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Home My WebLink AboutNCS000229_Comments Letter_20170907PSNz GAw W/ C - rte /fsi-n /1/i/ 'Roanoke Valley Energy Facility Westmoreland Partners, LLC September 7, 2017 Robert Patterson, PE North Carolina Department of Environmental Quality Energy, Mineral and Land Resources Stormwater Program 1612 Mail Service Center Raleigh, NC 27699-1612 RECEIVED SEP 15 2017 DENR-LAND QUALITY STORMWATER PERMITTING Subject: Comments on Draft NPDES Stormwater Permit Westmoreland Partners, LLC -Roanoke Valley Energy Facility (ROVA) Weldon, North Carolina; Halifax County NPDES Stormwater Permit No. NCS000229 Dear Mr. Patterson, Westmoreland Partners, LLC - Roanoke Valley Energy Facility (ROVA) received the draft NPDES Stormwater Permit on August 10, 2017. Our comments on the draft permit are as follows. 1. The draft permit states that analytical monitoring requirements would be required during ash transport. However, the ROVA facility does not transport ash on site as it does not have an ash settling basin, an ash landfill, or ash structural fills on site. Additionally, ash is not sluiced; rather, bottom ash is removed from the combustion chamber directly to haul trucks by conveyor. Dry fly ash is collected in hoppers, transferred to the silos by air, and then transferred to a pug mill where it is mixed with 10% water to minimize the fly ash. It is then dropped into the haul trucks using misting system within vinyl curtains. Haul trucks then transport the ash to an offsite Halifax County owned and operated disposal landfill. Ash excavation does not take place at the ROVA facility. Therefore, we request the monitoring required during ash transport be removed._ IwT K n -co fie/c �u oz -rM+c -r#eA0VSftA-r`"'r- Olt' ASN VI R -r/4,K GlC Te 4NY- oi/�S!'r"L S , 3ltt -'2. Part II, Section B, Table 1 (Analytical Monitoring Requirements for Outfalls 3, 4, 5, and 6) -Ab00 is missing footnote #5. 3. Tier One response actions are not consistent with recently issued permits for other coal fired electric plants. Tier One in draft permit NCS000229 requires monthly monitoring of all parameters if one benchmark value is exceeded. Other issued permits do not require monthly monitoring until Tier Two. Additionally, Footnote 1 to Table 1 refers to monthly monitoring for Tier Two and Tier Three status, not Tier One. The ROVA facility requests that implementation of monthly monitoring be removed from the Tier One response actions. _'1�(g✓'( �S co,��st K„K w.� cel✓ ��25 LSs.I.� �1. We request that the Tier Tbree description be clarified to say that this tier is triggered if the four occasions of exceeding the benchmark (or if outside the range) "occur within a consecutive 5 -year period beginning with the effective date of the permit". Roanoke Valley Energy Facility Westmoreland Partners, LLC If you have any comments or questions regarding this submittal or require additional information, please do not hesitate to contact Chris Hews at (252) 536-3200 ext. 232. Sincerely, Westmoreland Partners, LLC Roanoke alley Energy Facility Donald R eisling President Westmoreland - North Carolina Power, LLC GP of Westmoreland Partners EC: Chris Hews, NAES Eric Woods, NAES Joe Sullivan, AECOM