NCS000197_COMPLIANCE_20160418

STORMINATER DIVISION CODING SHEET
PERMIT NO.
P05 ON Nq
DOC TYPE
❑FINAL PERMIT
❑ MONITORING INFO
❑ APPLICATION
',COMPLIANCE
❑ OTHER
DOC DATE
❑ 20% OLi (S
YYYYMMDD

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IOLS 000
Dominion Resourtes Services, Inc.
5000 Dominion Boulevard, Glen Allan, VA 23060
dom.com
BY U.S. MAIL
RETURN RECEIPT REQUESTED
April 18, 2016
;jopftminione
RECEIVED
Ms. Greta C. Glover APR 25 2016
Pretreatment Coordinator
Waste Water Treatment Plant bl-NAUND QUALITy
135 Aqueduct Rd. ft"Af@R "MITTiNQ
Weldon, NC 27890
Re: Dominion - Rosemary Power Station
Industrial User Permit 40 CFR 403.12 - Authorized Signatories
Dear Ms. Glover:
In accordance with the Industrial User Permit Regulation 40 CFR 403.12 and in addition to the officers
referenced in the regulation, the persons in the following positions are authorized to sign correspondence,
reports, and other documents required by the Industrial Use Permit (#007)1 NPDES permit:
Director, Power Generation Station (I, II or 111)
Director, Power Generation Operations
Manager, Power Generation Operations & Maintenance (O&M)
Plant Manager
Operations & Maintenance (O&M) Supervisor
Technical Consultant
Director, Generation Environmental Services
Manager, Generation Environmental Services
Should you desire additional information or have any questions, please contact Ian Whitlock, of
Dominion's Electric Environmental Services, at [phone].
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
penalties for submitting false information, including the possibility of fine and imprisonment for knowing
violations.
David A. Craymer
Name of Authorized Agent
Signature of Authorized f9ent
Vice President
Power Generation System Operations
Title
Date

Ms. Glover
04/18/2016
Page 2
cc: Ms. Bethany Georgoulias
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
RECEIVED
APR 2 5 2016
DEAR -LAND QUALITY
STORMWATER PERMITTING

Georgoulias, Bethany
From: Pickle, Ken
Sent: Friday, January 31, 2014 12:47 PM
To: Georgoulias, Bethany; Bennett, Bradley
Subject: FW: Dominion Power's Rosemary Station
Well, here's my summary history from two years ago, but that doesn't locate the file for us.
kbp
Ken Pickle
Environmental Engineer
NCDENR I DEMLR I Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken. [e-mail]
Website: htto:Jlyortal.ncdenr.4rn/webLlr/stormwater
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations."
From: Pickle, Ken
Sent: Tuesday, March 06, 2012 5:52 PM
To: Jones, Jennifer; Georgoulias, Bethany
Cc: Bennett, Bradley
Subject: Dominion Power's Rosemary Station
OK then, here's the scoop on Dominion Power's Rosemary gas turbine station,
Current status:
• Active wastewater permit NCO079014 for the release of secondary containment fluids around a fuel oil storage
tank in excess of 1.MG capacity;
• Stormwater permit NCS000197 rescinded by KBP upon request in February 2007:
• According to their website today, they are a combined cycle natural gas turbine facility producing electricity and
industrial steam. Aerial photos on the website show a large fuel ail storage tank, presumably the one on which
NCO079014 is based, so in excess of 11VIG.
• So, they are a gas turbine facility. And they are a combined -cycle facility. And they are a dual -fuel facility. And
they are a cogeneration facility.
• Today's interpretation: per presumed NC criteria: electricRower? Yes; steam? Yes => DWQ stormwater permit
required.
• Today's interpretation: per MSGP criteria: electric sower? Yes: steam? Yes: gas turbine? Yes: auxiliary fuel? Yes
—fuel oil => MSGP would be required if located in one of EPA's states.
File history:

.t
• NCS000197 first issued to Panda Rosemary Limited Partnership and effective on October 1,1994. Discharging to
the MS4 of Roanoke Rapids and then to the Roanoke River, a class C stream. Annual monitoring of pH, O&G, Pb,
TSS, MBAS for VMA only, with cutoff concentrations.
• Reissued effective October 1, 1999. Quarterly monitoring in the fourth year for pH, O&G, TSS for VMA only,
without numerical constraints. Renewal site plan shows two gas turbines and a steam turbine.
• February 2005 Name/Ownership change to Virginia Electric and Power Company.
• February 2005 Myrl and BG inspect; no violations, not much to inspect.
• Reissued to Virginia Electric and Power Company effective June 1, 2005. Semi-annual monitoring for pH, O&G,
TSS for VMA only, with benchmarks.
• October 2006 — December 2006 email exchanges with SPU and NPDES from Dominion Power (new owner).
o October email: Dominion asserts that they are a 'heat captured cogeneration facility', and requests
termination of both the NCS stormwater permit, and the NC permit which covers stormwater within the
secondary containment area.
o They cite the 1995 MSGP and the 1995 Preamble in the Federal Register announcing the MSGP, both as
excluding 'heat captured cogeneration facilities' from the definition of storm water discharges
associated with industrial activity, and therefore not subject to regulation by stormwater permit.
o They cite the 2000 Federal Register notice for the next version of the MSGP, and note that it provides
that heat capture cogeneration facilities are not covered by the MSGP for stormwater discharges
associated with industrial activity from Steam Electric Power Generating facilities.
o They report that the same language is also included in the Proposed 2006 MSGP.
o SO: mid -stream summary — Dominion has cited the EPAs MSGP to exclude them from regulation - - but
they didn't cite the rules, or the Federal Register Preamble to the rules. This is the difficulty that we
became aware of over the last couple of days — EPA is not fully following their own rules in the MSGP.
o December 2006: Myrl in RRO comments that both permits could be rescinded based on his site visits
and his understanding of the federal regulations.
• February 2007 rescission of NCS000197. RIMS notation by KBP: "Permit rescinded upon request and concurrence by
RRO. Heat recovery co -generation facilities are specifically excluded from coverage under stormwater NPDES permits. Virginia
Electric staff specifically report the facility Is eligible for this exclusion. Concurrent request to rescind NC permit has today been
rejected by NPDES East Unit."
• February 2007 same day, NPDES Unit denies request to rescind NC0079014.
My interpretation today. and anv determination to act at Rosemarv. would be based on the followine considerations:
• It looks like I was not aware of the possibility of a disconnect between (the governing rule at 40CFR and its
associated FR Preamble) vs. (EPA's several MSGPs and their FR Preambles), and that I mistook the provisions of
the MSGP as having the authority of federal rule. I think our analysis this week is more developed and more on
point, although we would still differ from EPA in implementation at some sites (but not at this site! At this site
we would both require a permit based on industry categorization, and current 2008 MSGP.)
• Note that RRO had been to the site, and apparently concluded that there was not much risk of surface water
impacts. This input from RRO should be given some weight.
• A corollary to RRO's input is that we made the decision to rescind, which possibly might be considered to have
set a precedent — they already have one NPDES permit for the secondary containment discharges through the
oil/water separator (which permit Myrl also recommended we rescind.)
• Note that the 2008 MSGP and its Fact Sheet does away with the specific category that Dominion claimed for
exclusion, the 'heat captured cogeneration facilities', citing that wording as leading to much confusion, and
regarded as obsolete. This category has been removed from the MSGP and the Fact Sheet. It never was in the
rule or the FR Preamble to the rule.
I would not want my action at Rosemary to serve as any sort of precedent on rules interpretation for this
industry going forward. I made a mistake under confusing circumstances, and EPA has all but said they made a
mistake. Is it time to rectify? Or is it time to let it lie?
As far as rectifying now: We all know rules change. We could ask Rosemary to apply for a permit, or re -justify
their request for no permit, when current federal rule seems to indicate they should be permitted.

• As far as letting it lie: If another RRO and SPU inspection suggests that the NC permit has got it under control,
maybe we just call this a learning experience.
As far as Rosema�r r serving as any sort of precedent: Whether we„rectify the error at Rosemary or not. I think we know
enough now to be very comfortable knowing that Rosemary should not influence our decisions going forward in this
industry.
KBP
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: ken, [e-mail]
Website: htto://portal.ncdenr.ora/web/wa(ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**

Edward H. Hain
Vice President - Fossil & Hydro System Operations
Dominion Generation
An oprraing ugmenr of
Dominion Resources, Inc.
innsbrook Technical Center
5000 Dominion Boulevard, Glen Allen, VA 23060
dom,com
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
January 22, 2014
Ms. Greta C, Glover
Pretreatment Coordinator
Waste Water Treatment Plant
135 Aqueduct Rd.
Weldon, NC 27890
;,f Dominion®
N �s 000 ,h5 7
Re; Derninion » Rosemary Power &ntion — ES Permit 40 CFR 122.22 - Authorized
i natories
Dear Ms. Glover:
1n accordance with the NPDES Permit Regulation 40 CFR 122.22 and in addition to the officers
referenced in the regulation, the persons in the following positions are authorized to sign correspondence,
reports, and other documents required by the industrial Use Permit (#007) / NPDES permit:
Director, Power Generation Station
Director, Power Generation Operations w
Manager, Power Generation Operations & Maintenance (O&M)
Plant Manager JA N 2 7 201
Plant Operations / Maintenance (O&M) Supervisor
Technical Consultant ' wds1tJAr iJAZITY
Director, Electric Environmental Services ester Branq,
Manager, Electric Environmental Services
Should you desire additional information or have any questions, please contact Rick Woolard, of
Dominion's Electric Environmental Services, at [phone].
[ 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 orpersons 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
penalties for submitting false information, including the possibility of fine and imprisonment for knowing
violations.
Edward H. Baine
Name of Authorized Agent
Signature of Authorized Agent
Vice President
Power Generation System Operations
Title
Date

Ms, Glover
January 22, 2014
Page 2
cc: Ms. Bethany Georgoulias
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617