WQ0021577_Final Permit_20050826

of W ArFR Michael F. Easley, Governor
O� QG William G. Ross Jr., Secretary
y North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
p Y Division of Water Quality
August 26, 2005
MR. WILLIAM J. COOPER, JR., MILL MANAGER
INTERNATIONAL PAPER COMPANY
POST OFFICE BOX 580
ROANOKE RAPIDS, NC 27870
Subject: Permit No. WQ0021577
International Paper Company
IP RR Fly Ash Distribution Program
Distribution of Residual Solids (503 Exempt)
Halifax County
Dear Mr- Cooper:
In accordance with your application received on July 9, 2002 as well as the additional information
received on April 30, 2004; we are forwarding herewith Penmit'No. WQ0021577, dated August 26, 2005, to the
International Paper Company for the operation of the subject fly ash residuals distribution program.
This permit is being issued to approve the distribution of fly ash residuals (i.e., marketed under the
product name "IP RR Fly Ash") on unspecified fields or bulk distribution to potting soil makers. Note that the
residuals shall not be referred to as "biosolids" or as meeting Class A requirements as stipulated in 40 CFR Part
503 in marketing them to potential recipients.
This permit shall be effective from the date of issuance until July 31, 2010, and shall be subject to the
conditions and limitations as specified therein. PIease pay particular attention to the monitoring and reporting
requirements contained in this permit. Failure to establish an adequate system for collecting and maintaining the
required operational information will result in future compliance problems.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the right to
request an adjudicatory hearing upon written request within 30 days following receipt of this permit. This request
must be in the form of a written petition, conforming to Chapter 150B of North Carolina General Statutes, and
filed with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, NC 27699-6714. Unless
such demands are made, this permit shall be final and binding.
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636
Internet: hrinJlh2o.enr.state.ne.us 2728 Capital Boulevard Raleigh, NC 27604
No ` Carolina
�turu!!y
Phone [phone] Customer Service
Fax [phone]
Fax (919)715-W48
An Equal OpportunitylAlfrmative Action Employer- 50% Recycled110% Post Consumer Paper

If you need additional information concerning this matter, please contact J R Joshi at [phone], or
via e-mail [e-mail].
Si rely,
4L
Alan W. Klimek, P.E.
cc: Mr. Robert T. Branch, L.S.S., Brach Residuals & Soils, LLC
Halifax County Health Department
Raleigh Regional Office, Aquifer Protection Section
Technical Assistance and Certification Unit
APS Central Files
APS Files
LAU Residuals Program Coordinator

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
PERMIT FOR THE DISTRIBUTION OF FLY ASH RESIDUALS
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as amended,
and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
International Paper Company
Halifax County
FOR THE
operation of a program for the distribution of fly ash residuals from a surface disposal unit approved tinder Permit
Number WQ0000436 and produced at the Roanoke Rapids, NC Mill's No. I boiler located at North Roanoke
Avenue (i.e., at an approximate latitude of 36' 28' 19" and Iongitude of 77" 38' 14") in Roanoke Rapids, North
Carolina. The program shall result in the distribution of up to 15,000 dry tons per year of fly ash residuals from
the sources listed in Condition 11.2., with no discharge of wastes to the surface waters, pursuant to the application
received on July 9, 2002 as well as the additional information received on April 30, 2004;; and in conformity with
the project plan, specifications, and other supporting data subsequently filed and approved by the Department of
Environment and Natural Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until July 31, 2010, and shall be subject to the
following specified conditions and limitations:
I. PERFORMANCE STANDARDS
The distribution of fly ash residuals program shall be effectively maintained and operated as a non -
discharge system to prevent the discharge of any wastes resulting from the operation of this program.
2. This permit shall become voidable in the event of failure of the fly ash residuals program to adequately
protect the assigned water duality standards of the surface waters and groundwaters.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to surface or
groundwaters resulting from the operation of this program.
4. In the event that the fly ash residuals program is not operated satisfactorily, including the creation of
nuisance conditions, the Permittee shall take any immediate corrective actions as may be required by
the Division of Water Quality (Division).
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5. The following buffer zones shall be maintained for distribution efforts:
a. 100 feet from any public or private water supply source, waters classified as SA or SB, and any
Class I or Class H impounded reservoir used as a source of drinking water for both methods,
b. 100 feet from any streams classified as WS or B, any other stream, canal, marsh or coastal waters
and any other lake or impoundment for surface application,
c. 50 feet from any streams classified as WS or B, any other stream, canal, marsh or coastal waters
and any other lake or impoundment for subsurface application,
d. 50 feet from property lines for both surface and subsurface application methods;
e. 50 feet from public right of ways for both application methods,
f. 25 feet from downslope interceptor drains, surface water diversions, groundwater drainage
systems and surface drainage ditches for both application methods.
6. A copy of this permit and a spill prevention and control plan shall be maintained in all residuals
transport and application vehicles.
7. No fly ash residuals shall be stored at any location other than the surface storage unit approved under
Permit Number WQ0000436 at any time, unless approval has been requested and obtained from the
Division.
II. OPERATION AND MAINTENANCE REQUIREMENTS
The facilities and distribution program shall be properly maintained and operated at all times.
2. No fly ash residuals other than the following are hereby approved for distribution in accordance with
this permit:
Permit Volume
Source County Number (Dryons/Year)
International Paper Company -
Roanoke Rapids' Halifax NCO000752 15,000
'The storage units for this facility are the ash pond and monofil. The monofil at this fly ash
residuals source -generating facility is designed such that the fly ash residuals will remain in
storage for a period of greater than two years and are covered under Permit Number WQ0000436.
The following uses of ash are hereby approved:
a. Use as a soil amendment to land in accordance witb the requirements outlined in the product Iabel
as well as the application rates recommended by an agronomist based on soil analysis done prior
to distribution efforts.
b. Use for bulk distribution to potting soil makers as a component of the potting soil matrix
4. All fly ash residuals shall be adequately stored to prevent leachate runoff until treated. The finished
product may be placed on a concrete pad, placed under shelter or covered until such time as it is
distributed. If an alternate storage site is to be used, approval must be obtained from the Division.
No other residuals other than those specified under Condition 11.2. above may be distributed. The
Permittee shall request and obtain a permit amendment from the Division for each additional residual
source prior to acceptance of that residual.

6. For a residual to be distributed, sold or given away in bags or other container for application to the
land, the following must be satisfied:
The Ceiling Concentrations (Dry Weight Basis) and the Pollutant Monthly Average
Concentrations (Dry Weight Basis) must be maintained:
Ceiling Monthly Average
Concentrations Concentrations
Parameters mglkg mg/kg
Arsenic
75
41
Cadmium
85
39
Copper
4,300
1,500
Lead
840
300
Mercury
57
17
Molybdenum
75
--
Nickel
420
420
Selenium
100
100
Zinc
7,500
2,800
All recipients of the distributed shall be provided with an information/data sheet that contains the
following minimum information:
a. The name, address, and telephone number of the person who prepared the fly ash residuals.
b. The name, address, and telephone number of the person distributing the fly ash residuals.
c. A description of the source of or the process by which the fly ash residuals were generated.
d. A summary of the results from the most recent round of fly ash residuals sampling/monitoring.
e. A summary of the volume of fly ash residuals distributed either per unit or bulk provided
f A summary of the nutrients either per unit or bulk provided(i.e., PAN, phosphorus, and
potassium).
g. A statement that an acceptable pH (as defined by NCDA, agronomist or soil scieintist for the crop
to be grown) be maintained in the soil, fly ash residuals and lime mixture, on all sites to ensure
optimum yield for the crop(s) and a list of recommendations to the recipient of the fly ash
residuals regarding field use, soil testing, pH adjustment, and other relevant agronomic
information.
8. A label shall be affixed to the bag or other container in which fly ash residuals that are sold or given
away for application to the land, or an information sheet shall be provided to the person who receives
the fly ash residuals sold or given away in another container for application to the land. The label or
information sheet shall contain the following information:
a. The name, address, and phone number of the person who prepared the fly ash residuals that is
sold or given away in a bag or other container for application to the land.
b. A statement that application of the fly ash residuals to the land is prohibited except in accordance
with the instructions on the label or information sheet.
c. A statement which identifies that this material shall be prevented from entering any public or
private water supply source (including wells) and any stream, lake, or river.
d. Fly ash residuals shall not be applied to any site that is flooded, frozen or snow-covered.
e. Adequate procedures shall be provided to prevent surface runoff from carrying any disposed or
stored fly ash residuals into any surface waters.

III. MONITORING AND REPORTING REQUIREMENTS
I. Any monitoring (including groundwater, surface water, residuals, soil, or plant tissue analyses)
deemed necessary by the Division to insure protection of the environment will be established and an
acceptable sampling and reporting schedule shall be followed.
2. Proper records shall be maintained by the Permittee tracking all distribution activities. These records
shall include, but are not be necessarily limited to, the following information:
a. Source, volume, and analysis of each residual;
b. Name of residual's recipient, volume received, and intended use.
3. A representative residual analysis shall be conducted every 60 days from the date of permit issuance
by the Permittee for the first two years, and quarterly thereafter with prior review and approval from
this Division. The results of all analysis shall be maintained on file by the Permittee for a minimum
of five years. The residuals analysis shall include the following parameters:
Cadmium
Copper
Zinc
Arsenic
Selenium
Aluminum
Calcium
Magnesium
% Total Solids
pH
Potassium
Sodium
Plant Available Nitrogen
(by calculation)
Calcium Carbonate Equivalency (CCE) (by titration)
Lead Nickel
Mercury Molybdenum
Ammonia -Nitrogen
Nitrate -Nitrite Nitrogen
Phosphorus
TKN
4. A Toxicity Characteristics Leaching Procedure (TCLP) analysis shall be conducted by the Permittee
once per permit cycle. The TCLP analysis shall include the following parameters (please note the
regulatory level in mg/L in parentheses):
Arsenic (5.0)
Cadmium (1.0)
Chlorobenzene (100.0)
o-Cresol (200.0)
Cresol (200.0)
1,2-Dichloroethane (0.5)
Endrin (0.02)
Hexachlorobenzene (0.13)
Lead (5.0)
Methoxychlor (10,0)
Pentachlorophenol (100.0)
Silver (5.0)
Trichloroethylene (0.5)
2,4,5-TP (Silvex) (1.0)
Barium (100.0)
Benzene (0.5)
Carbon tetrachloride (0.5)
Chlordane (0.03)
Chloroform (6.0)
Chromium (5.0)
m-Cresol (200.0)
p-Cresol (200.0)
2,4-D (10.0)
1,4-Dichlorobenzene (7.5)
1,1-Dichloroethylene (0.7)
2,4-Dinitrotoluene (0.13)
Heptachlor (and its hydroxide) (0.008)
Hexachloro-1,3-butadiene (0.5)
Hexachloroethane (3.0)
Lindane (0.4)
Mercury (0.2)
Methyl ethyl ketone (200.0)
Nitrobenzene (2.0)
Pyridine (5.0)
Selenium (1.0)
Tetrachloroethylene (0.7)
Toxaphene (0.5)
2,4,5 TrichlorophenoI (400.0)
2,4,6-Trichlorophenol (2.0)
Vinyl chloride (0.2)
5. Three copies of all required monitoring and reporting requirements as specified in Conditions III.1.,
M. 2., III. 3., and III.4., shall be submitted annually on or before March 1st of the year following the
distribution event to the.following address:
NCDENR-DWQ
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

6. Noncompliance Notification:
The Permittee shall report by telephone to the Raleigh Regional Office, telephone number (919) 571-
4700, as soon as possible, but in no case more than 24 hours or on the next working day following the
occurrence or first knowledge of the occurrence of any of the following:
a. Any occurrence with the distribution program which results in the distribution of significant
amounts of wastes which are abnormal in quantity or characteristic.
b. Any failure of the distribution program resulting in a release of material to receiving waters.
c. Any time that self -monitoring information indicates that the facility has gone out of compliance
with the conditions and limitations of this permit or the parameters on which the system was
designed.
d. Any process unit failure, due to known or unknown reasons, that render the facility incapable of
adequate residual treatment.
e. Any spillage or discharge from a vehicle or piping system during transportation of residuals.
Persons reporting such occurrences by telephone shall also file a written report in letter form within
five days following first knowledge of the occurrence. This report must outline the actions taken or
proposed to be taken to ensure that the problem does not recur.
IV. GROUNDWATER REQUIREMENTS
The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in 15A NCAC
2L, Groundwater Classifications and Standards. The Compliance Boundary is for the disposal system
constructed after December 31, 1983 is established at either (1) 250 feet from the waste disposal area,
or (2) 50 feet within the property boundary, whichever is closest to the waste disposal area. An
exceedance of Groundwater Quality Standards at or beyond the Compliance Boundary is subject to
immediate remediation action according to 15A NCAC 2L .0106 (d) (2).
The REVIEW BOUNDARY is established around the disposal systems midway between the
Compliance Boundary and the perimeter of the waste disposal area. Any exceedance of standards at
the Review Boundary shall require remediation action in according with 15A NCAC 2L .0106 (d) (1).
2. Any groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
V. INSPECTIONS
The Permittee or his designee shall inspect the residuals storage, transport, and treatment facilities to
prevent malfunctions and deterioration, operator errors and discharges which may cause or lead to the
release of wastes to the environment, a threat to human health, or a nuisance. The Permittee shall
maintain an inspection log or summary including at least the date and time of inspection, observations
made, and any maintenance, repairs, or corrective actions taken by the Permittee. This log of
inspections shall be maintained by the Permittee for a period of five years from the date of the
inspection and shall be made available to the Division or other permitting authority, upon request.

2. Any duly authorized officer, employee, or representative of the Division may, upon presentation of
credentials, enter and inspect any property, premises or place on or related to the treatment site or
facility at any reasonable time for the purpose of determining compliance with this permit; may
inspect or copy any records that must be kept under the terms and conditions of this permit; and may
obtain samples of groundwater, surface water, or leachate.
VI. GENERAL CONDITIONS
This permit shall become voidable unless the distribution activities are carried out in accordance with
the conditions of this permit, the supporting materials, and in the manner approved by this Division.
2. This permit is effective only with respect to the nature and volume of fly ash residuals described in
the application and other supporting data.
3_ This permit is not automatically transferable. in the event that there is a desire for the facilities to
change ownership or a name change of the Permittee, a formal permit request must be submitted to
the Division accompanied by an application fee, documentation from the parties involved, and other
supporting materials as may be appropriate. The approval of this request will be considered on its
merits and may or may not be approved.
4. Failure to abide by the conditions and limitations contained in this permit may subject the Permittee
to an enforcement action by the Division in accordance with North Carolina General Statute 143-
215.6A to 143-215.6C.
The annual administering and compliance fee must be paid by the Permittee within 30 days after
being billed by the Division. Failure to pay the fee accordingly may cause the Division to initiate
action to revoke this permit as specified by 15 NCAC 2H .0205 (c)(4).
b. The issuance of this permit does not preclude the Permittee from complying with any and all statutes,
rules, regulations, or ordinances which may be imposed by other government agencies (local, state,
and federal) which have jurisdiction, including but not limited to applicable river buffer rules in 15A
NCAC 2B.0200, erosion and sedimentation control requirements in 15A NCAC Chapter 4 and under
the Division's General Permit NCG010000, and any requirements pertaining to wetlands under 15A
NCAC 2B ,0200 and 2H .0500.
7. The Permittee, at least six months prior to the expiration of this permit, shall request its extension.
Upon receipt of the request, the Commission will review the adequacy of the facilities described
therein, and if warranted, will extend the permit for such period of time and under such conditions
and limitations as it may deem appropriate.
8. This permit may be modified, or revoked and reissued to incorporate any conditions, limitations and
monitoring requirements the Division deems necessary in order to adequately protect the environment
and public health.
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Permit issued this the, twenty- sixth day of August, 2005
NORTH
AL MANAGEMENT COMMISSION
Alan W. Klimek, P.E.,Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0021577