NCS000349_Email_20180913

Lawyer, Mike
From: Bennett, Bradley
Sent: Thursday, September 13, 2018 9:20 PM
To: Lawyer, Mike
Subject: Fw: Re:[External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
Attachments: Lumberton Site Plan.pdf, Revised Contact List.pdf
Hey Mike,
Let me know what you think about the information provided. I know you won't be getting to this for awhile
given how the storm looks right now. I hope you guys make it through okay. We are thinking about you.
Below are a few thoughts after looking at the information on things that may be worth looking at with the site
visit.
• They indicate that they have not sampled new outfall 009 because they are still under construction in
that area and under NCGO1. Since they have industrial activity under way in the drainage are I think
this outfall needs to be monitoring and should start when the new permit is regardless of
whether construction is complete or not. The should be meeting the conditions of both the NCS and
NCGO1 permits.
• Probably need to investigate the material that falls off the conveyors and accumulates between the
two storage buildings. It appears from the response that they only clean it up monthly.
• Looking at the drainage and outfall locations it might be reasonable to figure out if there is an outfall
that should be monitored to specifically assess the potential impact from this material being on the
ground. r-��'s; p� r✓/ k* wns�+a r? it �
• Its not really clear to me how the bottom ash material is stored. Is it covered in some way or is it out in
the open? If out then is there a specific outfall that could assess the impact of this area?
• Seems the response about the material that had to be removed a few years ago indicates they didn't
meet the time frames set. Looks like the are working with DWM on this but is the process on track
now?
• There are a number of catch basins noted on the plan put the plan doesn't indicate which outfalls
these drain to.
Again, hope things go okay for you guys during the storm.
Thanks ,, s9
BB
Bradley Bennett Note New Office Phone wig/
Stormwater Program Phone: [phone] rti
NC Division of Energy, Mineral&Land Resources Fax: [phone] /S
1612 (a Mail Service Center Email:brad ley.bennett .ncdenr,gov
Raleigh,NC 27699-1612 �u I
Email correspondence to and from this address may be subject to public records laws
1 Y"` , _ y

From: Leona Miles<[e-mail]>
Sent:Thursday, September 13, 2018 11:32 AM
To: Bennett, Bradley; Lawyer, Mike
Cc: 'Dan Sherman'; 'Rick Houser'; 'Mark Fowler GRP'; 'Art Picken'
Subject: Re:[External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
CAUTION: s. not click links or open attachments unless verified.Send all suspicious email as an attachment to
Hello Bradley and Mike:
Below please find responses to questions you raised regarding the North Carolina Renewable Power,
Lumberton LLC facility and stormwater permit renewal application. I hope this information is helpful as an
initial start to the renewal process. We can discuss any additional questions once we meet at the site in the
near future.
In addition, there was a question regarding aboveground black piping observed on a Google Earth aerial. The
Black Pipes on the West side of the Waste Water Treatment Plant as shown on the Google Earth Aerial are the
hot water feed and recovery pipes to and from the belt dryers.
Also provided are an updated site figure and facility contact list.
hope you are both safe and ready for Florence. Take care.
Thank you,
Leona
Leo�Mae�s,, C 9 M M
Senior Project Manager
Atlanta Environmental Management, Inc.
2580 Northeast Expressway, NE
Atlanta, Georgia 30345
Office: [phone]
Cell: [phone]
[e-mail]
www.AEM-net.com
"PmvM Smtct..
'rU,rn�l�Cap.e4rsesa rrp.+�nr.�ia."
2

From: Bennett, Bradley<[e-mail]>
Sent: Wednesday, August 22, 2018 11:36 AM
To: Leona Miles <[e-mail]>
Cc: [e-mail]; Mark Fowler GRP <[e-mail]>;
[e-mail]; Lawyer, Mike<[e-mail]>
Subject: RE: [External] RE: Permit Renewal for NCS000349 Stromwater NPDES Permit
Leona,
Thanks to you and Art for talking with us yesterday about the Lumberton facility. The information you
provided was very helpful in our process. I just wanted to touch base after the call to make sure we are on
track with the things discussed and that we outline some things that we know we might need. Please correct
anything that isn't accurate and let me know about the process you see moving forward to get the information
we might need.
• The facility has changed from a coal fired plant and the fuel used now is a combination of
wood/biomass chips and poultry litter. Yes, this plant no longer uses coal. The fuel source mixture is
approximately 70%wood and 30% poultry litter.
• All coal products and materials (ash, etc.) have been removed from the site. The former coal piles and
coal ash were removed from the site in 2016 and are no longer present.
• Facility is still following the same process otherwise—steam electric power generation. The facility still
produces steam electric power.
• The facility purchased additional land and expanded north of the previous site boundary. This area
now contains the wood/biomass that is brought in, wood chipping operation, driers, conveyors for the
wood chips, storage barn for dried chips and other equipment. This area all drains to a new pond that
was constructed with the expansion. Please see the attached figure which shows the stormwater flow
to all outfalls at the Plant, including the new outfall (Outfall #9). There is a new outfall (#9)from the
pond. In this northern area of the property there was an area in the Google views that showed storage
of a black material, some covered with a blue tarp. Could you please provide information on what this
storage is and what material is there. The material seen beneath the "blue tarp" in the 2017 google
earth aerial was a one time storage of wood ash from facility operations. The material was placed
there following a temporary shutdown. The material was removed and disposed offsite to Craven AG
Services, Carolina Gypsum, or Sampson County Landfill.
• It would be helpful to have a new site map that shows the expanded area, gives information on the
material on the site, locates all outfalls and gives drainage boundaries for the outfalls. It is likely that
we will need to re-evaluate the representative outfall status as we get a better understanding of the
outfalls and drainage areas, etc. This will be handled as part of the site visit conducted by our
Fayetteville Regional Office. Please see the attached figure showing the overall site drainage and
stormwater outfalls.
• Poultry litter is brought in and stored in the storage building that was previously onsite (near the NE
part of the ditch that divides the old and new property). Wood chips go from storage after drying to
warehouse (built over the old coal storage) near the wastewater basins. Wood goes from here on
conveyor and mixes with poultry litter and mixture goes to the facility as fuel for the process. There is
an accumulation of material (wood and poultry litter) that falls off the conveyor between the two
buildings near the ditch. This material is collected and put back into the process. It would help to
3

r
know how long material stays on the ground here, etc. Veolia, the facility manager, has a monthly PM
schedule in place to clean up the fines or large wood debris.
• In the southeastern section of the facility by the plant there is a silo that collects the ash produced in
the process. The ash is removed from the site by truck on a daily basis. Is any ash stored anywhere
else on site? It seems that there is a good bit of ash produced and the one silo seems small for this
collection? Could you provide information on where the ash material is taken?The wood as is 5a
transported to Craven AG Services, Carolina Gypsum, or Sampson County Landfill. T fly as isoMt
currently stored in a silo and has several trucks removing the product on a daily basis o om as s
emptied into a concrete containment via the submerged and incline drag chains located on t e north
side of the power house.
• In the past few years there were some issues with ash material stored on site and material was
removed to offsite locations. Mike asked about this process and if all that material had been removed
from that site and taken care of. There was an August 1, 2018 date given in the past for completion of
this process. The Pembroke facility no longer receives the wood ash from the Lumberton facility. The
wood ash is disposed offsite to Craven AG Services, Carolina Gypsum, or Sampson County
Landfill. North Carolina Renewable Power, Lumberton LLC(NCRP-Lumberton) is in the process of
conducting additional cleanup of soil from previous stormwater runoff. This effort is anticipated to be
completed by end of the year. NCRP-Lumberton is working with Mr. Andrew Hammonds, NCDENR, to
complete this effort.
• If there has been any monitoring data collected from Outfall 9 (discharge from the pond) can you
please provide the results of that monitoring. There has been no data collected to date from Outfall 9
as this portion of the facility is still under construction and monitored by the Stormwater Construction
Permit. Visual observations are made as part of the construction/ground disturbing storm water
permit that was issued.
• As we go through our review it is possible that monitoring locations may change with the changes on
site and the addition of the pond and new discharge for the northern portion of the site. We will also
look at the activities now on site and consider needed adjustments in the monitoring parameters given
the changes. This may eliminate some parameters and add others. This is understood.
• 1 think there may be some ongoing questions about the facility name (Georgia vs NC Renewable
Power). We will need to have that worked out so we know the correct entity for issuance of the
permit. We will have to have an owner that is a registered NC Corporation. The owner and operator
of the property is North Carolina Renewable Power, Lumberton LLC. Georgia Renewable Power is the
parent company. Veolia is the current 0&M Company that is in charge of the daily operations and
maintenance of the Plant.
• I have also attached the owner/Facility contact information that we have in our database. Please
review that and make any updates/corrections needed and tell us any contacts that need to be
removed. A revised contact list is attached.
Hopefully I captured everything here. Mike—please add anything I missed. I tried to underline the things that
involve information we may need from you guys.
Thanks again for your help!
BB
From: Leona Miles [mailto:[e-mail]]
Sent: Monday, August 20, 2018 10:45 AM
4

NC Division of Energy, Mineral and Land Resources
NPDES Stormwater Permit Contacts Summary
NC DEMLR_has the followine contact information in our Permit Database for Your permit as of 61412018.
Permit Number: NCS000349
Permit Type: Stormwater Discharge,individual
Facility Name: firth CarOina Renewable Power Lumberton.LLC
Facility Addressi: 1866 Hestertown Rd
Facility Address2:
City,State&Zip: Lumberton,NC 28358
Owner Information Details:
' MUST submit a Change ofNatne/Ownershlpform to DEMLR to make any changes to this Owner informaition
(Click Here for"Chance of Name/ownershfu"Form)
Owner Name: North Carolina Renewable Power-L m on LLC
Owner Type: Non-Government Owner Type Group: Organization
low ***Legally Responsible for Permit***
(Responsible corporate officer/principle executive officer or ranking elected official/general partner or proprietor;
or any other person wE horlty from the legalty responsible person.)
Owner Affiliation: Carey Davis Title:
Address].: ^`"+tea 2100 Southbridge Pkwy, Suite 540 Executive Vice President
Address2:
City,Stage&Zip: Birmingham.AL 35ii7 35209
Work Phone: [phone] Fax: [phone]
Email Address: [e-mail]
*** Permit Annual Fee Billing**
Billing Month: April
Invoice Number Invoice Date Invoice Due Date Invoice Amount Invoice Status
Owner Contact Persons)
Contact Name Ti le Address Phone Fax Email
Facility; R' 'L ,
Contact Name Address Phone Fax Emai
Ciaran McManus, O&M Manager 1866 Hestertown Road, Lumberton NC 28358 964-218-6300 cmcmanusCVgeorgiarenewablepower.cam
ontal
Contact Name Title Address pig E" EMIR
Carey Davis,Executive Vice President 2100 Southbridge Pkwy, Suite 540 205-403-5273 cdavisCcDgeorgiarenewablepower.com
Contact Name Z,fg Address Phone Fax Email
Carey Davis.Executive Vice President 2100 Southbridge Pkwy, Suite 540 205-403-5273 [e-mail]
6192+u;; Page 1

/ \ Undeveloped
/ \ Undeveloped
Raw Biomass(Wood Chip) \ \\r c}c
` \ Processing Area \ c
�o
\ \ \ \ \\\ Residential
yi1► .l \
1 I \ \ \
a o
I � \
I
I II = Dry Wood Storage /®�\
UMw
I I I
I 1II Lmw-z
Undeveloped 1
Alamac Waste WaterTrcatmTlt Buildin i Q E`o /
Property 1 Waite Water Pond POULTRY
- LITTER / I
I II STORAGE /
I 111 BUILDING / (
0 ® /
Approximate Area of Former
DuVag ft / — — —— — — — —
Bulk Caustic/Acid Unloading
�
1 I office �h
11'I Traikrs—Nys7-�-I1Lryr11--I111 B°tt°
I it U 1 1 O Store e L I .ee/a(z�{A,ll/MVJ
I I I I I torage IJ FQ mm LJCC
I 1 wldinLs Boiler/ urbin<n.e
I I I Buil i o
Substation
I M H Undeveloped
I I . aWS a Bag House a I I
1 © WLhnlw- ® Stack
I I Fire K Q I
otection
I Building ® ® I
I
1 Cooling Towem Treatment Building I 1
Ovttall a3 Former Cha.oid Storage Tank our all La- O.tfdl 05
_--w-----
LEGEND t
-Approximate Fenced Site Boundary ®-Diesel ASTS 0-Lime Silo(Empty) ®-Cooling Tower Transfer Pumps Atl Site Location:North Carolina Renewable Power Lumberton,LLC
anta Environmental Management R-Surtace Water Flow DireDirection ©-450,000 Gallon Water Tanks 0-Waste Oil Tank(B Inc. 1866 Hestertownoad Waste Storage Area Scale "rvYiini41i"'•°'""^'"'"""^"r"""'^' Lumberton,North Carolina 28358
---+----Water Line ©-Cooling Tower Q-Chemical/Drum Storage o so 100 zS10 Xp"^"*'r'^^""w•"�°""•e.ers.amu
e ...:.a an.,aaa.r:ea 3 r
-Dumpster Q Conveyor Q-Bottom Ash Silo(Not in Use) eaOntrli: isor-TLI pvt: sepmwberzz,mza Figure
-Pole-Mounted Transformer tuah metro n. Subject Property m Waste Neutralization Tank Q-Fly Ash Silo oaxwu sr: n atwsEo: — 1 P rtY Sketch
• -Catch Basin Q-Condensate Tank Q-Ammonia AST fgNECTMGR: us nuetEo:s/tz/zov sea M ;tDwaNsm-wst,,,,y.m„uwrna,r„r

-- - - - - VEOLIA
Tim Cotner
pPantManager
MUNICIPAL&COMMERCIAL BUSINESS
Veolia North America
NCRP-Lumberton,I866 Hestertown Rd.•Lumberton,NC 28358
tel+I 9I0 887 6323
cell+I 9I 0 426 4341
tim.cotner(alveolia.com
www.veolianorthamerica com
bo
C
C [
a+
ro
Id
b
b Leona A. Miles, CHMM
r Senior Project Manager
z580 Northeast Expressway Voice:(404)329-90o6
Atlanta,Georgia 30345 Fax:(404)329_2057
W www.aem-net.com Celle(404)395 b9r3
r Email:[e-mail]
Environmental Consulting,Engineering,Hydrogeologic Services
I �
c �
v
n�a
2 Arthur W. Picken, P.E.
Senior Project Manager — - -
E
c i 258a Northeast Expressway Voice:(404)329-9oo6
Atlanta,Georgia 30345 Fax:[phone]
www.aem-net.com Cell:[phone]
Email:[e-mail]
a Environmental Consulting,Engineering,Hydrogeologic Services