NC0006254_Correspondence from ARO to Blue Ridge Tissue_20130925

North Carolina
Pat McCrory
Governor
10DENR
Department of Environment and
Division of Water Resources
David Hallock, General Manager
Blue Ridge Tissue Corporation
Post Office Box 99
Patterson, NC 28661
Dear Mr. Hallock,
Water Quality Programs
Thomas A. Reeder
Director
September 25, 2013
Natural Resources
John E. Skvarla, III
Secretary
Subject: Fiber Trap Assessment and Monitoring
Blue Ridge Tissue Corp. - Patterson Mill
NPDES Permit NC0006254
Caldwell County
In 2009, the Blue Ridge Tissue Corporation conducted a Phase II environmental site
assessment of their Patterson Mill facility in Caldwell County. The AECOM Environment
Phase II report (October 5, 2009) noted elevated levels of iron in the groundwater
surrounding the wastewater treatment works. Additional assessment documented total
iron concentrations ranging from 18 mg/l to 91 mg/l in 4 groundwater monitoring wells
located down gradient from the earthen fiber traps and wastewater treatment ponds.
Corresponding samples collected from an up gradient or background monitoring well
exhibited total iron concentrations below 0.4 mg/l.
The level of iron -in -groundwater below the wastewater treatment works exceeds the
North Carolina groundwater standard,15A NCAC 2L .0202. The Division contends that the
biotic breakdown of organic material in the unlined fiber traps is creating anoxic
conditions that solubilize iron and manganese oxyhydroxide minerals in the shallow
regolith. These anoxic or reducing conditions were documented during a site visit by ARO
staff on October 18, 2012. Process water pumped from the bottom of fiber traps was
characterized by low dissolved oxygen (< 0.3 mg/1) and a negative oxidation reduction
potential (-150 mv).
The Division will require additional groundwater monitoring as authorized by
Section B of Part III (Other Requirements) in your current NPDES permit (October 13,
2008). The purpose will be to determine if water quality violations extend beyond the
WATER QUALITY SECTION
North Carolina Division of Water Resources —Asheville Regional Office
2090 U.S. Highway 70, Swannanoa, N.C. 28778
Phone [phone]
FAX [phone]
Internet: h2o.enr.state.nc.us
An Equal Opportunity/Af rrnative Action Employer

Blue Ridge Tissue Corporation
September 25, 2013
Page 2 of 2
appropriate regulatory boundary. Initially, you will need to generate a site map depicting a
waste boundary that encompasses the current treatment works followed by a compliance
boundary. It is important to note that the origination date for your NPDES permit is 1979.
According to 15A NCAC 02L .0107(a), disposal systems individually permitted prior to
December 30, 1983, shall establish a compliance boundary 500 feet from the waste
boundary or at the property boundary, whichever is closer to the source.
You will be required to construct, at minimum, two down gradient monitoring wells
at the compliance boundary and one background monitoring well. The monitoring wells
will be drilled to top of bedrock (transition zone) and constructed with proper sand packs
to minimize turbidity. Specific requirements will include triannual monitoring for inorganic
constituents (i.e. iron and manganese) and field parameters (i.e. dissolved oxygen). This
water quality information will be submitted to the Division on a GW-59 reporting form
referencing your NPDES permit.
Additionally, the Division would like Blue Ridge Tissue Corporation to explore
alternate storage options or engineered solutions for the existing fiber trap process in
order to abate any further groundwater impacts.
We are available to meet and discuss the groundwater monitoring requirements in
greater detail. Please respond to this office within 60 days of receipt of this letter. I am
available if you have any additional questions or concerns. I can be reached at (828) 296-
4681 or [e-mail].
Sincerely,
Brett ?vertv
Ashevilfe,Wonal Office
Water Quality Section