NC0006254_Closure Plan Review Comments_20220831

North Carolina Department of Environmental Quality | Division of Water Resources
Asheville Regional Office | 2090 U.S. Highway 70 | Swannanoa, North Carolina 28778
828.296.4500

August 29, 2022

Dave Hallock
NPS Holdings LLC
3303 Spirit Way
Green Bay, WI 54304

RE: Review of Basin Closure and Lining Plan
Blue Ridge Tissue Corporation
Caldwell County, NC

Dear Mr. Hallock,

The NC Division of Water Resources Asheville Regional Office received the [Wastewater] Basin
Closure and Lining Plan (Plan) for the Blue Ridge Tissue facility located in Patterson, NC. The
purpose of this letter is to provide review comments and approval for the proposed changes to the
existing wastewater treatment system.

The Plan requests exemption from biological testing for fecal coliform, salmonella, enteric viruses,
and viable helminth ova for any wastewater sludge removed for off-site disposal. Biological testing
is not required if the sludge is being disposed of at a permitted landfill. However, biological testing
will be required for the land application of sludge whose source is either the aeration basin or the
polishing pond. Sludge/fibers removed from the north and south fiber traps is currently approved
for land application.

The Plan requests the most recent annual sludge analysis reporting (March 2022) be accepted in
lieu of collecting additional sludge samples from the north fiber trap. This sampling strategy can be
used for the land application of sludge/fibers from the north and south fiber traps only. No
additional permitting action is required to distribute the residuals from the aeration basin and
polishing pond, so long as Blue Ridge Tissue remains under their permitted dry tons. As stated
above, biological testing to show pathogen reduction will be required since the polishing pond and
aeration basin residuals fall under the Division’s definition of a “biological residual”. If the fecal
coliform results indicate the residuals are free of pathogens (<1000 MPN/g), then vector attraction
reduction is not required. The remaining testing, per Attachment A of the permit, will also be
required should Blue Ridge Tissue wish to land apply the polishing pond and aeration basin
residuals.

The Plan indicates disposal options for soils excavated from the fiber traps, aeration basin, and
polishing pond may include on-site reuse at the Blue Ridge Tissue facility and/or disposal at the
Foothills Regional Municipal Solid Waste Landfill. According to the sampling plan, a composite soil

sample collected from the north fiber trap will represent all soils generated during the excavation of
the wastewater basins (i.e., fiber traps, aeration basin, and polishing pond). This sampling strategy
can be used if soils are being disposed of at a permitted landfill. If any of the excavated soils are
being disposed of onsite, then separate composite soil samples will be required for each source of
soil. Analysis will be consistent with the Sampling Plan Summary and the proposed soil analysis for
the north fiber trap. The analytical results should be evaluated using the North Carolina Inactive
Hazardous Sites Branch Preliminary Soil Remediations Goals (PSRG) for industrial and protection of
groundwater PSRG’s.

The Plan requests exemption from analyzing sludge and soil samples for total chromium, because
this parameter is not required by Industrial Byproduct Residuals Facility, Permit No. WQ0011532 .
The Guidelines for the Closure of Permitted Wastewater Ponds and Lagoons does require analysis of
sludge and soil samples for total chromium. Furthermore, total chromium has been detected at
monitoring well MW-2 and at concentrations ranging from 6 to 307 micrograms per liter. Chromium
analysis will not be required for the land application of sludge/fibers. However, chromium analysis
will be required for any onsite disposal of soils excavated from the fiber traps, aeration basin, and
polishing pond.

A final closure report will be required at the end of the project. The report will include a summary
of closure activities including the volume of excavated sludge and soils, sampling map, analytical
results, disposal manifests, and photography of closure activities.

Please feel free to contact me if there any additional questions or concerns. I can be reached at
[phone] or [e-mail].

Sincerely,

Brett Laverty
Water Quality Regional Operations Section
Asheville Regional Office

ec: ARO files
Chris Bagley - Synterra