NCS000189_Email RE Permit Questions_20201124

Gamble, Aana C
From: Gamble, Aana C
Sent: Tuesday, November 24, 2020 3:26 PM
To: Hardison, Diane
Cc: Lilley, John Thomas; Moore, Bill; Lucas, Annette
Subject: RE: [External] Domtar comments concerning revised SW permit NCS000189
Good afternoon,
Please see below for responses to the questions Domtar sent earlier this month:
1. We are forwarding the communication string below for your reference. We notice the final version of our
renewed stormwater permit retained the requirement to monitor for dioxin from outfall WLS01. We had
requested removal of this monitoring requirement from our permit (reference the original renewal application
cover letter, dated Nov 6, 2013). You can see from the DEMLR correspondence associated with the 2019 drafts
of this permit (below), we received confirmation that this would be removed from the permit. Domtar
respectfully requests correction to this permit renewal to remove the requirement to monitor outfall WLS01 for
Dioxin.
Thank you for submitting the below correspondence regarding the removal of dioxin as a monitoring parameter
in the NPDES Individual Industrial Stormwater Permit NCS000189. Domtar will receive a permit correction
removing dioxin as a parameter for analytical monitoring.
Additionally, we notice that unlike the previously issued permits, the renewal does not denote or illustrate our
specific list of outfalls or speak to prior approvals for designated representative outfalls. Do we understand
correctly that we carry on as before with outfall quantitative monitoring of the previously designated
representative outfalls? Do we further understand correctly that we do not need to submit formal requests or
gain written approval from DEMLR to remove or add outfalls as long as we note these revisions in our SPPP and
quantitatively and qualitatively monitor any new outfalls?
You are correct — this renewed permit does not differentiate between the site's outfalls. In Part II, Section B, the
permit states "samples shall be collected at each stormwater discharge outfall (SDO) unless representative
outfall status (ROS) has been granted. A copy of the Division's letter granting ROS shall be kept on site." Please
maintain documentation of any ROS that has been granted to this facility, if applicable. Additionally, if Domtar
changes/modifies outfalls, which would be a change from the outfalls listed in the permit renewal application,
please notify DEMLR so that we can maintain documentation of the outfall information in the file and in our
eDMR system.
Concerning training — we have uploaded our mill -specific stormwater training presentation and quiz into on
online tool to more effectively and efficiently ensure completion of the required annual training by
employees. Employees who have Domtar logon accounts who are designated by our SPPP to receive this annual
training, individually log on when prompted by the system and complete the training. We personally
facilitate the training for onsite contractors and others in some mill depts who may not be able to complete the
training in this manner. In the cases of the online participants, the electronic program captures the date and
time the employee logged in and completed the training. Part II A 8 of the renewed permit states completed
annual training must be documented by employee signature. May our electronic training and tracking record
satisfy this requirement?
Yes, the electronic training/tracking record satisfies this requirement, as an electronic signature.

4. We have already established the electronic signature requirements and authorizations through NC NPDES eDMR
process for reporting our monthly wastewater information. Are the stormwater eDMR requirements the
same? Do we have to go through this process again and separately for stormwater reporting?
Unfortunately, Domtar will have to repeat the eDMR process for the stormwater eDMR system. Additional
information can be found here: https://deg.nc.gov/deg.nc.gov/sw-edmr.
Thank you again for your patience and your correspondence. I will work on getting the permit correction to you this
week. Please let me know if you have any additional questions.
Very respectfully,
Aana Gamble
Environmental Specialist II
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
Phone: [phone]
Email: [e-mail]
Physical Address: 512 North Salisbury Street
Mailing Address: 1612 Mail Service Center
Raleigh, NC 27699-1612
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Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Hardison, Diane < Diane. Hardison @domtar.com>
Sent: Monday, November 16, 2020 10:35 AM
To: Gamble, Aana C <[e-mail]>
Cc: Lilley, John Thomas <[e-mail]>; Moore, Bill <[e-mail]>
Subject: RE: [External] Domtar comments concerning revised SW permit NCS000189
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[e-mail]
Thank you Aana.
Diane R Hardison
Environmental Health and Safety Manager
P 252-793-8611 1 F 252-793-8871 1 M 252-217-2548
0 - _- Domtar Paper Company, LLC
P.O. Box 747
NC Highway 149 North
Plymouth, North Carolina 27962
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From: Gamble, Aana C <[e-mail]>
Sent: Monday, November 16, 2020 10:18 AM
To: Hardison, Diane <Diane.Hardison @domtar.com>
Subject: RE: [External] Domtar comments concerning revised SW permit NCS000189
Hi Diane,
I am reviewing your questions with my supervisor and I will get back to you as soon as possible. I apologize for the delay
— both of us have pretty packed schedules.
Thank you,
Aana Gamble
Environmental Specialist II
Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
Phone: [phone]
Email: [e-mail]
Physical Address: 512 North Salisbury Street
Mailing Address: 1612 Mail Service Center
Raleigh, NC 27699-1612
/it �qM a! FehYo�vnental Qwlit�
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Hardison, Diane <[e-mail]>
Sent: Thursday, November 12, 2020 4:51 PM
To: Gamble, Aana C <[e-mail]>
Cc: Moore, Bill <[e-mail]>; Lilley, John Thomas <[e-mail]>
Subject: [External] Domtar comments concerning revised SW permit NCS000189
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Aana,
We have a few more questions related to the permit renewal:
1. We are forwarding the communication string below for your reference. We notice the final version of our
renewed stormwater permit retained the requirement to monitor for dioxin from outfall WLS01. We had
requested removal of this monitoring requirement from our permit (reference the original renewal application
cover letter, dated Nov 6, 2013). You can see from the DEMLR correspondence associated with the 2019 drafts
of this permit (below), we received confirmation that this would be removed from the permit. Domtar

respectfully requests correction to this permit renewal to remove the requirement to monitor outfall WLS01 for
Dioxin.
Additionally, we notice that unlike the previously issued permits, the renewal does not denote or illustrate our
specific list of outfalls or speak to prior approvals for designated representative outfalls. Do we understand
correctly that we carry on as before with outfall quantitative monitoring of the previously designated
representative outfalls? Do we further understand correctly that we do not need to submit formal requests or
gain written approval from DEMLR to remove or add outfalls as long as we note these revisions in our SPPP and
quantitatively and qualitatively monitor any new outfalls?
Concerning training — we have uploaded our mill -specific stormwater training presentation and quiz into on
online tool to more effectively and efficiently ensure completion of the required annual training by
employees. Employees who have Domtar logon accounts who are designated by our SPPP to receive this annual
training, individually log on when prompted by the system and complete the training. We personally
facilitate the training for onsite contractors and others in some mill depts who may not be able to complete the
training in this manner. In the cases of the online participants, the electronic program captures the date and
time the employee logged in and completed the training. Part II A 8 of the renewed permit states completed
annual training must be documented by employee signature. May our electronic training and tracking record
satisfy this requirement?
4. We have already established the electronic signature requirements and authorizations through NC NPDES eDMR
process for reporting our monthly wastewater information. Are the stormwater eDMR requirements the
same? Do we have to go through this process again and separately for stormwater reporting?
Thank you for helping to clarify the above items.
Diane R Hardison
Environmental Health and Safety Manager
P 252-793-8611 1 F 252-793-8871 1 M 252-217-2548
x Domtar Paper Company, LLC
P.O. Box 747
NC Highway 149 North
Plymouth, North Carolina 27962
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This email is for the exclusive use of the addressee and is subject to Domtar Confidentiality Notice.
From: Garcia, Lauren V <[e-mail]>
Sent: Thursday, December 05, 2019 7:40 AM
To: Hardison, Diane <Diane.Hardison @domtar.com>
Cc: Lilley, John Thomas <[e-mail]>; Wynne, Don <[e-mail]>
Subject: RE: [External] Additional review comments concerning Draft SW permit NCS000189
I got the approval to remove dioxin as a parameter. It is possible that you will receive the new permit by January.
From: Hardison, Diane <[e-mail]>
Sent: Wednesday, December 04, 2019 4:03 PM
To: Garcia, Lauren V <[e-mail]>

Cc: Lilley, John Thomas <[e-mail]>; Wynne, Don <[e-mail]>
Subject: RE: [External] Additional review comments concerning Draft SW permit NCS000189
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mail. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment tM
Correction —
The biannual fish sample and tissue analyses per EPA (not per our NPDES permit) is related to Welch Creek (OU-04)
remediation and not the Roanoke River.
Diane R Hardison
Environmental Health and Safety Manager
P 252-793-8611 1 F 252-793-8871 1 M 252-217-2548
0 _ __- _ Domtar Paper Company, LLC
P.O. Box 747
NC Highway 149 North
Plymouth, North Carolina 27962
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From: Hardison, Diane
Sent: Wednesday, December 04, 2019 3:37 PM
To: 'Garcia, Lauren V
Subject: RE: [External] Additional review comments concerning Draft SW permit NCS000189
Yes, our NPDES permit no. NC0000680 still requires fish tissues analyses in accordance with an approved monitoring
plan, every other year, during odd -numbered years, for TCDD and TCDF. Samples much come from a one station
upstream and at two stations downstream. However, in our April 2016 renewal application submittal, we requested to
reduce this sampling and analyses to once per permit cycle.
For what periods did you recently review these data? Please note that the current monitoring requirements related to
the passive remediation (EPA) of the Roanoke River also include biannual fish tissue analyses.
When might we received the finalized, revised stormwater permit for Domtar's Plymouth facility?
Please let us know if you have any further questions.
Thank you
Diane R Hardison
Environmental Health and Safety Manager
P 252-793-8611 1 F 252-793-8871 1 M 252-217-2548
0 _ __- _ Domtar Paper Company, LLC
P.O. Box 747
NC Highway 149 North
Plymouth, North Carolina 27962
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From: Garcia, Lauren V [mailto:lauren.garciaCcbncdenr.gov]
Sent: Wednesday, December 04, 2019 12:46 PM
To: Hardison, Diane
Subject: RE: [External] Additional review comments concerning Draft SW permit NCS000189
Hi Diane,
We reviewed fish tissue data for the waters Domtar discharges to this week. Does your wastewater permit require
monitoring for dioxin or continued fish tissue analysis?
Thanks,
Lauren
From: Garcia, Lauren V
Sent: Friday, October 04, 2019 7:56 AM
To: Hardison, Diane <Diane.Hardison @domtar.com>
Subject: RE: [External] Additional review comments concerning Draft SW permit NCS000189
No problem!
From: Hardison, Diane <[e-mail]>
Sent: Friday, October 04, 2019 7:50 AM
To: Garcia, Lauren V <[e-mail]>
Cc: Lilley, John Thomas <[e-mail]>
Subject: RE: [External] Additional review comments concerning Draft SW permit NCS000189
�R External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Thank you Lauren.
Diane R Hardison
Environmental Health and Safety Manager
P 252-793-8611 1 F 252-793-8871 1 M 252-217-2548
0 _ - Domtar Paper Company, LLC
P.O. Box 747
NC Highway 149 North
Plymouth, North Carolina 27962
Paper informs us, persuades us, educates us and organizes us. It's OK to use paper. Learn More.
Domtar reminds you to print responsibly. Learn more about paper as a sustainable choice at paperbecause.com
This email is for the exclusive use of the addressee and is subject to Domtar Confidentiality Notice.
From: Garcia, Lauren V [mailto:lauren.garciaCcbncdenr.gov]
Sent: Friday, October 04, 2019 7:09 AM
To: Hardison, Diane
Cc: Lilley, John Thomas
Subject: RE: [External] Additional review comments concerning Draft SW permit NCS000189

Hi Diane,
That section will just start out by saying that the facility discharges to impaired waters experiencing problems with fish
tissue mercury. Fish tissue mercury will be the only impairment listed.
Thanks,
Lauren
From: Hardison, Diane <[e-mail]>
Sent: Thursday, October 03, 2019 12:40 PM
To: Garcia, Lauren V <[e-mail]>
Cc: Lilley, John Thomas <[e-mail]>
Subject: RE: [External] Additional review comments concerning Draft SW permit NCS000189
• External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
nc. ov
Thank you Lauren. Can you share how the revised text that will now appear in the permit?
Diane R Hardison
Environmental Health and Safety Manager
P 252-793-8611 1 F 252-793-8871 1 M 252-217-2548
Domtar Paper Company, LLC
P.O. Box 747
NC Highway 149 North
Plymouth, North Carolina 27962
Paper informs us, persuades us, educates us and organizes us. It's OK to use paper. Learn More.
Domtar reminds you to print responsibly. Learn more about paper as a sustainable choice at paperbecause.com
This email is for the exclusive use of the addressee and is subject to Domtar Confidentiality Notice.
From: Garcia, Lauren V[maiIto: lauren.garcia(ancdenr.gov]
Sent: Tuesday, October 01, 2019 3:31 PM
To: Hardison, Diane
Cc: Lilley, John Thomas
Subject: RE: [External] Additional review comments concerning Draft SW permit NCS000189
Hi Diane,
I have to compliment you for being this persistent because it exposed an issue in my permitting process. When I was
shown how to use the website I was told that every parameter of interest listed was considered an impairment. I
wanted to be able to answer your questions about where the data comes from and was just shown that only the
parameters listed as "Exceeding Criteria" are considered impairments. This is good for Domtar because dioxin is no
longer listed as an impairment. It will just be mercury. Paul Clark in Water Supply Watershed said you can contact him if
you have any other questions about how this information is collected. His number is [phone]. Paul Clark is also

one of the people involved in determining if we can remove dioxin from the permit. He is looking into fish tissue data in
the receiving waterbodies.
Let me know if there are any more questions or comments.
Thanks,
Lauren
From: Hardison, Diane <[e-mail]>
Sent: Tuesday, October 01, 2019 9:42 AM
To: Garcia, Lauren V <[e-mail]>
Cc: Lilley, John Thomas <[e-mail]>; Morman, Alaina <[e-mail]>
Subject: RE: [External] Additional review comments concerning Draft SW permit NCS000189
• External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Thank you for this further clarification.
Diane R Hardison
Environmental Health and Safety Manager
P 252-793-8611 1 F 252-793-8871 1 M 252-217-2548
Domtar Paper Company, LLC
P.O. Box 747
NC Highway 149 North
Plymouth, North Carolina 27962
Paper informs us, persuades us, educates us and organizes us. It's OK to use paper. Learn More.
Domtar reminds you to print responsibly. Learn more about paper as a sustainable choice at paperbecause.com
This email is for the exclusive use of the addressee and is subject to Domtar Confidentiality Notice.
From: Garcia, Lauren V[mailto:lauren.garciaCcbncdenr.gov]
Sent: Tuesday, October 01, 2019 9:22 AM
To: Hardison, Diane
Cc: Lilley, John Thomas; Morman, Alaina
Subject: RE: [External] Additional review comments concerning Draft SW permit NCS000189
In the 2009 permit, it is stated that Domtar Paper Company discharges to Welch Creek and the Roanoke River. The
website has been updated with the information from the 2018 Final Water Quality Assessment. The 303(d) List -Category
5 was approved by the EPA in March 2019. Parameters of Concern for Welch Creek are: Arsenic, Fish Tissue Mercury,
Iron, Cadmium, Copper, Nickel, Lead, Zinc (All circa 2008). Parameters from the Roanoke include: Arsenic, Chlorophyll a,
Fecal Coliform, pH, Iron, Zinc, Cadmium, Fish Tissue Mercury, Turbidity, Copper, Dissolved Oxygen, Temperature, Lead,
and Nickel (all circa 2008, 2012).
This website is also open to the uses of the public.
These waters are impaired for the above listed parameters. This section of the permit is standard and is consistent
across all renewed permits. It is necessary section for the awareness of the permittee and for the use of the Division.
The template language does not suggest that Domtar contributes to the impairments of the waterbodies.

From: Hardison, Diane <[e-mail]>
Sent: Tuesday, October 01, 2019 8:37 AM
To: Garcia, Lauren V <[e-mail]>
Cc: Lilley, John Thomas <[e-mail]>
Subject: RE: [External] Additional review comments concerning Draft SW permit NCS000189
• , External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
nc. ov
Thank you for sharing this map. I have played with it a little bit. I do not find any "problem" or parameter criteria listed
on the Roanoke where the mill discharges or anywhere else along the Roanoke up and down stream of the mill. The
river is "grey' from Roanoke Rapids to the mouth of the sound. I find a notation of "meeting criteria" when I click on the
lower river. How do we find exactly the information currently drafted in the permit text concerning the "problems"? I
believe there has been little to no metals data collected in the Roanoke since 2000. This permit is a public record.
Domtar is concerned with DEQ's implying in our permit that the waters are impaired when this is not the case per the
303 listings and neither validated through historical testing. Also, we are concerned with referring to the waters has
having "problems" with compounds when this has not been tested or validated. We recognize we are certainly not
experts in this matter and have much to learn. However, we request that our permit remain factual. Domtar request
either removal of the text in question from the permit or a revision to state only what is validated and factual for the
current conditions of the Roanoke. We will welcome a conf call if helpful.
Thank you for this consideration.
Diane R Hardison
Environmental Health and Safety Manager
P 252-793-8611 1 F 252-793-8871 1 M 252-217-2548
Domtar Paper Company, LLC
P.O. Box 747
NC Highway 149 North
Plymouth, North Carolina 27962
Paper informs us, persuades us, educates us and organizes us. It's OK to use paper. Learn More.
Domtar reminds you to print responsibly. Learn more about paper as a sustainable choice at paperbecause.com
This email is for the exclusive use of the addressee and is subject to Domtar Confidentiality Notice.
From: Garcia, Lauren V[mailto:lauren.garciaCcbncdenr.gov]
Sent: Tuesday, October 01, 2019 7:30 AM
To: Hardison, Diane
Cc: Lilley, John Thomas
Subject: RE: [External] Additional review comments concerning Draft SW permit NCS000189
Good morning Diane,
The parameters of concern can be viewed here:
https://ncdenr.maps.arcgis.com/apps/MapSeries/index.html?appid=14df5O75d8e3437b8476c89c3db3fOa5. This is an
interactive map, open to the public, that lists all of the parameters of concern for receiving waterbodies. This list of
parameters has been updated since 2009, which is why there are now more impairments and why dioxin is no longer
listed in the draft. This section of the permit is present for the benefit of the permittee, the purpose being 1) the
permittee is aware of the parameters of concern for the waterbody the facility discharges to and 2) for the permittee to

made aware that if the Division develops a TMDL for any of the parameters listed, the Division will consider the facility's
monitoring results in determining whether additional SCMs and/or BMPs are needed to control the pollutants of
concern to the extent practicable. The template language does not suggest that Domtar contributes to the impairments
of the waterbodies and if Domtar does not, then this disclaimer will likely never affect the facility. It is just necessary
template language.
Thanks,
Lauren
From: Hardison, Diane <[e-mail]>
Sent: Monday, September 30, 2019 4:16 PM
To: Garcia, Lauren V <[e-mail]>
Cc: Lilley, John Thomas <[e-mail]>
Subject: [External] Additional review comments concerning Draft SW permit NCS000189
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Laura,
Thank you again, for allowing us the opportunity to review the draft revision to our stormwater permit. In addition to
the comments and questions JT Lilley has already shared, we've noticed on page 10 of the draft permit (Section B, under
Table 5), the following statement, "this site discharges to impaired waters experiencing problems with copper,
cadmium, arsenic, chlorophyll a, fecal coliform, DO, pH, water temperature, turbidity, nickel, lead, zinc, iron and fish
tissue mercury". This text is very different than the impaired waters information provided in our current stormwater
permit. We are not aware that the lower Roanoke, specifically the area in the vicinity of our facility, has been listed as
impaired for these parameters or is having these multiple issues. This text as listed in the draft permit seems
unnecessarily intense, and perhaps subjective, and could contribute to unintended and negatives impacts to Domtar's
operations in Plymouth. The Domtar facility in Plymouth does not contribute to any of these "problem" conditions that
may be present in the area's surface waters. Could you please provide the formal, documented references which verify
that the lower Roanoke near Plymouth is sanctioned as impaired for or experiencing problems with these listed
parameters? Our current permit simply states the waters are impaired for dioxin and mercury, for which we are aware
of those health advisory postings. We respectfully request that DEMLR reconsider placing the "impaired waters"
statement in the revised stormwater permit as currently drafted. We welcome a conference call for DEMLR to further
explain to Domtar why this text, as drafted, is necessary in the permit. Any better understanding we may gain in this
regard, is appreciated.
Thank you for your consideration of our request.
Diane R Hardison
Environmental Health and Safety Manager
P 252-793-8611 1 F 252-793-8871 1 M 252-217-2548
Domtar Paper Company, LLC
P.O. Box 747
NC Highway 149 North
Plymouth, North Carolina 27962
Paper informs us, persuades us, educates us and organizes us. It's OK to use paper. Learn More.
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