NC0006254_Correspondence from ARO to Blue Ridge Tissue_20140115

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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A, Reeder John E, Skvarla, III
Governor Director Secretary
January 15, 2014
David Hallock, General Manager
Blue Ridge Tissue Corporation
Post Office Box 99
Patterson, NC 28661
Subject: Fiber Trap Assessment and Monitoring
Blue Ridge Tissue Corp. - Patterson Mill
NPDES Permit NC0006254
Caldwell County
Dear Mr. Hallock,
The Division of Water Resources (DWR) recently notified you that additional groundwater
monitoring wells will be required at your Patterson Mill in Caldwell County, as authorized by
Section B of Part III in your current NPDES permit. Based on existing data, it appears the biotic
breakdown of organic material in your unlined fiber traps is creating anoxic conditions that
solubilize iron and manganese oxyhydroxide minerals. Additionally, this anoxic process water
appears to be recharging local groundwater; therefore, directly responsible for the occurrence
of iron and possibly manganese concentrations above the North Carolina Groundwater
Standard, 15A NCAC 2L .0202. Our request for additional monitoring wells will determine
groundwater quality conditions at your permitted compliance boundary.
In your response letter (November 21, 2013), you delayed the installation of the compliance
boundary monitoring wells so that monitoring well MW-1 could be reevaluated as the sole
background well. You contend that monitoring well MW-5 does not appear to provide either
and up -gradient or cross -gradient reference point to the subject site nor is it in the same rock
type as the other monitoring wells. You maintain that monitoring well MW-1 is in a good
location and request further explanation as to why MW-1 is not an acceptable background well
location.
Groundwater movement across the Blue Ridge Tissue property encompasses three hydrologic
zones referred to as saprolite, transition, and fractured crystalline bedrock. The groundwater
Water Quality Regional Operations —Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, N.C. 28778
Phone [phone]
FAX [phone]
Internet: ncwater.org
An Equal Opportunity/Affirmative Action Employer

Blue Ridge Tissue Corporation
January 15, 2014
Page 2 of 3
potentiometric map generated by AECOM (see attached map) largely depicts groundwater flow
within the saprolite zone. Groundwater movement within the transition zone and crystalline
bedrock has yet to be defined. The contours on the map show groundwater flowing in a radial
pattern away from a knoll or groundwater recharge area near the fire sprinkler reservoir.
Groundwater quality should be somewhat consistent across this recharge area. Despite some
remaining questions as to the interpretation of groundwater contours north of the fiber traps,
all treatment works and monitoring wells (including MW5) are located down -gradient of this
recharge area.
Groundwater quality north of the recharge area (MW-5) is characterized by low iron -in -
groundwater concentrations, low specific conductivity, and aerobic conditions. Groundwater
quality immediately south of the recharge area (MW-2 & MW-3) is characterized by high iron -
in -groundwater concentrations, elevated specific conductivity, and anaerobic conditions.
Groundwater quality near the Yadkin River (MW-1 & MW-4) is very similar to the south side of
the recharge area; namely, high iron -in -groundwater concentrations, elevated specific
conductivity, and anaerobic conditions.
In your response, you attribute this discrepancy in groundwater quality to differences in
lithology. The AECOM report associates monitoring well MW-5 with a schist unit north of the
recharge area. Monitoring wells south of the recharge area are associated with a gneiss unit.
The boundary between these two geologic units was identified using the state geologic map.
Caution should be exercised in using the state geologic map for site investigations because of its
small scale (1:500,000) and lack of detail. The NC Geologic Survey also warns of possible
georectification issues associated with the location of these geologic boundaries. This
uncertainty is further supported by AECOM's own boring logs which associates monitoring well
MW-4 with a schist rock. A more detailed site investigation is recommended before assigning
specific geologic units to the monitoring wells.
The Division feels strongly that monitoring well MW-5 represents the natural background
concentration for iron -in -groundwater in the vicinity of the recharge area. In our experience, a
natural iron -in -groundwater concentration greater than 30 mg/I would be extraordinary for
western North Carolina. Background iron -in -groundwater concentrations at your former land
application site (Wagner Property) are less than 1 mg/l. Our limited survey (June 2012) of
drinking water wells in Patterson, NC found iron -in -groundwater concentrations ranging from
non -detect to less than 1 mg/l. A groundwater study of the Morganton Area by the State of
North Carolina found 85% of all drinking water wells surveyed contained iron concentrations
less than 0.3 mg/I.
Existing evidence suggests that a plume of anoxic water originating at the fiber traps is
infiltrating all three hydrologic zones on the south side of the recharge area and extends to the
Yadkin River near the production plant. Northeast/southwest trending fractures/joints/faults in
the crystalline bedrock provide a likely conduit for the anoxic process water to reach areas
farther out such as monitoring well MW-1. Monitoring well MW-1 is a poor background well

Blue Ridge Tissue Corporation
January 15, 2014
Page 3 of 3
location because of its proximity to a groundwater discharge area and evidence suggesting a
connection to the anoxic plume.
You will be required to construct, at minimum, two down -gradient wells at the compliance
boundary. You can continue to use MW-5 as the background well or select a new location that
is acceptable to the Division. Initially, you will need to submit a site map depicting all applicable
regulatory boundaries and any proposed monitoring well locations. Based on the origination
date of your NPDES permit (1979), the compliance boundary will be established 500 feet from
the waste boundary or at the property boundary, whichever is closer to the source. A
groundwater review boundary is not required for this facility.
Please respond to this office within 60 days of receipt of this letter. We are available to meet
and discuss the groundwater monitoring requirements in greater detail. I am available if you
have any additional questions or concerns. I can be reached at [phone] or
[e-mail].
Sincerely,
l
Brett 4verty
Water Quality Regional Operations
Asheville Regional Office
cc: file
Attachments: 1) AECOM Groundwater Potentiometric Map for Blue Ridge Tissue Corporation
2) Asheville Regional Office memo dated October 31, 2012
3) Geology and Groundwater Resources of the Morganton Area North Carolina
4) Preliminary Hydrogeologic Assessment and Study Plan for a Regional Ground -water Resource
Investigation of the Blue Ridge and Piedmont Provinces of North Carolina

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A=COM Property Boundary Groundwater Potentiometric Map
Monitoring Well Location
® Abandoned Water Well Blue Ridge Tissue Corporation
AECOM Environment [�1"
Groundwater Contour, dashed where inferred Patterson, North Carolina /�
8540 Colonnade Center Drive Ste 306 y Groundwater Flow Direction 0 200 400
Raleigh. North Carolina 27615 1240.9 Groundwater Elevation (ft above mean sea level) Feet
Phone :[phone]
Fak [phone] — Landsurface Elevation Contour (itabove mean sea level)1 inch = 200 feel
Web : wwwaecom com --, Yadkin River Flow Direction June 2012 60191560