NCS000369_Review Document_20180509

NC Division of Energy, Mineral and Land Resources
Review of Permit Renewal — NCS000369
Fayetteville Public Works Commission — Butler/Warner Generation Plant
SIC 4911— Electric Generation — Steam Electric — natural gas with #2 fuel back up.
Monitoring — The facility has been monitoring for TSS, Total Recoverable Iron and pH. Previous permit did have tier
system (2 tiers).
o Data reviewed from 2008 through 2017. Results for iron were consistently below benchmark as were TSS
and pH. pH did have one value outside the upper range (9.41).
o Iron — Due to it's ubiquitous nature iron is being removed from most of our monitoring and is the water
quality standard is proposed for removal as well.
o TSS and pH are baseline parameters that should be maintained in the permit.
o Based on their site visit the FRO has recommended that oil and grease monitoring be added to the permit.
This is a result of the potential storage capacity for #2 fuel and past spills.
o Parameters in permit — TSS, Non -Polar Oil and Grease and pH
o Tier structure adjusted to have the three levels as in current permits.
o Parameter codes added to permit.
Discussions with facility contact (William "Ace" May) indicated that there have been no major changes at the facility.
Mr. May indicated all drainage to the onsite pond and that the pond only discharges with large storm event. I
reviewed monitoring reports and looked at NOAA precipitation data. This indicates that the pond does not hold the
25 yr storm and does discharge in smaller events. Mr. May agreed. Maintain the footnote language from the
previous permit associated with manual discharge from the pond. Resturctured this language a little from the
previous permit. Mr. May noted that City of Fayetteville MS4 staff regularly inspect the facility as part of their
permit efforts.
Facility drains to the Locks Creek 18-24 in the Cape Fear River Basin, a class C stream. 2014 Assessment Report
shows no impairment of concern for this facility in this area.
NC National Heritage review — Report shows no record of species of concern.
FRO — Draft permit and related information sent to the region for comment by email on 3/14/2018. Had also
previously talked with Mike Lawyer about the facility and about contacts. FRO conducted site visit on 4/10/2018
and submitted comments on 4/11/18. Okay with changes and the facility was in compliance. Region recommends
adding oil and grease monitoring due to storage on site and past spills. See inspection report in file.