NCS000101_ROS_20120701

�,1 • • FOR AGENCY USE ONLY
Date Received,
, Division of Water Quality/Surface Water Protection Year Month Day
NCDENR National Pollutant Discharge Elimination System
rNCfiTM CAROLINA DEPARTMENT OF
/ ENVIRONMENT AND NATURAL RESOURCES REPRESENTATIVE OUTFALL STATUS (ROS)
REQUEST FORM
If a facility is required to sample multiple discharge locations with very similar stormwater discharges, the
permittee may petition the Director for Representative Outfall Status(ROS). DWQ may grant Representative
Outfall Status if storm water discharges from a single outfall are representative of discharges from multiple
outfalls. Approved ROS will reduce the number of outfalls where analytical sampling requirements apply.
If Representative Outfall Status is granted,ALL outfalls are still subject to the qualitative monitoring
requirements of the facility's permit—unless otherwise allowed by the permit(such as NCG020000)and DWQ
approval. The approval letter from DWQ must be kept on site with the facility's Storm water Pollution
Prevention Plan. The facility must notify DWQ in writing if any changes affect representative status.
For questions,please contact the DWQ Regional Office for your area(see page 3).
(Please print or type)
1) Enter the permit number to which this ROS request applies:
Individual Permit (or) Certificate of Coverage
N C S 0 0 0 1 0 1 N C G
2) Facility Information:
Owner/Facility Name International Paper Company
Facility Contact Wallace Coverdale
Street Address 865 John L./Riegel Rd.
City Riegelwood State NC ZIP Code 28456
County Columbus E-mail Address [e-mail]
Telephone No. 910 362-4590 Fax:
3) List the representative outfall(s) information (attach additional sheets if necessary):
Outfall(s) I is representative of Outfall(s) S
Outfalls' drainage areas have the same or similar activities? x❑ Yes ❑ No
Outfalls' drainage areas contain the same or similar materials? x❑ Yes ❑ No
Outfalls have similar monitoring results? x❑ Yes ❑ No ❑ No data*
Outfall(s) I is representative of Outfall(s) J
Outfalls' drainage areas have the same or similar activities? Cl Yes ❑ No
Outfalls' drainage areas contain the same or similar materials? ❑ Yes ❑ No Qo
01m
Outfalls have similar monitoring results? ❑ Yes ❑ No ❑ No data* uuu
=z
Outfall(s) is representative of Outfall(s) v^V
Outfalls' drainage areas have the same or similar activities? ❑ Yes ❑ No „ _
Outfalls' drainage areas contain the same or similar materials? ❑ Yes ❑ Now
Outfalls have similar monitoring results? ❑ Yes ❑ No ❑ No data* 7
*Non-compliance with analytical monitoring prior to this request may prevent ROS approval. Specific
circumstances will be considered by the Regional Office responsible for review.
Page 1 of 4
SWU-ROS-2009 Last revised 12/30/2009

Representative Outfall Status Request
4) Detailed explanation about why the outfalls above should be granted Representative Status:
(Or, attach a letter or narrative to discuss this information.) For example, describe how activities and/or
materials are similar.
See attachment
5) Certification:
North Carolina General Statute 143-215.6 B(i) provides that:
Any person who knowingly makes any false statement, representation,or certification in any application, record,
report, plan, or other document filed or required to be maintained under this Article or a rule implementing this
Article;or who knowingly makes a false statement of a material fact in a rulemaking proceeding or contested case
under this Article;or who falsifies,tampers with, or knowingly renders inaccurate any recording or monitoring device
or method required to be operated or maintained under this Article or rules of the [Environmental Management]
Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed
ten thousand dollars($10,000).
I hereby request Representative Outfall Status for my NPDES Permit. I understand that ALL outfalls are still
subject to the qualitative monitoring requirements of the permit, unless otherwise allowed by the permit
and regional office approval. I must notify DWQ in writing if any changes to the facility or its operations take
place after ROS is granted that may affect this status. If ROS no longer applies, I understand I must resume
monitoring of all outfalls as specified in my NPDES permit.
I certify that I am familiar with the information contained in this application and that to the best of my
knowledge and belief such information is true, complete, and accurate.
Printed Name of Person Signing: Floyd Whitmire _
Title: Mill Manager
74
(Signature of Applicant) (Date Signed)
Please note: This application for Representative Outfall Status is subject to approval by the
NCDENR Regional Office. The Regional Office may inspect your facility for compliance with the
conditions of the permit prior to that approval.
Final Checklist for ROS Request
This application should include the following items:
dis This completed form.
✓ Letter or narrative elaborating on the reasons why specified outfalls should be granted representative
status, unless all information can be included in Question 4.
E3/ Two (2) copies of a site map of the facility with the location of all outfalls clearly marked, including the
drainage areas, industrial activities, and raw materials/finished products within each drainage area.
Summary of results from monitoring conducted at the outfalls listed in Question 3.
❑ Any other supporting documentation.
Page 2 of 4
SWU-ROS-2009 Last revised 12/30/2009

Representative Outfall Status Request
For NPDES Permit Number NCS000101
Explanation of Requests
January 27, 2012/updated June 25, 2012
Basin S
Basin S was added to the mill SWPPP in May, 2008, after inspection by Linda Willis of the
Wilmington Regional DWQ office. Ms. Willis requested analytical data for Basin S for
consideration for representative status. However, sampling has proved difficult because the
outfall does not flow during normal representative rain events. To discharge, runoff passes
through a collection pond and a meandering stream through low-lying woods. Runoff rarely
flows as far as the outfall. Twice samples were collected to establish some data; these were both
collected after multi-day rain events that were not representative events. The results for these
Basin S samples are similar to analytical results for Basin I. Please refer to the attached analysis
comparison for Basins I and S. Please note that in 2010 and in early 2011, Basin I exceeded
benchmarks. After investigation, the basin was repaved, eliminating loose material washoff
and allowing improved housekeeping. Analytical results were within benchmarks after that
improvement. Again in Spring, 2012, the TSS benchmark for Basin I was exceeded; a buildup of
sand was observed along the diffuser and is suspected as the source of the solids. Area
maintenance practices have been improved to correct this issue.
Basins S and I are both used for storage of trailers, empty and full. Basin I trailers contain
finished product, and Basin S trailers store wood chips and logs. Both basins are on the south
side of the mill and runoff from both eventually drains to Livingston Creek, a tributary of the
Cape Fear River. As stated in the current NPDES stormwater permit, Basin I is currently
representative of Basins K,M, L, P, and R.
Basin J
Basin J was omitted from the list of representative outfall sampling points in Section B of the
existing NPDES permit. Per site visit by Aisha Lau, formerly of DWQ, Basin J was to have been
represented by Basin I. During review of the current permit, in a letter dated November 20,
2006(attached), specification of representative sampling points was requested to be included in
the permit for clarity. Basin 1 was the only basin out of 18 that was not specified. Please add it
to the list of outfalls represented by Basin I. Basin J is in the same general vicinity as Basin I,
and discharge drains in the same direction. Transfer or storage of materials is the main activity
in both basins. Basin I is used for storage of trailers containing finished product, and in Basin J
the main activity is transfer/storage by rail of wood chips and logs. Visual inspection results are
similar for both outfalls and are attached.

STORMWATER RESULTS: FALL 2007 - SPR 2010
ANALYTICAL RESULTS for Representative Basin I
Parameter(Permit Benchmark)
BASIN (BOLD), SEMESTER
COMMENTS
(F=Fall; S=Spring) BOD (30) COD (120) TSS (100) pH (6-9)
•
F 07
2/1/2008 10 435 597 7.5 Drought caused late sampling
2/26/2008 2 51 42 7.5
S08
6/21/2008 7 30 29 8.1
F08
11/29/2008 2 2 45 7.6
S09
5/11/2009 4 45 51 6.8
F09
9/22/2009 12 27 72 6.9
S10
11/17/2010 17 322 996 8.4
F10
11/4/2010 8 301, 770 8.4
S11
7/5/2011 38 36 130 7.8
F11
11/16/2011 12 69 34 7.2
S12
5/30/3012 9 89 203 7.8

STORMWATER RESULTS: FALL 2007 - SPR 2010
ANALYTICAL RESULTS for Basin S
Parameter(Permit Benchmark)
BASIN (BOLD), SEMESTER
COMMENTS
(F=Fall; S=Spring) BOD (30) COD (120) TSS (100) pH (6-9)
S .
F07 Basin S added in May, 2008
n/a n/a n/a n/a
S08
no flow Ino flow no flow no flow
F08
11/29/2008 3 44 12 7.0 Not a qualifying rain event
S09
5/18/2009 2 81 14 6.1 Not a qualifying rain event
F09
9/22/2009 no flow Ino flow [no flow no flow
S10
11/17/2010 no flow Ino flow [no flow no flow
F10
11/4/2010 no flow Ino flow no flow no flow
S11
7/5/2011 no flow Ino flow no flow �no flow
F11
11/16/2011 no flow Ino flow no flow no flow
S12
5/15/2012 no flow no flow no flow mno flow

STORMWATER RESULTS: FALL 2007 - SPR 2012
VISUAL RESULTS FOR BASINS J and I
VISUAL INSPECTION: 1-10 SCALE (I BEST) [2010 scale 1 -5), OR Y/N
EROSION/
BASIN(bold), SEMESTER COLOR It,med, FLOATING SUSPENDED DEPOSITION
(F=fall,S=Spr) dk(I,m,d) CLARITY SOLIDS SOLIDS ODOR FOAM OIL SHEEN 2010-12 ONLY
I
F 07 med gra 6 2 6 n n n n/a
S08 Igra 4 1 4 n *sl,at cascade n n/a
F08 It gra-tan 5 4 5 n n n n/a
S 09, F09 off-wh 2 1 2 n n n n/a
F09 off-wh 3 2 3 n n n: n/a
new NCDENR quantitative rating scale 1-5 for clarity,float sol,susp. sol.
S10 med gra 8 1 8 n n n y
F10 med br 4 1 4 n n n y sl
S11 It tan 3 1 3 n n n n
F11 very It yel 2 1 1 n n n n
S12 It.gray. 2 2 1 n n n n
J
F 07 It br-y. 3 2 3 n n n n/a
S 08 It yel 2 1 1 n n n n/a
F08 off-wh 2 1 2 n n n n/a
S 09 It br 6 1 6 n n n n/a
F09 It gra 5 1 4 n n n n/a
new NCDENR quantitative rating scale 1-5 for clarity,float sol, susp. sol. •
S10 clear 1 1 1 n n n n
F10 med br 4 1 4 n n n y
S11 It yel 2 1 2 n n n n
F11 very It yel 1 1 1 n n n n
S12 It tan/gray 2 1 1 n n n n
* slight bubbling where runoff exits pipe;dissipates quickly