NC0000078_Permit (Issuance)_20070813

NPDES DOCUWENT 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, 2007
This document is printed on reuse paper - ignore any
content on the reirerge side

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Michael F. Easley
Govemor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
August 13, 2007
Mr. William Ashbrook
Ecusta Business Development Center, LLC
One Ecusta Road
P.O. Box 1119
Pisgah Forest, NC 28768
Subject: Issuance of NPDES Permit NC0000078
Mill in Pisgah Forest, North Carolina
Formerly: RFS Ecusta, Inc.
Transylvania County
Dear Mr. Ashbrook:
Division personnel have reviewed and approved your application for renewal of
the subject permit. Accordingly, we are forwarding the attached NPDES discharge
permit. This permit is issued pursuant to the requirements of North Carolina
General Statute 143-215.1 and the Memorandum of Agreement between North
Carolina and the U.S. Environmental Protection Agency dated May 9, 1994 (or as
subsequently amended).
This final permit includes the following major changes from the draft permit
sent to you on March 28, 2007:
• New language for Special Condition A. (8) has been developed in response to
your request.
• A new effluent page for a tiered flow has been added to the permit in response
to your request.
• A new Special Condition regulating Dam Integrity was added to the perm• it (See
A. (9)).
• Monitoring frequency for Mercury has been reduced to Quarterly based on the
review of the additional monitoring data and as a response to your request.
• Monitoring frequency for Dioxin has been reduced to Semi -Annually based on
the review of the additional monitoring data and as a response to your request.
• The daily maximum limit for Mercury has been reduced to 0.055 .pg/L
from 0.057 pg/L to correct an error.
• The daily maximum limit for Dioxin has been reduced to 0.065 pg/L from
0.066 pg/L to correct an error.
N. C. Division of Water Quality / NPDES Unit Phone: [phone]
1617 Mail Service Center, Raleigh, NC 27699-1617 fax: [phone]
Internet: h2o.enr.state.nc.us DENR Customer Service Center. 1 800 623-7748

Letter to Mr. Ashbrook. page 2.
If any parts, measurement frequencies or sampling requirements contained in
this permit are unacceptable to you, you have the right to an adjudicatory hearing
upon written request within thirty (30) days following receipt of this letter. This
request must be in the form of a written petition, conforming to Chapter 150B of the
North Carolina General Statutes, and filed with the Office of Administrative Hearings
(6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such
demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the
Division. The Division may require modification or revocation and reissuance of the
permit. This permit does not affect the legal requirements to obtain other permits
which may be required by the Division of Water Quality or permits required by the
Division of Land Resources, the Coastal Area Management Act or any other Federal
or Local governmental permit that may be required. If you have any questions
concerning this permit, please contact Sergei Chernikov at telephone number (919)
733-5083, extension 594.
Sincerely,
Coleen H. Sullins
cc: NPDES Files
Asheville Regional Office / Surface Water Protection
Aquatic Toxicology Unit
Mr. Roosevelt Childress, EPA Region IV
Environmental Sciences Section, Biological Assessment Unit
Mr. Jack Butler, Division of Waste Management, Superfund Section

Permit NC0000078
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations
promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution
Control Act, as amended,
Ecusta Business Development Center, LLC
is hereby authorized to discharge wastewater from a facility located at the
Mill in Pisgah Forest
Ecusta Road
Brevard
Transylvania County
to receiving waters designated as the French Broad River (outfall 001) and the Davidson River (outfalls 002
and 003). The receiving streams are class C waters in subbasin 04-03-01 of the French Broad River Basin.
All discharges shall be in accordance with effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective September 1, 2007.
This permit and authorization to discharge shall expire at midnight on August 31, 2012.
Signed this day August 13, 2007.
/44.j) d'41:°"J
fp- Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission

1
Permit NC0000078
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this
permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive
authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and
provisions included herein.
Ecusta Business Development Center, LLC, is hereby authorized to:
1. Continue the operation of an existing 27.5 MGD wastewater treatment facility (outfall 001) that
includes the following components:
• Grit chamber
• Bar screens
• Influent pumps
• Primary clarifiers
• Aerated stabilization basin
• Sludge dewatering
The facility is located off Ecusta Road south of U.S. Highway 64/276 in Pisgah Forest, Transylvania
County (see part III of this Permit), and
2. Discharge from said treatment works (outfall 001) at the location specified on the attached map into
the French Broad River which is classified "C" waters in the French Broad River Basin, and
3. Discharge stormwater (outfall 002 and 003) into the Davidson River which is classified "C" waters in
the French Broad River Basin.

Facility Information
Latitude: 35° 15' 03" Sub -Basin:
Longitude: 82° 41' 34"
Ouad #: F 8 SW (Pisgah Forest)
Stream Class: C
Receiving Stream: French Broad River/ Davidson River
Permitted Flow: 27.5 MGD
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P.H. Glatfelter Co.
NC0000078
TransylvaniaCounty

Permit NC0000078
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [13.0 MGD]
During the period beginning on September 1, 2007 and lasting until the Division grants written
authorization to increase the facility's flow limit, the Permittee is authorized to discharge from outfall 001.
Such discharges shall be limited and monitored by the Permittee as specified below:
PARAMETER
LIMITS
MONITORING REQUIREMENTS
Monthly .
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Locationl
Flow 6
13.0 MGD
Continuous
Recording
Influent or
Effluent
BOD, 5-day, 20°C
(April 1— October 31)
30.0 mg/L
45.0 mg/L
3/Week
Composite
Effluent
BOD, 5-day, 20°C
(November 1— March 31)
30.0 mg/L
45.0 mg/L
3/Week
Composite
• Effluent
Total Suspended Solids
30.0 mg/L
45.0 mg/L
3/Week
Composite
Effluent
NH3-N
Monthly
Composite
Effluent
Total Phosphorus (mg/L)
Quarterly
Composite
Effluent
Total Nitrogen (mg/L)
Quarterly
Composite
Effluent
Settleable Solids (mUL)
Monthly
Grab
Effluent
2,3,7,8 Tetrachloro-dibenzo-p-Dioxin2
0.104 pg/L
Semi -Annually
Composite
Effluent
Chronic Toxicity3
Quarterly
Grab
Effluent
Conductivity
Monthly
Grab
Effluent
Conductivity's
Variable
Grab
U &.D
Dissolved Oxygen
Daily average > 4.0 mg/L
Daily
Grab
Effluent
Dissolved Oxygen4
Variable
Grab
U & D
Temperature (°C)
Daily
Grab
Effluent
Temperature4 (°C)
Variable
Grab
U & D
pH
> 6.0 and < 9.0 standard units
Daily
Grab
Effluent
Total Mercury5
0.121 pg/L
Quarterly
Grab
Effluent
Notes:
1 • U: upstream of the outfall near river mile 192 at Barnett Bridge. D: downstream of the outfall
approximately 10.8 miles at river mile 180.8 at Etowah Bridge.
2. See condition A. (6).
3. Chronic Toxicity (Ceriodaphnia) P/F at 12%; January, April, July, October [see A. (5)].
4. Upstream and downstream monitoring shall be conducted weekly from April through June, three times
per week from July through October, and monthly from November through March.
5. Effluent samples must be analyzed by an EPA -approved (EPA-1631e) low level mercury analysis
method.
6. When the most recent 12-month flow average is 95% of the permitted flow (> 12.35 MGD), the
permittee may send a written request to the Division to operate under the 27.5 MGD permit effluent
page [see A. (2)].
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NC0000078
A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [27.5 MGD]
During the period beginning after written authorization by the Division to increase effluent flow and lasting
until expiration, the Permittee is authorized to discharge from outfall 001. Such discharges shall be limited
and monitored by the Permittee as specified below:
PARAMETER
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample
Locationl
Flow 6
27.5 MGD
Continuous
Recording
Influent or Effluent
BOD, 5-day, 20°C
(April 1— October 31)
30.0 mg/L
45.0 mg/L
3/Week
Composite
Effluent
BOD, 5-day, 20°C
(November 1— March 31)
30.0 mg/L
45.0 mg/L
3/Week
Composite
Effluent
Total Suspended Solids
30.0 mg/L
45.0 mg/L
3/Week
Composite
Effluent
NH3-N
Monthly
Composite
Effluent
Total Phosphorus (mg/L)
Quarterly
Composite
Effluent
Total Nitrogen (mg/L)
Quarterly
Composite
Effluent
Settleable Solids (mUL)
Monthly
Grab
Effluent
2,3,7,8 Tetrachloro-dibenzo-p-Dioxin2
0.065 pg/L
Semi -Annually
Composite
Effluent
Chronic Toxicity3
Quarterly
Grab
Effluent
Conductivity
Monthly
Grab
Effluent
Conductivity4
Variable
Grab
U & D
Dissolved Oxygen
Daily average > 4.0 mg/L
Daily
Grab
Effluent
Dissolved Oxygen4
Variable
Grab
U & D
Temperature (°C)
Daily
Grab
Effluent
Temperature4(°C)
Variable
Grab
U & D
pH
> 6.0 and < 9.0 standard units
Daily
Grab
Effluent
Total Mercury5
0.055 pg/L
Quarterly
Grab
Effluent
Notes:
1 • U: upstream of the outfall near river mile 192 at Barnett Bridge. D: downstream of the outfall
approximately 10.8 miles at river mile 180.8 at Etowah Bridge.
2. See condition A. (6).
3. Chronic Toxicity (Ceriodaphnia) P/F at 22%; January, April, July, October [see A. (5)].
4. Upstream and downstream monitoring shall be conducted weekly from April through June, three times
per week from July through October, and monthly from November through March.
5. Effluent samples must be analyzed by an EPA -approved (EPA-1631e) low level mercury analysis
method.
6. When the most recent 12-month flow average is 95% of the permitted flow 12.35 MGD), the
permittee may send a written request to the Division to operate under the 27.5 MGD permit effluent
page [see A. (2)].
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit NC0000078
A. (3) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on September 1, 2007 and lasting until expiration, the Permittee is authorized
to discharge from outfalls 002 and 003. Such discharges shall be limited and monitored by the Permittee as
specified below:
PARAMETER
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency .
Sample
Type
Sample
Location
Flow (MGD)
Semi -Annually
Estimate
Effluent
Temperature (°C) 1
Semi -Annually
Grab
Effluent
Total Residual Chlorine2
Semi-Anniially
Grab
Effluent
Total Mercury3
Quarterly
Grab
Effluent
pH
> 6.0 and < 9.0 standard units
Semi -Annually
Grab
Effluent
Notes:
1. The temperature of the effluent shall not cause an increase in the temperature of the receiving stream of
more than 2.8 °C and in no case cause the ambient water temperature to exceed 29.0 °C.
2. Total Residual Chlorine monitoring requirements only apply if chlorine is added to the cooling water.
3. Effluent samples must be analyzed by an EPA -approved (EPA-1631e) low level mercury analysis
method.
There shall be no chromium, zinc or copper added to the treatment system except as pre -approved
additives to biocidal compounds.
The permittee shall obtain approval from the Division's Aquatic Toxicology Unit prior to the use of any biocide (not
previously approved by the Division) in the effluent discharged under this permit. Approval for use of any biocide
not previously approved should be requested at least 90 days in advance of any planned usage.
Contact the Aquatic Toxicology Unit for detailed instructions on requesting approval of biocides:
NC DENR / DWQ / Aquatic Toxicology Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
There shall be no discharge of floating solids or visible foam in other than trace amounts.
A. (4) AMMONIA NITROGEN CONDITION
This permit may be modified, or revoked and reissued to include NH3-N limitations and monitoring
requirements in the event monitoring conducted on the effluent indicate that NH3-N concentrations are
greater than 4.0 mg/L.

Permit NC0000078
l
A. (5) CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality
to Ceriodaphnia dubia at an effluent concentration of 12% at 13.0 MGD or 22% at 27.5 MGD.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the
"North Carolina Cet odapbnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent
versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February
1998) or subsequent versions. The tests will be performed during the months of January, April, July, and
October. Effluent sampling for this testing shall be performed at the NPDES permitted final effluent
discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the
permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two
following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised -February 1998) or subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the
highest concentration having no detectable impairment of reproduction or survival and the lowest
concentration that does have a detectable impairment of reproduction or survival. The definition of
"detectable impairment," collection methods, exposure regimes, and further statistical methods are specified
in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998)
or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the months in which tests were performed, using the parameter code TGP3B
for the pass/fail results and THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to
be sent to the following address:
Attention: NC DENR / DWQ / Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the
permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility
name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the
comment area of the form. The report shall be submitted to the Environmental Sciences Section at the address cited
above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be
required during the following month. Should any test data from this monitoring requirement or tests performed by
the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be
re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid
test and will require immediate follow-up testing to be completed no later than the last day of the month following
the month of the initial monitoring.

Permit NC0000078
A. (6) DIOXIN MONITORING
Adequate sample volume shall be collected to perform the analysis. The total sample volume shall be
collected and preserved in accordance with Part II, Section C Monitoring and Records. The sample shall be
analyzed in accordance with the appropriate method of analysis specified in Analytical Procedures and
Quality Assurance for Multimedia Analysis of Polychlorinated Dibenzo-para-dioxins and Polychlorinated
Dibenzofurans by High Resolution Gas Chromatography/High Resolution Mass Spectrometry, EPA, 1987
(EPA Method 1613), or another equivalent analytical protocol. approved by DWQ. A single sample may be
analyzed to determine compliance with the daily maximum effluent limitation. Alternatively, a sample
volume may be collected to enable the sample to be split (duplicate analysis). If the analysis of either split
sample is below the detection limit, the quantity, for the purposes of compliance evaluation, is considered to
be zero. If both splits are positive, the results of the two analyses shall be averaged to determine compliance
with the daily maximum effluent limitation. If the measurement is below detection limits, the quantity for
the purposes of compliance evaluation is considered to be zero. The detection limit using these methods
for the purpose of compliance evaluation is considered to be 10 picograms per liter. The dioxin isomer to
be monitored and limited by this permit is 2, 3, 7, 8, TCDD.
Fish tissue analysis will be performed, as a minimum, at one station established upstream of the discharge
and at two stations downstream in accordance with the Division's approved monitoring plan. The
monitoring plan is an enforceable part of this permit. All dioxin data collected pursuant to this monitoring
requirement will be reported within three months after collection.
The Permittee shall perform fish tissue analyses for TCDD and TCDF tri-annually (once every 3 years). If
the data from annual fish tissue analysis indicates there are no dioxin concerns, an alternative schedule may
be granted.
A. (7) MERCURY FISH TISSUE SAMPLING
The Permittee shall conduct fish tissue sampling for Mercury on a tri-annual basis (once every 3 years). The
Division's Environmental Sciences Section shall approve the fish -tissue sampling plan prior to
commencement of sampling.
A. (8) CHANGE OF OWNERSHIP
a. Within sixty days after a change in ownership, the following shall be submitted to the
Division:
1. proof of the change in ownership;
2. a request to transfer the permit to the Purchaser of the facility;
3. a completed and signed EPA Form 1; and
4. a statement indicating whether any physical alterations or additions to the permitted facility are
planned which meet the notice requirements of Part II E.2 of this permit.
[If no changes are planned, the Division shall transfer the permit to the Purchaser as a minor
modification. If any physical alterations or additions to the permitted facility are planned which meet the
notice requirements of Part II E.2, the Purchaser shall provide the following additional information:]
5. A new application for the modified discharge, completed and submitted by the new owner of
the facility
6. A request for a major modification of permit NC0000078.
7. Fee payment for a major permit modification.
8. A complete flow justification for the proposed discharge and an Engineering Alternatives
Analysis (EAA).

Permit NC0000078
When all of the above actions are completed, the Division shall provide a modified permit appropriate for
the proposed discharge or set of discharges.
b. During the next permit renewal, the Permittee shall submit a complete flow justification for
the proposed discharge and an Engineering Alternatives Analysis (EAA).
A. (9) DAM INTEGRITY
The Permittee shall inspect the ASB darn annually. The permittee shall provide proper maintenance of the
ASB Dam to assure its integrity.

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC000078, Ecusta Business Development Center (EBDC)
(formerly Ecusta Division of Glatfelter Company)
Facility Information
Applicant/Facility Name:
EBDC
Applicant Address:
1 Ecusta Road, Brevard, NC 28712
Facility Address:
Same
Permitted Flow
001 - Industrial/Sanitary wastewater - 27.5 MGD
002 and 003 - Storm water
Type of Waste:
Industrial/ Sanitary
Facility/Permit Status:
Major Industry/ Renewal;
County:
Transylvania County
Miscellaneous
Receiving Stream:
French Broad River -
001, Davidson River
- 002 86 003
Regional
Office:
ARO
Stream Classification:
C
Quad
F8SW
303(d) Listed?:
No
Permit Writer:
Sergei Chernikov
Subbasin:
040301 (French
Broad Basin)
Date:
March 1, 2007
Drainage Area (mi2):
221
- .. 1
.,, 1
'i
Ye
Summer 7Q10 (cfs)
154
Winter 7Q10 (cfs)
189
Average Flow (cfs) :
740
IWC (%):
12%/22%
Primary SIC Code:
SUMMARY
Ecusta Business Development Center (EBDC) is a corporation that is currently
attempting to redevelop former RFS ECUSTA/ Glatfelter Paper Mil. The previous
NPDES permit expired on August 30, 2000. Prior to permit expiration, on March 2,
2000 Glatfelter filed an application for permit renewal. The permit was
administratively continued pending review of the renewal application. On August 9,
2001, RFS Ecusta purchased the mill from Glatfelter and requested a name change for
the NPDES permit. On October 23, 2002, RFS Ecusta filed its petition for bankruptcy.
EBDC purchased the mill on August 8, 2003, and applied to DENR for a change in
ownership on October 27, 2003. Due to inability of the company to provide financial
documentation that would demonstrate it's ability to operate the site, the processing
of the request was delayed. After consultation with NCDENR's General Counsel, the
Division issued the name/ownership name change on January 30, 2006.
After numerous meetings and communications with the facility owners and their legal
representative, the EBDC submitted a renewal application on August 18, 2006.
However, PPA data that was used in the renewal application was older than 3 years.
As a result, the facility had to conduct additional analyses. The PPA results were
submitted to DWQ in 2007.
After purchasing the mill from RFS Ecusta, the EBDC produced flax pulp: the
operation consisted of digesting flax straw, bleaching it and processing it as market
pulp. Wastewater from this process was discharged to the ASB (aerated stabilization
basin). Those operations ceased when they became uneconomic. The last pulping
occurred July 2005.
EBDC (Ecusta) NC0000078
NPDES Renewal
Page 1

Currently, the site is being redeveloped as a brownfield. Parts of the site have been
sold to Lowe's, a vet clinic, and Eckerd. There are several small tenants that use the
site for various purposes. The EBDC is in the process of salvaging the industrial
equipment. Some of the equipment is located below the water table in the basement
and sump pumps are operating constantly to avoid flooding. The EBDC is still
producing potable water for tenants, but the process water system is not operational.
This is an old industrial site and has several areas that have been contaminated with
mercury, sodium hydroxides and dioxins (see attached MEMO from NC Superfund
Section). Several options to treat/remove this contamination are being evaluated.
Most mercury contamination occurred from 1948 until 1973. During this period the
facility was owned and operated by Olin Corporation. The Olin Corporation generated
it's own chlorine and caustic using the mercury cell variation of the chlor-alkali
process.
The ASB has been sampled and elevated levels of mercury were found in the water
(0.35 ug/L, 0.36 ug/L and 0.53 ug/L) and in the sediment (1.5 mg/kg and 1.8
mg/kg).
The site contains an ash landfill (process sludge and fly ash), an island landfill
(process waste) and a sludge landfill (process sludge and fly ash). The landfills are
closed but leachate from these landfills is collected and treated in the ASB. Due to the
presence of dioxins and mercury in the landfills, there is a potential for transferring
these toxicants to the ASB. Landfills are owned by EBDC, but Glatfelter is
responsible for their maintenance, leachate collection, etc.
The permit requires triennial dioxin monitoring in fish, the last monitoring was
conducted in 2001. Currently, the EBDC is unable to conduct monitoring due to the
difficult financial situation. The monitoring requirement will remain in the permit.
In 2006, the Glatfelter has hired RMT corporation to collect and analyze fish tissue
and sediment samples from the Davidson and French Broad Rivers in the vicinity of
Pisgah Forest. DWQ/ESS biologists reviewed the study and concluded that elevated
level of mercury in fish is likely influenced by the discharge from the EBDC (see
attached) . Additional sampling is recommended.
Outfall 001
This outfall from the ASB contains filter plant backwash, groundwater infiltration,
sump pumps discharge, sanitary wastewater, and leachate from landfills.
Outfall 002 and 003
These outfalls contain stormwater. Investigation conducted by the DWM and EPA
found mercury contamination in the sediment contained in stormwater ditches.
TOXICITY TESTING:
Current Requirement:
Proposed Requirement:
Chronic P/F at 21% - January, April, July, October
Chronic P/F at 21% - January, April, July, October
The facility has consistently met Toxicity Test requirements during the last 5 years
with one exception. The subsequent test passed.
COMPLIANCE SUMMARY: BASED ON THE PREVIOUS 5 YEARS
The facility has a mixed compliance record. Most of the NOVs issued are related to
administrative issues such as late submission of test results, annual fee or DMR.
There was only one water quality violation during the previous permit term when the
facility failed a WET test
EBDC (Ecusta) NC0000078
NPDES Renewal
Page 2

The Compliance Evaluation Inspection conducted on 9/26/05 found that facility is in
compliance:
INSTREAM MONITORING:
EBDC is required to perform stream sampling for D.O., temperature and conductivity
with their current permit. Review of the instream monitoring data indicated that
facility doesn't have a significant negative effect on the water quality of the receiving
stream with regard to these parameters. This result is expected since production of
the pulp/paper has been discontinued, and the effective IWC is relatively low.
PROPOSED CHANGES:
• The daily maximum Hg limit has been added to the permit. Sampling
conducted by the Division of Waste Management (DWM) and EPA indicated
that concentration of Hg in the ASB significantly exceeds the water quality
standard.
• Fish tissue monitoring has been added to the Permit (Condition A. (7)) based on
the potential for effluent from the ASB to contaminate the fish in the receiving
stream. Recent biological study indicates very high Hg concentration in various
fish species in French Broad River.
• The daily maximum dioxin limit has been added to the permit. Leachate from
the landfills contains dioxin and there is a potential for contamination of the
receiving stream.
• The BOD and TSS limits have been converted to "concentration based limits".
Since production at the mill has been discontinued, concentration based limits
became more appropriate. The limit for BOD is water quality based, not effluent
based.
• Mercury monitoring was added to the Outfalls 002 and 003. Investigation
conducted by the DWM and EPA found mercury contamination in stormwater
ditches, which might result in violation of the water quality standard.
• Change of Ownership special condition was added to the permit.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: March 28, 2007 (est.)
Permit Scheduled to Issue: May 21, 2007 (est.)
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit,
please contact Sergei Chernikov at [phone] ext. 594.
EBDC (Ecusta) NC0000078
NPDES Renewal
Page 3

CHANGES IN THE FINAL PERMIT:
• New language for Special Condition A. (8) has been developed in response
to your request.
• A new effluent page for a tiered flow has been added to the permit in
response to your request.
• A new Special Condition regulating Dam Integrity was added to the
permit (See A. (9)).
• Monitoring frequency for Mercury has been reduced to Quarterly based
on the review of the additional monitoring data and as a response to your
request.
• Monitoring frequency for Dioxin has been reduced to Semi -Annually
based on the review of the additional monitoring data and as a response
to your request.
• The daily maximum limit for Mercury has been reduced to 0.055
pg/L from 0.057 pg/L to correct an error.
• The daily maximum limit for Dioxin has been reduced to 0.065
pg/L from 0.066 pg/L to correct an error.
EBDC (Ecusta) NC0000078
NPDES Renewal
Page 4

NC0000078
Ecusta
Hg
7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (ng/L)
UPS BACKGROUND LEVEL (UG/L)
IWC (%)
Allowable Conc. (ng/L)
154
27.5
42.625
12.0
0
21.68
55.35
For Minor domestic -type facilities:
Minimum of 2 mg/I (summer) NH3-N; 4 mg/I (winter) NH3-N
Dioxin
7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (pg/L)
UPS BACKGROUND LEVEL (MG/L)
IWC (%)
Allowable Concentration (pg/L)
Chlorine:
Residual chlorine must be capped at 28 ug/I to protect for acute toxicity effects
c
27.5
42
0.000
21.678
0.065
0

NC0000078
Ecusta
Hg
7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (ng/L)
UPS BACKGROUND LEVEL (UG/L)
IWC (%)
Allowable Conc. (nglL)
154
13
20.15
12.0
0
11.57
103.71
Dioxin
7Q10 (CFS)
DESIGN FLOW (MGD)
DESIGN FLOW (CFS)
STREAM STD (pg/L)
UPS BACKGROUND LEVEL (MG/L)
IWC (%)
Allowable Concentration (pglL)
For Minor domestic -type facilities:
Minimum of 2 mg/I (summer) NH3-N; 4 mg/I (winter) NH3-N
Chlorine:
Residual chlorine must be capped at 28 ug/I to protect for acute toxicity effects
154
13
20 5.
0.014
0.000
11.570
0.121

Ecusta Mill Site ESI Sample Results Summary
1234678-HpCDD
2378-TCDF
1234678-HpCDF
TEF (Toxicity
Equivalent Factor)
©
#
Key release samples shown in bold, with ampersand
ug/L = micrograms per liter
mg/kg = milligrams per kilogram
ng/kg = nanograms per kilogram
= Location with duplicate sample.
Lesser reported value shown.
2
g
12378-PeCDD
123678-HxCDD
123789-HxCDD
U
O
12378-PeCDF
V
O
Surface Water Samples:
ug1L
_
Davidson Upstream
EM001 SW
#
Davidson Downstream
EM002SW
Davidson by Outfall 3
EM003SW
Davidson below Outfall
EM004SW
On -site Ditch
EM005SW
Off -site Ditch
EM006SW
Davidson Downstream of Ditch
EM007SW
_
_
ASB Old Sludge Outfall
EM008SW
0.47
New Sludge Outfall
EM009SW
Sludge Landfill Pond
EM010SW
Thrash Branch Upstream
EM011 SW
T
Thrash Branch Downstream
EM012SW
_
4
A
ASB #1
EM013SW
0.53
ASB #2
EM014SW
0.35
.
Slurry Wall Drainage Discharge
EM015SW
French Broad Upstream
EM16SW
_
French Broad Downstream
EM017SW
,
@ v
ASB Outfall
EM018SW
0.36
Groundwater Samples:
uglL
Background
EM001 MW
@ #
TMW Loading Dock
EM003MW
9
SME MW#1
EM004MW
0.42
_
@
SME MW3#
EMOOSMW
0.29
EM006MW
Below Clarifiers
EM007MW
Caustic Well
EM008MW
r
H:IHZ\EcustalEcustaSAMPTABLE.x1s
1 of 3
3/6/2006

Ecusta Mill Site ESI Sample Results Summary
_
@
#
Key release samples shown in bold,
with ampersand
ug1L = micrograms per liter
mglkg = milligrams per kilogram
nglkg = nanograms per kilogram
= Location with duplicate sample.
Lesser reported value shown.
Mercury
12378-PeCDD
123678-HxCDD
123789-HxCDD
1234678-HpCDD
0
0
O
2378-TCDF
12378-PeCDF
1234678-HpCDF
u_
0
O
TEF (Toxicity
Equivalent Factor)
Soil Samples:
mglkg
nglkg
nglkg
nglkg
nglkg
nglkg
nglkg
nglkg
ng/kg
nglkg
ng/kg
Background
EM001 SS
0.17
29
310
0
0
0
0.3100
Background
EM001 SB
33
270
•
0.2700
#
Loading Dock
EM002SS
4.3
_
Loading Dock
EM002SB
0.54•
Loading Dock
EM003SS
69
Loading Dock
EM003SB
2.2
Loading Dock
EM004SS
31
Loading Dock
EM004SB
0.34
Railroad by Loading Dock
EM005SS
15
#
Railroad by Loading Dock
EM005SB
0.22
_
_
Old Ash Landfill
EM00SSB
_
0.33
0.0000
Sludge Landfill
_
600
1400
190
20.4000
Sludge Landfill
,EM007SB
EM008SB
0.85
100
60
1800
3300
720
75.3000
Old Sludge Landfill
EM009SB
60
1200
5.8
1.7800
Ash Landfill
EM010SB
0.18
0.0000
Ash Landfill
EM011 SB
0.17
Strauss Park
EM012SB
,
Strauss Park
EM013SB
_
Strauss Park
EM014SB
_
H:1HZ\EcustalEcustaSAMPTABLE.xls
2 of 3
3/6/2006

Ecusta Mill Site ESI Sample Results Summary
@
#
Key release samples shown in bold,
with ampersand
ug1L = micrograms per liter
mg/kg = milligrams per kilogram
nglkg = nanograms per kilogram
= Location with duplicate sample.
Lesser reported value shown.
Mercury
0
0
a
cb
123678-HxCDD -e
123789-HxCDD
c.,
1234678-HpCDD -
0
0
O
2378-TCDF
12378-PeCDF
1234678-HpCDF
u_
0
O
TEF (Toxicity
Equivalent Factor)
Sediment Samples:
mglkg
nglkg
nglkg
ng/kg
nglkg
nglkg
nglkg
nglkg
ng/kg
nglkg
nglkg
Davidson Background
EM001 SD
11
0.0110
Davidson Outfall #2
EM002SD
50
0.0500
Davidson Outfall #3
EM003SD
42
0.0420
Davidson Downstream of Outfall
EM004SD
47
0.0470
On -site Ditch
EM005SD
1.4
440
4400
4.4000
Off -site Ditch
EM006SD
0.3
140
1400
50
86
1.4860
@
Davidson Below Ditch
EMOOTSD28
25
230
•
0.2300
#
Process Area Ditch
EM008SD
0.0000
Process Area Ditch
EM010SD
10
0.0000
Latex Ditch
EM012SD
9.1
0.0000
ASB Old Sludge Outfall
EM013SD
0.84
280
200
4100
85
420
42.0850
ASB New Sludge Outfall
EM014SD
0.0000
#
Sludge Landfill Pond
EM015SD
0.0000
Thrash Branch Upstream
EM016SD
97
3000
3.0000,
0.9000
Thrash Branch Downstream
EM017SD
900
ASB #1
EM018SD
1.5
270J
700
0.7000
ASB #2
EM019SD
1.8
590
0.5900
Slurry Wall Drainage Discharge
EM020SD
0.0000
French Broad Upstream
EM021 SD
190
_
0.1900
French Broad Downstream
EM022SD
46
0.0460
@
ASB Outfall
EM023SD
40
420
0.4200
H:IHZIEcustalEcustaSAMPTABLE.xIs
3 of 3
3/6/2006

Ja�SgO Srgizezt
gt
o
2 0Q
$n qL PRO'*
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTAFEDERALCENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
MAY 0 3 2007
Sergei Chernikov, Ph.D
North Carolina Department of Environment and
Natural Resources
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
SUBJ: Draft NPDES Permit
Mill in Pisgah Forest
Permit No. NC0000078
Dear Dr. Chernikov:
In accordance with the EPA/NCDENR MOA, we have completed review of the draft
permit referenced above and have no comments. We request that we be afforded an additional
review opportunity only if significant changes are made to the draft permit prior to issuance or if
significant comments objecting to the draft permit are received. Otherwise, please send us one
copy of the final permit when issued.
Sincerely,
Marshall Hyatt, Environmental Scientist
Permits, Grants, and Technical Assistance Branch
Water Management Division
,;g - 7 2007
DENR - WA! ER QUALITY
ytJ i S W(CE
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)

3E
custa Business Development Center, LLC
April 27, 2007
VIA EMAIL and US Mail
Sergei Chernikov, Ph.D.
Environmental Engineer II
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699
[e-mail]
Re: Ecusta Business Development Center, LLC ("EBDC")
Draft NPDES Permit NC 0000078
Dear Dr. Chernikov:
One Ecusta Road
Brtvarc; NC28712
P.O. Box 1119
Pisgah Forest, NC 28768
Phone: [phone]
Far 828.884-9766
`U
I
r
SI�GVLEbi
1��\
! AY - 2007 (.._'
1
D��+R - WATER QUALITY
oirlgt Ru,ouCH
I am responding on behalf of EBDC with comments to the draft NPDES permit that EBDC
received on April 2, 2007. I had tried to call you to discuss the comments prior to submitting
them in writing, but I learned that you will be out of the office until early May. Certainly, please
feel free to call me with any questions you may have regarding these comments.
1. Addressee: We have informed DENR on numerous occasions that that addressee,
Clifford Bell, has not been an employee of Ecusta Business Development Center, LLC
since early 2004. Please address future correspondence to William Ashbrook.
2. Expiration Date: NPDES permits, like the 1995 permit, typically expire roughly five
years after issuance. It is unclear why the draft permit is set to expire three years after
issuance and we ask that the permit be set to expire in 2012.
3. Mass based Limits: It is unclear why discharge standards have been converted to
"concentration based limits." The existing permit issued in 1995 has mass based limits
for TSS and BOD. The flow through the ASB is presently highly variable due to the shut
down of the facility and is highly influenced by precipitation. Mass based limits are more
appropriate in light of these flow conditions and request that they be reinstated.
4. Average Monthly Flow: The 1995 permit currently in effect permits an average
monthly flow of 27.5 million gallons per day, as does the Supplement to Permit Cover
sheet. It appears that the monthly average flow of 27.0 million gallons per day found in
the chart at section A(1) and A(8) are typographical errors that should be corrected.

•
5. Mercury Limit: I am not sure that we have received the Division of Waste Management
and EPA data referenced in the first bullet of your March 28, 2007 letter, unless it is the
Expanded Site Investigation report dated May 12, 2005. If, as indicated in your letter,
concentrations of mercury in the surface water of the ASB presently exceed the water
quality standard, it appears that exceedance of the draft permit limitations for mercury are
inevitable. Given the potential variability of the flow and to avoid a potential exceedance
of concentration based limits from the initial implementation of the draft permit, to the
extent that a mercury limit is necessary, we request a mass based standard of 5.82 g/day
(maximum).
6. Mercury Fish Tissue Sampling: We are not aware of any biological study that
identifies very high mercury concentrations in fish taken from the French Broad and
therefore do not agree that a fish tissue study is an appropriate permit condition. You
may not be aware that PH Glatfelter is conducting a separate investigation and evaluation
of potential impacts to the French Broad and Davidson Rivers under EPA Region IV
jurisdiction. This investigation recently included whole fish sampling (i. e., bone, organ,
skin and tissue, as opposed to tissue only) as described in the December 2006 Sediment
and Fish Tissue Sampling Report prepared by PH Glatfelter Company. In light of the
previous and ongoing Glatfelter work, fish tissue sampling described in section A(7) is
unnecessarily duplicative and should not be a permit requirement.
7. Mercury Fish Tissue Sampling — Frequency: Permit condition A(7) refers to Progress
Energy. Also, please confirm our understanding that DENR's request is for fish tissue
sampling once every three years and not 3 times per year.
8. Dioxin Limit: Part V of the 1995 permit originally required sampling influent and
primary sludge from the wastewater treatment facility for dioxin. DENR dropped this
requirement administratively after a number of consecutive sampling events showed no
dioxin above the method detection limit of 10 pg/l. Recent dioxin data collected by
Renova from the Ash and Sludge Landfills leachate discharges indicate no dioxin above
the method detection limit of 3.1 pg/l. The fish tissue sampling study prepared by RFS
Ecusta in January 2002 indicated a TCDD level of less than 1.0 ppt and a TCDF level of
less than 1.05 ppt in all samples. There are no plant activities that would contribute
dioxin to the effluent. We are not aware of any information that would indicate dioxin
monitoring should be a permit requirement and request that condition A(6) be removed in
its entirety.
9. Dioxin Fish Tissue Sampling — Frequency: Fish tissue monitoring does not seem
necessary in light of past sampling that indicates that dioxin is not detectable in fish
tissue in French Broad river fish. To the extent fish tissue monitoring for dioxin becomes
an enforceable permit condition, please confirm that DENR's request is for fish tissue
sampling every three years and not 3 times per year.
10. Chronic Toxicity Effluent Concentration: The 21 % effluent concentration found in
the Chronic Toxicity Permit Limit at A(5) assumes an average monthly flow of 27.5
million gallons per day. Given the extreme variability of the flow (which is currently
averaging 3.7 million gallons per day as reported in the permit renewal application dated
August 16, 2006), tested effluent concentration should be allowed to vary in proportion to
the measured average monthly flow for the immediately preceding three month period.
11. Change in ownership: The standard change in ownership provision in Part II Section
E.4 is in conflict with the unusual special provision found at A(8). As you know, EBDC

is in the final stages of facility sale arrangements with Renova. Renova plans to make no
immediate changes to the continued operation of the ASB after purchase of the facility.
Over time, Renova's operations could involve use as a regional wastewater treatment
facility. Only if that use cannot be implemented does Renova anticipate a scaled down
facility designed to treat leachate from the Ash and Sludge Landfills. In either case, once
Renova's longer term plans for the facility become firm, at that time Renova would
submit a application for permit modification to reflect those plans. The provision at A(8)
requires a request for a major modification when in fact Renova has no current plans for a
major modification and such a request would be premature. In addition, please explain
what an Engineering Alternatives Analysis (EAA) and why that would be necessary. We
request that Section A(8) be deleted in light of the standard terms and conditions found at
Part II Section E.4 and the current plans of Renova.
12. ASB Closure: The process and standards for closure of the ASB should be included in
the permit. [consider whether this opens the door to financial assurance and
unnecessary skepticism; note standard condition Part III section E (Facility Closure
Requirements), which provides the department with authority to require "specific
measures" during deactivation]
Thank you for your attention to these comments. Please feel free to call me with any questions
you might have about them.
Sincerely,
William J. Ashbrook
Cc: Bernard M. Kelly
William W. Toole
Mike McMullen

mailbox:///q/Documents%20and%20Settings/sergei chernikov/Applic...
Subject: Re: comments on EBDC mill in Pisgah Forest, NC0000078
From: Sergei Chemikov <[e-mail]>
Date: Mon, 16 Apr 2007 13:59:15 -0400
To: Hyatt.Marshall®epamail.epa.gov
Marshall,
Thank you for comments! My responses are summarized below:
1) Contamination was only determined in the sediment sample not in the water sample.
Therefore, Hg limit was not added. I changed the fact sheet to make it clear that
contamination was detected only in the sediment.
2) a. I will include calculations in the fact sheet.
b. You are correct, I have used 7Q10 and IWC to establish the limits. You are also
correct about using the mean annual flow for dioxin. But at this point I would rather
live the existing limit in place. I don't think that there would be significant
quantities of the dioxin in the discharge based on my experience with other paper
mills. This is more of a pre -caution based on a very limited data set. The company
should have no problem meeting this limit.
3) Correction has been made.
4) Correction has been made. Now the footnote contains the following "Parameters
requiring daily sampling shall be sampled 5 out of every 7 days per week."
5) We do not have any evidence to suggest that there were violations of our
temperature standard in the past and discharge from these ditches occur very
infrequently.
6) I have spoken about this issue with Matt (he is former supervisor of WET Unit) and
other people in the unit who are familiar with this issue. Based on this
conversations I have concluded that we allow split samples. Some of the facilities do
it routinely. If the permittee provides appropriate QA/QC information, all the
information available can be used. We would prefer to retain the ability to do split
sampling for any parameter.
Sergei
Hyatt.Marshall®epamail.epa.gov wrote:
Sergei:
hope these are useful. feel free to call if you want to discuss
further. Marshall
1. Based on the fact sheet, NC and EPA have detected Hg contamination
in the stormwater ditches downstream from Outfalls 002 and 003. My
understanding is if Hg is detected in a zero background flow ditch, it's
there at a level that exceeds NC WQS. If so, doesn't that mean there is
reasonable potential for these discharges to have detectable levels of
Hg that exceed NC WQS and thus, limits are needed?
2. a. shouldn't
derive the the Hg
b. Based on
flows for both.
annual
the fact sheet show the calculations and flows used to
and dioxin limits?
the dioxin and Hg limits, I'm guessing you used 7Q10
However, since dioxin is a carcinogen, shouldn't mean
background flow be used instead to calculate the limit?
•
1 of 2 5/3/2007 9:14 AM

•
mailbox:///q/Documents%20and%20Settings/sergei chernikov/Applic...
3. In A.1, for BOD, the summer season should be Apr 1 - Oct 31.
4. In A.1, for DO, temp. and pH, why does the daily measurement
frequency cite footnote 2/condition A.6? They don't seem to be related
to dioxin to me.
5. In A.2, since only effluent temp is monitored, how do you assess
compliance with the temp delta max limit of 2.8 degrees C. w/o
upstream/downstream monitoring?
6. In A.6, I see language that describes how split samples for dioxin
would be assessed for compliance. The precedent of allowing split
samples is in the Blue Ridge permit, but that permit does not contain
the explicit assessment language contained here. Based on allowing a
split sample and the draft assessment language here, you have given the
permittee a strong incentive to do splits because it's that much harder
to show noncompliance with splits. I am not aware that NC allows
splits for WET or any other parameter.. Would you consider removing the
option to do splits here (and later in Blue Ridge)?
Sergei Chernikov, Ph.D.
Environmental Engineer
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
phone: [phone] ext. 594
fax: [phone]
2of2
5/3/2007 9:14 AM

imap://[e-mail]:993/...
Subject: comments on EBDC mill in Pisgah Forest, NC0000078
From: Hyatt.Marshall®epamail.epa.gov
Date: Fri, 13 Apr 2007 10:39:59 -0400
To: [e-mail]
CC: [e-mail], [e-mail]
Sergei:
hope these are useful. feel free to call if you want to discuss
further. Marshall
1. Based on the fact sheet, NC and EPA have detected Hg contamination
in the stormwater ditches downstream from Outfalls 002 and 003. My
understanding is if Hg is detected in a zero background flow ditch, it's
there at a level that exceeds NC WQS. If so, doesn't that mean there is
reasonable potential for these discharges to have detectable levels of
Hg that exceed NC WQS and thus, limits are needed?
2. a. shouldn't the fact sheet show the calculations and f lowp. used o4,14{
derive the the Hg and dioxin limits? , - w, Wgr,y, \'V`L-
b. Based on the dioxin and Hg limits,
flows for both. However, since dioxin is a
annual
background flow be used instead to
I'm guessing you used 7Q10
carcinogen, shouldn't mean
calculate the limit?
3. In A.1, for BOD, the summer season should be Apr 1 - Oct 31.
4. In A.1, for DO, temp. and pH, why does the daily measurement
frequency cite footnote12/condition A.6? They don't seem to be
to dioxin to me.
related
5. In A.2, since only effluent temp is monitored, how do you assess
compliance with the temp delta max limit of 2.8 degrees C. w/o
upstream/downstream monitoring?
6. In A.6, I see language that describes how split samples for dioxin
would be assessed for compliance. The precedent of allowing split
samples is in the Blue Ridge permit, but that permit does not contain
the explicit assessment language contained here. Based on allowing a
split sample and the draft assessment language here, you have given the
permittee a strong incentive to do splits because it's that much harder
to show noncompliance with splits. I am not aware that NC allows
splits for WET or any other parameter. Would you consider removing the
option to do splits here (and later in Blue Ridge)?
1 of 1 4/13/2007 12:01 PM

ASI�VLLL6 ASHEVILLE
cITEZEN
- TIMES
VOICE OF THE MOUNTAINS • CITIZEN-TIMES.com
14 O. Henry Avenue • P.O. Box 2090 • Asheville, NC 28802.828-252-5611 • FAX [phone]
Ar
•PUBLIC Nut it. K+
• STATE OF NORTH CAROLINA
r', ENVIRONMENT MANAGEMENT COMMiSSION/NPDES UNI
.:.1617MAIL sERVICE CENTER >: :.•,.�
RALEIGH, NC 27699-1617 • • • " •
NOTIFICATION OF INTENT TO ISSUE A NPDES f' ':••`•�
WASTEWATER PERMIT . ,
On. the basis of through staff review and application of NC General Statut
113.2, Public law 92-500 and other lawful standards and regulations, th
North Carolina Environmental Management Commission proposes to issu
a National Pollutant Discharge Elimination System (NPDES) wdstowate
discharge permit to the person(s). listed .below effective 4S days from th
publish date of this notice. �,-.a:, ,. • . - • 4.. •
•
Written comments regarding the proposed permit will be accepted until
days after the publish date of this notice. All comments received prior
that date are considered in the final 'determinations regarding•the ppropel...
holpermit. public' meeting ffoor the proposedClpermiVsshhou` heipivision dreecceivvede f.
significant degree of Public interest. t: - ,, : . :;h:, • •!.
Copleai of the draft permit and other supporting information ante used tc
determine conditions present In the draft permit are available upon rogue
and payment of the cost of reproduction. Mall. comments and/or request
for Informatlon'to'the NC Division of Water Quality at the above address o
call the Point Source Branch at .[phone], extension 363. Comments ca
also be entailed to Carolyn.Bryant@naraii. net.•Please Include the NPDE
Permit number (attached) in any communication.* Interested persons
also visit the Division of Water Quality at 512 N. Salisbury Street, Raleigh
NC 27604-1148 between the hours of 8:00 a.m. and. 5:00 p.m. to review nfor;
motion on file. .. • . ...... .' i
The Charles Binkelman residence has applied for renewal permit
NC0085454 for Its WWTP in Buncombe County. This.permitted facility dis-
charges treated wastewater o the Swannanoa River In the' French .Broa
River Basin. Currently BOD, ammonia nitrogen, fecal conform, .and tots
residual chlorine are water quality limited. .•
The John Pruett residence has applied for renewal' of permit NC0085464 .fo
•
Its WWTP in Buncombe County. This, permitted facility discharges treat
wastewater to the Swanson River in the French Broad River Basin. Cur
rently BOO, ammonia nitrogen, fecal ,colHorm,,,,and total residual .chlorin
are water quality limited. _ .. • . • .
The MaryWatling • residences hire - applied for renewal of permit NC008534
for Its WWTP In Buncombe County. This permitted facility discharge
treated wastewater o the Swannanoa River in the French Broad River Ba
sin. .Currently BOD, ammonia nitrogen, fecal conform, and total' residua
chlorine are water quality limited.. • w.. , , . - -
Ecusta Business Development Center, LLP P.O. Box. 1119, Pisgah Forest
NC rr2SS8768, Transylvania Coup , has applieccglfor renewal of its NPDES dis
MOutfal1�001) lano (numbereDavidson�River (0utfalls 002 and �)"In the Broad
Broad River Basin. This facility operates three outfalls, 001 (treated wast
water), 002 and 003 (stormwater). Currently 80D, TSS, dioxin, and mer
cury are water quality limited. This discharge may affect future allocatlo
In this portion of the French Broad River Basin. •
April 1, 2007 ,• s• _(3405)
AFFIDAVIT OF PUBLICATION
BUNCOMBE COUNTY
SS.
NORTH CAROLINA
Before the undersigned, a Notary Public of said
County and State, duly commissioned, qualified and
authorized by law to administer oaths, personally
appeared Jesica Gaskin, who, being first duly
swom, deposes and says: that she is the Legal
Billing Clerk of The Asheville Citizen -Times,
engaged in publication of a newspaper known as
The Asheville Citizen -Times, published, issued,
and entered as second class mail in the City of
Asheville, in said County and State; that she is
authorized to make this affidavit and sworn
statement; that the notice or other legal
advertisement, a true copy of which is attached
hereto, was published in The Asheville Citizen -
Times on the following dates: April 1st, 2007. And
that the said newspaper in which said notice, paper,
document or legal advertisement was published
was, at the time of each and every publication, a
newspaper meeting all of the requirements and
qualifications of Section 1-597 of the General
Statues of North Carolina and was a qualified
newspaper within the meaning of Section 1-597 of
the General Statues of North Carolina.
Signed this 2nd, day of April, 2007
(Signatyfd'of person making affidavit)
Sworn to and subscribed before me the 2nd, day of
April, 2007.
(Notary ublic)
My ommission expires the 3rd day of §ep
2008
MBE G�;�''

Shaw Environmental, Inc.
11560 Great Oaks Way
Suite 500
Alpharetta, GA 30022
770-475-8994
FAX: [phone]
ShaVir -. Shaw Environmental, Ina
March 19, 2007
Michael McMullen, Principal
Renova Partners, LLC
55 Hawthorne Street, Suite 555
San Francisco, CA 94105
Subject: Phase II Environmental Site Assessment, Ecusta Paper Mill, Pisgah Forest, North Carolina
Dear Mr. McMullen:
This letter is a summary report describing the Phase II Envi ronmental Site Assessment (ESA) performed at
the former Ecusta Paper Mill located at 1 Ecusta Road, Pisgah Forest, NC 28768 by Shaw Environmental,
Inc. (Shaw). Renova Partners LLC tasked Shaw with providing the additional assessment work to better
characterize the environmental health of the property. As part of the field investigation Shaw conducted the
following activities: installed twelve (12) groundwater monitoring wells in the shallow water -bearing zone,
installed two additional wells to deeper wat er-bearing zones, and installed on geotechnical soil boring.
Groundwater samples were collected from the 12 newly installed shallow wells and three (3) existing onsite
wells; soil samples were collected along the east and south drainage structures, from one of the monitoring
well soil borings, from the geotechnical boring, and from east of building 48. Effluent water samples were
also collected from the discharge from the ASB Ash Landfill and Sludge Landfill areas. The locations of the
newly installed wells and the existing wells, and the soil sample locations are shown in Figures 1 and 2. Site
monitoring wells were gauged and surveyed and a potentiometric surface map was developed and is included
as Figure 3.
Based on the groundwater samples collected during the Phase II ESA, there is little to no impact from volatile
organic compounds (VOC) in groundwater (Table 1). The only wells that showed any presence of VOC
constituents were MW-9 and MW-10. The VOC constituent detected at well location MW-9 was carbon
disulfide at 1.1 pg/L, which is significantly lower than its respective North Carolina 2L groundwater standard of
700 pg/L. At well location MW-10, carbon disulfide and 1,1-dichlorethene (DCE) were detected at
concentrations of 3.0 pg/L and 0.92 pg/L. The NC 2L standard for 1,1-DCE is 7 pg/L.
As for mercury, it was only detected at well locations MW-4 and MW-16s, and from the sludge landfill effluent.
The slud . e l - - - - - .064 • /I and the - = •
MW-4 was 0.008; both below the NC 2L standard of 1.05 pg1L. There is a strong correlation of high turbidity
leve'Irwlttr1 tse-positive detections orMerc ry in groundwater due to the non -dissolved fraction adsorbed to
particles suspended in the sample. Despite efforts to the contrary, turbidity in groundwater removed from
EautaletterRptO3192007.doe
SHA W ENVIRONMENTAL, INC.

Michael McMullen March 19, 2007
Page 2
MW-16s remained high during the collection of the sample. It is likely that the 2.2 pg/L concentration
detected in the MW16s groundwater sample is due to interference of suspended fine particles.
The groundwater results did show elevated levels of iron and/or manganese, independent of turbidity, above
their respective NC 2L standards at each well location. Iron and manganese occur naturally as minerals from
sediment and rocks. Elevated concentrations of iron and manganese are not uncommon in this region due to
the local geology and geochemistry.
As part of the groundwater investigation, pH readings were recorded for each well. The pH in 14 out of the 15
wells ranged from 5.37 to 7.41 (Table 3). An elevated pH reading was recorded at 12.17 at well location MW-
3, which is located near a caustic storage budding (Figure 4).
One soil sample was collected adjacent to Building 48 and analyzed for dioxins. Dioxin soil results are
summarized in Table 4.
In an effort to assess the mercury levels in soils adjacent to the east and south drainage structures, eleven
(11) soil borings were located every 300 feet on alternating sides along the length of the drainage structures.
One soil sample was collected from each boring at approximately 1-2 feet below the bottom of the drainage
structure. Based on the soil samples collected, mercury was detected in 2 out of the 11 sample locations
(Table 2). Mercury was detected in soil boring SB04 at 0.033 mg/kg and in SB05 at 0.025 mg/kg, which were
located on the east and west sides of the east drainage structure. The Inactive Hazardous Waste Sites
Branch soil remediation goal (SRG) standard for mercury is 4.6 mg/kg and the Region IX residential
preliminary remediation goal (PRG) standard for mercury is 23 mg/kg. The mercury action level for both SRG
and PRG are significantly higher than that found at sample locations SB04 and SB05. An additional soil
sample was collected from the soil boring advanced to install MW16s to evaluate the horizontal extent of
mercury contamination from the east drainage structure, and retumed a result of 0.058 mg/kg; and one was
collected from the geotechnical boring located south of Building 59 where 0.41 mg/kg was detected. Both of
these results are below the SRG and PRG also.
The well construction logs are included in Appendix A and the Level IV data package generated by GPL
Laboratories is provided in Appendix B.
If you have any question or comments concerning this report please contact me at [phone], or by
email at raymond.boydeshawgrp.com.
Sincerely,
SHAW ENVIRONMENTAL, INC.
Raymond Boyd, P.E.
Project Manager
EcustaI. tterRpt03192007.doc
Shaw Environmental, Inc.

Michael McMullen March 19, 2007
Page 3
Enclosure: Table 1, Table 2, Table 3, Table 4, Figure 1, Figure 2, Figure 3, and Figure 4.
EcustaLetterRpt93192007.doc
Shaw Environmental, Inc.

Table 1
Target Compounds
Field Parameters (Lamotte 2020)
'Turbidity
ICP Metals (SW-846 method 6010B
Detected Constituents in Groundwater
Ecusta Mill
Brevard, North Carolina
Sample ID
Laboratory Sample #
Sample Date
MW01
MWO2
MWO3
MWO4
MWO5
MWO6
701101-002
701101-003
701101-004
701101-005
701101-006
701101-007
1/17/2007
1/17/2007
1/17/2007
1/16/2007
1/17/2007
1/16/2007
NC 2L
Results
Results
Results
Results
Results
Results
I
NS
1
1.38 1 10.22 I 9.18 1 8.45 1 6.44
1
4.90 1
Aluminum
NS
62.3 J
2230
5760
797
495
351
Antimony
NS
<20
<20
<20
<20
<20
<20
Arsenic
50
<20
<20
6.0 J
<20
<20
<20
Barium
2000
17.2
45.6
13.5
41.1
53.5
81
Beryllium
NS
0.54 J
2.6
1.6 J
<2
<2
<2
Cadmium
1.75
<6
<6
<6
<6
<6
<6
Calcium
NS
21000
3700
2730
58000
11100
8860
Chromium
50
2.9 J
24
25.7
1.5 J
1.3 J
1.1 J
Cobalt
NS
<5
1.1 J
1.1 J
<5
<5
<5
Copper
1000
1.0 J
16.8
9.0 J
1.9 J
1.9 J
2.0 J
Iron
300
909
8740
2100
1400
3980
6180
Lead
15
1.9 J
8.9 J
6.4 J
2.0 J
2.2 J
1.8 J
Magnesium
NS
3480
734
165 J
4410
1380
2210
Manganese
50
48.7
98.5
4.3 J
99.5
89.2
144
Nickel
100
<10
2.3 J
7.7 J
<10
<10
<10
Potassium
NS
3020
2010
1330
3420
3100
1560
Selenium
50
<20
<20
<20
<20
<20
<20
Silver
17.5
<5
<5
<5
<5
<5
<5
Sodium
NS
36500
109000
366000
6050
6390
2860
Thallium
NS
<30
<30
<30
<30
<30
<30
Vanadium
NS
4.5 J
44.5
243
1.1 J
1.6 J
1.4 J
Zinc
1050
12.9 J
19.5 J
20.2
25.6
35.5
21.6 J 1
CV Metals (SW-846 method 7470A)
Mercury 1 1.05
Volatile Oroanic Compounds (SW-846 method 8260B
I
<0.2 1 <0.2 1 <0.2 1 0.08 J I <0.2 1 <0.2 1
Acetone
700
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
Carbon disulfide
700
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
Chloroform
70
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
1.1-Dichloroethene
7
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
All data reported in ug1L (micrograms per liter)
NA = not analyzed
NC 2L = Title 15A Classifications and Water Quality Standards
Applicable to The Groundwaters of North Carolina
NS = no NC 2L standard
D = analyte reported from dilution run
J = estimated concentration between QL and MDL
J1 = estimated concentration due to high DUP RPD
Analytical services provided by GPL Laboratories
Page 1 of 3

Table 1
Target Compounds
Field Parameters (Lamotte 2020)
'Turbidity
Detected Constituents in Groundwater
Ecusta Mill
Brevard, North Carolina
Sample ID
Laboratory Sample #
Sample Date
MWO7
MW08
MWO9
MW10
MW11
MW12
701101-008
701101-009
701101-010
701101-011
701101-012
703010-003
1/16/2007
1/16/2007
1/16/2007
1/16/2007
1/17/2007
2/26/2007
NC 2L
Results
Results
Results
Results
Results
Results
ICP Metals (SW-846 method 6010B
NS 1 5.24 I 4.02 I 1.28 I 4.30 I 4.94 I 11.3 I
Aluminum
NS
142 J
54.1 J
155 J
576
99 J
424
Antimony
NS
<20
<20
<20
<20
<20
<20
Arsenic
50
<20
2.6 J
<20
<20
<20
<20
Barium
2000
31.6
41.3
64.9
45.1
73.6
19.4
Beryllium
NS
<2
<2
<2
<2
<2
0.15 J
Cadmium
1.75
<6
<6
<6
<6
<6
<6
Calcium
NS
37000
22300
19200
18700
25000
13900
Chromium
50
<5
<5
1.8 J
<5
<5
<5
Cobalt
NS
0.93 J
1.7 J
1.4 J
1.6 J
<5
20.7
Copper
1000
2.3 J
1.8 J
3.0 J
2.4 J
2.8 J
<10
Iron
300
12200
12400
1160
469
3880
11000
Lead
15
2.8 J
2.1 J
1.8 J
2.0 J
1.4 J
3.1 J
Magnesium
NS
6140
3380
5500
3520
5970
4050
Manganese
50
2690
482
129
170
330
1770
Nickel
100
<10
<10
<10
<10
<10
<10
Potassium
NS
3730
1680
1310
3910
1880
1230
Selenium
50
<20
<20
<20
<20
<20
<20
Silver
17.5
<5
<5
<5
<5
<5
<5
Sodium
NS
10400
5560
1020 J
9090
7440
3870
Thallium
NS
<30
<30
<30
<30
<30
<30
Vanadium
NS
<10 _
<10
<10
1.1 J
<10
<10
Zinc
1050
14.4 J
21.5
89.9
12.4 J
17.3 J
30.5
CV Metals (SW-846 method 7470A)
Mercury l 1.05
Volatile Organic Compounds (SW-846 method 8260B
<0.2 I <0.2 I <0.2 I <0.2 I <0.2 I 0.026 J
Acetone
700
<5.0
<5.0
<5.0
<5.0
<5.0
<5.0
Carbon disulfide
700
<1.0
<1.0
1.1
3.0
<1.0
<1.0
Chloroform
70
<1.0
<1.0
<1.0
<1.0
<1.0
1.3
1,1-Dichloroethene
7
<1.0
<1.0
<1.0
0.92 J
<1.0
<1.0 ,
All data reported In ug/L (micrograms per liter)
NA = not analyzed
NC 2L = Title 15A Classifications and Water Quality Standards
Applicable to The Groundwaters of North Carolina
NS = no NC 2L standard
D = analyte reported from dilution run
J = estimated concentration between QL and MDL
J1 = estimated concentration due to high DUP RPD
Analytical services provided by GPL. Laboratories
Page 2 of 3

Table 1
Target Compounds
Field Parameters (Lamotte 2020)
Detected Constituents in Groundwater
Ecusta Mill
Brevard, North Carolina
Sample ID
Laboratory Sample #
Sample Date
MW13
MW14
MW15
MWI6SGW
ASH
SLUDGE
703010-004
703010-005
703010-006
703010-007
703010-009
703010-010
2/26/2007
2/26/2007
2/27/2007
2/28/2007
2/27/2007
2/27/2007
NC 2L
Results
Results
Results
Results
Results
Results
'Turbidity
ICP Metals (SW-846 method 6010B
NS
5.81 I 6.80 I 6.28 I 472 I NS
NS
1
Aluminum
NS
<200
58.4 J
56.8 J J1
225000
<200
149 J
Antimony
NS
<20
<20
<20
<20
<20
<20
Arsenic
50
<20
<20
<20
62.5
6.6 J
4.5 J
Barium
2000
57.5
84.5
36.1
550
80.3
223
Beryllium
NS
<2
<2
<2
7.6
<2
<2
Cadmium
1.75
<6
<6
<6
0.98 J
<6
<6
Calcium
NS
48200
20000
15100
37900
121000
113000
Chromium
50
<5
5.9
<5
336
<5
<5
Cobalt
NS
<5
<5
<5
31.1
3.0 J
20.1
Copper
1000
2.0 J
1.4 J
<10
132
1.5 J
1.5 J
Iron
300
387
4310
1870
180000
5880
17200
Lead
15
2.1 J
1.7J
2.8JJ1
91.8
1.8J
3.OJ
Magnesium
NS
4580
2650
3040
9330
23000
70400
Manganese
50
384
458
160
1640
2390
3910
Nickel
100
<10
<10
<10
67.1
3.9 J
<10
Potassium
NS
2150
1530
1840
19500
12800
12600
Selenium
50
<20
<20
<20
16.5 J
<20
<20
Silver
17.5
<5
<5
<5
<5
<5
<5
Sodium
NS
5320
14900
2840
928000 D
29000
29000
Thallium
NS
<30
<30
<30
<30
<30
<30
Vanadium
NS
<10
<10
<10
769
<10
<10
Zinc
1050
17.4 J
7.8 J
12.2 J
154
8.7 J
12.3 J
CV Metals (SW-846 method 7470A)
Mercury I 1.05
Volatile Oruanic Compounds (SW-846 method 8260B
I 0.033 J I 0.028 J I 0.025 J I 2.2 I <0.021 I 0.064 J I
Acetone
700
<5.0
<5.0
<5.0
NA
<5.0
7.8
Carbon disulfide
700
<1.0
<1.0
<1.0
NA
<1.0
<1.0
Chloroform
70
<1.0
<1.0
<1.0
NA
<1.0
<1.0
1,1-Dichloroethene
7
<1.0
<1.0
<1.0
NA
<1.0
<1.0
All data reported In uglL (micrograms per liter)
NA = not analyzed
NC 2L = Title 15A Classifications and Water Quality Standards
Applicable to The Groundwaters of North Carolina
NS = no NC 2L standard
D = analyte reported from dilution run
J = estimated concentration between QL and MDL
J1 = estimated concentration due to high DUP RPD
Analytical services provided by GPL Laboratories
Page 3 of 3

Target Compounds
CV Metals (SW-846 method 7471A)
!Mercury
Table 2
Summary of Mercury Detection in Subsurface Soils
Adjacent to the East and South Drainage Ditches
Ecusta Mill
Brevard, North Carolina
Sample ID
Laboratory Sample #
Sample Date
Sample Depth (in feet bgs)
SB01
SB02
SB03
SB04
SB05
701100-001
701100-002
701100-003
701100-004
701100-005
1/17/2007
1/17/2007
1/17/2007
1/17/2007
1/17/2007
10-11
12-13
12-13
13-14
13-14
PRG
23
SRG
Results
Results
Results
Results
Results _
4.6 I <0.041 I <0.037 I <0.04 I 0.033 J 10.025 J J 1
All data reported in mg/kg (milligrams per kilogram) dry -weight basis
bgs = below ground surface
SRG = North Carolina Inactive Hazardous Sites Branch Soil Remediation Goals
PRG = Region IX Preliminary Remediation Goal standard for residential soils
J = estimated concentration between QL and MDL
J1 = estimated concentration due to high DUP RPD
Analytical Services provided by GPL Laboratories
Page 1 of 3

Target Compounds
CV Metals (SW-846 method 7471A)
!Mercury
Table 2
Summary of Mercury Detection in Subsurface Soils
Adjacent to the East and South Drainage Ditches
Ecusta Mill
Brevard, North Carolina
Sample ID
Laboratory Sample #
Sample Date
Sample Depth (in feet bgs)
SB06
SB07
SB08
SB09
SB10
701100-006
701100-007
701100-008
701100-009
701100-010
1/17/2007
1/17/2007
1/17/2007
1/17/2007
1/17/2007
17-18
13-14
13-14
12-13
12-13
PRG
SRG
Results
Results
Results
Results
Results
23
4.6 j <0.04 I <0.042 I <0.044
All data reported in mg/kg (milligrams per kilogram) dry -weight basis
bgs = below ground surface
SRG = North Carolina Inactive Hazardous Sites Branch Soil Remediation Goals
PRG = Region IX Preliminary Remediation Goal standard for residential soils
J = estimated concentration between QL and MDL
J1 = estimated concentration due to high DUP RPD
Analytical Services provided by GPL Laboratories
<0.044 I <0.05
Page 2 of 3

Table 2
Summary of Mercury Detection in Subsurface Soils
Adjacent to the East and South Drainage Ditches
Ecusta Mill
Brevard, North Carolina
Target Compounds
CV Metals (SW-846 method 7471A)
Mercury
Sample ID
Laboratory Sample #
Sample Date
Sample Depth (in feet bgs)
SB11
B104
MW16S
701100-011
703010-001
703010-002
1/17/2007
2/20/2007
2/27/2007
12-13
3-4
1-2
PRG
SRG
Results
Results
Results
23
4.6 I <0.045 I 0.41 I 0.058
All data reported in mg/kg (milligrams per kilogram) dry -weight basis
bgs = below ground surface
SRG = North Carolina Inactive Hazardous Sites Branch Soil Remediation Goals
PRG = Region IX Preliminary Remediation Goal standard for residential soils
J = estimated concentration between QL and MDL
J1 = estimated concentration due to high DUP RPD
Analytical Services provided by GPL Laboratories
Page 3 of 3

Table 3
Groundwater pH Readings
Ecusta Paper Mill
Pisgah Forest, North Carolina
WeII ID pH
MW-1
6.67
MW-2
6.90
MW-3
12.17
MW-4
6.69
MW-5
6.00
MW-6
5.37
MW-7
6.33
MW-8
6.38
MW-9
5.86
MW-10
6.49
MW-11
5.82
MW-12
5.69
MW-13
6.51
MW-14
6.42
MW-15
6.35
MW-16s
7.41

Table 4
Dioxin/Furan Analytical Data
Ecusta Mill
Brevard, North Carolina
Sample ID
Laboratory Sample #
Sample Date
Dioxin/Furan Compounds TEF
Bldg 48 Soil
Boring
MW05
Ash Landfill
Leachate
Sludge Landfill
Leachate
H7C010209-002
H7C010209-001
H7C010209-003
H7C010209-004
2/27/2007
2/27/2007
2/27/2007
2/27/2007
pg/g
pg/I
pg/i
pg/I
2.3.7.8-TCDD
1.0
ND
ND
ND
ND
1,2,3,7,8-PeCDD
1.0
ND
ND
ND
ND
1.2,3,4.7,8-HxCDD
0.1
1.5 QJ
ND
ND
ND
1,2,3,8,7,8-HxCDD
0.1
6.9 SJ
ND
ND
ND
1,2,3,7,8,9-HxCDD
0.1
2.5 QJ
ND
ND
ND
1.2.3,4,6,7,8-HxCDD
0.01
99 QJS
ND
ND
ND
OCDD
0.0003
720 B
9.2
BJ
8.1
BJ
4.6
BJ
2.3,7,8,-TCDF
0.1
14 Q
ND
ND
ND
1,2,3,7,8-PeCDF
0.03
2.4 QJS
ND
ND
ND
2,3,4,7,8-PeCDF
0.3
5.6 QJ
ND
ND
ND
1,2,3,4,7,8-HxCDF
0.1
5.7 QJ
ND
ND
ND
1,2,3,6,7,8-HxCDF
0.1
6.7 J
ND
ND
ND
2.3,4.6,7,8-HxCDF
0.1
7 J
ND
ND
ND
1,2,3,7,8,9-HxCDF
0.1
ND
ND
ND
ND
1,2.3,4.6,7.8-HpCDF
0.01
25 J
ND
ND
ND
1,2,304,7,8,9-HpCDF
0.01
2.9 J
ND
ND
ND
OCDF
0.0003
34 BJ
2.6
BJ
ND
ND
Total TEF Concentration (ND treated as 0)
7.6772
0.00354
0.00243
0.00138
EPA Region 9 PRG - Residential Soils
3.9
EPA Region 9 PRG - Industrial Soils
16
TEF = Toxicity Equavelance Factor: The 2005 World Health Organization Re-evaluation of Human and Mammalian Toxic Equivalency Factors for Dioxins and Dioxin -like Compounds
B = Method Blank contamination. The associated method blank contains the target analyte at a reportable level.
J = estimated result. Result is less than reporting limit.
Q= Estimated maximum possible concentration (EMPC)
S= Ion suppression
Analytical services provided by STL Knoxville
Page 1 of 1

a=d
LEGEND:
MW-1 -+- PRE-EXISTING
MONITORING WELLS
MW-4 + PHASE II
MONITORING WELLS
MW-12+ ADDITIONAL PHASE II
MONITORING WELLS
-I z --
0 400 800
155221
APPROXIMATE SCALE IN FEET
MiN iYllI,AWM
SOURCE: ENVIRONMENTAL SVCS
LANDFILL / AS8
PARCEL
wf MAYw MIMI m WM.
CMr w�pA MMtY.MII
maxWw�±w1Ar Aye
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ACAD 123455—B1.dwq
SOIL SAMPLE
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123455
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1
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ALPHARETTA. GA 30022
[phone] (TEL)
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FLLE:
123455—B2.dwq
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February 19. 2007
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123455
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11560 GREAT OAKS WAY
SURE 500
ALPHARETTA, GA 30022
(770) 775-777-95455(FAX)
ACAD FILE:
123455—B1.dWq
GROUNDWATER
PH READINGS
CLIENT:
LOCATSON: CHECKED:
PISGAH FOREST KM
NORTH CAROLINA
DESIGNED:
JA
ECUSTA PAPER MILL
DETAILED:
TFR
PM:
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PROJECT NO.: FIGURE:
123455 4

� f !f
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•
Sh v," Shaw Environmental, Inc.
ASB and Clarifer Water
Samples
Ecusta Mill
Pisgah Forest, NC

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
January 19, 2007
Sergei Chernikov
Western NPDES Program
Division of Water Quality
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699 —1617
Sergei,
As the new coordinator of the fish tissue program, I have reviewed the December 2006 RMT Sediment
and Fish Tissue Sampling Report for the French Broad and Davidson Rivers. Based on the results in this
report, I believe that further monitoring efforts are warranted in the vicinity of the P.H. Glatfelter plant in
Ecusta. As the report states, the Largemouth Bass showing 1.97 mg/kg Hg at the ASB discharge is likely
being influenced by the size/age of the fish, and possibly by the whole body analysis (vs. fillet only).
Nonetheless, it would be good to collect more individuals of this species for confirmation of this elevated
Hg concentration. Generally, predator species Hg levels in the western part of the state do not exceed
0.6 mg/kg. Further analysis of a bottom feeder, such as carp, is also warranted because of the elevated
Hg concentrations in this species at the ASB discharge that were roughly three fold higher than at the
upstream and downstream French Broad sites.
As part of the 2005-2006 NC Mercury Study Extension (follow-up to the 2003-2004 Eastern Regional
Mercury Study), DWQ sampled the Davidson River at Sycamore Flats Recreation Area (approximately
2.5 river -miles upstream of the Davidson/French Broad Rivers confluence) for Hg in fish tissue. The
results of this study included elevated Hg levels in Rock Bass (0.56 mg/kg) and exceptionally high levels
in Golden Redhorse (1.6 mg/kg). Because of the close proximity of the DWQ site to the Ecusta plant, it is
possible that these fish are being influenced by the same source of Hg as those collected for P.H.
Glatfelter. We plan to revisit this site in the summer of 2007 to collect more tissue data, and would also
be able to coordinate follow-up monitoring efforts in the vicinity of the Ecusta plant during the same trip, if
requested.
Please contact me if you have any questions.
Jeff D Berardinis
Biologal Assessment Unit
[e-mail]
919-733-6946 x229
No�rthCarolina
Naturally
North Carolina Division of Water Quality 1621 Mail Service Center Raleigh, NC 27699-1621
Internet: h2o.enr.state.nc.us 4401 Reedy Creek Rd. Raleigh, NC 27607
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper
Phone [phone]
FAX [phone]

Section 3
Results and Observations
The Davidson River is a classic trout water, exhibiting a riffle and pool complex with cold, clear water
and a gravel, cobble and boulder substrate. The Davidson River ranges in depth along the sampled
stretch from approximately 1-foot deep, to pools of greater than 6-feet deep. Sediment and fish tissue
sampling on the Davidson River was performed by wading. In the sampled stretch, the French Broad
River is calmer in appearance than the Davidson River, with large flat stretches between short sections of
riffles. The depth of the French Broad was not measured, but required a boat for sampling. These rivers
are both relatively fast -flowing rivers, with the Davidson River being the faster of the two.
3.1 Sediment Results and Observations
Sediment deposits were limited in both rivers, but especially so in the Davidson River. Typical sediment
deposits in the Davidson River were very sandy and not more than a few inches deep along sandbars
and in eddies. Where deeper sediments were encountered, distinct layers of organic material and sandy
material were observed. It is suspected that these layers are reflective of annual deposition cycles with
leaf debris depositing in the fall and sandy geological erosion materials being deposited year-round.
Not more than three layers of organic -rich sediment were observed in any sediment core. It is believed
that both rivers are periodically scoured by heavy rains and seasonal flows, Which limit the sediment
record present.
Following sample collection, the coordinates of each sediment sample collection point and the upstream
and downstream extents for fish tissue sample collection were located by a registered land surveyor.
The exact coordinates for the sediment cores were presented previously in Table 1. This information was
overlaid on an aerial photograph (USGS March 15, 1998) of the site. Figure 1 in Appendix A depicts the
sediment sampling locations and the extents for fish tissue collection along each stretch of the two rivers.
Average mercury concentrations are summarized in Table 2 by location for surficial sediments, deep
sediments and the entire sediment profile. Individual sediment sample results are presented in
Appendix B, along with the laboratory analytical reports, field notes, and chain of custody forms.
These analytical results indicate that the mercury content of sediment samples from the Davidson and
French Broad Rivers are relatively low. The average mercury concentrations in sediments are below the
USEPA Region 4 Waste Management Division Sediment Screening Values for Hazardous Waste Sites
value of 0.13 mg/kg1. Only one individual sample, a shallow sediment sample collected in the French
1 USEPA. 2001. Supplemental Guidance to RAGS: Region 4 Bulletins, Ecological Risk Assessment. Table 3. Originally
published November 1995. Website version last updated November 30, 2001:
http://www.epa.gov/region4/wastelots/ecolbul.htm. Downloaded November 28, 2006.
5
!:1 WPGVL1PJT\00.727081021R00727Q802-OOI.DOC
December 2006

Broad River upstream from the confluence of the Davidson River, which was collected as being
representative of background concentrations, was greater than the screening value at 0.19 mg/kg. The
average mercury concentration for all of the shallow sediment samples collected at the upstream location
was 0.077 mg/kg dry weight.
Table 2
Average Mercury Concentrations in Davidson and French Broad Rivers
Pisgah Forest, North Carolina
-'4*''' ' ' ti
'S' a, 's= 1 rr
'�..� 'M
B SAMPLE ra0
t4�' M _
•'lit OCATION`
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{ ! Y
t �`2`"j s' �} $. ,'.
h t,l. S�
i.,, r" •c 1 -'c} G
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' s m 'TYPE °s + �+'`
.F ti r �j+° Y u.• . f,,c•,�'L
i f; ity 3 x
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t' VERAGE
t ,
fkMERCU]tY Z.
r r F r
%yy CONTENTa r
5..+•t,,tr' $,. -'_ '
mglkg
x
7 cart' wt )<
Y'f �`+ f,.
- ' } `
yy.r •'yG_%�
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a ,' �::
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"}
i ^a. -
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t rs
E
,� ry,
-f g y�
to .eta
Davidson River
Surficial Sediment
0.054
61,4
37,300
Deep Sediment
0.066
58.9
68,267
Entire Sediments Profile
0.060
60.2
52,783
French Broad River
-Upstream
Surficial Sediment
0.077
52.7
14,400
Deep Sediment
0.050
50.5
27,333
Entire Sediments Profile
0.063
51.6
20,867
French Broad River
- At ASB Discharge
Surficial Sediment
_ 0.019
72.5
6,777
Deep Sediment
0.012
72.7
1,680
Entire Sediments Profile
0.015
7216
4,228
French Broad River
- Downstream
Shallow Sediment
0.017
67.3
10,633
Deep Sediment
0.021
65.2
12,233
All Sediments
0.019
66.3
11,433
It was observed that the mercury content of the sediment samples correlated to the TOC content of the
samples, with relatively higher mercury concentrations correlated with increasing TOC. This result is
expected, considering that mercury preferentially adsorbs to organic materials.
3.2 Fish Tissue Results and Observations
The whole body fish tissue sample results are presented in Table 3. The highest concentrations were
observed in the fish caught in the vicinity of the discharge point of the ASB treatment system. Both the
predator (largemouth bass) and bottom feeder (carp) species had monomethylmercury concentrations
greater than the USEPA Ambient Water Quality Criterion for the protection of human health
concentration of 0.30 mg methylmercury/kg of fish tissue' The largemouth bass monomethylmercury
concentration was 1.85 mg/kg (wet weight), while the carp concentration was 0.339 mg/kg (wet weight).
2 USEPA. 2001. Water Quality Criterion for the Protection of Human Health: Methylmercury. EPA-823-R-01-001.
USEPA Office of Science and Technology, Office of Water. Washington, DC.
http://www.epa.gov/waterscience/criteria/methylmercury/document.html Downloaded November 28, 2006.
6
1: \ WPC VL\ PJT\ 00-71708 \011 R007170801-001.DOC
December 2006
dlsSI,I, ICSII aNV IN3N[Ia3$
V XiaNBddV

t should be noted that these concentrations are for whole body tissue samples, including organs, bone
rnd skin, which are not typically consumed by humans.
Table 3
Whole Body Fish Tissue Samples from the Davidson Carolina
and French Broad Rivers
Pisgah Forest, North
French Broad River
— At ASB Discharge
mg/k
and
In the fish caught at the ASB discharge site, the total mercury concentrations
ons weretions are comp g able to
0.609 mg/kg for the largemouth bass and carp, respectively. These
both statewide and regional mercury concentrations documented in the 1ite areg regional nationre
presented in Table 4. However, the majority of the information available
is based on fish tissue fillets, rather than whole body samples. While e than inions are
r difficult to
surveys in fillets are
predict, it is expected that mercury concentration which preferentially accumulate mercury at a higher
samples due to the inclusion of the internal g
rate than the muscle tissue of the fillet.
Mercury has a tendency to bioaccumulate and biomagnify in the d 22 inches and weighing 8 pounds.
e largemouth bass was an
unusually large single fish, not typical for this water body, measuring
Base
d on the size of the fish and the scars and damage visible on this fish, inA particularly on the
x e bottom of
the caudal fin, it was an old individual. A photograph of this fish is includedP
C.
nt
It was observed that the two trout species caught in the Davidson
on conver sidering significantly
troutwasbelieved
to be o concentrations. Thby ss observation t outfitters who lease property along the river for guided fishing
to be stocked in the river by sport fishing v
tours. The brook trout were believed to be native to the river, since the outfitters have no record of M
havingstocked brook trout. The brown trout was a single individual fish, of approximately 22 inches. r
The brook trout composite consisted of two individual fish, one of aA stocked trout4would be whicho c
is large for the species, and the other smaller, at approximately 8 inches.x 9
N
N
7 rn
December 2006 m
I:\WPGVL\PJT \00-71708 \ 01 \ R007170801-001.DOC
z o
m
11

expected to have a lower lifetime mercury exposure since is would be fed prepared, processed feedstock,
rather than feeding on lower-trophic organisms in the natural food web.
The mercury concentrations in bluegill and carp tissue samples from the French Broad River both
upstream and downstream of the ASB discharge are relatively similar and within the range of
concentrations observed in the national mercury survey data presented in Table 4. Based on the limited
number of samples, the results do not indicate a significant difference in mercury concentrations
between background and the downstream samples. There was no observed correlation between
mercury concentrations in the sediments and mercury concentrations in fish tissues.
Table 4
Summary of State-wide and Regional Mercury Measurements in Fish Tissue
.: • i...fY
wl, ;
A
,:i,
MEDAN.
x ,
_ OURCE }
- ,ir NOt
State-wide
Nat'l Hg Survey, NC
— LM Bass
0.020
3.600
0.532
0.390
1327
USEPA, 1990-
1995
Large mouth bass,
composite samples
Nat'l Hg Survey, NC
—Bluegill
0.020
0.780
0.186
0.160
304
USEPA, 1990-
1995
Bluegill sunfish, composite
samples
Regional
USGS, Santee River Basin
only
0.471
1.803
0.803
0.572
5
USGS Pilot
Study, 2001
Large mouth bass, fillets
USGS, South Florida Basin
only
0.37
4.22
1.35
0.74
6
USGS Pilot
Study, 2001
Large mouth bass, fillets
Soil Erosion Lake, GA
0.59
1.33
0.87
0.83
7
USGS, 1999
Large mouth bass, fillets
Gordon Lake, GA
0.08
0.53
0.23
0.22
8
USGS, 1999
Large mouth bass, fillets
Lower Leitner Lake, GA
0.54
0.95
0.74
0.72
10
USGS, 1999
Large mouth bass, fillets
8
I: \WPGVL\P/T\00-71708\01 \R007170801-001.DOC
December 2006

I have reviewed the permit application, which was submitted to me in August and found
several deficiencies:
1) Application has no estimate on leachate from landfill, it contains following statement
"flow from landfill depends on rain". It is not sufficient, we need maximum and average
flows.
2) We need to know when the mill has completely ceased operation. Application states
that since 2002 only pulping off flax has opcurrd lout has no information on when this
operation discontinued.I J
3) For the parameters that are believed to be present we need concentrations
on Form 2-
C, just a few examples: nitrates, fecal coliforms, oil and grease, phosphorus. It has to be
done for all outfalls.
4) Data submitted on Reporting Form A and additional chemical data are from 2000.
According to the EPA requirements we do not accept any data that is more than 3 years
old. The annual pollutant scan has to be repeated.
5) Permit requires triennial dioxin monitoring in fish tissue. The last sampling was
conducted in 2001. We need a new sampling to be conducted before the permit is
renewed. If the results of sampling are satisfactory this requirement is very likely to be
removed from the new permit.
When all deficiencies are remedied, please submit 3 copies of application that contains
new data to us.
r r
C. —1 i �,� let/
-___.) ),i . -\ , li J
`/

custa Business Development Center; LLC
One Ecusta Road
Breoard NC 28712
P.O. Box 1119
Pisgah Forest, NC28768
Phone:[phone]
Fax [phone]
Express Mail
August 17, 2006
Sergei Chernikov, Ph.D.
Environmental Engineer
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Doctor Chernikov:
Enclosed please find Ecusta Business Development Center's LLC Permit Modification
for the ASB at the former Ecusta Site which I am mailing to you on behalf of Bill
Ashbrook.
Sincerely
Ecusta Business Development Center
Bernard M. Kelly
Chief Financial Officer

yard
thletic
jeld
DISCHARGE
BASE MAP ADAPTED FROM USGS 7.5 MIN QUADS
PISGAH FOREST, NC — 1978
BREVARD, NC —SC — 1991
1000 0
2000
der
rn
0
POINT 003
BM J 56 •
ter idtrahon
Plant.
�Pumpin��
% •' .170 -Pisgah Pores';;"'• :.1. stationit
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rch I "ram•(
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1 Hosp'tett p0
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SOCONDAN! MITE 111EA11111111 MUM .
•=TA PIM DOWN
OLIN CATION
I: out j roe 1 mot T......,:eicaas.acas6. 31

1
4
p.e
1
u
•
•
LC •
•
•
.. ♦

9.0
8.5
8.0
7.5
7.0
Data Over Time
5/1 5122 6/12 7/3 7/24 8/14 9/4 9/25 10/16 11/6 11/27 12/18 1/8 1/29 2/19 3/12 4/2 4/23 5114
Date (5/1 /2005 to 5/1 /2006 )
/ 6 ASB Effluent pH
OPS 32

18
13
3
Data Over Time
5/1 5/22 6/12 7/3 7/24 8/14 9/4 9/25 10/16 11/6 11/27 12/18 1/8 1/29 2/19 3/12 4/2 4/23 5/14
Date (5/1/2005 to 5/1/2006)
/ 7 ASB Dissolved Oxygen
OPS 32
WWTP

uMHOS/cm
450
400
350
300
250
200
Data Over Time
5/1 5/22 6/12 7/3 7/24 8/14 9/4 9/25 10/16 11 /6 11/27 12/18 1/8 1/29 2/19 3/12 412 4/23 5/14
Date (5/1 /2005 to 5/1 /2006 )
/ 15 ASB Conductivity
OPS 32
WWTP

Flow MGD Temp Deg C BOD Lbs/day
Outfall # Avg Max Min Avg Max Min Avg Max Min
001 2006 Mar 0 0 0 11.3 14.5 8. • 0 0 0
001 2006 Feb 0.3 3.1 0 7.7 7.7 7.7 92 92 92
001 2006 Jan 0 1 0 6.6 7 6.3 40 52 27
001 2006 Dec 0.2 1.2 0 7.1 9.8 5.3 16 41 0
001 2006 Nov 0.1 1.5 0 11.2 14.8 9.5 37 39 35
001 2005 Oct 0.1 1.6 0 22.1 22.6 21.8 0 0 0
001 2005 Sep 2.9 5.5 0 24.2 25.3 23.4 85 210 27
001 2005 Aug 4.4 8 2.9 26.1 27 25 158 387 80
001 2005 Jul 5.2 9.9 3.3 26.4 28.3 24.6 167 242 68
001 2005 Jun 5.6 9.5 2.7 23.4 25.2 19.5 224 544 97
001 2005 May 5 7.3 3.8 19.6 22.7 16.1 333 111
001 2005 Apr 4.9 7.5 2.6 16 18.3 13.5 299 5 150
001 2005 Mar 5.5 3.8 10.4 14.2 7.6 342 007 112
001 2005 Feb 5.5 11. 2.1 6.9 9.8 4.5 331 192
001 2005 Jan 4.2 6.9 2.6 6.9 10.8 3.8 122 246 51
001 2004 Dec 4.9 8.2 3.3 7.6 11 4.1 171 383 58
001 2004 Nov 4.4 7.4 2.7 14.6 19.5 11 139 208 96
001 2004 Oct 3.9 6.3 2.4 19.3 21.1 17.5 108 178 76
001 2004 Sep 6.6 17 2.3 22.1 25.1 20 131 284 44
001 2004 Aug 5.1 8.2 3.5 24.9 26.7 23.7 186 897 68
001 2004 Jul 6.6 11.3 5.1 26.1 26.8 24 371 857 161
001 2004 Jun 5.9 9 2.6 24.9 27.4 23.6 197 324 64
001 2004 May 4.4 7.7 2.4 21.7 25 17.4 112 257 43
001 2004 Apr 3.3 8.3 2.2 15.4 20.3 12.1 101 255 41
i
TSS Lbs/day N h3 mg/I
Avg Max Min
0 0 0 0.94
334 334 334 1
79 110 48 0.1
41 111 0 0.1
33 82 18 0.34
50 150 0 0.1
166 291 59 0.3
215 644 83 0.19
434 752 133 0.52
488 999 220 0.32
345 760 135 0.41
293 468 103 0.43
337 674 139 1.1
258 436 52 1.7
130 255 49 0.81
150 421 60 0.81
242 677 78
257 383 159 0.07
449 3696 116 0.17 Storm
198 340 76 0.42
406 802 218 0.43
333 6.9 55 0.22
226 516 53 0.1
96 196 40 0.11
001 Average 3.7 7.0 2.1 16.8 19.2 14.6 156.8 343.9 70.5 231.7 546.0 92.8 0.46
pH
002 2005 Nov 0.28 14.6 6.8
002 2005 Mar 0.59 9.4 7.4
002 2004 Nov 0.42 9.2 8.2
002 2004 Feb 0.59 6.8 7.1
002 Avg 0.47 10 7.38
003 2005 Nov 0.417 8.9 6.6
003 2005 Mar 0.197 9.1 7.1
003 2004 Nov 0.197 9.7 7.2
003 2004 Feb 0.338 7.1 6.9
003 Avg 0.287 8.7 6.95

ch44JE 002

Flow MGD TempDeg C BOD Lbs/day TSSLbs/day Nh3mg/I
Outfall # Avg Max Min AvgMax Min Avg Max Min AvgMax Min
001 2006 Mar 0 0 0 11.3 14.5 8.6 0 0 0 0 0 0 0.94
001 2006 Feb 0.3 3.1 0 7.7 7.7 7.7 92 92 92 334 334 334 1
001 2006 Jan 0 1 0 6.6 7 6.3 40 52 27 79 110 48 0.1
001 2006 Dec 0.2 1.2 0 7.1 9.8 5.3 16 41 0 41 111 0 0.1
001 2006 Nov 0.1 1.5 0 11.2 14.8 9.5 37 39 35 33 82 18 0.34
001 2005 Oct 0.1 1.6 0 22.1 22.6 21.8 0 0 0 50 150 0 0.1
001 2005 Sep 2.9 5.5 0 24.2 25.3 23.4 85 210 27 166 291 59 0.3
001 2005 Aug 4.4 8 2.9 26.1 27 25 158 387 80 215 644 83 0.19
001 2005 Jul 5.2 9.9 3.3 26.4 28.3 24.6 167 242 68 434 752 133 0.52
001 2005 Jun 5.6 9.5 2.7 23.4 25.2 19.5 224 544 97 488 999 220 0.32
001 2005 May 5 7.3 3.8 19.6 22.7 16.1 333 652 111 345 760 135 0.41
001 2005 Apr 4.9 7.5 2.6 16 18.3 13.5 299 586 150 293 468 103 0.43
001 2005 Mar 5.5 9.3 3.8 10.4 14.2 7.6 342 1007 112 337 674 139 1.1
001 2005 Feb 5.5 11.1 2.1 6.9 9.8 4.5 331 512 192 258 436 52 1.7
001 2005 Jan 4.2 6.9 2.6 6.9 10.8 3.8 122 246 51 130 255 49 0.81
001 2004 Dec 4.9 8.2 3.3 7.6 11 4.1 171 383 58 150 421 60 0.81
001 2004 Nov 4.4 7.4 2.7 14.6 19.5 11 139 208 96 242 677 78
001 2004 Oct 3.9 6.3 2.4 19.3 21.1 17.5 108 178 76 257 383 159 0.07
001 2004 Sep 6.6 17 2.3 22.1 25.1 20 131 284 44 449 3696 116 0.17 Storm
001 2004 Aug 5.1 8.2 3.5 24.9 26.7 23.7 186 897 68 198 340 76 0.42
001 2004 Jul 6.6 11.3 5.1 26.1 26.8 24 371 857 161 406 802 218 0.43
001 2004 Jun 5.9 9 2.6 24.9 27.4 23.6 197 324 64 333 6.9 55 0.22
001 2004 May 4.4 7.7 2.4 21.7 25 17.4 112 257 43 226 516 53 0.1
001 2004 Apr 3.3 8.3 2.2 15.4 20.3 12.1 101 255 41 96 196 40 0.11
001 Average 3.7 7.0 2.1 16.8 19.2 14.6 156.8 343.9 70.5 231.7 546.0 92.8 0.46
pH
002 2005 Nov 0.28 14.6 6.8
002 2005 Mar 0.59 9.4 7.4
002 2004 Nov 0.42 9.2 8.2
002 2004 Feb 0.59 6.8 7.1
002 Avg 0.47 10 7.38
003 2005 Nov 0.417 8.9 6.6
003 2005 Mar 0.197 9.1 7.1
003 2004 Nov 0.197 9.7 7.2
003 2004 Feb 0.338 7.1 6.9
003 Avg 0.287 8.7 6.95

MGD -- Deg C -- SU
30
25
20
15
10
0
Co)
O_
N
Data Over Time
0 .
N to r-
N T T
1- O) T
T
0 0 0 0 a 0 0 0 0
_M 00 M 0_0 M 0o0 N_ 0 IIt)
CO two 00 O C N M
Date (5/1/2003 to 5/1/2006 )
/ 43 V-notch Weir 002 / 44 V-notch Weir 002 / 45 V-notch Weir 002
Flow Temp pH
OPS 32
WWTP

----D -
,SC

Flow MGD TempDeg C BOD Lbs/day TSSLbs/day Nh3mg/I
Outfall # Avg Max Min AvgMax Min Avg Max Min Avg Max Min
001 2006 Mar 0 0 0 11.3 14.5 8.6 0 0 0 0 0 0 0.94
001 2006 Feb 0.3 3.1 0 7.7 7.7 7.7 92 92 92 334 334 334 1
001 2006 Jan 0 1 0 6.6 7 6.3 40 52 27 79 110 48 0.1
001 2006 Dec 0.2 1.2 0 7.1 9.8 5.3 16 41 0 41 111 0 0.1
001 2006 Nov 0.1 1.5 0 11.2 14.8 9.5 37 39 35 33 82 18 0.34
001 2005 Oct 0.1 1.6 0 22.1 22.6 21.8 0 0 0 50 150 0 0.1
001 2005 Sep 2.9 5.5 0 24.2 25.3 23.4 85 210 27 166 291 59 0.3
001 2005 Aug 4.4 8 2.9 26.1 27 25 158 387 80 215 644 83 0.19
001 2005 Jul 5.2 9.9 3.3 26.4 28.3 24.6 167 242 68 434 752 133 0.52
001 2005 Jun 5.6 9.5 2.7 23.4 25.2 19.5 224 544 97 488 999 220 0.32
001 2005 May 5 7.3 3.8 19.6 22.7 16.1 333 652 111 345 760 135 0.41
001 2005 Apr 4.9 7.5 2.6 16 18.3 13.5 299 586 150 293 468 103 0.43
001 2005 Mar 5.5 9.3 3.8 10.4 14.2 7.6 342 1007 112 337 674 139 1.1
001 2005 Feb 5.5 11.1 2.1 6.9 9.8 4.5 331 512 192 258 436 52 1.7
001 2005 Jan 4.2 6.9 2.6 6.9 10.8 3.8 122 246 51 130 255 49 0.81
001 2004 Dec 4.9 8.2 3.3 7.6 11 4.1 171 383 58 150 421 60 0.81
001 2004 Nov 4.4 7.4 2.7 14.6 19.5 11 139 208 96 242 677 78
001 2004 Oct 3.9 6.3 2.4 19.3 21.1 17.5 108 178 76 257 383 159 0.07
001 2004 Sep 6.6 17 2.3 22.1 25.1 20 131 284 44 449 3696 116 0.17 Storm
001 2004 Aug 5.1 8.2 3.5 24.9 26.7 23.7 186 897 68 198 340 76 0.42
001 2004 Jul 6.6 11.3 5.1 26.1 26.8 24 371 857 161 406 802 218 0.43
001 2004 Jun 5.9 9 2.6 24.9 27.4 23.6 197 324 64 333 6.9 55 0.22
001 2004 May 4.4 7.7 2.4 21.7 25 17.4 112 257 43 226 516 53 0.1
001 2004 Apr 3.3 8.3 2.2 15.4 20.3 12.1 101 255 41 96 196 40 0.11
001 Average 3.7 7.0 2.1 16.8 19.2 14.6 156.8 343.9 70.5 231.7 546.0 92.8 0.46
pH
002 2005 Nov 0.28 14.6 6.8
002 2005 Mar 0.59 9.4 7.4
002 2004 Nov 0.42 9.2 8.2
002 2004 Feb 0.59 6.8 7.1
002 Avg 0.47 10 7.38
0Q3 2005 Nov 0.417 8.9 6.6
003 2005 Mar 0.197 9.1 7.1
003 2004 Nov 0.197 9.7 7.2
003 2004 Feb 0.338 7.1 6.9
0Q3 Avg 0.287 8.7 6.95

MGD -- Deg C -- SU
30
25
20
15
10
0 Iltllll
Data Over Time
CO 0 0
•� �O.
r Cr
N N
0 0 0
ET2 r
N
O 0
CO r Cfl
N r •-
-— r
- Qi r
r
O 0
1 �
O
Date (5/1 /2003 to 5/1 /2006 )
/ 47 Parshall Flume / 48 Parshall Flume / 49 Parshall Flume
003 Flow 003 Temp D03 pH
IIIIIIIIIIIIIIIIIlII
0 CO 0 CO 0
M C.. N
N M N
r
r
OPS 32

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Cri t r2rt St-za-r7 0 * .50o a C-r- r7 e� 3 4-bv63, 666 Are71
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[Fwd: J .e: Ecusta Business Development Center]
Subject: [Fwd: Re: Ecusta Business Development Center]
From: Coleen Sullins <[e-mail]>
Date: Mon, 19 Dec 2005 17:10:09 -0500
To: Paul Rawls <[e-mail]>, [e-mail], Dave Goodrich
<[e-mail]>
fyi
Subject: Re: Ecusta Business Development Center
From: Roger Edwards <[e-mail]>
Date: Mon, 19 Dec 2005 15:03:15 -0500
To: Roger Edwards <[e-mail]>
CC: Harry Zinn <[e-mail]>, Mary Penny Thompson <[e-mail]>,
JESSE WELLS <[e-mail]>, Rick Shiver <[e-mail]>, Alan Klimek
<[e-mail]>, Coleen Sullins <[e-mail]>, Larry Frost
<[e-mail]>, Keith Haynes <[e-mail]>
Staff of ARO visited EDBC this morning and found no immediate danger to the
environment. All black liquor is tanked with confinement for tank volume. Mr.
Ashbrook told DWQ inspectors there is no hazardous waste on site. If electrical
power is cut off an over flow of low strength, BOD & TSS, waste would be discharged
from the pump station. There is a diesel pump located at the pump station however
the fuel tank is empty. I understand a meeting is scheduled for December 27, 2005 to
determine a responsible party for the electrical power supply.
If any additional information is needed, feel free to contact ARO
R. Edwards
Roger Edwards wrote:
Mr. Zinn,
I spoke with Mr. Ashbrook on Friday, December 15, 2005, regarding electrical
reliability for NPDES permit systems at EDBC site. Mr. Ashbrook indicated to me
P.H.Glatfelter is paying the electrical bill at this time and is expected to
continue. If electrical power is shut off an overflow will occur. The flow is
250,000 gallons per day with the manufacturing facility not in production. The
clarifies are the lowest point in the treatment system and would be the point of
overflow.
Two staff member will visit EDBC this morning to evaluate the situation. I will
e-mail an up -date as soon as possible.
R. Edwards
Harry Zinn wrote:
I do not know which of your Sections are currently overseeing the NPDES permit
for the Aeration Sedimentation Basin at the Ecusta site, Pisgah Forest,
Transylvania County. However, I wanted to let you know that during recent
discussions with P.H. Glatfelter on other issues at this site, it was brought
to our attention that EBDC is close to having the power shut off by Duke
Power. We are currently in discussions with EPA, Duke Power, Glatfelter and
DWM on how to avoid a prolonged outage at the site which could jepordize the
environmental systems currently in operation there. The attached is the issues
that we have identified which would require immediate attention. If you have
1 of 2 12/27/2005 3:42 PM

[Fwd: Re: Ecusta Business Development Center]
any further concerns that you feel we need to address, you can contact EBDC or
myself.
Thank you for your help in this matter.
Harry Zinn Environmental Engineer
NC DENR Superfund
401 Oberlin Rd. Suite 150
Raleigh, NC 27605
[phone] phone
[phone] fax
Roger Edwards - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
2090 U.S. 70 Highway
Swannanoa, NC 28778
Tel: [phone]
Fax: [phone]
Roger Edwards <Roger.EdwardsRncmail.net>
NC DENR - Asheville Regional Office
Division of Water Quality - Water Quality Section
Re: Ecusta Business Development CenterContent-Type: message/rfc822
Content -Encoding: 7bit
2 of 2 12/27/2005 3:42 PM

Memorandum
Date: October 5, 2005
To: James Bateson
Site Evaluation and Removal Branch Head
NC Superfund Section
From:
Harry Zinn
Environmental Engineer
NC Superfund Section
Subject: Concerns at the Ecusta Mill Site
Pisgah Forest, Transylvania County, NC
EPA ID: NCD 033 166 675
Below are listed the areas of concern (ADCs) that remain at the Ecusta site and possible actions
to address these concerns. Applicable benchmarks are shown in italics:
1. Electro-Chemical Building
Concerns: Mercury contamination documented in the groundwater and via the
overland flow pathway to and in the Davidson River.
Remedy:
a. Remedy for source area under EC Building for ongoing groundwater release,
remedy for air release into building, remedy floor drains and drainage flume under
loading dock to eliminate ongoing release into process area ditch.
b. Remedy sediments in process ditch.
c. Fully investigate sediments in Davidson for mercury contamination.
d. Screening level ecological risk assessment for surface water pathway.
Air Sampled inside Building at benchmark levels
Soil SRG 4.6 mg/kg mercury Loading Dock (4.3, 69, 31)
Groundwater 2L 1lug/1 mercury
Sediments no benchmarks
Temp MW at Loading Dock 9 ug/1
Process Area Ditches (14 and 10 mg/kg)
S&ME MW 1 0.42
S&ME MW3 0.29
Process Area Ditches (14 and 10 mg/kg)
Latex Spill Ditch (9.1)
On-site/Off-site ditches (1.4, 0.3)
Davidson Release EM007SD (0.287)
C:\DOCUME-1\SERGEI-1.000\LOCALS-'1\TEMP\EcustaConcernsRev4.doc Page 1

2. Sludge Landfills
New: Process sludge
DWQ Permit
Old: Process sludge and 20,000 cu.yd. flyash
NCD 980 502 827 ("Brow n #1")
CERCLA: NFRAP 1988 State IHS: Active
Concerns -
a. Mercury contamination associated with old sludge landfill outfall into the ASB.
b. Structural Integrity of the current sludge landfill dam.
c. Dioxin contamination in landfills and into ASB.
Remedy- Proper closeout of the landfills 4nd continued treatment of the leachate.
rfra
Soils SRG 2378-TCDF (40 ng/k
New Sludge Landfill EM007SB 2378-TCDF (190 ng/kg)
EM008SB 2378-TCDF (720 ng/kg) mercury (0.85 mg/kg)
Old Sludge Landfill EM009SB 2378-TCDF (5.8 ng/kg)
Groundwater 2L 2.2x10-1 ° mg/1 Dioxin; 2L 11 ug/l Mercury
Old Sludge Landfill Outfall to ASB 0.47 ug/1 mercury
Sediments
Old Sludge Landfill Outfall to ASB 0.84 mg/kg mercury; 2378-TCDF (420 ng/kg)
3. Aeration and Sedimentation Basin
Concern- Mercury and low levels of dioxin contamination documented in the
sediments and released to the ASB outfall.
Remedy- If the ASB is closed out, further characterization of the sediments will be
required and treatment of the process waste, sanitary waste, and the
leachate collected from the sludge and ash landfills need to be addressed.
If not closed out, agreement needed for long-term financial assurance.
Surface Water
ASB Mercury (0.35, 0.53 ug/1)
ASB Outfall Mercury (0.36 ug/1)
Sediments ASB Mercury (1.5, 1.8 mg/kg)
C:IDOCUME-1ISERGEI-1.0001LOCALS-11TEMP\EcustaConcernsRev4.doc Page 2

4. Ash Landfills (Old and New)
New: Coal Flyash
NC Solid Waste Permit #88-01
Old: Process sludge and 20,000 cu.yd. flyash
NCD 980 502 827 ("Brown #1")
CERCLA: NFRAP 1988 State IHS: Active
Concern- Sulfates in groundwater associated with the ash landfills;
Surface water runoff and erosion control; structural integrity of the
landfills.
Remedy- Glatfelter to meet industrial landfill permit closure and post -closure care
requirements under terms of Solid Waste Section Compliance Order.
5. Island Landfill
NCD 003 166 675 process waste
NC Solid Waste Permit #88-05
CERCLA NFRAP: 1994 State IHS: Active
Ike),
t ei-(—
st-0(
(This landfill was the primary area of concern during CERCLA Site Inspection in 1985
after the site was initially listed on CERCLIS as the Olin Corporation Ecusta Paper and
Film Group. Glatfelter currently is working to meet industrial landfill permit closure
requirements under NC Solid Waste Section Compliance Order.
Site is now re -activated on CERCLIS with a new site name of Ecusta Mill to include all
potential Areas of Concern associated with the plant, using the original EPA ID number
(NCD 003 166 675).
6. Caustic Plant
Concern- Leaky seal on the caustic pump released approximately 1500-3000 gallons
per day of 50% NaOH for 5 days.
Remedy- Pump and treat and monitoring under NC Division of Water Quality
oversight.
7. Asbestos
Concern- Possible asbestos in buildings.
Remedy- Compliance with the North Carolina Asbestos Hazard Management
Program (AHMP) administered by Health Hazards Control
C:\DOCUME-4\SERGEI-1.0001LOCALS'IITEMP\EcustaConcernsRev4.doc Page 3

8. Lead Paint
Concern- Lead paint in the old existing structures.
Remedy- Compliance with the North Carolina Lead -Based Paint Hazard
Management Program (LHMP) administered by Health Hazards Control
Other offsite landfills associated with Ecusta Mill and their present status are:
9. O'Shields Fly Ash NCD 980 728 745 22,000 cu.yd. flyash
CERCLA: NFRAP 1984 State IHS: Active
10. Knob Creek NCD 980 729 677 6,000 cu.yd. flyash
CERCLA: NFRAP 1995 State IHS: Active Remediation
11. Camp Strauss NCD 980 729 537 Rubble, C&D, mercury cells
CERCLA: NFRAP 2004 State IHS: NFRAP 1988
Further CERCLA Site Assessment sampling in 2004 detected no
mercury in the subsurface.
12. Owens Landfill NCD 980 503 072 Paper and cellophane waste
CERCLA: NFRAP 1991 State IHS: NFRAP 1992
C:IDOCUME'1ISERGEI-1.0001LOCALS-11TEMP\EcustaConcemsRev4.doc Page 4

Ecusta Site --Sludge and Ash Landfills --Issues
Subject: Ecusta Site --Sludge and Ash Landfills --Issues
From: Forrest Westall <[e-mail]>
Date: Wed, 29 Sep 2004 09:28:10 -0400
To: JAMES COFFEY <[e-mail]>
CC: Landon Davidson <[e-mail]>, Bev Price <[e-mail]>,
Kerry Becker <[e-mail]>, Jim Patterson <[e-mail]>, Kim
Colson <[e-mail]>, TED BUSH <[e-mail]>, Dave Goodrich
<[e-mail]>, Susan A Wilson <[e-mail]>
Jim,
This will follow-up my phone message to you today about this site and the ongoing issues
with these two landfills.
Mike Cody with Gladfelter (formally at Ecusta and RFS Ecusta) discussed this with me
yesterday. The Ash Landfill and the Sludge Landfill were under the "management" (and I use
this term "loosely") of RFS Ecusta and really are a part of the "transfer" to EDBC ("New Tech"
as we have often referred to the group that now is trying to manage and make this site work
as a pulp production operation, among other things). However, as part of the "agreement"
with Glatfelter and EDBC and NC, EDBC has until January 2005 to "make a go" of the
operation and let us and Glatfelter know if they will (want to) "operate" the two landfills.
During the "test" phase of this "new" owner, these two landfills have not received any new
waste material. Under the direction of DWM, Gladfelter has been working to "close out" the
"process landfill" (Island Landfill), but now awaits what is supposed to happen in January
concerning the long term use of the Ash and Sludge Landfills.
Gladfelter, in anticipation of the need to "close out" these two landfills (if indeed that is what
is undertaken after the January decision), wants to discuss the "process" for getting and the
details of an approved closure plan from DWM for the Ash Landfill and DWQ for the Sludge
Landfill. This is a needed planning step and even though it may not be needed in 2005, it will
be needed at some time. It is to all of our advantage to start "working through" the issues
with closure of these landfills anyway. A complication factor is the role of the ASB (aerated
stabilization basin --the 75 ac. wastewater treatment lagoon) and the short and long term
disposition of this facility. There is some possibility that the ASB would remain in service,
even if EDBC doesn't want to operate the Ash or Sludge Landfills (to provide wastewater
service to the site pending perhaps connection to Brevard WWTP or some other method of
dealing with wastewater generation --depending on how the site will be used and how much
and what type of wastewater will be generated). This is important because both the Ash and
Sludge Landfills have stormwater and "1hate" wastewater that is currently going into the
ASB and those waste streams are being treated by that facility. Even in "closure" mode, both
landfills will still need to deal with the wastewater generated by the existence of these
facilities. Should the ASB be available and the owner/operator of it willing to work with
Gladfelter to reach an agreement for "treatment" of the ongoing discharges, then that would
be one solution (which would make landfill leachate a continued part of the NPDES discharge
permit for the ASB). If the ASB is "closed" as well (an NPDES issue) or no agreement can be
reached on its use for treatment of the stormwater and "leachate," then the responsible party
for landfill closure (Glatfelter as it is today) will have to make other arrangements for the
management, permitting and operation of some kind of wastewater management system for
the landfills (it is likely that the stormwater can be discharged without treatment under a
general NPDES Stormwater Permit, but the "leachate" material will need to be treated and
discharged, pumped to treatment or hauled to an approved treatment facility).
With all of these issues on the table, any comprehensive discussion of plans and procedures
for landfill closure at these two sites need to include the appropriate folks at DWM and DWQ.
Under our new (as of July 1, 2004) organization in DWQ, the appropriate components
1 of 2 9/29/2004 11:13 AM

Ecusta Site --Sludge and Ash Landfills --Issues •
includes the Aquifer Protection Program in both the Central (Ted Bush, Chief of APP, and Kim
Colson, non -discharge permitting) and Regional Offices (Landon Davidson and Bev Price) and
the Surface Water Protection Program (because of the "connection" with the ASB, it will
depend on how the future of how that facility will be used in its relationship to "closure" of the
landfills) in RO (Kerry Becker and I) and CO (Dave Goodrich and Susan Wilson). As for the
SWPP side, Kerry and I will provide the "lead" on the ASB relationship to the closures and
keep Dave and Susan informed of all developments in this area (they of course are welcome to
be a part of the preliminary discussions --just let us know). I would defer to Ted and Landon
on the APP side.
I hope this is helpful in trying to pull together a meeting to discuss the landfill closure issues
on this site. I think it is a good idea to start this process before it becomes a time "crunch"
issue. If you have any questions, please let me know. Take care.
Forrest
2 of 2
9/29/2004 11:13 AM

(Fwd: Resumption of Negotiations]
Subject:
Date:
From:
Organization:
To:
CC:
[Fwd: Resumption of Negotiations]
Wed, 03 Sep 2003 13:16:24 -0400
Forrest Westall <[e-mail]>
NC DENR - Asheville Regional Office
Susan A Wilson <[e-mail]>,
Bradley Bennett <[e-mail]>,
Kim Colson <Kim.Colson@ ncmail.net>, Paul Muller <[e-mail]>
James Gulick <[e-mail]>, Kerry Becker <[e-mail]>,
dan oakley <[e-mail]>, Coleen Sullins <[e-mail]>,
Jim Patterson <[e-mail]>,
JESSE WELLS <[e-mail]>
Hello, Attached is Jim G's letter to Glatfelter and legal council to the new Ecusta site owner. The letter establishes a "deadline"
for the completion of the process to "work out" site responsibilities. This agreement needs to be completed before we proceed
with a "name change" on the permits. I talked to Paul Muller yesterday and he has a letter requesting transfer of the AQ permit
for the site boiler emissions. I briefed him about he meeting last week and efforts to get the parties in agreement before any
permits are processed. I talked with Susan Wilson last week and she was going to send out a letter to the new owner(s) about
"name changes" for DWQ permits and the need to secure "financial information" on the capability of the new owners to meet all
site environmental management demands. Clearly, the agreement discussed in Jim's letter would help "clear the way" for us to
do a name change. In the WQ letter we are informing the new owners that they are responsible for compliance with all existing
WQ permits and regulations pending reissuance of the permits in the new owner's name. Also, we are noting that site plans
which would affect the quality and/or quanity of wastewater going to ASB treatment system will need to be addressed by a new
application for the wastewater management permit (NPDES). Until actual plans for the site have been developed along with
"expected" wastewater characteristics, the existing limits, monitoring requirements and WQ management responsibilities will
remain as they are under the existing permit. Hopefully by Oct. 1 we can have a much clearer picture of how the long term site
responsiblilities will be met. Thanks.
Forrest
Original Message
Subject: Resumption of Negotiations
Date: Wed, 03 Sep 2003 10:44:44 -0400
From: "James Gulick" <[e-mail]>
To: <[e-mail]>, <[e-mail]>
CC: <[e-mail]>, "Robert Gelblum"
<[e-mail]>,<Bruce.Nicholson @ncmail.net>,
<[e-mail]>,<DEXTER.MATTHEWS @ncmail.net>,
<forrest.westall @ ncmai l .net>
Bill and Markus: Attached in Word and WordPerfect please find my letter inviting your clients back to the negotiating table. I
will send you a copy also by fax and by mail.Jim James C. Gulick
Senior Deputy Attorney General
Environmental Division
North Carolina Department of Justice
Post Office Box 629
[114 West Edenton Street, Room 306A]
Raleigh, North Carolina 27602
Telephone: [phone]
Facsimile: [phone]
1 of 2 9/9/03 11:28 AM

REPLY TO: James C. Gulick
Environmental Division
[e-mail]
Telephone: [phone]
Fax: [phone]
September 3, 2003
William W. Toole, Esq.
Robinson Bradshaw & Hinson
101 North Tryon Street, Suite 420
Charlotte, North Carolina 28246
Via e-mail and facsimile to 704.373.3973
Markus R. Mueller, Esq.
Corporate Counsel and Secretary
P.H. Glatfelter Company
96 South George Street, Suite 500
York, PA 17401
Via e-mail and facsimile to 717.846.2419
Re: "Ecusta Site" (the "Site")
Pisgah Forest, North Carolina
Dear Bill and Markus:
Prior to the closing of the purchase of the mill by Ecusta Business Development
Center and its affiliates, we had what I thought were some fairly useful meetings to
discuss how the various environmental issues at the site might be addressed. Both of
your clients (through you) expressed willingness to perform certain work, and/or pay
money, in relation to the site's environmental challenges, and for that we are
appreciative. Unfortunately, since the purchase both your clients appear to have taken
a harder line with one another. In our view, global resolution is in the interest of all
concerned; Glatfelter, so it can limit its liability, EBDC, so the requisite permits and
approvals can be garnered and a Brownfields Agreement signed, and the State, so the
environment can be protected.
We believe it essential that negotiations be resumed at once with the purpose of
negotiating a division of responsibility for work to be performed at the site. We would
like negotiations to resume no later than next week and to be concluded by October 1,
2003. In our (the State's) ideal world, your clients could make that division without us.
However, recognizing that is unlikely, we are prepared to be an active participant, along
with your clients and their environmental consultants of choice, in the negotiations. We

are prepared to make available necessary staff and offices for meetings in Raleigh for
this purpose.
Here are the topics we view as needing to be addressed in this manner:
• closure, post -closure care and ground- and surface -water monitoring of the
process island landfill;
• closure, post -closure care and ground- and surface -water monitoring of the ash
and sludge landfills, including collection and treatment of the ash landfill leachate,
whether or not the pulping operation is resumed;
• closure of the ASB, including post -closure care and ground- and surface -water
monitoring if needed;
• assessment, and remediation if any is necessary, of the caustic, mercury and
any other non -landfill contamination resulting from releases and/or disposal at the site;
• storage, handling and disposal of hazardous materials remaining on -site from
prior operations.
Please respond to this letter by Tuesday, September 9, 2003. Thank you.
Sincerely,
James C. Gulick
Senior Deputy Attorney General
cc: Daniel C. Oakley
Dexter Matthews
Bruce Nicholson
Forrest Westall
Robert Gelblum
Bonnie Sawyer

Re: [Fwcl: Today's Mtg. at Ecustal
Subject:
Date:
From:
Organization:
To:
CC:
Dan,
Re: [Fwd: Today's Mtg. at Ecusta]
Tue, 24 Jun 2003 10:46:04 -0400
Forrest Westall <[e-mail]>
NC DENR - Asheville Regional Office
Dan Oakley <[e-mail]>
James Gulick <[e-mail]>,
Kerry Becker <[e-mail]>,
Dave Goodrich <[e-mail]>,
Susan A Wilson <[e-mail]>,
Coleen Sullins <[e-mail]>, Alan Klimek <[e-mail]>
This has always been my position: that we do business by "allowing" new owners to operate under existing permits until we can
"reissue" those permits to the new owner. We generally call these "name changes" and are for the most part "minor" revisions
and reissuances that are done without public notice (defined as such in the NPDES rules 2H 0114 (b) (2)). The key point in this
regard is that we "can" evaluate a new owner's capability, financially and technically, to be able to "manage" the permits they are
requesting to be placed in their name, i.e. we have the authority to "resist" reissuance if we believe the new owner to be
incapable of meeting these tests. Our intention on the Ecusta site is to "use" this process to improve understanding of how the
site will be managed and what would happen if closure needed to happen, not to interfere with New Tech's efforts to obtain the
site. There have been general discussions of "bonding" requirements (some legislation has been introduced for discussion in
Raleigh), but there is nothing specific for this site. Because of the complex relationship between the existing owner, the
bankruptcy, the potential new buyer, past owners and so forth, I don't think it is reasonable to expect that all this will be resolved
before New Tech will need to "start up" operations.
Since we are deeply involved in the process to see the Ecusta site sold to a viable operator so that management of the
environmental systems can continue, we should be in a good position to evaluate this over some time. The reality of the Ecusta
Mill is that Puri, et al (RFS Ecusta) have been operating under "expired" permits that were applied for by Glatfelter and that
have not been reissued yet. Our expectation would be that New Tech would "request" that the permits be placed in their name
(once they actually "close" on the site). We would then remind them that as they operate the mill (after transfer we "assume"
that they will continue operations as allowed under existing or administratively continued permits --the expired ones) they are
responsible for meeting all the conditions of the existing permits.
There is no good way to deal with the issue of permit reissuance to new owners because we do not always know when a new
owner "takes over" a facility and we have generally considered the need to continue operations as a practical reality. Permit
compliance during this period is not an "option" for the new owner, however. If an owner were to "fail" to follow existing
permits (before they could be reissued in their name), we would take whatever action necessary to address this, i.e. as we have
done in relation to RFS Ecusta--court orders, getting involved in Federal Bankruptcy, etc. New owners generally abide by this
process and "accept" compliance and enforcement actions under the existing permits as a condition of site management and a
woring relationship with DWQ. Failure to accept the exisiting system for managing this activity means the new owner is
"operating without a permit" which provides a high degree of "exposure."
I do not see the situation of the Ecusta site WQ permit transfer as a "deal killer." Our intent is to generally do business as we've
always done. As long as Mr. Bell and New Tech commits to operate the environmental systems in an acceptable manner, we
would not "remove" their ability to operate under existing permits. We do need to reserve our right to "review" the capability of
the new owner to meet permit requirements and to revise the permit to reflect actual plans for the site (since they are likely to be
different than the way the plant operated up to closure last August). This approach is really to both the advantage of the new
owner and to the State and its citizens. Since the preliminary plans for the site doesn't include "full" paper production at the
previous levels (though this could change), wastewater flows may be significantly lower. Additionally, we understand Mr. Bell
is considering "other" uses of the site that may only generate "employee" waste or even possibly "commercial" waste generation
or even "municipal" wastewater service to the surrounding area. I believe the existing system on the site to treat wastewater
provides quite a bit of capacity and opportunity, but until the plans for the site are more finalized, they cannot specifically
request or we cannot reissue a revised WQ permit package. That means that full permit transfer at this time will not happen and
should not until we know the final plans for operation of the site. The existing permit and the capability of the systems there
should in no way "limit" New Tech's ability to "start up" production on the site. Because of the "special" recent history of this
plant and the ongoing needs to manage the environmental systems on the site, we will need to work on how "closure" would
happen, but this will not nor should it be "used" by DENR to "upset" the ability of New Tech to move forward with its plans.
1 of 4 8/18/03 2:50 PM

Re: [Fwd: Today's Mtg. at Ecusta]
•
We can discuss further as we need to.
Forrest
Dan Oakley wrote:
let's discuss. i assume the permit transfer would be at the time of
ownership change -- correct? has there been any talk of a
performance bond for the new owners?
Subject: Re: Today's Mtg. at Ecusta
Date: Mon, 23 Jun 2003 18:55:08 -0400
From: Rob Gelblum <[e-mail]>
To: James Gulick <[e-mail]>,
[e-mail],
David Blackwell <[e-mail]>,
John Bason <[e-mail]>,
Nancy Scott <[e-mail]>,
Beverly Hall <Beverly.Hall @ncmail.net>,
Wallace Finlator <wfinlat@mail jus.state.nc.us>,
[e-mail], [e-mail],
[e-mail], [e-mail],
[e-mail], [e-mail],
[e-mail], [e-mail],
[e-mail], Kay Dechant <[e-mail]>,
James Coffey <[e-mail]>,
"Jill.Pafford" <[e-mail]>, [e-mail],
Bobby Lutfy <[e-mail]>,
Keith Overcash <[e-mail]>
References:<[e-mail]> <[e-mail]>
Toole (T) called me late today. He's drafting the agreement to seek agreement. He said that, in the course of doing it, it hit
him that somehow or other permit transfer issues, at least re: the NPDES permit, must be dealt w/ at this time. (Something
along those lines had occurred to me.) In essence, he seems to be saying:
-Continuation of the wastewater treatment system (WTS) may be required to prevent enviro problems.
- Thus, the WTS must continue to be operated.
-New Tech (NT) can't be issued the NPDES permit until it owns the property.
- NT is reluctant to go forward until it knows what DWQ will require in the way of financial assurance re: that permit.
T went on to reiterate that, re: all the NPDES permits he's dealt w/, he's never heard of financial assurance being required
regarding, say, closure of the likes of the ASB, and that, even if financial assurance is to be required regarding same, it should
be extremely low, as the ASB could successfully be closed by poking hole in it, draining it, putting in a package plant, and
hiring someone to come pump it out once a week.
When I suggested to T that he might want to consider quickly putting his thoughts on this subject in an email, he said maybe
it's time for another mega -letter. We talked of him at least sending something regarding the NPDES situation to Jim, Dan, me,
2 of 4 8/18/03 2:50 PM

Re: [Fwd: Today's Mtg. at Ecustal
Forrest and maybe Kay; he said he'd probably be sending out (to Jim, Dan & me, I think) his draft agreement to seek
agreement before he leaves the office today.
Rob
Rob Gelblum wrote:
Harry Zinn & I are fresh back from same. DENR staff there besides Harry were Jesse Wells, Bobby Lutfy, James Albright
and Kay Dechant. The mtg. proper lasted from —11 to 1-something, then some techfolk did some site touring while EPA's,
New Tech's & Glatfelter's lawyers and me (plus 2 Glatfelter techfolk) caucused 'til —3. The mtg. proper essentially
consisted of Bill Toole (New Tech's atty.) "MC'g" a series of presentations by staff of New Tech's 2 consultants, Altamont
& ERM.
The main news I can think of (other than the Cody departure), though it was stated in a phone call the other day, is that New
Tech's consultants are convinced the pump is not needed to dewater the ash landfill, and that a gravity -based system will
work quite nicely. (They emphasize, however, that while they would like to discuss the necessary changes, they have no
plans whatsoever of letting the pump fail.) They also don't believe failure of the WWTP would lead to a massive release of
pollutants to the waters of the state. Putting it differently, they don't believe the site poses an imminent hazard. I, of
course, can't say whether they're right or wrong, but they're saying these things in an utterly reasonable way, and maintain
that the data supports this conclusion.
Harry says they didn't do their metals sampling as they should have, but ultimately the bailing method they used would only
"hurt" them (in the sense of giving higher hits), and I believe I recall him saying that the hits are not problematic as is
(except maybe mercury?). (Jump in here, Harry or any other DENR staff, if I get anything wrong.) Harry also expressed
concern that the numbers are showing possibly problematically contaminated sediments in the river.
Jesse expressed concern about the 18 mos. they want to dispose of hazardous materials, and Toole expressed total
flexibility as to a shorter period beyond the absolute 8-mo. minimum he says would be required.
Glatfelter is quite nervous about committing to serve as New Tech's financial assurance, and may bail. Glatfelter's & EPA's
attys. hammered Toole for more info re New Tech's finances and re the backgrounds of its principals. I noted that we need
the same info.
This is becoming increasingly clear: If there's an imminent hazard, it relates (in contrast to the usual situation) to the
permitted operations, not hazardous substances that have already been released to the environment. In other words, we're
not talking about threats posed by preexisting releases of hazardous substances ("Superfund releases"), but by releases that
will occur if certain things occur in relation to permitted operations (for which there's a defense under Superfund). The
implication is that, to the extent there's a need for haste, the main emphasis needs to be placed on permit transfer issues
(NPDES, solid waste, air quality, others?), not any kind of a Prospective Purchaser Agreement (PPA) or Brownfields
Agreement (BFA). Such agreements are all about the addressing of existing contamination.
That said, Toole says he very much wants an agreement, and concedes that, if nothing else, it's for the sake of public
relations. He is saying he fears that it will take EPA too long to make decisions. Thus, he's willing to forego the federal
animal (a PPA), and "settle" for a BFA. We've done a number of BFAs where there were DENR things going on that the
brownfields program doesn't deal with -- most typically USTs -- in which case we just recite in the BFA that the PD
(Prospective Developer) shall satisfy the relevant DENR program. It would seem strange to negotiate a BFA where the
principal enviro concerns at the site relate to non-brownfields matters, but there's nothing to stop us from doing so.
That said, it has been made clear to Toole how very, very problematic even negotiating an agreement's Work To Be
Performed section would be by 6/30, much less concluding negotiation of an entire agreement (especially given that we still
lack from him sufficient financials and info re New Tech's principals). Thus, he seems very open to the idea of concluding
3 of 4 8/18/03 2:50 PM

Re: [Fwd: Today's Mtg. at Ecusta]
by 6/30 nothing more than what would in effect be a very brief agreement to use best efforts to negotiate an agreement. He
has promised to send a draft.
Rob Gelblum
Forrest Westall - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
59 Woodfin Place
Asheville, NC 28801
Tel: [phone]
Fax: [phone]
Forrest Westall <[e-mail]>
NC DENR - Asheville Regional Office
Division of Water Quality - Water Quality Section
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•
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
Mr. Nathu Ram Puri (via Fed.Ex.)
Environment House
6 Union Road
Nottingham NG3 1 FH
Isle of Mann
Mr. Steven H. Smith (Return Receipt)
RFS Ecusta, Inc.
One.Ecusta Road
Pisgah Forest, NC 28768
RE: Environmental Liability Issues
RFS Ecusta Inc.
Ecusta Mill, Pisgah Forest
Transylvania County,, NC
OCT 1 G 2002
RFS US, Inc. (Return Receipt)
RFS Ecusta, Inc.
c/o C T Corporation System
225 Hillsborough Street
.-Raleigh, NC 27603
RFS US, Inc. (Return Receipt)
RFS Ecusta, Inc.
'1991 Northampton St
Easton, PA
OCT 11 8 �'
L0t;,
NM]
OCT 2 2 2002
IN, i ER QUALITY
SECTION
j,)02
NOS
Dear Gentlemen:
The North Carolina Department of Environment and Natural Resources (DENR or the
Department) has advised the Environmental Protection Agency (EPA) of the recent shutdown of
your Pisgah Forest mill and of the Department's concerns regarding the continued proper
operation and maintenance of the environmental management systems on the facility. The EPA
shares DENR's view that the various process and waste materials used or produced by the mill
represent a potential hazard to public health or the environment if they are discarded, abandoned,
or otherwise not properly managed. We also share the DENR's position that you and your
corporations are legally responsible for assuring that this facility, whether in production or not,
continues to meet its environmental obligations.
Please be advised that failure to comply with environmental permits, or to otherwise
properly address the waste management, treatment, and disposal issues at the facility, will be
taken very seriously by the EPA. Such failure could subject any organizations or individuals
with the power to control what actions are or are not taken at the facility, as well as any entities
with an ownership interest in the property, to civil and/or criminal liability under a variety of
federal laws. Those laws include, but may not be limited to the Clean Water Act (CWA), 33
U.S.C.A. §1251, et seq., the Resource Conservation and Recovery Act (RCRA), 42 U.S.C.A.. §
6901, et seq., and the Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA), 42 U.S.C.A. § 9601, et seq.
Internet Address (URL) a http://www.epa.gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)

A
2
The EPA intends to monitor developments in this matter very closely and strongly advises
that you work cooperatively with the State of North Carolina to assure that the environmental
responsibilities related to the Pisgah Forest mill are met and the public and the environment of
North Carolina are fully protected.
Sincerely,
ti f
A. Stanley Meiburg •
Deputy Regional Administrator
cc: William G. Ross; Jr., Secretary, NCDENR
Forrest Westall, NCDENR
Daniel C. Oakley, General Counsel, NCDENR
David Blackwell, N.C. Attorney General's Office
Mike Burns, Transamerica Business Capital Corporation
Ivan DeVoren, Law Offices of Dechert, Price & Rhoads
Jim Giattina, EPA
Doug Lair, EPA
Bill Anderson, EPA

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