NCS000229_Staff Report

Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Regional Office: RALEIGH
Owner/Company:
Facility Name:
NPDES Permit Number:
Expiration Date:
Facility Location:
Type of Activity:
SIC Code or Description:
Receiving Stream:
River Basin:
Stream Classification:
Proposed Permit Requirements:
Response Requested by (Date):
Central Office Staff Contact:
Central Office Review Summary:
ROY COOPER
G.,,,,.
MICHAEL S. REGAN
see,'e,n
TRACY DAVIS
Direnor'
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Westmoreland Partners, LLC DENR-LAND Q ALIT(
ROANOKE VALLEY ENERGY FACILITY STORMWATER PE RMITTiNG
NCS000229 z
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June 30, 2012 0 b
CIO
290 Power Place, Weldon, NC (Halifax County) ;;zf M
Coal Fired Electric Generation o' o
4911
Roanoke River, 23-(26) 0 0
Roanoke River Basin, Sub -basin 03-02-08
See attached draft permit.
August 28,2017
Robert Patterson, [phone]
1. Special Issues: Facility stopped operating, but still has an exposed coal pile. They plan
to have the coal removed from site over the next 6 months. Once the site is cleaned up,
they could request to rescind the permit. Any new owner in the future would need to
apply for their own permit if they start operating again.
2. Changes at the facility since previous permit: Operations ceased on March 1, 2017.
Facility currently for sale.
3. Receiving Waters: Roanoke River, 23-(26), Class C, supporting
4. Threatened and Endangered Species: Coppery Emerald, Somatochlora georgiana, a
dragonfly/damselfly
State of North 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

NCS000229
Page 2 of 3
5. Analytical and/or qualitative monitoring during this pastep rmit cycle: Monitoring
continued to report exceedances for Aluminum; but also are monitoring the flow
coming into the site that also is already exceeding the Al benchmark before the site
runoff is added to the flow. There have been some intermittent exceedances for TSS
and COD; most of which appear to coincide with the inlet flow exceeding benchmarks.
6. Rationale for monitoring parameters: Revised to be consistent with similar recently
issued coal power facilities. 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. Limi in 40 CFR 423 are not included for the coal pile
runoff since that area is collected, pre-treated, and discharged to wastewater. However,
benchmarks are included based 40 CFR 423 Appendix A. Also, see attached staff report
from previous proposed permit.
7. Permit. Facility. and Owner Contacts updates:
® Confirmed contact information with permittee and updated BIMS if necessary.
® Obtained e-mail addresses for each contact and updated BIMS.
8. Annual Fees:
® Confirmed in BIMS that permittee does not owe fees.
Recommendations:
Based on the documents reviewed, the application information submitted on December 29,
2011 is sufficient to issue an Individual NPDES Stormwater Permit.
Central Office recommends reissuance of this permit with with modifications to the
monitoring as stated above in 6. Also included are standard revisions to VMA monitoring
for consistency with other permits and metals benchmark revisions for consistency with
EPA recommended acute water quality criteria. The proposed draft permit reflects the
most recent individual stormwater permit template and boiler plate language,
incorporating revisions that are similar to the industrial general permits issued during
2017.
Prepared by (Signature) 7t7Y /Z -' V Date i Z! /
Stormwater Permitting Supervisor
f*K Mike Randall (Acting Supervisor)
Concurrence by Regional Office
RO DEMLR Supervisor
State of �4o,&CamSm Ensimomeotal Qoaliry. Energy, hinerai andl and Reso=es
1612 \4d Smioe Center 512 N-ort6 Satibmy Street Raleigh, VC 27699.1612
9197079200 T
Date 2 c�2
Date
Date

NCS000229
Page 3 of 3
Regional Office Staff Comments (attach additional pa es as cessary)
T,
Statedbn6Caroli® Enriwnmental Quality• Eneagy,%bmMandLand Retomtma
1612MO Seniu Center 512 North SaGabwy Stott Raleigh, 2x 276KI6L
919-079200 T

NCS 000229
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Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. E. Director
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
History:
• 17 February 1995: Original permit was issued. Analytical monitoring was required for the following (with
cutoff concentrations): TSS (100 mg/L), COD (120 mg/L), Hg (0.0024 mg/L), and pH (6-9). (One sample
in the first and last years.) Visual monitoring was required. Vehicle maintenance was also required for: pH
(6-9), oil and grease (30 mg/L), total recoverable lead (0.033 mg/L), TSS (100 mg/L), and detergents
(MBAS) (0.50 mg/L).
• 17 April 1995: Corrections to permit (name change, added outfall 004, renumbered outfalls as 003, 004,
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [phone] Customer Service
1-877-623-6748
STAFF REVIEW AND EVALUATION
NPDES Stormwater Permit
Facility Name:
Roanoke Valley Energy Facility
NPDES Permit Number:
NCS000229
Facility Location:
Weldon, NC (Halifax County)
Type of Activity:
Power Production
Receiving Streams:
Roanoke River, See Figure 1 (NOTE: Previous
permit said that it was Wolf
Swamp, but that is incorrect. There is no Wolf Swamp in this area.)
River Basin:
Roanoke River Basin, Sub -basin 03-02-08
Stream Classification:
C
Proposed Permit Requirements:
See attached draft permit.
Monitoring Data:
See Table 1
Facility Location:
See Figure 1
Response Requested by (Date):
Central Office Staff Contact:
Kelly Johnson, [phone], ext. 376
z 3iu
Description of Onsite Activities:°
{
This facility is a 180 -megawatt coal-fired non-utility generating station.
T o
p .a
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Documents Reviewed:
• NPDES Stormwater Permit Application Materials
• Stormwater Permit File
� c�
• Roanoke River Basinwide
Plan, 2006
?
• Draft 2006 303(d) List
• EPA Sector -Specific Permit, 2006 draft
• Check 40 CFR Subchapter N, Stormwater Effluent Guidelines
History:
• 17 February 1995: Original permit was issued. Analytical monitoring was required for the following (with
cutoff concentrations): TSS (100 mg/L), COD (120 mg/L), Hg (0.0024 mg/L), and pH (6-9). (One sample
in the first and last years.) Visual monitoring was required. Vehicle maintenance was also required for: pH
(6-9), oil and grease (30 mg/L), total recoverable lead (0.033 mg/L), TSS (100 mg/L), and detergents
(MBAS) (0.50 mg/L).
• 17 April 1995: Corrections to permit (name change, added outfall 004, renumbered outfalls as 003, 004,
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [phone] Customer Service
1-877-623-6748

NCS000779
005, and 006 in order to avoid confusion with their existing wastewater outfalls, 001 and 002.)
• 4 November 1996: Permittee contacted the Division to inform us of an alternative fuel test that was to take
place at their facility. They did not expect any changes to runoff, and provided follow-up data that they
collected during the test.
• 14 April 2000: The permittee designated the Plant Engineer as the Duly Authorized Representative.
• 1 May 2000: Permit issued. Removed pH from the analytical monitoring. Added TN and TP. Samples
quarterly in the fourth year. No cut off concentrations. Qualitative monitoring and vehicle maintenance was
required.
• 4 November 2004: Applicant applied for permit renewal
• 31 May 2005: Pen -nit expired
• 21 August 2006: Ownership change form received (Westmoreland LG&E Partners to Westmorland
Partners).
• 11 January 2007: Division provided a permit renewal status update per the permittee's request.
Figure 1: Map of Facility
2

NCS000229
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Central Office Review Summary:
1. General Observations: Though this facility burns coal, the data provided do not suggest any significant stormwater
concerns onsite. The coal is contained in a handling and storage area. Stormwater from the coal area is collected and
routed into the coal pond for containment, detention, and treatment per their Pretreatment Industrial User Permit.
The coal pond is concrete, and is sized for the 25 -year, 24-hour storm plus freeboard. (This is the volume
requirement for mine dewatering in our General Permit.)
2. Impairment: The Roanoke River is not impaired and is not discussed in the 2006 Basinwide Plan. fish advisory
— Mercury has been expanded basinwide, so is not addressed specifically in the narrative about the Roanoke
River.
3. Location: Drains to Segment 23-(26) of the Roanoke River, which is class C. Segment 23-(26) is located from a
line across the river 50 feet downstream from NC Highway 48 Bridge to 18 -mile marker at Jamesville. Segment
3
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Central Office Review Summary:
1. General Observations: Though this facility burns coal, the data provided do not suggest any significant stormwater
concerns onsite. The coal is contained in a handling and storage area. Stormwater from the coal area is collected and
routed into the coal pond for containment, detention, and treatment per their Pretreatment Industrial User Permit.
The coal pond is concrete, and is sized for the 25 -year, 24-hour storm plus freeboard. (This is the volume
requirement for mine dewatering in our General Permit.)
2. Impairment: The Roanoke River is not impaired and is not discussed in the 2006 Basinwide Plan. fish advisory
— Mercury has been expanded basinwide, so is not addressed specifically in the narrative about the Roanoke
River.
3. Location: Drains to Segment 23-(26) of the Roanoke River, which is class C. Segment 23-(26) is located from a
line across the river 50 feet downstream from NC Highway 48 Bridge to 18 -mile marker at Jamesville. Segment
3

NC5000229
23-(25.5) is immediately upstream of this segment. Segment 25-25 is upstream of Segment 23-(25.5). Segment
23-(53) is downstream of Jamesville.
Figure 2: Determining Location: NC Highway 48 Bridge
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Figure 3: Determining Location: Jamesville
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4. Changes Since Previous Permit: A dirt berm was constructed around the Bulldozer Refueling Storage Tank and
the hose connection on the Main Oil Storage Tank was relocated inside the secondary containment.
5. EPA Sector -Specific Permit: 40 CFR Subchapter N requires stormwater effluent guidelines for some industries
including coal pile runoff at steam electric generating facilities such as this facility. For steam generating
industries, the EPA recommends total recoverable iron (1.0 mg/L) and TSS. The Division considers iron to be
an ubiquitous substance that generally does not need to be monitored. (1994 Stormwater Permitting
Development memo, Coleen Sullins). For coal mining and coal mining related industries, the EPA recommends
total recoverable iron, total recoverable aluminum (0.75 mg/L), and total suspended solids.
6. Analytical Monitoring: None of the samples were above the current benchmarks, as shown in Table 1.
4

NCS000229
7. Qualitative Monitorine: The qualitative data did not pose any concerns. It is not summarized in this report.
Table 1: Analytical Monitoring
Outfall
Required
Sample
Range
Sample
Date
COD
TSS
Hg
TN
TP
Benchmark: Benchmark: Benchmark: Benchmark:
120 mg/L 100 mg/L <0.0014 mg/L 30 mg/L
Benchmark:
2 mg/L
003
1 Jun 03 -
31 Aug 03
31 -Aug -03
47
25
<0.0002
0.55
0.05
004
35 2 <0.0002 1.38
<0.05
005
68 65 <0.0002 1.56
0.17
006
104 22 <0.0002 2.99
0.17
003
1 Sep 03 -
30 Nov 03
19 -Nov -03
25
17
<0.0002
0.11
0.08
004
61 73 <0.0002 1.02
28 64 <0.0002 1.26
0.14
0.19
005
006
52 59 <0.0002 1.68
0.20
003
1 Dec 03 -
29 Feb 04
2_Mar-04
83
90
<0.0002
3.92
0.12
004
14 32 <0.0002 0.89
<0.05
005
<10 <1.0 <0.0002 1.59
<0.05
006
59 26 <0.0002 2.72
0.13
003
1 Mar 04 -
31 May 04
15 -Mar -04
49
36
<0.0002
2.88
0.1
004
33 15.5 <0.0002 3.08
0.14
005
37 8.7 <0.0002 1.29
0.09
006
18 63.5 <0.0002 0.13
0.13
Revised Permit Recommendations: Analytical Monitoring:
1. Mercury has been removed from the analytical monitoring requirements because it was below detectable limits
during the previous cycle. The source of mercury at the facility is the coal. Online data show that bituminous
coal contains -0.11 mg/L mercury. This is above the detection limit that the facility used for the previous cycle
(0.0002 mg/L). If there was a significant source of mercury onsite, I believe it would have been detected in the
stormwater for the previous cycle, but it was not.
2. TN and TP have been removed from the analytical monitoring requirements. The stream classification for the
previous permit showed that the receiving stream was Wolf Swamp and NSW. That was incorrect. The
receiving stream is the Roanoke River, which is not NSW.
3. Aluminum has been added to the analytical monitoring requirements per EPA's recommendation. Do you plan
any explanation of EPA's position in the new permit, i.e. why the concern for Aluminum?
4. pH has been added to the analytical monitoring requirements.
5. Due to a potential lag time between the expiration of this permit and its renewal, I have specified in the permit
that the permittee is responsible for all monitoring until the renewal permit is issued. See Footnote 1 of Tables
1, 4, and 5. This approach is recommended because there has been a significant lag time since the expiration of
the previous cycle. This will provide testing if there is a lag in future timeframes. "Measurement Frequency: All
analytical monitoring will be performed two rimes per year for each year until either another permit is issued for
this facility or until this permit is revoked or rescinded. If at the end of this permitting cycle, the permittee has
submitted the appropriate paperwork for a renewal application before the submittal deadline, the permittee will
be considered for a renewal application. The applicant must continue semi-annual analytical monitoring until
the renewed permit is issued. See Table 2 for schedule of monitoring periods through the end of this permitting
cycle."
6. Benchmarks have been added to this draft permit.
7. All analytical monitoring has been set to semi-annually.
8. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainfall and event
duration parameters are in this permit, however.) (There was no flow requirement in the previous permit.)
9. The permittee is required to collect all of the analytical monitoring samples during representative storm events as

NCS000229
defined in this permit. Qualitative monitoring does not have to be performed during a representative storm
event.
It will be at the permittee's discretion, but they may wish to sample upstream of Outfall 001 because there is flow
into that outfall from the Industrial Park. This was mentioned in the inspection report.
Other Proposed Changes to the Previous Permit:
1. Part II Section A has been revised. It now specifies all of the items to include on the site map.
2. Vehicle maintenance has been revised to semi-annually in order to coincide with analytical and qualitative
monitoring. They do not meet the Vehicle Maintenance threshold at this time, so are not sampling for those
parameters.
3. I will mention in the cover letter that Form SWU-242-020705 is available for qualitative monitoring. f C)
Discussions with permittee: Chris Hughes Hews, 252.536.3200x232, 23 March 2007 Recently named
Environmental Manager
1. What additional changes have occurred at your facility since your permit application?
a. ANSWER: No significant process changes have taken place.
2. Do you conduct vehicle maintenance onsite?
a. ANSWER: No significant volume of oil generated.
3. Is there a source of mercury at your facility? Mercury has been an analytical requirement in your previous
permits, but you have not had detectable limits. Mercury does not appear in the EPA recommended sampling
requirements for your industry.
a. ANSWER: Coal has a minimal amount of mercury in it, but they generally have very low analytical
mercury testing for both air and water.
4. What type of fuel do you currently use at your facility? In 1996 you did a feasibility test for petroleum coke. Did
you begin using this fuel after the test, or are you still using bituminous coal?
a. ANSWER: Eastern Bituminous
Do you bring in coal, or do you mine it onsite? The EPA recommends total recoverable aluminum and total
recoverable iron sampling for coal mining facilities
a. ANSWER: It is shipped in.

NCS000229
Recommendations: Based on the documents reviewed, the application information submitted on 4 November 2004
sufficient to issue an Individual Stormwater Permit.
Prepared by (Signature) Date 313,0107
Stormwater Permitting Unit Supervisor L Date 3 L�
Concurrence by Regional
Water Quality Supervisor i'j 1A Date d`
Regional Office Staff Comments
This facility has a good program that is proactively carried out. Please see the attached inspection report.

NCS000229
Recommendations: Based on the documents reviewed, the application information submitted on 4 November 2004
sufficient to issue an Individual Stonnwater Permit.
Prepared by (Signature) r Date
Stormwater Permitting Unit Supervisor PU� Date 0/1
O 7
Concurrence by Regional
Water Quality Supervisor
Regional Office Staff Comments
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