Mayo Monofill General Permit File (17)

Georgoulias, Bethany
From: Romanski, Autumn
Sent: Wednesday, December 18, 2013 7 49 AM
To: Georgoulias, Bethany
Subject: RE Mayo Steam Plant CCR Monofill - NCG12 COC Issuance with Amended Conditions
Bethany,
Thank you for your consideration to review and research this. I agree with your call to pull out of the list Mn and Al,
upon further review studies did show less likely to leach and low leach - ability and only under very specific conditions.
The list is long, but well researched and applicable0
Sincerely,
Autumn
From: Georgoulias, Bethany
Sent: Thursday, December 12, 2013 9:50 AM
To: Parnell, David; Bennett, Bradley
Cc: Romanski, Autumn; Holley, John; Pickle, Ken; Smith, Danny
Subject: Mayo Steam Plant CCR Monofill - NCG12 COC Issuance with Amended Conditions
Importance: High
Dave,
I hope you had a nice vacation over the Thanksgiving holiday I'm sure you are still catching up
Attached are documents I've drafted in preparation to issue a Certificate of Coverage for NCG12 for the Mayo Steam
Plant Monofill under construction in Person County It's scheduled to begin operation early next year, and we'd like to
issue it before the Christmas holidays
This is an unusual COC because it has several amended conditions based on the material (coal combustion reside
sprayed with evaporator liquid waste from the ZLD system going in at Mayo Steam Plan). We have proposed additional
monitoring through the permit cycle, as well as two special events with a more comprehensive list. Please see the
attached DRAFT COC This COC will be finalized before being sent to the permittee — we don't run public notices or
normally provide permittees with "draft" COC's I dust wanted you to review it
I have some information about the Solid Waste Permit, but I assume there is also an E &SC plan in place for this site?
Dave, if it would help to talk with you and John about any questions you have, please let us know. Bradley and I can
be available to discuss We want to make sure RRO DEMLR understands how different this site is than our usual general
permits. Does the RRO [DEMLR or DWR] have any objection to proceeding with issuance of this COC? Please let us
know your concurrence by December 18th
Autumn and Danny are very familiar with the Mayo Steam Plant and the variety of issues there. She has provided a lot
of information I've incorporated into my review (and by the way, please disregard the first one I sent, because I had to

correct some history in there with the help of her summary below ) THANK YOU FOR ALL YOUR HELP WITH THIS ONE,
AUTUMN"
Autumn and Danny, please let us know your concurrence with this proposed path forward on the COC as
well. Instead of putting the extra monitoring in dust the cover letter, we have amended it to the actual COC and noted
the COC is an enforceable part of the permit We are also requesting in- stream sampling results from the WQMP under
the solid waste permit be copied to RRO (see draft cover letter).
We plan to brief Tracy and Toby in DEMLR about this permit, since there's been litigation surrounding the Mayo Steam
Plant NPDES wastewater permit and so many issues with the coal fired power plants in general Our AG's office has said
we are okay to move ahead with this one since it is a separate site
We also know there are several landfills out there (many unlined, unlike this one — which we expect to be much lower
risk) that are accepting coal ash. Autumn has given me info on the Halifax County Landfill after her investigations there,
and certainly there are many others. I think this will be an important aspect to consider in our NCG12 renewal, and we'll
probably incorporate additional monitoring for outfalls that receive any runoff from areas where ash was /is being
landfilled
Thanks so much for your prompt attention to this one,
Bethany
Bethany Georgoulrus, Envn•onnmental Engineer
NCDENR / Division of Energy, Mineral, and band Resouices
Ston nwater Permitting Progl am
1612 Mail Service Centel, Raleigh, NC 27699 -1612
512 N Salisbury Street, Raleigh, NC 27604
919 / 807 -6372 (phone), 919 / 807 -6494 (fax)
Website http //portal ncdenr org /web /Ir /stormwater
A -ntad corierponderrce to and lrom this address mad be sub /ect to the AotthCarolma Public Records lux, and may be dtsctosed to thud partier
From: Romanski, Autumn
Sent: Tuesday, December 10, 2013 2:26 PM
To: Georgoulias, Bethany
Subject: RE: Mayo Steam Plant CCR Monofill - 2009 file review question
Bethany,
This is the only signed SOC for Mayo and it took 1 Y� years to reach a final agreement Application dated Dec 9, 2010
with final signed June 2012. Any other SOC documents (which originate from the RRO Office and then are finalized by
the CO and Director) dated earlier than June 2012 would have been drafts from 2010 to final in 2012. The modified
permit currently in effect was effective November 1, 2009 and expired March 31, 2012 No reissuance, e-mail trail of
permit renewal being passed from permit writer to permit writer and according to Sergei- who did the final draft in
2012 -2013, the permit cannot be reissued yet due the law suit?
I think Roxboro SOC draft (an application for SOC was received March 30, 2009, a second SOC draft was submitted to CO
on November 9, 2009, then another draft sent to CO on February 2, 2010, none ever signed.) Eventually, the SOC was
no longer needed by August /Sept 2010 since by then the treatment units were repaired Additional sampling was
required by RRO during the wastewater treatment units failures, starting in March 2008. The additional monitoring
required by RRO stopped in Sept 2010 when the treatment units repairs were completed. There is currently no SOC at
Roxboro and last permit issued was modification dated 2009 and expiration date March 31, 2012

I hope providing this timeline of events associated with 2009 and Soc applications clears up any ambiguity from the CO
file review. If not, just give a call.
Autumn