NCS000349_Renewal application_20060912

Elizabethtown/Lumberton Power, LLC _
P.O. Box 1899 P.O. Box 1063
3100 West Broad Street 1866 Hestertown Road
Elizabethtown,N.C.28337-1899 Luutberton, N.C.28359
(910)-862-2698 (910)-738-8742
Fax[phone] Fax[phone]
September 12, 2006
Mr. Mike Randall
Stormwater and General Permits Unit
1617 Mail Service Center
Raleigh, N.C. 27699-1617
SUBJECT: NPDES Stormwater Permit Renewal
Lumberton Power,LLC
Permit Number-NCS000349
Robeson County
Dear Mr. Randall,
Please find enclosed the requested information and forms for Lumberton
Power,LLC'S Stormwater Permit Renewal. Permit number NCS000349. 1f you have any
questions or comments please feel free to contact me at (910)-738-8742 ext 21 or by e-mail
at rhousergengeneration.com.
Sincerely,
C X
Rick Houser
Plant Manager
Lumberton Power,LL � '
EHS File 1.8.2 �`

AoF W a rF9QG Michael F.Easley,Governor
William G.Ross Jr.,Secretary
A p North Carolina Department of Environment and Natural Resources
Alan W.Klimek,P.E.Director
Division of Water Quality
September 5,2006
LUMBERTON POWER LLC
ATTN: RON VARNADOE,OR SUCCESSOR
PO BOX 1063
LUMBERTON, NC 28359
Subject: NPDES Stormwater Permit Renewal
Lumberton Power LLC
Permit Number NCS000349
Robeson County
Dear Permittee:
Your facility is currently covered for stormwater discharge under NPDES Permit NCS000349. This permit expires
on April 30,2007. North Carolina Administrative Code(15A NCAC 2H.0105(e))requires that an application for
permit renewal be filed at least 180 days prior to expiration of the current permit. In order to assure your continued
coverage under your permit,you must apply to the Division of Water Quality(DWQ)for renewal of your permit.
To make this renewal process easier,we are informing you in advance that your permit will be expiring. Enclosed
you will find an individual permit renewal application form,supplemental information request,and Stormwater
Pollution Prevention Plan certification.
Filing the application form along with the requested supplemental information will constitute your application for
renewal of your permit. As stated above,the application form must be completed and returned along with all
requested information by in order for the permit to be renewed by April 30,2007.
Failure to request renewal by may result in a civil assessment of at least$500.00. Larger penalties may be
assessed depending on the delinquency of the request. Discharge of stormwater from your facility without
coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and could
result in assessments of civil penalties of up to $25,000 per day.
If you have any questions regarding the permit renewal procedures please contact Mike Randall of the Stormwater
Permitting Unit at(919)733-5083,ext. 545.
Sincerely,
Bradley Bennett,Supervisor
Stormwater Permitting Unit
cc: Central Files
Stormwater Permitting Unit Files
Fayetteville Regional Office
NamN`h Carolina
aturally
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh,NC 27699-1617 Phone[phone] Customer Service
Internet: www.newaterqualitv.org Location: 512 N.Salisbury St. Raleigh,NC 27604 Fax [phone]
An Equal OpportunitylAf4irmative Action Employer—50%Recycled110%Post Consumer Paper

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
N.0 Division of Water- Quality, Stormwater and General Permits Unit
Facility Name: LUMBERTON POWER LLC
Permit Number: NCS000349
Location Address: NCSR 2202
LUMBERTON,NC 28358
County: ROBESON
"I certify,under penalty of law,that the Stormwater Pollution Prevention Plan(SPPP)document and all attachments
were developed and implemented under my direction or supervision in accordance with a system designed to assure
that qualified personnel properly gather and evaluate the information required by the SPPP. Based on my inquiry of
the person or persons who manage the system, or those persons directly responsible for gathering the information,
the information gathered is,to the best of my knowledge and belief,true,accurate,and complete"
"I certify that the SPPP has been developed,signed and retained at the facility location and the SPPP has been fully
implemented at the named facility location in accordance with the terms and conditions of the stormwater general
permit."
"I am aware that there are significant penalties for falsifying information,including the possibility of fines and
imprisonment for knowing violations"
Sign (according to permit signatory requirements) and return this Certification. DO NOT SEND THE
STORMWATER POLLUTION PREVENTION PLAN WITH THE CERTIFICATION.
Signature Date 6�
Print�or type name of person signing above 'Title
SPPP Certification 2/99

o�oF wnrFR4c PERMIT COVERAGE
Y RENEWAL APPLICATION FORM Permit Number
National Pollutant Discharge Elimination System NCS000349
Stormwater Discharge Permit
THIS APPLICATION MUST BE SIGNED AND RETURNED ALONG WITH THE REQUESTED SUPPLEMENTAL
INFORMATION TO THE DIV.OF WATER QUALITY IN ORDER FOR YOUR FACILITY TO QUALIFY FOR
RENEWAL OF YOUR STORMWATER PERMIT NCS000349
The following is the information currently in our database for your facility. Please review this information carefully
and make all corrections as necessary in the space provided to the right of the current information.
OWNER INFORMATION
Owner/Org.Name; NORTH CAROLINA POWER HOLDINGS LLC lVe—,04 &e_c
Owner Contact: c lc y_ w CLAM "&
Mailing Address: p.0 (.3 _
Phone Number;
Fax Number
E-mail address:
FACILITY INFORMATION
Facility Name: LUMBERTON POWER LLC Ly, ,. LLC-
Facility Contact: l g(.�- FP-AS
Facility Address: NCSR 2202 C_ s2es 36-I$
LUMBERTON, NC 28358
Phone Number:
Fax Number
E-mail address: 1 rs -- 1 6 — asug, yC
PERMIT INFORMATION O n'
Permit Contact: RON VARNADOE RSC.K. er
Mailing Address: PO BOX 1063 r bto
LUMBERTON, NC 28359 L_ AJ16,fy&�Srl
Phone Number: 9107388742 9 t6 7 6 8 - �4 -
Fax Number: q .6-- -Z3 S --
E-mail address: k—b6-u.sC4,' le
DISCHARGE INFORMATION f � � r�
Discharge Receiving Water: i.i t IVt��r R"'Irr­
Stream Class: [ s
Basin: L.l crw'�Ci crier 804Sih
Sub-Basin#:
Number of outfalls:
CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the best of my knowledge and
belief such information is true,complete and accurate.
Signatur �'__C Date - S er6
Print or type name of person signing above Title
Please return this completed renewal application form to:
Individual Permit Renewal
Attn:Mr.Mike Randall
Stormwater and General Permits Unit
1617 Mail Service Center
Raleigh,North Carolina 27699-1617

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SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL NPDES
STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application to be
considered complete:
(Do not submit the site Stormwater Pollution Prevention Plan)
Initials
1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities(including storage of materials,disposal areas,process areas and
loading and unloading areas),drainage structures,drainage areas for each outfall,building
locations and impervious surfaces should be clearly noted.
-P-k 2. A summary of Analytical Monitoring results during the term of the existing permit(if your
permit required analytical sampling). Do not submit individual lab reports. The summary
can consist of a table including such items as outfall number,parameters sampled,lab
results,date sampled, and storm event data. *
3. A summary of the Visual Monitoring results. Do not submit individual monitoring reports.
The summary can consist of a table including such items as outfall number,parameters
surveyed,observations,and date monitoring conducted.
4. A summary of the Best Management Practices utilized at the permitted facility. Summary
should consist of a short narrative description of each BMP's in place at the facility. If the
implementation of any BMP's is planned,please include information on these BMP's.
5. A short narrative describing any significant changes in industrial activities at the permitted
facility. Significant changes could include the addition or deletion of work processes,
changes in material handling practices,changes in material storage practices,and/or
changes in the raw materials used by the facility.
b. Certification of the development and implementation of a Stormwater Pollution Prevention
Plan for the permitted facility(Sign and return attached form).
* If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal,then the last years monitoring results should be
submitted within 30 days of receipt of the laboratory reports. (i.e.do not withhold renewal
submittal waiting on lab results)
Representative storm sampling may now be conducted anytime during the year(the April to
November window has been eliminated) and the representative rainfall event is now
defined as a storm event that measures greater than 0.1 inches and is preceded by at least 72
hours in which no storm event measuring greater than 0.1 inches has occurred.

Permit No.NCS000349
SECTION B: ANALYTICAL MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the
permittee is authorized to discharge stormwater subject to the provisions of this permit.
Analytical monitoring of stormwater discharges shall be performed as specified below in Table
1.
All analytical monitoring shall be performed during a representative storm event. The required
monitoring will result in a minimum of 7 analytical samplings being conducted over the term of
the permit at each stormwater discharge outfall (SDO). The permittee shall complete the
minimum 7 analytical samplings in accordance with the schedule specified below in Table 2.
JTable 1. Analytical Monitoring Requirements
Discharge Measurement Frequencyl Sample Sample
Characteristics Units Type2 Location3
Total Suspended Solids mg/l Annually year 1,2,3 Grab Outfall 5
Quarterly year 4
Chemical Oxygen Demand mg/l Annually year 1,2,3 Grab Outfall 5
Quarterly year 4
Total Rainfa114 inches Annually year 1,2,3
Quarterly year 4
Event Duration4 minutes Annually year 1,2,3 _
Quarterly year 4
Total Flow4 MG Annually year 1,2,3 _ Outfall 5
Quarterly year 4
Footnotes:
1 Measurement Frequency: Once per year during years 1,2,and 3 of the permit tern. Each quarter during the 4t'
year of the permit term. A year is defined as the 12 month period beginning on the month and day of issuance of
the Permit.See Table 2 for schedule of monitoring periods.
2 If the stormwater runoff is controlled by a stormwater detention pond,a grab sample of the discharge from the
pond shall be collected within the first 30 minutes of discharge. If the detention pond discharges only in response
to a storm event exceeding a ten year design storm,then no analytical monitoring is required and only qualitative
monitoring shall be performed.
3 Sample Location: Samples shall be collected at each stormwater discharge outfall (SDO) unless representative
outfall status has been granted. In the case of this permit,outfall 5 has been determined to be the outfall to be
sampled as representative.
4 For each sampled representative storm event the total precipitation,storm duration,and total flow must be
monitored. Total flow shall be either; (a)measured continuously,(b)calculated based on the amount of area
draining to the outfall,the amount of built-upon (impervious)area,and the total amount of rainfall,or(c)
estimated by the measurement of flow at 20 minute intervals during the rainfall event.
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Part II Page 4 of 6

Permit No.NCS000349
• Table 2 Monitoring schedule
Monitoring period Sample Number Start End
Year 1 1 May 1, 2002 April 30, 2003
Year 2 2 May 1, 2003 April 30, 2004
Year 3 3 May 1, 2004 April 30, 2005
Year 4 - I"quarter 4 May 1,2005 July 31, 2005
Year 4 - 2rtd quarter 5 August 1, 2005 October 31, 2005
Year 4 -3`d quarter 6 November 1, 2005 January 31, 2006
Year 4 - 4`"quarter 7 February 1, 2006 April 30, 2006
SECTION C: QUALITATIVE MONITORING REQUIREMENTS
Qualitative monitoring requires a visual inspection of each stormwater outfall regardless of
representative outfall status and shall be performed as specified below in Table 3. Qualitative
monitoring is for the purpose of evaluating the effectiveness of the Stormwater Pollution
Prevention Plan (SPPP) and assessing new sources of stormwater pollution. No analytical tests
are required. Qualitative monitoring of stormwater outfalls does not need to be performed during
a representative stone event.
In the event an atypical condition is noted at a stormwater discharge outfall, the Permittee shall
document the suspected cause of the condition and any actions taken in response to the
discovery. This documentation will be maintained with the Stormwater Pollution Prevention
Plan.
All qualitative monitoring will be performed twice per year, once in the spring (April - June) and
once in the fall (September- November).
✓ Table 3. Qualitative Monitoring Requirements
Discharge Characteristics Frequency Monitoring
Locations
Color Semi-Annual SDO
Odor Semi-Annual SDO
Clarity Semi-Annual SDO
Floating Solids Semi-Annual SDO
Suspended Solids Semi-Annual SDO
Foam Semi-Annual SDO
Oil Sheen Semi-Annual SDO
Other obvious indicators Semi-Annual SDO
of stormwater pollution
Part II Page 5 of 6

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LUMBERTON Plant
Combined SPCC Plan and P3 Inspections
Date of Inspection: Inspection By:
Description Vessel Condition of Housekeeping Comments (indicate Work
Condition Containment/ Order#if applicable)
Valve
Good Good Good
Work Work
k Work Needed Needed Needed
Oil Storage Room
Front End Loader Diesel
Tank
Fire Pump Diesel Storage
Tank
Main Transformer Yard
Used Oil Tank
...........
Electric Fire Pump
Transformer
Turbine Oil Filter System and
EHC Sump
Transformer Storage Area
(Warehouse)
Oil Trap Pit
Acid and Caustic Unloading
Ash Handling including silt N/A N/A
fences, catch basins with
grated inlet
Coal Pile Handling and N/A N/A
Conveyor System: coal pile
runoff collected m' V-ditch,
conveyed to wastewater
treatment system
Cooling Tower Chemical
Storage
Railcar Unloading Area N/A N/A
including silt fences and catch
basin with grated inlets
Waste Neutralization Tank
Drum Storage Area
Storm Water Management N/A N/A
System includes silt fences,
grass-lined swales,grated
catch basin inlets
File a copy of completed inspection forms in the appropriate SPCC and F3 binder appendices.
Version: 7/12/99

ANALYTICAL MONITORING RESULTS PERMIT#NCSOCOU9
LUMBERTON POWER
DATE YEAR QUARTER 24hr MGD Ph TSS COD
3/28/2005 3 ANN. 0.08 5.71 19.5 28
5/6/2005 4 1 0.076 5.69 6 33.9
8/23/2005 4 2 0.1154 6.78 14 48
11/28/2005 4 3 0.095 6.8 29 21.9
2/7/2006 4 4 0.033 4.7 5.5 41.5
5/8/2006 5 1 0.168 4.9 7.3 21

QUALITATIVE MONITORING RESULTS PERMITS NCSMU9
LUMBERTON POWER
DATE YEAR QUARTER l�1TFALL COLOR ODOR CLARITY FLOATING SOURS SUSPENDED SOWDS FOAM OIL SHEEN
3128/2008 3 ANN. 5 LT.GREY NONE 2 1 2 NO NO
51612Q05 4 1 5 LT.TAN NONE 3 2 3 NO NO
8123MIM 4 2 5 LT.GREY NONE 3 2 3 NO NO
11/28/2005 4 3 5 LT.GREY NONE 4 3 3 NO NO
217/2006 4 4 5 LT.TAN NONE 3 3 2 NO NO
518/2006 5 1 5 LT.GREY NONE 2 2 1 NO NO

Elizabethtown/Lumberton Power, LLC
P.O. Box 1899 P.O.Box 1063
3100 West Broad Street 1866 Hestertown Road
Elizabethtown,N.C.28337-1899 Lumberton,N.C.28359
(910)-862-2698 (910)-738-8742
Fax(910r862-2919 Fax[phone]
September 11,2006
#5 SIGNIFICANT CHANGES IN INDUSTRIAL ACTIVITIES
There have been NO changes in industrial activities at the Lumberton Power
Facility.
Rick Houser
Plant Manager
Lumberton Power,LLC

BMP ' S

4.0
BMP IDENTIFICATION
Based upon an assessment of the Lumberton Power facilities potential for
contaminating storm water runoff due to material exposure,the following sections
describe best management practices(BMPs),both structural and non-structural,
which are in place to insure the potential for contamination is minimized. Table 2
presents a summary of existing structural and non-structural BMWs at the facility.
4.1 Technical and Economic Feasibility Evaluation
This section evaluates the technical and economic feasibility of changing the methods
and/or storage practices at the facility to eliminate or reduce exposure of materials
and processes to storm water.
The facility currently has minimal areas that have the potential to pollute storm water,
as described in Section 3.6. The BMPs identified in the following sections are
sufficient to control potential storm water pollution. Additional control in thses areas
are not warranted due to the structural and non-structural BMPs currently employed
at the facility.
4.2 Good Housekeeping
Good housekeeping maintenance of the facility is the responsibility of all plant
personnel. Good housekeeping procedures implemented at the Lumberton Power
facility include the following:
• General policing of plant grounds and equipment areas to maintain a safe and
trash-free environment.
• Routine inspections of exposed plant equipment for leaks or conditions that could
lead to discharges of chemicals or petroleum products.
• Proper inventory control procedures to insure that stored chemical and petroleum
products are maintained at the minimum level necessary.
• Proper operation and maintenance of exposed plant equipment (see section 4.3 on
preventive maintenance).
• Proper material storage products to ensure materials are stored in containers
adequate for the locations, such that corrosion and deterioration of the containers
is minimized. This also includes proper labeling of all containers and maintenance

of MSDS on materials stored. These procedures are addressed fully in the
Lumberton Power Hazard Communication Plan.
r
4.3 Preventive MaintenanceNisnal Inspection
The Lumberton Power facility has a comprehensive preventive maintenance program
for all systems and equipment on the plant site. This program consists of regular
checks and inspections, routine lubrication, and vibration monitoring and analysis.
The responsibility for implementing various aspects of the program fall directly with
the various area supervisors. The overall responsibility falls to the Plant Manager,
who is also the leader of the pollution prevention team. The program includes daily,
weekly, monthly, semi-annual, and annual checks and inspections for the equipment
used at the site, including equipment and materials storage facilities have the potential
to contaminate storm water. In particular,the following items area included in routine
inspections: pipes, pumps, storage tanks, pressure vessels, pressure release valves,
material storage and handling equipment, secondary containment, catch basins, storm
sewers, and the oil trap pit.
Work orders are processed through the Plant Supervisor, who is a member of the
pollution prevention team. The inspections include examinations for leaks, corrosion,
support or foundation failure, or other forms of deterioration or leaks. Particular
attention is placed on inspecting storage containers and secondary containment for
signs of deterioration or leaks. The preventive maintenance program also includes
maintenance of a spare parts inventory, and a records system for documentation of
tests and inspections, clearance procedures, and corrective actions.
Since visual inspections are a constant part of the facility preventive maintenance
program, no specific record of each inspection will be recorded in this SP3. Incident
reports generated which have the potential to contaminate storm water runoff will be
documented in Appendix B. These incidents may include corroded drums, drums
without plugs, corroded/damaged/leaking tanks,tank support,tank drain valves,
corroded or leaking pipes or valves, leaking pumps, broken or cracked secondary
containment, etc.
Since this facility is not required to report under EPCRA, Section 313 by virtue of its
SIC code, no additional preventive maintenance inspection requirements are
applicable.
4.4 Spill Prevention and Response
Subject to the Oil Pollution Act of 1990,the Lumberton Power facility has in place
and maintains a Spill Prevention Control and Countermeasures Plan, or SPCC plan, to
address planning,response, and mitigation procedures in the event of a petroleum
product spill. Under this plan,the Plant Supervisor is the primary spill response
coordinator. The Assistant Plant Supervisor is the secondary spill response
coordinator. Included in this plan are an identification of potential oil sources and

spill areas, records of past spill events, emergency contacts and telephone numbers,
documentation procedures, and requirements for training.
r
For chemicals stored at the facility could be exposed to storm water(acid, caustic,
cooling tower treatment chemicals), both the Hazard Communication Plan and Lab
Safety Plan address spill response procedures. This includes maintenance of adequate
safety equipment, such as respirators, eye guards,protective clothing, fire
extinguisher, etc. Spill prevention is provided through a combination of employee
training, maintenance of primary and secondary containment, and visual inspections.
In addition„ materials handling and storage procedures in place are integral to a spill
prevention plan. These include labeling of storage containers, maintenance of MSD's,
placarding of materials storage areas, etc.
Particular attention should be placed on minimizing ash spills and dusting in the
vicinity of the ash silos. This will be done through training employees in the proper
procedures for unloading ash, including the dust suppression system, and good
housekeeping around the ash silo areas.
Spills which have contaminated, or have the potential to contaminate, storm water
runoff will be documented. Appendix VI of the SPCC Plan contains forms for spill
documentation, and documented spill information will be kept in Appendix II of the
SPCC Plan. This documentation will include date and time of incident, weather
conditions, duration, cause, environmental problems, response procedures, parties
notified, recommended revisions of the BMP program, operating procedures, and/or
equipment needed to prevent recurrence.
Since this facility is not required to report under EPCRA, Section 313 by virtue of its
SIC code, no additional spill prevention and response requirements are applicable.
4.5 Sediment and Erosion Control
There are no current construction activities occurring at the facility; however, during
construction activities, adequate erosion and sediment control measures are
maintained. There are no steep slopes or other areas susceptible to erosion. The open
areas of the site are either stabilized with grass or gravel, or are grated such that
erosion is not a significant problem.
4.6 Management of Runoff
Table 2 identifies specific structural BMPs on place at the Lumberton Power facility
to minimize the introduction of containments into the storm water system. These
BWs are organized by potential spill or materials storage areas previously identified.

5.0
IMPLEMENTATION/TRAINING SECTION
5.1 BMP Implementation
The BMPs previously discussed have already been implemented at the plant site. No
other BMPs have been identified which are to be implemented. The implementation
date of this Storm Water Pollution Prevention Plan is noted on the cover page of this
plan.
5.2 Semi-Annual Site Inspection/SP3 Revision
The Assistant Plant Supervisor will be responsible for conducting a semi-annual site
inspection of storm water BMPs outlined in this SP3 (Section 4.0).This site
inspection shall be informal, and should be documented in a brief narrative format,
including the date of inspection, and recorded in Appendix C. In addition, the SP3
shall be revised annually following a change in design, construction, operation, or
maintenance activity may impact the potential for pollutants to be discharged into the
storm water system.
5.3 Training
Employee training involving this SP3 plan will be conducted as a part of new
employee training. This training will include general plant procedures and guidelines
with respect to spill prevention and response, good housekeeping,and material
management practices. The SP3 plan will be available to all employees for their
inspection. In addition,the general procedures for storm water management(e.g. spill
prevention and response, good housekeeping, and material management practices)
will be reviewed with all employees annually in health and safety meetings.
The members of the pollution prevention team shall familiarize themselves with the
contents of the SP3 on an annual basis.
5.4 SP3 Certification
The SP3 document certification is located in Appendix D.

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t .
6.0
CONCLUSION
r
This SP3 has been prepared for the Lumberton Power facility in accordance with the
North Carolina Storm Water Pollution Prevention Guidance Document. Existing
BNTs at the facility include secondary containment, dusting control, oil/water
separators, preventive maintenance, good housekeeping, and spill response/control.
This plan implements certain training programs and record keeping activities
(maintenance incident reports and annual BW inspections). Several components of
this plan co-exist with environment, health, and safety procedures currently in-place
at the facility.