NC0006254_Correspondence from Blue Ridge Tissue_20131121

Mr. Brett Laverty
Water Quality Section
North Carolina Division of Water Resources - Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778
November 21, 2013
Subject: Blue Ridge Tissue and Sealed Air Joint Response Letter
Fiber Trap Assessment and Monitoring
Blue Ridge Tissue Corp. - Patterson Mill
NPDES Permit NC 0006254
Caldwell County
Dear Mr, Laverty;
This letter is in response to your September 25, 2013 letter regarding the subject matter
In February 2011, a background monitoring well MW-1 was installed to establish background total iron
concentrations in groundwater on the Blue Ridge Tissue Patterson Mill site. The selected background
monitoring well location was in a wooded area northeast of the intersection of Yadkin River Road and
Whisnant Road. At the same time, three additional monitoring wells, originally installed in 2009 were
sampled: MW-2, MW-3 and MW-4.The subsequent groundwater monitoring identified total iron
concentrations ranging from 29,000- 91,000ug(L including MW-1.
Following a review of the results, in a letter dated June 2, 2011, the NCDENR indicated that MW-1 was
not in a suitable location due to a soil contamination incident report during the replacement of the bridge
over the Yadkin River on Whisnant Road. However, MW-1 location is north and up -gradient of the soil
cleanup area and bridge project and thus, not believed to be in close proximity of or impacted by the oil
release. The consultant's soil boring logs appear to confirm that the soil was not disturbed from prior
remediation or construction activities. We maintain MW-1 is a good background well location and ask for
further explanation as to why MW-1 is not an acceptable background well location understanding that it is
not in close proximity to the prior remediation site and was not involved in previous construction activities.
A photo of MW-1 location relative to oil release clean-up near the bridge and MW 1 Soil Boring Log are
attached.
In August 2011, NCDENR requested an additional monitoring well be installed to establish background
iron concentrations in groundwater. The monitoring well was located west of Yadkin River Road and north
of the existing well MW-3 on property owned by Joseph Doll. Groundwater samples were taken from MW-
5 on August 17, 2011 by AECOM showing total iron concentrations of 400ugtL. Based on area
topography, this well does not appear to provide either an up -gradient or cross -gradient reference point to
the subject site. Furthermore, based upon a North Carolina Geologic survey map that is attached, MW-5
also does not appear to be in the same rock type as monitoring wells 1-4 and thus MW-5 does not appear
to represent a good background well location.

Page 2
Mr. Brett Laverty
November 21, 2013
Blue Ridge Tissue received information from NCDENR under a cover letter dated October 31, 2013
showing sampling results of five down -gradient neighboring drinking water wells. These sample results,
which are from the June 2012 well receptor assessment that was conducted by the NCDENR, identified
total iron to be very low in all five wells tested and therefore below the NC groundwater standard 15A
NCAC 2L.0202 .
We would like to better understand the assessment that was done on the down gradient drinking water
wells. Can the NCDENR provide any additional information about those drinking water wells such as type
of construction, aquifer sampled, etc.?
Regarding the installation of an additional background monitoring well and two down gradient monitoring
wells at the compliance boundary, we ask that the question as to the viability of MW1 versus MW5 be
investigated further before we commit to the installation of these additional wells. If it is determined that a
new background well is required, we prefer to develop an appropriate background well before developing
the site reap and the two down gradient monitoring wells at the compliance boundary.
In the meantime, Blue Ridge Tissue and Sealed Air are actively looking at alternatives to the Fiber Trap
waste water treatment process as requested in your September 25, 2013 letter.
Sincerely,
li-IIk
Dave Hallock
Vice President and General Manager
Blue Ridge Tissue
avid Day
Global Director EHS Auditing — Sealed Air
Attachments: Photos, N.C. Geologic Map & Soil Boring Log
cc: Dan Williams -- Global Environmental Programs Director - Sealed Air

AECOM eport (Capability, 2
OF Approximate location of
former Maintenance Garage
(location of the new bridge)
Blue Ridge Tissue Facility
Monitoring Well MW-9
Photograph 3: View looking south toward the Blue Ridge Tissue Facility. Mote the location of MW-1
relative to the new bridge, where the maintenance garage was located.
i
Former concrete pad for A
maintenance garage
Photograph 4: 2007 view from the concrete pad looking north toward the future location of MW-1
CAWINDOWS\TEMPNAppendix D - Photograph Log.docx Oecernber 2011

Chem: Sealed Air
Project Number.
BORING ID.' MW-1
Site Location: Patterson, NC
Coordinales: .Elevation:
Sheet:
Drilling Method.-
Momforing Well Installed. Y
Sam to T e s : Soria Diameter:
Screened Interval. 6-1I t
Weather:
Lo ed Syr MD
Daieffime Started; 217111
De 1h o Boring. 11 t
DrillingContractor: AB Drilling
Ground Elevation:
Date/Trme Finishe, 217111
Water Level:
p
q
o
c�
a
U
Q
o
w
C
a
ro
5
MATERIALS: Color, size, range, MAIN COMPONENT, minor
component(s), moisture content, structure, angularity, maximum grain size,
odor, and Geologic Unit (If t{nawn)
a
n
E K
n s
o Q
(0-2) light brown SANDY SILT w/minor orgainic rnateral, dry.
x
3
4
(2-6) Yellowish -orange SAND with gravel and minor fine sediment, dry- Alluvial sediment
5
deposits-
fi
7
8
(6-10) As above with increasing gravel and rn inor cobbles (partially pulverized).
9
10
(10-1 1) PWR, refusal al 11' bls, gneiss.
II
12
13
14
15
ifi
17
18
I9
20
Dale
Time
Depth to groundwater while drilling
(VOTES:
Checked by Date.