NC0006254_Correspondence from Blue Ridge Tissue_20140725

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'Blue Ridge '
July 25, 2014
Mr. Landon Davidson
Water Quality Regional Operations
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778
RE: Blue Ridge Tissue Corporation — Effluent Treatment System Replacement Project.
Dear Mr. Davidson,
This letter is intended to give NCDENR Water Quality Division an overall view of Blue Ridge Tissue's proposed
approach to addressing the Division's concerns about iron in groundwater on our property. This includes our
request/recommendation on the post installation conditions that would allow for final resolution of this issue.
Background:
Blue Ridge Tissue, (BRT), currently operates an effluent treatment system that was installed in the 1960's. The
system consists of two long narrow trenches in the ground, (referred to as fiber traps), and two ponds, (one
aeration and one final settling). The fiber traps are unlined. The aeration pond shows evidence of having been
lined at one time. The final settling pond, known as the polishing pond, shows no evidence of even' being lined.
There is also an unused pond adjacent to the current aeration pond that has been out of service for the majority of
the time the system has been in service. The system is currently operating within required permit parameters. In
the last 12 months there have been two instances of upset that resulted in our monthly BOD average to exceed our
permit limit.
The due diligence that was conducted in 2009 by NPS Corporation, (parent of Blue Ridge Tissue), during their
purchase of the property from Sealed Air Corporation, (parent of Omni Supply), revealed iron levels in the
groundwater on site that exceeded the State of North Carolina groundwater standard. NCDENR believes that
conditions created by the operation of the fiber traps is the cause of the high iron.
Proposal:
In an effort to fully and completely eliminate any potential cause of the high iron levels in the onsite groundwater
and in order to support a significant increase in production and the expansion of the current facility operations,
Blue Ridge Tissue proposes the complete closing of the current effluent treatment system and the installation of a
completely new, engineered, above ground treatment system to handle the in ill's effluent. The preferred location
for the new system is in the area where the polishing pond currently sits. (see attachment #1, 3D concept drawing,
and attachment #2, overhead satellite view of the current system).
Page I of 3
Blue Midge Tissue Corporation — Patterson Mill
1427 Yadkin River Road, Lenoir NC 28645

The first step in this project is to conduct a geotechnical study of the preferred location to confirm that the site
will support the construction of a new system such as the one that has been proposed.
Step #2:
The polishing pond must be taken out of service in order to drain the pond, clean out any remaining residuals and
prepare the site for construction of the new system. The residuals would be land applied per our current land
application permit. An operating variance would be requested from NCDENR to allow for the polishing pond to
be shut down and for effluent from the aeration pond to be directly discharged. See attachment #3, pounds per day
BOD and TSS coming from the aeration pond over the last 13 months. A temporary final filtering process such as
a Fuzzy Filter or geo-tube filter bag is being investigated as a way to improve aeration pond effluent quality if
deemed necessary.
Step #3#3:
The complete new system, (as shown in attachment #1), would be installed and commissioned while the current
system continued to operate as outline in Step #2 above.
Step #4:
Once the new system is completely operational and able to process all mill effluent within permit requirements,
the current system would be shut down. The fiber traps, the aeration pond and the unused pond would all be
dewatered either by allowing them to dry up or by pumping them out. Any water pumped from the fiber traps and
ponds would be run through the new system for treatment. Then they would be properly cleaned out with the
residuals being land applied. The current plan for final closing of the fiber traps and the ponds calls for the upper
level of the system, where the fiber traps are dug into the ground, to be bulldozed down to the lower level and into
the aeration and unused ponds. Additional fill, if needed, would be sourced onsite. The resulting large level area
would be left with the proper grade and drainage for rainwater run-off.
New system permitting_
At this point we do not anticipate the need to request any permit increases in daily loading of TSS, BOD, etc.
However, we may need to request a modest increase in the permitted daily flow of discharge from the system to
no more than 1,000,000 million gallons per day from the current 450,000 gallons per day limit. We would also
seek to continue with our land application permit for handling the residuals. The actual annual volume of
residuals has not yet been determined but is estimated to be 5000 — 6000 tons annually once the final phase of
production capacity is reached. A change to the permit would be requested to accommodate this increase in
volume.
Page 2 of 3

Resolution:
With this complete system replacement, BRT expects that what NCDENR believes to be the cause of high
iron in the groundwater will be completely eliminated, (fiber traps cleaned out and closed). We also feel that by
closing the entire current system, all possible suspicion of the aeration, polishing and unused ponds will be
eliminated as well.
The proposed new system will be constructed using modern methods and will be completely above ground. There
will be no release of any process water into the soil and water table below. We are confident that with the
complete closing of the current system and with the installation of the completely new system, the conditions
NCDENR believes to result in high iron concentrations will by default be eliminated.
We understand based on previous discussions with NCDENR that a No Further Action Required letter cannot be
issued prior to our moving forward with the project. We also understand that the monitoring wells and ground
water testing will still be required as previously instructed by NCDENR. However, before BRT commits to this
major capital expense and subsequent facility wide upgrade, we request that a letter of understanding/agreement
be provided by NCDENR that outlines the conditions that will result in the issue of a NFA letter after the new
system is installed and fully operational.
In this regard we propose the following conditions:
1. Monitoring will continue for 2 years after the current system is closed.
2. Iron levels will be deemed to be no longer impacted by the effluent treatment process on the site.
3. No further action would be required if levels of iron remain stable and do not increase after 2 years of
testing.
Based on these conditions, we specifically ask that NCDENR close the case and not require any further
monitoring beyond the 2 year time period. We ask NCDENR to concur that the cause of the issue has been
eliminated and that the iron levels will eventually return to natural levels if they have not within the 2 year
timeframe.
We appreciate your time and consideration as we work together on resolving this matter.
Thank you and Best Regards,
Dave Hallock X
Vice President and General Manager
Blue Ridge Tissue Corporation.
Page 3 of 3

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BOD Obs/day}
TSS (lbs/day)
Notes.
• Aeration data is BOD and TSS coming
out of the aeration pond prior to the
polishing pond stated in pounds per
day.
• Effluent data is BOD and TSS coming
out of the polishing pond stated in
pounds per day. This is the data that is
reported to NCDENR monthly per our
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discharge permit.
• The overall averages for BOD and TSS
during the entire 13 month period are
basically at the allowable monthly
average limits for the current permit,
(177.5#/day BOD and 230#/day TSS).
• BOD from the aeration pond would
have exceeded our current monthly
average permit limit four times, (Dec
q
'13, Jan'14, Feb'14 and April'14).
• TSS from the aeration pond would
have exceeded our current monthly
average permit limit six times, (July
'13, Aug'13, Dec'13, Jan'14, Feb'14,
June 14).
• When compared to the BOD and TSS
limits of our pending/proposed new
discharge permit, there would have
been no limits exceeded at anytime
during the entire 13 month period.
DATE
Aeration
Effluent
Aeration
Effluent
7/2/2013
182
500
7/6/2013
141
75
7/9/2013
42
52
159
36
7/16/2013
49
46
197
51
7/23/2013
107
87
304
87
7/30/2013
45
40
243
73
8/6/2013
182
424
8/7/2013
57
131
8/13/2013
91
249
8/14/2013
53
80
8/20/2013
106
92
307
104
8/27/2013
75
38
192
91
9/3/2013
65
245
9/4/2013
34
87
9/10/2013
145
139
273
112
9/17/2013
150
47
154
84
9/24/2013
241
162
187
78
10/1/2013
187
210
133
91
10/8/2013
133
202
10/9/2013
7z
72
10/15/2013
708
113
237
87
10/22/2013
108
56
139
55
10/29/2013
190
75
173
67
11/5/2013
140
59
166
84
11/12/2013
128
175
206
90
11/19/2013
177
150
227
121
11/26/2013
185
155
213
133
12/3/2013
219
91
264
126
12/10/2013
144
100
371
147
12/17/2013
264
102
230
106
12/23/2013
307
321
12/31/2013
256
228
204
45
1/7/2014
317
291
220
97
1/14/2014
400
339
229
88
1/21/2014
271
239
292
79
1/28/2014
185
83
2/4/2014
353
2/5/2014
151
90
2/11/2014
245
97
237
70
2/18/2014
261
161
367
93
2/25/2014
262
187
311
109
3/5/2014
101
78
233
77
3/11/2014
227
120
185
71
3/18/2014
255
230
139
57
3/25/2014
285
256
118
82
4/l/2014
276
251
131
Al
4/9/2014
250
279
170
74
4/17/2014
83
161
197
105
4/22/2014
221
168
253
97
4/23/2014
95
116
4/28/2014
268
231
275
145
5/6/2014
163
140
238
128
5/13/2014
157
132
255
148
5/20/2014
83
98
173
91
5/28/2014
68
113
97
343
6/3/2014
194
150
216
111
6/10/2014
161
81
228
137
6/17/2014
134
92
296
147
6/24/2014
93
64
267
77
7/1/2014
57
38
208
76
7/8/2014
51
35
148
75
7/15/2014
85
45
145
64
Average
175
129
229
97
Decrease
46
132
Decrease
26%
58%
h-rT 4e-H A^ Cly r # 3