NCG500664_Permit (Issuance)_20130814

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder
Governor Director
August 14, 2013
Charles Packard, President
INGENCO Renewable Development
2250 Dabney Road
Richmond, Virginia 22901
Subject:
Dear Mr. Packard:
John Skvarla, III
Secretary
Issuance under General Permit NCG500000
Certificate of Coverage (COC) NCG500664
IRD Wake Power Plant / South Wake MSW Landfill
6300 Old Smithfield Road, Apex 27502
Wake County
In accordance with your application received May 20, 2013, and supplemental data received on
August 9, 2013, the Division of Water Resources (DWR) hereby forwards this Certificate of Coverage
to discharge under the subject general permit. We issue this permit pursuant to the requirements of
North Carolina's General Statue 143-215.1 and the Memorandum of Agreement between North
Carolina and the US Environmental Protection Agency dated July 17, 2007 (or as subsequently
amended).
The Division understands that this is a new discharge, previously unpermitted. Please note that your
facility discharges to a stream segment currently classified C. The following information is included
with your permit:
• A copy of the Certificate of Coverage for your treatment facility
• A copy of General Permit NCG500000 for non -contact cooling water, boiler blowdown
• A copy of a Technical Bulletin for General Permit NCG500000
If any parts, measurement frequencies or sampling requirements contained in this general permit are
unacceptable, you have the right to request an individual permit by submitting an individual NPDES
permit application. Unless such demand is made, this Certificate of Coverage shall be final and
binding.
Please note that this Certificate of Coverage is not transferable except after notice to the Division of
Water Resources. The Division may modify, or revoke and reissue this Certificate of Coverage. This
issuance does not affect your legal obligations to obtain other permits that may be required by the
Division of Water Resources, the Division of Land Resources, the Coastal Area Management Act, or
any other Federal or Local government.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet www.ncwaterresources.org
An Equal Opportunity 4 Affirmative Action Employer
NorthCarohna
Naturally

If you have any questions concerning this permit, please contact Joe R. Corporon L.G. at telephone
number [phone] or email ([e-mail]).
Since
or Thomas A. Reeder
cc: Raleigh Regional Office (RRO), Danny Smith, Supervisor, Surface Water Protection Section
Central Files
NPDES General Permit Files
ec: Thomas Hecmanczuk [[e-mail]]
Stacey Smith [[e-mail]]
Joan A. Smyth, P.G., [[e-mail]]
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
Phone: [phone] \ FAX: [phone] \ Customer Service:1-877-623-6748
Internet: www.ncwaterresources,org
An Equal Opportunity \ Affirmative Action Employer
NorthCarohnaII
Naturally

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
General Permit NCG500000
Certificate of Coverage NCG500664
To discharge boiler blowdown from renewable energy power generation, as back-up for discharge -water
used for dust control in proposed landfill operations, and similar wastewaters under the
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES)
In compliance with the provisions 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,
INGENCO Renewable Development
is hereby authorized to discharge wastewater from a facility located at
IRD Wake Power Plant / South Wake MSW Landfill
6300 Old Smithfield Road, Apex
Wake County
to receiving waters designated as Little Branch [stream segment [ 18-7-6-1-1 ], a waterbody currently classified C
within Subbasin 03-06-07 of the Cape Fear River Basin, in accordance with effluent limitations, monitoring
requirements, and other conditions set forth in Parts I, II, III and IV of the General Permit NCG500000, as attached.
This permit shall become effective August 14, 2013.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day August 14, 2013.
A. Reeder, Director
Sion of Water Resources
By Authority of the Environmental Management Commission

INGENCO Renewable Development
IRD Wake Power Plant
South Wake MSW Landfill
State Grid/USGS Quad:
Drainage Basin:
Receiving Stream:
Latitude:
HUC:
) 23NE/Apex, NC
Cape Fear Basin
Little Branch
35° 40' 27"
03030003
Sub -Basin: 03-06-07
Stream Class: C
Longitude: 78° 51' 28"
Stream Segment: 18-7-6-1-1
North
General Permit COC NCG500664
Wake County

Corporon, Joe
From: Corporon, Joe
Sent: Monday, August 12, 2013 6:53 AM
To: 'Joan Smyth'
Cc: Hennessy, John ([e-mail]); Thomas Hecmanczuk; Stacey Smith
Subject: RE: IRD Well Reanalysis
Ms. Smyth — Received your updated analytical data - issues resolved.
I will resubmit your COC documents for signature; I expect them to be processed this week. I will email you a PDF copy
after signature, hardcopy to follow by mail. Thanks for your patience and perseverance with purging and resampling the
well.
Respectfully,
Joe R. Corporon, L.G. ROC
Expedited Permitting Compliance and Enforcement Unit
DWR
DMslon c 115u, Fncaices Division of Water Resources
NCDENR/ NPDES Program / Surface Water Protection Section
919-807-6394; FAX [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.
From: Joan Smyth [mailto:[e-mail]]
Sent: Friday, August 09, 2013 8:50 PM
To: Corporon, Joe
Cc: Thomas Hecmanczuk; Stacey Smith
Subject: IRD Well Reanalysis
Mr. Corporon —
Mr. Stacey Smith of my office has left messages to discuss the results of our latest sampling of the well for cooling water
for the IRD Wake Power Plant. Attached please find a letter summarizing our latest findings and revising a portion of the
original NPDES submittal. We look forward to discussing this further at your earliest convenience.
Thank you.
Joan A. Smyth, P.G.
Senior Hydrogeologist
SMITH GARDNER
14 N. Boylan Avenue
Raleigh, NC 27603
P [phone] x 221
1

SMITH . GARDNER
August 9, 2012
ADDRESS
14 N. Boylan Avenue, Raleigh NC 2?603 919.828.05/7
r'rE
wwwsmithgardnerinc.com
Mr. Joe Corporon, L.G.
NCDENR Division of Water Resources — Water Quality Programs
1611 Mail Service Center 5\
Raleigh, NC 27699-1611 W/ok
RE: Revised NPDES Permit Application t. -
IRD Wake Power Plant - South Wake Landfill \--)N�
Holly Springs, North Carolina
Dear Mr. Corporan:
Due to some elevated inorganic constituent concentrations detected during our initial sampling
(March 20131 of the IRD Wake Power Plant well at the South Wake Landfill, Smith Gardner, Inc. (5+G)
personnel resampled the well on July 161h, 2013. As you know, this well is proposed to supply cooling
water as part of the renewable energy project for the South Wake Landfill.
Prior to the July sampling event, the well was pumped for a period of approximately 3 hours. During
this time, approximately 360 gallons of water were purged from the well. This is more than one well -
volume for this size well. It should be noted that no pumping occurred prior to the initial sampling
event in March, which was conducted within 24 hours of the well chlorination. During this second
sampling event filtered samples were also collected to evaluate the effect of filtration on reducing
inorganic constituent concentrations.
Analytical results from the July sampling event, as compared with the original March sampling event,
indicated significantly reduced concentrations of certain inorganic constituents including zinc and
selenium. Additionally, the total suspended solids in the sample were reduced. Solids suspended
within the sample can yield inorganic results that are "biased high". The sample collected after
filtration did not yield significantly different results from the non -filtered samples collected in July.
Since this well had not been purged prior to the initial sampling, and the initial sampling occurred
shortly after well chlorination, we believe the well development/purging completed prior to the July
sampling event yielded water samples that are more representative of the true aquifer condition. This
is supported by the reduced total suspended solids analytical results from the July sampling event.
Based on this evaluation, we believe the July 2013 sampling data is representative of future discharge
conditions.
We have attached a revised Table 1 for inclusion in the NPDES permit application that reflects the July
sampling results. Please contact us if you have any questions or require any additional information.
Sincerely,
SMITH GARDNER, INC.
,v,„,*A_
Joan A. Smyth, P.G.
,Senior Hydrogeologist
ioanfasmithgardnerinc.com
Stacey A. Smith, P.E.
Project Manager
Staceyfasmithuardnerinc.com
Attachments Table 1 — Laboratory Analytical Summary
Cc: Tom Hecmanczuk - Ingenco
H:\Projects\South Wake\Ingenco\NDPES\Revised Analytical Letter-8-7-13.docx

SMITH+GARDN ER
Table 1
Expected Concentrations
Ingenco Well South Wake Landfill
Parameter
units
7-16-13
Sample
Expected
Concentration
Factor
Anticipated
Concentration
Arsenic
ug/I
<5.4
1
<5.4
Chromium
ug/I
<1.4
1
<1.4
Iron
ug/I
<22
1
<22
Magnesium
ug/I
11100
2.4
26640
Manganese
ug/I
30.2
1
30.2
Molybdenum
ug/I
<2.5
1.3
3.25
_
Selenium
ug/I
<5
1
<5
Silver
ug/I
1.9 J
1
1.9
Zinc
ug/I
685
2
1370
az!uii_ _ . -
:. 'A
tom: riit
z '_.. �u,
Chloride
mg/I
95
3.6
342
COD
mg/I
15
2.5
37.5
pH
Std Units
7.7
1.1
8.47
TDS
mg/I
470
2
940
Turbidity
NTU
0.5 J
1
0.5
Expected Concentration Factor = from previously submitted NCG500000 permit application
Anticipated concentration based on 7-16-13 sample (not filtered) and the concentration factor
7-30-13

Table 1
EXPECTED CONSTITUENTS
Constituents
3-12-2013 Sample
Results (ug/L)
Anticipated
Concentration
Factor**
Expected Values
(ug/L)
Arsenic
7.6
1
7.6
Chromium (total)
7.2
1
7.2
Iron
68
1
68__
Zinc*
34000
2
C 68000)
Total Nitrogen
1200
5.6
- 6720
Magnesium`
14000
2.4
33600
Manganese
29
1
29
Molybdenum
3.7
1.3
4.
Selenium
29
1
29
*diluted 50x
" estimated from other Ingenco facilities
<RL indicates samples detected below laboratory reporting limit

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NPDES APPLICATION NC6500000
EXISTING SITE CONDITIONS
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SMITH GARDNER
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14 N. Boylan Avenue, Raleigh NC 27603 S1.9.828.0577 wwwsmithgardnerinc.com
Narrative Summary
The IRD Wake Power Plant (Landfill Gas to Energy Facility at South Wake MSW Landfill) is
planning on discharging up to 4,300 GPD of non -contact cooling water from the proposed
renewable energy project as an alternative to re -use on -site for road dust control. The
cooling water will not include any additives from the discharge, but may result in a slight
increase in concentrations due to evaporation as it flows through the process. The cooling
water will originate from an on -site groundwater well that was sampled on March 12, 2013 for
the a variety of metals and general chemistry parameters including chloride and
mercury. The metals were analyzed by EPA Method 3030C and 6020A, while the general
chemistry parameters [which included total nitrogen, BOD, COD, cyanide, Nitrate/Nitrite as N,
oil and grease, phosphorus, residual chlorine, TDS, TKN, TSS, and ammonia as N) were
analyzed by a variety of methods. Chloride was analyzed by EPA Method 9056A. Table
1 provides a summary of the detected constituents and the anticipated concentration factors
(from similar operations) compared to water quality standards (15A NC 2B .0211).
The primary use for the discharge water will be for dust control to on -site access and haul
roads in support of the existing landfill operation. Direct discharge will be performed as a
backup and would be discharged to an on -site channel that flows into Sediment Basin No. 1
(see Figure 2) which in turn discharges into Little Branch Creek.
Alternatives to Discharge
The Town of Holly Springs is unable to provide sewage services to discharge the non -contact
cooling water without annexation of the site. Therefore, connection to a municipal sewer
collection system is not feasible.
Spray irrigation and subsurface disposal are not practical alternatives as Sediment Basin No.
1 [see Figure 21 is already in place in consideration of the limited discharge under an
alternative scenario. The primary use is for dust control ("watering") for the roads. This
practice is already performed at the site utilizing collected stormwater and would not add any
extra costs to the operation.

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REFERENCE: U.S.G.S. 7.5 MIN. QUADRANGLE
APEX', DATED 1974, PHOTOREVISED 1987,
PHOTOINSPECTED 1988.
PREPARED FOR
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PREPARED BY
IRD WAKE POWERPLANT
SOUTH WAKE MSW LANDFILL
NPDES APPLICATION NC6500000
SITE VICINITY MAP
C.T.J.
APPROVE
J.L.M.
CALF -
AS SHOWN
DATE:
Apr 2013
PROJECT NO.•
INGENCO 12-1
FIGURE NO. -
FILE NAME.
WAKE-A0348
© Smith Gardner Inc.
5\jvi(-. 413 ovc-ik-cC ob\ Ltki- 356 4-6(446f-
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FOR AGENCY USE ONLY
ATA
NCDENR
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NOTICE OF INTENT
National Pollutant Discharge Elimination System application for coverage under General Permit
NCG500000: Non -contact cooling water, boiler blowdown, cooling tower blowdown, conden
similar point source discharges
ORIGINAL
Division of Water Quality / Water Quality Section
National Pollutant Discharge Elimination System
NCG500000
Date Received
Year
Month
Day
Certificate of Coverage
NICIGI1
Check #
Amount
Permit AssiRned to
/li( 6-5-coC'/
(Please print or type)
1) Mailing address' of owner/operator:
Company Name
Owner Name
Street Address
City
Telephone No.
INGENCO Renewable Develop
Charles Packard, President
2250 Dabney Rd
Richmond
804 521 3500
* Address to which all permit correspondence will be mailed
2) Location of facility producing discharge:
Facility Name
Facility Contact
Street Address
City
County
Telephone No.
IRD Wake Power Plant
State
Fax'
Desi Gulley
6300 Old Smithfield Rd
Apex
Wake
State Ni ZIP Code 27502
804 521 3500
Fax:
3) Physical location information:
Please provide a narrative description of how to get to the facility (use street names, state road numbers,
and distance and direction from a roadway intersection). US HWY 55 Bypass S 2 mi south of 1 JS 1
(A copy of a county map or USGS quad sheet with facility clearly located on the map is required to be submitted with this application)
4) This NPDES permit application applies to which of the following :
IN New or Proposed
❑ Modification
Please describe the modification:
O Renewal
Please specify existing permit number and original issue date:
5) Does this facility have any other NPDES permits?
❑ No
• Yes
NCG 120080
If yes, list the permit numbers for all current NPDES permits for this facility:
6) What is the nature of the business applying for this permit? Green power production from
landfill gas already collected on landfill
Page 1 of 4 04/05

NCG500000 N.O.I.
7) Description of Discharge:
a) Is the discharge directly to the receiving water? 0 Yes DI No
If no, submit a site map with the pathway to the potential receiving waters clearly marked. This
includes tracing the pathway of the storm sewer to the discharge point, if the storm sewer is the only
viable means of discharge.
b) Number of discharge points (ditches, pipes, channels, etc. that convey wastewater from the
property): A single point as described in attached narrative and as shown in Figure 2.
c) What type of wastewater is discharged? Indicate which discharge points, if more than one.
❑ Non -contact cooling water Discharge point(s) #:
❑ Boiler Blowdown Discharge point(s) #:
CEI Cooling Tower Blowdown Discharge point(s) #: t
❑ Condensate Discharge point(s) #:
❑ Other Discharge point(s) #:
(Please describe "Other")
d) Volume of discharge per each discharge point (in GPD):
#1: 4300 #2: #3: #4
e) Please describe the type of process (i.e., compressor, NC unit, chiller, boiler, etc.) the wastewater is
being discharged from, per each separate discharge point (if applicable, use separate sheet):
2MMbtu/hr cooling tower blowdown with no additives as described in the attached narrative.
8) Please check the type of chemical added to the wastewater for treatment , per each separate discharge
point (if applicable, use separate sheet):
O Biocides Name: Manuf.:
O Corrosion inhibitors Name: Manuf.:
0 Chlorine Name: Manuf.:
❑ Algaecide Name: Manuf.:
❑ Other Name: Manuf.:
a None
9) If any box in item (8) above, other than none, was checked, a completed Biocide 101 Form and
manufacturers' information on the additive is required to be submitted with the application for the
Division's review.
10) Is there any type of treatment being provided to the wastewater before discharge (i.e., retention ponds,
settling ponds, etc.)? 0 Yes 5 No
If yes, please include design specifics (i.e., design volume, retention time, surface area, etc.) with
submittal package. Existing treatment facilities should be described in detail. Design criteria and
operational data (including calculations) should be provided to ensure that the facility can comply with the
requirements of the General Permit. The treatment shall be sufficient to meet the limits set by the
general permits.
Note: Construction of any wastewater treatment facilities requires submission of three (3) sets
of plans and specifications along with the application. Design of treatment facilities
must comply with the requirements of 15A NCAC 2H .0138. If construction applies to
this discharge, include the three sets of plans and specifications with this application.
Page 2 of 4 04/05

NCG500000 N.O.I.
11) Discharge Frequency:
a) The discharge is: EN Continuous 0 Intermittent 0 Seasonalo
i) If the discharge is intermittent, describe when the discharge will occur:
ii) If seasonal check the month(s) the discharge occurs: 0 Jan. 0 Feb. 0 Mar. 0 Apr.
0 May 0 Jun. 0 Jul. 0 Aug. 0 Sept. 0 Oct. 0 Nov. 0 Dec.
b) How many days per week is there a discharge? 7
c) Please check the days discharge occurs:
a Sat. IN Sun. IX Mon. ® Tue. IN Wed. El Thu. IX) Fri.
12) Pollutants:
Please list any known pollutants that are present in the discharge, per each separate discharge point (if
applicable, use separate sheet): See attached Table 1 - Expected Constituent Level Comparison.
13) Receiving waters:
a) What is the name of the body or bodies of water (creek, stream, river, lake, etc.) that the facility
wastewater discharges end up in? If the site wastewater discharges to a separate storm sewer
system (4S), name the operator of the 4S (e.g. City of Raleigh). Little Branch Creek
b) Stream Classification: Class C
14) Alternatives to Direct Discharge: See attached Narrative Summary.
Address the feasibility of implementing each of the following non -discharge alternatives
a) Connection to a Municipal or Regional Sewer Collection System
b) Subsurface disposal (including nitrification field, infiltration gallery, injection wells, etc.)
c) Spray irrigation
The alternatives to discharge analysis should include boring Togs and/or other information indicating that
a subsurface system is neither feasible nor practical as well as written confirmation indicating that
connection to a POTW is not an option. It should also include a present value of costs analysis as
outlined in the Division's "Guidance For the Evaluation of Wastewater Disposal Alternatives".
15) Additional Application Requirements: See attached Figures 1 & 2 and authorization.
For new or proposed discharges, the following information must be included in triplicate with this
application or it will be returned as incomplete.
a) 7.5 minute series USGS topographic map (or a photocopied portion thereof) with discharge location
clearly indicated.
b) Site map, if the discharge is not directly to a stream, the pathway to the receiving stream must be
clearly indicated. This includes tracing the pathway of a storm sewer to its discharge point.
c) If this application is being submitted by a consulting engineer (or engineering firm), include
documentation from the applicant showing that the engineer (Or firm) submitting the application has
been designated an authorized Representative of the applicant.
d) Final plans for the treatment system (if applicable). The plans must be signed and sealed by a North
Carolina registered Professional Engineer and stamped -"Final Design -Not released for construction".
Page 3 of 4 04/05

NCG500000 N.O.I.
e) Final specifications for all major treatment components (if applicable). The specifications must be
signed and sealed by a North Carolina registered Professional Engineer and shall include a narrative
description of the treatment system to be constructed.
I certify that I am familiar with the information contained in this application and that to the best of my
knowledge and belief such information is true, complete, and accurate. r�
Printed Name of Pers Signing: Owi. 1'4C—AA,,r1�J LZ v
Title: ,i---_—
(Signature of ph ant)
North Carolina General Sta to 143-215.6 b (i) provides that:
Any person who knowingly makes any false statement, representation, or certification in any
application, record, report, plan or other document filed or required to be maintained under Article 21
or regulations of the Environmental Management Commission implementing that Article, or who
falsifies, tampers with or knowingly renders inaccurate any recording or monitoring device or method
required to be operated or maintained under Article 21 or regulations of the Environmental
Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by
a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C.
Section 1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more
than 5 years, or both, for a similar offense.)
4- Zc, t3
(Da • Sig ed)
Notice of Intent must be accompanied by a check or money order for $100.00 made payable to:
NCDENR
Mail three (3) copies of the entire package to:
NPDES Permits Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Final Checklist
This application will be returned as incomplete unless all of the following items have been
included:
❑ Check for $100 made payable to NCDENR
❑ 3 copies of county map or USGS quad sheet with location of facility clearly marked on map
❑ 3 copies of this completed application and all supporting documents
❑ 3 sets of plans and specifications signed and sealed by a North Carolina P.E.
❑ Thorough responses to items 1-7 on this application
❑ Alternatives analysis including present value of costs for all altematives
Note
The submission of this document does not guarantee the issuance of an NPDES permit
Page 4 of 4 04/05

SMITH GARDNER
AnnnESS TEL WEB
14 N. Boylan Avenue, Raleigh NC 27603 919.828.0577 www.smithgardnerinc.com
Narrative Summary
The IRD Wake Power Plant (Landfill Gas to Energy Facility at South Wake MSW Landfill) is
planning on discharging up to 4,300 GPD of non -contact cooling water from the proposed
renewable energy project as an alternative to re -use on -site for road dust control. The
cooling water will not include any additives from the discharge, but may result in a slight
increase in concentrations due to evaporation as it flows through the process. The cooling
water will originate from an on -site groundwater well that was sampled on March 12, 2013 for
the a variety of metals and general chemistry parameters including chloride and
mercury. The metals were analyzed by EPA Method 3030C and 6020A, while the general
chemistry parameters (which included total nitrogen, BOD, COD, cyanide, Nitrate/Nitrite as N,
oil and grease, phosphorus, residual chlorine, IDS, TKN, TSS, and ammonia as N) were
analyzed by a variety of methods. Chloride was analyzed by EPA Method 9056A. Table
1 provides a summary of the detected constituents and the anticipated concentration factors
(from similar operations) compared to water quality standards (15A NC 2B .0211).
The primary use for the discharge water will be for dust control to on -site access and haul
roads in support of the existing landfill operation. Direct discharge will be performed as a
backup and would be discharged to an on -site channel that flows into Sediment Basin No. 1
(see Figure 2) which in turn discharges into Little Branch Creek.
Alternatives to Discharge
The Town of Holly Springs is unable to provide sewage services to discharge the non -contact
cooling water without annexation of the site. Therefore, connection to a municipal sewer
collection system is not feasible.
Spray irrigation and subsurface disposal are not practical alternatives as Sediment Basin No.
1 (see Figure 2) is already in place in consideration of the limited discharge under an
alternative scenario. The primary use is for dust control ("watering") for the roads. This
practice is already performed at the site utilizing collected stormwater and would not add any
extra costs to the operation.

Table 1
EXPECTED CONSTITUENTS
Constituents
3-12-2013 Sample
Results (ug/L)
Anticipated
Concentration
Factor* *
Expected Values
(ug/L)
Arsenic
7.6
1
7.6
Chromium (total)
7.2
1
7.2
,
Iron
68
1
68
Zinc*
34000
2
68000
Total Nitrogen
1200
5.6
6720
Magnesium*
14000
2.4
33600
Manganese
29
1
29
Molybdenum
3.7
1.3
4.81
Selenium
29
1
29
*diluted 50x
** estimated from other Ingenco facilities
<RL indicates samples detected below laboratory reporting limit

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D 2013 Smith Gardner, Inc.