NCS000106_Representative Outfall Status Documentation_20090611

Davis, Neal
jdffllhFrom: Pickle, Ken [ken.pickle®ncdenr.gov]
Sent: Thursday, June 11, 2009 4:36 PM
To: Ransmeier, MARY
Cc: myrl.nisely*ncmail.net; Davis, Neal; Bennett, Bradley; Lowther, Brian
Subject: RE: KapStone Kraft NCS000106
Dear Ms. Ransmeier,
Thanks for being available on such short notice for our unscheduled visit. It really helps the permitters when
we can see the site conditions. Based on your note, we are in agreement as to the Storeroom Outfall and as to the
sample point for the Tent Outfall. I've re -stated below your points just to confirm our agreement on them; please
contact us if I have missed any minor point.
I have relayed our conversation and my observations at Kapstone to your permit writer, Brian Lowther, and to
our supervisor, Bradley Bennett. Please take this note as written confirmation of certain comments I made while on
your site. Specifically, as to your current coverage under the expired individual permit, NCS000106, you are authorized
for Representative Outfall Status from this time forward. DWQ will consider the Tent Outfall representative of the
stormwater discharges from both the Tent Outfall and the Storeroom Outfall, until and unless significant changes in on -
site activities suggest that the Representative Outfall Status is no longer appropriate. Scheduled analytical samples
need only be taken for the Tent Outfall. Visual monitoring is to be continued at both outfalls. Further, we are in
agreement with the relocation of the sample point for flows from the Tent Outfall to a location further downstream
than previously located. As you note and as we discussed, the new location will be close to, but still upstream of the
junction with the large flows from off site, i.e. the city stormwater flows.
Akftk
As to provisions in the pending renewed permit, we intend that the Representative Outfall Status will continue
for the Tent Outfall, and we will so note in the transmittal letter that will accompany the renewed permit.
Administratively it has been our practice to address the granting of Representative Oufall Status by separate letter
outside of the permit text, and we propose to continue that practice if you do not object. Similarly, on large and
complicated sites we typically do not direct the exact location of stormwater sampling, unless we see a need to. We are
in agreement with the current proposed location further downstream, and are agreeable for that location to be
continued under the renewed permit. Please contact us for concurrence if you subsequently judge that another location
might be more representative of the stormwater flows from your site.
Ken Pickle
DWQ Stormwater Permitting Unit
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