NCS000304_Outfall Narrative_20180917

OUTFALL NARRATIVE
OUTFALLS — Our 2009 permit lists 4 outfalls, with the removal of the parking lot outfall we
will have 3 outfalls:
• OUTFALL 1 (aka SOUTHEAST OUTFALL): As noted in your email this outfall collects
rainwater strictly from non -industrial activities (i.e. parking lot and landscaped areas).
We therefore agree that it should not be covered under the NPDES permit. Our
attached new topographical map now notes that this area is 'Non Industrial Activity'.
• OUTFALL 2 (aka SOUTH OUTFALL): As indicated in your email there was a project years
ago to help us capture more Stormwater for recycling purposes. This project installed a
pump system at the OUTFALL 2 area which can handle a 2 year storm event. The water
from this outfall is therefore collected and pumped over to the South Stormwater
Collection Pond. Since the collection/pumping system is only built to withstand a 2 year
event, we agree that it should still be captured in the NPDES permit.
• OUTFALL 3 (aka NORTH OUTFALL): The North Outfall is set back in the woods as
indicated on the attached map. This outfall discharges into a creek that runs through our
property. In the past, we have not been able to gather samples from this outfall. Due to
the lay of the land, the outfall only discharges during extreme weather events. Last year,
we spoke with Bethany Georgoulias in regards to sampling this outfall. She informed us
that the state does not require us to go out into extreme weather events to gather
samples. She said it would be sufficient to use the West Outfall samples as
representative data for this outfall (as well as for Outfall 2 in the event that we had a
greater than 2 year storm event and it discharged). We discussed this with you as well
and you also referred to a 'representative' status for this outfall. We understand that
the permit will not list the outfall as a 'representative' status, but that we can note the
representative status on our DMRs.
• OUTFALL 4 (aka WEST OUTFALL): The West Outfall is located back in the woods. It is
made up of a culmination of overflow from the South Stormwater Collection Pond as
well as runoff from the top of the landfill. This runoff and overflow goes through a
culvert where it is treated with CO2, if needed, and then flows into the woods. In the
event that the West Stormwater Collection Pond's pumping system were to
malfunction, or in the event of extreme weather, the West Stormwater Collection Pond
may overflow. This overflow will be captured by Outfall 4. We sample this outfall at the
edge of our property where it is most accessible.
STORMWATER COLLECTION PONDS — Our site captures Stormwater through the
use of 3 stormwater collection ponds. These are separate and not to be confused with our
outfalls. These ponds are strictly for capturing and holding STORMWATER (except for
the west pond which also collects slag cooling water runoff), they do not hold process
water of any kind. In the event of a severe weather event, the ponds may overflow.
Overflow water will flow to one of our 3 OUTFALLS.
SOUTH STORMWATER COLLECTION POND: The South Stormwater Collection collects
rainfall runoff from storm drains throughout the majority of the mill as well as water
from the West Stormwater Collection Pond. Water from this collection pond is pumped

to the North Stormwater Collection Pond. In the event that this South Stormwater
Collection Pond overflows, excess water will pass under a culvert in the road, flow down
the drainage area around the landfill, be treated with CO2 as needed and then make its
way back to OUTFALL 4.
• WEST STORMWATER COLLECTION POND: The West Stormwater Collection Pond consists
of rainfall runoff as well as runoff from slag cooling operations. Water from this pond is
treated with CO2 before it is pumped to the South Stormwater Collection Pond.
• NORTH STORMWATER COLLECTION POND: The North Stormwater Collection Pond
consists of water from storm drains as well as water pumped from the South
Stormwater Collection Pond. The North Stormwater Collection Pond is used as makeup
water for our caster process water pond.