HomeMy WebLinkAboutNC0000272_LV20160252_20161213 (2) l l PAT MCCRORY
Gmarnar
DONALD R..V,AN DER VAART
waaary
WaterResources
ENVIRONMENTAL OVaur+ S. JAY ZIMMERMAN
Dsarm
Certified Mail#7014 0510 0000 4466 4019
Return Receipt Requested
December 13,2016
Stephen J Hutchins, General Manager
Blue Ridge Paper Products Inc
175 Main St
Canton,NC 28716
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute(G.S.) 143-215.1(ax6)
and NPDES W W Permit No.NC0000272
Blue Ridge Paper Products Inc
Canton Mill
Case No. LV-2016-0252
Haywood County
Dear Permittee:
This letter transmits a Notice of Violation and assessment of civil penalty in the amount of$616.62($500.00 civil penalty+
$116.62 enforcement costs)against Blue Ridge Paper Products Inc.
This assessment is based upon the following facts: a review has been conducted of the discharge monitoring report(DMR)
submitted by Blue Ridge Paper Products Inc for the month of June 2016. This review has shown the subject facility to be
in violation of the discharge limitations and/or monitoring requirements found in NPDES W W Permit No.NC0000272. The
violations,which occurred in June 2016,are summarized in Attachment A to this letter.
Based upon the above facts,I conclude as a matter of law that Blue Ridge Paper Products Inc violated the terms,
conditions or requirements of NPDES W W Permit No.NC0000272 and G.S. 143-215.1(ax6)in the manner and extent
shown in Attachment A. In accordance with the maximums established by G.S. 143-215.6A(a)(2),a civil penalty may be
assessed against any person who violates the terms, conditions or requirements of a permit required by G.S. 143-215.1(a).
Based upon the above findings of fact and conclusions of law,and in accordance with authority provided by the Secretary
of the Department of Environmental Quality and the Director of the Division of Water Resources,I, G.Landon Davidson,
P.G.,Regional Supervisor,Asheville Regional Office hereby make the following civil penalty assessment against Blue Ridge
Paper Products Inc:
State of North Carolina I Environmental Quality I Water Resources
2090 U.S.70 Highway,Swannanoa,NC 28778
Q� 828-296A500
$500.00 2 of the 3 violations of 143-215.1(a)(6) and Permit NO.NC0000272,by discharging waste water into ,
the waters of the State in violation of the Permit Daily Maximum for FCOLI BR.
500.00 TOTAL CIVIL PENALTY
$116.62 Enforcement Costs
616.62 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-282.I(b),which are:
(1) The degree and extent of harm to the natural resources of the State,to the public health, or to private property
resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty(30) days of receipt of this notice,you must do one of the following:
(1) Submit payment of the penalty, OR
(2) Submit a written request for remission, OR
(3) Submit a written request for an administrative hearing
Option 1: Submit payment of the penalty:
Payment should be7 made directly to the order of the Department of Environmental Quality(do not include waiver
form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
Option 2: Submit a written request for remission or mitigation including a detailed justification for such
request:
Please be aware that a request for remission is limited to consideration of the five factors listed below as they may
relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper
procedure for contesting whether the violation(s)occurred or the accuracy of any of the factual statements contained in
the civil penalty assessment document. Because a remission request forecloses the option of an administrative hearing,
such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and
agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you
believe the civil penalty should be remitted,and submit it to the Division of Water Resources at the address listed below.
In determining whether a remission request will be approved,the following factors shall be considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282.1(b)was wrongfully
applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
Please note that all evidence presented in support of your request for remission must be submitted in writing. The
Director of the Division of Water Resources will review your evidence and inform you of his decision in the matter of
your remission request. The response will provide details regarding the case status,directions for payment,and
provision for further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty
Remissions(Committee). Please be advised that the Committee cannot consider information that was not part of the
original remission request considered by the Director. Therefore,it is very important that you prepare a complete and
thorough statement in support of your request for remission.
In order to request remission,you must complete and submit the enclosed"Request for Remission of Civil Penalties,
Waiver of Right to an Administrative Hearing and Stipulation of Facts"form within thirty(30)days of receipt of this
notice. The Division of Water Resources also requests that you complete and submit the enclosed"Justification for
Remission Request."
Both forms should be submitted to the following address:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
Option 3: File a petition for an administrative hearine with the Office of Administrative Hearines:
If you wish to contest any statement in the attached assessment document you must file a petition for an administrative
hearing. You may obtain the petition form from the Office of Administrative Hearings. You must file the petition with
the Office of Administrative Hearings within thirty(30)days of receipt of this notice. A petition is considered filed
when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m.,except for official state
holidays. The petition may be filed by facsimile(fax)or electronic mail by an attached file(with restrictions)-provided
the signed original,one(1)copy and a filing fee(if a filing fee is required by NCGS §15013-23.2)is received in the
Office of Administrative Hearings within seven(7)business days following the faxed or electronic transmission. You
should contact the Office of Administrative Hearings with all questions regarding the filing fee and/or the details of the
filing process.
The mailing address and telephone and fax numbers for the Office of Administrative Hearings are as follows:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh,NC 27699-6714
Tel: (919)733-2698
Fax: (919)733-3478
One(1)copy of the petition must also be served on DEQ as follows:
Mr. Sam M.Hayes,General Counsel
Department of Environmental Quality
1601 Mail Service Center
Raleigh,North Carolina 27699-1601
Please indicate the case number(as found on page one of this letter)on the petition.
Failure to exercise one of the options above within thirty(30)days of receipt of this letter, as evidenced by an internal
date/time received stamp(not a postmark),will result in this matter being referred to the Attorney General's Office for
collection of the penalty through a civil action. Please be advised that additional penalties may be assessed for violations
that occur after the review period of this assessment.
If you have any questions,please contact Janet Cantwell with the Division of Water Resources staff of the Asheville
Regional Office at(828)2964667 or via email atjanet.cantwell@ncdenr.gov.
Sincerely,
G. Landon Davidson,P.G.,Regional Supe ' or
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources,NCDEQ
ATTACHMENTS
Cc: WQS Asheville Regional Office-Enforcement File
NPDES Compliance/Enforcement Unit-Enforcement File
(i R dV Pape IX)72,�LV.201"2 2 N'
JUSTIFICATION FOR RENIISSION REQUEST
Case Number: LV-2016-0252 County: Haywood
Assessed Party: Blue Ridge Paper Products Inc
Permit No.: NC0000272 Amount Assessed: $616.62
y
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts"form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s)occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c),remission of a civil
penalty may be granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation,including copies of supporting documents,as to why the
factor applies(attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 143B-282.1(b)were wrongfully applied to the
detriment of the petitioner(the assessment factors are listed in the ctvil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation(i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident(i.e., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(c) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION:
4
STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF HAYWOOD
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
Blue Ridge Paper Products Inc )
Canton Mill )
PERMIT NO.NC0000272 ) CASE NO. LV-2016-0252
Having been assessed civil penalties totaling$616.62 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated December 13,2016,the undersigned, desiring to seek remission of the civil penalty, does hereby
waive the right to an administrative hearing in the above-stated matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned further understands that all evidence presented in support of remission of this civil
penalty must be submitted to the Director of the Division of Water Resources within thirty(30)days of receipt of the notice
of assessment. No new evidence in'support of a remission request will be allowed after(30)days from the receipt of the
notice of assessment.
This the day of 20
SIGNATURE
ADDRESS
TELEPHONE
ATTACHMENT A
Blue Ridge Paper Products Inc
CASE NUMBER: LV-2016-0252
PERMIT: NC0000272 REGION: Asheville
FACILITY: Canton Mill COUNTY: Haywood
LIMIT VIOLATION(S)
SAMPLE LOCATION: Outfall 001 -Effluent
Violation Report Unit of Limit Calculated %Over Violation Penalty
Date MohthfYr Parameter Frequency Measure Value Value Limit Type Amount
6/2/2016 6-2016 Coliform, Fecal MF, Weekly #/100ml 400 600 50.0 Daily Maximum $250.00
MFC Broth,44.5 C Exceeded
6/9/2016 6-2016 Coliform, Fecal MF, Weekly #/100ml 400 1410 252.5 Daily Maximum $250.00
MFC Broth,44.5 C Exceeded
-6/16/2016 6-2016 Coliform, Fecal MF, Weekly #/100ml 400 435 8.7 Daily Maximum $0.00
MFC Broth,44.5 C Exceeded
DIVISION OF WATER RESOURCES-CIVIL PENALTY ASSESSMENT(File)
Violator: Blue Ridee Paper Products Inc
Facility Name: Canton Mill
Permit Number: NC0000272
County: Haywood
Case Number: LV-2016-0252
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State,to the public health,or to private property
resulting from the violation;
All effluent violations may be detrimental to the receiving stream but may not be immediately quantified.
2) The duration and gravity of the violation;
Three Daily Max Fecal Coliforms exceeded the permit limit by 50%,252%& 8.7%.
3) The effect on ground or surface water quantity or quality or on air quality;
All effluent violations may be detrimental to the receiving stream but may not be immediately quantified.
4) The cost of rectifying the damage;
The cost is unknown.
5) The amount of money saved by noncompliance;
The amount of money saved is unknown.
6) Whether the violation was committed willfully or intentionally;
It does not appear to be either.
7) The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority; and
There has been one civil penalty enforcement in the twelve months prior to this violation.
8) The cost to the State of the enforcement procedures.
$116.62
Date G.Landon Davidson,P.G.,Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources,NCDEQ
evergreen Canton Office
.packaging I 175 Main Street• Conlon, NC 28716
June 16, 2016 NMM#29-16
CERTIFIED MAIL
Return Receipt Regnested __,..
7006 0100 0003 6622 5613 ! RECEIVED
Division of Wader Fiesources i
Landon Davidson
Asheville Regional Supervisor AN 10 2016
Division of Water Resources 1 i
North Carolina Department of Environment Water Quality Regional Operations
and Natural Resources Asheville Ragional Otfr_•_e
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
f�
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging
Canton Mill, Canton,Haywood County,North Carolina
Daily Maximum Fecal Coliform 6/9/2016
NPDES Permit: NC0000272
- i
Dear Mr.Davidson:
This is the 5-day written submission for'the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
6/9 at approximately 11:35 am and picked up by the laboratory for analysis. Proper sampling
procedures were followed by plant personnel. We received the laboratory report via email the
afternoon of 6/10. The result of the analysis showed a value of 1410 MPN per 100 ml. The fecal
coliform excursion on 6/9 was limited to that sample parameter and day. A phone call was
placed to the NCDEQ regional office on 6/10.
Once we received the value from the laboratory all systems in the treatment facility were
inspected. They were found to be operating correctly leading up to and during the time of
sample. The Town of Canton's chlorine injection system was also inspected.
We are continuing our in depth investigation into the cause of these recent results. If an
identified source or cause is determined, a follow up notice to your office will occur describing
the results of our findings.
If you have any questions or comments,please feel free to contact us at your earliest
convenience.
fresh by design..
Doing Business in CoGfo No os Evergreen Bevercga Packaging
Ileverpackl6alE0HSISHARE1Water RlesWxWs Water ReslD WR
NCDWR Page 2
Sincerely,
Nick McCracken
Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
Nick.McCrackengevemack.com
cc:
Mr. Tim Heim
Environmental Specialist, Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778
C. File—Water Notebook
Q�:I�i�n O(yValer Reslu
AUG 0 0-2016 AUG 11
2016 AUG 15020%
Effluent I
NPDES No.: NC 0000272 a No.: 001 Month: June 1' ar:"�•;` 2016:';';"Discharg '*°=>}"v -
Ye "
Facility Name: Blue Ridge Paper Products Inc. Class:IV Coun :_Na 'ood
Operator in Responsible Charge(ORC): Nick McCracken Grade: IV jPhone 828-646-6720
Certified Laboratories: (1)Blue Rid epaper,ProQ.,#198; 2 Pace #40,#12, 3 Environmental Testing Solutions#037
Check Box it ORC Has Changed I-N'r�U r-3 Vt::ZPerson(s)Collecting Samples: Operators on Duty
Mail ORIG'L-1 COPY to:
Attn:Central Files AUG 0I, 2(?i6
Div.of Environmental Mgt. -2-7- (o
DEHNR CENTRL L FI E� (Signature of Operator In Responsible Charge) Date
P.O.Box 29535 DWRS CTIO YTHIS SIGNATURE,I CERTIFY THAT THIS REPORT IS ACCURATE AND COMPLETE
Raleigh,NC 27626405M '"TO THE BEST OF MY KNOWLEDGE.
50050 00010 1 00400 00310 1 00610 G0530 31111 00111 I10600
E LL
_ y w y
F w a'_
m 0o m Z
U o
� ti
U E' 8 a o
0r-
0 0 LL
HRS Y/N MGD °C I Bid Units lb./day mg/L ItaJday ml mg/L mg/L
,I, , 07M 24 , Y',� '25:340:: 335 120q
2. 0700 24 Y 27.360 35.0 7.0 1321 0.1 2282 600 8.3
3; .0700, 24 'Y'-., MOM.` 331 ,,`;.:7 1 = .i 826 0.1 _'1739 . _9'T
4 0700 24 N 26.770 33.7 7.1 1163 0.58 3572 9.0
5:>':0700 24 :':N_ '2Z:320 _34. „7 3„. . -- '. '1458:.: . '0.89 _4.0 _
6 0700 24 Y 27.540 33.6 7.2 1481 0.56 3905 8.5
7t;;0700 .. 24 ;<< Y' a =26.800 32.9 - ,`'71..: _ 1560;" ', 0.42 2682_. ._._ 84 ',,.._7
8 0700 24 Y 25.170 32.0 7.3 1658 0.16 2939 8.9
9- 0700' 24 r Y 26.650 31.2, %-T.22 , `_'_ . _ :1636;_ :`.'Oit 4223 1-'1410 .7.2 ,'..
10 0700 24 Y 27.820 32.6 7.1 1712 0.15 3712 9.1
11 :0700 24 - - N?? ;27.540 34 0 ',,7.4 . : . _,' 1787, �_ 1.45 3905 , _ 8 8 . _.
12 7 0 7.510 7.1 1225 1.6 3212 8.
J3.107-00 _:24_.-_'X-.,2MD_--34.91 `_'6.8, .___2036w:c- _';1.3_ ,_2334„,.t
14 0700 24 Y 26.240 34.5 7.1 1972 1.5 2188 8.7
15 WOO- -:24 - s• Y.. -291704 34 3• =6.9_ _. -� 9679_-• 0:44: -:2919 "'�8 5
16 0700 24 Y 28.820 35.5 7.2 1771 0.27 2884 435 9.3
47t a0700: ::24, Yi ., ,28.040�' 330;_ ;�7.2,` _ „1,812 +;" -01� 1,2572 84
18 0700 24 N 26.550 30.6 7.1 1592 0.1 2657 19.4
5 3 2166 -, .0:1 .- 2596 16 4:A
20 0700 24 Y 26.380 32.8 7.1 1740 0.16 2860 15.7
.21 `0700: 24__ .. ,:Y 27:160_ ..-, 32.5 7 0_ 1187_..i._ _0.12. ,_N92 ;; U15 9
22 0700 24 Y 26.830 32.2 6.9 1251 0.1 2461 16.7
23 :0700 24_ ,Y;,t '26.880 - 33 2 ' `;'6 9,1, = _2392ak 0'.1 2018 161
24 0700 24 Y 25.960 34.3 6.9 894 0.1 1732 7 14.3
25. "0700• _, 24 ,N'`; _27,270 33.6, ;_71 , 1060 ,'- '0:1 : "'2274 _ _ 113-
26
700 2 28.0m 34.2 6.9 1376 0.1 3275 14.0
;:27 `0700 24 Y' Fr.27.:250_,_30 3.,. `6.9 _' 1059 ;:_„0:1., _r2954., ,- _I ,' 16 8- r -
28 0700 24 Y 26.180 31.0 7.1 1131 0.1 2620 17.7
29 :0700, :-24, . Y="_26.810'" 307,. _`�7.1 1313;. ' � 01'.; 1789
30 0700 24 Y 24.980 29.7 7.2 1458 0.1 3125 16.6
2
Average 26.946 32.9 1492 0.3733 2776 76 11.9 1.20
Maxlmurn:- =.: - 29r170 < 355 74 , ',.2392i. w 16 F4223 1410. ,.194 - 1:20+
Minimum 24.980 29A 6.8 826 < 0.1 1268 1 7.2 1.20
Com _C/Gra6 G G G. G'-< C .; G .. G'; C
Monthly Limit 29.9 9.0 6.0 3205.0 12549.0 200.0 6.0
,Nos
g/�/r� Nbv- zo/6 -/,v,o6-z6 1 LV-zol�-a�-72 6'�U
Facility Status:(Please check one of the following)
All monitoring data and sampling frequencies meet permit monitoring requirements.
Compliant
All monitoring data and sampling frequencies do NOT meet permit monitoring requirements. FT I
Noncompliant
If the facility is noncompliant,please comment on corrective actions being taken in respect to equipment,
operation,maintenance,etc.and a time table for improvements to be made.
Three weekly fecal coliform tests were noncompliant for the month of June.The monthly geometric mean however was within compliance.
All systems were checked and appeared to be functioning as designed.No disruption in treatment was observed.The National Council
for Air and Stream Improvement(NCASI)was contacted to help assist with determining the cause for the test values. Bacterial speciation
'testing was performed along with duplicate samples for total coliform and E.coli..NCDEQ's regional office staff were contacted after each
test and kept informed of the ongoing study.This study is still currently being run with the results going to the regional office for review.
'I certify,under penalty of law,that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted.
Based on my inquiry of the person or persons who manage the system,or those persons directly responsible forgathering the
Information,the information submitted is,to the best of my knowledge and belief,true,accurate,and complete.I am aware that there are
significant penalties for submitting false information,including the possibility of fines and imprisonment for knowing violations.'
Michael Ferguson
Permittee(Please print or type)
f\..-.Q. Q P-��
Signature of PermiHee" Date
P.O.Box C-10 Canton,NC 28716 828-646-2840
Parameter Codes
00010 Temperature 00556 Oil 8 Grease 00951 Total Fluoride 01067 Nickel 50060 Total
00676 Turbidity 00600 Total Nitrogen 01002 Total Arsenic 01077 Silver Residual
00080 Color(Pt-Co) 00610 Ammonia Nitrogen 01092 Zinc Chlorine
00082 Color(ADMI) 00625 Total Kjeldahl 01027 Cadmium 01105 Aluminum
00095 Conductivity Nitrogen 01147 Total Selenium 71880 Formaldehyde
00300 Dissolved Oxygen 00630 NirateslNitrites 01032 Hexavalent Chromium 31614 Fecal Coliform 71900 Mercury
00310 BOD5 01034 Chromium 32730 Total Phenolics 81551 Xylene
00340 COD 00665 Total Phosphorus 34235 Benzene
00400 pH 00720 Cyanide 01037 Total Cobalt 34481 Toluene
00500 Total Solids 00745 Total Sulfide 01042 Copper 38260 MBAs
00530 Tot Suspended 00927 Total Magnesium 39516 PCBs
Residue 00929 Total Sodium 01045 Total Iron 50050 Flow
00545 Settleable Matter 00940 Total Chloride 01051 Lead
Parameter Code assistance may obtained by calling the Water Quality Compliance Group at(919)733-5083,extension 581 or 534.
The monthly average for feral coliform is to be reported as a GEOMETRIC mean. Use only units designated in the reporting
facilitys permit for reporting data.
ORC must visit facility and document visitation of facility as required per 15A NCAC 8A.0202(b)(5)(B).
-if signed by other than the permittee,delegation of signatory authority must be on file with the Stale per 15A NCAC 2B.0506(b).
Ammar
DONA}LDIr IVAN I}ER, AAT
;r�HvtaoNr�gt#YSt_Wgf;iTN�, p5� 7-Al'*�ZI�vIIvTEIt�Lfr''L"N:.
Certified Mail#7014 0510 0000 4466 4019
Return Receipt Requested
December 13,2016
Stephen J Hutchins, General Manager
Blue Ridge Paper Products Inc
175 Main St
Canton,NC 28716
SUBJECT: Notice of Violation and Assessment of Civil Penalty
for Violations of North Carolina General Statute(G.S.) 143-215.1(a)(6)
and NPDES W W Permit No.NC0000272
Blue Ridge Paper Products Inc
Canton Mill
Case No. LV-2016-0252
Haywood County
Dear Permittee:
_This letter transmits a Notice of Violation and assessment of civil penalty in the amount of$616.62($500.00 civil penalty+
$116.62 enforcement costs)against Blue Ridge Paper Products Inc.
This assessment is based upon the'following facts: a review has been conducted of the discharge monitoring report(DMR)
submitted by Blue Ridge Paper Products Inc for the month of June 2016. This review has shown the subject facility to be
in violation of the discharge limitations and/or monitoring requirements found in NPDES W W Permit No.NC0000272. The
violations,which occurred in June 2016, are summarized in Attachment A to this letter.
Based upon the above facts,I conclude as a matter of law that Blue Ridge Paper Products Inc violated the terms,
conditions or requirements of NPDES WW Permit No.NC0000272 and G.S. 143-215.1(a)(6) in the manner and extent
shown in Attachment A. In accordance with the maximums established by G.S. 143-215.6A(a)(2), a civil penalty may be
assessed against any person who violates the terms, conditions or requirements of a permit required by G.S. 143-215.1(a).
Based upon the above findings of fact and conclusions of law, and in accordance with authority provided by the Secretary
of the Department of Environmental Quality and the Director of the Division of Water Resources,I, G.Landon Davidson,
P.G.,Regional Supervisor,Asheville Regional Office hereby make the following civil penalty assessment against Blue Ridge
Paper Products Inc:
State of North Carolina I Environmental Quality I Water Resources
2090 AS'.70 Highway,Swannanoa,NC 28778
828-296-4500
$500.00 2 of the 3 violations of 143-215.1(a)(6)and Permit No.NC0000272, by discharging wastewater into
the waters of the State in violation of the Permit Daily Maximum for FCOLI BR.
$500.00 TOTAL CIVIL PENALTY
$116.62 Enforcement Costs
$616.62 TOTAL AMOUNT DUE
Pursuant to G.S. 143-215.6A(c), in determining the amount of the penalty I have taken into account the Findings of Fact and
Conclusions of Law and the factors set forth at G.S. 143B-282.1(b),which are:
(1) The degree and extent of harm to the natural resources of the State, to the public health, or to private property
resulting from the violation;
(2) The duration and gravity of the violation;
(3) The effect on ground or surface water quantity or quality or on air quality;
(4) The cost of rectifying the damage;
(5) The amount of money saved by noncompliance;
(6) Whether the violation was committed willfully or intentionally;
(7) The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority; and
(8) The cost to the State of the enforcement procedures.
Within thirty(30) days of receipt of this notice,you must do one of the following:
(1) Submit payment of the penalty, OR
(2) Submit a written request for remission, OR
(3) Submit a written request for an administrative hearing
Option 1: Submit payment of the penalty:
Payment should be made directly to the order of the Department of Environmental Quality(do not include waiver
form). Payment of the penalty will not foreclose further enforcement action for any continuing or new violation(s).
Please submit payment to the attention of:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
Voption2: Submit a written request for remission or mitigation including a detailed justification for such
request:
Please be aware that a request for remission is limited to consideration of the five factors listed below as they may
relate to the reasonableness of the amount of the civil penalty assessed. Requesting remission is not the proper
procedure for contesting whether the violation(s)occurred or the accuracy of any of the factual statements contained in
the civil penalty assessment document. Because a remission request forecloses the option of an administrative hearing,
such a request must be accompanied by a waiver of your right to an administrative hearing and a stipulation and
agreement that no factual or legal issues are in dispute. Please prepare a detailed statement that establishes why you
believe the civil penalty should be remitted,and submit it to the Division of Water Resources at the address listed below.
In determining whether a remission request will be approved,the following factors shall be considered:
(1) whether one or more of the civil penalty assessment factors in NCGS 143B-282.I(b)was wrongfully
applied to the detriment of the petitioner;
(2) whether the violator promptly abated continuing environmental damage resulting from the violation;
(3) whether the violation was inadvertent or a result of an accident;
(4) whether the violator had been assessed civil penalties for any previous violations; or
(5) whether payment of the civil penalty will prevent payment for the remaining necessary remedial actions.
Please note that all evidence presented in support of your request for remission must be submitted in writing. The
Director of the Division of Water Resources will review your evidence and inform you of his decision in the matter of
your remission request. The response will provide details regarding the case status, directions for payment, and
provision for further appeal of the penalty to the Environmental Management Commission's Committee on Civil Penalty
Remissions(Committee). Please be advised that the Committee cannot consider information that was not part of the
original'remission request considered by the Director. Therefore, it is very important that you prepare a complete and
thorough statement in support of your request for remission.
In order to request remission,you must complete and submit the enclosed"Request for Remission of Civil Penalties,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts"form within thirty(30) days of receipt of this
notice. The Division of Water Resources also requests that you complete and submit the enclosed"Justification for
Remission Request."
Both forms should be submitted to the following address:
Wastewater Branch
Division of Water Resources
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
Option 3: File a petition for an administrative hearing with the Office of Administrative Hearings:
If you wish to contest any statement in the attached assessment document you must file a petition for an administrative
hearing. You may obtain the petition form from the Office of Administrative Hearings. You must file the petition with
the Office of Administrative Hearings within thirty(30) days of receipt of this notice. A petition is considered filed
when it is received in the Office of Administrative Hearings during normal office hours. The Office of Administrative
Hearings accepts filings Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m., except for official state
holidays. The petition may be filed by facsimile(fax) or electronic mail by an attached file(with restrictions) -provided
the signed original, one(1)copy and a filing fee(if a filing fee is required by NCGS §150B-23.2) is received in the
Office of Administrative Hearings within seven(7)business days following the faxed or electronic transmission. You
should contact the Office of Administrative Hearings with all questions regarding the filing fee and/or the details of the
filing process.
The mailing address and telephone and fax numbers for the Office of Administrative Hearings are as follows:
Office of Administrative Hearings
6714 Mail Service Center
Raleigh,NC 27699-6714
Tel: (919)733-2698
Fax: (919) 733-3478
One (1)copy of the petition must also be served on DEQ as follows:
Mr. Sam M.Hayes, General Counsel
Department of Environmental Quality
1601 Mail Service Center
Raleigh,North Carolina 27699-1601
Please indicate the case number(as found on page one of this letter)on the petition.
Failure to exercise one of the options above within thirty(30) days of receipt of this letter, as evidenced by an internal
date/time received stamp (not a postmark),will result in this matter being referred to the Attorney General's Office for
collection of the penalty through a civil action. Please be advised that additional penalties may be assessed for violations
that occur after the review period of this assessment.
If you have any questions, please contact Janet Cantwell with the Division of Water Resources staff of the Asheville
Regional Office at(828)296-4667 or via email atjanet.cantwell@ncdenr.gov.
Sincerely,
G. Landon Davidson,P.G.,Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources,NCDEQ
ATTACHMENTS
Cc: WQS Asheville Regional Office-Enforcement File
NPDES Compliance/Enforcement Unit-Enforcement File
G'iICRlW2''NawooR.\5'enncmer\Indnemnl`.Rluc Ridee PVer 00272W V-2010.0252 N'
JUSTIFICATION FOR RENHSSION REQUEST
Case Number: LV-2016-0252 County: Haywood
Assessed Party: Blue Ridge Paper Products Inc
Permit No.: NC0000272 Amount Assessed: $616.62
Please use this form when requesting remission of this civil penalty. You must also complete the "Request For Remission,
Waiver of Right to an Administrative Hearing, and Stipulation of Facts"form to request remission of this civil penalty.
You should attach any documents that you believe support your request and are necessary for the Director to consider in
evaluating your request for remission. Please be aware that a request for remission is limited to consideration of the five
factors listed below as they may relate to the reasonableness of the amount of the civil penalty assessed. Requesting
remission is not the proper procedure for contesting whether the violation(s)occurred or the accuracy of any of the factual
statements contained in the civil penalty assessment document. Pursuant to N.C.G.S. § 143B-282.1(c),remission of a civil
penalty maybe granted only when one or more of the following five factors apply. Please check each factor that you
believe applies to your case and provide a detailed explanation, including copies of supporting documents,as to why the
factor applies(attach additional pages as needed).
(a) one or more of the civil penalty assessment factors in N.C.G.S. 14313-282.1(b)were wrongfully applied to the
detriment of the petitioner(the assessment factors are listed in the civil penalty assessment document);
(b) the violator promptly abated continuing environmental damage resulting from the violation(i.e., explain the
steps that you took to correct the violation and prevent future occurrences);
(c) the violation was inadvertent or a result of an accident(i.e., explain why the violation was unavoidable or
something you could not prevent or prepare for);
(d) the violator had not been assessed civil penalties for any previous violations;
(e) payment of the civil penalty will prevent payment for the remaining necessary remedial actions (i.e., explain
how payment of the civil penalty will prevent you from performing the activities necessary to achieve
compliance).
EXPLANATION:
STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY
COUNTY OF HAYWOOD
IN THE MATTER OF ASSESSMENT ) WAIVER OF RIGHT TO AN
OF CIVIL PENALTIES AGAINST ) ADMINISTRATIVE HEARING AND
STIPULATION OF FACTS
Blue Ridge Paper Products Inc )
Canton Mill )
PERMIT NO.NC0000272 ) CASE NO. LV-2016-0252
Having been assessed civil penalties totaling$616.62 for violation(s) as set forth in the assessment document of the Division
of Water Resources dated December 13, 2016,the undersigned, desiring to seek remission of the civil penalty, does hereby
waive the right to an administrative hearing in the above-stated matter and does stipulate that the facts are as alleged in the
assessment document. The undersigned further understands that all evidence presented in support of remission of this civil
penalty must be submitted to the Director of the Division of Water Resources within thirty(30) days of receipt of the notice
of assessment. No new evidence in support of a remission request will be allowed after(30) days from the receipt of the
notice of assessment.
This the day of .20
SIGNATURE
ADDRESS
TELEPHONE
. ATTACHMENT A
Blue Ridge Paper Products Inc
CASE NUMBER: LV-2016-0252
PERMIT: NC0000272 REGION: Asheville
FACILITY: Canton Mill COUNTY: Haywood
LIMIT VIOLATION(S)
SAMPLE LOCATION: Outfall 001 -Effluent
Violation Report Unit of Limit Calculated %Over Violation Penalty
Date Month[Yr Parameter Frequency Measure Value Value Limit Type Amount
6/2/2016 6-2016 Coliform, Fecal MF, Weekly #/loom] 40D 600 50.0 Daily Maximum $250.00
MFC Broth,44.5 C Exceeded
6/9/2016 6-2016 Colifonn, Fecal MF, Weekly #/loom] 400 1410 252.5 Daily Maximum $250.00
MFC Broth,44.5 C Exceeded
6/16/2016 6-2016 Colifonn, Fecal MF, Weekly #/looml 400 435 8.7 Daily Maximum $0.00
MFC Broth,44.5 C Exceeded
,q �1NL'gn of Water Rascurces
AUG 0 9 2016 DJ
AUG 1 2016 AUG 1512016 I
Effluent t
NPDES No.: NC 0000272 Dischage No.: 001 Month: June /vj b� e
6Y
Facility Name: Blue Ridge Paper Products Inc. Class:IVI 1C :_N
Operator in Responsible Charge(ORC): Nick McCracken I Phone 828.646-6720
Certified Laboratories:(I)Blue Rime PaRer,prod #1.$8; 2 Pace #40,#12, 3 Environmental Testing Solutions#037
Check Box if ORC Has Changed NM1ate In I zF I-. 2erson(s)Collecting Samples: Operators on Duty
Mail ORIG'L+1 COPY to:
Attn:Central Files AUG (� � 2Qi6
Div.of Environmental Mgt.
DEHNR CNT L FILE (Signature of Operator in Responsible Charge) Date
C
P.O.Box 29535 ENTR �TI YTHIS SIGNATURE,I CERTIFY THAT THIS REPORT IS ACCURATE AND COMPLETE
Raleigh,NC 27626-0535 DWR N0 THE BEST OF MY KNOWLEDGE:
5D050 00010 00400 00310 1 00610 00530 31616 00300 00600
N LL
E ui W m c c
m E m' ,° ? U Z a�+�' € Off• a
Qt F o o w
N n n •Q Z
o
E E r'n Cg w o
O O O O LL F- W m !4 x F
O
HRS Y/N MGD °C Sid Units Ib./day mg/L lb./day mI mg/L mg/L
1• ;0700 i;24 = Y'_ ... '35340_ 335'i >71 , '1029- '0.9._ 1268
2. 0700 24 Y 27.360 1 35.0 7.0 1321 0.1 2212 600 8.3
'`,3 ;0700- -- 24' Y- _:`26i070'' 331 1- __ ,_ -_826 ,' ,01.:' '1739 91'
4 0700 24 1 N 26.770 1 33.7 1 7.1 1163 0.58 3572 9.0
5-. ':0700. 24 :_ N: , -27<320." _34:4 . z`_,7 3. a 19587;a," 0.89, _-7101 T9 5 e
6 0700 24 1 Y 27.540 33.6 1 7.2 1481 0.56 3905 8.5
a;7' 4700; 24, -Y .` .'X800, 32 9-. i71 1560;; "0.42 3682 _ 8 4 ;
8 0700 24 1 Y 25.170 32.0 7.3 1658 0.16 2939 8.9
9' _.0700` " 24 X,�,,-, 26.650 312 _r7 2 1636; -_c,0:1._. 4223 1 t 1410t 3,2
10 0700 24 1 Y 27.820 32.6 7.1 1712 0.15 3712 9.1
11 07001, .24 '. : N:', 27:540 34.0., ,:7 4 1787; 1.45_ 3905 =T 8.8
12 0700 24 N2 .5 .9 7.1 5 1.6 3212 8.4
.13. _07.00, 24_. . Y;_.:�27;990_ ._ X9,� .� 6.8.- -2036.-., v1.3 c--2334 . � -. 8.9
14 0700 24 Y -26.240 '34.5 7.1 1972 1.5 2188 8.7
15 0700 -,24--- r;Y= 29.170, 44.3 6 9. x 1679 s,r 0:44 :2919
16 0700 24 Y 28.820 35.5 7.2 1771 0.27 2884 435 9.3
17 0700;:t-24� --
,;28.040;' 33 0 < ' T.2 , _ 1812 i ,0 1 '257218 070026.550 30.6 7.1 1592 0.1 2657N5! . 7 3_ 2166 .0.1; -2596 ;r1 16.420 070026.380 32.8 7.1 1740 0.16 2860 15.7
21 0700: =27:160. 32'S=" 7 0 , _._ F_ 1187, ,0.12: ; 2492 15.9 22 070026.830 32.2 6.9 1251 0.1 2461 16.7
23 0700` 26l880: 33 2 . ;'6 9 2392 0:1 _2018 161 24 070025.960 34.3 6.9 894 0.1 1732 7 14.3
25 0700 :'__24 =.N=i' .27270 336 ' 60_; . '0:1 '2274 _ r.;., 133
26 700 2 .05 .2 6.9 76 0.1 3275 14.0
27 ,0700s> 24 Y';'r;"27250. .30.3 ,; 6't9 1059 ' rn;0.1 2954_ ._.. �116 6 b s
28 0700 24 Y 26.180 31.0 7.1 1131 0.1 2620 17.7
29 07_00- =24 Y; '_26.810_"_ 307 j!1 J313 - , 01'^,"'2789 s 1'.,u 163,
30 0700 24 Y 24.980 29.7 7.2 1458 0.1 3125 16.6
Average 26.946 32.1 1492 0.3733 2776 76 11.9 1.20
Maximum 29:170• --355� a:7:4 . ---_� ".2392< -r" .16 ,4223�;=9410<, 194:;_.-1>.20'_;
Minimum 24.980 29.4 6.8 826 < 0.1 1268 1 7.2 1.20
;G ,G. - C C,� C
Monthly Limit 29.9 9.0 6.0 3205.0 12549.0 1 200.0 1 6.0
>/Ve v- ?,0i6 I-v,o6-Zeoll L v-zo/�--
a���.
Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit monitoring requirements.
Compliant
All monitoring data and sampling frequencies do NOT meet permit monitoring requirements.
Noncompliant
If the facility is noncompliant,please comment on corrective actions being taken in respect to equipment,
operation,maintenance,etc.and a time table for improvements to be made.
Three weekly fecal coliform tests were noncompliant for the month of June.The monthly geometric mean however was within compliance.
All systems were checked and appeared to be functioning as designed.No disruption in treatment was observed.The National Council
for Air and Stream Improvement(NCASI)was contacted to help assist with determining the cause for the test values.Bacterial specials n
testing was performed along with duplicate samples for total coliform and E.ccli..NCDEQ's regional office staff were contacted after each
test and kept informed of the ongoing study.This study is still currently being run with the results going to the regional office for review.
°I carry,under penalty of law,that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted.
Based on my inquiry of the person or persons who manage the system,or those persons&e*responsible forgathering the
Information,the information submitted is,to the best of my knowledge and belief,true,accurate,and complete.I am aware that there are
significant penalties for submitting false information,including the possibility of fines and imprisonment for knowing violations!
Michael Ferguson
Permittee(Please print or type)
Signature of Pernittee" Date
P.O.Box C-10 Canton,NC 28716 82H46-2840
Parameter Codes
00010 Temperature 00556 Oil&Grease 00951 Total Fluoride 01067 Nickel 50060 Total
00076 Turbidity 00600 Total Nitrogen 01002 Total Arsenic 01077 Silver Residual
00080 Color(Pt-Co) 00610 Ammonia Nitrogen 01092 Zinc Chlorine
00082 Color(ADMI) 00625 Total Kjeldahl 01027 Cadmium 01105 Aluminum
00095 Conductivity Nitrogen 01147 Total Selenium 71880 Formaldehyde
00300 Dissolved Oxygen 00630 Nitrates/Nitrites 01032 Hexavalent Chromium 31614 Fecal Coliform 71900 Mercury
00310 BOD5 01034 Chromium 32730 Total Phenolics 81551 Xylene
00340 COD 00665 Total Phosphorus 34235 Benzene
00400 pH 00720 Cyanide 01037 Total Cobalt 34481 Toluene
00500 Total Solids 00745 Total Sulfide 01042 Copper 38260 MBAs
00530 Tot Suspended 00927 Total Magnesium 39516 PCBs
Residue 00929 Total Sodium 01045 Total Iron 50050 Flow
00545 Settleable Matter 00940 Total Chloride 01051 Lead
Parameter Code assistance may obtained by calling the Water Quality Compliance Group at(919)733-5083,extension 581 or 534.
The monthly average for fecal coliform is to be reported as a GEOMETRIC mean. Use only units designated in the reporting
facility's permit for reporting data.
ORC must visit facility and document visitation of facility as required per 15A NCAC 8A.0202(b)(5)(8).
'If signed by other than the pemmittee,delegation of signatory authority must be on file with the State per 15A NCAC 2B.0506(b).
evergreens Canton Office
I 175 Main Street• Canton, NC 28716
packaging
June 16, 2016 NMM#29-16
CERTIFIED MAIL
Return Receipt Requested — _ �•.._
7006 0100 0003 6622 5613 F - RECEIVED_a_, -. -
1Jwwon of Water Resources
Landon Davidson
Asheville Regional Supervisor JUN 10 2016
Division of Water Resources t
North Carolina Department of Environment Water Quafity Regional Operations i
and Natural Resources A f avuta Raafonal oitf•,n
Asheville Regional Office
2090 US Highway 70
Swannanoa,NC 28778
f�
Subject: Blue Ridge Paper Products Inc. dba Evergreen Packaging I
Canton Mill, Canton,Haywood County,North Carolina
Daily Maximum Fecal Coliform 6/9%2016
NPDES Permit: NC0000272
Dear Mr. Davidson:
This is the 5-day written submission for the subject monitoring result required by NPDES permit
Standard Conditions Section E: 6(a). The secondary effluent fecal coliform sample was taken on
6/9 at approximately 11:35 am and picked up by the laboratory for analysis. Proper sampling
procedures were followed by plant personnel. We received the laboratory report via email the
aftemoon of 6/10. The result of the analysis showed a value of 1410 MPN per 100 ml. The fecal
coliform excursion on 6/9 was limited to that sample parameter and day. A phone call was
placed to the NCDEQ regional office on 6110.
Once we received the value from the laboratory all systems in the treatment facility were
inspected. They were found to be operating correctly leading up to and during the time of
sample. The Town of Canton's chlorine injection system was also inspected.
We are continuing our in depth investigation into the cause of these recent results. If an
identified source or cause is determined, a follow up notice to your office will occur describing
the results of our findings.
If you have any questions or comments,please feel free to contact us at your earliest
convenience.
fresh by design e.
Doing Business In California as Evergreen Beverage Packaging
IleverpacklcalEOHSISHAREMater FilesWick's Water FlleslDWR
NCDWR Page 2
Sincerely,
Nick McCracken
Water Supervisor
Evergreen Packaging—Canton Mill
828-646-2874
Nick.McCracken a,everpack.com
cc:
Mr. Tim Heim
Environmental Specialist,Asheville Regional Office
North Carolina Department of Environment
&Natural Resources
2090 U.S. Highway 70
Swannanoa,NC 28778
C. File—Water Notebook
VDIVISION OF WATER RESOURCES-CIVIL PENALTY ASSESSMENT(File)
Violator: Blue Ridge Paper Products Inc
Facility Name: Canton Mill
Permit Number: NC0000272
County: Haywood
Case Number: LV-2016-0252
ASSESSMENT FACTORS
1) The degree and extent of harm to the natural resources of the State,to the public health,or to private property
resulting from the violation;
All effluent violations may be detrimental to the receiving stream but may not be immediately quantified.
2) The duration and gravity of the violation;
Three Daily Max Fecal Coliforms exceeded the permit limit by 50%,252% & 8.7%.
3) The effect on ground or surface water quantity or quality or on air quality;
All effluent violations may be detrimental to the receiving stream but may not be immediately quantified.
4) The cost of rectifying the damage;
The cost is unknown.
5) The amount of money saved by noncompliance;
The amount of money saved is unknown.
6) Whether the violation was committed.willfully or intentionally;
It does not appear to be either.
7) The prior record of the violator in complying or failing to comply with programs over which the Environmental
Management Commission has regulatory authority; and
There has been one civil penalty enforcement in the twelve months prior to this violation.
8) The cost to the State of the enforcement procedures.
$116.62
Date G.Landon Davidson,P.G.,Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources,NCDEQ
Enter/Verify Violations f,
L^imifViola ons_ Monitoring violations Reporting Violations Other Violations
_ .
Perrrut NC0000272 #Detads`�, SOCC AD: ❑etails... Monitoring Report 6-2016 Details':'
Facility: antonMill -Details=-- Region: Fheville County aywood
Owner: lue Ridge Paper Produdslnc ` Maintain-c= Incident Details._ Inspect Dt Details...
e-
-- 1
Facility Reported As: fb6ornpliant Non-Compliant QNotReported ` fvIssigned Report Type: FMR
I`OulfW j'Locagon{ W� Parameter �- - 'Date ;Manual Description ('SDC i Limit Calcu_.I Unit.. r%Over j -�--
001 Effluent Coliform,Fecal MF,MFC B_ 06102/2016 H Daily Maximum_ 0 1400 _ 600 _#1100ml 50
001 Effluent Coliform Fecal MF,MFC B_ 061DW016 Ej DadyMaximum_ 0 1400 _ 1410 _fN10Drd 252.5 _
001 Effluent Colitorm,Fecal MF,MFC B_ 06116P2016 L-j DaOy Maximum_ H 400 _435 _tN100m1 8.7499_
edd
t
• Remove
Initiate NOD... Initiate NOV_, IniOateEnforcemenL_ Initiate tt emantl . Save 8 Recalculate DfrIR_
3LImitViolafons found.,.^
IFrom: ...., �
Sent: Davidson, Landon
To: Monday, October 03, 2016 1:05 PM
Cc: Nick McCracken
Subject: Cantwell,Janet Heim, Tim
NOV deadline extension
Nick-
I received your voicemail message requesting an extension to the
approval to extend the response deadline 10 days,
Thanks. NOV response deadline. Please consider this email
Landon
G. Landon Davidson, p,G,
Regional Supervisor—Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ—Division of Water Resources
828 296 4680 office
828 230 4057 mobile
Landon.Davidson,ncdenr. ov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28711
M.
"Nothing Compares
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Swannanoa,NC 28778-8211
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Nue Ridge Paper Products, Inc.
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