NCS000514_Email_20191008

Garcia, Lauren V
From: Garcia, Lauren V
Sent: Tuesday, October 08, 2019 1:45 PM
To: German, Bryce
Subject: RE: [External] Mount Holly NCS000514 Draft Permit Questions
Hey Bryce,
Sorry it has taken me a bit to get back to you. Since some of your questions involved language revisions and
interpretation, you questions were discussed among several of us here. The following conclusions were made:
1) Operating hours mean operating hours. Not business hours. We understand why you preference is to plan for 8
AM-5 PM on weekdays, and you can make that your goal because it's most practical. But if you miss a sampling
period altogether when there were safe (daylit) hours to sample during operation before or after that window,
or during weekends, we would have a sound basis for compliance/enforcement action. You are advised to plan
for the possibility of not having a pass on that if you are nearing the end of your sample period opportunity and
haven't gotten a sample within that convenient time, given that the place runs 24/7.
2) We can revise the language as such: "Grab samples shall be collected within the first 30 minutes of discharge.
Where physical separation between outfalls prevents collecting all samples within the first 30 minutes, the
permittee shall begin sampling within the first 30 minutes, and shall continue until completed."
3) You are correct, the Lab Cert rules do not apply to stormwater-only discharges. But it does not relieve the
burden of the facility to properly measure and the pH with appropriate and calibrated equipment within the 15-
minute hold time, per approved EPA methods (i.e., it doesn't give them a free pass to use a pH strip
instead). NPDES requirements mandate that across the board.
4) The language in the draft permit for the rain gauge has been updated mainly because the amount can vary quite
a lot in an isolated area. The rain gauge is a basic and expected requirement for compliance, particularly at
construction sites. How far away is the location of the reading from the PWS network? It was discussed that it
may be acceptable if it is within 1 mile of your site.
Let me know if you have any more questions or comments!
Thanks,
Lauren
From: German, Bryce <[e-mail]>
Sent: Monday, September 23, 2019 4:03 PM
To: Garcia, Lauren V <[e-mail]>
Subject: [External] Mount Holly NCS000514 Draft Permit Questions
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Lauren,
In regards to our draft stormwater permit, would you be able to clarify the following points?

1) The requirements for analytical sampling specified in Section B of the draft permit stipulate that sampling is not
required outside of the facility's normal operating hours. Although the facility operates 24/7 (production), the facility
observes normal business hours of 8AM to 5PM five days a week, when non -production personnel (management,
administrative staff, environmental staff) are onsite. As there is no definition in the draft permit, we interpret "operating
hours" in this case to be the facility's business hours as defined above. Please advise if you concur with this
interpretation.
2) The draft permit states that grab samples shall be obtained within the first 30 minutes of discharge. We request
additional language to be added to this condition to allow for sampling outside this window with valid documentation of
the reason for noncompliance with the 30 minute window.
3) In order to comply with the fifteen minute holding time for pH, we intend to perform field analysis of grab samples
using test equipment maintained by the facility in accordance with the manufacturer's recommendations. All other
parameters would be analyzed by an NC -certified laboratory. The state of North Carolina has determined that the
certification procedures of 15A NCAC 2H .0800 do not apply to stormwater-only discharges. Please advise if you concur
with this interpretation.
4) In our previous communication I inquired as to the state's position on substituting offsite weather station data from a
public weather network for the onsite rain gauge specified in the draft permit. If this is acceptable, we would request
language be added to the permit to this effect.
Please contact me if you have any questions regarding the above.
Thank you!
Bryce German
Environmental Leader
o. 704.812.2018 1 m. 404.360.8284
Mount Holly Operations
Georgia-Pacific, LLC
Axe `Em Jacks