NC0006254_Correspondence from ARO to Blue Ridge Tissue_20140829

NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
David Hallock, General Manager
Blue Ridge Tissue Corporation
Post Office Box 99
Patterson, NC 28661
Dear Mr. Hallock,
John E. Skvarla, III
Secretary
August 29, 2014
Subject: Application of 15A NCAC 2L .0200
Land Application Permit W00011532
NPDES Permit NC0006254
Blue Ridge Tissue Corp. - Patterson Mill
Caldwell County
This letter is a follow up to your July 25, 2014 correspondence in which you outline plans to
replace the current wastewater treatment system with a modern system. Conceptually, these
changes will eliminate the infiltration of process water to the subsurface and no longer contribute
to the observed reducing conditions present in the filter traps and aquifer system. The Division
appreciates Blue Ridge Tissue Corporation's efforts to upgrade the wastewater system and
commitment to addressing groundwater issues at the plant.
As indicated in your letter, permit modifications to the permitted flow volume and the amount of
residuals applied would need to be addressed through permit modifications. The NPDES permit
contact is Ron Berry (rDn [e-mail]) and the residuals management permit contact is Jon
Risgaard (ion [e-mail]). The Asheville regional office will continue to provide
support and assist where possible to facilitate these permit modifications.
In your letter, you indicate that the proposed new system will be completely above ground
resulting in the elimination of any process water releases to the soil and water table. Based on
these changes, you propose the following conditions to which we have provided a response based
on the regulatory requirements of 15A NCAC 2L.0200:
Monitoring will continue for 2 years after the current system is closed.
Response: NCDENR requiresgroundwater monitoring through DWR permits (e.g., NPDES,
non -discharge, etc.) and through regulatory requirements imposed on an entity when a
groundwater violation has occurred. Determining the duration of monitoring is difficult due
to fluctuations in groundwater chemistry, varying rates of attenuation, etc. DWR is however
veryflexible and open to reviewing anygroundwater monitoring requirements on a frequent
basis to reduce costs while maintaining quality data collection and compliance to applicable
regulatory requirements. Groundwater monitoring for many NPDES permits is required for
the duration of the system operation. Groundwater monitoring for sites with groundwater
standard violations is required usually one year (assuming levels have stabilized) after
Water Quality Regional Operations —Asheville Regional Dili
2090 U.S. Highway 70, Swannanoa, North Carolina 28778
Phone: 828-296A500 FAX: [phone]
Internet . hitp://poral.nodenr,orglweb&q
An Equal opportunity I ARrmalive Action Employer

Blue Ridge Tissue Corporation
August 29, 2014
Page 2 of 2
groundwater standards or natural condition concentrations are achieved. Evaluation of risk
to receptors is also a factor in determining monitoring frequency.
• Iron levels will be deemed to be no longer impacted by the effluent treatment
process on the site.
• Response: DWR agrees that by upgrading the system as proposed, you will be removing any
communication between the groundwater and wastewater components. 1SA NCAC 02L
.0106(c)(3) requires removal, or treatment and control of primary pollution sources.
Upgrading the system will satisfy the 15A NCAC 02L.0106(c)(3) corrective action
requirement by removing/replacing what DWR believes is the primary pollutant source.
• No further action would be required if levels of iron remain stable and do not
increase after 2 years of testing.
• Response: As previously stated, it is difficult to predict the concentration of constituents in
groundwater over time, especially metals. The need for continued testing and the frequency
of required testing will depend on concentration trends and otherfactors as previously
stated. The DWR will continue to assist Blue Ridge Tissue in reducing sampling frequency and
sampling points while maintaining quality data collection and regulatory compliance.
Your letter references the issuance of a No Further Action (NFA) letter by NCDENR. NFA letters
are only issued by NCDENR and therein, DWR, after completion of corrective action and only
when DWR has required an 'action' through a regulatory notice issued to a responsible party (i.e.,
Notice of Violation). To -date, Blue Ridge Tissue has not been issued a Notice citing regulatory
requirements as DWR determined that additional groundwater assessment was necessary to
establish naturally occurring concentrations and to evaluate compliance boundary monitoring
well locations. Following evaluation of recent groundwater analytical results at the compliance
boundary wells, DWR will be able to provide a more specific course of action for future regulatory
requirements.
Please feel free to contact me if you need further clarification or have any additional questions or
concerns. Please understand that DWR remains committed to assisting Blue Ridge Tissue through
this upgrade process. I can be contacted at [phone] or [e-mail].
Sincerely,
Brett Lav
Water Quality Regional Operations Section
Asheville Regional Office
cc: file
Peter McGrath - Moore & Van Allen PLLC