NCS000348_Application_20100309

NR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
March 9, 2010
Mr. Lynette Bryan
Capital Power Operations (USA) Inc.
PO 10836
Southport, North Carolina 27573
Subject: Draft NPDES Stormwater Permit
Permit No. NCS000348
Southport Facility
Brunswick County
Dear Ms. Bryan:
Dee Freeman
Secretary
Enclosed with this letter is a copy of the draft stormwater permit for your facility. Please review the draft
very carefully to ensure thorough understanding of the conditions and requirements it contains.
The draft permit contains the following significant changes from this facility's current permit:
Analytical monitoring changes:
1. Analytical monitoring parameters including 15 metals, sulfate, and oil & grease have been added to
this permit as an effort to investigate the pollution potential of stormwater discharges.
2. pH has been added to the analytical monitoring requirements.
3. All analytical monitoring has been set to semi-annually during a representative storm event as defined
in Part II Section B. The permittee must also document the total precipitation for each event. If no
discharge occurs during the sampling period, the permittee must submit a monitoring report indicating
"No Flow" within 30 days of the end of the three-month sampling period. Additionally, samples must
be taken a minimum of 30 days apart, as specified in Table 2.
4. No documentation of representative outfall status was found. Please monitor for at all outfalls.
Representative outfall status can be requested filling out the Representative Outfall Status (ROS)
Request on our website.
5. Benchmarks for analytical monitoring have been added to this draft permit. Exceedances of
benchmark values require the permittee to increase monitoring, increase management actions,
increase record keeping, and/or install stormwater Best Management Practices (BMPs) in a tiered
program. If the sampling results are above a benchmark value, or outside of the benchmark range, for
any parameter at any outfall then the facility shall follow the Tier 1 guidelines which require a facility
inspection within two weeks and implementation of a mitigation plan within two months. If during the
term of this permit, the sampling results are above the benchmark values, or outside of the benchmark
range, for any specific parameter at a specific discharge outfall three times in a row (consecutive),
then the facility shall follow the Tier 2 guidelines which require a repetition of the steps listed for Tier 1
and also immediately institute monthly monitoring for all parameters at every outfall where a sampling
result exceeded the benchmark value for two consecutive samples.
6. You are required to collect all of the analytical and qualitative monitoring samples during
representative storm events as defined in Part II Section B. Qualitative monitoring is required at all
outfalls regardless of representative outfall status.
7. You are responsible for all monitoring until the renewal permit is issued.
8. The flow reporting requirement has been removed per DWQ revised strategy. (The total rainrall
parameter is in this permit, however.)
9. Vehicle maintenance monitoring has been revised to semi-annually. This requirement appears in all
Individual Stormwater permits; however it only applies to facilities that do vehicle maintenance. If the
facility begins vehicle maintenance during the permitted timeframe then the requirements shall apply.
Wetlands and Stormwater Branch One
1617 Mail Service Center, Raleigh, North Carolina 27699.1617 Noce t tC�ayrT olina
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Cl�
Phone: [phone] \ FAX: [phone] \ Customer Service: 1.877-623-6748 at6�6[ �
Internet: www.iicwaterqualit .org
An Equal Opportunity \ Affirmative Action Employer

Ms. Lynette Bryan
Capital Power Operations (USA) Inc.
Permit No. NCS000348
Other permit changes:
1. Additional guidance is provided about the Site Plan requirements. The site map must now identify if
the receiving stream is impaired and if it has a TMDL established. It must also describe potential
pollutants in each outfall. The map requirements are stated more explicitly. And, the site plan must
contain a list of significant spills that have occurred In the past three years and also rnusl c;erlify lhdl
the outfalls have been inspected to ensure that they do not contain non-stormwater discharges.
Additional information is provided in Part II Section A.
2. Additional requirements for the Stormwater Management Plan have been specified in Part II Section A.
More details regarding secondary containment are provided.
3. Additional requirements for the Stormwater Pollution Prevention Plan have been specified in Part II
Section A. The plan must also be updated annually to include a list of significant spills and to certify
that the outfalls do not contain non-stormwater discharges.
4. The facility must now implement a semi-annual Facility Inspection Program of the site's stormwater
management controls as specified in Part II Section A.
5. Information regarding the No Exposure Exclusion has been added to this draft permit. If industrial
materials and activities are not exposed to precipitation or runoff as described in 40 CFR §122.26(g),
the facility may qualify for a No Exposure Exclusion from NPDES stormwater discharge permit
requirements. Additional information is provided in Part I 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 at the bottom of page one 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]
Sincerely,
1_1111-el�
Z"Z_�
Brian Lowther
Environmental Engineer
Stormwater Permitting Unit
cc: Wilmington Regional Office
Stormwater Permitting Unit
Attachments: Draft Permit

General Permit
Part $ — Sector -Specific Requirements for Industrial Activity
Subpart C — Sector ® — Stearn Electric Generating Facilities.
You must comply with Part 8 sector -specific requirements associated with your primary
industrial activity and any co -located industrial activities, as defined in Appendix A. The sector -
specific requirements apply to those areas of your facility where those sector -specific activities
occur. These sector -specific requirements are in addition to any requirements specified
elsewhere in this permit.
$,0,1 Covered Stormwater Discharges.
The requirements in Subpart O apply to stormwater discharges associated with industrial
activity from Steam Electric Power Generating Facilities as identified by the Activity Code
specified under Sector O in Table D-1 of Appendix D.
�.0.2 Industrial Activities Covered by Sector ®.
This permit authorizes stormwater discharges from the following industrial activities at
,tor 0 facilities:
.2.1 steam electric power generation using coal, natural gas, oil, nuclear energy, etc., to
Produce a steam source, including coal handling areas;
12.2 coal pile runoff, including effluent limitations established by 40 CFR Part 423; and
2.3 dual fuel facilities that could employ a steam boiler.
?;3 I imitations on Coverage.
3..1 Prohibition of Non-StormwaterDischarges. Non-stormwater discharges subject to
effluent limitations guidelines are not covered by this permit.
3.2 Prohibition of Stormvvater Discharges. Stormwater discharges from the following are
not covered by this permit:
$.0.3.2.1 ancillary facilities (e.g., fleet centers and substations) that are not contiguous
to a stream electric power generating facility;
8.0.3.2.2 gas turbine facilities (providing the facility is not a dual -fuel facility that
includes a steam boiler), and combined -cycle facilities where no supplemental
fuel oil is burned (and the facility is not a dual -fuel facility that includes a
steam boiler); and
rt
8:0.3.2.3 cogeneration (combined heat and power) facilities utilizing a gas turbine.
4 f Additional 'Technology -Based Effluent Limits. The following good housekeeping
measures are required in addition to Part 2.1.2.2e
1 fugitive Dust Emissions. Minimize fugitive dust emissions from coal handling areas.
To minimize the tracking of coal dust offsite, consider procedures such as installing
e
,,charges Associated with Industrial Activity — Sector 0
103

General Permit
specially designed tires or washing vehicles in a designated area before they leave the
site and controlling the wash water.
8.0.4.2 Delivery Vehicles. Minimize contamination of stormwater runoff from delivery vehicles
arriving at the plant site. Consider procedures to inspect delivery vehicles arriving at the
plant site and ensure overall integrity of the body or container and procedures to deal
with leakage or spillage from vehicles or containers.
8.0.4.3 Fuel Oil Unloading Areas. Minimize contamination of precipitation or surface runoff
from fuel oil. unloading areas. Consider using containment curbs in unloading areas,
having personnel familiar with spill prevention and response procedures present during
deliveries to ensure that any leaks or spills are immediately contained and cleaned up,
and using spill and overflow protection devices (e.g., drip pans, drip diapers, or other
containment devices placed beneath fuel oil connectors to contain potential spillage
during deliveries or from leaks at the connectors).
8.0.4.4 Chemical Loading and Unloading. Minimize contamination of precipitation or surface
runoff from chemical loading and unloading areas. Consider using containment curbs at
chemical loading and unloading areas to contain spills, having personnel familiar with
spill prevention and response procedures present during deliveries to ensure that any
leaks or spills are immediately contained and cleaned up, and loading and unloading in
covered areas and storing chemicals indoors. .
8.0.4.5. Miscellaneous Loading and Unloading Areas. Minimize contamination of precipitation
or surface runoff from loading and unloading areas. Consider covering the loading area;
grading, berming, or curbing around the loading area to divert ruji-on; locating the
loading and unloading equipment and vehicles so that leaks are contained in existing
containment and flow diversion systems; or equivalent procedures.
8.0.4.6 Liquid. Storage. Tanks. Minimize contamination of surface runoff from above -ground
liquid storage tanks. Consider protective guards around tanks, containment curbs, spill
and overflow protection, dry cleanup methods, or equivalent measures.
8.0.4.7 Large Bulk Fuel Storage Tanks. Minimize contamination of surface runoff from large
bulk fuel storage tanks. Consider containment berms (or their equivalent). You must
also comply with applicable State and Federal laws, including Spill Prevention, Control
and Countermeasure (SPCC) Plan requirements.
8.0.4.8 Spill Reduction Measures. Minimize the potential for an oil or chemical spill, or
reference the appropriate part of your SPCC plan..Visually inspect as part of your
routine facility inspection the structural integrity of all above -ground tanks, pipelines,
pumps, and related equipment that may be exposed to stormwater, and make any
necessary repairs immediately.
8.0.4.9 Oil -Bearing Equipment in Switchyards. Minimize contamination of surface runoff from
oil-bearing equipment in switchyard areas. Consider using level grades and gravel surfaces
to retard flows and limit the spread of spills, or collecting runoff in perimeter ditches.
8.0.4.10 Residue -Hauling Vehicles. Inspect all residue -hauling vehicles for proper covering over
the load, adequate gate sealing, and overall integrity 'of the container body. Repair
E
Stormwater Discharges Associated With Industrial Activity — Sector 0 104

General Permit
vehicles without load covering or adequate gate sealing, or with leaking containers. or
beds.
8.0.4.11 Ash Loading Areas. Reduce or control the tracking of ash and residue from ash loading
areas. Clear the ash building floor and immediately adjacent roadways of spillage,
debris, and excess water before departure of each loaded vehicle.
8.0.4.12 Areas Adjacent to Disposal Ponds or Landfills. Minimize contamination of surface
runoff from areas adjacent to disposal ponds or landfills. Reduce ash residue that may
be tracked on to access roads traveled by residue handling vehicles, and reduce ash
residue on exit roads leading into and out of residue handling areas.
8.0.4.13 Landfills, Scrap yards, Surface Impoundments, Open Dumps, General Refuse Sites.
Minimize the potential for contamination of runoff from these areas.
8.0.5 Additional SWPPP Requirements.
8.0.5.1 Drainage Area Site Map. (See also Part 5.1.2) Document in your.SWPPP the locations
of any of the following activities or sources that may be exposed to precipitation or
surface runoff: storage tanks, scrap yards, and general refuse areas; short- and long-term
storage of general materials (including but not limited to supplies, construction
materials, paint equipment, oils, fuels, used and unused solvents, cleaning materials,
paint, water treatment chemicals, fertilizer, and pesticides); landfills and construction
sites; and stock pile areas (e.g., coal or limestone piles). -
8.0.5.2 Documentation of Good Housekeeping Measures. You must document in your SWPPP
the good housekeeping measures implemented to meet the effluent limits in Part 8.0.4.
8.0.6 Additional Inspection Requirements.
8.0.6.1 Comprehensive Site Compliance Inspection. (See also Part 4.3) As part of your
inspection, inspect the following areas monthly: coal handling areas, loading or
unloading areas, switchyards, fueling areas, bulk storage areas, ash handling areas,
areas adjacent to disposal ponds and landfills, maintenance areas, liquid storage tanks,
and long term and short term material storage areas.
8.0.7 Sector -Specific Benchmarks
Table 8.0-1 identifies benchmarks that apply to the specific subsectors of Sector 0.
These benchmarks apply to both your primary industrial activity and any co -located industrial
activities, which describe your site activities.
Table 8.0-1.
Subsector
Benchmark
(You may be subject to requirements for more than one
Parameter
Monitoring
sector/subsector)
-
Concentration
Subsector 01. Steam Electric Generating Facilities (Industrial
Total Iron
1.0 mg/L
Activit Code "SE"
Stormwater Discharges Associated With Industrial Activity — Sector 0 105

General Permit
8.0.8 Effluent Limitations Based on Effluent Limitations Guidelines (See also Part 6.2.2.1
of the permit.)
Table 8.0-2 identifies effluent limits that apply to .the industrial activities described
below. Compliance with these effluent limits is to be determined based on.'discharges from these
industrial activities independent of commingling with any other wastestreams that may, be.
covered under this permit.
Table 8.0-21
Industrial Activity
Parameter
Effluent Limit
Discharges from coal storage piles at Steam Electric
Generating Facilities
TSS
50 mg/12
pH
6.0 min - 9.0 max
ivionnor annually.
2 If your facility is designed, constructed, and operated to treat the volume of coal pile runoff that is associated with
a 10-year, 24-hour rainfall event, any untreated overflow of coal pile runoff from the treatment unit is not subject to
the 50 mg/L limitation for total suspended solids.
Stormwater Discharges Associated With Industrial Activity — Sector 0 106

Monitoring Strategy for Power Plant NPDES Stormwater
Permit Renewals in 2009
Renewal Permit Monitoring:
In recent years, the Stormwater Permitting Unit has recognized the complex issues
associated with coal -burning power plants and the increased attention on coal ash storage,
use, and disposal at these sites. Data on stormwater discharges from these plant sites is
limited because the focus has traditionally been on wastewater. Regions have also voiced
concern about potential contamination from metals in stormwater discharges associated
with the activities at these sites. After researching constituents these activities or materials
may introduce to the power plant property (and with them potential for stormwater
pollution), the Unit formulated a strategy for these renewal permits:
Basis: 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. SPU also discussed contaminants
with Duke University researcher, Dr. Avner Vengosh, who researched the TVA ash pond
spill that occurred in Dec 2008 in Kingston, TN (Mtg with SPU on May 4, 2009). In
addition, RRO/DWQ has sampled discharges from cogeneration plants in the FRO area
and flagged metals of concern. Overall, we have very little data with which to
characterize stormwater discharges from this industry, but we know there is a concern
and need for better understanding about possible stormwater pollution from the
activities here.
(FYI - Cost of clean
mercury.method around $100.) .
Basis: Power plants area potential major source of mercury,. and although some Hg
maybe regional, there is a risk that significant quantities come from the activities at
the plant itself. While wastewater permit limits are calculated based on low stream
flow and high wastewater effluent flow conditions —and sometimes do not warrant
the lower -detection method—stormwater contributions vary broadly and do not
change the bio-accumulative nature of methyl -mercury. SPU recognizes the
complexity of -regional air transport and deposition, as well as the cost and .resources
involved in clean mercury sampling protocol, and therefore. will exempt Hgfrom
monthly monitoring in the tier structure. However, if mercury data suggest a problem
driven by sources or activities at the plant, DWQ should investigate further and could
require additional monitoring in the future.
Semi annual monitoring for COD, TSS, pH, sulfaes, and 0&G
Basis: conventional pollutants associated with types of activities here. Note -include
provision to allow pH values below benchmark if facility can document rainfall pH is
as low or lower at time of sampling.
1
Last revised 912212009

0
Per
Basis: Consistency with current draft General Permits and to facilitate prompter
awareness of monitoring results at the regional office level,
example, plants might consider installing bioretention cells for drainage areas
where metals are a problem and monitor for effectiveness, in exchange for
decreased monitoring frequency and/or no benchmark trigger. We will also
consider relieving monitoring if the facility can demonstrate levels are not
attributable to, or else not able to be separated from, industrial activities. SPU will
wo.rkwith the regional offices to address situations on a case -by -case basis.
Basis: SPU recognizes the ubiquitousness of copper and zinc, and the low benchmark
concentrations for metals like Cd, but we also know activities at power plants can be
contributors of these pollutants. SPUfeels alternatives to more monitoring can
facilitate solutions and that the permit tier structure is flexible enough to relieve the
permittee of monitoring when appropriate.
Federal effluent guidelines apply specifically to the Steam Electric Generating
industry, which excludes cogeneration facilities. However, cogeneration plants are
similar in many respects, and coal storage and handling activities may even be
identical. SPU will consider a tailored approach for certain SDOs based on proximity
to coal sources, storage area size, etc. Depending on the size and similarity of the
coal storage and handling (and perhaps other factors), the permit writer could
decide to (a) apply limits initially, or (b) an arrangement where benchmarks
mirroring BPT requirements for coal pile leachate in 40 CFR §423 (TSS of SO mg/l
and pH 6-9 SU) would become limits after two exceedences (i.e., Tier 2 action), or
(c) just impose benchmarks.
Basis: Federal stormwater effluent limits apply to coal piles at steam electric
generating facilities; similarity of cogeneration plants (and even elsewhere) warrant
similar scrutiny. Other states such as Virginia, Ohio, and Georgia have already
imposed the same BPT limits on coal pile runoff and leachate at facilities where coal
burning for steam electric generation is not necessarily the primary industrial activity.
The flexibility for North Carolina to do the same follows that lead and acknowledges
the potential for the same pollution problems.
2
Last revised 912212009

Monitoring Strategy for Power Plant NPDES Stormwater
Permit Renewals in 2009
Relevant E-mail Correspondence:
----- Original.Message-----
From: Jones, Jennifer M. [mailto:[e-mail]] .
Sent: Monday, May 04, 2009 9:05 AM
To: Bethany Georgoulias; Ken Pickle; Cory Larsen; [e-mail];
Jennifer Jones
Cc: Bradley Bennett; 'Robert Patterson'; Mike Randall
Subject: RE: Power Plants & SW Permit Strategy
Just talked to Robert Schreusdale @ RTI.
He.said our list of analytes sounds good but we should consider adding Cobalt and
Iron. I mentioned the concerns with Iron ubiquitousness but he said that it may
be present at such high levels that it's a concern.
He suggested background monitoring - I told.him the concerns we have with that.
-----Original Message -----
From: Hoban, Autumn
Sent: Tuesday, luly 07, 2009 11:52 AM
To: Lawyer, Mike
Cc: Brower, Connie; Jones, Jennifer; Georgoulias, Bethany
Subject: Correction on FRO Power Plant Sampling Qualification
Mike,
Just needed to follow up on e-mail from April 9, 2009. This e-mail is inserted
between the number lines below in light blue:
I have the lab results from the FRO power plant visits.
***Lumberton NCO058297
outfall 003 - *Arsenic 3.8 ug/L*, *Copper 31 ug/L*, *Nickel 15 ug/L*, Titanium 29
ug/L., and *Zinc 390 ug/L*, *A1 400ug/L*
SW1- *Al 4400 ug/L,* *Arsenic 3.6 ug/L*, *Copper 14 ug/L*, *Titanium 220 ug/L*,
*Zinc 420 ug/L*
Elizabethtown NCO058301
outfall 003 wastewater -*Copper 22 ug/L*, Zinc 20 ug/L
outfall 005 SW- Zinc 11 ug/L
I bolded possible concerns*, "this data is not adequate for determining
compliance."
*
These samples went to lab the same time their freezer went out, so data is
qualified -not the best situation, but for identifying what's there, I think this
is relatively accurate.
Another sampling event would be needed, especially at Lumberton. Sampling should
probably be done at the Progress Energy Plant nearby that has the ash pond.
3
Last revised 914212009

PermitMonitoring Strategy for Power Plant NPDES Stormwater
Renewals009
These two facilities have coal piles, but no ash ponds on site and neither
facility has been operating consistently. Neither was operating the day we
sampled. If operating expect these would be higher.
Just let me know if I can be of assistance.
Connie has so kindly pointed out that the metals sample results would not be
effected by the freezer/cooler issues experienced at lab, so my statement about
"results not being adequate.to determine compliance" is incorrect. Please review
the laboratory sections qualifiers by each analyte to determine which analytes
were qualified. If you have not received a copy of the results from the lab, I
can scan and send the copies that came to RRO.
Can you let me know if anyone is evaluating Lumberton Site "SW1 outfall" and "WW
Outfall 003" with regards to permit requirements and these sample results. We
may want to resample, since some levels in these results seem unusually high, but
that's.up to FRO.
Sorry for the confusion.
-----Original Message-----
From: Drew Zurow[mailto:[e-mail]]
Sent: Tuesday, July 28, 2009 8:56 AM
To: Georgoulias, Bethany
Cc: Larry Hedges
Subject: Re: [stormwater] Coal Pile.Runoff SW Effluent Limitations
Bethany,
Georgia's general industrial stormwater permit has TSS/pH limits for all coal
pile runoff, whether or not thethe source is a Steam Electric Generating Plant.
This has been the case since our first industrial stormwater permit issuance in
1993. We have not yet seen a good reason to modify our original permit language
and exclude facilities that are not Steam Electric Generating Plants from these
limits.
4
Last revised 912212009

Primary Energy - Southport Facility
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8.2.3 BMP Summary
Table 8.1 below summarizes the BMPs used at the Southport Plant.
Potentially exposed materials at the Primary Energy plant include coal, petroleum products stored in
existing ASTs, water treatment chemicals, and ash. Coal for the boiler plant is stored outside in the coal
pile and coal pile runoff is treated in the low volume wastewater system prior to discharge (i.e., it is not
drained to the storm water system). Coal is brought in by rail at the west end of the plant and unloaded
daily through the coal chute and transported via conveyor belt to the coal pile. The risk of coal dust
entering the storm water via fugitive dust exists and minimize that risk, coal unloading BMPs are used and,
because the drainage from the DAl area is through vegetative buffers, the quantity of coal reaching the
receiving water is minimal. Water is sprayed onto the coal as it is unloaded from the rail cars in one of the
coal unloading BMPs. Also, coal dust from the edges of the chute where coal is deposited is swept up daily
after unloading operations. These BMPs, coupled with the comparatively limited surface area draining to
the storm water system in the western plant site, minimize fugitive dust transport.
The risk of the petroleum products entering the storm system is low due to the use of secondary
containment that conforms to 40 CFR 112.8(c)(2) and non-structural controls (e.g., routine inspections) to
prevent spills. Used kerosene is stored in a 250-gallon aboveground storage tank (AST) located at the
Drum Storage Area. Safety Kleen removes the used oil as needed. Diesel is stored in a 300-gallon AST
inside the Demineralizer Building and in a 1,000-gallon AST located within the Rail Car Unloading Area
secondary containment. Quarles supplies Primary Energy with diesel as needed. There are dedicated
unloading bays at each location.
Chemical storage and usage is limited to the Demineralizer Building area and the RO Building area. The
several chemical storage units in the Demineralizer Building are all equipped with secondary containment
and, any spills are routed to the Neutralization Tank and then the Wastewater Basin for treatment. A spill
kit is located inside the water treatment building. There is a dedicated unloading bay at the Demineralizer
Building. The chemicals used in the RO Building are stored a chemical skid on the floor in the building.
The floor is sloping towards a drain that discharges into the chemical sump from the Demineralizer
Building.
The risk of ash or ash residue entering the storm system is low due to the use of dikes and non-structural
controls (i.e. curtain). As the truck enters the ash loading area, a curtain is dropped from the ceiling of the
ash loading area to the ground. This procedure minimizes fugitive dust due to the ash loading. When the
ash loading is complete, the ash loading area floor is thoroughly hosed down to minimize the tracking of
ash residue. The ash loading areas are located in the western portion of Drainage Area 5, and as such, are
treated at the onsite waste water treatment plant.

Integrated SPCC/SWPPP
Primary Energy of NC, LLC - Southport Plant
Table 8-1. Inventory of Materials Exposed to Precipitation
2
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DA1 — adjacent to rail
Coal (de minimus)
Good housekeeping BMPs for
Overland flow
spur
rail car unloading
DA2 — adjacent to rail
Coal (de minimus)
Good housekeeping BMPs for
Overland flow
spur
rail car unloading
DA3
None.
None.
None.
DA4 — Demineralizer
None.
None.
None.
Building
DA4 — Point -of -Fill Tote
Proprietary water treatment
Secondary containment with
None.
chemicals (1,000-gal
discharge routed to
capacity)
Wastewater Basin
DA4 — Electric Fire
Transformer oil (125-gal
Secondary containment with
None.
Pump Transformer
capacity)
discharge to Wastewater Basin
DA4 — Materials
None.
Containment with direct
None.
Transfer Bay (at
drainage to Wastewater Basin
Demineralizer Building)
DA4 — Rail Car
Diesel fuel (1,000-gal
Secondary containment with
None.
Unloading Area
capacity); Transformer oil
INSPECTION then discharge to
Secondary Containment
(990-gal capacity)
Storm water system
DA4 — Drum Storage
Used kerosene (250-gal
Secondary containment with
None.
Area
capacity)
INSPECTION then discharge to
Storm water system
DA4 — Laydown Area
Iron/steel equipment and
None.
None.
wood packing materials
(quantity varies)
DA5 — Transformer
Transformer oil (2 at 9,170-
Gravity discharge to Oil Trap
None.
Yards
gal and 2 at 990-gal capacity)
Pit
DA5 — Oil Trap Pit
Typically none (13,125-gal
Gravity discharge to
None.
capacity)
Wastewater Basin
DA5 — Slaker, Ash Silos,
Fly ash and/or Lime
Gravity discharge to
None.
and ash handling area
(indeterminate)
Wastewater Basin
DA5 — TDF Storage Yard
TDF (>1,000 tons)
Gravity discharge to
None.
Wastewater Basin
DA6 — Switching Yard
Sulfur hexafluoride — gas
None.
None.
DA7
None.
None.
None.
DA8 — near Coal
Coal (de minimus)
Good housekeeping BMPs for
Overland flow
Conveyor
area beneath conveyor
DA9 — Coal Pile
Coal (>1,000 tons)
Gravity discharge to
None.
Wastewater Basin
DA 10
None.
None.
None.
49

Significant Changes in Industrial Activities
In 2006 the Primary Energy Southport Facility added unadulterated wood as an alternative fuel and an RO
building to produce raw water.
The wood is stored in a dedicated storage bin which directs rain runoff to the waste treatment basin via a
vee ditch. Transfer to the blending area is short (less than 50 yds) which minimizes any stormwater
contamination from the transfer process.
Chemical storage and usage in the RO Building area consist of Sodiumm Hypochlorite and coagulant
injections to well water. The dissolved iron in the well water reacts with the Sodium Hypochlorite is then
filtered by multimedia filters prior to purification by the RO unit. The chemicals used in the RO Building
are stored in a chemical skid on the floor in the building. The floor is sloping towards a drain that
discharges into the chemical sump from the Demineralizer Building.