NC0006254_Correspondence from ARO to Blue Ridge Tissue_20150219

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North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
February 19, 2015
David Hallock, General Manager
Blue Ridge Tissue Corporation
1427 Yadkin River Road
Lenoir. NC 28645
Dear Mr. Hallock,
Donald R. van der Vaart
Secretary
Subject: Additional Site Assessment Activities Report
Land Application Permit W00011532
NPDESPermit NC0006254
Blue Ridge Tissue Corp. - Patterson Mill
Caldwell County
The Asheville Regional Office received the AECOM report (December 18, 2014) concerning
the latest phase of groundwater monitoring at the Blue Ridge Tissue facility in Caldwell
County. As you are aware, North Carolina Division of Water Resources (DWR) personnel
were present during the August 18 -19, 2014 sampling event and split samples with
AECOM field staff. DWR samples were analyzed for 18 metals by our laboratory in Raleigh.
The final analytical results are attached to this letter.
One of the goals of the investigation was to establish a background level for iron -in -
groundwater within the quartz monzonite gneiss unit that underlies the fiber traps and
wastewater treatment ponds. After some discussion, it was agreed upon by all parties that
monitoring well MW6 would represent background groundwater quality for the immediate
area of investigation. Analytical results from both the AECOM and DWR samples indicate no
detectable iron at MW6. It is important to note that manganese was present in the DWR
sample at a concentration of 200 micrograms per liter, which is above the state's
groundwater standard (15A NCAC 02L.0202). This concentration will be used as an
approximate background level for manganese -in -groundwater within the quartz
monzonite gneiss unit.
Monitoring wells MW1 thru MW4 extend eastward from the fiber traps to the Yadkin River
and represent the quality of groundwater down gradient of the wastewater treatment
system. Analytical results from both the AECOM and DWR samples indicate total iron
concentrations ranging from 7,600 micrograms per liter to 120,000 micrograms per liter.
Manganese was present in the DWR samples at concentrations ranging from 640
micrograms per liter to 1,700 micrograms per liter. All four monitoring wells exceed the
applicable groundwater standards and the local background levels for iron and manganese.
2090 U.S. Hwy. 70, North Carolina 28778
Phone: [phone] Internet www.ncdarrgov
An Equal Oppo ainly \Affirmafiva AcOon Employer —Made In parr b'rMolnd paper

Dave Hallock
February 19, 2015
Page 2 of 3
Some of the highest concentrations of total iron and ferrous iron are associated with the
two monitoring wells (MW2 and MW3) immediately down gradient of the fiber traps.
Furthermore, anoxic or reducing conditions such as low dissolved oxygen and negative
oxidation reduction potential values were documented at all four monitoring wells.
Monitoring wells MW7 and MW8 are located down gradient and directly south of the
wastewater treatment system. These monitoring wells were required by DWR to ascertain
the quality of groundwater near residential water supply wells along Roby Martin Road.
Analytical results from both AECOM and DWR samples indicate no detectable iron at either
monitoring well. Manganese was present in the DWR samples at concentrations ranging
from 44 micrograms per liter to 210 micrograms per liter, which is similar to the local
background level. Field parameters indicate aerobic conditions and positive oxidation
reduction potential values at these two monitoring wells.
DWR 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. The latest groundwater monitoring results confirm the existence of
anoxic or reducing conditions and elevated iron and manganese concentrations down
gradient of the fiber traps. Aerobic conditions and the lack of detectable iron at monitoring
wells MW5 thru MW8 assist in defining a narrow contaminant plume that moves eastward
from the fiber traps towards the Yadkin River.
According to 1SA NCAC 02L .0106 (c), any person conducting or controlling,an activity
which has not been permitted by the Division and which results in an increase in the
concentration of a substance in excess of the standard, other than agricultural operations,
shall:
1. Immediately notify the Division of the activity that has resulted in the increase and
the contaminant concentration levels;
2. Take immediate action to eliminate the source or sources of contamination;
3. Submit a report to the Director assessing the cause, significance and extent of the
violation; and
4. Implement an approved corrective action plan for restoration of groundwater
quality in accordance with a schedule established by the Director, or his designee.
As was stated in an August 29, 2014letter from this office, DWR supports your proposed
upgrades to the wastewater treatment system; namely the transition to an above ground
clarifier. We believe this change, along with the proper closure of the existing wastewater
treatment system, will remove any communication between the groundwater and
wastewater components. The current and historic groundwater assessment study coupled
with upgrading the wastewater/fiber system will satisfy regulatory requirements cited in
.0106(c) (1), (2) and (3) at this time. The DWR is not requiring a corrective action plan at
this time but continued groundwater monitoring is required.

Dave Hallbck
February 19, 2015
Page 3 of 3
1 propose that we convene a meeting at your earliest convenience to discuss a timetable for
replacement of the current wastewater treatment system, the closure of the existing
wastewater treatment system, and any associated groundwater monitoring.
Please feel free to contact me if you have any additional questions or concerns. I can be
contacted at [phone] or brettlaverty0ncdenr gov.
Sincerely,
Brett Laver
Water Quail egional Operations Section
Asheville Regional Office
Attachment NC DWR analytical results
cc: David Day- Sealed Air Cerebration