NC0003298_CORRESPONDENCE_20010510

WDES DOCUWENT SCANMIMG COVER SHEET I
NPDES Permit:
NC0003298
Riegelwood Paper Mill
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
~
Correspondence
+amwwwathwN:'h�'ATtI' Vs.rax�3+"'s v+�
Monitoring Report
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date:
May 10, 2001
1
ThiB documext is r�i�t,sd on reuse a - f ore an '
P P l�r � 9
coateat an the re-Werae aide '

Cluster Rule Meeting
... . d
Subject: Cluster Rule Meeting
Date: Thu, 10 May 2001 17:46:57 -0400
From: Dave Goodrich <dave.goodri ch@ncmail. net>
To: Tom Belnick <[e-mail]>, Mike Myers <Mike, Myers@ncmail. net>,
Susan A Wilson <[e-mail]>,
Jackie Nowell <[e-mail]>
Folks,
You are my four permit writers for the cluster rule permits. Joe is
with Weyco-Plymouth, which will be your permit, Susan. However, it
might be useful for all three of you (or more than Susan) to sit in on
this discussion via conference call. I'll leave it up to you four to
decide. Also, Susan, I'll leave it with you to respond to Betsy
Huddleson who is with WaRO AQ Section. Thanks.
- Dave
Subject: [Fwd.- Cluster Rule Meeting]
Date: Tue, 08 May 2001 17:04:54 -0400
From: Betsy Huddleston <Betsy.H uddleston@ncmail. net>
To: [e-mail]
Robert Tankard and Roger Thorpe will be at this meeting. Robert
suggested I include you or someone you designate in this meeting. We are
trying to plan it for the 21st, 22nd or the 25th of this month.
Conference call participation is fine - travel isn't necessary. Please
let me know if your office wishes to participate and which day is best.
Thanks much.
Subject: Cluster Rule Meeting
Date: Sat, 5 May 2001 08,07:35 -0700
From: "Kloeker, Joe (Plymouth)" <[e-mail]>
To: "'Huddleston, Betsy - DEHNR WRO"' <Betsy. Huddl eston@ncmail. net>
CC: "Lawson, Steve"<[e-mail]>,
"Wynne; Don" <[e-mail]>, i
"Kimball, Bob (Plymouth)" <[e-mail]>
Betsy,
We would like to meet with you and who ever else is appropriate from
the State to explain and discuss our methanol data and ways to calculate
compliance with the cluster rule requirements. We've used several methods
of potentially calculating compliance with our data set (NCASI,. our
corporate recommendation which is derived from NPDES standard accepted
methods and our own modification). The various results, while not
drastically different, would drive us to different levels of spending to
assure compliance. In order to proceed in a timely manner with internal
spending approval we need to know what method will be approved by the State
Agencies for use in demonstrating compliance. Since the Cluster Rules are
some what of a mix of air and water permit compliance we definitely need
some advice, guidance and help for the regulators. Our NPDES permit
application is due the end of November and some modification to our Air
Permit may be required depending on the calculation method approved and
physical modifications required. So we would like to meet as soon as
possible. Could you look at your calendar and consult the other State folks
who need to be involved and suggest a couple of dates and times. This could
take 3 or 4 hours given the complexity of the process and overlapping
1 of2
5/ 1 1 /01 3:23 PM

Cluster Rule Meeting
. ,
issues.
If time allows I would also like to include some discussion around the
required chloroform sampling and testing of the bleach plants effluents.
Some states we operate in are approving methods which differ from EPA
Guidance and we need to get some idea of where NC stands on some issues.
For example flow meters vs. calculating/mass balance for bleach plant
effluent flows and the use of automated samplers rather than manual grab
sampling and compositing.
Thanks, Joe
2 of 2 5/ 1 1 /01 3:23 PM