NC0088081_Permit Modification_20060601

NPDES DOCIMENT SCANNING COVER SHEET
NPDES Permit:
NC0088081
Cookson remediation site
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
'"'..1-
"0■060.,04 _
,..---._
Permit Modification.
Complete File - Historical
Engineering Alternatives (EAA)
Staff Report
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Permit
History
Document Date:
June 1, 2006
Thies document is printed ozi reuse paper - ignore any
conterit an the resrerse side

Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
June 1, 2006
Mr. Phillip L. Rahn
Waters Edge Environmental, LLC
4901 Waters Edge Drive, Suite 201
Raleigh, North Carolina 27606
Subject: NPDES Permit Modification
Permit No. NC0088081
Former Cookson Fibers Facility
Anson County
Dear Mr. Rahn:
The Division has reviewed your request to modify your permit to change the whole effluent
toxicity test from a composite sample to a grab sample. Due to the complexity of the site the
Division cannot grant the request. To consider this request the facility must demonstrate that
the effluent doesn't show variability over a 24 hour period. The Division has established
consistent requirements for this type of facilities, the chronic effluent toxicity test is a minimum
requirement for groundwater remediation facilities. Regarding your question about the
requirements to visit the site by the ORC please call or write to the Technical Assistant and
Certification Unit, 1618 Mail Service Center, Raleigh, NC 27699, [phone].
If you have any questions please call Teresa Rodriguez at [phone], extension 553.
EAST NPDES Unit Supervisor
Cc: Mr. Jamie Kalanta - Cookson DOG
NPDES Files
Aquatic Toxicology Unit
Central Files
Npr Caroli
/lna
atura!!y
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

WATERS EDGE ENVIRONMENTAL, LLC
4901 WATERS EDGE DRIVE, SUITE 201 • RALEIGH, NC 27606 • PHONE [phone] • FAx [phone]
May 17, 2006
Ms. Teresa Rodriquez
North Carolina Department of Environment and
Natural Resources/Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Reference: NPDES Permit Sampling Problems
Permit No. NC0088081
Former Cookson Fibers Facility
US 52
Ansonville, North Carolina
Waters Edge Job No. R3-28
Dear Ms. Rodriquez:
QUA'
BR,. •
Based upon a telephone conversation with the NCDENR Aquatic Toxicity Unit, Waters
Edge was unable to perform the April 2006 toxicity testing due to encountering major
difficulties with the continued operation of the ground water remediation system. This is
primarily due to iron which occurs naturally in the ground water and exsolves on the
filter, shallow tray stripper and carbon adsorption units. These iron deposits clog the
remediation system which basically shuts down in less than a week, therefore we cannot
collect the two aquatic toxicity samples necessary for the quarterly toxicity testing.
We have attempted to cut back the flow to the system and are cleaning out the filters on a
weekly basis. If this is successful, we will attempt toxicity sampling in the end of May.
However, I would request review of the following items:
• Consideration made for grab versus composite aquatic toxicity sampling
• One other option we may have to consider is a sequestering agent to keep the iron
in solution; however, I am told that this would potentially involve more stringent
ORC requirements (daily versus weekly visits). I would request your review as to
whether this is true.
• I cannot understand the requirement that an ORC has to visit the site on a weekly
basis. My client views this as entirely unnecessary for a ground water remediation
system composed of only a filter, shallow tray stripper and carbon adsorption
units. This surely is not required on all ground water remediation systems in
North Carolina.

If you have any questions regarding the information
hesitate to contact our office at 919.859.9987.
Sincerely,
WATERS EDGE ENVIRONMENTAL, LLC
Phillip L Rahn, P.G.
President
cc: Mr. Jamie Kalanta- Cookson DOG
Mr. Sean Boyles- NCDENR
NCDENR Aquatic Toxicity Unit
06-069/PLR/aht
NPDES Sampling Problems
Former Cookson Facility
Ansonville, NC
Page 2 of 2
contained herein, please do not

Re: Cookson Fibers
Subject: Re: Cookson Fibers
From: Kevin Bowden <[e-mail]>
Date: Fri, 26 May 2006 09:11:57 -0400
To: Teresa Rodriguez <[e-mail]>
Teresa,
I have not seen any request. Information below may be helpful.
I spoke with Mr. Rahn on 5/11/06 concerning Fe fouling the filters.
On 10/11/05, Matt spoke with Mr. Phil Rahn of Waters Edge Environmental, LLC regarding his request for a change in sampling
type from composite to grab at the former Cookson groudwater remediation site. He told Mr. Cookson that we had discussed the
issue with FRO staff (D. Lopez) and determined that we were NOT comfortable with this change at this time due to the complexity
of the site and questions about treatment technology. Matt left open the possibility of a change in sampling type in the future upon
showing by Waters Edge that the character of the effluent does not change over the course of 24 hours.
This is a 20 acre site with 17 pump wells and >30 monitoring wells. The facility only has about 4 minutes of EQ time and will be
remediating 107 #/day of VOC. Dale recommend use of composite versus grab sample. Consistency in permitting these facilities
is important.
Teresa Rodriguez wrote:
Kevin, did you received a letter from Waters Edge Environmental regarding a modification to the tox test for the Cookson
Fibers GW Facility, NC0088081?
Teresa
Kevin Bowden
NC DENR/DWQ
Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
[e-mail]
voice - 919.733.2136 X 253
fax - 919.733.9959
1 of 1 5/26/2006 9:17 AM