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Home My WebLink AboutNCS000369_Compliance Evaluation Inspection_20180511sm Energy, Mineral and Land Resources ENVIRONMENTAL QUALITY April 11, 2018 Fayetteville Public Works Commission Attn: William "Ace" May, Power Plant Manager PO Box 1089 Fayetteville, NC 28302-1089 Subject: COMPLIANCE EVALUATION INSPECTION NPDES Stormwater Permit NCS000369 Fayetteville Public Works Commission Butler/Warner Generation Plant Cumberland County Dear Mr. May: ROY COOPER Governor MICHAEL S. REGAN Secretary WILLIAM E. (TOBY) VINSON, JR. Interim Director On April 10, 2018, a site inspection was conducted for the Butler/Warner Generation Plant facility located at 2274 Custer Avenue, Fayetteville, Cumberland County, North Carolina. A copy of the Compliance Inspection Report is enclosed for your review. Along with yourself, Mr. Terry Hayner, Operations Supervisor, was also present during the inspection and both your and his time and assistance is greatly appreciated. The site visit and file review revealed that the subject facility is covered by NPDES Stormwater Permit NCS000369. Permit coverage authorizes the discharge of stormwater from the facility to receiving waters designated as an unnamed tributary of Locks Creek, a Class C waterbody in the Cape Fear River Basin. As a result of the inspection, the facility was found to be in compliance with the conditions of NPDES Stormwater Permit NCS000369. Please refer to the enclosed Compliance Inspection Report for additional comments and observations made during the inspection. Please be advised that violations of the NPDES Stormwater Permit are subject to a civil penalty assessment of up to $25,000 per day for each violation. If you or your staff have any questions, comments, or needs assistance with understanding any aspect of your permit, please contact me at (910) 433-3394 or by e-mailat mike.lawyer@ncdenr.gov. Sincerely, �-7 Michael Lawyer, CPSWQ Environmental Program Consultant DEMLR Enclosure ec: William "Ace" May, Power Plant Manager — Butler/Warner Generation Plant Terry Hayner, Operations Supervisor — Butler/Warner Generation Plant Bradley Bennett — DEMLR, Stormwater Permitting Program cc:, FRO — DEMLR, Stormwater Files State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources Fayetteville Regional Office 1 225 Green Street, Suite 714 1 Fayetteville, NC 28301 910-433-3300 Permit: NCS000369 SOC: County: Cumberland Region: Fayetteville Compliance Inspection Report Effective: 07/01/08 Expiration: 06/30/13 Owner: Fayetteville Public Works Commission Effective: Expiration: Facility: Butler/Warner Generation Plant 2274 Custer Ave Contact Person: William Ace May Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): On-site representative On-site representative Related Permits: Title: Power Plant Manager Certification: William Ace May Terry Hayner Inspection Date: 04/10/2018 Entry Time: 2:00PM Primary Inspector: Mike Lawyer'?.� Secondary Inspector(s): Reason for Inspection: Routine Permit Inspection Type: Stormwater Discharge, Individual Facility Status: Compliant E] Not Compliant Question Areas: 0 Storm Water (See attachment summary) Fayetteville NC 28312 Phone: 910-223-4814 Phone: 910-223-4814 910-223-4236 Exit Time: 04:25PM Phone: 910-433-3300 Ex� 3391 Inspection Type: Compliance Evaluation Page: 1 Permit: NCS000369 Owner - Facility: Fayetteville Public Works Commission Inspection Date: 04/10/2018 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Inspection conducted to determine compliance with current/expired permit and as part of the permit renewal process. Met with William "Ace" May, Power Plant Manager, and Terry Hayner, Operations Supervisor. Discussed aspects of the draft permit including the significant changes regarding measurable storm events definition, removal of the Iron parameter from the monitoring requirements, modified tiered response process for benchmark exceedances, etc. Also discussed the annual review and update requirements pertaining to the Stormwater Pollution Prevention Plan; listing of significant spills or notation that none have occurred, re -certification that the stormwater outfall has been evaluated for the presence of any non-stormwater discharges, effectiveness of BMPs, and comparison of analytical monitoring data to benchmark values. Reviewed facility's current Stormwater Pollution Prevention Plan as well as analytical and qualitative (visual) monitoring records from 2013 through 2017. Monitoring records indicate no exceedances of benchmark values with a few records indicating 'No Flow'. Facility primarily uses natural gas for power generation with #2 fuel oil as a backup source. Facility has seven ASTs that can store up to five million gallons of fuel oil. An earthen dike is provided around each AST for secondary containment. Drains at the fuel oil off-loading area are tied to an oil/water separator. Facility has a robust spill prevention and response plan and conducts mock exercises on a routine basis. Secondary containment is also provided around the facility's acid and caustic tanks. Releases of accumulated stormwater from this containment structure flow into the facility's sanitary sewer system. Observations were made of the facility's 5 -acre stormwater retention pond, stormwater discharge outfall and secondary containment structures. Facility appears to be very well operated and maintained., Page: 2 Permit: NCS000369 Inspection Date: 04/10/2018 Owner - Facility: Fayetteville Public Works Commission Inspection Type : Compliance Evaluation Reason for Visit: Routine Stormwater Pollution Prevention Plan Does the site have a Stormwater Pollution Prevention Plan? # 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: Qualitative Monitoring Has the facility conducted its Qualitative Monitoring semi-annually? Comment: Analytical Monitoring Has the facility conducted its Analytical monitoring? # Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? Comment: Permit and Outfalls # 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 outfall status, is it properly documented by the Division? # Has the facility evaluated all illicit (non stormwater) discharges? Comment: Yes No NA NE N ❑ ❑ ❑ ■❑❑❑ ■❑❑❑ ■ ❑ F1 El ■❑❑❑ ■❑❑❑ ■❑❑❑ ■❑❑❑ ■❑❑❑ ■❑❑❑ Yes No NA NE ■❑❑❑ Yes No NA NE E ❑ ❑ ❑ ❑❑■❑ Yes No NA NE ■❑❑❑ N ❑ ❑ ❑ 1:11:1 N ❑ E ❑ ❑ ❑ Page: 3