WQ0009477_Staff Report_20200814

State of North Carolina
Department of Environmental Quality
Division of Water Resources
DWR WATER QUALITV REGIONAL OPERATIONS SECTION
Division of Witter Resources NON -DISCHARGE APPLICATION REVIEW REQUEST FORM
June 18, 2020
To: FRO-WQROS: Trent Allen / Mark Brantley
From: Poonam Giri, Water Quality Permitting Section - Non -Discharge Branch
Permit Number: WQ0009477 Permit Type: Distribution of Residual Solids (503 Exempt)
Applicant: Cascades Tissue Group - North Carolina, A Division of Cascades Holding US, Inc. Project Type: Renewal
Owner Type: Organization Owner in BIMS? Yes
Facility Name: Rockingham FiberClay Distribution Program Facility in BIMS? Yes
Signature Authority: John Quick Title: Mill Manager
Address: PO Box 578, Rockingham, NC 28380 County: Richmond
Fee Category: Non -Discharge Major Fee Amount: $0 - Renewal
Comments/Other Information: [e-mail], [e-mail]
Attached, you will find all information submitted in support of the above -referenced application for your review,
comment, and/or action. Within 45 calendar days, please take the following actions:
® Return this form completed. ® Return a completed staff report.
❑ Attach an Attachment B for Certification. ❑ Issue an Attachment B Certification.
When you receive this request form, please write your name and dates in the spaces below, make a copy of this sheet, and
return it to the appropriate Central Office Water Quality Permitting Section contact person listed above.
RO-WQROS Reviewer: 1
Date: /�( 6VC,, Oa Zp _
FORM: WQROSNDARR 09-15 Page 1 of]

�.kt'
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: Poonam Girl
From: Jim Barber
Fayetteville Regional Office
Application No.: W0009477
Facility name: Rockingham FiherC]av Dist. Pro am
Cascades Tissue Group
Note: This form has been adapted from the non -discharge facility staff report to document the review of both non-
dischar a and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 9 July and 15 July 2020
b. Site visit conducted by: Jim Barber and Tony Ho_n_e t
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: NIA and their contact information: (--) - ext.
e. Driving directions: From Rockingham proper, at the intersection of South Hancock SUDS I Bus. & Hwy
74 Business,• take US I Business south and turn ri ht onto Midway Rd. Drive approx. I mile and turn
left into plant entrance.
2. Discharge Point(s): NIA. Wastewater generated at the Cascades production facility is -discharged to the Ci
of Rockingham collections stem for treatment at the City of Rockingham wastewater treatment plant.
Latitude: NIA Longitude: NIA
Latitude: Longitude:
3. Receiving stream or affected surface waters: NIA
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
H. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
Proposed flow:
Current permitted flow:
Are the new treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No
If no, explain:
3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? ❑ Yes ❑ No ❑ N/A
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? ❑ Yes ❑ No ❑ NIA
If no, please explain:
FORM. WQROSSR 04-14 Page l of 6

5. Is the proposed residuals management plan adequate? ❑ Yes ❑ No ❑ NIA
If no, please explain:
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? ❑ Yes ❑ No ❑ NIA
If no, please explain:
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or ❑ No
If yes, attach a map showing conflict areas.
8. Is the proposed or existing groundwater monitoring program adequate? ❑ Yes ❑ No ❑ NIA
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ NIA
If yes, attach list of sites with restrictions (Certification B)
Describe the residuals handling and utilization scheme:
10. Possible toxic impacts to surface waters:
i l . Pretreatment Program (POTWs only):
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ N❑ ❑ NIA
ORC: Karen Bellamy,Certificate #: LA-19I97 Backup ORC: ARM contractor Certificate #:
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
If no, please explain:
Description of existing facilities: Land application Program for Class A non -biological residual.
Proposed flow: 50,000 Dry Tons/year application rate/distribution
Current permitted flow: 50,000 Dry Tons/year application rate/distribution
Explain anything observed during the site visit that needs to be addressed by the pen -nit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.)
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No
If no, please explain: Class A residuals are land a lication in multiple counties in central North Carolina
i.e. Richmond, Union, Scotland, Robeson, etc.]. Application is made to row crop fields.pre-plant, consistine
of small arain production corn soybeans, wheat and oastureerass Bermuda and Fescue). Ha
production fields are also apolied to where hay is cut and bailed to be fed to cattle and in some cases used
for erosion control on construction projects.
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or ® No
If yes, please explain:
5. Is the residuals management plan adequate? ® Yes or ❑ No
If no, please explain:
b. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
If no, please explain: Typical aimfication rates range 1.5 tons/acre to 3 tons/acre.
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® NIA
If no, explain and recommend any changes to the groundwater monitoring program:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
If yes, attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
If no, please explain:
FORM: WQROSSR 04-14 Page 2 of b

10. Were monitoring wells properly constructed and located? ❑ Yes [] No ® NIA
If no, please explain:
FORM: WQROSSR 04-14 Page 3 of

11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® NIA
If no, please complete the following (ex and table if necessary):
Monitoring Well
Latitude
Longitude
❑ ! 11
❑ f l
❑ r !!
❑ 1 77
a f +7
❑ r rr
❑ 1 r!
� � If
❑ 1 r!
a r 11
12. Has a review of all self monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review:
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
If yes, please explain:
14. Check all that apply:
® No compliance issues
❑ Notice(s) of violation
❑ Current enforcement action(s) ❑ Currently under JOC
❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Perrnittee? Is a solution underway or in place?
Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ❑ No ® NIA
If no, please explain:
15. Are there any issues related to comp Iiancelenforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
If yes, please explain:
16. Possible toxic impacts to surface waters: NIA
17. Pretreatment Program (POTWs only): NIA
FORM: WQROSSR 04-14 Page 4 of 6

IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ® Yes or ❑ No
If yes, please explain: See comment below.
2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request:
Item
Reason
The current TCLP data provided with the renewal application dated February
2020 from Summit indicates a 2,4-D result of 0.600 mg/I (600 ug/1) on page 6
of 36. The 2L groundwater standard is 70 ug/l (.070 mg/1). Based on the
Updated TCLP and/or
historical TCLP data
leachable result reported, there appears to be a possible issue with groundwater
impacts if this sample is representative of the Cascades material. There should
be no process within the Cascades production facility to introduce 2,4-D in the
residual waste product. Cascades recycles waste paper (office, newsprint, etc.)
and may purchase pre-processed bulk paper pulp for introduction into their
papermaking process.
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
5. Recommendation: ® Hold, pending receipt and review of additional information by regional office
❑ Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
❑ Issue
❑ Deny (Please state reasons: ____)
6. Signature of report preparer:
Signature of regional supervisor: �1''t iZ
Date: I q e4y6 • Z0 20
FORM: WQROSSR 04-14 Page 5 of 6

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The Cascades program is well maintained and ❑ erated consistent with State and Federal rules/guidelines by a
third party contractor Advanced Residuals Management - ARM and Elwood Black soil scientist). Existing
permit conditions appear to be ade uate to monitor the o eration of this facj!jtyj
In reviewing the last three annual reports 2017 to 2019 the total amount of material land applied for each
year is well below the 50,000 Dry_Tonslyear.
The permittee rea uests that a loner stora a period be allowed to "one cropping cycle" verses the current 60-
day stora a window. The current condition III. 10.b allows for a longer storage window beyond 60 days with
concurrence from the Fayetteville regional office once the permittee submits a written plan. The request for
"one cropping cycle"' is vague, which could lead to material being stored Votentially uy to one year, crossin
over into the next year i.e. stored in 2020but land a lied until 2021). The Fayetteville Regional office feels
that the current condition III-10-b allows for extended periods of storage and provides for the ability to et
firm dates of application and notification that material is to be stored for longer than 60 days. The Fayetteville
Regional office will consider the request as Ion as permit language in condition III.10.b is still maintained that
a notification is made to the re ienal office with a plan and the material is still land applied in the same year as
it is stored.
FORM: WQROSSR 04-14 Page 6 of 6

Client IM Lair JD# Collected Analyt
.Summrr Enrironmemal 14hrrologies, lac.
e
W()p;
20020508
3311) Win A
Cu-whoga Falls, Ohio 44223
Date Repom-d:
2/21/2020
0L: f33o) 253-8211 F.4.V.. r_i301 253-448Y
Company:
Cascades Tissue Group - North Carolina I
web-syle: blip. }V+III..sellek.com
address:
805 Midway Road
Rockingham NC 28379
Received:
21i2020
Project#:
waste Characteri
TCLP Herbicides by EPA 8321E
Rep Lmt Result Units
;Matrix
Method DF RegLvi Run Analyst
Sludge 001 2/712020 2.4-D 0.500 0.600 mWL
Sludge 001 2/7/2020 2,4.5-TP 0.500 ND mglL
Sludge 001 2/7/2020 Surr DGAA 70-130 98.7 %Rec
Sludge EPA 8321B 50 10.0 2/1312020 BJH
Sludge EPA 8321E 50 1.00 2/13/2020 BJH
Sludge EPA 8321B 50 2/13/2020 BJH
Page 6 of 36

Appendix # 2 Summary Table of Groundwater Standards
Disclaimer: This table is intended to provide summary information only. It does not substitute for any written regulation, nor
is it a regulation itself.
Substance
15A NCAC 02L .0202
Groundwater Standards
(Effective April 1, 2013)
Caprolactam
4 mg/L
ug/L (unless otherwise indicated)
Carbofuran
40
Carbon disulfide
700
Carbon tetrachloride
0.3
Chlordane
0.1
Chloride
250 mg/L
Chiorobenzene
50
Chioroethane
3 mg/L
Chloroform (trichloromethane)
70
Chloromethane (methyl chloride)
3
2-Chlorophenol
0A
2-Chlorotoluene (o-chlorotoluene)
100
Chromium
10
Chrysene
5
Coliform organisms, Total
1 per 100 mL
Color
15 color units
Copper
1 mg/L
Cyanide, free
70
2,4-D
70
DDD
0.1
DDT
0.1
❑ibenzo(a,h)anthracene
0.005
Dibromochloromethane
0.4
1,2-Dibromo-3-chloropropane
0.04
Dibutyl phthalate (di-n-butyl phthalate)
700
1,2-Dichlorobenzene (orthodichlorobenzene)
20
1,3-Dichiorobenzene (metadichlorohenzene)
200
NORTH CAROLINA ADMINISTRATIVE CODE Amended April 1, 2013 26