NC0088081_NPDES Permit Application_20130905

DIVISION OF WATER RESOURCES
September 5, 2013
MEMORANDUM
TO:
FROM:
Jim McKay
Point Source Branch
Dale Lopez, Environmental Specialist
THROUGH: Belinda S. Henson, Surface Water Protection Section Supervise , FRO
SUBJECT:
Renewal of NPDES Permit No. NC0088081
Cookson D.O.G.
Former Cookson Fibers Facility
Anson County
giteA,2,"-ro
The Fayetteville. Regional Office has reviewed the subject permit renewal, associated file
information, as well as compliance data that was pulled from BIMS.
Based upon the above, the Fayetteville Regional Office recommends that the subject permit be
reissued in keeping with the basinwide strategy.
If you have questions or comments pertaining to this project, please do not hesitate to contact me
at [phone].

VA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild; P. E. Dee Freeman
Governor . Director SecretarY
January 2, 2013
Thomas Haynes, ORC
Waters Edge Environmental, TLC
4901 Waters Edge Drive, Suite 201
Raleigh, NC 27606
SUBJECT: Compliance Evaluation Inspection (CEI)
Former Cookson Facility Groundwater Remediation System
NPDES Permit NC0088081
Anson County
Dear Mr. Haynes,
Enclosed you will fmd a copy of the Compliance Evaluation Inspection report for the
December 5, 2012 inspection. All observations, suggestions, and a requirement are in the
enclosed EPA Water Compliance Inspection Report.
On the day of this CEI, this facility was found to be in compliance with the NPDES
permit NC0088081. You are commended for your work at this facility. I appreciated.the time
and professional courtesy that you extended to me during the inspection. If you have any
questions or comments concerning this report, please feel freeto contact me at [phone].
Environmental Specialist
Enclosures: EPA Water Compliance Inspection Report
Brief description of the GW remediation facility
cc:
FRO Files (Mark Brantley)
225 Green Street -Suite 714 —Fayetteville, North Carolina 2830.1-5043
Phone: [phone] FAX• 910-486-07071 Customer Service: 1-877-623-6748
Internet: www.ncwatemuality.orq
An Equal Opportunity 1 Affirmative Action Employer
No thCarolina
naturally

United States Environmental Protection Agency
EPA Washington, D.C. 20460
• Water CnmplianrP. inRertinn Repoli
Form Approved:
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (Le., PCS)
Transaction Code - NPDES yr/mo/day - -- Inspection
1 IN I 2 15 I 31 NC0088081 111 121 12/12/05 117
Type Inspector FacType
18I C I 19I S I 20I
-
I I I I I I I U 66
Remarks
21I •� I I
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA671 2.0 . 169 70 13 I 711 I 72I N I MI I 174 751 I I I I 1 I 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Cookson remediation site .
10056 US Hwy 52 •Exit
Ansonville NC 28007
Entry Time/Date
PM 12/12/05
Permit Effective Date
09/09/01
Time/Date
01:30 PM 12/12/05
Permit Expiration Date
14/01/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Thomas Foster Haynes/ORC/336-613-3339/ -
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number .
Contacted
Jamie Kalanta,22 Hedgefield Ct Orange CT 06477//203-795-0554/2037950553 . No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
as necessary)
Permit f''? Flow Measurement Operations & Maintenance"'_• Records/Reports
and checklists
Self -Monitoring Program , Effluent/Receiving Waters
Section D: Summary of Finding/Comments (Attach additional sheets of narrative
(See attachment summary) .
•
Name(s)-d.Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers - Date ,
Dale Lopez FRO WQ//910 433 3300 Ext.712/
Signature of M. nagement Q AJwer Agency/Office/Phone and Fax Numbers Date
OC I// 2/) Z
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type -
3I NC0088081 111 12I 12/12/05 117 18I CI
(cont.) 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Enclosed you will find a copy of the Compliance Evaluation Inspection report for the December 5, 2012
inspection. All observations, suggestions, and a requirement are in the enclosed EPA Water Compliance
Inspection Report.
On the day of this CEI, this. facility was found to be in compliance with the NPDES permit NC0088081.
You are commended for your work at this facility. I appreciated the time and professional courtesy that you
extended to me during the inspection. If you have any questions or comments concerning this report, •
please feel free to contact me at [phone]. -
It is required that the sample aliquot size be at -least 100 mL per grab sample -so as to be in agreement with
the NPDES permit, Part II, Section A, Composite Sample.
It is suggested to check the box for effluent flow on the DMRs. It is also suggested that an air diffuser in the
EQ Tank might help to reduce some of the iron at the beginning of your system.
Brief Description of the Cookson GW remediation facility (Groundwater Recovery System):
Seventeen groundwater extraction wells (with 4-inch Grundfos submergible well pumps) and seventeen
subguard pump controllers intermittently pumped well water to a treatment building (8' x 16') with plywood
floor that housed the following units. The influent from the extraction wells first flowed into a 425-gallon
vertical Equalization Polytank (EQ), then through an EQ Tank transfer pump to a spray nozzle at the top of
an air stripper (Product Recovery Management Model 624), then through the bottom drain #hragfrby
means of an AST transfer pump through a bag filter, to two activated granular charcoal carbon filters (1,000
lbs each) that were positioned in series, and finally to the effluent near an unnamed tributary receiving
stream.
The following is more detail about the system:
Each of the seventeen groundwater extraction wells (with an average depth of 55.feet, and a couple of wells
that were 65 feet deep) produced well water intermittently, depending upon the drawdown and recharge
conditions of the groundwater aquifer. The seventeen submergible pumps were each protected by a
dedicated subguard pump controller that prevented the well pump from operating while dry. Since the GW
remediation unit began, the activated carbon filter media was changed out one time (March 17, 2009).
That change was, for the most part, due to the build-up of precipitated iron in the carbon filter media. The
iron that precipitated in the air scrubber was washed into the bag filter before the water was pumped to the
activated carbon filter units. Following the water pressure after it left the air scrubber: after the AST pump,
it was approximately 40 psi, then after the bag filter the pressure was approximately 25 psi, after the first
activated carbon filter the pressure was approximately 19 psi, and after the second activated carbon filter
the pressure was approximately 10 psi. The activated carbon filters were the last treatment unit before the
wastewater was pumped to the Plant Effluent 001 and discharged to an unnamed tributary that flowed to
Buffalo Creek, then to the PeeDee River.
The 24-hour composite sampler was set up at the effluent, with the sample strainer placed in a 5-gallon
container that overflowed into the unnamed tributary. The 24-hour composite sampler was based onset
Page # 2

Permit: NC0088081
Inspection Date: 12/05/2012
Owner - Facility: Cookson remediation sife
Inspection Type: Compliance Evaluation-
time/set volume, at 96 samples (one per 15 minutes) and 80 mL aliquot;sample size: To: be:in.agreement
with your permit, please change the volume to at least 100 mL per aliquot. Also, please notice in the permit
(in Part II, Section A, Composite Sample) that the.aliquots should:ribrbe at intervals greater than 20
minutes. The digital flow meter readout was periodically checked and documented (in the ORC logbook)
against a 5-gallon bucket. The flow calibration used the Totalizer before and after one. minute of flow, and
the flow meter was last checked on November 28, 2012. A semi-annual report was sent to REC Program
(Shannon McDonald).
Page # 3

Permit: NC0088081 Owner - Facility: Cookson remediation site
Inspection Date: 12/05/2012 Inspection Type: Compliance Evaluation
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping?
Yes No NA NE
e ❑D0
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ® n `D 0
Judge, and other that are applicable?
Comment:
Permit
(If the present permit expires in 6 months or less).. Has the permittee submitted a new application?
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Comment:
Record Keeping
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain -of -custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility.is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility classification?
Is the backup operator certified at one grade less or greater than the facility classification?
Is a copy of the current NPDES permit available on site?
Yes No NA NE
nnon
o nnn
[Ennn
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n nn
Yes No NA NE
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Page # 4

Permit: NC0088081
Inspection Date: 12/05/2012
Owner - Facility: Cookson remediation site
Inspection.Type: Compliance Evaluation
Record Keeping
Facility has copy of previous year's Annual Report on file for.review?
Comment:
Effluent Pipe
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required). are they operating properly?
Comment:
Flow Measurement - Effluent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment: . Calibration last checked on November 28, 2012. .
Effluent Sampling
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected? •
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
Comment: Please change the sample aliquots to at least 100 mL per sample to be in
agreement with the NPDES permit. Please see Part II, Section A, Composite Sample.
Yes No NA NE
❑❑la 0
Yes No NA NE
n nn
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Yes No NA NE
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Yes No NA NE
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Page # 5

Brief Description of the Cookson GW remediation facility (Groundwater Recovery System):
Seventeen groundwater • extraction wells (with 4-inch Grundfos submergible well pumps) and
seventeen subguard pump controllers intermittently pumped well water to a treatment building
(8' x 16') with plywood floor that housed the following units. The influent from the extraction
wells first flowed into a 425-gallon vertical Equalization Polytank (EQ),. then through an EQ
Tank transfer pump to a spray nozzle at the top of an air stripper (Product Recovery Management
Model 624), then through the bottom drain through by means of an AST transfer pump through a
bag filter, to two activated granular charcoal carbon filters (1,000 lbs each) that were positioned
in series, and finally to the effluent near an unnamed tributary receiving stream.
The following is more detail about the system:
Each of the seventeen groundwater extraction wells (with an average depth of 55 feet, and a
couple of wells that were 65 feet deep) produced well water intermittently, depending upon the
drawdown and recharge conditions of the groundwater aquifer. The seventeen submergible
pumps were each protected by a dedicated subguard pump controller that prevented the well
pump from operating while dry. Since the GW remediation unit began, the activated carbon
filter media was changed out one time (March 17, 2009). That change was, for the most part,
due to the build-up of precipitated iron in the carbon filter media. The iron that precipitated in
the air scrubber was washed into the bag filter before the water was pumped to the activated
carbon filter units. Following the water pressure after it left the air scrubber: after the AST
pump, it was approximately 40 psi, then after the bag filter the pressure was approximately 25
psi, after. the first activated carbon filter .the pressure was approximately 19 psi, and after the
second activated carbon filter the pressure was approximately 10 psi. The activated carbon
filters were the last treatment unit before the wastewater was pumped to the Plant Effluent 001
and discharged to an unnamed tributary that flowed to Buffalo Creek, then to the PeeDee River.
The 24-hour composite sampler was set up at the effluent, with the sample strainer placed in a 5-
gallon container that overflowed into the unnamed tributary. The 24-hour composite sampler
was based on set time/set volume, at 96 samples (one per 15 minutes) and 80 mL aliquot sample
size. To be in agreement with your permit, please change the volume to at least 100 mL per
aliquot. Also, please notice in the peiinit (in Part II, Section A, Composite Sample) that the
aliquots should not be at intervals greater than 20 minutes. The digital flow meter readout was
periodically checked and documented (in the ORC logbook) against a 5-gallon bucket. The flow
calibration used the Totalizer before and after one minute of flow, and the flow meter was last
checked on November 28, 2012. A semi-annual report was sent to REC Program (Shannon
McDonald).

PERMIT NUMBER: NC0088081
FACILITY NAME: Cookson D 0 G - Cookson remediation site
CITY: Ansonville
OUTFALL: 001
EFFLUENT
COUNTY: Anson
PERIOD ENDING MONTH: 7 - 2013
REGION: Fayetteville
DMR 12 Month Calculated
PAGE 4 OF 5
32103
ug/I
1,2-dichloroetha
ne
34010
ug/I
Toluene
.
34423
ug/I
Methylene
Chlonde
(dichloromethane
methylene
dichloride)
34501
ug/I
1,1-dichloroethy
lene
34506
ug/l
1 1,1-trichloro-
ethane
34516
ug/I
1122TETR
34696
ug/I
Naphthalene
50050
mgd
Flow, in
conduit or thru
treatment plant
0.1
1. 13
0.004226
2_,13._....
0.•/
0.005214
0.1
3=13
0.005948
4-13
0.1
0.005033
5 13..
..
0.1 -
0.004677
0.1
6-13
0
0
0
0
0
0
0
p.0072
8-12
0.1
0
0.00471
9-12
•
0.1
0.006967
10 - 12
0.1
0
0.002968
11-12
0.1
0.002767
12 - 12
0./
0.003129

PERMIT NUMBER:. NC0088081
FACILITY NAME: Cookson D 0 G - Cookson remediation site
CITY: Ansonville
78391
ug/I '
Trichloroethene
TGP3B
pass/fail
P/F STATRE 7Day
Chr Ceriodaphnia
1-13
•
1
2-13
3-13
4-13
0
1
5-13
6-13
0
8-12
•
9-12
10-12
1
11-12
12 - 12
COUNTY: Anson
PERIOD ENDING MONTH: 7 - 2013 DMR 12 Month Calculated
PAGE 5 OF 5
REGION: Fayetteville

PERMIT NUMBER: NC0088081
FACILITY NAME: Cookson D 0 G - Cookson remediation site
CITY: Ansonville
OUTFALL: 001
EFFLUENT
COUNTY: Anson
PERIOD ENDING MONTH: 7 - 2012
REGION: Fayetteville
DMR 12 Month Calculated
PAGE 1 OF 4.
32103
ug/I
1,2-dichloroetha
ne
34010 .
ug/I
Toluene
34423
ug/I
Methylene
Chloride
(dichloromethane
methylene ,
dichloride)
34501
ugh
1,1-dichloroethy
lene
34506
ug/I
1 1,1-trichloro-
ethane
34516
ug/I
1122TETR
34696
ug/I
Naphthalene
50050
mgd
Flow, in
conduit or thru
treatment plant
1-12
0.1
- 2-12
.0.1
3-12
0.1
4-12
0.1
•5 - 12
0.1
6-12
0"1
7-12
0.1
8-11
0"9
9 - 11
0' "/
10-11
0"/
11-11
0./

PERMIT NUMBER: NC0088081
FACILITY NAME: Cookson D 0 G - Cookson remediation site
CITY: Ansonville
COUNTY: Anson
PERIOD ENDING MONTH: 7 - 2012
REGION: Fayetteville
DMR 12 Month Calculated
PAGE 2 OF 4
12 - 11
0.1
78391
ug/I
Trichloroethene
TGP3B
pass/fail
P/F STATRE 7Day
Chr Ceriodaphnia
1-12
2-12
3-12
4-12
5-12
6-12
7-12
8-11
9-11
10-11
11 - 11

PERMIT NUMBER: NC0088081
FACILITY NAME: Cookson D 0 G - Cookson remediation site
CITY: Ansonville
12-1.1
COUNTY: Anson
PERIOD ENDING MONTH: 7 - 2012 DMR 12 Month Calculated
PAGE 3 OF 4
REGION: Fayetteville

PERMIT NUMBER: NC0088081
FACILITY NAME: Cookson D 0 G - Cookson remediation site
CITY: Ansonville
OUTFALL: 001
EFFLUENT
COUNTY: Anson
34010
ug/I
Toluene
34501
ug/I
1,1-dichloroethy
Iene
50050
mgd
Flow, in
conduit or thru
treatment plant
TGP3B
pass/fail
P/F STATRE 7Day
Chr Ceriodaphnia
1 - 12
0.1
0.002903
1
2 - 12
0.1
0.005103
3 - 12
0.1
0.004
4-12
0.1
0.0061
1
5 - 12
0.1
0.006645
6 - 12
0.1
0.0076
7-12
0.1
0
0.010226
1
8 - 11
0.1
0.028935
9-11
0.1
0
0.015333
10 - 11
0.1
0.005645
1
11 - 11
0.1
0
0.0021
12 - 11
0.1
0.003065
PERIOD ENDING MONTH: 7 - 2012 DMR 12 Month. Calculated
PAGE 4 OF 4
REGION: Fayetteville

Whole Effluent Toxicity Testing and Self Monitoring Summary
tntonrLaitc-
ns WA_ F !r ' , NC0020117/00
C00a5�904/o0
2008
2009
2010
2011
2012
2013
J
2008 Pass
2009 Pass
2010 Pass
2011 Pass
2012 Pass
2013 Pass
J
2008 Pass
2009 Pass
2010 Pass
2011 Pass
2012 Pass
.2013 Pass
2008
2009
2010
2011
2012
2013
F
M
Pass
Pass
Pass
Pass
Pass
Pass
A
*
*
*
*
A
Pass
Pass
Pass
Pass
Pass
Pass
A
Pass
Pass
Pass
Pass
Pass
Pass
M
*
*
*
M
*
*
J .
Pass
Fail
Pass
Pass
Pass
Pass
J
J
H
H
H
H
H
H
J
•
92.5
*
*
*
*
J
Pass
Pass
Pass
Pass
Pass
J
Pass
Pass
Pass
Pass
Pass
*
S
Pass
>100
Pass
Pass
Pass
A
•
•
*
*
0
Pass
Pass
Pass
Pass
Pass
A S 0
* * Pass
# * Pass
* * Pass
* * Pass
* * Pass
*
*
S
*
*
*
0
Pass
Pass
Pass
Pass
Pass
N
•
*
*
*
*
*
*
*
*
Page 3 of 13

MONITORING REPORT(MR) VIOLATIONS for:
PERMIT:
FACILITY:
COUNTY:
Report Date: 09/04/
REGION:
13 Page: 1 of 1
atego`,ry NPDES WW
MONITORING OUTFALL /
REPORT PPI LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE % OVER LIMIT VIOLATION TYPE VIOLATION ACTION
VIOLATION UNIT OF
12/31/69
CALCULATED

�AT_
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory' Thomas A. Reeder
Governor Director
August 7th 2013
Cookson D.O.G
Former Cookson Facility
10056 US Highway 52
Ansonville, NC 28007
Subject: Receipt of permit renewal application
NPDES Permit NC0088081
Anson County
DENR-FRO
MMb 0 9 2013
wo
John E. Skvarla, III
Secretary
Dear Jamie Kalanta,
The NPDES Unit received your permit renewal application on August 6th 2013. This permit
renewal has been assigned Jim McKay (919-807-6404) who will contact you if any additional
information is required to complete your permit renewal. Due to current backlog, you should
continue to operate under terms of your current permit, until a new permit is issued. If you have
any questions, please contact the assigned permit writer.
Jeff Poupa
Point Source Branch Program Supervisor IV
Cc: Central Files
Fayetteville Regional Office
NPDES Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] Fax: [phone]
Internet:: www.ncwaterouality.orq
An'Equal OpportunitylAffirmative Action Employer