NCS000229_Renewal Application_2011

NPDES STORMWATER PERMIT
RENEWAL APPLICATION
NCS000229
WESTMORELAND PARTNERS, LLC
ROANOKE VALLEY ENERGY FACILITY
Prepared for:
Westmoreland Partners, LLC
Roanoke Valley Energy Facility
290 Power Place
Weldon, North Carolina 27890
Prepared by:
URS Corporation — North Carolina
1600 Perimeter Park Drive, Suite 400
Morrisville, North Carolina 27560
[phone]
URS Project No. 31827518
December 2011

Roanoke Valley Energy Facility
Westmoreland Partners, LLC
December 22, 2011
Mr. Bradley Bennett
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
RE: NPDES Stormwater Permit Coverage Renewal
Roanoke Valley Energy Facility
Permit Number NCS000229
Halifax County
Dear Sir,
p@[Eawmo
DEC 2 9 2011
DENR- WATER QUALITY
KTLAMSAND 5TDRMWATER BRANCH
On behalf of Westmoreland Partners, LLC, attached is the application for the renewal of NPDES
Permit NCS000229, which expires on June 30, 2012. Enclosed is the permit renewal application,
which consists of the individual permit Renewal Application Form, the Supplemental
Information Request form with required documentation, and the signed Stormwater Pollution
Prevention Plan Certification.
In a letter to you dated February 9, 2009, Westmoreland Partners, LLC, submitted a permit
modification to request the removal of Total Aluminum as benchmark discharge characteristic.
In your letter dated March 24, 2009, you state that the agency cannot make a determination until
six more sample events are completed. We have continued to sample both inlet and outfall
locations on site for Total Aluminum, the results of which are shown in Table 1 of the permit
renewal application. Based on the additional sampling results, the facility asks that DWQ
remove Total Aluminum as a discharge characteristic as the results are not indicative of potential
contamination due to activities at the ROVA facility. The above correspondence with respect to
this modification request is included as Appendix E.
Additionally, there are two additional documents included in this renewal. Appendix F is a copy
of a previous sampling point relocation request to move the sample locations for outfalls 005 and
006. The sampling point relocation request was originally submitted on March 1, 2011, but no
response was received. Westmoreland Partners, LLC is requesting permission to move the
sample locations for outfalls #5 and #6 from the front side of the drainage basins to the back side
of the drainage basins next to the fence line. The attached document includes a detailed
explanation of the request and pictures of the two drainage basins with the old and new sampling
points for your review.
290 Power Place Weldon, North Carolina 27890 Phone: [phone] Fax: [phone]

Roanoke Valley Energy Facility
Westmoreland Partners, LLC
If you have any questions please contact me at [phone] ext. 230 or Chris Hews at ext.
232.
Sincerel ,
Donald R. eisling
President, Westmoreland — North Carolina Power, LLC
GP, Westmoreland Partners
CC: Fred Silva, NAES
Brian Quinney, NAES
Chris Hews Sr, NAES
Libby Robinson, URS
290 Power Place Weldon, North Carolina 27890 Phone: [phone] Fax: [phone]

STORM WATER PERMIT RENEW APPLICATION
Roanoke Valley Projects I & II
Submitted to:
North Carolina Department of Environment and
Natural Resources
Division of Water Quality
Storm Water and General Permits Unit
1617 Mail Service Center
Raleigh, NC 27699
Prepared by.
URS Corporation
1600 Perimeter Park Drive, Suite 400
Morrisville, NC 27560
On Behalf of.•
Westmoreland Partners, LLC
Roanoke Valley Projects I & II
290 Power Place
Weldon, NC 27890
December 2011

TABLE OF CONTENTS
Section page
I. Permit Renewal Application Form........................................................................ I
II. Supplemental Information......................................................................................
l
A.
Current Site Maps................................................................................................
I
B.
Summary of Analytical Monitoring.....................................................................
2-4
Table 1
C.
Summary of Qualitative Monitoring....................................................................
5-8
Table 2
D.
Summary of Best Management Practices............................................................
9
i. Indoor Storage..................................................................................................
9
ii. Secondary Containment...................................................................................
10
iii. Primary Containment.......................................................................................
11
iv. Loading/Unloading/Conveying Activities.......................................................
11
v. Containment and Contact Management...........................................................
12
vi. Preventive Maintenance and Good Housekeeping ..........................................
13
vii. New Best Management Practices....................................................................
13
E.
Narrative of Significant Changes.........................................................................
14
F.
Certifications........................................................................................................
14
i. Development and Implementation of Storm Water Pollution Prevention Plan
14
Appendices
A. Permit Renewal Application Form
B. Checklist of Required Supplemental Information
C. Current Site Maps
D. Storm Water Pollution Prevention Plan Development and Implementation Certification
E. 2009 Correspondence Regarding Total Aluminum Benchmark
F. Sampling Point Relocation Request for Outfalls 005 and 006
Roanoke Valley Projects I & H December 2011
Page

Storm Water Permit Renewal Application
I. Permit Renewal Application Form
The completed Permit Renewal Application Form can be found in Appendix A.
II. Supplemental Information
This section contains the Supplemental Information requested. A complete checklist of
required supplemental information can be found in Appendix B.
A. CURRENT SITE MAPS
List of Drawings that can be found in Appendix C:
• RVEF Site Drainage Map
• Structures and Area Drainage Plan — RVP I & RVP II
• Site Plan — RVP I & RVP II
• Aerial Photo of Inlet and Outfall Locations
B. SUMMARY OF ANALYTICAL MONITORING
Analytical monitoring was performed semi-annually throughout the permit term as
specified in the schedule shown in Table 2 of Part II Section B of the permit. Analytical
monitoring is conducted for the following parameters:
• Chemical Oxygen Demand (COD)
• TSS
• Total Aluminum
• pH
Additionally, storm event data (total rainfall in inches, and rainfall event duration in
minutes) was collected for each sample.
Monitoring results are compared to the benchmarks shown in Table 3 of Part II Section B
of the permit. The monitoring results and benchmarks are summarized in the following
table.
As this permit renewal application must be submitted prior to conducting the final
analytical monitoring (due Spring 2012), these results will be submitted to NC DWQ
within 30 days of receipt of the laboratory results.
Roanoke Valley Projects I & II December 2011
Page I

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9

Storm Water Permit Renewal Application
On February 9, 2009, Westmoreland Partners, LLC, submitted a permit modification to
request the removal of Total Aluminum as a benchmark discharge characteristic. In a
response letter dated March 24, 2009, the Division of Water Quality (DWQ) requested
that six more sample events be completed prior to making a determination. We have
continued to sample both inlet and outfall locations on site for Total Aluminum, the
results of which are shown in Table 1 above. Based on the additional sampling results,
the facility asks that DWQ remove Total Aluminum as a discharge characteristic as the
results are not indicative of potential contamination due to activities at the ROVA
facility. The above correspondence with respect to this modification request is included
as Appendix E.
C. SUMMARY OF QUALITATIVE MONITORING
As required, qualitative monitoring was performed twice per year, once in the spring and
once in the fall, for each outfall. The results are summarized in Table 2 below.
Roanoke valley Projects I & II December 2011
Page 4

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4

Storm Water Permit Renewal Application
D. SUMMARY OF BEST MANAGEMENT PRACTICES
The Roanoke Valley Projects I & II (RVP I & II) use many Best Management Practices
(BMP) throughout the entire plant site for both power generating units. The most
appropriate BMP, or combination of BMP, was selected for a specific area, based on the
desired pollution prevention purpose and the practicality of its use. In most cases, the
same BMP utilized at Unit I was utilized at Unit II. The following is a brief summary of
the types of BMP used in various plant areas and the intended purpose.
L Indoor Storage
Where possible, the plant chemicals are located within designated buildings to avoid
contact with storm water. Since the buildings' design includes perimeter curbing, the
inside area is contained. In addition, the buildings have sumps to contain small spills
that may occur. The following describes the various buildings:
The Cooling Tower Chemical Buildings store the cooling tower chemicals.
The buildings are curbed, have roll -up doors and ramps for inside loading and
unloading activities, and floor sumps to contain small spills and facilitate
cleanup activities.
• The Demineralizer Building does not currently contain chemicals. In the past,
chemicals were used to pre -treat the water to the proper boiler feedwater
quality. Since filtration is used to treat the water to the proper quality,
chemicals are no longer needed, used or stored. Because chemicals were once
stored in this building, the building design includes a sloped floor to direct
spills to the trench -type floor which is routed to the coal pile pond.
• The Boiler/Turbine Generator Buildings also contain the boiler feedwater
chemicals, miscellaneous chemical tanks, including; cleaners, maintenance
chemicals, lubricants and hydraulic oils. Also located within the buildings are
small oil storage tanks for, boiler feed pump oil reservoirs, auxiliary
generator, and self-contained steam turbine lube oil system. The boiler
feedwater chemicals are placed on a specified curbed skid. The chemicals and
oils within these buildings are in secondary containment, either permanent or
portable units. The fire protection pump diesel engine tank is located in the
pump station, and is within a concrete containment.
Roanoke Dalley Projects I & II December 2011
Page 9

Storm Water Permit Renewal Application
• The coal pile pond treatment chemicals are located in the Pond Area
Treatment Shed. The chemicals are stored in polypropylene tanks, and on
occasion, specific chemical barrels are stored in the building if needed for
treatment. The polypropylene storage tanks have been installed and piped up
in the same fashion as stationary tanks. The building is curbed for spill
containment.
• The Used Oil Area is located in a 3 -sided covered structure that is contained
by a concrete floor, perimeter curbing and ramped access for inside loading
and unloading activities.
• Warehouse Sheds and Maintenance Warehouse Buildings house maintenance
materials and spare parts. The structures are fully enclosed and have curbed
foundations to contain spills.
ii. Secondary Containment
If it is not practical for the chemicals to be stored indoors, the chemical storage
tanks are located outside, designed with secondary containment to contain the
contents of the tank, with additional sufficient freeboard for precipitation. Each
containment area is of the proper material for its use and is capable of collecting
and holding spills, leaks, and a storm event. The concrete containment structures
have a holding capacity equal to 10 % of the volume of all containers or 100% of
the volume of the largest container, whichever is greater. The base of each
concrete containment area is free of cracks or gaps, and sufficiently impervious to
leaks, spills and rainfall. The permanent containment structures used are
constructed of concrete floors and side-walls and the portable containment units
used are of a plastic (polypropylene) material. All indoor and outdoor chemicals
are located within either a permanent containment structure or a portable
containment unit.
Only a few chemical/oil tanks are located outside; these include the following tanks:
• The sulfuric acid tanks, limestone storage vessel, and the urea tank (RV II
only) are located outdoors. All of these tanks are contained separately using
concrete containment structures, sized to contain 100% of each tank, with
capacity for precipitation.
• The main oil storage tank is located outside. It is located in a concrete
containment dike sized to hold 100% of the tank volume, as well as capacity
for precipitation.
• The induced fan (ID) lube oil reservoirs are located outdoors. Each of the
three lube oil skids has self-contained reservoirs which are surrounded by a
concrete dike containment.
Roanoke Valley Projects I & 11 December 2011
Page 10

I
Storm Water Permit Renewal Application
• The electrical transformers are equipped with cooling oil reservoirs that
contain Type I oil. RVP I & II has a total of ten transformers. All
transformers are located outdoors and are surrounded by concrete diked
containment. Each dike is filled with rock for fire protection and has a sump
in one corner. The dikes are sized to contain 100% of the reservoir volume
plus one -inch of precipitation.
iii. Primary Containment
The coal handling and storage area was designed to be "controlled and separated"
from the other areas of the plant. Since this coal area is considered a "contact'
area, all rain water runoff from this designated handling and storage area is
collected and routed into the coal pond for containment, detention, and treatment
prior to discharge as allowed per the Pretreatment Industrial User Permit. The
pond is split into two sections to facilitate maintenance. The pond is sized for a
24 -hr, 10 -year storm, with sufficient freeboard for containing normal rain events.
iv. Loading /Unloading/Conveying Activities
For all the chemicals, oils, and materials handled at the plant, specific loading and
unloading procedures have been developed and continue to be implemented to
minimize the possibility of spill events and prevent possible pollution exposure.
These include using guard posts, flexible hoses, valve sequence, activity
supervision, storm drain covers, automatic flow shutoff valves, and local and
remote high level alarms.
The same procedures are followed for the materials, oils, and chemicals located
within the various buildings. Because the loading/unloading activities are
performed within the building, the potential for exposure of storm water to
pollution is further reduced.
The coal, limestone, and ash handling systems are controlled to mitigate fugitive
emissions that could allow the material to come into contact storm water. The
following BMP are used to limit exposure:
• A water and surfactant mixture can be sprayed at several points in the coal
• unloading and conveying systems to moisten the coal to minimize the fugitive
emissions.
• The coal silos, lime surge bin and silos, fly ash receiver, ash recycle silo and
flyash silos use bin vent filters to control particulates. All coal handling and
conveying operations are enclosed.
• Limestone is conveyed pneumatically in a closed system.
Roanoke Palley Projects I & H December 2011
Page 11

Storm Water Permit Renewal Application
• All silos and surge bins have been provided with fabric filters and dedicated
fans to further reduce fugitive dust emissions into the atmosphere, therefore,
reducing contact with storm water.
• Ash is loaded into the ash trucks from the ash silos. The ash can be sprayed
or conditioned to the correct moisture content to minimize fugitive emissions
during the activity. The ash silos are equipped with curtains to also assist in
controlling ash emissions along with a misting halo around the discharge
chute. The paved area surrounding the designated ash loading/unloading area
is cleaned after the activities are completed. This area is curbed and the
drainage does not commingle with "non -contact' drainage areas.
v. Containment and Contact Management
Procedures have been developed and implemented to inspect collected storm
water in secondary containment areas. Storm water that accumulates in the
containment areas is visually inspected as required in the Storm Water Permit and
Storm Water Pollution Prevention (SWPP) Plan prior to the release of the
collected water. If the accumulated storm water is determined to meet the visual
permit limits, it is released through a normally closed manual valve. If the
collected storm water appears to be contaminated, the liquid is pumped using a
manual pump into 55 -gallon drums, properly labeled and stored with other liquids
until it can be recycled or properly disposed. Each release from the containment
is recorded as required per the Storm Water Permit and the records are kept on
file at the plant.
Areas where potential material contact can occur, such as ash area, Flue Gas
Desulfurization (FGD) system area (which consists of limestone and lime slurry
used for emission control of the flue gas) are curbed to contain, separate and
minimize flow into non -contact drainage areas. If materials are spilled in these
concrete curbed areas, clean up is performed immediately to limit exposure to
storm water.
The facility was designed with separate drainage systems, non -contact and
contact. The non -contact drainage systems route "non -contact' storm water to the
storm water outfalls. The contact drainage areas route storm water, which could
potentially be exposed to contaminants, to the appropriate treatment system (i.e.
the station sump for oily water separation or the coal pile detention pond for
sedimentation, clarification and pH adjustment) prior to discharge per the
Industrial User Pretreatment Permit. The drainage systems do not commingle.
Visual inspections are performed to ensure that "contact' storm water and/or
process wastewater is not discharged into the storm water outfalls.
Roanoke Valley Projects I & II December 2011
Page 12

Storm Water Permit Renewal Application
vi. Preventive Maintenance and Good Housekeeping
The facility uses a maintenance -tracking software program (MAXIMO) to
schedule and perform routine and non -routine maintenance activities. Storm
water inspection and maintenance activities and schedules, as required by the
Storm Water Permit and the SWPP Plan, have been programmed into the
MAXIMO Program. The ability for tracking special design modification projects,
such as the wastewater drainage improvements project performed at the plant, is
also a valuable function of this program.
Most of the areas throughout the plant are paved, using concrete and asphalt. The
paved areas facilitate and expedite clean up activities by using on-site equipment.
Daily inspections are performed to ensure a "clean" plant and reduce the potential
for pollutants entering the storm water conveyance system and flowing off-site.
Common sense is also implemented; this includes the following:
• store containers indoors and in an orderly fashion,
• keep surfaces clean and free of chemicals and oils,
• properly dispose of rags and towels,
• sweep dry chemicals, and
• clean up small liquid accumulations on the floor or ground.
Drainage structures, dikes, ditches and storm water outfalls are inspected to
ensure that there are no obstructions by sediment or debris.
vii. New Best Management Practices
The following are BMPs that have more recently been implemented at ROVA:
• filter dams consisting of crushed stone were installed at Inlets A and B to
reduce sediment from flowing onto the site,
• filter socks were installed in blue drains by ash silos and coal crushers to
reduce particulate, and
• new sampling platforms were installed at all outfalls to provide better and
safer access.
Roanoke Valley Projects I & 11 December 2011
Page 13

Storm Water Permit Renewal Application
G. NARRATIVE OF SIGNIFICANT CHANGES
There were no significant changes in industrial activities at the permitted facility.
H. CERTIFICATIONS
The signed certification of Storm Water Pollution Prevention Plan Development and
Implementation can be found in Appendix D.
Roanoke Dalley Projects I & II December 2011
Page 14

APPENDIX A
Permit Renewal Application Form

3Of W. Permit Permit Coverage _
e�Renewal Application Form
�. National Pollutant Discharge Elimination System Permit Number
Stormwater Discharge Permit NCS009229
The following is the information currently in our database for your facility. Please review this information carefully and make all
corrections/additions as necessary in the space provided to the right of the current information.
Owner Affiliation Information * Reissued Permit will be mailed to the owner address
Owner/ Organization Name:
Owner Contact:
Mailing Address:
Phone Number:
Pax Number:
E-mail address:
Westmoreland - L O & E Parmers
Mr. Don Keisling
290 Power PI
Weldon, NC 27890
[phone]
Facility/Permit Contact Information
Facility Name: Roanoke Valley Energy Facility
Facility Physical Address: 290 Power PI
Weldon, NC 27890
Facility Contact:
Mailing Address:
Phone Number:
Fax Number:
E-mail address:
Discharge Information
Receiving Stream
Stream Class:
Basin:
Sub -Basin:
Number of Outfalls:
Roanoke River
Roanoke River Basin
03-02-08
.41111111 F43MIqtr
Impaired Waters/TMDL
Does this facility discharge to waters listed as impaired or waters with a finalized TMDL? O Yes Jd No ❑ Don't Know
( for information on these waters refer to hitp://h2o.enrstate.nc.us/su/Impaired Waters_TMD/J )
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.
Signature Date I ZI Z-7 12611
➢prlald ietslmh t�testden� V3esh�twl�td-+�CPat� (u
Print or type name of person sig mg above Title C l'r W -e S�'f11 W i2'r.p( Pyq-}tie,
Please return this completed renewal application form to: Stonnwater Permitting Unit
Attn: Brian Lowther
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

APPENDIX B
Checklist of Required Supplemental Information

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 div 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.
' 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. H
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.
`AdU� 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.
'12J� 6. 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)

APPENDIX C
Current Site Maps

E
c
U
O
■ •
- w
L
G
C
7AX.J

APPENDIX D
Storm Water Pollution Prevention Plan Development and
Implementation Certification

ATER POLL NU41OPT RUIN
North Carolina Division of Water Quality — Stormwater Permitting Unit
Facility Name: Roanoke Valley Energy Facility
Permit Number: NCS000229
Location Address: 290 Power PI
Weldon, NC 27890
County: Halifax
"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. Rased 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."
And
I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP has been fully implemented at
this facility location in accordance with the terms and conditions of the Stormwater discharge permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and imprisonment for knowing
violations."
s
Signature —
DonzlC{ V,, slI
Print or type name of person signirlg'above
Date t z I`Z 7l Z6lI
preg,de„+,tic Pow¢, -,t (
Tale 6fW25fMUT2lzna(PLrj1.Oz
SPPP CaooarsM 5/09

APPENDIX E
2009 Correspondence Regarding Total Aluminum Benchmark

Roanoke Valley Energy racility
Westmoreland Partners, LLC
Febivaty 9, 2009
Mr% Bradley Bennett
Stormwater Permitting Unit Supervisor
NC DNER Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
RE: Request for Permit Modification
Westmoreland Partners, LLC
NPDES Permit No., NCS000229
DearMr. Bennett
On behalf of Westmoreland Partners, LLC, the purpose of this letter is to request a permit
modification for the Roanoke Valley Energy Facility (ROVA) located at 290 Power Place,
Weldon, North Carolina. Ms, Brittany Robinson of URS Corporation spoke with Ms.
Bethany Georgoulias ofDWQ in December regarding this request„
Table .3 of the facility's NPDES Permit, requires that samples be tested for Total Aluminum
and compared to a benchmark. It is noted that "the benchmark values in Table 3 are not permit
limits but should be used as guidelines for the permittee's Stormwater Pollution Prevention
Plan (S WPPP).. The permittee shall evaluate the sources of any benchmark exceedances and
evaluate the effectiveness of any site BMPs. The permittee shall review and/or update the
SWPPP and document any efforts to address stormwater contamination."
Samnline Results
Sampling for Total Aluminum began in the Fall of'2007. After the first sampling event, it was
noted that the results at all outfalls were above the benchmark limit of'035 ppm, with some
locations above the benchmark for COD and TSS. Corrective actions were taken and since the
first sampling event, the results for all other benchmark characteristics (pH, COD and ISS)
have been below their respective benchmarks while Total Aluminum remains above its
benchmark.
In addition to improving the effectiveness of BMPs, the facility also decided to test upstream
samples (prior to exposure to industrial activities at ROVA) for Iotal Aluminum. Testing
through 2008 shows that results for Inlet Samples #1 and #2 are consistently above the
benchmark. Also, results for Outfall #4 have decreased dramatically, which is the location
that has the highest potential for Total Aluminum due to coal fly ash loading in this drainage
area Iable I summarizes all results with ones above the benchmark shaded in gray,

Roanoke Valley Energy Facility
Westmoreland Partners, LLC
Table 1: Total Aluminum Results (ppm)
Date
_101512007
2/22/2008
1412812008 11117_12008
Inlet # 1
4.56
1.51 0.776
Inlet # 2
_
3.14
1.79 5.08
Outlet #3
_ _
7.1
1,94.` 2.21 `
Outlet # 4
12 -
_
0.237 0.238
_Outlet # 5 _
2.5
4.49 1.11
Outlet # 6
1.5
_
4.42
Benchmark for Total Aluminum is 0.75 ppm.
In an effort to better understand the characteristics of the stormwater coming on-site, the
facility also tested upstream samples for iron during an October 2008 sampling event. The
results in Table 2 show that iron is above the typical benchmark of 1 •.0 ppm.
Table 2: Iron Results (ppm)
of averaged duplicate samples (Inlet 1:
Modification Re uest
Based on these observations, the facility asks that DWQ remove Total Aluminum as a
discharge characteristic as the results are not indicative of potential contamination due to
activities at the ROVA facility.
"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 fines and imprisonment for knowing
violations."
Thanks in advance for your consideration. If you have any comments or questions, please
contact W. Chris Hews of my staff at 252-5.36-3200 x 232
Sincerely,
�`r C
Donald R. Keisling
General Manager and Director of Operations
Roanoke Valley Energy Facility

Roanoke Valley Energy Facility
Westmoreland Partners, LLC
CC: DWQ - Regional Office (2) copies
Fred Silva, NAES
Biian Quinney, NAES
Cluis Hews Sr„ NAES
Brittany Robinson, URS

Roanoke Valley Energy Facility
Westmoreland Partners, LLC
March 19, 2009
Myrl Nisely
Environmental Chemist
Division of Water Quality
North Carolina Department of'Environment and Natural Resouces
1628 Mail Service Center
Raleigh, North Carolina 27699-1628
Re: Aluminum in Storm Water
Dear Mr. Nisely,
Per your phone request on March 19, 2009,1 am sending you a site layout with the
locations of the outfalls and Inlet sampling points indicated. I am also sending you a map
of the drainage areas in the plant which shows the areas for each outfall and a previous
sampling we did on just the inlet run-on sites February 22, 2008. On the February
sampling the #3 inlet showed a level of 19..8 mgll for Aluminum, yet on subsequent
samplings it was even within permit limits.. This is why it is almost impossible to keep
the outfalls within limits and why we are requesting that Aluminum be removed.. In out
letter to request the change we indicated that Iron is also running high in this area in the
oncoming flows.. Ihis will hopefully aide in our decision should you choose to monitor
for a different metal..
Respectfully,
Chris E. Hews Sr.— _..._.
Environmental Manger
Roanoke Valley Energy Facility
290 Power Place Weldon, North Carolina 27890 Phone: [phone] Fax: [phone]

Client Sample Marks: DAY 1 INLET#1 RUN ON
Microbac Laboratories, Inc.
Sample Collection Date: 2/22/2008
SOUTHERN TES'TOVO & RESEARCH DIVISION
Matrix: WW
.3809AIRPOR7 DRIVE, NW
t
WILSON, NC 278968649
CAT No. ANALYSES
[phone] [phone] (%ax)
ANALYZED by POL RESULT UNIT
www. southerntestingcorn
REPORT Of ANALYSIS
SAMPLE No: T1701-001 / A857923
EP 001 Digestion(ICP/FAAS)
Date Reported: Thursday, March 06, 2008
CHRIS HEWS
EW -007-13 Chemical Oxygen Demand
ROANOKE VALLEY ENERGY
2/27/2008 AJF 10 23 8 mgt
290 POWER PLACE
Phone / Fax: [phone]
W ELDON NO 27890
P 0: 2080220
Client Sample Marks: DAY 1 INLET#1 RUN ON
Sample Collection Date: 2/22/2008
11:31:00 AM
Matrix: WW
Lab Submittal Date: 2/25/2008
1:40:00 PM
Classification: E
CAT No. ANALYSES
METHOD
ANALYZED by POL RESULT UNIT
EM 013-L Aluminum (ICP)
EPA 200 7
3/5/2008 GAR` 0 010 4 56 mg/L.
EP 001 Digestion(ICP/FAAS)
EPA 2007
2/27/2000 DJS Yes
EW -007-13 Chemical Oxygen Demand
HACH 8000
2/27/2008 AJF 10 23 8 mgt
Sample Comments:
w
ed dnd Approved by:
ZR L
helm'Innant
Manager, Analytical Sciences Department
Page 1 of 8 _ Admin 3/6/2008 10:47:45 AM
Wilson Division - NCO0120 Certification: Drinking Water #37708 Wastewater #21 -
(-G) Greensboro Division - NCO01754 Certification: Drinking Water #37795 Wastewater #637
Forany feedback conceming our services, please contact Rob Denner, Managing Director,
at rdermerOmicrobao com, or Trevor Boyce, President, at president®microbac cam
Chemical and Microbiological Analysis: Environmental • Agrochemical •Foods • Pharmaceuticals

I'
Microbae Laboratories, Inc.
Matrix:
SOUTHE'RNTES77NC&RESEARCH DI VISION
3809AIRPORTDRIVE; NW
e
WLSON, NC 27896-8649
E
[phone] [phone](fax)
CAT No. ANALYSES
WWW. southernte51U7$.com
REPORT Of ANALYSIS
SAMPLE No: T1701.002 / AB57924
_
Date Reported: Thursday, March 06, 2008
CHRIS HEWS
-
ROANOKE VALLEY ENERGY
DJS Yes
290 POWER PLACE
Phone / Fax: 252-53&3200/252-536.4448_
WELDON NC 27890
P O: 2080220
Client Sample Marks: DAY 1 INLET#2 RUN ON
Sample Collection Dale: 2/22/2008
11:23:00 AM
Matrix:
WW
Lab Submittal Date: 2/25/2008
1:40:00 PM
I Classification:
E
CAT No. ANALYSES
METHOD ANALYZED by POL RESULT'
UNIT
EM -013L Aluminum (ICP)
EPA2007 3/5/2008
GAR 0010 314
mg/L.
EP -001 Digestion (ICP/FAAS)
EPA 200 7 2/27/2000
DJS Yes
EW -007-G Chemical Oxygen Demand
_ HACH 8000 2(27/2008
AJF 10 <10
mg/L
Sample Comments:
_. __.._...__.
R[�(i Land keproved by:
—
SF1'etra"Hinnant
Manager, Analytical Sciences Department
Page 2 of 8 _ Admin 3/6/2008 10:47:45 AM
Wilson Division - NC00120 Certification: Drinking Water #37708 Wastewater #21
(•G) Greensboro Division - NCO01754 Certification: Drinking Water #37795 Wastewater 9637
For any feedback concerning our services, please contact Rob Dermer, Managing Director, -
at rdermeriti?mfcrobac com, or Trevor Boyce, President, at president ®mforobac cam .
Chemical and Microbiological Analysis: Environmental • Ancehemical • Foods • Pharmaceuticals
I

Sample Comments:
Re ' d and Approved by:
hinnant-11
Manager, Analytical Sciences Department
Page 3 of 8 Admin 3/6/2008 10:47:46 AM
Wilson Division - NCO0120 Certification: Drinking Water #37708 Wastewater #21
(-G) Greensboro Division - NCO01754 Certification: Drinking Water 437795 Wastewater #637
For any leedback concerning our services, please contact Rob Denner, Managing Director,
at rdermer@microbac com, or Trevor Boyce, President, at president microbac corn
Chemical and Microbiological Analysis: Environmental • Amnchemical • Foods • Pharmaceuticals
i
Microbac Laboratories, Inc.
SOUTIIERY TESTING & RESEARCH DIVISION
3809AIPPORT DRIVE; NIP
.
WILSON, NC 278968649
(252)2;7.4175 [phone](f")
W1t+1Y.5outherntesting. cont
REPORT of ANALYSIS
SAMPLE No: T1701-003 / AB57925
_
Date Reported: Thursday, March 06, 2008
CHRIS HEWS —
—
ROANOKE VALLEY ENERGY
290 POWER PLACE
Phone / Fax: [phone] _.
WELDON NC 27890
P 0.: 2080220
Client Sample Marks: DAY 1 INLET#3 RUN ON
Sample Collection Date: 2/22/2008 11:15:00 AM
Matrix: _ WIN
Lab Submittal Date: 2/25/2008 1:40:00 PM
Classification_ E
CAT No. ANALYSES METHOD
ANALYZED by POL RESULT UNIT
EM -013-1. Aluminum(ICP) EPA2007
3/5/2008 GAR 0010 198 mg/L
EP -001 Digestion(ICP/FAAS) EPA 2007
2/27/2000 DJS Yes i
EW -007-G Chemical Oxygen Demand MACH 8000
2/27/2008 AJF 10 51 3 mg/L
Sample Comments:
Re ' d and Approved by:
hinnant-11
Manager, Analytical Sciences Department
Page 3 of 8 Admin 3/6/2008 10:47:46 AM
Wilson Division - NCO0120 Certification: Drinking Water #37708 Wastewater #21
(-G) Greensboro Division - NCO01754 Certification: Drinking Water 437795 Wastewater #637
For any leedback concerning our services, please contact Rob Denner, Managing Director,
at rdermer@microbac com, or Trevor Boyce, President, at president microbac corn
Chemical and Microbiological Analysis: Environmental • Amnchemical • Foods • Pharmaceuticals
i

APPENDIX F
Sampling Point Relocation Request for Outfalls 005 and 006

Roanoke Valley Energy Facility
Westmoreland Partners, LLC
March 1, 2011
Coleen H. Sullins, Director
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-16I7
RE: Moving of Sample Locations for Outfalls #5 and #6 on
Permit #NCS000229
Roanoke Valley Energy Facility
Halifax County
Dear Ms. Sullins;
On behalf of Westmoreland Partners, LLC, I would like to request permission to move the
sampling points for Outfalls #5 and #6 on Permit #NCS000229 from the front side of the
drainage basins to the back side of the drainage basins next to the fence line.
Permit Condition Part III.D.1. requires that "all samples shall be taken before the discharge joins
or is diluted by any other waste stream, body of water, or substance." Currently, the sample
locations for Outfall 005 and 006 are located where storm water enters each drainage basin rather
than the discharge from the basins at the property boundary. In several cases during qualifying
rainfall events, storm water was sampled at the basin inlets, but has not discharged from the site.
Therefore, the facility collected and reported results when there was actually no discharge at
these sample points.
For this reason, the facility proposes to move the sample outfall locations so storm water is
collected after the drainage basins and just prior to the discharge leaving the property. This will
be a more accurate sample of what is actually leaving the site.
Attached are several pictures of the two drainage basins with the old and new sampling points.
If you have any questions please contact me at [phone] ext. 230 or Chris Hews at ext.
232.
Sincerely,
Donald R. Keisling
President, Westmoreland — North Carolina Power, LLC
GP, Westmoreland Partners
290 Power Place. Weldon. North Carolina 27890 Tel: [phone] Fax [phone]

Roanoke Valley Energy Facility
Westmoreland Partnere, LLC
CC: Fred Silva, NAES
Brian Quinney, NAES
Chris Hews, NAES
Brittany Robinson, URS
290 Power Place. Weldon. North Carolina 27890 Tel: [phone] Fax: [phone]

Outfall 005
Proposed and Current Outfall Location

Outfall 005
Proposed and Current Outfall Location
I Current Outfall Location I
T, 3: sem .
T �•A 1

Outfall 006
Proposed and Current Outfall Location
Fence Line —
Property Boundary
Where discharge leaves site
Proposed Outfall Location
7'n°. v.41 / ,, i'. �,� �✓ iN r yr , � � ,
Current Outfall Location is Upgradient
and not seen on the picture
fn
h
tN
7'n°. v.41 / ,, i'. �,� �✓ iN r yr , � � ,
Current Outfall Location is Upgradient
and not seen on the picture