NC0023442_Closure Plan_20190424

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Boise Cascade
Chester Plywood
1445 Lancaster Highway
PO Box 1110
hester, SC 29706
April 24, 2019 RE CEIVEDINCDE�ID
Via Certified Mail: 7018 2290 0001 7085 7070 MAY 0 2019
Aquifer Protection Section Non-Discharge
ne
Permitting Unit RECEM2t;„ C,DE0101itIP
NCDEQ, Division of Water Quality
1617 Mail Service Center MAY 0 8 2019
Raleigh, North Carolina 27699-1617
Water Quality
Re. Waste Treatment Pond Closure Plan, NPDES Permit NC0023442 Regional Operations Section
To Whom It May Concern:
By way of this letter, we are informing the Aquifer Protection Section (APS) that in February
2019, Boise Cascade Wood Products, L.L.C. (BCWP) sold its Moncure, NC facility, including
the Domestic Facultative Wastewater Treatment Pond, Permit NC0023442 (Pond), to Southern
Veneer Specialty Products (SVSP). However, BCWP will be decommissioning the pond in
accordance with the facility's wastewater Permit NC0023442. We are submitting this Pond
Closure Plan that follows the June 22, 2012 APS Guidance Document (the Guidance), and
correspondence between Brian Van Gelder of BCWP and Thomas McKinney at the
APS. BCWP will manage the closure project and will coordinate with APS as necessary.
Checklist With Chosen Options Our Checklist is attached.
Historical Use and Current Status of the Pond: The Pond received sanitary wastewater from the
main wood products processing facility and stormwater inflow. The sanitary wastewater inflow
from the main facility stopped in January of 2017 The pipe from the facility to the Pond was cut
and capped so that sanitary wastes from the facility could no longer discharge to the Pond.
Stormwater still enters the Pond.
Future Plan for Site: Currently, SVSP does not have any plans to use the pond for any specific
purpose If SVSP decides to use the pond for any purpose requiring a permit, SVSP will apply
for the necessary permits for the Pond in accordance with that use.
Disposal Options for Wastewater: BCWP received a Domestic Wastewater Pump and Haul
Permit (WQ0040664 Revision 1), and is currently disposing of the wastewater according to the
permit at Shamrock Environmental Corporation 6106 Corporate Park Dr. Browns Summit, NC
27214. BCWP expects to continue to pump and haul wastewater as necessary to maintain the
Pond level below freeboard limits in accordance with the Pump and Haul Permit. Wastewater is
also pumped from the Pond to the new wastewater treatment system for treatment and
discharged as allowed by the facility's wastewater permit. BCWP will continue to remove
wastewater from the treatment Pond through pump and haul and through discharge to the
treatment system until the Pond can be accessed for sludge removal as described below.
Disposal Options for Sludge: North Carolina Department of Environmental Quality (NC DEQ)
approved landfill, NC DEQ approved composting site or NC DEQ approved land application
{ENV Dept LLC/599/01937275 DOCX }PPAB 4139348v1

April 24, 2019
Page 2
sites are still being considered and multiple sites may be selected depending on the ability of
the facilities to accept all of the sludge. The preferred option is disposal at a compost facility.
Sludge Disposal Location(s): BCWP is considering the following locations for sludge disposal:
Greak Oak Landfill — Randleman, NC; Uwharrie Landfill - Mount Gilead, NC; McGill Compost
Facility — New Hill, NC and Sampson County Landfill — Roseboro, NC. All of these landfills are
permitted to accept this type of material. BCWP will inform NC DEQ of the selected site or sites
prior to initiating sludge removal. BCWP requests NC DEQ to approve each of the sites at this
time.
Pre-Removal Sludge Sampling and Analysis: Sludge samples will be collected and analyzed in
accordance with the attached Waste Characterization Plan prepared by Shamrock
Environmental Corporation (Shamrock). Shamrock based the plan on NC DEQ requirements
and discussions with potential disposal facilities. Shamrock will collect six composited samples
of the sludge. All samples will be shipped under Chain-of-Custody to Pace Analytical in
'Raleigh, NC for analysis for the following constituents as identified in the Waste
Characterization Plan;
Hazardous Waste Characterization and Landfill Acceptance
TCLP 8 RCRA Metals, VOCs, SVOCs and Herbicides & Pesticides
PCBs DRO & GRO
Oil & Grease Corrosivity
Ignitability (Flashpoint) Reactivity (Cyanide and Sulfide)
Compost Characterization —Total Metals
Arsenic Molybdenum Cadmium Nickel
Copper Selenium Chromium Zinc
Lead Mercury Aluminum
Compost Characterization — Plant Nutrients and General Chemistry
Phosphorus Calcium Magnesium Potassium
Sodium Total Carbon % Solids Volatile Solids
TKN NO3-N NH4-N Plant Available N
pH
Sludge Removal Procedure:
1. Continue to remove and dispose wastewater as much as possible to access sludge.
2. Using a long-reach excavator, build an entry point into the Pond and place equipment
work mats as necessary to provide for safe operation with minimal disturbance of the
Pond bottom.
3. Excavate visually identifiable bio-solids to the top of the soil, depositing the soils into one
or more mixing areas within the Pond.
4. Sawdust will be staged at several locations around the Pond perimeter within reach of
the excavator. The sawdust will be mixed with the sludge in sufficient quantities to
ensure the sludge will pass the paint filter test. The sludge-sawdust mixture will then be
loaded into dump trucks for transport to the selected disposal site(s).
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April 24, 2019
Page 3
5. Excavation and mixing of the sludge will continue until visual observations indicate the
sludge has been adequately removed and the bottom of the Pond is visible. Because
SVSP may re-use the Pond after decommissioning, excavation will minimize impact to
the clay liner. There are no plans to remove or scarify the liner unless post-sludge
removal soil samples indicate the need to address that issue.
Post-Sludge Removal Soil Sampling and Analysis: Once the sludge is removed, post-removal
soil samples will be collected from eight locations within the Pond area. Soil samples will be
collected by Randall Jarrell, the facility Operator in Responsible Charge (ORC) using
appropriate hand auger or similar tool. Samples will be collected at one-foot intervals to a depth
of three feet in each sample location. If the boreholes remain open, they will be backfilled with
bentonite pellets. The soil samples will be analyzed based on the sludge analytical results.
Once the sludge analyses are complete, BCWP will submit those results and recommendations
for specific soil analyses to NC DEQ for review and approval.
The concentration of contaminants in the post-removal soil samples will be compared to
protection of groundwater standards as per the Guidance. Soil meeting these standards will be
left in place. If soil exceeds these standards, a decision will be made in consultation with APS
regarding removal of additional soil.
Post-Decommissioning Pond Water Evaluation: After sludge removal is complete, and
the Pond bottom has been determined to be sufficiently remediated, some residual material may
exist which could impact the quality of water remaining in the Pond and/or that fills the Pond
over time. SVSP will monitor the Pond water quality and will discharge to the existing treatment
system any water that exceeds current permit limits. Once the Pond water quality consistently
meets the current permit limits and/or the applicable water quality standards for the receiving
stream, SVSP will provide those results to NC DEQ, request to have the waste treatment Pond
removed from the current permit and apply for a new permit, if a new permit is required for a
future intended use
Liner Removal/Disposal and Site Reclamation: The Pond's clay liner will remain in place
unless it must be partially removed to meet the site remediation goals. The Pond berms will
also remain in place. Any remaining sawdust and the liners used in the mixing areas will be
removed and disposed in the approved landfill. The site will be re-graded as necessary to
restore proper drainage, and the area will be reseeded as necessary to reestablish grass cover
of disturbed areas.
Final Report Submittal: BCWP will provide a final report including photos of closure
activities documenting conditions prior to initiating closure, closure activities, and post-closure
conditions will be provided. Analytical reports and disposal records will be attached to the
report. Once the Pond closure is accepted by the APS, BCWP's obligation for the waste
treatment Pond is completed
We would appreciate NC DEQ's prompt review and approval of the Decommissioning Plan so
that we can move forward with the project and minimize the amount of precipitation and runoff
that might enter the Pond from future rain events. If you have any questions regarding the Pond ,
Decommissioning Plan, please contact Brian Van Gelder of BCWP at 803-385-4957 or Tim
Berrigan of SVSP at 229-424-0294.
Yours truly,
- {ENV Dept LLC/599/01937275 DOCX:}PPAB 4139348v1

April 24, 2019
Page 4
4kAk--- 4.—
Brian Cullen
Eastern Region Manager
Cc Brian Van Gelder, BCWP
Tim Berrigan, SVSP
Att: Wastewater Pond Closure Checklist
Shamrock Waste Characterization Sampling Plan.
{ENV Dept LLC/599/01937275.DOCX }PPAB 4139348v1

6106 Corporate Park Drive•Browns Summit,NC 27214
336-375-1989. 800-881-1098•Fax [phone]
ENVIRONMENTAL CORPORATION www.shamrockenviro.com
Apri15,2019
Mr.Brian Van Gelder
Boise Cascade
Environmental Manager
Re: Waste Characterization Sampling of the Waste Pond
at the Former Boise Cascade Waste Pond in Moncure,NC
Dear Van Gelder,
The following approach will be used to collect and analyze samples of the sludge in the Waste Pond at the
former Boise Cascade Plant in Moncure,NC. The purpose is to characterize the waste,validate it's non-
hazardous and obtain waste approval at permitted disposal facilities.
Sampling of Sludge for Waste Characterization:
We understand NC DEQ requires one composite sample per acre foot.Based on the size of the pond,2.3
acres, a minimum of 3 composite samples is required.In addition,we have evaluated potential disposal
facilities including Subtitle D Landfills and Composting facilities.The Subtitle D Landfills are requesting
6 composite samples across the pond to confirm the homogenous nature of the sludge. As such,
Shamrock will divide the Pond into 6 grid sections. Within each Section,2 samples will be collected and
composited into one sample for analysis: (See Attached-Figure 1)
Section 1 Samples 1,2, Section#1 Composite of Samples 1-2
Section 2 Samples 3,4 Section#2 Composite of Samples 3-4
Section 3 Samples 5,6 Section#3 Composite of Samples 5-6
Section 4 " -Samples 7 8-- — - Section#4 Composite of Sainydes 7-8 -" -" -
Section 5 Samples 9,10 Section#5 Composite of Samples 9-10
Section 6 Samples 11,12 Section#6 Composite of Samples 11-12
Boise Cascade will send sample jars sent to the Moncure facility for the sampling event. Shamrock will
collect, seal and mark the samples by section and sample number. Boise will arrange for a Courier
service to pick-up the samples at the Moncure plant the day Shamrock performs the sampling event. The
Courier service will be responsible for completing the chain of custody forms and shipping the samples to
a laboratory contracted by Boise Cascade.Based on hold times,its critical that the samples are delivered
to the laboratory and processed within 48 hours.The 6 composite samples are to be analyzed for the
following:
TCLP 8 RCRA Metals
TCLP VOCs
TCLP SVOCs
TCLP Herbicides&Pesticides
PCBs
DRO
GRO •
Oil&Grease

Boise Cascade
Apri15,2019
Page 2 of 2
Total Residuals Analysis
Arsenic Molybdenum
Cadmium Nickel
Copper Selenium
Chromium Zinc
Lead
Mercury
Aluminum pH
Ammonia-Nitrogen Phosphorus
Calcium Plant Available Nitrogen(by calculation)
Magnesium Potassium
Nitrate-Nitrate Nitrogen Sodium
%Solids Total Carbon ,
Volatile solids(VOC)TKN
Corrosivity Ignitability(Flashpoint)
Reactivity(Cyanide and Sulfide)
Sincerely,
•
Bob Graziano
Shamrock Environmental
Cc: Mitch McCalhster,Shamrock
Mark Wise,Shamrock
Henry Havener,Shamrock

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ATTACHMENT A CLOSURE OF PERMITTED WASTEWATER PONDS AND LAGOONS
Checklist and Instruction Items
The purpose of the following checklist and instruction items is to aid in the development of a closure plan for
a permitted Non-Discharge wastewater pond or lagoon to be submitted to the appropriate APS Regional
office for approval.
The following checklist allows the applicant to identify the type of lagoon to be closed, and the preferred closure
and disposal options. The selected options include references to instruction items(e.g. Item A)found on
subsequent pages of this attachment. The instruction items describe what steps are expected to be complete prior to
approval of the closure plan,'including expected sampling and monitoring,and final certifications of complete
closure. Note that the following steps are not all inclusive,as each site is unique and may have varying site
conditions. In addition,flowcharts(Attachment B)have been provided as an alternate to the instructional Items A-
H. These charts contain the same information, but give a visual representation of the closure process. For
questions,contact the approving APS Regional Supervisor. Please check all items below that apply and submit a
completed copy with the lagoon closure plan.
I. Type of Pond or Lagoon System
a.Primary and Secondary Biological Wastewater Lagoon Systems(examples: food processing treatment
lagoons,municipal treatment systems without pretreatment programs,neighborhood treatment systems).
b.Primary and Secondary Industrial Wastewater Lagoon Systems(examples: non-food type industrial
treatment systems,municipal treatment systems with pretreatment program).
c.Tertiary Wastewater Pond Systems(examples: wastewater biological treatment systems with tertiary
treatment to include infiltration disposal pond systems,effluent polishing pond systems).
II. Closure Options—Structure
N/ a. Conversion to Non-Wastewater Pond—Change of Use(Item B)
b.Complete or partial removal of structure(Items G)
c. Site Reclamation(Item F and H)
HI. Final Liquid and Solid Content Disposal Options
a. Wastewater Disposal to Onsite Permitted Field(Item A) ,
b. Wastewater Disposal through Pump and Haul(Item A)
c. Sludge Disposal to Permitted Site(Items C and D)
11
d. Sludge Left in Place(Items C and E)
IV. Sampling and Monitoring Requirements
a.Wastewater Sampling Required (Items A and B)
.1 b. Soil and Sludge Sampling Required(Items C and F)
c.Groundwater Monitoring Required(Item G)
V. Final Certification Required for Closure Activities,as required in Item I.
a. Structural Deconstruction(Professional Engineer or Hydrogeologist)
✓! b. Wastewater Disposal(Facility ORC)
c. Sludge Disposal(ORC I Licensed Sludge Land Application Contractor)
d. Other(Explain: )
A-1
Attachment A June 22,2012