am
Figure 3. Edgecombe Generating, LLC; Rocky Mount Plant
Site Plan Showing Drainage Features and Areas Where Industrial Materials are Potentially Exposed to Stormwater
Bay 2
WA
WA
Car Spar And
Hr8nikc al
30
L.ocomova Parkeg
NW- 01 products
cm
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n Cod Statlmut C°nvay0r
Coal
Cad Pie
Coal
Cod Conveyor
Cod
n Laydown Ana
WA
WA
9 10 sw ad
Scale ((eat)

Item 3. Summary of Visual Examination of Stormwater Runoff Data
Edgecombe Generating, LLC; NPDES Stormwater Permit No. NCS000350
Parameter
OutfallI
Outfall2
Outfail3
Outfall4
Outfall5
Color and Extent
Absent
Absent
Absent
Absent
Absent
Odor
Absent
Absent
Present
Present
Absent
Clarity or Turbidity
Absent
Absent
Absent
Present
Present
Floating Solids
Absent
Absent
Absent
Absent
Absent
Settled Solids
Absent
Absent
Absent
Absent
Present
Foam
Absent
Absent
Absent
Absent
Absent
Oil Sheen
Absent
Absent
Absent
Absent
Absent
Other Obvious Indicators of
Absent
Absent
Absent
Absent
Absent
Stormwater Pollution
Notes: I. See EHS Form 055 for description of the parameters.
2. The "Present" odor at Outfalls 3 and 4 was observed to be
"musky"; neither Outfall drains an industrial area of the plant.
3. The "Present" turbidity at Outfalls 4 and 5 is likely due to
influences from farm field immediately east of the Plant.
Edgecombe Generating, LLC - Location of Stormwater Outfalls
------='�='�-+ Stormwater
•�:�
— -�"y i- = Outfall No 5
,If V o
Stormwater Stormwater ` r
Oulfall No. 1 Oulfall No. 2
�?U
r r o�
Stormwater Stormwater
Walt No. 3 Oulfall No. 4

WORKSHEETA5 Facility: Edgecombe Generating, LLC
EXISTINGITRADITIONAL STORMWATER MANAGEMENT Rev.: I
PRACTICES WORKSHEET Date: October 23, 2006
Page: I
BEST MANAGEMENT PRACTICE
COMMENTS
Maintenance of Secondary Containment Areas — See Table A5.1 for secondary
containment area details. All secondary containment areas will be routinely observed to
determine fitness for service; any deficiencies will be reported to the Plant management.
Preventative Maintenance and Good Housekeeping Program —The Rocky Mount Plant
regularly maintains and keeps in a clean, orderly manner, areas which may contribute
pollutants to storm water discharges. Good housekeeping procedures implemented at the
facility include the following:
I. Perform general weekly inspections of facility and equipment areas to maintain a
safe and trash free environment. Street sweeping is performed as needed.
2. Routinely inspect exposed plant equipment for leaks or conditions that could lead
to discharges of chemicals or petroleum products. Records of inspections are kept
in the fax room on the first floor of the administration building.
3. Proper inventory control procedures to insure that stored chemicals and petroleum
products are maintained at the minimum level necessary.
4. Proper material storage practices to ensure that materials are stored in containers
adequate for the locations, such that corrosion and deterioration of the containers
is minimized. This includes proper labeling of all containers and maintenance of
MSDS on materials stored.
The preventive maintenance program for the facility includes inspecting and maintaining
the storm water management devices, equipment, and systems, on a semi-annual basis, to
prevent the discharge of pollutants to surface waters. In addition, the storm water
management devices, equipment, and systems are visually inspected on a daily basis. Bulk
storage tanks, transformers, and heavy equipment are inspected on a quarterly basis, and
visually inspected on a daily basis. Records of quarterly/semi-annual inspections are kept
in the Administration Building.
Employee Training — The Plant conducts annual training programs for personnel
responsible for any aspect of storm water management, including those individuals
responsible for implementing activities identified in the Plan. This training will inform
responsible personnel of the components and goals of the Plan and will address topics
related to storm water management, such as:
1. Good housekeeping;
2. Spill prevention and response; and
3. Material handling and storage practices.
In addition, each member of the Plant's Pollution Prevention Team will undergo initial
training on the Plan prior to implementation. If a member joins the Team after the Plan has
been implemented, they will be trained prior to becoming listed in the Plan as a Team
member. Where possible, employee training under the Plan can be conducted in
conjunction with training under other regulatory programs (e.g., hazardous waste
management training, SPCC training). Currently Plan training is conducted at least
annually through the safety meeting program. Employees attending Plan training will sign
the attendance roster. Names of those in attendance are recorded in a plant -wide training
matrix. A manager and/or section leader will follow up with employees who were not in
attendance at the Plan training. Records of the training programs will be maintained on file
in the Administration Building.
Responsible Party — The Plant Manager is the responsible party for the Rocky Mount
Plant. See Section 2.2 above, for the Plant Manager's signed certification of this
Stormwater Pollution Prevention and Stormwater Management Plan

9
•
WORKSHEETAS Facility: Edgecombe Generating, LLC
EXISTING/TRADITIONAL STORMWATER MANAGEMENT Rev.: I
PRACTICES WORKSHEET Date: October 23, 2006
Page: 2
BEST MANAGEMENT PRACTICE
COMMENTS
Plan Amendment — The Rocky Mount Plant will amend/revise the Plan whenever there is
a change in design, construction, operation, or maintenance which has a significant effect
on the potential for the discharge of pollutants to surface waters. The Stormwater Pollution
Prevention Plan will be reviewed and updated on an annual basis.
Facility Inspection Program — One of the core stormwater requirements is to conduct
Facility Inspections on at least an annual basis — Worksheet A2 can be used for this
purpose. Members of the Pollution Prevention Team will conduct the evaluation annually.
This evaluation provides a basis for evaluating the overall electiveness of the SWPP Plan.
The compliance evaluation includes the following elements:
1. A visual INSPECTION of the site
2. Based on the results of the INSPECTON, revisions to the SWPP Plan and
implementation of any additional measures and controls
3. A written report summarizing the results of the annual evaluation (Worksheet A6
may be used for this purpose)
Implementation of changes — Based on the results of the annual INSPECTION, necessary
revisions to pollution prevention measures, controls, and the SWPP Plan should be initiated
within 2 weeks of such INSPECTION. Revisions should be completed within 12 weeks of
the INSPECTION.
• The SWPP Plan shall be reviewed and the following sections updated, where
necessary:
• Changes to the Pollution Prevention Team member roster (Worksheet C 1)
• The inventory of SIGNIFICANT MATERIALS and BMPs (Worksheet AI, Site Drainage
Map)
• The history of significant SPILLS and leaks (Worksheet B 1)
A report summarizing the CSC Evaluation will be prepared and maintained in accordance
with Worksheet A6 in the Plan. Among other things, this Report will summarize major
observations relating to the implementation of the Plan, describe necessary or appropriate
revisions to the Plan, and identify incidents of noncompliance with the Plan. If no
incidents of noncompliance are identified in the Report, the Rocky Mount Plant will certify
that the facility is in compliance with this PLAN.
The CSC Evaluation Report, and any necessary certification, will be maintained on file in
the Administration Building.

0
•
WORKSHEETA5 Facility: Edgecombe Generating, LLC
EXISTING/TRADITIONAL STORMWATER MANAGEMENT Rev.: I
PRACTICES WORKSH EET Date: October 23, 20D6
Page: 3
BEST MANAGEMENT PRACTICE
COMMENTS
Pollution Prevention Team — Worksheet Cl in Appendix C identifies individuals within
the facility organization who have been designated as members of the facility Pollution
Prevention Team. Team members are responsible for implementing and maintaining this
Plan.
The number of members on the team will vary depending on the size of the facility. As a
standardized approach, the FACILITY MANAGER and the Compliance Supervisor assigned to
the facility ("Facility Compliance Supervisor") are core members of the team and are listed
in Worksheet Cl. FACILITY MANAGERS are encouraged to assign additional site members
to the team as part of their employee involvement initiatives. Additional Pollution
Prevention Team members and their responsibilities should be listed in Worksheet C1.
The FACILITY MANAGER is ultimately responsible for the implementation of this Plan. The
FACILITY MANAGER is accountable for the prevention of SPILLS and leaks that could
adversely impact surface water or ground water. The FACILITY MANAGER is responsible
for ensuring that:
1. The Plan is implemented, maintained, and amended at the intervals required in the
Plan;
2. Appropriate measures and controls (BMP's) are implemented and maintained;
3. Periodic INSPECTIONs are conducted;
4. Corrective or follow-up actions are completed in a timely manner;
5. All SPILLS are promptly reported and cleaned up; and
6. Employees are periodically trained on Pollution Prevention.

•
P
Worksheet A5.1
Summary of Secondary Containment at the Edgecombe Generating, LLC; Rocky Mount Plant
Largest
Containment
Plan Section /Location
Map
Description
Significant Material
Capacity
Single
Rainfall
Volume
Runoff
ID
(gallons)
Capacity
(gallons)
(gallons)
Direction
(gallons)
6.2.1 / Boiler Building
A
Various boiler chemicals
Unit 1 Bulk Tank for HP54414
1,000
Unit 2 Bulk Tank for HP54414
1,000
Unit I Day Tank for HP54414
100
Unit 2 Day Tank for HP54414
100
Unit 1 OS1292 Tote
400
1,000
N/Al
2,100�"
N/A'
Unit 2 OS1292 Tote
400
Unit 1 OS 1292 Day Tank
100
Unit 2 OS 1292 Day Tank
150
Unit 1 Sodium hydroxide tank
100
Unit 2 Sodium hydroxide tank
150
6.2.2 / Turbine Building
B
Turbine tube oil sumps
Lubricating oil
2,000
N/Al
See Note 4
N/Al
C
EHC units
Hydraulic oil
80
N/A'
270
N/Al
6.2.3 / Transformer Yards I
Transformers
Transformer oil
9,170
N/A5
See Note 4
to Oil Trap Pit
6.2.4 / Oil Trap Pit
J
Oil trap pit
Misc. oil products
9,170
1,420
13,125
Industrial6
6.2.5 / Demineralizer
L
Bulk acid tank
Sulfuric acid
4,500
6,730
NIA`
6,730
NIA'
Building and Adjacent
Bulk caustic tank
Sodium hydroxide
4,500
6,950
NIA`
6,950
N/A'
Areas
Acid day tank
Sulfuric acid
130
340
N/p
340
i
NIA
Caustic day tank
Sodium hydroxide
280
Tank for diesel fire pump
Diesel fuel
300
650
N/A'
650
N/A�
O EFP Transformer Transformer oil 125 650 N/A' 650 Industrial6
P Outdoor chemical storage Continuum AEC3153 1,625
OX1202 (sodium bromide) 400 1,910 N/A6 1,910 Industrial6
BD 1500 400
Page 1 of 2
Print Date: 19.Oct.2006

Worksheet A5.1
Summary of Secondary Containment at the Edgecombe Generating, LLC; Rocky Mount Plant
Largest
Containment
Plan Section / Location
Map
Description
Significant Material
Capacity
Single
Rainfall
Volume
Runoff
ID
(gallons)
Capacity
(gallons)
(gallons)
Direction
(gallons)
6.2.6 / Wastewater
V
Acid drums (2)
Sulfuric acid
55
55
NIA'
55
N/A'
Building
Caustic drums (2)
Sodium hydroxide
55
55
N/A'
55
NIA'
6.2.7 / Drum Storage
Y
Used oil tank
Used oil
500
500
N/A7
2,270
Stormwater7
6.2.8 / Oil Storage
Z
Multiple oil products
Multiple oil products with a
55
55
NIA'
350
N/A'
• Builidng
combined volume off1,100-gal
6.2.9 / Rail Car Unloading Bb
Diesel Tank No. I
Diesel fuel
1,000
Area
Diesel Tank No. I
Diesel fuel
250
I,000
2,810
14,380
Stormwater
Kerosene tank
Kerosene
300
Spare transformer
Transformer oil
99
Dd
Car spotter unit'-s
Hydraulic oil
30
30
130
280"B
Stormwater
.2kn / Locomotive
Ee
Locomotive parking area
Miscellaneous oil products
210
210
120
440
Stormwater
Parking Area
P
Notes: 1. No accumulated water because tar"equipment are located indoors.
2. Exempt from SPCC per 40 CFR 112.1(d)(5).
3. Exempt from Stormwater Permit No. NCS000350 because area is located indoors.
4. Meets 40 CFR 112.7(c) by diversion to the Oil Trap Pit.
5. Oil is in Operating Equipment, no provision for accumulated water required per 40 CFR 112.7(c).
6. Drains into the Wastewater Basin and discharged per NPDES Permit NC0077437, Outfall 003.
7. No accumulated water because tanks/equipment are fully under a roof.
8. Exempt from Stormwater Permit No. NCS000350 because Significant Material is in operating equipment.
Page 2 of 2
Print Date: 19.Oct.2006

I STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION I
CERTIFICATION
N.C. Division of Water Quality, Storinwaier and General Permits Unit
Facility Name: EDGECOMBE GENCO, LLC-BATTLEBORO
Permit Number: NCS000350
Location Address: 6358 OLD BATTLEBORO RD
BATTLEBORO, NC 27809
County: EDGECOMBE
1 certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all attachments
were developed and implemented under my direction or supen ision in accordance with a system designed to assure
that qualified personnel properly gather and evaluate the information required by the SPPP. Based on my inquiry of
the person or persons who manage the system, or those persons directly responsible for gathering the information,
the information gathered is, to the best of my knowledge and belief, true, accurate, and complete"
"I certify that the SPPP has been developed, signed and retained at the facility location and the SPPP has been fully
implemented at the named facility location in accordance with the terms and conditions of the stormwater general
permit."
"1 am aware that there are significant penalties for falsifying information, including the possibility of fines and
imprisonment for knowing violations"
Sign (according to permit signatory requirements) and return this Certification. DO NOT SEND THE
STOR119NWATER POLLUTION PREVENTION PLAN WITH THE CERTIFICATION.
Signature Date / /A x 0L
Print or type name of person signing above Title
SPPP Ccrtirication 2199

LISPS - Track & Conf r n
. Page 1 of I
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Label/Receipt Number: 2103 8555 7491 1159 8473
Status: Delivered
Your item was delivered at 8.13 am on October 25, 2006 in RALEIGH,
NC 27699 to MAIL SVC CENTER . The item was signed for by 8 LENS
si RarurnrallSPScorrrNamo>
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Online Label Record (Label 1 of 1
Signature ConfirmationTm Number:
2103 8555 7491 1159 8473
Not Paid Online
Print Date: 10/24/2008 1 Priority MailO Postage:
Ship Date: 10124t2006 I Signature Confirmation: $1,35
Weight: 4 Ib 4 oz (Electronic Rate)
Total: $6.40
From: RICHARD FRYMYER
EDGECOMBE GENCO, LLC
P.O. BOX 370
BATTLEBORO NC 27809
To: MR. MIKE RANDALL
STORMWATER AND GENERAL PERMITS UNIT
INDIVIDUAL PERMIT RENEWAL
1617 MAIL SERVICE CENTER
RALEIGH NC 27699-1617
Regular Priority Mail rates apply. Signature Confirmation service electronic fee
required. Delivery Information is not available by phone for the electronic rate.
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A POSTAL SERVICES
Check the status of your shipment on the Track & Confirm page at www.usps.com
I ILLP.11 L11S.Gllll III .b1111. UbPbX1UIIII r 1 J111LU111GL yY UU11illG1 "ULIllll u11 Y -uu i V, A. r 1 c.vvu

Beverly Eaves Perdue
Governor
i
MC1 WR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins
Director
10.2.09
Mr. David Herring, Environmental Manager
Cogentrix
Edgecombe Genco, LLC
P. O. Box 370
6358 Old Battleboro Road
Battleboro, NC 27809
Subject: Compliance Evaluation Inspection
NPDES Individual Stormwater Permit NCS000350
Cogentrix
Edgecombe County
Dear Mr. Herring:
Dee Freeman
Secretary
On May 20, 2009, Autumn Hoban and Dave Parnell of the Raleigh Regional Office of the
Division of Water Quality, performed a compliance evaluation inspection (CEI) for the
NPDES Individual Stormwater Permit at the subject site. Your assistance was helpful and
appreciated. The following observations were noted during the Division of Water Quality
inspection:
SITE DESCRIPTION
This is a coal-fired power generation facility. All site stormwater flows into a detention
pond and is then discharged via one stormwater discharge outall (SDO) located on the
southern end of the site. The stormwater is discharged to receiving waters known as an
unnamed tributary to Beech Branch, a Class C, nutrient sensitive water (NSW) in the Tar -
Pamlico river basin. When corresponding with the Stormwater Permitting Unit, please
correct the stream name currently listed as Beech Creek to Beech Branch.
INSPECTION SUMMARY
1. The Individual Stormwater Permit expired on April 30, 2007 and the Stormwater Permitting
Unit has not received an application for renewal. Please note that an application for renewal
Noon Carolina
J41�atura!!�
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Internet: www.ncwaterquality.org 1828 Mail Service Center Raleigh, NC 27609-1628 FAX [phone]
An Equal Opportunity/Affirmative Action Employer - 50% Recvclaril1 nO P­ r-- T — _.

Cogentrix'Energy, Ince
aCbmpffance EvbrIuatfd6 Ihspectfon
is required 6 months prior to the expiration of the permit. Neglecting to apply for the
renewal of the permit is a violation of North Carolina General Statute 143-215.1. Please
contact Jest Jones of the Stormwater Permitting Unit immediately at 919 807.6379,
concerning the permit renewal process.
2. The Best Management Practices (BMP) plan was available during the CEI. The
documented records of BMP inspections were reviewed and they were found to be in order.
3. SDO 001 was visited during the inspection. As noted above, SDO 001 has continuous flow,
and therefore, both qualitative and analytical monitoring is required. A documented record
of the monitoring is required. If the flow is absent, the comment "no flow" should be
entered on the monitoring report. Qualitative monitoring is currently being conducted at
SDO 001, but analytical monitoring results were not produced. Please begin sampling the
discharge from the stormwater pond immediately as required by your permit. There
was some discrepancy in the SDO numbering shown on the SPPP plan (SDO 001) and
DWQ records (SDO 005) which creates confusion. Please notify this office of the correct
SDO number.
4. SDO 001 was sampled during the CEI. The following parameters were reported by the
DWQ Chemistry Lab. Sample result for total recoverable Aluminum (Al) was 510 ug/L.
The Iran (Fe) results were 420 ug/L.
Please address and respond in writing to the above item, shown in bold, to this office, by September
15, 2009. If you have any questions regarding the attached report or any of the findings, please
contact me at: [phone] or email: david.narnell(Zt ncdenrr.gov.
Sincerely,
Dave Parnell
Environmental Specialist
Surface Water Protection Section
Enclosure: May 20, 2009, Compliance Evaluation Inspection
Cc RRO/SWP files
DWQ Stormwater Permitting Unit

Compliance Inspection Report
Permit: NCS000350 Effective: 05/01/02 Expiration: 04/30/07 Owner: Edgecombe Genco LLC
SOC: Effective: Expiration: Facility: Edgecombe Genco, LLC-Battleboro
County: Edgecombe 6358 Old Battleboro Rd
Region: Raleigh
Battleboro NC 27809
Contact Person: Seth Carter Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Data: 05/20/2009 Entry Time: 09:30 AM Exit Time: 03:00 PM
Primary Inspector: David R Parnell
Secondary Inspector(s):
Autumn Hoban
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ■ Compliant Q Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Phone:
Phone: [phone]
Phone:
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000350 Owner - Facility: Edgecombe Genco LLC
Inspection pate: 05/20/2009 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page: 2

Permit: NCS000350 Owner - Facility: Edgecombe Genco LLC
Inspection Date: 05/20/2009 Inspection Typo: Compliance Evaluation
Reason for Visit; Routine
Stormwater Pollution Prevention Plan
Yes
No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
0000
# Does the Plan include a General Location (USGS) map?
■
❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
■
❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
❑ ❑ ❑
# Has the facility evaluated feasible alternatives to current practices?
■
❑ ❑ ❑
# Does the facility provide all necessary secondary containment?
■
❑ ❑ ❑
# Does the Plan include a BMP summary?
■
❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
■
❑ ❑ ❑
# Does the facility provide and document Employee Training?
■
❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
■
❑ ❑ ❑
# Is the Plan reviewed and updated annually?
■
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
■
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
■
❑ ❑ ❑
Comment: Secondary containment adequate.
Qualitative Monitorin
Yes
No
NA NE
Has the facility conducted its Qualitative Monitoring semi-annually?
0000
Comment: Adequate qualitative monitoring
Analytical Monitoring
Yes
No
NA NE
Has the facility conducted its Analytical monitoring?
❑
■
❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas?
❑
❑
■ ❑
Comment: Continuous discharging stormwater pond requires sampling. No analytical
monitoring data available. Recommend measuring sediment in stormwater pond.
Permit and Outfalls
Yes
No
NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site?
■
❑
❑ ❑
# Were all outfalls observed during the inspection?
■
❑
❑ ❑
# If the facility has representative outfa11 status, is it properly documented by the Division?
■
❑
❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges?
■
❑
❑ ❑
Comment: Plant refers to SOO 001, DWQ refers to it as 005.
Page: 3

0
f�
County:
EDGECOMSE
River Basin
Report To
TAR
RROSP
,t�� NA'�A`?EiS>
w q
Collector:
Region:
A HOBAN
RRO
Sample Matrix:
WASTEWATER
Loc. Type:
EFFLUENT
Emergency Yes/No
VisitlQ
COC Yes/No
Loc. Descr.: BAT COGEN 003 SW
Location ID:
BATCOGEN003SW
Collect Date: 05/2012009
Collect Time:: 12:15
Sample Qualifiers and Comments
Sample ID:
PO Number #
Date Received:
Time Received:
Labworks LoginlD
Date Reported:
Report Generated
Sample Depth
IT -
A B44508
9 W4335
05/21/2009
08:15
SMATHIS
711109
0712912009
I "a 6)10q
Routine Qualifiers
For a more detailed description of these qualifier codes refer to www.dwglab.org under Staff Access
A -Value reported is the average of two or more determinations
N3-Estimated concentration is < PQL and >MDL
81-Countable membranes with 40 colonies; Estimated
NE -No established POL
B2- Counts from all filters were zero.
83- Countable membranes with more than 50 or 80 colonies; Estimated P-Elevated PQL due to matrix interference and/or sample dilution
B4-Filters have counts of both >60 or 80 and < 20: Estimated 01-Holding time exceeded prior to receipt at lab.
BrrToo many colonies were present; too numerous to count (TNTC) 02- Holding time exceeded following receipt by lab
!2- Reported value failed to meet QG criteria for either precision or accuracy; Estimated PQL- Practical QuantRation Limit -subject to change due to instrument sensitivity
.!3-The sample matrix interfered with the ability to make any accurate determination; Estimated U- Samples analyzed for this compound but not detected
J5-The lab analysis was from an unpreserved or improperly chemically preserved sample; Estimated X1- Sample not analyzed for this compound
NII-The component has been tentatively identified based on mass spectral library search and has an estimated value
LAB
Laboratory Section>> 1623 Mall Service Center, Raleigh, NC 27699-1623 [phone]
Page 1 of 4
L-
� JUL 3 0 2009

NC (DWQQ Laboratory Section 1�esufts Sample ID AB44508
Loca
tion 0: BATCOGEN003SW Called Date: 0512012009
Loc. Descr.: BAT COGEN 003 SW Collect Time:; 12:15
Visit ID
CAS #
Analyte Name
POL
Result
Qualifier
Units
AnalystfDate
Approved By /Date
w
Sample temperature at recelpt by lab
1.9
'C
HPARKER
SMATHIS
Method Reference
52lM9
521109
WET
Ion Chromatography
_TITLE_
m911-
AWLLIAMS
CGREEN
Method Reference EPA 300.0
618109
6112109
Total Dissolved Solids In liquid
12
165
mg/L
ADEXTER
CGREEN
Method Reference APHA254DC-18TH
5126109
5/28109
Chloride
1
9.6
J8
mg/L
AWILLIAMS
CGREEN
Method Reference EPA 3DO.0
61a109
6/12M9
Fluorlde
0.4
0.4
U J8
mg1L
AWILLIAMS
CGREEN
.
Method Reference EPA 300.0
611109
6/12/09
Sulfate
2
54
J8
mg/L
AWILLIAMS
CGREEN
Method Reference EPA 300.0
6mm
6112M
NUT
NH3 as N In liquid
0,02
0.06
mg1L as N
MAJAYI
CGREEN
Method Reference LaclO.107.06-1-J
5122109
5128109
Total lgeldahl N as N In liquid
0.2
0.47
mg1L as N
MOVERMAN
CGREEN
-
Method Reference Lachaf107-06-2-H
5127/09
612109
NO2+NO3 as N In liquid
0.02
0.05
mg/L as N
MAJAYI
CGREEN
Method Reference LactO-107-04-1-c
5/22N9
528109
Phosphorus total as P In liquid
0.02
0.07
mg/L as P
GBELK
CGREEN
Method Reference Lac10-115.01•tEF
529/09
614109
MET
7440-22-4
Ag try ICPMS
5
5.0
U
ug1L
JJURGEVICH
ESTAFFORD
Method Reference EPA 200.8
5129109
6112f09
7429-90-5
All by ICP
50
510
ug/L
$GOSS
FSTAFFORD
Method Reference EPA 200-7
527109
6112M9
7440-38-2
As try ICPMS
2
7.0
ug/L
BSKINNER
ESTAFFORD
Method Reference EPA200.8
614109
6112/09
7429-90-5
B by ICP
50
65
ug/L
SGOSS
ESTAFFORD
Method Reference EPA 200.7
U28109
6112M9
7440-38-3 Be by ICP 10 21
ug/L
SGOSS
ESTAFFORD
Method Reference EPA 200.7
5/78M
6112/09
7440-41-7 Be by ICP 5 5.0 U
ug1L
SGOSS
ESTAFFORD
Method Reference EPA 2W.7
527109
6112/09
7440-70-2 Ca by ICP 0.1 38
mglL
SGOSS
ESTAFFORD
Method Reference EPA 200.7
528/09
6112109
Laboratory Section? 1623 Mall Service Center, Raleigh, NC 27699-1623 (9191 733-3909
Page 2 of 4

NC CDWQ. La6oratory Section 1�esufts Sample ID AB44508
Location ID: BATCOGEN003SW Collect Date: 0612012009
Loc. Descr.: BAT COGEN 003 SW Collect Time:: 12:15
Visit ID
CbkS f1
Analyte Name
PQL
Result
Qualifier
Units
Analyst/Date
Approved By /Date
7440-03-9
Cd by ICPMS
1
1.0
U
uglL
JJURGEVICH
ESTAFFORD
Method Reference
EPA 200.8
5129109
6112f09
744GA8-1
Cobalt by ICP
50
50
U
uglL
SGOSS
ESTAFFORD
Method Reference
EPA 200.7
5127109
6112109
744047-3
Cr by ICPMS
10
10
U
ug1L
JJURGEVICH
ESTAFFORD
Method Referents
EPA 200.8
529109
6112109
7440-50-8 .
Cu by ICPMS
2
2.0
U
ug1L
JJURGEVICH
ESTAFFORD
Method Referents
EPA 200.8
5i29109
6112109
7439-W6
Fe by ICP
50
420
UgA-
SGOSS
ESTAFFORD
.
Method Reference
EPA 200.7
5I27f09
6112109
7439-97-6
Hg 245.1
02
020
U
ug1L
ESTAFFORD
ESTAFFORD
' Method Reference
EPA245.1
6111f09
61t21o9
7440-09-7
K by ICP
0.1
2.8
mg1L
$GOSS
ESTAFFORD
Method Reference
EPA 200.7
528109
GilV09
7439-93-2
LI ICP
25
25
U
ug/L
SGOSS
ESTAFFORD
Method Reference
EPA 200.7
5128109
6112109
7439-95-4
Mg by ICP
0.1
1.7
mglL
SGOSS
FSTAFFORD
Method Reference
EPA 200,7
5128f09
6112f09
7439-96-5
Mn by ICP
10
34
ug1L
SGOSS
ESTAFFORD
Method Reference
EPA 200.7
5127109
6112M9
7439-98-7
Mo by ICPMS
10
10
U
Ug1L
JJURGEVICH
ESTAFFORD
Method Reference
EPA200.8
5129M9
6112109
7440-23-5
Na by ICP
0.1
7.2
mgfL
SGOSS
ESTAFFORD
Method Reference
EPA200,7
528109
6112109
7440-02-0
NI by ICPMS
10
10
U
ug1L
JJURGEVICH
ESTAFFORD
Method Reference
EPA200.8
6129109
6112M
7439-92-1
Pb by ICPMS
10
10
U
Ug1L
JJURGEVICH
ESTAFFORD
Method Reference
EPA200.8
E129/09
6112109
7440-36-0
Sb by ICPMS
10
10
U
ug/L
JJURGEVICH
ESTAFFORD
Method Reference
EPA 200.9
5129109
6112J09
7782-49-2
Se by ICPMS
5
5.0
U
ugh-
JJURGEVICH
ESTAFFORD
Method Reference
EPA2W.8
5l29f09
'6112109
7440-31-5
Sn by ICPMS
10
10
U
UWL
JJURGEVICH
ESTAFFORD
Method Reference
EPA200.8
5129f09
W12/09
7440-28-0
Tha01um (M ICPMS
10
10
U
13911-
JJURGEVICH
ESTAFFORD
Method Reference
EPA200.8
5129109
6/12/09
Laboratory Section:-:- 1623 Mail Service Center, Raleigh, HC 27699-1623 [phone]
Page 3 of 4

•
i
JVC (DWQ^ La6oratory Section Results Sample ID AB44508
Loption ID: BATCOGEN003SW Collect Date: 0512012009
Loc. Descr.: BAT COGEN 003 SW Collect Time:: 12:16
Visit ID
FEAS #
anaiy a Name
POL Result Qualifier Un;s AnalystfDate
Approved ery /Date
7440-32-6
-
Ti (rttanium) by ICP
-
10 10 U uplL SGOSS
ESTAFFORD
Method Reference EPA 200.7
5128109
6112109
7440-62-2
V by ICP
25 25 U ug/L SGOSS
ESTAFFORD
Method Reference EPA 2D0.7
5127109
611209
7440-66-6 Zn by ICPMS 10 21 ug/L JJURGEVICH ESTAFFORD
Method Reference EPA 20D.8 5129109 61121D9
Laboratory Sectfon>> 1623 Mail Service Center, Raleigh, NC 27699-1623 [phone] Page 4 of 4

•
i
DIVISION OF WATER QUALITY
l J
OChemistry
Mblt
Laboratory Report I Water Qaality
❑ SAMPLIE
Date Received : t, �'V111
COUNTY
RIVER BASIN:
t L'.0 e-
t�
PRIORtiY
❑ AMBIENT ❑ QA
❑ STREAM
5
P(EFFLUENT
Time Recei%vd : J$�a
Reeeiwd By . TlRfS
REPORT TO
�
�'Q/1 i Regional Office
Noa�—
IJ�i MPIJANCE CHAllV OF CIISiODY
❑ L4KE
❑ INFLUENT
1`J � �f 17.did 0+ r
Other
❑EMERGENCY VISIT
❑ESTUARY
Released :
COLLECTOR(S) :
aM ,+{1�A,el3,n,�,
�J �L`�
❑
♦i Dos
Estimated ROD Range*
Station Location:
Seed:
Cliloriaated:
Remarks: _- O T'C t t`l lio l
Station #/Location Cede
Date Cn1 m/dd)
Date End /mm/d)
Time 'n
lime End
Deptb - DM, DR. DBM
Value Type- A, R, L.
Composite-T, S, B
Sample T
—c G-
0�35GJ
o
;6
a:�o
D dV6!lti
BOD 310 mg/L
COD High 340 mg(L
COD Low 33 5 mg/L
Coliform: MF Fecal 31616 /loom[
Coliform: MF Total 31504 /100m]
Coliform: tube Fecal 31615 /loom]
Coliform- Fecal Suep 31673 /loom]
Residue' Total 500 mg/L
Volatile 505 mp/L
Fixed 510 mR/L
Residue: Suspended 530 mg/L
Volatile 535 mgrl.
Fixed 540 mg/L
pH403 units
Acidity to pH 45 436 mpfl..
Acidity to pH 8.3 435 mglL
Alkalinity to pH 8-3 415 mg/L
Alkalinity to 9H 45 410 MVL.
TOC 680 m13/1.
Turbidity 76 NRl
Coliform Total Tube 1100 ml
Chloride 940 mg/L
Chlorophyll a EPA 445.0 modified aption ugIL
Color: True 80 c u-
Color: (pH) 83 PH. C.U.
Colar.pH7-6 82 C.U.
Cyanide 720 mglL
Fluoride 951 mg/L
Formaldehyde 71980 m91L
Grease and Oils $56 n*L
Hardness Total 900 mg/L
Specific Cood. 95 umhos/cm
MBAS 39260 mg/L
Phenols 32730 ug/L
Sulfate 945 MIX
Sulfide 745 mE/L
Boron
Tannin & Ligrin u#L.
Hexavalent Chromium ug/L.
Bicarbonate r4l,
Carbonate milt.
otal Di solwd Solids mg/L
NH3 as N 610 mg/L
TKN an N 625 mg/L
NO2 plus NO3 as N 630 mg/l,
P: Total as P 665 mg/L,
PO4 as P 70507 m8/L
P; Dissolved as P 666 mg/L
K-Potassium mvrL
Cd-Cadmium 1027 ua/L,
Cr-ChromiumTotal 1034 ug/L
Cu-Copper 1042 ug/L
Ni-Nickel 1067 uSIL
Pfr Lead 1051 ug/L
Za-Zinc 1092 ug/L
V-Vanadium ug/L
Ag- Silva 1077 ug/L
A]- Aluminum 1105 ug/L
Be -Beryllium to12 ug/L
Ca- Calcium 916 n*L
Co -Cobalt 1037 ug/L
Fe- Iron 1045 uy/L
Mc -Molybdenum up/L
Sb-Antimony ug/L
Sn-Tin ng/L.
71 ThOlium ug/L.
Ti-Titanium ug/L.
Hg-1631 ng/L
Li -lithium 1132 ug/L.
Mg- Magnesium 927 Eng(L
Mn-Manganese 1055 ug/L
Na- Sodium 929 ti mg/L
Arsenic Total 1002 ug/L.
Se- Selenium 1147 uS/L,
Lig- Mercury 71900 ug/L
Ba-Barium ug/L
i ides
o irides
OrSmonitrogm Pesticides
Acid Herbicides
BawJNeutrA&Acid Extractable Organics
TPH Diesel Range
Purgeable OrgLnics (VOA bottle Teq'd)
TPH Gasoline Mange
TPHBTEX Gasoline Ransc
Phytoplankton
Temperature on arrival (*Q:

COUNTY
E7 4, ` l..L' I Cl C—
RIVER BASIN
I r,
REPORT TO
A L Q.i Regional Og«
Other
�} r
COLLECTOR(S) :
2a39
Estimated BOO Range:
Seed;
Chlorinated:
slab..ttfL—&-Cede
35iN
Date (7?', m/dd
09 05�at�
•
13013310 m8/1.
CO➢ High 340 mgfL
COD Low 335 rng/L
Cnliform: MF Fecal 31616 /100m]
Coliform: MFToad 31504 /IOOmi
Coldb mtube Fecal 3160 /IOOmI
Coliforrn: Fecal Strap 31673 /100m1
Residue Total 500 n%/L
Volatile 505 m9/1-
Fixed 510 m91L
Resdue. Suspended 530 131811-
Volatile 535 mg/L
Fixed 540 mng(L
pH 403 units
Acidity to pH 45 436 mg/L
Acidity to pH 8.3 435 mail..
Alkalinity to pH 83 415 mg/L
Alkalinity to pH 4.5 410 mg/L
TOC 680 mg/L,
Turbidity 76 NfU
Coliform Total Tube /100 fill
COMMENTS: D , L /1 a S D T- 1 `i of 0
DIVISION OF WATER QUALITY
Chemistry Laboratory Report / Water Qaality
SAMPLE TYPE
EtIp--- ORfCY
5
❑ AMBMM QA
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❑
SUtioa Location:
Remarks; �}-'r.'
L-fiC..L£YY✓
Ie End `yY/tom�'/
n9r�sao
rime Time End A Depth - DM, DX DBM
Ti1 sp La:�
Valera Type - A, R, L
Chloride 940 maL
Chlorophyll a EPA 445.0 modified option ug/L
Color: True 80 c.u.
Color: (pH) 83 pH= c u,
Color. pH T6 82 c.u.
Cyanide 720 nrwrL
Fluoride 951 migrL,
Formaldehyde 71880 marl.
Grease and Oils 556 mglL
Hardness Total 900 mg/L
Specific Cond. 95 umhoshm
MBAS 39260 mg/L
Phenols 32730 ug/l.
K.Sul&e
945 mg(L
Sulfide 745
Boron
Tannin & lrgnin ug'L.
Hexavadent Chromium ug/L
Bicarbonate m911.
Carbonate ng/L
otal Dissolved Solids marl.
NM as N 610 mg(L.
TKN an N 625 mg(L
NO2 plus NO3 as N 630 mg/L
P_ Total as P 665 mg/L
PO4 as P 70507 mg(L
P: Dissohed as P 666 nwL
K-Potassium ffwjL
Cd-Cadmium 1027 ug/L
CY-Chrornium:Total 1034 uAfL
Cu- Copper 1042 ug/L
Ni-Nickel 1067 ug/L
Pb- Lead 1051 uarL.
Zn- Zinc 1092 ug/L
V-Vanadium ug/L
A, Silver 1077 ug/L
A] -Aluminum 1105 ug/L
Be- Beryllium t012 ugIL
Ca- Calcium 916 rwL
Co -Cobalt 1037 ug/L
Fe -iron 1045 ug/L
Mc -Molybdenum ug/L
Sb-Amimony ug/L
Sn-Tm ug(L
Ti-Tlia]liron UWL
Ti-Titarnum ug/L
Hg-1631 ng/E.
Lab Number :
IAte Reixived :
Time Received:
Reclined By
Composite-T, S, B
Li-Lrhium 1132 ug/L
Mg-Magirsium927 nigh.
Mn-Mangancst 1055 ug(L.
Na-Sodium 929 mail.
Atsenic-Toial 1002 ug/L
Se-Selmiumlid7 ugrl.
SMercury 71900 ug/L,
Ba-Barium ugR.
es
Or 'idea
Orb-onarogetn Pesticides
Acid Herbicides
Base/Neutral&Acid Extractable Organics
TPH Diesel Range
Purge -able Organics (VOA bottle req'd)
TPH Gasoline Rwge
TPH/BTF.X Gasoline Range
Phytoplankton
Temperature on arrival (°C):
l /J lIF "®r,

Repprte ,by
a
Checked by
Reviewed by
Sample Matrix: WASTEWATER Emergency Ye&No
E^fDWQLaboratory
L90 �UaJytical4lgport
COC Yes/No
Sample ID: AEA4508
Supervisor
Date
AS # Analyte Name PQL Resutt Qualifier Units CAS # Anatyte Name PQL ResuR Qualifier Units
Sample temperature at receipt by 1.9 °C
s

Reported'by
'Checked by
Reviewed by
E-NWIDUAQLabaratory Sample ID: AB44608
"t E7 AMdy6ra(q?,?port Supervisor
Date
Sample Matrix: WASTEWATER
Emergency Yes/No
COC YeslNo
AS # Analyte Name
PQL Result
Qualifier
Units CAS # Anatyte Name PQL Result Qualifier Units
Total Dissolved Solids in liquid
12 12
165
mg1L
Chloride
1 1
9.6 J8
mg1L
Fluoride
1 0.4
0.4 U,J8
mg1L
Ian Chromatography
1
_TITLE_
mg1L
Sulfate
1 2
54 J8
mg1L
P
•

Reported'by
'Checked by
Reviewed by
f R/bWQLa6oratnry
9VI&T 4mdytmd eport
Sample iD: AB44508
Supervisor
Date
Sample Matrix: WASTEWATER
Emergency Yes1No
COC YeslNo
AS # Analyte Name
PQL Result
Qualifier
Units CAS # Ana" Name PQL Result Qualifier Unite
141i3 as N in liquid
O.02 0.02
0.06
ig/L as I
Total Kjeldahl N as N in liquid
0.2 0,2
0.47
ig/L as I
NO2+NO3 as N in liquid
0.02 0.02
0.05
ig/L as I
Phosphorus —total as P in liquid
0.02 0.02
0.07
iglL as 1
0

Reported by
Checked by
Reviewed by
EAWjfI7WQGa6orato7y Sample ID: AB44508
MET -AnaFyticaf"rt Supervisor
Date
Sample Matrix: WASTEWATER Emergency Yes/No COC Yes/No
AS # Analyte Name PQL Result Qualifier Units CAS # Ana" Name PQL Result Qualifier Units
7440.224
Ag by ICPMS
5.0
5
5.0 U
ug/L
. 429-90.5
Al by ICP
50
50
510
ug/L
7440-38-2
As by ICPMS
2.0
2
7.0
ug/L
7429-90-5
B by tCP
50
50
65
ug/L
7440-38-3
Ba by ICP
10
10
21
uglL
744041-7
Be by ICP
5.0
5
5.0 U
ug/L
7440-70-2
Ca by ICP
0.10
0.1
38
mg/L
7440-43-9
Cd by ICPMS
1.0
1
1.0 U
ug1L
440-484
Cobalt by ICP
50
50
50 U
ug/L
44047-3
Cr by ICPMS
10
10
10 U
ug/L
7440-50-e
Cu by ICPMS
2.0
2
2:0 U
ug/L
7439-89-6
Fe by ICP
50
50
420
uglL
7439-97-6
Hg 245.1
0.2
0.2
0.20 U
ug1L
7440-09-7
K by ICP
0,10
0.1
2.8
mg/L
7439-93-2
Li ICP
25
25
25 U
uglL
7439-95-4
Mg by ICP
0,10
0.1
1.7
mglL
7439-96-5
Mn by tCP
10
10
34
ug/L
7439-98-7
Mo by ICPMS
10
10
10 U
uglL
7440-23-5
Na by ICP
0.10
0.1
7.2
mg/L
7440-02-0
Ni by ICPMS
10
10
10 U
ug/L
7439-92-1
Pb by ICPMS
10
10
10 U
ug/L
7440-36-0
Sb by ICPMS.
10
10
10 U
ug/L
778249-2
Se by ICPMS
5.0
5
5.0 U
ug/L
7440-31-5
Sn by ICPMS
10
10
10 U
ug/L
7440-2"
Thallium (fl) ICPMS
10
10
10 U
ug/L
7440-32-6
Ti (Titanium) by ICP
10
10
10 U
ug/L
440-62-2
V by ICP
25
25
25 U
ug/L
7440-66-6
Zn by ICPMS
10
10
21
ug/L

RepQrteei by
Checked by
Reviewed by
Sample Matrix: WASTEWATER Emergency Yes/No
EAV,4DRNA0 La6oratory
WET Anafyricaf4Ztport
COC Yes/No
Sample ID: AB44508
Supervisor
Date
AS # Analyte Name PQL Result Qualifier Units CAS # Analyte Name PQL Result Qualifier Units
C!
•

Cogentrix
Edgecombe Genco, LLC
Art Affiliate of Cogentrix Enery); lnc.
April 23, 2007
Mr. Charles Wakild, P.E.
Surface Water Protection Supervisor
North Carolina Division of Water Quality
Raleigh Regional Office
1628 Mail Service Center
Raleigh, North Carolina 27699-1628
P.O. Box 370
6358 Old Battichoro Road
Bar[leboro, NC 27809
252-442-0708
Fax [phone]
Re: Edgecombe Generating, LLC; Battleboro Plant; Edgecombe County
Letter from the Division dated March 30, 2007 including NOV-2007-PC-0151 for:
NPDES Wastewater Permit No. NC0077437
NPDES Stormwater Permit No. NCS000350
Dear Mr. Wakild:
/The purpose of this letter is for Edgecombe Generating, LLC (Edgecombe) to provide the
Division of Water Quality (DWQ) with its comments regarding the above referenced letter (the
"Letter"). The specific comments include:
COMMENT A (ADDRESSING LETTER ITEM 2, FIRST SENTENCE) — the sentence reads:
All site stormwater flows into a detention pond and is then discharged via one stormwater
discharge outfall (SDO) located on the southern end of the site.
The sentence should read:
Site stormwater that potentially contacts industrial materials flows into a detention pond and
is then discharged via one stormwater discharge outfall (SDO) located on the southern end
of the site (identified as Outfall 5 in the existing permit).
COMMENT B (ADDRESSING LETTER ITEM 2, SECOND SENTENCE THROUGH END) — The
correction is noted.
i.
APR 2 4 2007
r f iA1—rsGH ?t-G':G,NAL OFFICE

I**
Os
COMMENT C (ADDRESSING LETTER ITEM 6) — Please note the following regarding the total
residual chlorine (TRC) limits for NPDES Permit NC0077437, Outfall 002 (cooling tower
blowdown):
The facility uses water that is supplied by the City of Rocky Mount; the City uses a
chloramine biocide program. A substantial fraction of the TRC in the cooling tower is from
the chloramines present in the raw water. Chloramines are not as readily reduced by
dechlorination technology (e.g., a sodium bisulfite system), nor are they as readily
volatilized, as are the chlorine and bromine products which the facility uses in its cooling
water biocide program. The facility has had the capability to dechlorinate cooling tower
blowdown since 1993 but has elected not to use it. Rather than rely on a chemical based
treatment program for controlling TRC in the cooling tower discharge, Edgecombe has
reduced both its raw water consumption and discharge to the Tar River, as well as chemical
usage, by:
1. Increasing the cycles of concentration in the cooling tower from f8 to f 12. This change
in cooling tower operation reduces both raw water consumption and cooling tower
blowdown while the increased water residence time in the tower allows for the chlorine
compounds to be consumed; and
2. Cooling tower blowdown continues to first be recycled into the facility's flue gas
desulfurization system (where it is consumed) prior to any "excess" blowdown being
discharged via Outfall 002 —a practice that began in the mid- 1990s. The reduced
blowdown volume that results from the increased cycles of concentration results in
infrequent discharges to Outfall 002 because the tower's blowdown rate when operating
at ±12 cycles is typically equal to water demand for the flue gas desulfurization recycle
system. Edgecombe retains the NPDES Outfall 002 because the supply/demands of the
recycle system are not in perfect balance and there are times when a cooling tower
discharge is necessary. The de minimus flow at Outfall 002 was most recently discussed
with DWQ on November 21, 2005; see Attachment 1.
COMMENT D (ADDRESSING LETTER ITEM 10, FIRST SENTENCE) — Edgecombe disagrees that
analytical monitoring is not being performed as required because:
NPDES Stormwater Permit No. NCS000350 became effective on May 1, 2002.
Therefore, the "years" of the permit are as follows:
o Year 1 — May 1, 2002 through April 30, 2003;
o Year 2 — May 1, 2003 through April 30, 2004;
o Year 3 — May 1, 2004 through April 30, 2005;
o Year 4 — May 1, 2005 through April 30, 2006; and
o Year 5 — May 1, 2006 through April 30, 2007.

2. NPDES Stormwater Permit No. NCS000350 at Part II.B, Table 1 requires analytical
monitoring during Years 1 through 4 only; there is no analytical monitoring requirement
for Year 5;
3. Comment F, below, addresses the issue of the bleed -down orifice at the stormwater
detention pond. For the purposes of this comment, the germane fact is that the bleed -
down orifice did not exist prior to October 2006 (i.e., during Year 5 of the permit);
4. The DWQ inspection conducted on March 8, 2007 occurred during permit Year 5 — a
permit Year during which no analytical monitoring is required. Therefore, Edgecombe
believes that a violation of NPDES Stormwater Permit No. NCS000350 for not
conducting analytical monitoring did not and, could not, occur during a permit Year for
which no analytical monitoring is required;
5. The DWQ also inspected the Edgecombe facility during Years 3 and 4 of NPDES
Stormwater Permit No. NCS000350. It is noted that the DWQ inspector was
accompanied by two inspectors from the USEPA for the Year 4 inspection. The
management and staff at Edgecombe are proud of their environmental performance and
record and welcomes the thorough scrutiny and detailed inspections that DWQ has
provided during this stormwater permit's coverage;
6. Neither of the DWQ inspections conducted during permit Years 3 and 4 concluded that
Edgecombe was not performing required analytical monitoring. Copies of the DWQ
Inspection Reports for those years are presented in Attachment 2; therefore,
Edgecombe believes that it has not and, is not, violating the analytical monitoring
requirements of NPDES Stormwater Permit No. NCS000350 at Part ll.B, Table 1;
and
■ Edgecombe requests that DWQ rescinds NOV-2007-PC-0151 for the reasons
provided above.
COMMENT E (ADDRESSING LETTER ITEM 10, LAST SENTENCE) — Edgecombe began quarterly
monitoring of the stormwater pond on March 9, 2007. This monitoring is being conducted as
a good faith effort and without prejudice to Edgecombe's positions stated in Comments D
and F.

so
COMMENT F (ADDRESSING THE REMAINDER OF LETTER ITEM 10) — The crux of the portions of
Letter Item 10 not contained in the first and last sentences is: DWQ believes that flow from a
bleed -down orifice in a wet detention pond designed and operated per 15A NCAC
02H.1008(e) constitutes a discharge of stormwater to a surface water of the state that is
subject to analytical monitoring. Edgecombe's reading of 15A NCAC 02H.1008(e) is that if
a wet detention pond is constructed/operated per the regulation — as the Edgecombe pond is —
then, water flowing through the bleed -down orifice has been treated for 85% removal of total
suspended solids. Therefore, bleed -down orifice flow is presumed by rule to have met water
quality requirements and is not subject to further regulation (e.g., additional treatment,
analytical monitoring, etc.).
The pond was constructed in 1989 to serve as a stormwater Best Management Practice
(BMP) during the construction and operation of the facility. The pond was designed and
built prior to the promulgation of USEPA's Stormwater Phase I regulations (55 FR 47990)
and DWQ's Stormwater Management Regulations (specifically, the design requirements
found in 15A NCAC 02H. I 008(e)).
NPDES Stormwater Permit No. NCS000350 became effective on May 1, 2002. After
receiving the permit, Edgecombe verified that the design volume of the pond was capable of
detaining a 10-year, 24-hour storm event. The outfall from the pond consisted of a solid
stand -pipe (i.e., no bleed -down orifice was present); the overflow elevation of the stand -pipe
was/is unchanged since the pond's construction. The pond's design in Years 1 through 4 of
the Stormwater Permit was unchanged from that described above. It is noted that pond
maintenance (e.g., removal of accumulated sediment) was conducted in May 2005 (i.e., the
beginning of Permit Year 4) to assure that the pond would continue to operate per the
original design objectives.
In September 2006 (i.e., during Permit Year 5) Edgecombe, with assistance from Cogentrix
Energy, Inc., initiated the renewal process for NPDES Stormwater Permit No. NCS000350.
At that time, the Cogentrix engineer who prepared the facility's Stormwater Pollution
Prevention Plan, Mr. C. Richard Neff, P.E., noted that the facility needed few improvements
in order to qualify for the No Exposure Certification for Exclusion from NPDES Stormwater
Permitting. Edgecombe is pursuing those improvements and expects to be capable to
complete the No Exposure Certification in the near future.

Mr. Neff also noted that the pond's design predated the promulgation of DENR's Stormwater
Management Regulations and recommended that the facility modify the pond's outlet
structure so that it would comply with design requirement presented in 15A NCAC
02H.1008(e)(2)*. The modification to the pond's discharge structure (i.e., addition of a 2-
inch diameter bleed -down orifice approximately 2-feet below the standpipe's crest) was
made in October 2006 (i.e., Year 5 of the Stormwater Permit).
Edgecombe understands that DWQ's interpretation of NPDES Stormwater Permit No.
NCS000350, Table 1, Footnote 2 is that flow from the bleed -down orifice is subject to
analytical monitoring. Edgecombe regrets that its independent attempt to comply with the
design requirements for a wet detention pond created a flow that DWQ has interpreted to be a
violation of the permit. However, Edgecombe's stormwater discharges have not been subject
to any analytical monitoring requirement imposed by the permit since the orifice was
constructed. Therefore, Edgecombe does not believe that a violation of the permit's
analytical monitoring requirements has occurred; see Comment D, above.
COMMENT G (ADDRESSING LETTER ITEM 11) — The March 8, 2007 inspection included an
inspection of Edgecombe's Integrated SPCC and Stormwater Pollution Plan. Appendix C of
the Plan presents the facility's certifications that there are no unauthorized non-stormwater
discharges to the stormwater system. These certifications fulfill the requirements of NPDES
Stormwater Permit No. NCS000350 at Part II.A. L(e) and Part 111.13.3. The certifications
were initiated at the facility in 1996 and have been subject to periodic
inspection/verification/certification since that time. The DWQ's Letter implicitly attests to
this fact in Letter Item 7. A site inspection was conducted at Edgecombe after receipt of
DWQ's Letter and the certification that there are no unauthorized non-stormwater discharges
to the stormwater system was once again verified. The assertion in the DWQ's Letter that
there may be unpermitted industrial wastewater discharges into the Edgecombe stormwater
pond is considered unfounded and baseless.
The only possible source of the flow from the pond's orifice observed during the March 81h
inspection could have been uncontaminated groundwater; an allowable non-stormwater
discharge (see NPDES Stormwater Permit No. NCS000350; Part VI.3.(b)).
15A NCAC 02H.1008(e)(2) state: The discharge rate from these systems following the one inch rainfall design
storm shall be such that the draw down to the permanent pool level occurs within five days, but not in less than
two days

The Edgecombe pond is a "wet detention" design and its normal water surface elevation
therefore approximates that of the local water table, The local water table responds to
precipitation much more slowly than do surface drainage freatures and the water table can be
observed discharging into surface features (e.g., Beech Branch, the Edgecombe wet detention
pond) weeks after the precipitation has ended. Prior to the installation of the orifice, the
Edgecombe pond's elevation could be affected by water table inflow for weeks at a time.
Since its installation, the bleed -down orifice has functioned as envisioned in 15A NCAC
02H.1008(e)(2); namely, the elevation of the pond is restored to the design level in 2 to 5
days after a rainfall event. And, the infiltrating groundwater that arrives weeks after the direct
precipitation and surface runoff will accumulate in the pond only if the local water table is
below the pond's design pool elevation (i.e., orifice invert); otherwise it will flow through the
orifice.
Thank you for the opportunity to respond to the DWQ's March 30, 2007 letter. Please contact
me if you require further information regarding this matter.
I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate
and complete. I am aware that there are significant criminal penalties for submitting false
information, including the possibility of fines and imprisonment for knowing violations.
Sincerely,
,t
Richard S. Frymyer
General Manager

0•
November 21, 2005
Mr. Kenneth Schuster
North Carolina Division of Water Quality
Raleigh Regional Office
1628 Mal Service Center
Raleigh, NC 27699-1628
Subject: Compliance Evaluation Inspections
Cogentrix of Rocky Mount
NPDES Permit No. NCO077437
Stormwater Permit NCS000350
Edgecombe County
Dear Mr. Schuster:
In regards to the inspection conducted July 27h 2005, for NPDES permit compliance of
our Waste Basin Outfall as well as our Storm Water Outfall by Judy Garrett of the Raleigh
Regional Office, Louis Salguero and Rashe Malcolm of the EPA, we wish to address the
modifications and/or changes to remedy the areas in which they had concerns. The letter
from your office dated November 2, 2005 had (4) action items listed. These action items were
for lines 3,4, 5 and 7.
Line 3. An audible and visual alarm has been installed at the Waste Water Building. The
sump level has always been monitored through a field transmitter (Rosemont) that is tied
directly to the Plant Operations Control Room. When the high sump level indicator now
activates, the Control Room Operator is notified via the Rosemont, and all field Plant
Operators in the area will also be alerted. The normal level set point is set below the parshall
flume effluent level. The parshall flume is no longer flooded, and the high level alarm will
activate upon a flume -flooded condition.
Line 4. A new ISCO composite sampler has been installed and is being utilized. This is a
refrigerated model. This refrigerated unit will maintain composite samples at the required 4
degrees celsius throughout the composite cycle. Also, all Oil and Grease samples are being
pulled utilizing a glass bottle. The glass -sampling device is manufactured for this application.
Samples are pulled and shipped utilizing glass.
Line 5. Mr. Sandy Bunn (ORC) utilizes a logbook to document the days he is on the plant
site. Mr. Bunn is very detailed in logbook entries and the importance of maintaining accurate
records. Mr. Bunn has started documenting not only the days he is on site, but also the days
all "back-up" operators are on site. Mr. Jerry Rimmer of the (TACU) was notified by me on
September 12", 2005 that we had (2) more operators that had met the necessary
requirements as PC 1 operators. This would make a total of (3) shift operators who are
deemed "back-up". This gives us good coverage for most waste outfall functions, daily,

• Page 2
I**
nightly, weekends and holidays.
assist the ORC and/or back-ups
DMR.
I also maintain an active PC 1 license, and am available to
. The ORC has started listing all back-ups on the monthly
Line 7. The elimination of the 002 effluent (Cooling Tower Blowdown) from the combined
source outfall 003 has caused the waste effluent total to be reduced. This isolation of the
tower blowdowns is to utilize this water stream in other functions throughout our facility, and
thus create a point source loss and eliminate the need to activate blowdown and blow water
to the waste basins. This has resulted in discharge swings in excess of the +/-15% allowed.
All plant operations are maintained fairly consistently with minimal water loss from boiler
blowdowns and other system losses. Due to the purchase price for water from the City of
Rocky Mount, water is a precious commodity. We have a scheduled visit from Mr. Vincent
Bryant with Johnston Inc. on Monday November 21' to set us up with the proper module to
convert our ISCO sampler to flow proportional. We will utilize -Mr. Bryant and his expertise to
set up our sampling system to meet mandated requirements for flow proportional sampling.
Flow proportional sampling should be in place and be utilized by the December sampling
cycle.
Regards,
S::�A_L � C
David L. Herring
Compliance Coordinator
Cogentrix of Rocky Mount
DLH

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From: DAVID HERRING
COGENTRIX
P,D. BOX 370
BATTLEBORO NC 27809
MR. KENNETH SCHUSTER
RALEIGH REGIONAL OFFICE
1628 MAIL SERVICE CENTER
RALEIGH NC 27699-1628
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--' .'�war�AQ
0(0-
Michael F. Easley. Govemor
November 2, 2005
Mr. Richard S. Frymer, Plant Manger
Cogentrix Energy, Inc.
P.O. Box 370
Battleboro, North Carolina 27809
Subject: Compliance Evaluation Inspections
Battleboro Cogeneration Plant
NPDES Permit No. NCO077437
Stormwater Permit NCS000350
Edgecombe County
Dear Mr. Frymer:
William G. Ross, Jr.. SecrLtary
North Carolina �..,,drtment of Environment and Natural Rcsources
Alan W. Klimek, P.E.. Director
Division of Water QualiLV
APB 2 Q 2007
_J
OFFlGF
Enclosed are checklists which transmit the findings of the inspections conducted by Judy
Garrett of the Raleigh Regional Office, and Louis Salguero and Rashe Malcolm of EPA, on July
27, 2005. You and Sandy Bunn represented Cogentrix during the inspection. Judy Garrett also
met with you and David Herring on August 17, 2005. Your cooperation and assistance is
appreciated. As a result of the inspections, we have the following continents and
recommendations:
1) The treatment system consists of 2 neutralization/settling basins which receive wastewater
from the coal pile runoff, cooling tower blowdowns, and oil/water separators/plant overflow
pit. If necessary, pH is adjusted as it leaves the neutralization weirs using either caustic or
acid. Pipe 002 discharges into the head of the neutralization basins. Flow is measured in a
parshall flume. Domestic wastewater from this facility is discharged to the Rocky Mount
Regional Collection System.
2) Mr. David Herring was ORC of the facility at the time of the inspection. Since that time,
Mr. Alexander(Sandy) Bunn has been delegated as ORC. The facility has 3 Back-up ORCS.
All 4 of these operators Hold PC-1 classifications as required for this PC-1' classified
facility.
3) A walk-through inspection of the facility was conducted. It was noted that the effluent
pump station does not have visual and audible high water alarms. These need to be
installed as soon as possible. In addition, the water in the wet well was backing up into the
parshall flume, causing a flooded condition. You informed Ms. Garrett that this problem has
already been corrected.
4) A review of the sampling practices at the facility indicated that the composite samples are
not being iced during collection. Please begin refrigerating or icing these samples during
collection. The Oil and Grease grab sample should be taken in a glass container. Oil and
grease clings to plastic containers and causes sample bias. Please begin collecting Oil and
Grease samples in glass as required in 40 CFR 136 immediately.
P�,�,o��Caro Iina
11vahmillIJ
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Internet h2o.encsfate.nc.us 1628 Mail service Center Raleigh, NC 27699-1628 FAX [phone]
An Equal Opportunity/ARirmadve Action Employer — 50% RecycWIO% Post Consumer Paper

Mr,e2 6 • • •
Page 2
5) A review of the facility records was conducted. The flow meter was calibrated on 1/6/05.
The continuous pH meters were calibrated on 1/6/05. The ORC should document visits in a
log indicating visitation by him or a back-up operator.
6) Mr. Bunn said that the operators cause a discharge from Pipe 002 in order to meet the
minimum monitoring requirements contained in the NPDES Permit. If no discharge occurs
during the month from this pipe, you may report 0 flow for each day and no further
monitoring is required.
7) Composite sampling of Pipe 003 is constant time/constant volume. You have indicated that
the flow does not vary by more than 15%. The permit requires flow proportional monitoring
unless approval of constant time/constant volume sampling is approved by the DWQ
Director. Please submit a request for approval along with documentation that the flow does
not vary by more than 15 %.
8) A review of the Stormwater records indicated that the records are well maintained with all
requirements met. The stormwater outfall was inspected and found to be satisfactory.
Please respond to the concerns listed in items 3, 4, 5 and 7 above on or before November 23,
2005. If you have questions concerning this inspection, please contact me or Ms.Garrett at (919) 791-
4200.
Sincerely, •�
Z
Kenneth Schuster, PE
Water Quality Regional Supervisor
cc: Edgecombe County Health Department
DWQ Central Files
Louis Salguero, EPA Science and Ecosystem Support Division, 980 College Station
Road, Athens, GA 30605-2720

00
400
Unwed States EnvirOnrnental Protection Agency
Form Approved.
EPA Washington, D C 20460
OMB No. 2040-0057
Water Compidance Inspection Report
Approval expires B-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yrlmolday Inspection Type Inspector Fac Type
1 U 2 151 31 - t 11 12 - U _- 17 181 -I 191 , l 20U
LJ LJ J LJ
Remarks
211 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 6
inspection Work Days Facility Self -Monitoring Evaluation Rating 131 CA ------ -- --- Reserved-----------
67 169 70 U liI 71 I 721 LJ yi 73I —I—I I 174 751 J l I I 180
t
Section B: Facility Data
Name and Location of Facility Inspected (For industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTVV name and NPDES permit Number)
Exit TlmeiDate
Permit Expiration Date
4C 276f;9
,:,;r: 'P.l e,P,' _
'a;
Name(s) of Onsile Representative(s)fTittes(s)jPhone and Fax Number(s)
Other Facility Data
O52
nAvi��rfrr��
Name, Address of Responsible Officiairritle!Phone and Fax Number
2cx 3'!Contacted
i ?a.._eboro 4C 2"549/:""�-9;_-u305. N
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Records/Reports Self -Monitoring Program ■ Facility Site Review
Etfluent/Recelving Waters E Storm Water
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers
1Date 1�
RRO J'0 EX-.27c" r�a�fi-s
Signature of Managenn r, Q A ReVtewer AgencyiOfficefPhone and Fax Numbers Die
it
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.

NPDES yrlmolday inspection Type
3 11 11 12 _ _ 17 181 j
Section D Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)

a.
00
Permit: NGS000350 Owner - Facility: Cogentrix Energy Inc-Battlebor
Inspection Date: 07/27/2005 Inspection Type: Compliance Evaluation
?errrnt
Yes
No
NA
NE
(if the present permit expires in 6 months or less). Has the permittee submitted a new application?
■
Cl
❑
Cl
Is the facility as descnbed in the permit?
■
❑
❑
❑
Are there any speciat conditions for the permit?
❑
■
n
n
is access to the plant site restricted to the general public?
■
❑
❑
0
Is the inspector granted access to all areas for inspection?
■
❑
Cl
❑
Comment:

General Stormwater Inspection Checklist
Type of Visit ®Compliance InspectionlProgram Audit []Tech Assistance orRecon
Location: Cogentrix of Rocky Mount, Edgecombe County
Facility Number NCS000350 Date07/27/05 Time Inl0:30 Time Out 3:30
People Interviewed. and Titles- Richard Fryrper and David Herring
Name of Inspector: C
SPPP Documentation (Site Pliii Pat4e II (A)(1))
1. Copy of Certificate of Coverage ®Yes ❑No Copy of Permit pees pNo Requested but not required
2. General Location (USGS) Map shows plant SYes ❑No, lines of discharge Part II(A)(1 )(a)
to water of State ®Yes ®No. Stream labeled ®Yes pNo, Latitude and longitude ®Yes ❑No
Comments:
3. Narrative Description of Practices ®Yes [:]No Part Il(A)(1 )(h )
4. Site maP ®Yes ❑No Shows flows & areas served with arrows and Part II(A)(1)(c)
% impervious surface ®Yes ❑No, buildings SYes pNo, process areas ®Yes ❑No,
disposal areas ®Yes ❑No, drainage structures ®Yes ❑No, existing BMPs such as secondary containment
®Yes pNo, list of potential pollutants ®Yes ❑No
Comments:
5. List of si-nificant spills in last 3 years or certif. if none ®Yes ❑No
Part II(A)(1)(d)
RRO called? ®Yes pNo
6. SW outfalls have been evaluated for process water SYes ❑No
Part II(A)(1)(e)
7. Feasibility of Changing Practices SYes pNo
Part II(A)(2)(a)
8. Secondary Containment ®Yes ❑No Schedule needed? ❑Yes SNo
Part II(A)(2)(b)
Records of Draining Containment, Observations Made ❑Yes pNo
9. BMP Summary ®Yes ❑No
Part II(A)(2)(c)
10. SPRP Plan ®Yes ❑No, Responsible personnel still employed here? ❑Yes ❑No
Part II(A)(3)
11. PM and Housekeeping Plan ®Yes ❑No Record of Inspections? ❑Yes ❑\o
Part II(A)(4)
12. Employee traininP, ®Yes ❑No — for everybody ®Yes ❑No
Part II(A)(5 )
13. Responsible parties, chain of command page ®Yes pNo
Part II(A)(6)
14. Plan updated/reviewed annually ❑Yes ❑No
Part LI(A)(7)
15. Stormwater Facility Inspection Program ®Yes ❑No
Part II(A)(8)
16. This Plan Has Been Implemented (documents in manual,
Part II(A)(9)
employees show awareness ®Yes []No Comments:Spill plan is updated every 5 years.
Sampling and Analytical Data Part II(C)
All Stormwater and Process Water is Recycled (IIC(3)) ❑Yes ISNo
Rain Gauge on site (not required) SYes pNo
Record of an overflow SYes []No Details
If not all recycled, what is allowed to discharge? Vehicle Cleaning (IIC2) ❑ Recycle overflow (II0)
above) ❑ Wetting of Aggregate (IIC4)❑ Mixing drum cleanout (IIC5) ❑ Vehicle Maintenance ❑
Note: this checklist does not take the place of your permit. You are fully responsible for
following the permit.

o•
00
For the topics checked in last question, Analytical data present ®Yes ❑No. Compliantc." ®Yes []No
Details:
Total precip ®Yes ❑No, Storm duration ®Yes ❑No, Total flow Est. ❑Yes ❑No,Field pH ®Yes []NO,
Chain of custody ®Yes []No
Qualitative Monitoring performed semiannually ®Yes ❑No Part II(F)
Stormwater not combined with process_ wastewater— general runoff Partll(C)(1)
Analytical data []Yes []No, Chain of Custody ❑Yes ❑No, Qualitative Monitoring performed
semiannually (Section F) []Yes []No,
If using cutoff policy, how many sample rounds 2 analyses in 2004 as required.
Cutoff Concentrations met ❑Yes ❑No Ever have a Bypass? ❑Yes ❑No (Ul (C)(4)a1&2)
Notification given? ❑Yes ❑No
Outdoor Inspection
I_located all discharaepoints ®Yes ❑No No. of areas served
Sample points appropriate ®Yes ❑No
Location if different from discharge point
Housekeeping Trash ❑Yes SNo Dust ❑Yes SNo
Take pH ®Yes ❑No Value(s)
Take photos ®Yes []No
Containment Area satisfactory ❑Yes ❑No, Loose drums ❑Yes SNo, Locked drain ❑Yes ENo
Inspection Summary Comments
See attached letter
Recommendations:
Requirements:
Letter is to go to:
Name Richard S. Frymer, Plant Manager
Title Plant Manager
Address P.O. Box' 70, Battleboro, NC 27809
Helpful Information at http://h2o.enr.state.nc.uslsu/Manuals_Factsheets.htm
Vote: this checklist does not take the place of your permit. You are fully responsible for
following the permit.
Revised 7l23103. 101? 1103, 4113105

00
00
Unrtec States Environmental Protection Agency
Form Approved.
EPA Washington, D C 2C460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expiresB-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yrlmolday Inspection Type Inspector Fac Type
1 Li2 I C I 31 - _ 111 12 - 17 18I_j 191 L- J I 20I I
J
Remarks
211 1 1 l 1 1.1 1,. 1 1 1 1 1 1 1 1 1 1 l 1 1 l 1 1 l 1 1 1 l 1 1 1 1. 1 1 1 1111 1 1 _I 1 I 1 15
Inspection Work Days Facility Self -Monitoring Evaluation Rating 61 QA —-------- Reserved- ----- _--
67 69 7071 .721u 7374 751 I I I I I I I 80
70uI
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to PQTVV, also include
Entry Time/Cate
Permit Effective Date
POTVV name and NPDES permit Number)
Exit Timet Date
Permit Expiration Date
Name(s) of Onsite Representative(s)Mtles(s)fPhone and Fax Number(s)
Other Facility Data
sav-ty ac to V1 g S') _W;k - t 5
5,d 'r Xle+r
Name, Address of Responsible Official/TitlerPhone and Fax Number
Contacted
3:"': .70
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenance ■ Records/Reports
Self -Monitoring Program 0 Sludge Dandling Disposal Effluent/Receiving Waters Storm Water
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Names) and Signature(s) of Inspector(s) Agency/OfficelPhone and Fax Numbers
IDate
/,C
Signature of Management Q A Reviewer Agencyi0fficelPhone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.

400
06
NPOES yrlmolday Inspection Type 1
3I 11 12� - 17 18i _I
Section D: Summary of Finding]Comments (Attach additional sheets of narrative and checklists as necessary)

G*
00
Permit: NCO077437 Owner - Facility: Battleboro Cogen plant
Inspection Date: 07f2712005 Inspection Type: Compliance Evaluation
Yes
No
NA
NE
(tt the present permit expires in 6 months or less). Has the permittee submittec a new application?
■
❑
❑
❑
Is the facility as described in the permit?
■
❑
❑
❑
Are there any special conditions for the permit?
■
❑
❑
❑
Is access to the plant site restricted to the general public?
■
❑
❑
❑
Is the inspector granted access to all areas for inspection?
■
❑
❑
❑
Comment: Special condition A(3)- Use of Biocides must be approved,
Coefations 3 Maintenance
Yes
No
NA
NE
is the plant generally clean with acceptable housekeeping?
■
❑
n
n
Goes the facdlty analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge
■
❑
❑
❑
Judge, and other that are applicable?
Comment; They use continuous pH monitoring and addition of acid or caustic to adjust pH
Equalization Basins
Yes
No NA
NE
Is the basin aerated?
❑
■ ❑
❑
is the basin free of bypass lines or structures to the natural environment?
■
❑ ❑
n
Is the basin free of excessive grease?
■
❑ ❑
n
Are all pumps present?
❑
❑ ■
❑
Are all pumps operable?
❑
❑ ■
❑
Are float controls operable?
❑
❑
❑
Are audible and visual alarms operable?
❑
❑ ■
❑
Is basin size:volume adequate?
■
❑ ❑
❑
Comment: There are 2 settlil neutralization basins. They are not actually equalization basins
Pump Station - Effluent
Yes
No NA
NE
is the pump wet well free of bypass lines or structures?
■
❑ n
❑
Are all pumps present?
■
❑ n
n
Are all pumps operable?
■
❑ ❑
❑
Are float controls operable?
■
❑ ❑
❑
Is SCAOA telemetry available and operational?
❑
■ ❑
❑
Is audible and visual alarm available and operational?
Cl
■ n
❑
Comment: Audible and visual alarms must be added.
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
■
n
❑
❑
Are all other parameters(exciuding field parameters) performed by a certified lab?
■
n
n
Cl
Is the facility using a contract lab?
■
❑
Cl
❑
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
❑
■
Cl
❑
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/• 0.2 degrees?
❑
❑
■
❑
Incubator (300) set to 20.0 degrees Celsius +/- 1,0 degrees?
❑
❑
■
❑
Comment: Sampler must be iced during collection. J.R Reed lab used. pH is the only field parameter
7lovi Measurement - Effluent
Yes
No
NA
NE
Is flow meter used for reporting?
■
❑
❑
❑
Is flow meter calibrated annually?
■
n
❑
n
is the flow meter operational?
■
❑
n
n
(if units are separated) Does the chart recorder match the flow meter?
■
11
13
0

06
406
Permit: NC0077437 Owner - Facility: Battleboro Cogen plant
Inspection Date: 07�2712005 Inspection Type: Compliance Evaluation
F1c,v Measurement - Effluent
Yes
No
NA
NE
Comment: Parshall flume is flooded by pump wet well. They are going to reset the float controls for the wet welt.
Record Keepir.
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
■
❑
n
n
Is all required information readily available. complete and current'?
■
n
n
n
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
n
n
n
Are anaiytical results consistent with data reported on OMRs?
■
[]
0
❑
Is the chain -of -custody complete?
■
❑
Cl
❑
Dates. times and location of sampling
■
Name of individual performing the sampling
■
Results of analysis and calibration
■
Dates of analysis
■
Name of person performing analyses
■
Transported CQCs
■
Are DMRs complete: do they include all permit parameters?
■
n
n
n
Has the facility submitted its annual compliance report 10 users and DVVQ?
■
❑
❑
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 2417 with a certified operator on each shift?
■
❑
❑
❑
Is the CRC visitation tag available and current?
■
❑
n
n
Is the ORC certified at grade equal to or higher than the facility classification?
■
❑
❑
1 1
Is the backup operator certified at one grade less or greater than the facility ciassification?
■
❑
❑
Cl
Is a copy of the current NPDES pen -nit available on site?
■
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
■
❑
n
n
Comment: ORC log must be established to document CRC and back-up visitation.
[fluent Sampim
Yes
No
NA
NE
Is composite sampling flow proportionai?
❑
■
❑
Cl
Is sample collected below all treatment units?
■
❑
❑
❑
Is proper volume collected?
■
❑
❑
❑
Is the tubing clean?
■
❑
❑
❑
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■
❑
❑
❑
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
■
❑
❑
❑
Comment: The flow does not vary by more than 15%. Cogentrix may request a variance from the requirement to
collect samples flow proportionally. Composite sampler must be iced during collection.
Solids Handling Equipment
Yes
No
NA
NE
Is the equipment operational?
❑
❑
■
n
Is the chemical feed equipment operational?
Cl
❑
■
Cl
Is storage adequate?
❑
❑
■
❑
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
❑
❑
■
Cl
Is the site free of sludge buildup on belts and/or rollers of filter press?
Cl
Cl
■
n
Is the site free of excessive moisture in belt filter press sludge cake?
❑
❑
■
❑
The facility has an approved sludge management plan?
❑
Cl
❑
Comment: The solids are burned with coal.
- --��-: Feec
Yes
No
NA
NE
Is containment adequate?
■
0
n
n

00
00
Permit: NC0077437
Inspection Date: 07t2712005
Owner - Facility: Battleboro Cogen plant
Inspection Type: Compliance Evaluation
Chemical Feed Yes No NA NE
Is storage adequate? ■ ❑ ❑ ❑
Are backup pumps available? ❑ ■ ❑ ❑
Is the site free of excessive leaking? ■ ❑ ❑ ❑
Comment: The caustic feed pump requires a back-up pump.
Effluent Pip Yes No NA NE
Is right of way to the outfall properly maintained? ■ ❑ ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris? ■ ❑ ❑ ❑
If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ ■ ❑
Comment:

*I*
Michael F. Easley, Governor
DF W A TFR �. William G, Ross Jr., Secretary
�O� 0G North Carolina Department of Environment and Nalural Resources
/~- Alan W. Klimek, P.E. Director
Colleen H. Sullins, Deputy Director
Division of Water Quality
June 23, 2004
Mr. Richard Neff
Cogentrix of North Carolina- Battleboro Plant
9405 Arrowpoint Boulevard
Charlotte, NC 28273-8110
Subject: Permit Compliance Evaluation Inspection
Cogentrix of North Carolina-Battleboro Plant
Permit # NCO077437
Edgecombe County
Dear Mr. Neff:
On June 22, 2004 Jerry Rimmer of the Raleigh Regional Office —DWQ conducted a compliance
evaluation inspection of the Cogentrix of North Carolina- Battleboro Plant, Permit #
NC0077-13 7. A copy of the inspection checklist is attached. The assistance Mr. David Herring
provided during the inspection was greatly appreciated. His knowledge of the stormwater and
treatment system discharges demonstrated the commitment that the facility has made to comply
with permit requirements. Findings listed on the checklist were as follows:
The pen -nit, site plan, site chemical inventory, analytical records, DMR, and operation
procedures were reviewed.
David Herring (Certification # PC28585 & WW grade2-45933) is designated as
ORC. Backup ORC is Drew Israel (Certification # PC985777). ORC logbook
documents presence of ORC or back up per requirements.
3. Review of the site lab analyses indicates that the facility is sampling per the permit.
The sample points are acceptable and data has been submitted in compliance with the
permit. Stormwater in areas of the plant outside the coal pile area is discharged at
one outfall after a series of catch basins and a retention basin at outfall. J.R. Reed
Lab of Newport News, VA is used for contract analyses. Site lab reports were
compared to DMR submittal for January through May 2004 and found to be
consistent and accurate.
4. 0& NI manuals are held on file. These must be followed to insure appropriate
maintenance is performed.
The system consist of two parallel concrete settling and equalization basins with flow
re -circulation, in -line flow meter and an automatic neutralization system with pH
probe to add caustic or sulfuric acid as needed via metering pumps to treat cooling
tower blowdown, boiler blowdown, coal pile runoff and low volume site wastewater.
Sludge is applied to coal pile and dewatered and burned in boilers or disposed in
landfill, Sanitary waste discharges to Rocky Mount Regional POTW. Oil tanks have
secondary containment.
Raleigh Regional Office 1628 Mail Service Center NCOENR
Water Quality Section Raleigh, NC 27699.1628
No rb Carolina
flaturally
phone [phone] Customer Service
facsimile [phone] 1-877.623-6748

Page 2 010
Mr. Richard Neff
June 23, 2004
so
b. Review of DNIR reports indicates no violations since fluoride limits were adjusted.
7. The discharge pipe is apparently maintained properly up to the discharge point in the
Tar River at Highway 97 and Old Battleboro Road intersection.
S. Sanitary wastewater is discharged to Rocky Mount Regional POTW. Flue Gas
scrubber blowdown is pumped to evaporation pit for reuse or evaporation. This is not
discharged.
Your continued attention to the operations of the wastewater treatment and stormwater
discharges is appreciated. The discharge system program appears well organized, sufficiently
documented and is being managed in a timely manner.
If you have any questions or comments, please call me at [phone].
Sincerely,
Jerry F. Rimmer
Environmental Specialist
,'Enclosure: CEI checklist
cc: David Herring, Cogentrix-Battleboro, PO Box 370, Battleboro, NC 27809
Central Files

00
90
Unaea States Enwonmental Protection Agency
Form Approved.
EPA Washington, D C 20450
OMB No. 2040.0057
Y�ater CompHanca inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yrlmolday Inspection Type Inspector Fac Type
1 j ( 2 l I 31 ., .-- - 11 12
tJ a �---+ 17 18Lj 19� 20U
Remarks
21I 11 1 1 1 1 1 1 1 1 1 1 1 1 1 I 1 1 1 I I I I I -I I I III I I I I I I I I I I I I I 1 I Iss
Inspection Work Days Facility Self -Monitoring Evaluation Rating 81 CIA671
169 70 U 71 U 72 LJ 73 I I' 74 751 ' 1 I I I I I a0
�+
Section B: FacilityData
Name and I-ocat,en of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry TimelOale
Permit Effective Date
POTW name and NPDES permit Number)
Exit TimeiDate
Permit Expiration Date
Namelsi of Onstle Representali ve(sl;Titles(s)1Phone and Fax Number{s)
Other Facifily Data
Narre Aduress cl Resoonsible Olfictai: Title; Phone and Fax Number
Contacted
9iGs �I�r+✓� .v�r 0/vi� C.L.�.r/y/yJ Yt i ,;7
`-� `
Section C Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement ■ Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review EffluenUReceiving Waters
Laboratory Storm Water
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Nametst and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Signature of Managed! t O A Review r � Agency+'OKce/Phone and Fax Numbers Date
04 6 (z o�
EPA Form 3560.3lRev 9.A) Previous edtlionsure obsolete.

*0
00
Permit: NCO077437 Owner - Facility: Cogentrix Energy Inc - Elattleboro Cogen plant
Inspection Date: 06122j04 Inspection Type: Compliance Evaluation
I j4-r)raIr34 Yes bin M NF_
Comment. ice down sampler. Use JRReed Labs in Newport News. VA. pH meter and thermometers calibrated per
certification guidelines Record sheets reflect improvements implemented as result of Edith Henderson of DWO review
in 2004.
; . r.% 1.1,
no, o,.,_,iei u fcr ,
a Cl 0
0
ti,'.'. 01-:10 . a1:t'-­31&" x1n­311�'
No 0
0
IS fiij,,. -T Ott;t j"ravng uropwiy'7
M D 0
0
0 13 [3
Comment, In -line anubar meter works well and appears accurate.
W'. zlqf;
Yf--: No NA
UE�
JS 01, if)-,, 3er7!it"
M 13 0
0
ii. Complete and current
M 0 13
0
j,i rt;ccojs niairiia,ilea for 3 years tiat reg required 5 years)?
M 13 0
0
dIIJIyIiCal rIE'SU11S CCIiSiitent with data reported on DN.Rs?
M 0 0
0
Are sarr,;)Isnyanu analysis cata adequale and inCILde.
M 0 0
0
Cates. times anc location of sampling
Name of noivicual p:erlorrnirig the Sampting
Results of analys-s and calibration
Dates at anaNsis
If ';r' sc:n Ut,.rf.,rlrinq irai, 5ei
'r-3nt,[,Or,e'J COOS
�!""jj jrr., .1 ' '3,13;;Iu aria inCILC2
0 0 El
0
:­0 Er'yIrut! Xg -Ira..'01rigs
M
y , _'J%;n _f V_;Lrr:o'cw n7jii'tLI1ji!Ce and repairs
CL, ;he', :1Ck.-_-e 311 ;erMit .1X'3rreters)
0 0
1:1
'1,1111% SL,01r111-20 IIS ilinual compfiance report to users,
0 0 0
13
%1UU permirtt:,: %,vi Co trey operate 24,7 jviiti a ^_ernfieC operator an each shift'
0 0 0
0
0 0
0
S !nf, ORC -.eriificd at grade equal to or higher than the facility classification7
0 0 0
13
;, We U,4CKLI) Cper,iioi certified at one grace iess or greater than the facility classification?
0 0
0
Is o ccq•i cf the CLirrent,14POES permit available On site'
0 0
0
.S tr:t. ;esunfpnon viarified as contained in the NPOES permit?
11 0 0
0
Does the facility analyze process control parameters, for example: MLSS. MCRT. Settleable Solids, DO, Sludge
0 0 0
0
Judge pH, and others that are applicable?
Facility has copy of previous year's Annual Report on file for review?
0 0 0
0
Comment Reviewed 2004 field data records and compared to DNIR. All are accurate. Contract lab data in locked
office was not reviewed David Herring is ORC- Certifica lion# PC28585 & WW245933. Backup is Drew Isreal
Certificate PC985777
P"i'_ip2t Oiamplo_a
Yen Nn NA
NE,
i!i cort,pome sampling flow proportional?
0 0
0
-hl W _51L: 4tox I
0 0
0
11 C3
11
Ir)t! CleAn"
M00
0
JOI :Jr storage tKupi at 10 to 4 4 ceyroes Celsius)?
ME] 0
11

*0
00
Permit: NCO077437 Owner - Facility: Cogentrix Energy Inc - Battleboro Cogen plant
Inspection Date: 06/22/04 Inspection Type: Compliance Evaluation
Yen
No NA
bir-
less) Has the permittee sc:bmitted a new application?
M
❑ ❑
❑
, i Wt: i j,_iIi as rldscnhed In the pern,d?
No
❑
❑
a.0 thurq dnv spaCwl candi;ions for ?he permit')
❑
0 ❑
❑
Is access to the plant site restricted to the general pubtic'
M
❑ ❑
❑
I, the 6nsGe6ter granted access to all areas for inspection?
❑ ❑
❑
Comment: Permit is followed and equipment operated as described in permit
Q-Prwinnc P. 6lain1enance Yes
No
NA
N;`
Does the plant have general safety structures in place such as rails around or covers over tanks. ads, or wells'
❑
❑
❑
l5 the plant generally clean with acceptable housekeeping'
❑
❑
❑
Comment
ilalt�qhen. Eosins Yac
Nn
NA
NF
;r _• ;;,,tut Ire_ Dr c�cnii •ln;Js or structures ;o the nai'_ral en•nronmeol°
❑
❑
❑
, X, ; •a., �1�;7, tiL KL'2.,n'ny .1 t;Cdi; Ir't.'ilr, �
■
❑
❑
❑
.nk- c.,,,n uc,7 it exetiiive gr_as,=7
❑
❑
❑
Arm Lill ;;r.^'tiS 3L?r3t;1r'''
❑
❑
❑
... _.!!7,:3r'd :li'.11� dldrq'i�CRr7Cla�
❑
❑
■
❑
Comment Two basins for equalization and settling Normally use one with backup ready for surge flows or problems
with one in service Receive water from coal pile runoff, deionizer unit blowdown, cooling blowdown (with metered flow)
in cooler months.beder btowdowns and slormwater. Scrubber blowdown is discharged top evaporation pit and reused
or evaporated This is not discharged to treatment plant. Portion of now is recirculated to reduce temperature of
discharge Sludge from basins is dewatered at coal pile and either burned or disposed at landfill.
YPc
Nn
NA
NF
Pill Stafinn - Fff(uent
is the Gump .vet ,ve!I free of oy;;ass lines or structures?
❑ ❑
❑
'i the ,)eryr it `rot:5eK aeping acceptable'
❑
❑
❑
is the wel well ii or _xt,ssi%e gr'3ase'
0
❑
❑
❑
Are all pumps;resent•'
■
❑
❑
❑
:+rc dll µuneps operaole'.
❑
❑
❑
.
11
zi%ail;ici. _iru c: pf3l
`i
,_,];r,•' .j.,O IL•le and .:peralicnal'
❑
❑
0
❑
Comment Tno pumps are available One is normally used Only one site slormwater ourfall after a settling basin with
several In -line catch basins This does not include coal management area which goes through treatment unit,
j"i i 7�r�rd YES,,. tjyNA NE
-v.,.Gf-•c! relscnn- cr l3bdralcry' 0 ❑ ❑ ❑
111 ,,tors I,nrdlll2le1ylCA_luu1riy r,elc parameters) pertormed by a certified lad' 0 Cl Cl ❑
; I,•.•lrt. .5 n•, lj -, '.nrtrpGt Ir�h' ❑ ❑ ❑
,111.1lY,r-.il rusLltS tcnsiii kith gala reported on plvlRs' ❑ ❑ ❑
i;rcuur le,r1Pul azure .;el for sample storage (kept all 1.0 to 4 4 degrees Celsius)? ❑ ❑ ❑
!'IcLbalor (Fecal Coliforml set to 44 5 degrees Celsius*;- 0.2 degrees? ❑ ❑ 0 ❑
Ir,cl-oalor (BUD) set to 20 0 degrees Celsius -1- 1 0 degrees? 0 ❑ M 0

00
00
Permit: NC0077437 Owner - Facility: Cogentrix Energy Inc - Battleboro Cogen plant
Inspection Date. 06;22r04 Inspection Type: Compliance Evaluation
Yes No NA NE
;;ertu' Wdo �.s requited by the permit tfrequency. sampling type representative)? 0 ❑ ❑ ❑
Comment Composite samples are collected on ice and maintained on ice for shipping. Chromium and zinc are
analyzed In addition to other metals in effluent even though neither is added to cooling tower or boiler. Chlorine is added
to cooling tower in hot months, but [here is no blowdown due to evaporation.
��1' �•;--t! 1:i—r Yee No NA NF
is :onlinoment aoequate?
IS storage adequate?
Are pdCKup rLMPS a,ra,lable''
r. Irc :;ilc lrOC')f OxceSsivC Icdking'�
Comment Sulfuric acid and caustic are used for neutraliztion if needed. The system is controlled by in line pH probe
system
F'rl .-ri P -^P-
1S `qr'r Sf .v:iy :o rhq outlali voperly mainiainedl
..c�'•��'.; ...tl�;r ifs: .l joi.! tlr_dfdtle A35:s.vdler IPalerlals-)
i• 'I•. � .� .. ..'I, G• . -- :r 4'7i^ ql.^C' :h7rt ,i �raC?�
Yoe Nn KJA NF
■❑a❑
M ❑ ❑ ❑
❑ ❑ ❑
■❑❑❑
"t.. „1— 1('_ •v4L, WC; art ln�or wcra!irg pfoperly') ❑ ❑ ❑
C3mmens Discharge rto Tar River at Hwy 97 and Old Balteboro Road. Rock fined discharge at end of force main, No
of )sion evident 31 time of rnspecllen

NPDES yrlmolday Inspection Type
31 11 12) e-;:cei22 117 1B u
Section D: Summaa of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)

Z -i
Y
30 March 2007
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7006-0810-0002-6048-1528
Mr. Richard Frymyer, General Manager
Cogentrix of Rocky Mount
P.O. Box 370, 6358 Old Battleboro Road
Battleboro, NC 27809
Michael F. Easley, Govemor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
Subject. Compliance Evaluation Inspections for NPDES Permits
NCO077437 (wastewater) and NCS000350 (stormwater)
and Resulting Notice of Violation,
NOV-2007-PC-0151
Cogentrix of Rocky Mount, Battleboro Plant
Edgecombe County
Dear Mr. Frymyer:
On 8 March 2007, Ronald Boone, of the Division of Water Quality's (DWQ) Raleigh Regional Office (RRO),
conducted Compliance Evaluation Inspections (CEI) for the subject NPDES permits at the subject site. Your
assistance and cooperation, as well as that of Mr. David Herring, Compliance Coordinator, were helpful and
appreciated. Inspection reports are attached for your records and inspection findings are listed below.
SITE DESCRIPTION
1. This is a coal-fired power generation facility. Wastewater generated at the site is treated in one of two
sedimentation/neutralization basins. The effluent is then pumped into a forced main that discharges into
receiving waters known as the Tar River, this segment of which is classified as a Class C, nutrient sensitive
water (NSW) in the Tar Pamlico river basin. The actual discharge point is located approximately four miles
from the plant, in the river on the southwest corner of NC Hwy 97 and Springfield Road.
2. All site stormwater flows into a detention pond and is then discharged via one stormwater discharge outfall
(SDO) located on the southern end of the site. The stormwater is discharged to receiving waters known as
an unnamed tributary to Beech Branch, a Class C, nutrient sensitive water (NSW) in the Tar Pamlico river
basin. Please note that the receiving stream currently listed on the Certificate of Coverage (COC) is Beech
Creek. This is incorrect and should be corrected now, during the ongoing permit renewal cycle. The
appropriate office of DWQ will be sent a copy of this letter to make them aware of the needed change. The
actual receiving stream should be an unnamed tributary to Beech Branch.
INSPECTION SUMMARY —Wastewater NC0077437
,o`,
No,
aro a
atrrra l
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
lntemet h2o.enrslate.nc.us 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled110% Post Consumer Paper

Cogentrix of Rocky Mount, NCO077437 NCB 0' Compliance Evaluation Inspections 03/30/2007, Page,2 o
3. There were no problems noted with the wastewater treatment facility. The sedimentation basins, chemical
injection systems, effluent pump station and flow measurement systems were all operational and as
described in the permit. All equipment seemed well maintained and in good condition.
4. Effluent sampling is being accomplished as required in the permit. Comparison of discharge monitoring
reports (DMR) with official lab data turned up no discrepancies and all parameters are being monitored as
required. Field lab test -data and -procedures were examined and no problems were noted.
5. Outfall 003 and the.,efflu ti w ree of Lg1y_gd and no problems were detected. The right-of-way (ROW) to the
outfall was sufficiently maintained to allow access when needed.
6. It was noted that discharges from the cooling tower blowdown (outfall 002) have become less frequent since
the new total residual chlorine (TRC) limit became effective back on 1 January 2007 and that you have not
installed any systems to dechlorinate the water in order to meet the limit. Mr. Herring stated that you are
blowing down into outfall 002 less frequently, in part because of the difficulty in meeting this limit. You
may want to consider installing a dechlorination system to ensure you can meet the TRC limit when the time
comes. It was noted that you do use gas chlorine at times to shock the system, along with Sodium Bromide
regularly in the cooling tower system to control growth.
INSPECTION SUMMARY— Stormwater (NCS000350)
7. The Stormwater pollution prevention plan was inspected. All required components were present and met the
minimum requirements.
8. The entire site was clean and well maintained. No obvious pollutant sources of concern were noted.
9. Qualitative monitoring is being performed more often than necessary. Please take note however that even
though it is being performed more often than necessary, it still must be performed during the time periods
specified in the permit, i.e. once during the spring (2°a quarter, Apr -Jun) and once during the fall (Sep -Nov).
10. Analytical monitoring is not being performed as required. According to Mr. Rick Neff, Cogentrix's
engineer that designed the wet Stormwater detention pond, the pond is designed to meet the criteria specified
in footnote #2, for table #1 (Analytical Monitoring Requirements), in Part II, Section B of the permit.
According to this footnote, "If the detention pond discharges only in response to a storm event exceeding a
ten year design storm, then no analytical monitoring is required and only qualitative monitoring shall be
performed". This pond was actually discharging during the inspection, through an orifice placed in the side
of the overflow standpipe, approximately 12" to 24" below the overflow level of the standpipe. This pond
does not meet the intention of the above -mentioned footnote. In order to qualify for this exception, the pond
would need to be designed not to discharge except for a storm event exceeding the 10-year design storm. In
other words, in order to meet the intent of the footnote, the pond would never be allowed to discharge
except in response to a storm event greater than the 10-year design storm. As it is currently designed, the
wet stormwater detention pond at your site is not the correct unit for this application. Therefore, Cogentrix
must immediately begin sampling the pond effluent in accordance with the analytical monitoring
requirements found in the permit.

Co
gentrix of Rocky Mount, NC00774"00350, Compliance Evaluation inspections 03/30/2007, Page 3 of 3
11. Additionally, the combined facts that it was not raining at the time of the inspection, it hadn't rained for
quite some time prior to the inspection and yet the pond was still discharging during the inspection, strongly
indicates that the pond must also be receiving flow from other unidentified sources. This may constitute one
or more unidentified, unauthorized, illicit wastewater discharges. Cogentrix must immediately undertake to
identify and halt all sources of wastewater, aside from site stormwater runoff, from draining into the pond
and making it discharge during dry periods. Once identified, such discharges will have to be appropriately
permitted.
Please be aware that the issues mentioned in paragraph 10 above, constitute violations of your stormwater
discharge permit. Such noncompliance is unacceptable and these violations may result in the assessment of
civil penalties in an amount of up to $25,000 per day per violation. Please reply to this offlce within 30 days of
your receipt of this letter, with a detailed corrective action plan, including an implementation schedule, leading
to full and continuous compliance with your stormwater permit. Additionally, please specify your plan to
identify and correct all illicit discharges into your stormwater system. If you or your staff has any questions
regarding the inspection or this letter, please contact Ron Boone for assistance at 919-791-4200.
Sincerely,
Charles Wakild, P.E.
Surface Water Protection Supervisor
Raleigh Regional Office
Attachments:
1. Final Inspection Checklist
cc: Stormwater Permitting Unit
Non -Point Source Compliance Enforcement Unit
Central Files
RRO/SWQ Files

. . & so
N
United States Environmental Protection Agency
Form Approved.
EPA Washington, D.G. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yrlmolday Inspection Type Inspector Fac Type
1 U 2 1 51 3 NCS000350 11 121 07/03/08 1 17
1_I EJ
181 rf 19us 20I j
�J Lj u
Remarks
21111 L I IIIIIIIIII1IIIIIIiIIIIIIIIIII111111111111I6
Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA
—---------- _-------- _-_Reserved---------------
671 1 69 70I � 71 I ty ' 72 (N �
u u
73I ' 174 751 I I 1 1 1 I j 80
�t�l
Section B: FacilityData
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
10:00 AM 07/03/08
02/05/01
Edgecombe Genco, LLC-Battleboro
Exit Time/Date
Permit Expiration Date
6358 old Battleboro Rd
Battleboro NC 27809
12:00 PM 07/03/08
07/04/30
Name(s) of Onsite Representative(s)/ritles(s)/Phone and Fax Number(s)
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Seth Carter,PO Box 370 Battleboro NC 27809//252-442-0805/ No
Section C: Areas Evaluated During Inspection (Check onIX those areas evaluated)
Storm Water
Section D: Summary of Finding/Comments Attach additional sheets of narrative
and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Ron Boon PRO WQ//919-791-4200/
1.31
Signature of Man ent 0 A vie r AgencylOffice/Phone and Fax Numbers Date
f�
0 2,v
J
EPA Form 3560-3 (Rev 9-9 revious editions are obsolete.
Page # 1

00 00
NPDES yrlmo/day Inspection Type (cont
31 NCS000350 '11 12[ 07/03/08 ' 47 18� _
L,
Section Q; Summary of Finding/Comments (Attach additionalsheetsof narrative and checklists as necessary)
SP3 has been developed and implemented.
Qualitative monitoring being done more often than required. However, permittee must ensure that even
though its being done more often than needed, it still must be done at least twice per during the timeframes
specified in the permit, i.e. spring - Apr through June and fall - Sep through Nov.
Also, permittee is not conducting analytical monitoring because they have.a SW detention pond that they
assert meets the criteria of footnote #2 of table #1, Analytical Monitoring Requirements, in Part 11, Section B
of the permit, i.e. the stormwater "...detention pond discharges only in response to a storm event exceeding
a ten yar design storm...". However, the pond was discharging at the time of the inspection through an
orifice in the side of the overflow pipe that was placed approximately 12" to 24" below the overflow level of
the overflow pipe. According to Cogentrix personnel and their engineer, the orifice is the mechanism by
which the level of the pond is kept at the level required for the pond to contain the 1 0-year design storm
without overflowing at the overflow pipe. This is still considered a discharge that must be monitored in
accordance with table #1.
Finally, the above mentioned pond was discharging during the inspection despite that fact that it was not
raining and hadn't rained for quite some time prior to the inspection. This strongly indicates one or more
unidentified, unauthorized; illicit wastewater discharges through the SW detention pond. The permittee must
immediately undertake to identify all discharges into the pond and stop them and/or have them appropriately
permitted.
Page # 2

O�OtWAT �
r
0 Nii� Y
Michael F. Easley, Governor
William G.' Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality _
September 5, 2006 _ y
EDGECOMBE GENCO, LLC-BATTLEBORO
ATTN: SETH CARTER, OR SUCCESSOR
PO BOX 374
BATTLEBORO, NC 27809
Subject: NPDES Stormwater Permit Renewal
Edgecombe Genco, LLC-Battleboro
Permit Number NCS000350
Edgecombe County
Dear Permittee:
Your facility is currently covered for stormwater discharge under NPDES Permit NCS000350. This permit expires
on April 30, 2007. North Carolina Administrative Code (13A NCAC 2H.0105(e)) requires that an application for
permit renewal be filed at least 180 days prior to expiration of the current permit. In order to assure your continued
coverage under your permit, you must apply to the Division of Water Quality (DWQ) for renewal of your permit.
To make this renewal process easier, we are informing you in advance that your permit will be expiring. Enclosed
you will find an individual permit renewal application form, supplemental information request, and Stormwater
Pollution Prevention Plan certification.
Filing the application form along with the requested supplemental information will constitute your application for
renewal of your permit. As stated above, the application form must be completed and returned along with all
requested information by in order for the permit to be renewed by April 30, 2007.
Failure to request renewal by may result in a civil assessment of at least $500.00. Larger penalties may be
assessed depending on the delinquency of the request. Discharge of stormwater from your facility without
coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and could
result in assessments of civil penalties of up to $25,000 per day. '
If you have any questions regarding the permit renewal procedures please contact Mike Randall of the Stormwater
Permitting Unit at [phone], ext. 545.
Sincerely,
Bradley Bennett, Supervisor
Stormwater Permitting Unit
cc: Central Files
Stormwater Permitting Unit Files
aleigh Regional Office .
NCaton
dVQt1lt9?l!f/
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: wvrw.ncwateMuality.ora location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
An Equal OpportunitylAftrmative Action Employer — 50% Rerycled/IQ% Post Consumer Paper

WArFR O • Michael F. Easley. Governor
PG William C. Ross Jr., Secretary
7� North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
March 17, 2006
Mr. Richard S. Frymyer
Edgecombe Genco, LLC
6358 Old Battleboro Road
Battleboro, NC 27809
Dear Mr. Frymyer:
Subject: Permit No. NCS000350
Edgecombe Genco, LLC
Formerly Cogentrix of Rocky Mount,
LLC
Edgecombe County
Division personnel have reviewed and approved your request to transfer coverage under the Individual Permit
Number NCS000350, received on February 9, 2006.
Please find enclosed the revised permit cover sheet. The terms and conditions contained in the remainder of the
permit remain unchanged and in full effect. This revised permit is issued under the requirements of North Carolina
General Statutes 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental
Protection Agency.
If you have any questions, please contact the Stormwater Permitting Unit at [phone], extension 502.
Sincerely,
Alan W. Klimek P. E.
cc: DWQ Central Files
Raleigh Regional Office, Water Quality Section
Stormwater Permitting Unit
♦� �r ♦
_5 L. J�
L%1
No hCaroIina
North Carolina Division of Water Quality 1617 Mail Service Cenler Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: h2o.enr.statem.us. 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirmative Action Employer— 509% Recyded110% Post Consumer Paper

STATE OF NORTH CAROLINA
DEPARTMENT OF -ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT NO. NCS000350
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
EDGECOMBE GENCO, LLC
is hereby authorized to discharge stormwater from a facility located at
EDGECOMBE GENCO, LLC SITE .
ROUTE 2, STATE ROAD 1400
BATTLEBORO
EDGECOMBE COUNTY
to receiving waters designated as an unnamed tributary to Beech Creek, a class C NSW stream, in the Tar -Pamlico
River Basin in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in
Parts 1,1I, I1I, IV, V, and VI hereof.
This permit shall become effective March 17, 2006.
This permit and the authorization to discharge shall expire on April 30, 2007.
Signed this day March 17, 2006.
Alan W. Klimek, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Page I of I
Herring, David
From: Neff, Ride
Sera: Friday, Marla 09, 200710:32 AM
To: 'ron.booneonc mail.netenr.state.nc.us'
Cc: Frymyer, Sid; Herring, David
Saber Edgecombe Generating, LLC - Stogy Pond Design
Dear Mr. Boone:
Mr. Sid Frymyer, General Manager at Edgecombe Gig, informed me of the inspection conducted by DENR ycstaday,
March 8, 2007, and your interest in the design and operatim of the wet demotion Warmwatm pond at the f wiiity. As the
Engineer of Record for the facility's Storrawater Pollution Prevention Plan and SPCC Plan, I am familiar with the pond's
design and operation.
For your reference I have attached the applicable pages Snm DENR's Stonmwd w Guidance Man m* the stotmwater pond at
Edgecombe coafctms to the design pry preseatod there. Specifically, the methodology detadod in Appendix L
indicates that a minimum pond mrfim area of 031-acres is required to provide adequate treatment; the Edgecombe pond
area is *0.4-acres when the water level is at the blee"wa orifice invert. Appendix L recommends that the bled -town
orifice be sized to restore the stmmwaler treatment volume in 2 to 5 days and the Edgecombe pond orifice (2-arch diameter)
is sized to restore the pond's voh me in 3-days afkr treating the 10-year, 244xmr paecipludon event.
Please call either me or Mr. Frymyer if you need any additional information regarding this matter.
ly,
,-� C. Richard Neff, P.E.
Manager, Environmental Affairs
Cogentrix Energy, Inc.
9405 Arumpoint Boulevard
Charlotte, NC 28273
Telephone: [phone]
Facsimile: [phone]
Cellular' [phone]
e-mail: RickNeMCogenmcom
03/09/2007

",;'A . _" .' t e , 1,

November 2, 2005
Mr. Richard S. Frymer, Plant Manger
Cogentrix Energy, Inc.
P.O. Box 370
Battleboro, North Carolina 27809
Subject: Compliance Evaluation Inspections
Battleboro Cogeneration Plant
NPDES Permit No. NCO077437
Stormwater Permit NCS000350
Edgecombe County
Dear Mr. Frymer:
so
Michnel F. Easlev, Governor
William G. Ross, .Ir., Sccrclun
North Carolina Department of Environment and Nawral RCSOUNCS
Alan W. Klimek, 11,15., Director
Division or Water QoaIi(V
Enclosed are checklists which transmit the findings of the inspections conducted by Judy
Garrett of the Raleigh Regional Office, and Louis Salguero and Rashe Malcolm of EPA, on July
27, 2005. You and Sandy Bunn represented Cogentrix during the inspection. Judy Garrett also
met with you and David Herring on August 17, 2005. Your cooperation and assistance is
appreciated. As a result of the inspections, we have the following comments and
recommendations:
1) The treatment system consists of 2 neutralization/settling basins which receive wastewater
from the coal pile runoff, cooling tower blowdowns, and oil/water separators/plant overflow
pit. If necessary, pH is adjusted as it leaves the neutralization weirs using either caustic or
acid. Pipe 002 discharges into the head of the neutralization basins. Flow is measured in a
parshall flume. Domestic wastewater from this facility is discharged to the Rocky Mount
Regional Collection System.
2) Mr. David Herring was ORC of the facility at the time of the inspection. Since that time.
Mr, Alexander(Sandy) Bunn has been delegated as ORC. The facility has 3 Back-up ORCs.
All 4 of these operators Hold PC-1 classifications as required for this PC -I classified
facility.
3) A walk-through inspection of the facility was conducted. it was noted that the effluent
pump station does not have visual and audible high water alarms. These need to be
installed as soon as possible. In addition, the water in the wet well was backing up into the
parshall flume, causing a flooded condition. You informed Ms. Garrett that this problem has
already been corrected.
4) A review of the sampling practices at the facility indicated that the composite samples are
not being iced during collection. Please begin refrigerating or icing these samples during
collection. The Oil and Grease grab sample should be taken in a glass container. Oil and
grease clings to plastic containers and causes sample bias. Please begin collecting Oil and
Grease samples in glass as required in 40 CFR 136 immediately.
ort Nlicaroiina
I/ V1111'alli/
North Carolina Division or Water Quality Raleigh Regional Office Surface Water Protection Phone [phone] Customer Service
Internet: h2o,enr.state.nc.us 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled110% Post Consumer Paper

Mr. Frymer �
Page 2 1-7
5) A review of the facility records was conducted. The flow meter was calibrated on 1/6/05.
The continuous pH meters were calibrated on 1/6/05. The ORC should document visits in a
log indicating visitation by him or a back-up operator.
6) Mr. Bunn said that the operators cause a discharge from Pipe 002 in order to meet the
minimum monitoring requirements contained in the NPDES Permit. If no discharge occurs
during the month from this pipe, you may report 0 flow for each day and no further
monitoring is required.
7) Composite sampling of Pipe 003 is constant time/constant volume. You have indicated that
the flow does not vary by more than 15%. The permit requires flow proportional monitoring
unless approval of constant time/constant volume sampling is approved by the DWQ
Director. Please submit a request for approval along with documentation that the flow does
not vary by more than 15 %.
8) A review of the Stormwater records indicated that the records are well maintained with all
requirements met. The stormwater outfall was inspected and found to be satisfactory.
Please respond to the concerns listed in items 3, 4, 5 and 7 above on or before November 23,
2005. If you have questions concerning this inspection, please contact me or Ms.Garrett at (919) 791-
4200.
Sincerely,
Kenneth Schuster, PE'
Water Quality Regional Supervisor
cc: Edgecombe County Health Department
DWQ Central Files
Louis Salguero, EPA Science and Ecosystem Support Division, 980 College Station
Road, Athens, GA 30605-2720

i M N
United States Environmental ProtacLon Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No, 2040-0057
Water Compliance inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yrlmo/day Inspection Type Inspector Fac Type
20J
1 I NJ 2 151 31 NCS000350 11 121 05/07/27 117 181 C 19� J
Lf U U l
Remarks
211 1 1 1 I 1 1 1 Ills I I I 1_1 1 1 1 1 1 1 1 1 1 1 1 1 I_1..1.1 I I I 1 1 1 1 1 1 1 I 1 1166
Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA----------------- Reservod-------------- -
671 ' 69 70I I 71 I uI :.j 72 73 � 74 751 I 1 iI 11 I Li 80
u
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTVV, also include
Entry Time/Date
Permit Effective Date
POTVV name and NPDES permit Number)
Ccac:r,crix. Energy Inc-Battiebor
10:O0 Fly
Exit Time/Date
Permit Expiration Date
NCS 2 1400
Battleboro KC 27809
03:00 PM 05/07/27
07/04/30
Name($) of Onsite Representative(eyTitles(s)IPhone and Fax Number(s)
Other Facility Data
Name, Address of Responsible Offlciai/Title/Phone and Fax Number
Seth Carter, PO Box 370 Battleboro NC 27909//252-942-0905/ ContactedNo
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Records/Reports Self -Monitoring Program 0 Facility Site Review
Effluent/Receiving Waters 0 Storm Water
Section D: Summary of Findin Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
,'.udy F Sarrett RRO WQ//919-571-4700 Ext.270/
frVY� fff
Signature of Managem Q A eatewer Agency/Office/Phone and Fax Numbers D e
rr
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.

NPDES yrlmolday Inspection Type
racsaoasso J 11 121 05/07/27 17 is ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checldists as necessary) _ _�

l ' 17' ft so
Permit: NC5000350 Owner - Facility: Cogentrix Energy Inc-Battlebor
Inspection Date: 0M712005 Inspection Type: Compliance Evaluation
Permit
Yes
No NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
❑ ❑
❑
Is the facifity as described in the permit?
❑ ❑
❑
Are there any special conditions for the permit?
❑
■ ❑
D
is access to the plant site restricted to the general public?
■
❑ ❑
❑
Is the inspector granted access to all areas for inspection?
❑ ❑
❑
Comment:
r

so
,T
General Stormwater Inspection Checklist
Type of Visit ®Compliance inspection/Program Audit ❑Tech Assistance or Recon
Location: Cogentrix_ofRocky.Mount,.Edgecombe County
Facility Number NCS0003'50 Date07/27/05 Time In10:30 Time Out 3:30
People Interviewed, and Titles- Richard Fryrper and David!. Herring
Name of Inspector.ga� C
SPPP Documentation (Site PI&A Pai# II (A)(1))
1. Copy of Certificate of Coverage ®Yes ONO Copy of Permit ❑Yes ONO Requested
but not required
2. General Location (USGS) Map shows plant ®Yes pNo, lines of discharge
Part li(A)(l)(a)
to water of State ®Yes mo, Stream labeled ®Yes ONO., Latitude and longitude ®Yes ONO
Comments:
3. Narrative_ Description of Practices ®Yes ❑No
Part II(A)(1)(b)
4. Site map ®Yes ONO Shows flows & areas served with arrows and
Part 1I(A)(1)(c)
% impervious surface ®Yes ONO, buildings ®Yes ONO, process areas ®Yes ONO,
disposal areas ®Yes pNo, drainage structures ®Yes ONO, existing BMPs such as secondary containment
®Yes ❑No, list of potential pollutants ®Yes pNo
Comments:
5. List of significant spills in last 3 years or certif. if none ®Yes O'No `,< <
Part II(A)(1)(d)
RRO called? ®Yes pNo
6. SW outfalls have been evaluated for process water ®Yes pNo; „ ;
Part II(A)(1)(e)
7. Feasibility of Changing Practices ®Yes pNo , ._ ; `
Part II(A)(2)(a)
8. Secondary Containment ®Yes ONO Schedule needed. pYes ®No
Part II(A)(2)(b)
Records of Draining Containment, Observations Made OYes ONO
9. BMP Summary ®Yes ONO
Part II(A)(2)(c)
10. SPRP Plan ®Yes pNo, Responsible personnel still employed here? ❑Yes ONO
Part II(A)(3)
11. PM and Housekeeping Plan ®Yes pNo Record of Inspections? O'Yes ONO
Part II(A)(4)
12. Employee training ®Yes ONO — for everybody ®Yes ❑No
Part Il(A)(5)
13. Responsible parties, chain of command page_ ®Yes []No:- _ .''
Part II(A)(6)
14. Plan undated/reviewed annually ❑Yes pNo ..:.
Part H(A)(7)
15. Stormwater Facility Inspection Program ®Yes ONO
Part II(A)(8)
16. This Plan Has Been Implemented (documents in manual,
Part II(A)(9)
employees show awareness ®Yes pNo Comments:Spill plan -is updated every 5 years..
Sampling and Analytical Data Part II(C)
All Stormwater and Process Water is Recycled (IIC(3)) Oyes ONO
Rain Gauge on site (not required) ®Yes ❑No
Record of an overflow ®Yes ONO Details
If not all recycled, what is allowed to discharge? Vehicle Cleaning (IIC2) ❑ Recycle overflow (IIC3
above) ❑ Wetting of Aggregate (IIC4)❑ Mixing drum cleanout (IIC5) ❑ Vehicle Maintenance []
Note: this checklist does not take the place of your permit. You are fully responsible for
following the permit.

For the topics checked in last question, Analytical data present ®Yes ONO, Compliant'? ®Yes ❑No
Details:
Total precip ®Yes ONO, Storm duration ®Yes 'ONO, Total flow Est. ❑Yes ❑No,Field pH ®Yes ONO,
Chain of custody ®Yes pNo
Qualitative Monitoring performed semiannually ®Yes 0-'No Part II(F)
Stormwater not combined with process wastewater — general runoff Partll(C)(1)
Analytical data pYes pNo, Chain of Custody pYes pNo, Qualitative Monitoring performed
semiannually (Section F) pYes pNo,
If using cutoff policy, how many sample rounds 2;�analyses_in 2004"' a's required:
Cutoff Concentrations met pYes ONO :....° 'Ever have a Bypass? pYes ONO (I1=1(C)(4)a1&2)
Notification given? (pYes pNo
Outdoor Inspection
I located all discharge points ®Yes pNo No. of areas served ; r'=T:
Sample points appropriate ®Yes pNo
Location if different from discharge point T'
Housekeeping: Trash pYes ®No Dust pYes ®No
Take pH ®Yes pNo Value(s) ?=
Take photos ®Yes pNo
Containment Area satisfactory pYes pNo, Loose drums 'pYes ®No, Locked drain b'Yes ®No
Inspection Summary Comments
See=attached�'letter
Recommendations•:!`'k" '
L.—'
Requirements:
Letter is to go to:
Name Richard S: Frymer, Plant: 'Manager
Title Plant.Manager
Address P.O: Box 37; Battleboro; NC r-27809
Helpful Information at http://h2o.enr.state.ne.us/su/Manuals_Eactsheets.htm
Note: this checklist does not take the place of your permit. You are fully responsible for
following the permit.
Revised 7/23/03, 10/21/03, 4/13/05