NCS000101_email_20230926

Young, Brianna A
From: Young, Brianna A
Sent: Tuesday, September 26, 2023 9:19 AM
To: Lambe, Brian; Rodak, Andrew
Cc: Lawyer, Mike
Subject: RE: [External] Questions regarding IPRW Stormwater permit
Good morning,
Please see below for responses to your questions on the recently issued permit renewal for International Paper
(NCS000101):
1. The Mill requests that DEMLR clarify oil and grease requirements for all outfalls. In communications with
Brianna Young, she stated that "monitoring for O&G may or may not be required from VMA areas only'which
leaves some room for interpretation. The Mill believes that the only outfall that may be subject to oil and
grease requirements is Outfall E,which would be representative for C& E (both contain chip dumps) and A(oil
unloading). The other areas are covered, and VMA are not routinely conducted there.
As stated in the response to your comments on the draft permit, monitoring and reporting for oil and grease is required
if>55 gallons per month are used on average, and monitoring for Estimated Average Monthly Oil Usage is a standard
monitoring requirement of all individual industrial permits and required for each drainage area with an outfall. Part D-1.
(b) of the issued permit states: "In addition to the grab samples,the average monthly usage of new motor and hydraulic
oil for the facility shall be tracked, recorded, and reported to the Division if it exceeds an average of 55 gallons per
month over the previous twelve (12) months."
2. There are still questions about whether quantitative sampling should be required for Outfall M, as quantitative
sampling has not been required for this outfall in previous permits. The Mill asked for Outfall M to be removed
from the quantitative sampling list in its July 2023 comments letter on the draft permit and was denied. In
addition, if Outfall M is added to the quantitative sampling list, DEMLR will be required to update the eDMR
template. There is no guarantee the new eDMR template would be ready by the time the next DMR needs to
be submitted. This outfall discharges runoff from a drainage area that contains a methanol AST(in
containment), and the majority of runoff in the area around the tank flows into the WWT system. Any
potential impacts to stormwater runoff would be from the (very unlikely) event of a catastrophic failure of a
tanker truck loading event. Therefore,would the quantitative analysis still be required on that outfall,given
that it is not expected to contain pollutants related to industrial activities under normal conditions?
As stated in the response to your comments on the draft permit, quantitative sampling is required for Outfall M as
transport of methanol and other industrial activities occurs in the drainage area.The Stormwater Program understands
that the facility has SOPs in place to prevent material being tracked through the area, however, as the potential
exposure exists, monitoring is required. Regarding eDMR,the Stormwater Program's internal database, which eDMR
pulls from to create reports, has already been updated to have all outfalls and their appropriate monitoring
requirements.The next report to be submitted should contain all required monitoring when the report is created in
eDMR.
3. The Mill would like to confirm with DEMLR which outfalls they currently see falling into which Tier(1, 2, or
3). The Mill believes B, E, and I are in Tier 1 (due to relief granted for B&E during the last permit term),while
Outfall T is in Tier 2. There is a reference on page S of the permit fact sheet that B and E were in Tier 2 during
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the previous permit term;the Mill is assuming that DEMLR means that these two outfalls were in Tier 2 at some
point during the permit term but is unsure of the context of this sentence. The Mill would like to understand
definitively what their Tier starting point is for each outfall in the new permit.
Tier"status" carries forward, i.e., monitoring frequency and any follow-up actions you started under the last permit, but
the "count" of exceedances to move you into a different Tier starts over with the new permit period. Depending on
when Tier Relief was granted, it may no longer be active.As stated on the issued permit cover letter, "Per the policy of
the Stormwater Permitting Program,Tiered Response relief effectively ends at the new permit cycle. Conditions start
over at baseline monitoring, and permittees will have to seek relief again if/when appropriate." Please work with the
Wilmington Regional Office on Tiered Response and Relief actions.
4. DEMLR continues to send communications to Hunter Whiteley, as the facility owner, even the Mill has
requested several times to direct communications only to the facility. (Facility staff are typically cc'ed on these
communications but this is adding an unnecessary layer.) Is this a request to pose to Brianna or Brittany Cook?
As stated in the response to your comments on the draft permit, when sending official permit correspondence, such as
providing a newly issued permit, we must communicate with the person listed as the legally responsible official. When
obtaining additional information, we may communicate with facility contacts only. I apologize for any inconvenience this
may cause.
5. If the Mill is required to conduct the additional sampling listed in Items 1 and 2,the Mill would like to discuss
options for sampling relief with DEMLR.
You may request Representative Outfall Status (ROS) by the following: Submit the completed Representative Outfall
Status (ROS) Request Form with this Stormwater Upload Form. Mail one hard copy of the form and supporting
documents directly to the appropriate Regional Office.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From: Lambe, Brian <[e-mail]>
Sent: Monday, September 25, 2023 3:28 PM
To: Rodak, Andrew<[e-mail]>
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Cc:Young, Brianna A<[e-mail]>
Subject: RE: [External] Questions regarding IPRW Stormwater permit
I think these questions should be directed to central office. However,you may have my two cents.
1. Speaking to the Stephen Greer, environmental manager, during last inspection, he stated that the plant has
issues with quantifying the amount of oil used in certain locations. The main issue he raised was privacy for
methods, forgive my lack of terminology. He also had issues for quantifying the oil used in each drainage area. I
did not have an answer for him.
2. If you would like M to be removed, please feel free to provide a map with a list of potential pollutants and how
they are not impacting outfall M.
3. 1 have not reviewed the data to evaluate what tier each sampling point should be in.
4. 1 don't know the answer to the question
5. We are always open to discussing what is best for the site,the permittee, and the environment.
Brian Lambe
Environmental Specialist
910-796-7313
919-268-1678 cell
State of North Carolina I Environmental Quality I Energy,Mineral and Land Resources
127 Cardinal Drive Extension I Wilmington,NC 28405
910 796 7215 T 1 910 350 2004 F I httn://nor[al.ncdenr.org/web/Ir,
From: Rodak, Andrew<[e-mail]>
Sent: Monday, September 25, 2023 3:05 PM
To: Lambe, Brian <brian.lam [e-mail]>
Subject: [External] Questions regarding IPRW Stormwater permit
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
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Brian:
I am working with IP-RW on a review of their stormwater permit renewal, and there are some items they wish
to address with DEMLR, as follows:
1. The Mill requests that DEMLR clarify oil and grease requirements for all outfalls. In communications
with Brianna Young, she stated that "monitoring for O&G may or may not be required from VMA areas
only" which leaves some room for interpretation. The Mill believes that the only outfall that may be
subject to oil and grease requirements is Outfall E, which would be representative for C & E (both
contain chip dumps) and A (oil unloading). The other areas are covered, and VMA are not routinely
conducted there.
2. There are still questions about whether quantitative sampling should be required for Outfall M, as
quantitative sampling has not been required for this outfall in previous permits. The Mill asked for
Outfall M to be removed from the quantitative sampling list in its July 2023 comments letter on the
draft permit and was denied. In addition, if Outfall M is added to the quantitative sampling list, DEMLR
will be required to update the eDMR template. There is no guarantee the new eDMR template would
be ready by the time the next DMR needs to be submitted. This outfall discharges runoff from a
drainage area that contains a methanol AST (in containment), and the majority of runoff in the area
around the tank flows into the WWT system. Any potential impacts to stormwater runoff would be from
the (very unlikely) event of a catastrophic failure of a tanker truck loading event. Therefore, would the
quantitative analysis still be required on that outfall, given that it is not expected to contain pollutants
related to industrial activities under normal conditions?
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3. The Mill would like to confirm with DEMLR which outfalls they currently see falling into which Tier (1, 2,
or 3). The Mill believes B, E, and I are in Tier 1 (due to relief granted for B &E during the last permit
term), while Outfall T is in Tier 2. There is a reference on page 5 of the permit fact sheet that B and E
were in Tier 2 during the previous permit term; the Mill is assuming that DEMLR means that these two
outfalls were in Tier 2 at some point during the permit term but is unsure of the context of this
sentence. The Mill would like to understand definitively what their Tier starting point is for each outfall
in the new permit.
4. DEMLR continues to send communications to Hunter Whiteley, as the facility owner, even the Mill has
requested several times to direct communications only to the facility. (Facility staff are typically cc'ed
on these communications but this is adding an unnecessary layer.) Is this a request to pose to
Brianna or Brittany Cook?
5. If the Mill is required to conduct the additional sampling listed in Items 1 and 2, the Mill would like to
discuss options for sampling relief with DEMLR.
If you would like to discuss these issues by phone, I am available.
Thanks,
Andrew Rodak, P.E. (NC, SC, MD, VA, GA)
Senior Project Manager
TIRC114 Edinburgh South Drive,Suite 200, Cary, NC 27511
O 919.827.8132 C 919.649.77691 a rod a k(cDtrccompanies.com
Linkedln I Twitter Blo. I TRCcompanies.com
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
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