NCS000229_Draft Permit Cover Letter

Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
August 10, 2017
Ms. Jennifer S. Grafton
Westmoreland Partners, LLC
290 Power Place
Weldon, NC 27890
Dear Ms. Grafton:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
TRACY DAVIS
Director
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000229
Roanoke Valley Energy Facility
Halifax County
Enclosed with this letter is a copy of the draft stormwater permit for your facility. Please review the
draft very carefully to ensure a thorough understanding of the conditions and requirements it contains.
The draft permit contains these significant changes from the facility's current permit:
1. Monitoring parameters and benchmarks have been revised to be consistent with recently issued
permits for similar coal fired electric plants. Stormwater benchmarks are not permit limits but
are guidelines for implementing the Stormwater Pollution Prevention Plan (SPPP). A benchmark
exceedance is NOT a permit violation; however, the permittee must respond to exceedances as
directed in the Tiers.
2. Aluminum is being removed since it is not included in the divisions recent permit approach for
coal fired facilities; and based on the inlet flows already exceeding benchmark.
3. You are required to collect analytical and qualitative monitoring samples during a "measureable
storm event" as defined in Part II, Section B. This term is different from the "representative
storm event" in earlier permits.
4. Vehicle maintenance monitoring parameters have been revised. "Non -Polar Oil & Grease" by
Method 1664 (SGT -HEM) replaces Oil & Grease or TPH. This requirement appears in all
individual stormwater permits; however, it only applies to facilities that perform vehicle
maintenance activities (VMA) on-site. If the facility begins vehicle maintenance during the
permit cycle, the requirements shall apply. Also, pH monitoring is no longer required for
discharges only associated with VMA.
5. Requirements for the Stormwater Pollution Prevention Plan have been updated in Part II, Section
A.
Please submit any comments to me no later than thirty (30) days following your receipt of the draft.
Comments should be sent to the address listed on the front page of this letter. If no adverse
comments are received from the public or from you, this permit will likely be issued in about two
months.
If you have any questions or comments concerning this draft permit, contact me at [phone] or
[e-mail]
State ofNorth Carolina I Environmental Quality I Energy, Mineral and Land Resources
1612 Mail Service Center 1 512 North Salisbury Street I Raleigh, NC 27699-1612
919 707 9200 T

Ms. Jennifer S. Grafton
NCS000229, August 10, 2017
Page 2 of 2
cc: Mr. Chris Hews - ROVA
Raleigh Regional Office, DEMLR
Stormwater Program
Attachments
Sincerely,
Robert D. Patterson, PE
Environmental Engineer
Stormwater Program
5 tate of NoT iCaroliiia Emimnwnhl Quality Energy, Nineral and Laud Remuiues
1612 Mail Senxe Center j12 North Salisbiuy Street Raleigh: NC 27699-1612
919 707 9200 T