NC0000078_Plan of Action_20080813

NPDES DOCYNENT SCANNING COVER SHEET
NC0000078
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
(
Plan of Action
Speculative Limits
Instream Assessment (67b)
Environmental Assessment (EA)
Permit
History
Document Date:
August 13, 2008
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Davidson Aver Village
PO box 880
Pisgah forest, NC 28768
rkone828-88+-5541- tax828-88+-9766
August 13, 2008
Dr. Sergei Chernikov
NC DENR
Division of Water Quality
NPDES Permitting
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Sergei:
RECEIVED
AUG 1 8 2005
DENR - WATER DUALITY
POINT SOURCE BRANCH
I have attached a copy of what is being called an ASB Management Plan.
As you know, the Ecusta site is being cleaned up and torn down. We have been working
closely with Roger Edwards and Keith Hanes of DWQ here in Asheville along with Jim
Bateson and Harry Zinn from Raleigh.. In addition, Jennifer Wendel and Dave Andrews,
both from the EPA, are involved with the site. Roger and Keith have raised two issues
upon which your guidance is sought.
The first issue is our desire to use our waste treatment systems to treat a 200,000 gallon
solution of liquors andpulping solutions that we have on site. From our point of view, we
can assure you that this mix is not new to the site and consists of products that have been
treated here since the system was installed in the early 70's. It would be very helpful if
you would be kind enough to review the document and provide your concurrence or offer
any additional testing, monitoring procedures, or permit modifications that you would
like to see in place.
The second issue involves storm water. Because of our desire to protect the river from
demo activities, we have directed all storm water thru the treatment system. As you
know Sergei, some of the storm water drains on this site have always gone throug the
treatment systems. The concern is that this may vary the historical flow and require a
permit modification. As you know, the historical flows are as much a factor of rain
events as they are of the number of pipes being re -directed into the system. Again, your
guidance and concurrence on this issue is also sought. We are willing to perform any
additional testing or monitoring parameters that you suggest.

Page Two
Dr. Sergei Chernikov August 13, 2008
Through the entire process we will continue to monitor and sample and test and continue
to perform all of the requirements of our NPDES Permit. All of the equipment at the ASB
is functioning correctly including the composite sampler.
Sergei, should you have any questions or require any additional information, kindly feel
free to contact Bill Ashbrook or me. Bill is of course much more technical on these
matters than am I. Bill's phone number is 828-489-9878. My phone number is 828-884-
5544.
Thank you for your help in this matter.
Sincerely,
A L-----
Bernard M. Kelly
Business Manager
CC: Roger Edwards, NC DENR
Keith Haynes, NC DENR
William Ashbrook, Davidson River Village
Mike Singer, Davidson River Village

ECUSTA MILLS
ASB MANAGEMENT PROCEDURES
1.0 Introduction
The purpose of the Ecusta Aeration Sedimentation Basin (ASB) Management Procedure
is to provide guidance and procedures for the on -site treatment of select process
materials, and to provide a framework for the on site personnel that will perform the
work. This plan will also provide NC DENR an opportunity to approve the procedure
and/or add any additional testing to ascertain that the ultimate discharge to the French
Broad River is in accordance with the NPDES Permit. The selected materials consist of
process liquors and solutions formerly used at the facility treated by the ASB system.
The total volume of materials currently scheduled for on -site treatment is approximately
200,000 gallons, which represents less than 1% of the daily influent the system
historically treated. All materials identified for treatment have been sampled and tested
to assure accurate identification and suitability for on -site treatment. The procedures
discussed below will involve transport of the process materials to the North clarifier by
using a vacuum truck or tanker, followed by testing, additional treatment as necessary
discharge over to the ASB. It is important to note that only materials formerly used in the
paper and pulp making process along with filter plant substances are included in the
200,000 gallons.
2.0 Preparations for Treatment
In order to prepare the ASB for treatment, several loads of septic sludge have been
introduced to provide additional biological population. In addition, six aerators in the
ASB have been repaired and brought on-line, and recent monitoring results in the ASB
have shown an increase in dissolved oxygen (DO) levels.
Secondly, prior to the transport of any process materials to the North Clarifier, the
structure has been emptied of standing water and inspected for integrity by the Division
of Water Quality (DWQ) Asheville, representatives, Roger Edwards and Keith Haynes.
3.0 Site Materials for ASB Treatment
Based on an April 2008 survey, there are 445 inventoried tanks at the Ecusta Mill. The
majority of the tanks on site are either empty or contain residual quantities usually in the
form of solids/sludge or tank bottoms. Of the remaining tanks, approximately 50 contain
aqueous liquids that can be safely treated in the waste treatment plant. All tanks and
container contents were characterized by researching labels (MSDS's), performing
hazardous categorization and/or laboratory analysis. An itemized list containing the
materials and amounts proposed for water treatment are pre jj�� 4' Table 1 " . tN' I"
-�J d m�
.. mom+ � '
AUG 1 s 2008
DENR - WATER QUALITY
POINT SOURCE BRANCH

4.0 Management of Materials to the Clarifiers
As outlined above, a vacuum truck will be used to transport all of the materials from their
respective tanks into the North Clarifier. A dedicated offloading area has been
constructed adjacent to the clarifier to contain any potential spills. The offloading area
will be bermed and lined such that the back end of the vacuum truck will be fully
contained to prevent spilled materials from discharging to the environment. Additionally,
spill kits will be staged at the offload area in case of any incidental discharge.
5.0 Management of Materials staged in the Clarifiers
As tank materials are transferred to the clarifier, DRV will institute routine monitoring of
the clarifier. After review, it is believed that solutions listed in Table 1 can be safely co -
mingled. As an additional precaution Shaw Environmental will conduct a bench scale
"blending test" as new loads of material arrive to assure no adverse reactions will occur
within the clarifier. This procedure involves adding a small scale, proportional amount of
the incoming material to a glass vessel (i.e 5,000 gallons equals 50 ml of material added
to the test vessel) representing the material staged in clarifier, and observing the vessel
for adverse reactions (see Section 5.0 below). As additional materials are introduced to
the clarifier, several methods for pre-treatment of the liquids are available prior to
discharge to the ASB including the following:
Aeration/ Circulation
Both DRV and DWQ believe that additional aeration of the clarifier would be beneficial.
This process will allow the homogenation of the discharge and will eliminate "pockets"
of undesirable quality in the clarifier, providing additional dissolution of solids to reduce
total TSS values. As the clarifier motors are inoperable, aeration/ circulation will be
accomplished utilizing one of the large pumps, or if possible, thru the introduction of an
air -pipe into the clarifier.
pH Adjustment
While the material is staged in the clarifier, continuous monitoring of the clarifier pH will
be conducted. A bench -scale pH titration may be used to determine the full-scale volume
of reagent needed to adjust the clarifier pH. Final testing of the clarifier liquids with a
calibrated pH meter will occur prior to the slow release of the liquids to the ASB.
6.0 Management of Materials to ASB
DRV believes that all 200,000 gallons of material identified can be added to the North
Clarifier without incident. Before discharge to the ASB, testing of the batched clarifier
materials will be conducted, for BOD5, and pH. Upon receipt of results, discharge rates
will be established with DWQ that insure no overloading occurs at the treatment pond.
After commencing discharge, a visual check will be made of the ASB influent point and
DO readings will be collected daily from two locations along North and South sides of
the ASB lagoon and the quiescence zone.
2

Discharges into the ASB will be halted if any suspect, or concerning conditions exist.
Other conditions that may cease discharge of the staged material to the ASB discharge
could include:
• Large storm water events, which may alter the chemistry of the clarifier batch or
require that the entire system be dedicated to storm water at the time
• Physical changes in the batch material (i.e. overnight) such as color, viscosity,
increased solids or precipitation
• Visible adverse chemical reactions such as excessive heat, foaming or off -
gassing
In this event, additional baseline sampling and testing of the clarifier material will occur
to aid in the development of a revised treatment scheme any new discharge processes will
utilize the clarifier management procedures discussed above.
7.0 Testing and Monitoring Procedures
Testing and monitoring of the entire process will occur at four major points of the process
as summarized below:
• Bulk Tank Small Volume Container — As discussed above, a comprehensive
survey and testing of tanks, totes and containers have been completed. The result
of this survey served as the basis for the list of materials DRV included in Table
1.
• Clarifier — The materials placed into the clarifier will be closely monitored in
relation to the ASB NPDES discharge limits.
• ASB — As an additional safety factor, the ASB will be sampled and tested prior to
discharge if there is a concern that an undesirable condition exists within the
lagoon.
• ASB Discharge — During discharge to the French Broad River, the effluent will
continue to be sampled and tested in accordance with the current NPDES permit.
All on -site monitoring such as DO or pH will be conducted by trained and qualified Shaw
technical personnel along with DRV's licensed waste water operators using calibrated
field instrumentation. All off -site analyses will continue to be conducted by a State of
North Carolina certified laboratory.
8.0 Design Changes to Site the Process Sewer System
Due to the ongoing demolition activities, as well as the May 2008 release, several
engineered changes to the site storm water system and process sewer system have been
constructed. During the 70's, when the sewer separating project and the wastewater
treatment system were installed there was an effort to separate storm -water from process
water on the "paper making" side of the facility. Hardly any effort to separate these flows
was made on the "film side" of the facility. The "paper making side" of the facility was
considered to be high risk were not separated. High risk was determined in areas such as
3

unloading etc., where it was felt a spill might get into the river. In essence, the ASB has
always seen some storm water. As a result and as added protection to the Davidson River
and the surrounding site lands, DRV has engineered the two major storm water ditches on
site (South Ditch and East Ditch) to receive all site storm water during demolition
activities and transfer the storm flow to the waste water system.
9.0 Summary
These procedures were developed by Shaw Environmental in conjunction with Bill
Ashbrook who has overseen the operation of the Waste Treatment Facility at the Ecusta
site since the system was constructed. Bill Ashbrook is a chemist with a Grade IV
Wastewater license. Bill is completely familiar with all of these materials outlined on
Table 1, and the ability of the system to handle them. In essence, we are asking DENR
for permission to precede with this proposal by assuring them that nothing new in the
way of a chemical waste make-up is being introduced into the system.
4

TABLES
5

TABLE 1
Proposed Chemicals for ASB Disposal
Chemical/Product Name
Volume (Gallons)
Total
Volume
(Gal)
Associated Tank (T) or
Container (C) #
Haz-Cat, Label,
Analytical
Notes
Order In Which
Product Will Be
Placed In Clarifier
Tank(s)
Aggregate
Containers
Weak Liquor
135,000
135,000
T115, T129, T269, T270, T271,
T444, T65, T64
Haz-Cat, Label,
Analytical
This estimate may vary depending on how
thick the sludge is and how much weak
liquor is setting in the sumps.
1
Small Containers of
Assorted Alkaline/Caustics
50
50
C460, C461, C462
Label
2
Caustic Soda 50%
60
60
C303, C304, C305
Label
3
Elimin-ox
40
40
T31
Haz-Cat, Analytical
pH 12
4
Nalco 7221
175
175
T35
Haz-Cat, Label
Positive for phosphates
5
Solid Calcium Carb/Water
22,500
_ 22500
T42
Haz-Cat, Label
pH 9 positive for calcium
6
DETAC DC3970
2,062
1,855
3917
T141, C7, C8, C9, C10, C58,
C126, C127, C388, C397, C401
Haz-Cat, Label
pH 7 slightly sinks in water, viscosity
standard 3-4
7
Latex Solution
4,000
4000
T243
Label
8
Aluminum Sulfate
3,000
3000
T430, T431
Label
9
Chemtreat BL 122
160
160
T30, T33
Haz-Cat, Analytical
10
Unknown
275
_
275
T133
Haz-Cat, Analytical
pH 10
11
Small Containers of
Assorted Acids
50
50
C457, C458, C459
Label
12
Paper Stock
5,075
5075
T337, T126
Haz-Cat, Analytical
13
Calcium Carbonate Slurry
14,700
14700
T39, T40
Label
14
Phosphoric Acid
140
- 140
C264, C265, C528
Label
15
Solid Calcium Carbonate
375
375
T41
Label
16
Sulfuric Acid
800
800
C263, C385, C387, C398
Label
17
Lime Slurry
9,300
9300
T56
Haz-Cat
pH 10 positive for calcium
18
Soda Ash (Solid)
450
450
C236
Label
One pallet of 50# bags total of 450#
19
Sodium Metabisulfate
(Solid)
250
250
C76
Label
One pallet of 50# bags total of 250#
20
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