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Home My WebLink AboutNC0003298_Compliance Evaluation Inspection_20231130DocuSign Envelope ID: D9885AE8-2FDC-48A8-B58D-EE1 1311 F847A2 ROr COOPER ELIZABETH S. BISER RICHARD E. ROGERS, JR. NORTH CAROLINA Director Environmental Quality December 06, 2023 Stephen Greer, PhD International Paper Company 865 John L Riegel Rd Riegelwood, NC 28456 SUBJECT: Compliance Inspection Report Riegelwood Mill NPDES WW Permit No. NC0003298 Columbus County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Riegelwood Mill on 11/30/2023. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0003298. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report". There were no significant issues or findings noted during the inspection and therefore, a response to this inspection report is not required. If you should have any questions, please do not hesitate to contact Bryan Lievre with the Water Quality Regional Operations Section in the Wilmington Regional Office at 910-796-7215 or via email at bryan.lievre@deq.nc.gov. Sincerely, C DocuSigned by:�"W►n (� 5ol�,� j ,ry,-6, 8554BOF62D ED464... Morelia Sanchez -King, Regional Supervisor Water Quality Regional Operations Section Wilmington Regional Office Division of Water Resources, NCDEQ Attachment Cc: Wallace Coverdale (via email WaIlace. Coverdale@ipaper.com) Upload to Laserfiche Nwth Carolina Otpao—t orEnvlronmenlal Qa Ilty I [AMsion J Watee Rew—s Wilmington Reglanalow-I 12ICaMIna1Dr1ve Eetenslan I W.Wng10 North Ca 11l a25495 91619b ]215 DocuSign Envelope ID: D9885AE8-2FDC-48A8-B58D-EE1 B11 F847A2 United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 IN 1 2 15 1 3 I NC0003298 I11 121 23/11/30 I17 18 n 19 L G j 201 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 CA ---------------------- Reserved ------------------- 67 I 71 I I 72 L n, � 73 LLI74 71 I I I I I I I80 70 Iu ty LJ Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES permit Number) 08:30AM 23/11/30 19/11/01 Riegelwood Mill 865 John L Reigel Rd Exit Time/Date Permit Expiration Date Riegelwood NC 28456 12:15PM 23/11/30 23/07/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Patricia Coleman Soles/ORC/910-362-4729/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Stephen Greer,865 John L Riegel Rd Riegelwood NC 28456//910-362-3476/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran 0 Sludge Handling Dispos Facility Site Review Compliance Schedules Effluent/Receiving Wate 0 Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date DocuSigned by: Bryan Lievre $ "zt DWR/WIRO WQ/910-796-7215/ 12/6/2023 31BDD428 Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date DocuSigned by. morella.sanchez-king@deq.nc.gov 12/6/2023 L-8 5gg OF62DED464... V EPA Form 3560-3 (Rev 9-94� F'reVious editions are obsolete. Page# DocuSign Envelope ID: D9885AE8-2FDC-48A8-B58D-EE1 1311 F847A2 NPDES yr/mo/day Inspection Type (Cont.) 31 NC0003298 I11 12I 23/11 /30 117 18 ICI Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) A routine compliance inspection of the Riegelwood Mill Wastewater Treatment Plant (WWTP) was performed on November 30, 2023. The purpose of the inspection was to verify that the facility is operating in compliance with the conditions and limitations specified within Permit NC0003298. Facility staff present during the inspection were Wallace Coverdale, Patricia Soles (ORC) and Colleen Cohn. Stephen Greer, PhD, Halima Moses and Charlie Knox were also present during discussions prior to and after the inspection of structures. The facility is currently permitted to receive up to 50 million gallons per day (mgd) of wastewater and has an average daily flow of 28.5 mgd since 2018. Water supply for the facility is derived from an intake on the Cape Fear River, approximately 0.6 miles west of Outfall 001. The WWTP is a Grade 4 biological plant that has the following components: - Dual mechanical barscreens (1 at each clarifier with bypass lines to the other clarifier) - Two (2) primary clarifiers, each with dual sludge pumps o Clarifier #1 is has an earthen bottom and sides and has a capacity of —9.3 MG and typically receives flow from domestic wastewater system, storm water from the lumber yard and other facility operations o Clarifier #2 has a concrete bottom and sides and has a capacity of —2.3 MG and typically receives flow from the bleach plants and stormwater from the Holtrachem site - Nutrient addition facilities, with injection of aqueous ammonia (<20%) at up to two locations along the clarifier effluent channel prior to the lagoon system - 173 acres of aerated lagoons with re -circulation and —72 surface aerators (aka aerated stabilization basin system or ASB) o A spillway channel leading to the aerated stabilization basin (ASB) system o New Bay o Theodoraris (aka "Theo") Pond, —42 acres with primary aeration o South Lagoon, —45 acres with some aeration and internal baffle wall o North Lagoon, —32.5 acres with effluent to Outfall 001 - Six (6) sludge holding lagoons o Ponds A, B and C which typically receive WAS from Clarifier #'s 1 & 2 o Ponds 1, 2 and 3 which typically receive secondary sludge from the ASB - Sludge dewatering presses - Oxygen injection facilities - Flow measurement and equipment Outfall 001 discharges wastewater associated with all industrial operations, landfill leachate, stormwater, and sanitary sewer wastewater. Outfall 001 consists of a Parshall Flume and discharges wastewater to the Cape Fear River. The facility also has two internal Outfalls. Internal Outfall 004 receives flow from Bleach Plants 1 and 2 and Internal Outfall 005 receives flow from Bleach Plant 3. The system also has separate flow meters for Outfalls 004 and 005 upgradient of their respective sampling locations. The facility has not had any violations since prior to the last inspection which was performed on 12/10/2021. The staff were very knowledgeable of the facility operations and the facility seemed to be well maintained. Records were reviewed and found to be detailed, well organized and complete. The facility is compliant with the terms and conditions of the permit. Please review the comment sections of the inspection report for more details. Page# DocuSign Envelope ID: D9885AE8-2FDC-48A8-B58D-EE1 1311 F847A2 Permit: NC0003298 Owner - Facility: Riegelwood Mill Inspection Date: 11/30/2023 Inspection Type: Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new 0 ❑ ❑ ❑ application? Is the facility as described in the permit? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? 0 ❑ ❑ ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑ Comment: The current permit was issued 9/23/2019 and expired 7/31/2023. A permit renewal application was submitted by the permittee in February 2023. Special Conditions includes chronic toxicity sampling, effluent and fish tissue dioxin monitoring plans and adherence to Cluster Rule BMPs for monitorina and spill prevention and control. 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 for 3 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? Facility has copy of previous year's Annual Report on file for review? Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Page# 3 DocuSign Envelope ID: D9885AE8-2FDC-48A8-B58D-EE1 1311 F847A2 Permit: NC0003298 Owner - Facility: Riegelwood Mill Inspection Date: 11/30/2023 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Comment: On-line DMRs were viewed prior to the inspection and hard copies of DMRs for 6/23 — 9/23, random chain of custody forms, an ORC visitation log, calibration logs for field instruments, and a report entitled Cluster Rule Best Management Practices, dated July 2022 were viewed during the inspection. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? 0 ❑ ❑ ❑ Are all other pa ra mete rs(exclud ing field parameters) performed by a certified lab? 0 ❑ ❑ ❑ # Is the facility using a contract lab? 0 ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 ■ ❑ ❑ ❑ degrees Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? 0 ❑ ❑ ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? 0 ❑ ❑ ❑ Comment: International Paper — Riegelwood Mill maintains certification #140 for BOD, DO, PH TSS and temperature. The system uses a Hach 40D for DO and a Yokagawa PH72 portable PH meter. The system has also installed and is utilizing a Real -Time Tech monitoring system in the clarifier discharge canal to assist in understanding system characteristics prior to entering the lagoons. The system utilizes outside lab for other analyses such as ETS for chronic toxicity, ALS Environmental for dioxins, Envirochem for other compounds. The incubator for BOD analysis was 20.3°C the day of inspection and calibrants for field instruments were within their respective hold -times. Bar Screens Yes No NA NE Type of bar screen a.Manual ❑ b.Mechanical Are the bars adequately screening debris? 0 ❑ ❑ ❑ Is the screen free of excessive debris? 0 ❑ ❑ ❑ Is disposal of screening in compliance? 0 ❑ ❑ ❑ Is the unit in good condition? 0 ❑ ❑ ❑ Comment: Prior to each bar screen, the facility has ISCO composite samplers and flow meters (for internal use). The facility contains dual mechanical bar screens and both appear to be operating effectively. Debris recovered from the bar screens is sent to the on -site landfill for disposal. Primary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? 0 ❑ ❑ ❑ Are weirs level? ❑ ❑ ❑ Page# 4 DocuSign Envelope ID: D9885AE8-2FDC-48A8-B58D-EE1 1311 F847A2 Permit: NC0003298 Owner - Facility: Riegelwood Mill Inspection Date: 11/30/2023 Inspection Type: Compliance Evaluation Primary Clarifier Yes No NA NE Is the site free of weir blockage? 0 ❑ ❑ ❑ Is the site free of evidence of short-circuiting? 0 ❑ ❑ ❑ Is scum removal adequate? 0 ❑ ❑ ❑ Is the site free of excessive floating sludge? 0 ❑ ❑ ❑ Is the drive unit operational? 0 ❑ ❑ ❑ Is the sludge blanket level acceptable? ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) ❑ ❑ ❑ Comment: The facility has two primary clarifiers — one receiving the effluent from the three internal bleach plants (Clarifier #2) and the other receiving effluent from other facility operations (Clarifier #1). The primary clarifiers remove wood fibers and debris which is returned to the mill to be pressed, dried and used for fuel or directed to sludge basins where the sludge is dewatered and placed in the on -site landfill. Clarifier loading rates and blanket levels are monitored by measuring amperage used by each units rake motor amperage, with higher values indicating a higher/heavier blanket level. Aeration Basins Mode of operation Type of aeration system Is the basin free of dead spots? Are surface aerators and mixers operational? Are the diffusers operational? Is the foam the proper color for the treatment process? Does the foam cover less than 25% of the basin's surface? Is the DO level acceptable? Is the DO level acceptable?(1.0 to 3.0 mg/1) V0M. ill r•7ill rim ill I:I Ext. Air Surface ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Comment: After primary clarification wastewater from the mill process areas is treated in the 173-acre aerated stabilization basin (ASB) system. Wastewater travels from the Primary clarifiers to the ASB system via a canal to the "New Bay." Seventy two (72) floating surface aerators are positioned within the 42-acre "New Bay" to provide mixing and treatment of process wastewaters before flow is directed to the intermediate "Theo Pond" area. Within the "Theo Pond" and "New Bay" areas of accumulated solids can be more easily dredged for disposal. Wastewater then flows to the 42-acre "South Lagoon" which contains five (5) surface aerators and a floating baffle curtain to prevent short circuiting before reaching the 32.5-acre "North Lagoon". Effluent is discharged from a gate and weir feature from the "North Lagoon" into the Cape Fear River. The ASB system has a detention time of approximately 9 days. DO levels within the New Bay, South Lagoon and North Lagoon were 2.6 mg/L, 3.1 mg/L and 1.8 mg/L, respectively. Chemical Feed Yes No NA NE Page# 5 DocuSign Envelope ID: D9885AE8-2FDC-48A8-B58D-EE1 1311 F847A2 Permit: NC0003298 Inspection Date: 11/30/2023 Owner - Facility: Riegelwood Mill Inspection Type: Compliance Evaluation Chemical Feed Yes No NA NE Is containment adequate? 0 ❑ ❑ ❑ Is storage adequate? ■ ❑ ❑ ❑ Are backup pumps available? 0 ❑ ❑ ❑ Is the site free of excessive leaking? 0 ❑ ❑ ❑ Comment: The addition of sulfuric acid, 20% ammonia solution, defoamer, bacterial cultures and oxygen can used as needed within the treatment process. NH3 and supplemental bacteria can be added prior to entry into New Bay. Oxygen and defoamer can be infected into the effluent, as needed. Compliance Schedules Yes No NA NE Is there a compliance schedule for this facility? 0 ❑ ❑ ❑ Is the facility compliant with the permit and conditions for the review period? 0 ❑ ❑ ❑ Comment: Lagoons Yes No NA NE Type of lagoons? Aerated # Number of lagoons in operation at time of visit? 4 Are lagoons operated in? Series # Is a re -circulation line present? ❑ 0 ❑ ❑ Is lagoon free of excessive floating materials? 0 ❑ ❑ ❑ # Are baffles between ponds or effluent baffles adjustable? 0 ❑ ❑ ❑ Are dike slopes clear of woody vegetation? 0 ❑ ❑ ❑ Are weeds controlled around the edge of the lagoon? 0 ❑ ❑ ❑ Are dikes free of seepage? 0 ❑ ❑ ❑ Are dikes free of erosion? 0 ❑ ❑ ❑ Are dikes free of burrowing animals? 0 ❑ ❑ ❑ # Has the sludge blanket in the lagoon (s) been measured periodically in multiple ❑ ❑ ❑ locations? # If excessive algae is present, has barley straw been used to help control the growth? ❑ ❑ 0 ❑ Is the lagoon surface free of weeds? 0 ❑ ❑ ❑ Is the lagoon free of short circuiting? 0 ❑ ❑ ❑ Page# 6 DocuSign Envelope ID: D9885AE8-2FDC-48A8-B58D-EE1 1311 F847A2 Permit: NC0003298 Owner - Facility: Riegelwood Mill Inspection Date: 11/30/2023 Inspection Type: Compliance Evaluation Lagoons Yes No NA NE Comment: As mentioned above, the aerated stabilization basin (ASB) currently use 4 lagoons with —72 floating surface aerators. There is a diversion curtain wall located in the South Lagoon to prevent short circuiting within the basin. Accumulated material on the bottom of the lagoons is removed as needed, typically on an annual basis. A windshield survey of the berms for the aeration basins was performed. The northeast side of the North Lagoon has the highest berm height. The system has taken steps to cut back vegetation in this area, the sides appeared to be maintained and no visible seepage was observed. The facility has also set up their own dam safety department that regularly inspects lagoon sidewalls. The system also has six (6) sludge earthen wall sludge lagoons (Ponds A, B, C, 1, 2 & 3). 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: The ultrasonic effluent flow meter is calibrated at least last calibration performed on 10/2/2023. 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)? MOM kr•7k rim kI:I ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ m staff. with the Yes No NA NE ■ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ Is the facility sampling performed as required by the permit (frequency, sampling type 0 ❑ ❑ ❑ representative)? Comment: The composite sampler at Outfall 001 was inspected and the sample tubing was found to be clean with no kinks at the storage chamber had a dedicated thermometer which indicated a temperature of 1 °C. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? 0 ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0❑ Comment: Effluent is discharged to the Cape Fear River which is classified Class C:Swamp waters in the area. The facility infects oxygen at Outfall 001 to increase DO levels above 5.0 mg/L, as needed, depending on the downstream monitoring location. Page# 7 DocuSign Envelope ID: D9885AE8-2FDC-48A8-B58D-EE1 1311 F847A2 Permit: NC0003298 Owner - Facility: Riegelwood Mill Inspection Date: 11/30/2023 Inspection Type: Compliance Evaluation Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, ■ ❑ ❑ ❑ and sampling location)? Comment: The downstream monitoring site is overseen by the Lower Cape Fear River Monitoring Coalition which monitors 36 locations along the river. Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: System staff monitor each process throughout the system to enable early detection and prevention of downgradient problems. Page# 8