NCS000349_Staff report_20090828

NCS000349
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North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H.Sullins Dee Freeman
Governor Director Secretary
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Facility Name: Lumberton Energy,LLC
NPDES Permit Number: NCS000349
Facility Location: Lumberton,NC(Robeson County)
Type of Activity: ELECTRICAL POWER PLANT
SIC Code(if applicable): 4911 (Electrial Services)
Receiving Streams: See Figure 1
River Basin: Lumber River Basin,Sub-basin 03-07-51
Stream Classification: C;Sw
Proposed Permit Requirements: See attached draft permit.
Monitoring Data: See Table 1
Response Requested by(Date): August 28,2009
Central Office Staff Contact: Return to: Cory Larsen 919 807-6365
Special Issues:
Issue Rating Scale: 1 eas to 10 hard
Compliance history3
Benchmark exceedance 3
Location(TMDL,T&E
species,etc
Other Challenges: 9
• See below
Difficulty Rating: 20/40
Special Issues Explanation:
• During this permit renewal DWQ has significantly increased efforts to more closely monitor the power
plant industry to evaluate potential impacts to stormwater(see file).
Description of Onsite Activities:
• The facility is a relatively small,coal-fared, steam-electric power plant(cogeneration plant).
Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• National Heritage Program (NHP)Threatened and Endangered Species Database
• SPU File
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NCS000349
• Central Files
• EPA Sector-Specific Permit,2008,"Sector O—Steam Electric Generating Facilities"
• 303(d)List,2008 draft, 2006 final
• 2003 Lumber Basinwide Plan
History:
• April 12,2002: Date permit first issued. Analytical monitoring includes TSS and COD. Monitoring was
done annually for the first 3 years and quarterly for the 4°i year.
• September 5, 2006: Renewal permit reminder letter sent to permittee.
• September 14, 2006: Date permittee submitted renewal application
• September 18,2007: Site Inspection
• February 4, 2008: Permit writer site visit
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NCS000349
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NCS000349 Lumberton Energy, LLC
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Lab wde: 340 35' 27"N
t�' r Longitude: 780 59'48"
County: Robeson
' Receiving Stream: Lurrber River
Stream Class: C; Sw
Map Scale P20,000 Sub-basin: 03-07-51 (Lumber River Basin) Facility Location
Figure ]: Map of Facility
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NCS000349
Central Office Review Summary:
1. Owner's Other Permits:
• NCO058301 —Outfall 001 includes Flow, Oil&Grease, pH, and TSS. Outfall 002 includes Priority
Pollutant scan, chlorine, chromium, flow, and zinc. Outfall 003 includes chlorine, ceriodaphnia, flow,
mercury,pH and temperature;
• NOTE: Hg monitoring frequency=quarterly. No limit imposed for Hg in permit. Analytical method
not specified in wastewater permit but since no limit it is assumed 1631 E is not required;
2. General Observations:
• 13 acre property. Approximately 40% impervious:
• The site has several different outfalls that discharge into a single ditch and the samples are taken at the last
outfall so a representative sample is taken at that point;
• There was a completed and updated stormwater pollution prevention plan in place.
3. Impairment:
o Lumber River is not listed on 303(d) list for impairment,
0 2003 Basinwide Plan for the Lumber basin shows impairment for fish consumption based on 20 of 22
fish samples collected that exceeded the State's recommended criterion for methylmercury;
o The Lumber River currently has a TMDL in place for Mercury.
4. Threatened and Endangered:
o No federally T or E species were found within two miles of the facility
5. Location:
o Facility is located off NC Hwy 72 approximately three miles southeast of downtown Lumberton.
6. Industrial Changes Since Previous Permit:
o Since the application was submitted in September 2006, there have been no significant changes in
industrial process activities at the facility.
7. Analytical Monitoring Notes:
o Six of seven monitoring events required by the previous permit were completed for pH,TSS and COD.
Values for pH were outside of benchmark range on five occassions;
o See Table 1 below.
8. Qualitative Monitoring Notes:
o Visual monitoring was performed on six occasions from 3/28/05 to 5/8/06 on Outfall 005;
o Most values were relatively low and showed few signs of pollution except for occasional clarity and
color remarks.
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NCS000 349
Table 1: Analytical Monitoring
Required Sample Total Precipitation Duration TSS COD pH
Sampling Date Flow (in) (hours) Benchmark: Benchmark: Benchmark:
Range (MGD) 100 mg1L 120 mg/L 6-9 su
Outfall 1
05/01/02 to
04/30/03
05/01/03 to
04/30/04
05/01/04 to 3/2812005 0.08 19.5 28
04130/05
05/01/05 to 5/6/2005 0.076 6 33.9
07/31/05
08/01/05 to 8/23/2005 0.1154 14 48 6.78
10/31/05
11/1/2005 to 11/28/2005 0.095 29 21.9
01/31/06
02101/06 to 2/7/2006 0.033 5.5 41.5
4130106
5/8/2006 0.168 1 7.3 j 21
Over Current Benchmark
Data Not Collected
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NCS000349
Revised Permit Recommendations: Analytical Monitoring:
1. Maintaining parameters...
a. TSS—to track solids concentration. Sandy soils and equipment/truck traffic potential source:
b. COD—submitted analytical results show moderate oxygen demand in stormwater.
2. Adding parameters...the following parameters were added as part of a comprehensive effort to investigate
stormwater pollution associated with coal-fired power plant facilities:
a. 13 priority pollutant metals(Ag,As, Be, Cd,Cr, Cu, Hg, Ni, Pb, Sb, Se, TI, Zn) plus Al and B—basis:
known association with coal and coal combustion. TMDL for Hg in place. Draft RTI Study('Human
and Ecological Risk Assessment of Coal Combustion Wastes', RTI, August 2007)and discussions with
Robert Schreusdale of RTI suggest these metals may signal contamination problems. Have also
discussed contaminants with Dr.Avner Vengosh from Duke University, who researched ash pond spills
in TN last year. In addition, RRO/DWQ has sampled discharges from cogeneration plants in the FRO
area and flagged several of these metals of concern. Finally, DWQ has little data with which to
characterize stormwater discharges from this industry but knows there is concern,
b. Sulfate—conventional pollutant associated coal,
c. O&G—conventional pollutant associated with onsite petroleum storage and truck traffic.
3. pH added—standard addition to permit.
4. All analytical monitoring set to quarterly. Cover letter to permittee will include language to allow the permittee
to contact DWQ and request modifications of the required monitoring parameters and/or fi-equency if justified by
sufficient data collection.
5. Benchmarks for analytical monitoring and Tiered monitoring system added to this draft permit.
6. Analytical and qualitative monitoring required during representative storm events. Qualitative monitoring
required regardless of representative outfall status.
7. Flow reporting replaced by total rainfall parameter.
8. Vehicle maintenance monitoring revised to semi-annually.
Other Proposed Changes to the Previous Permit:
1. See draft permit for full details.
Discussions with permittee: Rick Houser, 910-788-8742, Date 05/29/2009
1. Q: Have there been any ownership or industrial changes activities since DWQ visited the site in February 2009?
a. ANSWER:No, the ownership change should occur around June of this year. Facility activities remain
unchanged.
Note:Ownership change was recorded on 07/28,2009. New owner is Lumberton Energy,LLC.
2. Q: How many acres is Lumberton Power?
a. ANSWER: 13 acres
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NCS000349
Recommendations: Based on the dOCnlnews reviewed,the application inlo1-1nation submitted on September 14,
'006 sufficient to issue an Individual Stonnwater Pen-nit.
Prepared by(Signature) Date
Stormwater Permitting Unit Superviso 00A Date ' 'Ltooq
for Bradley Be ett
Concurrence by Regional Office �V�;:�VDate ld
RO Water Quality Supervisor Date
Regional Office Staff Comments (attach additional pages as necessary)
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