NCS000101_Fact sheet binder_20230907

DEQ / DEMLR
FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL
STORMWATER PERMIT DEVELOPMENT
Basic Information for Permit Issuance and Renewals:
Permit Writer/Date Brianna Young 9/l/2023
Permit Number NCS000101
Owner/Facility Name International Paper Company/Riegelwood Mill
SIC AICS Code/Category 2611 /Pulp Manufacture
Basin Name/Sub-basin number Cape Fear/03-06-17
Receiving Stream/HUC Cape Fear River/030300050405
UT to Cape Fear River/030300050405
UT to Livingston Creek/030300050303
Stream Classification/Stream Segment Cape Fear River: C; Sw/ 18-(63)
UT to Cape Fear River: C; Sw/ 18-(63)
UT to Livingston Creek: C; Sw/ 18-64
Is the stream impaired [on 303(d) list]? Yes See Section 2 below
Any TMDLs? No
Any threatened and/or endangered species? See Section 2 below
Any compliance concerns? See Section 2 below
Any permit mods since lastpermit? See Section 1 below
New expiration date 9/30/2028
Comments on Draft Permit? See Section 6 below
Section 1. Facility Activities and Process:
The International Paper Co. Riegelwood Mill is a pulp mill. The facility was previously a paper and pulp
mill. Per the renewal application, changes since the last permit renewal include:
• Disinfection process for potable water converted from chlorine to sodium hypochlorite.
• Process changed from a pulp/paper mill to a strictly pulp mill, decreasing process chemicals
onsite and increasing containerized pulp and truck traffic (pulp containers moved into and out of
Basin R). There was a switch to strictly pine wood(no hardwood mix), changing the type of
wood chips stored and handled in Basins C, D, E, F, and G (more pine=more turpentine
production as a byproduct). No. 1 power boiler taken offline.
• Basin A: Cessation of oil barging; infrastructure still in place to receive barges.
• Outfall F2: Outfall removed(runoff was rechanneled to discharge at Fl).
• Outfall G3: Outfall removed(black liquor line removed). Basin contains a mill road and rail spur
for wood chips.
• Basin H: Outfall removed(black liquor line removed and adjacent black liquor ponds emptied,
cleaned out, and no longer in use). Basin contains mill road and a rail spur for wood chip cars.
• Basin K: Outfall removed. Basin contains an access road and an underground natural gas line.
• Basin Q: Backwash pond from water plant filters permanently piped to the intake pumps at the
pumphouse; electrical backup provided.
• Outfall Rl: Outfall removed(runoff now discharges through Outfall S).
• Basin T: Added when the mill woodyard was upgraded to increase the mill's ability to produce
its own chips; a new wood truck entrance and scalehouse were constructed; other affected areas
drain to the mill wastewater treatment system.
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Per the inspection conducted in March 2023, representative outfall status was in effect and ROS
documented for all outfalls. The site is well maintained and conscientious of the stormwater pollution
prevention plan. Representative outfalls were:
• B: B,N, O
• E: A, C, D, E, F, G, H, Q
• I: I, J, K, L, M, P, R, S
• T: T is not a representative outfall
Outfall SW001: Basin A
Drainage area consists of oil barge unloading, oil unloading pipeline, and mill access road. Oil barging
activity has ceased, but infrastructure remains in place. Potential pollutants include: Fuel oil and
sediment.
Outfall SW002: Basin B
Drainage area consists of a firewater house,No. 5 cooling tower, electrical control room, chemical
storage and feed equipment for corrosion inhibitor in cooling water, and mill access road. Potential
pollutants include: Process water, biocide, and water treatment chemicals.
Outfall SW003: Basin C
Drainage area consists of transfer and storage of raw wood chips, a wood chip truck dumper, and mill
access road. Potential pollutants include: Hydraulic oil and woodchips.
Outfall SW004: Basin D
Drainage area consists of transfer and storage of raw wood chips, a firewater house, and mill access
road. Potential pollutants include: Woodchips.
Outfall SW005: Basin E
Drainage area consists of transfer and storage of raw wood chips, wood chip truck dumper, and mill
access road. Runoff passes through an oil/water separator prior to discharge. Potential pollutants
include: Hydraulic oil and woodchips.
Outfall SW006: Basin F
Drainage area consists of a chip screen, mill access road, an electrical control room, and water storage.
Basin is adjacent to process water. Potential pollutants include: Woodchips and process water.
Outfall SW007: Basin F1 and F2
Drainage area consists of a chip screen, mill access road, an electrical control room, and water storage.
Basin is adjacent to process water. Potential pollutants include: Woodchips and process water.
Outfall SW009: Basin G
Drainage area consists of raw wood chips transfer, maintenance material storage, mill access roads, and
rail lines. Basin is adjacent to the water treatment plant(process water). Stormwater runs through a small
collection basin and oil/water separator prior to discharge. Potential pollutants include: Woodchips,
hydraulic oil, and process water.
Outfall SW0010: Basin G1
Drainage area consists of raw wood chips transfer, maintenance material storage, mill access roads, and
rail lines. Basin is adjacent to the water treatment plant(process water). Stormwater runs through a small
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collection basin and oil/water separator prior to discharge. Potential pollutants include: Woodchips,
hydraulic oil, and process water.
Outfall SW0011: Basin G2
Drainage area consists of raw wood chips transfer, maintenance material storage, mill access roads, and
rail lines. Basin is adjacent to the water treatment plant(process water). Stormwater runs through a small
collection basin and oil/water separator prior to discharge. Potential pollutants include: Woodchips,
hydraulic oil, and process water.
Outfall SW014: Basin I
Drainage area consists of parking for trailers and trucks transporting finished products and a rail line for
some mill process areas. Drainage goes to a collection pond before discharge. Potential pollutants
include: Wood debris, sediment, and chemicals.
Outfall SW015: Basin J
Drainage area consists of a truck weighing station, rail lines for wood chips, chemical byproducts,
railcar repair, and mill access roads. Drainage goes to three (3) collection ponds before discharge.
Potential pollutants include: Chemicals, wood chips, and process byproducts.
Outfall SW018: Basin M
Drainage area consists of mill roads, a firehouse, fire suppressant, and a methanol storage tank. Potential
pollutants include: Methanol and chemicals.
Outfall SW019: Basin N
Drainage area consists of access to the No. 3 cooling tower and cooling water process chemical storage
(including biocides) and feed equipment. Potential pollutants include: Process water and water treatment
chemicals.
Outfall SW020: Basin O
Drainage area consists of access to the No. 3 cooling tower and cooling water process chemical storage
for biocides and corrosion inhibitors. Potential pollutants include: Process water and water treatment
chemicals.
Outfall SW021: Basin P
Drainage area consists of construction and maintenance equipment storage, transformers, truck and
trailer parking, and office trailers. Potential pollutants include: Sediment.
Outfall SW022: Basin Q
Drainage area consists of mill water intake, water plant filter backwash pond, and mill road. Backwash
pond from water plant filters has been permanently piped to the intake pumps at the pumphouse.
Potential pollutants include: Water plant backwash.
Outfall SW023: Basins R and S
Drainage area consists of wood chips, staging for trailers transporting logs and woodchips,parking for
trailers transporting finished products, and parking. Drainage goes to a sedimentation basin before
discharge. Potential pollutants include: Sediment and woodchips.
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Outfall SW024: Basin T
Drainage area consists of wood truck entry and scalehouse. Stormwater runs through catch basins and
two collection ponds. Potential pollutants include: Wood debris.
Additional outfalls:
Basin F2:
Outfall has been removed as runoff was rechanneled to discharge at outfall Fl.
Basin G3:
Outfall has been removed. Drainage area consists of raw wood chips transfer, maintenance material
storage, mill access roads, and rail lines. Basin is adjacent to the water treatment plant (process water).
Stormwater runs through a small collection basin and oil/water separator prior to discharge. Potential
pollutants include: Woodchips, hydraulic oil, and process water.
Basin H:
Outfall has been removed. Drainage area consisted of rail lines for raw wood chips and a mill access
road.
Basin K:
Outfall has been removed. Drainage area formerly contained laydown yard and went to a collection area
before discharge. Drainage area consisted of access road for utilities, natural gas utility line, and rail
passtracks.
Basin L
Drainage area consists of parking for trailers transporting finished products. Trailers are empty reject
trailers. Drainage goes to a collection pond before discharge. Potential pollutants include: Sediment.
Basin 1:
Previously named as a mill stormwater basin temporarily. This basin as an enclosed system operating
independently from the NPDES permit. The truck parking/staging area is excluded from industrial
activity. The drainage does not mix with stormwater from other drainage basins. Per information
provided 3/9/2023 and 3/28/2023, Basin 1 was a construction project to build a wet wood storage
adjacent to the mill and temporarily named as a stormwater outfall. After construction was completed,
the storage facility was issued a non-discharge permit. A different division of International Paper owns
that facility and is separate from the stormwater permit (Cape Fear Woodyard manages this area and the
associated non-discharge permit).
Why Industrial Sites with Stormwater are Subject to a Permit: Federal NPDES regulations define
stormwater discharge associated with industrial activity in 40 CFR §122.26 (b)(14) as: "the discharge
from any conveyance that is used for collecting and conveying storm water and that is directly related to
manufacturing,processing or raw materials storage areas at an industrial plant. The term does not
include discharges from facilities or activities excluded from the NPDES program under this part 122.
For the categories of industries identified in this section, the term includes, but is not limited to, storm
water [sic] discharges from industrial plant yards; immediate access roads and rail lines used or traveled
by carriers of raw materials, manufactured products, waste material, or byproducts used or created by
the facility; material handling sites; refuse sites; sites used for the application or disposal of process
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waste waters (as defined at part 401 of this chapter); sites used for the storage and maintenance of
material handling equipment; sites used for residual treatment, storage, or disposal; shipping and
receiving areas; manufacturing buildings; storage areas (including tank farms) for raw materials, and
intermediate and final products; and areas where industrial activity has taken place in the past and
significant materials remain and are exposed to storm water. For the purposes of this paragraph, material
handling activities include storage, loading and unloading, transportation, or conveyance of any raw
material, intermediate product, final product, byproduct or waste product. The term excludes areas
located on plant lands separate from the plant's industrial activities, such as office buildings and
accompanying parking lots as long as the drainage from the excluded areas is not mixed with storm
water [sic] drained from the above described areas."
Section 2. Monitoring Information and Compliance History:
• June 2015 to December 2022, benchmarks exceeded for:
o B: TSS 5x
o E: COD 6x, BOD Ix
o L• COD 2x, TSS 7x
o T: COD 16x, TSS 12x, BOD 2x
• There is a history of exceedances and Tiered Response actions
• Sludge pipe failed on 1/8/2021, resulting in—5,000 gallons reaching stormwater Outfall M
• Permit previously had representative outfall status for:
o B: representative of N and O
o E: representative of A, C, D, F, G, H, and Q
o I: representative of J, K, L, M, P, R, and S
• Per the May 2018 inspection report:
o Drainage basins A-S have ROS with basins B, E, I, and T.
o Basin B was in Tier 2 for TSS and Basin E was in Tier 2 for COD, but tier response
discontinued due to response (repairs and housekeeping)
o Basin I was in Tier 1
o Basin T was in Tier I for COD. Also, an area previously used for truck parking would be
used as a container storage area(no industrial activity)
• Per information provided 3/28/2023, Basins B, E, and T were in Tier 2 status during the previous
permit cycle
303(d)listing:
CAPE FEAR RIVER 18-(63)a ;Sw 3.8 F Miles
4387 From rawwater supply intake at Federal Paper Board corporation(Riegelwood)to Bryant Mill Creek
PARAMETER IR CATEGORY CRFIERIA STATUS REASON FOR RATING 303D YEAR
Benthos(Nar,AL,FW) 50 Exoeedin Criteria I Fair,Poor or Severe Biodassification 199
Threatened/Endangered Species:
There are no threatened/endangered species at the point of discharge. In the vicinity is the Coppery
Emerald(Somatochlora georgiana;NC status: SR), Atlantic Sturgeon(Acipenser oxyrinchus
oxyrinchus;NC status: E; Federal status: E), Shortnose sturgeon(Acipenser brevirostrum;NC status: E;
Federal status: E), and Social Sedge (Carex socialis; NC status: SR-P).
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Section 3. Proposed Monitoring for Stormwater Discharges:
The Division considered potential pollutants from past and present industrial activities and data was
submitted for June 2015 to December 2022. Quantitative sampling included pH, TSS, COD, and BOD.
Parameters are based on potential pollutants in the drainage area, sampling results, and in some cases,
dependent upon future activities (e.g., ash removal through the drainage area). Below is a table of the
proposed monitoring for each outfall at the Riegelwood Mill site.
Outfalls SWO01 (Basin A), SWO02 (Basin B), SWO03 (Basin C), SWO04 (Basin D), SWO05 (Basin
E), SWO06 (Basin F), SWO07 (Basins F1 and F2), SWO09 (Basin G), SWO10 (Basin GI), SWOT I
(Basin G2), SWO14 (Basin I), SWO15 (Basin.I), SWO19 (Basin N), SW020 (Basin O), SW021
(Basin P), SW022 (Basin Q), SW023 (Basins R and S), and SW024 (Basin T)
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness
(TSS) indicator.
Quarterly monitoring
pH BASIS: Pollutant indicator
Quarterly monitoring
Total Rainfall BASIS: Discharge potential indicator
Quarterly monitoring
Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM
targets petroleum-based O&G
Quarterly monitoring
Monthly Oil Usage BASIS: Potential pollutant from drainage area
Quarterly monitoring
BOD BASIS: Discharge potential indicator
Quarterly monitoring
COD BASIS: Discharge potential indicator
Page 6 of 15

Outfall SWO18 (Basin M)
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness
(TSS) indicator.
Quarterly monitoring
pH BASIS: Pollutant indicator
Quarterly monitoring
Total Rainfall BASIS: Discharge potential indicator
Quarterly monitoring
Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM
targets petroleum-based O&G
Quarterly monitoring
Monthly Oil Usage BASIS: Potential pollutant from drainage area
Quarterly monitoring
BOD BASIS: Discharge potential indicator
Quarterly monitoring
COD BASIS: Discharge potential indicator
Quarterly monitoring
Methanol BASIS: Potential pollutant from drainage area
Stormwater Benchmarks and Tiered Response: Rather than limits,North Carolina NPDES
Stormwater permits contain benchmark concentrations. Stormwater benchmarks are numerical action
levels for stormwater monitoring. Benchmarks are not effluent limits, and benchmark exceedances are
not permit violations. Benchmarks provide facilities a tool for assessing the significance of pollutants in
stormwater discharges and the effectiveness of best management practices (BMPs). Benchmark
concentrations are intended as guidelines for the facility's development and implementation of the
Stormwater Pollution Prevention Plan(SWPPP).
Benchmark exceedances require the permittee to increase monitoring, increase management actions,
increase record keeping, and/or install stormwater BMPs in a tiered program. The permit establishes a
tiered approach to specify actions the permittee must take in response to analytical results above
benchmark concentrations. The tiered structure of the permit provides the permittee and DEMLR wide
flexibility to address issues that may arise with one or more parameters and/or outfalls.
Metals benchmarks are calculated to mimic acute water quality standards and with the guidance of
DWR. NC DWR follows established federal procedures for calculating acute standards when developing
the benchmarks. Just like the acute standards, metals benchmarks normally reflect one half of the
calculated Final Acute Value (the "1/2 FAV"). In most cases, translation into total recoverable values is
based on an assumed hardness of 25 mg/L and a total suspended solids (TSS) concentration of 10 mg/L.
Acute standards protect aquatic life from negative impacts of short-term exposure to higher levels of
Page 7 of 15

chemicals where the discharge enters a waterbody. The Stormwater Permitting Program applies this
approach because of the ephemeral nature of rainfall events.
The Division may evaluate results to determine if a smaller suite of parameters for some outfalls is
adequate to characterize potential pollution or BMP effectiveness. For example, one or more metals or
other parameters may serve as an adequate tracer for the presence of ash pollution during disturbance or
ash removal in specific drainage areas at this site. For parameters that do not have a stormwater
benchmark, the Division may develop a benchmark value if appropriate toxicity data become available
or if rising trends in concentrations suggest a persistent source.
A summary of the benchmarks in the draft permit, and their basis, is below:
Parameter Benchmark Basis
Total Suspended 100 mg/L National Urban Runoff Program(NURP) Study, 1983
Solids TSS
H 6 s.u. —9 s.u. NC Water Quality Standard(Range)
Non-Polar Oil & Review of other state's daily maximum benchmark
Grease 15 mg/L concentration for this more targeted O&G;NC WQS that
EPA Method 1664 does not allow oil sheen in waters
SGT-HEM
BOD 30 mg/L BPJ; Based on Secondary Treatment Regulation(40 CFR
133.03
COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic
wastewaters
Methanol 6,400 mg/L Species Mean Acute Value of two 96-hour equilibrium EC50
end oints for Le omis machrochiris blue ill
Stormwater Pollution Prevention Plan: The proposed permit conditions reflect the EPA and NC's
pollution prevention approach to stormwater permitting. The Division's maintains that implementation
of Best Management Practices (BMPs) and traditional stormwater management practices that control the
source of pollutants meets the definition of Best Available Technology (BAT) and Best Conventional
Pollutant Control Technology(BCT). The permit conditions are not numeric effluent limitations but are
designed to be flexible requirements for implementing site-specific plans to minimize and control
pollutants in stormwater discharges associated with the industrial activity. Title 40 Code of Federal
Regulations (CFR) §122.44(k)(2) authorizes the use of BMPs in lieu of numeric effluent limitations in
NPDES permits when the agency finds numeric effluent limitations to be infeasible. The agency may
also impose BMP requirements which are "reasonably necessary" to carry out the purposes of the Act
under the authority of 40 CFR 122.44(k)(3). The conditions proposed in this draft permit are included
under the authority of both of these regulatory provisions. In essence, the pollution prevention and BMP
requirements operate as limitations on effluent discharges that reflect the application of BAT/BCT.
Flexibility in Tier Responses: Tier Two actions provide an opportunity for the permittee to propose an
alternative monitoring plan for approval by the Region:
• Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive exceedances,
exercise the option of contacting the DEMLR Regional Engineer as provided below in Tier
Three. The Regional Engineer may direct the response actions on the part of the permittee as
provided in Tier Three, including reduced or additional sampling parameters or frequency.
• If pursuing the alternative above after two consecutive exceedances, the permittee may propose
an alternative monitoring plan for approval by the Regional Engineer.
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The permit therefore allows the permittee to petition the Regional Office for monitoring changes sooner
than Tier Three (upon any four benchmark exceedances) and gives guidance on one option to take. For
example, the permittee may request that mercury only be monitored semi-annually under the tiers, or
that only parameters over the benchmark be monitored more frequently. In this way, changes to the
monitoring scheme for any outfall could be handled outside of a permit modification.
Other Proposed Requirements:
• It is standard for Stormwater Pollution Prevention Plan(SWPPP)requirements to include an
annual certification that stormwater outfalls have been evaluated for the presence of non-
stormwater discharges, and if any are identified, how those discharges are permitted or otherwise
authorized.
• Requirement to submit a request for permit modification if the facility identifies or creates any
new outfalls, removes outfalls, or alters any drainage area that changes potential pollutants.
• The Division expects the permittee to apply best professional judgment and consider the safety
of its personnel in fulfilling sampling obligations under the permit.
• Federal regulations require electronic submittal of all discharge monitoring reports (DMRs). If a
state does not establish a system to receive such submittals, then permittees must submit DMRs
electronically to the EPA.
• Quarterly QualitativeNisual Monitoring to assure regular observation of outfalls throughout
year.
Section 4. Changes from previous permit to draft:
• Monitoring increased from semi-annually to quarterly for all parameters (qualitative and
quantitative)
• "No discharge" clarifications made
• eDMR requirement added
• Boilerplate language moved into body of the permit; boilerplate no longer attached
• Feasibility study removed
• Outfalls F2, G3, H, K, and R removed from permit per information submitted with the renewal
application
• Monitoring for Basin M separated from other basins and monitoring added for methanol due to
potential pollutants present
• Basin T has been added to the permit per information submitted with the permit renewal
application
• Benchmarks updated for parameters per guidance from DWR Standards group on stormwater
benchmarks
Section 5. Changes from draft to final:
• Cape Fear River added as a receiving stream on permit cover sheet and location map
• Basins F and G added to the monitoring requirements based on information provided on draft
permit and subsequent outfalls renumbered
o Basin F2 combined with Basin F1 based on information provided during the permit
renewal
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o Basin G3 removed per comments received on the draft permit
• Basin L removed as no industrial activity occurs in the drainage area(per comments on the draft
permit)
• Updates to language made in sections D-1(b), D-7(a), and E-1 per comments received on the
draft permit
Section 6. Discussions with the Facility and Regional Office:
• Initial contact with facility: 1/31/2023
• Initial contact with Regional Office: 1/31/2023
• Draft sent to CO peer review: N/A
• Draft sent to Regional Office: 6/14/2023
• Final permit sent for supervisor signature: 9/1/2023
Section 7. Comments received on draft permit:
Colleen Cohn and Wallace Cloverdale (International Paper; via email 7/13/2023 and subsequent
dates): We request the opportunity to review a second draft that addresses our comments prior to final
issuance of our permit.
• DEMLR Response: It is the policy of the Stormwater Permitting Program to provide one draft
permit for comment. Please find the attached issued permit and responses below to your
comments.
Draft permit cover letter
• To streamline communications, we respectfully request that all correspondence related to IP-
Riegelwood's stormwater permit be directed to Kevin Driscoll, Riegelwood Mill Manager, rather
than Hunter Whiteley, Vice President of Manufacturing for IP's Global Cellulose Fibers
Division. Mr. Driscoll has been delegated signatory authority for IP Riegelwood's stormwater
permit and should be the primary recipient of correspondence related to this permit. Please
continue to copy Ms. Wallace Coverdale and include Ms. Colleen Cohn on any stormwater-
related correspondence.
o DEMLR Response: Official correspondence is sent to the legally responsible official,
with additional permit contacts cc'd. Currently Hunter Whiteley is listed as the legally
responsible official in our database. Additional contacts are identified below. If you wish
to update the contacts for this facility, please visit the Permit Contact Update Request
Form.
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Entity *Affiliation Type Name Title _
Facility Contact Person Burk, Kevin G. Senior Enviro... (€
Facility Contact Person Gill,Timothy EH&S Man ag... (€
Facility Contact Person Boles, Patricia C. ORG (€
Owner Has Permit Signature Authority Alexander, Lee VP Global Fi... (€
Owner Owner Whitely, Hunter M. VP Manufact... (€
Permit Billing International Paper Comp... (€
Permit Contact Person Grissom, Louis O. (€
Permit Has Permit Signature Authority Burk, Kevin O. (€
Permit Has Permit Signature Authority Fail, Kimberly W. (€
Permit Has Permit Signature Authority Gill,Timothy
Permit Has Permit Signature Authority Greer, Stephen (€
Permit Has Permit Signature Authority Morrow, Gary
• Item 2 of the cover letter notes that units of measure for several benchmarks have been changed
from mg/L to µg/L. Please specify which benchmarks have been updated, as this was not readily
apparent during our permit review.
o DEMLR Response: This is standard language used in many permit cover letters. The
language was mistakenly kept in this draft permit.
• Item 7 does not include Basin L, which was also removed from the permit per information
submitted with the permit application.
■ DEMLR Response: Per information provide with the permit renewal application,
the drainage area consists of parking for trailers transporting finished products.
Are there any other industrial activities that occur in the drainage area?
■ Wallace Cloverdale Response: No, only trailer parking.
■ DEMLR Response: Basin L has been removed as there is no industrial activity in
the drainage area.
• Item 8 notes that Basin M is being separated from the other basins for additional monitoring. Our
rationale for not including this basin for additional monitoring is outlined later in this letter.
o DEMLR Response: Monitoring for Basin M will remain in the permit as methanol
transport and other industrial activities occur in the drainage area.
• Second page, first paragraph: It is our understanding from the Wilmington Regional Office's
(WiRO) DEMLR section that representative outfall status (ROS) is to be self-certified on an
annual basis, that no additional forms are required to be submitted to the Department if there is
no change in ROS and that ROS carries over from permit to permit(unless changes are
required). For analytical monitoring purposes, IP-Riegelwood will continue to monitor Basins B,
E, and I as representative outfalls.
o DEMLR Response: The Stormwater Program requires ROS be requested with each
permit renewal. If you had ROS in the previous permit term, attach the completed ROS
Renewal Certification Form and prior documentation that was provided when the
Division originally granted ROS to the Stormwater Upload Form.
Draft permit
• Location Map (page 6): The Cape Fear River should be included as an additional receiving
stream.
o DEMLR Response: The reference has been updated.
• C-2 Qualitative Monitoring Response (b): IP-Riegelwood requests that this requirement be
expanded to include electronic and hard copy records.
o DEMLR Response: The storage mechanism of this requirement is up to the permittee as
long as the record is kept in the SWPPP.
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• D-1 Required Baseline Monitoring (b): IP-Riegelwood requests that this condition be clarified to
include only the average oil usage individually for the chip dumps in Basins C and E. Other
activities on-site that involve motor and hydraulic oil are conducted in areas that drain directly to
the wastewater treatment system(WTS) and should not be included in this permit condition.
o DEMLR Response: This is standard monitoring required of all industrial individual
permits. If the facility meets this threshold, then monitoring and reporting must occur.
• Table 1 description:
o Basin L should be removed from this listing,per information submitted with the permit
application.
■ DEMLR Response: Per information provide with the permit renewal application,
the drainage area consists of parking for trailers transporting finished products.
Are there any other industrial activities that occur in the drainage area?
■ Wallace Cloverdale Response: No, only trailer parking.
■ DEMLR Response: Basin L has been removed as there is no industrial activity in
the drainage area.
o IP-Riegelwood requests that a footnote be added to this table denoting that Basins B, E,
and I are representative outfalls for the remaining basins except for Basin T.
■ DEMLR Response: Representative Outfall Status (ROS) is a separate review
process and not handled during permit renewal. If you wish to request ROS, you
may visit our website at deq.nc.gov/SW-industrial and follow the instructions
under"Request Representative Outfall Status".
o General Comment: IP-Riegelwood requests that the numbering of the stormwater outfalls
throughout the permit be revised to reflect letters rather than numbers, e.g. Outfall A,
rather than Outfall SW001. IP-Riegelwood has historically referred to outfalls in this
manner and prefers that this nomenclature be continued.
■ DEMLR Response: Outfalls must be numbered numerically in order for the NC
eDMR system to properly upload monitoring data to the EPA ECHO database. If
you wish the numerical assignments to differ than what is currently given,please
let the Stormwater Permitting Program know.
• Table 1 rows:
o Row 4: IP-Riegelwood requests clarification on the averaging period for drainage areas
where greater than 55 gallons of oil per month could be used.
■ DEMLR Response: As stated in Table 1, monitoring and reporting is required if
> 55 gallons per month are used on average.
o Row 5: IP-Riegelwood requests that this condition be clarified to only include the type(s)
of oil that are normally used in Basins C and E for the chip dumps. Other activities on-
site that involve various types of oil (hydraulic, lube, motor, fuel oil, etc.) are conducted
in areas that drain directly to the WTS and should not be included in this permit
condition.
■ DEMLR Response: Estimated Average Monthly Oil Usage is a standard
monitoring requirement of all individual industrial permits and required for each
drainage area with an outfall.
• Table 1 footnotes:
o General Comment: As noted previously, IP-Riegelwood requests that the numbering of
the storm water outfalls in this footnote section be revised to reflect letters rather than
numbers, e.g. Outfall A, rather than Outfall SW001.
■ DEMLR Response: Outfalls must be numbered numerically in order for the NC
eDMR system to properly upload monitoring data to the EPA ECHO database. If
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you wish the numerical assignments to differ than what is currently given,please
let the Stormwater Permitting Program know.
o General Comment: IP-Riegelwood also asks that each bullet in this footnote section be
re-formatted in the following manner to describe each drainage basin: "Basin A (Outfall
A): Drainage area consists of oil barge unloading, oil unloading pipeline and mill access
road."
■ DEMLR Response: Outfalls are identified this way in order to match with the
assigned numerical values for easier reference to the monitoring tables. If you
wish the numerical assignments to differ than what is currently given, please let
the Stormwater Permitting Program know.
o Outfall SW001 (Basin A): This area does include the oil barge unloading area and
associated pipeline; however,No. 6 fuel oil has not been received by barge since 2015
and the pipeline is maintained in caretaker status. IP-Riegelwood currently receives all
No. 6 fuel oil by truck in an area that drains to the WTS, and there are no future plans to
receive fuel oil via barge.
■ DEMLR Response: This has been noted in the permit file.
o Outfall SW002 (Basin B): All chemical storage and feed equipment is contained in
secondary containment that drains to the WTS.
■ DEMLR Response: This has been noted in the permit file.
o Outfall SW006 (Basin Fl): IP-Riegelwood requests that the description for Basin F be
modified to include two outfalls, Outfalls F and Fl. This bullet incorrectly identifies the
basin as Basin Fl.
■ DEMLR Response: The permit renewal application received May 2019
identified 2 outfalls for Basin F (FI and 172), with F2 having been removed.
Please confirm the correct nomenclature for these outfalls.
■ Wallace Cloverdale Response: Basin F has outfalls F and FL F2 is no longer
active.
■ DEMLR Response: Basin F has been added to the permit and subsequent outfalls
have been renumbered.
o Outfall SW008 (Basin G1) and Outfall SW009 (Basin G2): IP-Riegelwood requests that
the description for Basin G be modified to include three outfalls, Outfalls G, G1, and G2.
These bullets incorrectly identify the basins as Basins G1 and G2.
■ DEMLR Response: The permit renewal application received May 2019
identified 3 outfalls for Basin G, with Basin G3 having been removed. Please
confirm the correct nomenclature for these outfalls.
■ Wallace Cloverdale Response: Basin G includes Outfalls G, G1, and G2. G3 is
obsolete.
■ DEMLR Response: Basin G has been added to the permit and subsequent
outfalls have been renumbered.
o Outfall SW015 (Basin L): Basin L should be deleted from this listing,per information
submitted with the permit application.
■ DEMLR Response: Per information provide with the permit renewal application,
the drainage area consists of parking for trailers transporting finished products.
Are there any other industrial activities that occur in the drainage area?
■ Wallace Cloverdale Response: No, only trailer parking.
■ DEMLR Response: Basin L has been removed as there is no industrial activity in
the drainage area.
o Outfall SW018 (Basin O): All chemical storage is contained in secondary containment
that drains to the WTS.
Page 13 of 15

■ DEMLR Response: This has been noted in the permit file.
• Table 2: IP-Riegelwood requests that Basin M be removed from the draft permit for all
quantitative monitoring. The methanol tank and unloading area are located south of the roadway
outside and east of the contractor gate; drainage areas south of this roadway are currently routed
to a grassy swale that leads to the WTS. The containment for the methanol tank is also routed to
the WTS. IP-Riegelwood employs a formal unloading checklist and procedure for the methanol
tank(as well as other bulk tanks on-site) [...] Please note that all subsequent comments related to
table numbering may be disregarded if Table 2 is omitted from the draft permit. IP-Riegelwood
also requests that the outfall associated with Basin M be referred to as Outfall M, rather than
Outfall SW016.
o DEMLR Response: Monitoring for Basin M will remain in the permit as methanol
transport and other industrial activities occur in the drainage area. Outfalls must be
numbered numerically in order for the NC eDMR system to properly upload monitoring
data to the EPA ECHO database. If you wish the numerical assignments to differ than
what is currently given,please let the Stormwater Permitting Program know.
• Additional Outfalls (page 15): As noted previously in this letter, IP-Riegelwood requests that
Basin L be included in the listing of basins to be removed from this permit.
■ DEMLR Response: Per information provide with the permit renewal application,
the drainage area consists of parking for trailers transporting finished products.
Are there any other industrial activities that occur in the drainage area?
■ Wallace Cloverdale Response: No, only trailer parking.
■ DEMLR Response: Basin L has been removed as there is no industrial activity in
the drainage area.
• D-5 Tier One Response: Single Benchmark Exceedance:
o IP-Riegelwood requests that language be added to this condition specifying that an outfall
enters Tier 1 status by exceeding a single benchmark parameter on one occasion.
■ DEMLR Response: This section is standard language used in all permits. Section
D-5. (a) states this requirement.
o (a) and (d): These requirements should reference Table 3, rather than Table 2.
■ DEMLR Response: The reference has been fixed.
• D-6 Tier Two Response: Two Consecutive Benchmark Exceedances
o (d): IP-Riegelwood requests that the first sentence of this requirement be reworded as
follows: "Two consecutive exceedances of a single benchmark parameter at a single
outfall shall constitute an event that requires a Tier Two response."
■ DEMLR Response: This section is standard language used in all permits. Section
D-6. (a) states this requirement.
o (d): IP-Riegelwood requests clarification as to the meaning of the last sentence in this
condition: "Subsequent events shall not include the same exceedances that have been
addressed in a Tier Two response."
■ DEMLR Response: If there are additional exceedances for a benchmark at an
outfall, new Tier II responses need to be accounted for.
o (a) and (e): These requirements should reference Table 4, rather than Table 3.
■ DEMLR Response: The reference has been corrected.
• D-7 Tier Three Response: Four Benchmark Exceedances Within 5 Years
o Section Title and(a): IP-Riegelwood requests that the 5-year period be more specifically
defined as the 5-year permit term.
■ DEMLR Response: The 5-year period is a rolling period and not limited solely to
the permit term.
Page 14 of 15

o IP-Riegelwood requests clarification as to whether events that have been addressed in
Tier One or Tier Two responses should count towards the four exceedances tallied for a
Tier Three response.
■ DEMLR Response: Yes, exceedances are cumulative.
o (a) and (f): These requirements should reference Table 5, rather than Table 4.
■ DEMLR Response: The reference has been corrected.
• E-1 Deadlines for Submittal of Discharge Monitoring Reports
o This requirement should reference Table 6, rather than Table 5.
■ DEMLR Response: The reference has been corrected.
o The first quarterly monitoring period should be from January 1-March 31, rather than
March 30.
■ DEMLR Response: The reference has been corrected.
o Table 6: IP-Riegelwood requests clarification on inconsistencies between the Table 6
deadlines and Condition E-4, which requires that the facility submit sampling results no
later than 30 days from the date the facility receives the sampling results. For example, if
a facility takes its first quarterly sample on March 31 but does not receive the results until
May 1, is the first quarter DMR due on May 31, rather than April 30? In contrast, if the
first quarterly sample is taken on January 1 and sample results are received on February
1, is the first quarter DMR due on March 2, rather than April 30?
■ DEMLR Response: Monitoring results should be submitted by the end of the
month following the reporting period(i.e. the month the samples were taken). For
example, if a sample is taken on March 31st, then the results need to be reported in
eDMR by April 30tn
• Part F: Other Occurrences that Must be Reported
o Please correct the spelling of"Occurrences" in the section heading.
■ DEMLR Response: The reference has been corrected.
o The first paragraph of this section references Table 6, rather than Table 7.
■ DEMLR Response: The reference has been corrected.
• H-6. Required Notice for Bypass or Upset: The first paragraph of this section references Table 7,
rather than Table 8.
o DEMLR Response: The reference has been corrected.
Page 15 of 15

LOCAL'100
Stai-News I The Dispatch PO Box 631697 Cincinnati, OH 45263-1697
Times-News
NORTH CAROLINA
PROOF OF PUBLICATION ENVIRONMENTAL
MANAGEMENT COMMISSION
INTENT TO ISSUE
Joyce Sanford NPDES STORMWATER
Joyce Sanford DISCHARGE PERMITS
Nc Division Of Energy,Mineral And Land Resources The North Carolina
1612 Mail Service CTR Environmental Management
Raleigh NC 27699-1600 Commission Proposes to issue
NPDES stormwater discharge
permit(s) to the person(s) listed
below. Public comment or
STATE OF NORTH CAROLINA,COUNTY OF NEW HANOVER obiection to the draft permits is
invited. Written comments
regarding the proposed permit
The Wilmington Star-News, a newspaper printed and published in will be accepted until 30 days
the city of Wilmington,and of general circulation in the:County of after the publish date of this
personal knowledge of notice and considered in the final
New Hanover, State of North Carolina,and
p g determination regarding permit
the facts herein state and that the notice hereto annexed was issuance and permit Provisions.
Published in said newspapers in the issue dated: The Director of the NC Division
of Energy, Mineral, and Land
Resources (DEMLR) may hold a
06120/2023 public hearing should there be a
significant degree of Public
and that the fees charged are legal. interest. Please mail comments
and/or information requests to
Sworn to and subscribed before on 06/20/2023 DEMLR at 1612 Mail service
Center, Raleigh, NC 27699-1612,
• International Paper Company
t6400 Poplar Ave, Memphis, TN
381971 has requested renewal of
permit NCS000101 for the
Riegelwood Mill in Columbus
County. This facility discharges
to an unnamed tributary to the
Cape Fear River and an
unnamed tributary to Livingston
Creek in the Cape Fear River
Basin.
Interested persons may visit
DEMLR at 512 N. Salisbury
Legal f/er ,n / � Street, Raleigh, NC 27604,.-ter review information on file.
Additional information on
Notary,State of WI County of Brown NPDES permits and this notice
may be found on our website:
https://deq.nc.gov/about/divisions/
/ D1 energy-mineral-and-land-
My commision expires resources/stormwater/stormwater
-program/stormwater-publ ic-
Publlcation Cost: $184.80 notices, or by contacting Brianno
Yonne at
Order No: 8954526
#of Copies: [e-mail] or 919-
Customer No: 745790 1 707-3647.
PO#.
THIS IS NOT AN INVOICE!
Please do not rise this form for payment remittance.
NOiLaf
Page 1 of 1

Compliance Inspection Report
Permit:NCS000101 Effective: 12/01/14 Expiration: 11/30/19 Owner: International Paper Company
SOC: Effective: Expiration: Facility: Riegelwood Mill
County: Columbus 865 John L Reigel Rd
Region: Wilmington
Riegelwood NC 28456
Contact Person:Louis O Grissom Title: Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 03/16/2023 Entry Time 10:OOAM Exit Time: 12:OOPM
Primary Inspector:Brian P Lambe Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCS000101 Owner-Facility:International Paper Company
Inspection Date: 03/16/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Representative outfalls:
B: B, N, O
E: A, C, D, E, F, G, H, Q
I: I, J, K, L, M, P, R, S
T: T is not a representative outfall
Site is well maintained and contiencious of the stormwater pollution prevention plan.The staff works well as a team to
address issues immediately.
Recommend issuing permit.
Page 2 of 3

Permit: NCS000101 Owner-Facility:International Paper Company
Inspection Date: 03/16/2023 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? ❑ ❑ ❑
#Does the Plan include a General Location (USGS) map? ❑ ❑ ❑
#Does the Plan include a"Narrative Description of Practices"? ❑ ❑ ❑
#Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑
#Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ❑
#Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑
#Does the facility provide all necessary secondary containment? ❑ ❑ ❑
#Does the Plan include a BMP summary? ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑
#Does the facility provide and document Employee Training? 0 ❑ ❑ ❑
#Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually? 0 ❑ ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑
Comment: Please review permit requirements, especially with new permit to be issued, and include in the
SPPP. Yearly updates, certification, and employee training should documented in the SPPP.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? 0 ❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment: ROS documented for all outfalls to be represented by B, E, I, T.
Permit and Outfalls
Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ ❑
#Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
#Has the facility evaluated all illicit(non stormwater)discharges? 0 ❑ ❑ ❑
Comment:
Page 3 of 3

Young, Brianna A
From: Wallace H Coverdale <[e-mail]>
Sent: Wednesday,August 23, 2023 3:19 PM
To: Young, Brianna A
Cc: Colleen Cohn; Stephen Greer
Subject: RE: [External] IP Riegelwood's Response to Draft NPDES Stormwater Permit NCS000101
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Hello Brianna, I checked with production personnel to be sure,the trailers in Stormwater Basin L are empty reject
trailers.
From:Young, Brianna A<[e-mail]>
Sent:Wednesday,August 23, 2023 1:35 PM
To:Wallace H Coverdale<[e-mail]>
Cc: Colleen Cohn <[e-mail]>; Stephen Greer<[e-mail]>
Subject: RE: [External] IP Riegelwood's Response to Draft NPDES Stormwater Permit NCS000101
Good afternoon,
I have one follow-up question based on the information provided. In Basin L, do the trailers parked in the drainage area
contain finished product, or do they sit empty?
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
**DEQ has updated its email addresses to @deq.nc.gov. Employee email addresses may look different but email performance will
not be impacted.
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From:Wallace H Coverdale<[e-mail]>
Sent:Tuesday, August 15,2023 1:22 PM
To:Young, Brianna A<[e-mail]>

Cc: Colleen Cohn<[e-mail]>; Stephen Greer<[e-mail]>
Subject: RE: [External] IP Riegelwood's Response to Draft NPDES Stormwater Permit NCS000101
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Thank you, Brianna, please reach out with any questions or comments.
From:Young, Brianna A<[e-mail]>
Sent: Monday,August 14, 2023 1:48 PM
To: Wallace H Coverdale<[e-mail]>
Cc: Colleen Cohn<[e-mail]>; Stephen Greer<[e-mail]>
Subject: RE: [External] IP Riegelwood's Response to Draft NPDES Stormwater Permit NCS000101
Good afternoon,
Thank you for providing this information. I apologize for the delayed response as I was out of the office last week. I will
reach out with any other questions once I complete my review of the comments received.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
**DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th. Employee email addresses may look
different, but email performance will not be impacted.
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From: Wallace H Coverdale<[e-mail]>
Sent:Tuesday, August 8, 2023 2:45 PM
To:Young, Brianna A<[e-mail]>
Cc: Colleen Cohn<[e-mail]>; Stephen Greer<[e-mail]>
Subject: RE: [External] IP Riegelwood's Response to Draft NPDES Stormwater Permit NCS000101
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Hi, Brianna, please see the responses to your questions below.
2

Regarding Drainage Basin F:
The permit renewal application received May 2019 identified 2 outfalls for Basin F (F1 and F2),with F2 having been
removed. Please confirm the correct nomenclature for these outfalls. Basin F has outfalls F and F1. F2 is no longer
active.
Regarding Drainage Basin G:
The permit renewal application received May 2019 identified 3 outfalls for Basin G, with Basin G3 having been removed.
Please confirm the correct nomenclature for these outfalls. Basin G includes Outfalls G, G1, and G2. G3 is obsolete.
Regarding Drainage Basin L:
Per information provide with the permit renewal application,the drainage area consists of parking for trailers
transporting finished products. Are there any other industrial activities that occur in the drainage area? No,only trailer
parking.
We are working on updating the SWPPP map descriptions to provide a little more clarity for basins with multiple
outfalls, and will incorporate those revisions in the next annual SWPPP update.
If we can provide further clarity, please reach out. If possible, we would like to comment on permit drafts before
issuance. Thank you, Wallace Coverdale
From:Young, Brianna A<[e-mail]>
Sent:Thursday,July 27, 2023 3:51 PM
To: Colleen Cohn <[e-mail]>
Cc:Wallace H Coverdale<[e-mail]>; Kevin Driscoll <[e-mail]>;Tim D Gill
<[e-mail]>; Stephen Greer<[e-mail]>
Subject: RE: [External] IP Riegelwood's Response to Draft NPDES Stormwater Permit NCS000101
Good afternoon,
After reviewing all the comments submitted, I have a few follow-up questions:
Regarding Drainage Basin F:
The permit renewal application received May 2019 identified 2 outfalls for Basin F (F1 and F2),with F2 having been
removed. Please confirm the correct nomenclature for these outfalls.
Regarding Drainage Basin G:
The permit renewal application received May 2019 identified 3 outfalls for Basin G, with Basin G3 having been removed.
Please confirm the correct nomenclature for these outfalls.
Regarding Drainage Basin L:
Per information provide with the permit renewal application,the drainage area consists of parking for trailers
transporting finished products. Are there any other industrial activities that occur in the drainage area?
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
3

[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
**DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th. Employee email addresses may look
different, but email performance will not be impacted.
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From:Young, Brianna A
Sent:Thursday,July 13, 2023 4:09 PM
To: Colleen Cohn <[e-mail]>
Cc:Wallace H Coverdale<[e-mail]>; Kevin Driscoll <[e-mail]>;Tim D Gill
<[e-mail]>; Stephen Greer<[e-mail]>
Subject: RE: [External] IP Riegelwood's Response to Draft NPDES Stormwater Permit NCS000101
Good afternoon,
Thank you for submitting comments on the draft permit. Once the comment period closes, I will review all comments
received and reach out with any questions.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
**DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th. Employee email addresses may look
different, but email performance will not be impacted.
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From: Colleen Cohn <[e-mail]>
Sent:Thursday,July 13, 2023 3:04 PM
To:Young, Brianna A<[e-mail]>
Cc:Wallace H Coverdale<[e-mail]>; Kevin Driscoll <[e-mail]>;Tim D Gill
4

<[e-mail]>; Stephen Greer<[e-mail]>
Subject: [External] IP Riegelwood's Response to Draft NPDES Stormwater Permit NCS000101
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good afternoon,
International Paper's Riegelwood Mill appreciates the opportunity to review and provide initial comments on the draft
NPDES Stormwater Permit for our facility (NCS0001010). Please find attached a scanned copy of International Paper—
Riegelwood's comments.A hard copy will be mailed today via Certified Mail 7018 0680 0002 0722 5587.
We respectfully request the opportunity to review a second draft that addresses our comments prior to final issuance of
our permit. If you have any questions or need additional information, please contact Wallace Coverdale
([e-mail]) or myself([e-mail]) at your convenience.
Thank you, and have a wonderful day!
Colleen Cohn
Sr. Environmental Engineer-Wastewater
Riegelwood Mill
colleen.cohn(aNpaper.com
T 9103623339
M 9107893545
rr-ar IrttBrrtiOrla<I
ww Paper
international paper.com
Follow us on Facebook,Twitter, Instagram and Linkedln.
This message and any attachments are intended solely for the addressees and are confidential.If you
receive this message in error,please delete it and immediately notify the sender.Any use not in accord
with its purpose,any dissemination or disclosure,either whole or partial,is prohibited except following
formal approval. The internet cannot guarantee the integrity of this message.International Paper shall
not,therefore,be liable for the message if modified.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
5

Young, Brianna A
From: Wallace H Coverdale <[e-mail]>
Sent: Tuesday, August 8, 2023 2:45 PM
To: Young, Brianna A
Cc: Colleen Cohn; Stephen Greer
Subject: RE: [External] IP Riegelwood's Response to Draft NPDES Stormwater Permit NCS000101
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Hi, Brianna, please see the responses to your questions below.
Regarding Drainage Basin F:
The permit renewal application received May 2019 identified 2 outfalls for Basin F (F1 and F2),with F2 having been
removed. Please confirm the correct nomenclature for these outfalls. Basin F has outfalls F and F1. F2 is no longer
active.
Regarding Drainage Basin G:
The permit renewal application received May 2019 identified 3 outfalls for Basin G, with Basin G3 having been removed.
Please confirm the correct nomenclature for these outfalls. Basin G includes Outfalls G, G1, and G2. G3 is obsolete.
Regarding Drainage Basin L:
Per information provide with the permit renewal application,the drainage area consists of parking for trailers
transporting finished products. Are there any other industrial activities that occur in the drainage area? No,only trailer
parking.
We are working on updating the SWPPP map descriptions to provide a little more clarity for basins with multiple
outfalls, and will incorporate those revisions in the next annual SWPPP update.
If we can provide further clarity, please reach out. If possible, we would like to comment on permit drafts before
issuance. Thank you, Wallace Coverdale
From:Young, Brianna A<[e-mail]>
Sent:Thursday,July 27, 2023 3:51 PM
To: Colleen Cohn <[e-mail]>
Cc:Wallace H Coverdale<[e-mail]>; Kevin Driscoll <[e-mail]>;Tim D Gill
<[e-mail]>; Stephen Greer<[e-mail]>
Subject: RE: [External] IP Riegelwood's Response to Draft NPDES Stormwater Permit NCS000101
Good afternoon,
After reviewing all the comments submitted, I have a few follow-up questions:
Regarding Drainage Basin F:
The permit renewal application received May 2019 identified 2 outfalls for Basin F (F1 and F2),with F2 having been
removed. Please confirm the correct nomenclature for these outfalls.
1

Regarding Drainage Basin G:
The permit renewal application received May 2019 identified 3 outfalls for Basin G, with Basin G3 having been removed.
Please confirm the correct nomenclature for these outfalls.
Regarding Drainage Basin L:
Per information provide with the permit renewal application,the drainage area consists of parking for trailers
transporting finished products. Are there any other industrial activities that occur in the drainage area?
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
**DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th. Employee email addresses may look
different, but email performance will not be impacted.
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From:Young, Brianna A
Sent:Thursday,July 13, 2023 4:09 PM
To: Colleen Cohn <[e-mail]>
Cc:Wallace H Coverdale<[e-mail]>; Kevin Driscoll <[e-mail]>;Tim D Gill
<[e-mail]>; Stephen Greer<[e-mail]>
Subject: RE: [External] IP Riegelwood's Response to Draft NPDES Stormwater Permit NCS000101
Good afternoon,
Thank you for submitting comments on the draft permit. Once the comment period closes, I will review all comments
received and reach out with any questions.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
**DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th. Employee email addresses may look
different, but email performance will not be impacted.
2

919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From: Colleen Cohn <[e-mail]>
Sent:Thursday,July 13, 2023 3:04 PM
To:Young, Brianna A<[e-mail]>
Cc:Wallace H Coverdale <[e-mail]>; Kevin Driscoll <[e-mail]>;Tim D Gill
<[e-mail]>; Stephen Greer<[e-mail]>
Subject: [External] IP Riegelwood's Response to Draft NPDES Stormwater Permit NCS000101
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good afternoon,
International Paper's Riegelwood Mill appreciates the opportunity to review and provide initial comments on the draft
NPDES Stormwater Permit for our facility (NCS0001010). Please find attached a scanned copy of International Paper—
Riegelwood's comments.A hard copy will be mailed today via Certified Mail 7018 0680 0002 0722 5587.
We respectfully request the opportunity to review a second draft that addresses our comments prior to final issuance of
our permit. If you have any questions or need additional information, please contact Wallace Coverdale
([e-mail]) or myself([e-mail]) at your convenience.
Thank you, and have a wonderful day!
Colleen Cohn
Sr. Environmental Engineer-Wastewater
Riegelwood Mill
colleen.cohn(aNpaper.com
T 9103623339
M 9107893545
Iriternatianal
row
1Wr Paper
i nternationaIPa per.com
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receive this message in error,please delete it and immediately notify the sender.Any use not in accord
with its purpose,any dissemination or disclosure,either whole or partial,is prohibited except following
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not, therefore,be liable for the message if modified.
3

Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
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4

International
Www
Raper
RECEIVED
7023 RIEGELWOOD MILL
JOHN L.RIEGEL ROAD
`OYl�lb� '2t Nogram RIEGELWOOD,NC 28456
PHONE [phone]
July 12, 2023
Ms. Brianna Young
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC Department of Environmental Quality—DEMLR
1612 Mail Service Center
Raleigh,NC 27699-1612
Certified Mail: 7018 0680 0002 0722 5587
Subject: Draft Permit Comments
International Paper—Riegelwood Mill
NPDES Stormwater Permit NCS000101
Dear Ms. Young:
International Paper's Riegelwood Mill (IP-Riegelwood) appreciates the opportunity to review
and provide initial comments on the draft NPDES stormwater permit for our facility, which
was received electronically on June 14, 2023. This submission should be considered timely as
it is being submitted within 30 days of receipt of the draft permit. Our comments are outlined
below.
Draft Permit Cover Letter
1. To streamline communications, we respectfully request that all correspondence related
to IP-Riegelwood's stormwater permit be directed to Kevin Driscoll, Riegelwood Mill
Manager, rather than Hunter Whiteley, Vice President of Manufacturing for IP's Global
Cellulose Fibers Division. Mr. Driscoll has been delegated signatory authority for IP-
Riegelwood's stormwater permit and should be the primary recipient of correspondence
related to this permit. Please continue to copy Ms. Wallace Coverdale and include Ms.
Colleen Cohn on any stormwater-related correspondence.
2. Item 2 of the cover letter notes that units of measure for several benchmarks have been
changed from mg/L to µg/L. Please specify which benchmarks have been updated, as
this was not readily apparent during our permit review.
3. Item 7 does not include Basin L, which was also removed from the permit per
information submitted with the permit application.
4. Item 8 notes that Basin M is being separated from the other basins for additional
monitoring. Our rationale for not including this basin for additional monitoring is
outlined later in this letter.

Ms. Brianna Young
NC Department of Environmental Quality—DEMLR
Page 2
5. Second page, first paragraph: It is our understanding from the Wilmington Regional
Office's (WiRO) DEMLR section that representative outfall status (ROS) is to be self-
certified on an annual basis,that no additional forms are required to be submitted to the
Department if there is no change in ROS and that ROS carries over from permit to
permit(unless changes are required). For analytical monitoring purposes, IP-
Riegelwood will continue to monitor Basins B, E, and I as representative outfalls.
Draft Permit
1. Location Map (page 6): The Cape Fear River should be included as an additional
receiving stream.
2. C-2 Qualitative Monitoring Response (b): IP-Riegelwood requests that this
requirement be expanded to include electronic and hard copy records.
3. D-I Required Baseline Monitoring (b): IP-Riegelwood requests that this condition be
clarified to include only the average oil usage individually for the chip dumps in Basins
C and E. Other activities on-site that involve motor and hydraulic oil are conducted in
areas that drain directly to the wastewater treatment system(WTS) and should not be
included in this permit condition.
4. Table I description:
a. Basin L should be removed from this listing,per information submitted with the
permit application.
b. IP-Riegelwood requests that a footnote be added to this table denoting that Basins
B, E, and I are representative outfalls for the remaining basins except for Basin T.
c. General Comment: IP-Riegelwood requests that the numbering of the stormwater
outfalls throughout the permit be revised to reflect letters rather than numbers, e.g.
Outfall A, rather than Outfall SW001. IP-Riegelwood has historically referred to
outfalls in this manner and prefers that this nomenclature be continued.
5. Table 1 rows:
a. Row 4: IP-Riegelwood requests clarification on the averaging period for drainage
areas where greater than 55 gallons of oil per month could be used.
b. Row 5: IP-Riegelwood requests that this condition be clarified to only include the
type(s) of oil that are normally used in Basins C and E for the chip dumps. Other
activities on-site that involve various types of oil (hydraulic, lube, motor, fuel oil,
etc.) are conducted in areas that drain directly to the WTS and should not be
included in this permit condition.

Y
d
Ms. Brianna Young
NC Department of Environmental Quality—DEMLR
Page 3
6. Table ]footnotes:
a. General Comment: As noted previously, IP-Riegelwood requests that the
numbering of the stormwater outfalls in this footnote section be revised to reflect
letters rather than numbers, e.g. Outfall A, rather than Outfall SW00L
b. General Comment: IP-Riegelwood also asks that each bullet in this footnote
section be re-formatted in the following manner to describe each drainage basin:
"Basin A (Outfall A): Drainage area consists of oil barge unloading, oil unloading
pipeline and mill access road."
c. Outfall SW001 (Basin A): This area does include the oil barge unloading area and
associated pipeline; however,No. 6 fuel oil has not been received by barge since
2015 and the pipeline is maintained in caretaker status. IP-Riegelwood currently
receives all No. 6 fuel oil by truck in an area that drains to the WTS, and there are
no future plans to receive fuel oil via barge.
d. Outfall SW002 (Basin B): All chemical storage and feed equipment is contained in
secondary containment that drains to the WTS.
e. Outfall SW006 (Basin F1): IP-Riegelwood requests that the description for Basin
F be modified to include two outfalls, Outfalls F and F L This bullet incorrectly
identifies the basin as Basin F1.
f. Outfall SW008 (Basin G1) and Outfall SW009 (Basin G2): IP-Riegelwood
requests that the description for Basin G be modified to include three outfalls,
Outfalls G, G1, and G2. These bullets incorrectly identify the basins as Basins G1
and G2.
g. Outfall SW015 (Basin L): Basin L should be deleted from this listing, per
information submitted with the permit application.
h. Outfall SW018 (Basin O): All chemical storage is contained in secondary
containment that drains to the WTS.
7. Table 2: IP-Riegelwood respectfully requests that Basin M be removed from the draft
permit for all quantitative monitoring. The methanol tank and unloading area are
located south of the roadway outside and east of the contractor gate; drainage areas
south of this roadway are currently routed to a grassy swale that leads to the WTS. The
containment for the methanol tank is also routed to the WTS. IP-Riegelwood employs
a formal unloading checklist and procedure for the methanol tank (as well as other bulk
tanks on-site) that include the following best management practices (BMPs)to mitigate
releases:
® The gate attendant contacts the IP-Riegelwood unloading point contact to
meet the truck at the delivery point and reviews the safety instructions with
the driver. Both the gate attendant and driver initial the safety instruction
section(Part 1) of the permit.
® The driver proceeds to the delivery point with a copy of the bulk unloading
permit to meet the IP-Riegelwood unloading point contact. In the case of
the methanol tank, the primary IP-Riegelwood unloading point contact is the
Bulk Chemical Unloader, who oversees all chemical deliveries for the pulp
mill area.

r
Ms. Brianna Young
NC Department of Environmental Quality—DEMLR
Page 4
• The IP-Riegelwood unloading point contact reviews Part 2 of the unloading
permit with the delivery driver, confirms the transfer hose is not damaged,
there is adequate tank volume to accept the delivery, and adequate safety
measures are in place to protect the driver and to prevent a release. Both the
IP-Riegelwood unloading point contact and the driver initial Part 2 of the
unloading permit prior to starting the unloading process. The driver is
required to remain with the truck during the entire unloading process.
• Following successful unloading,the IP-Riegelwood unloading point contact
and the driver inspect for any signs of leakage at the unloading point,
confirm that valves have been returned to their original positions (and
locked if required) and confirm that the unloading process was completed in
a safe manner. Both the IP-Riegelwood unloading point contact and the
driver initial Part 3 of the unloading permit prior to the truck disconnecting
and departing the unloading area.
• Prior to departing the Mill site, the driver returns to the access gate. The
gate attendant confirms that the unloading permit has been completed
appropriately and that there is no visible leakage beneath the truck or at the
valves (Part 4 of the permit). Once Part 4 is initialed by the driver and the
gate attendant, the delivery driver may depart from the Mill site, with the
gate attendant maintaining the completed permit.
Please note that all subsequent comments related to table numbering may be
disregarded if Table 2 is omitted from the draft permit. IP-Riegelwood also requests
that the outfall associated with Basin M be referred to as Outfall M, rather than Outfall
SW016.
8. Additional Outfalls (page 1 S): As noted previously in this letter, IP-Riegelwood
requests that Basin L be included in the listing of basins to be removed from this
permit.
9. D-S Tier One Response: Single Benchmark Exceedance:
a. IP-Riegelwood requests that language be added to this condition specifying that an
outfall enters Tier 1 status by exceeding a single benchmark parameter on one
occasion.
b. (a) and(d): These requirements should reference Table 3, rather than Table 2.
10. D-6 Tier Two Response: Two Consecutive Benchmark Exceedances
a. (d): IP-Riegelwood requests that the first sentence of this requirement be reworded
as follows: "Two consecutive exceedances of a single benchmark parameter at a
single outfall shall constitute an event that requires a Tier Two response."

Ms. Brianna Young
NC Department of Environmental Quality—DEMLR
Page 5
b. (d): IP-Riegelwood requests clarification as to the meaning of the last sentence in
this condition: "Subsequent events shall not include the same exceedances that
have been addressed in a Tier Two response."
c. (a) and(e): These requirements should reference Table 4, rather than Table 3.
11. D-7 Tier Three Response: Four Benchmark Exceedances Within 5 Years
a. Section Title and(a): IP-Riegelwood requests that the 5-year period be more
specifically defined as the 5-year permit term.
b. IP-Riegelwood requests clarification as to whether events that have been addressed
in Tier One or Tier Two responses should count towards the four exceedances
tallied for a Tier Three response.
c. (a) and 69: These requirements should reference Table 5, rather than Table 4.
12. E-1 Deadlines for Submittal of Discharge Monitoring Reports
a. This requirement should reference Table 6, rather than Table 5.
b. The first quarterly monitoring period should be from January 1 —March 31. rather
than March 3 0.
c. Table 6: IP-Riegelwood requests clarification on inconsistencies between the Table
6 deadlines and Condition E-4, which requires that the facility submit sampling
results no later than 30 days from the date the facility receives the sampling results.
For example, if a facility takes its first quarterly sample on March 31 but does not
receive the results until May 1, is the first quarter DMR due on May 31,rather than
April 30? In contrast, if the first quarterly sample is taken on January 1 and sample
results are received on February 1, is the first quarter DMR due on March 2, rather
than April 30?
13. Part F.• Other Occurrences that Must be Reported
a. Please correct the spelling of"Occurrences" in the section heading.
b. The first paragraph of this section references Table 6, rather than Table 7.
14. H-6. Required Notice for Bypass or Upset: The first paragraph of this section
references Table 7, rather than Table 8.

Ms. Brianna Young
NC Department of Environmental Quality—DEMLR
Page 6
Thank you again for the opportunity to provide comments on this draft permit. We request the
opportunity to review a second draft that addresses our comments prior to final issuance of our
permit. If you have questions or need additional information regarding the information in this
submittal,please contact Wallace Coverdale (910/362-4590,wallace.coverdalegipaper.com)
or Colleen Cohn(910/362-3339,colleen.cohn(c�r�,ipaper.com) at your convenience.
c
Sincerely,
Kevin Driscoll
Mill Manager

Young, Brianna A
From: Colleen Cohn <[e-mail]>
Sent: Thursday,July 13, 2023 3:04 PM
To: Young, Brianna A
Cc: Wallace H Coverdale; Kevin Driscoll; Tim D Gill; Stephen Greer
Subject: [External] IP Riegelwood's Response to Draft NPDES Stormwater Permit NCS000101
Attachments: IP Riegelwood Response to Draft Stormwater NPDES Permit NCS000101_07.12.23.pdf
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good afternoon,
International Paper's Riegelwood Mill appreciates the opportunity to review and provide initial comments on the draft
NPDES Stormwater Permit for our facility (NCS0001010). Please find attached a scanned copy of International Paper—
Riegelwood's comments.A hard copy will be mailed today via Certified Mail 7018 0680 0002 0722 5587.
We respectfully request the opportunity to review a second draft that addresses our comments prior to final issuance of
our permit. If you have any questions or need additional information, please contact Wallace Coverdale
([e-mail]) or myself([e-mail]) at your convenience.
Thank you, and have a wonderful day!
Colleen Cohn
Sr. Environmental Engineer-Wastewater
Riegelwood Mill
colleen.cohn(aMpaper.com
T 9103623339
M 9107893545
§FV06 IrAernatiorxal
ww Paper
international paper.com
Follow us on Facebook,Twitter, Instagram and Linkedln.
This message and any attachments are intended solely for the addressees and are confidential.If you
receive this message in error,please delete it and immediately notify the sender.Any use not in accord
with its purpose,any dissemination or disclosure,either whole or partial,is prohibited except following
formal approval. The internet cannot guarantee the integrity of this message.International Paper shall
not,therefore,be liable for the message if modified.
1

Ei International
ww. Paper
RIEGELWOOD MILL
JOHN L.RIEGEL ROAD
RIEGELWOOD,NC 28456
PHONE [phone]
July 12, 2023
Ms. Brianna Young
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC Department of Environmental Quality—DEMLR
1612 Mail Service Center
Raleigh,NC 27699-1612
Certified Mail: 7018 0680 0002 0722 5587
Subject: Draft Permit Comments
International Paper—Riegelwood Mill
NPDES Stormwater Permit NCS000101
Dear Ms. Young:
International Paper's Riegelwood Mill {IP-Riegelwood} appreciates the opportunity to review
and provide initial comments on the draft NPDES Stormwater permit for our facility, which
was received electronically on June 14, 2023. This submission should be considered timely as
it is being submitted within 30 days of receipt of the draft permit. Our comments are outlined
below.
Draft Permit Cover Letter
1. To streamline communications, we respectfully request that all correspondence related
to IP-Riegelwood's storm-water permit be directed to Kevin Driscoll, Riegelwood Mill
Manager, rather than Hunter Whiteley, Vice President of Manufacturing for IP's Global
Cellulose Fibers Division. Mr. Driscoll has been delegated signatory authority for IP-
Riegelwood's stormwater pen-nit and should be the primary recipient of correspondence
related to this permit. Please continue to copy Ms. Wallace Coverdale and include Ms.
Colleen Cohn on any stormwater-related correspondence.
2. Item 2 of the cover letter notes that units of measure for several benchmarks have been
changed from mg/L to pg/L. Please specify which benchmarks have been updated, as
this was not readily apparent during our permit review.
3. Item 7 does not include Basin L, which was also removed from the permit per
information submitted with the permit application.
4. Item 8 notes that Basin M is being separated from the other basins for additional
monitoring. Our rationale for not including this basin for additional monitoring is
outlined later in this letter.

Ms. Brianna Young
NC Department of Environmental Quality—DEMLR
Page 2
5. Second page, first paragraph: It is our understanding from the Wilmington Regional
Office's (WiRO) DEMLR section that representative outfall status (ROS) is to be self-
certified on an annual basis, that no additional forms are required to be submitted to the
Department if there is no change in ROS and that ROS carries over from permit to
permit(unless changes are required). For analytical monitoring purposes, IP-
Riegelwood will continue to monitor Basins B, E, and I as representative outfalls.
Draft Permit
1. Location Map (page 6): The Cape Fear River should be included as an additional
receiving stream.
2. C-2 Qualitative Monitoring Response (b): IP-Riegelwood requests that this
requirement be expanded to include electronic and hard copy records.
3. D-I Required Baseline Monitoring(b): IP-Riegelwood requests that this condition be
clarified to include only the average oil usage individually for the chip dumps in Basins
C and E. Other activities on-site that involve motor and hydraulic oil are conducted in
areas that drain directly to the wastewater treatment system(WTS) and should not be
included in this permit condition.
4. Table I description:
a. Basin L should be removed from this listing,per information submitted with the
permit application.
b. IP-Riegelwood requests that a footnote be added to this table denoting that Basins
B, E, and I are representative outfalls for the remaining basins except for Basin T.
c. General Comment: IP-Riegelwood requests that the numbering of the stormwater
outfalls throughout the permit be revised to reflect letters rather than numbers, e.g.
Outfall A, rather than Outfall SW00L IP-Riegelwood has historically referred to
outfalls in this manner and prefers that this nomenclature be continued.
5. Table I rows:
a. Row 4: IP-Riegelwood requests clarification on the averaging period for drainage
areas where greater than 55 gallons of oil per month could be used.
b. Row 5: IP-Riegelwood requests that this condition be clarified to only include the
type(s) of oil that are normally used in Basins C and E for the chip dumps. Other
activities on-site that involve various types of oil (hydraulic, lube, motor, fuel oil,
etc.) are conducted in areas that drain directly to the WTS and should not be
included in this permit condition.

Ms. Brianna Young
NC Department of Environmental Quality—DEMLR
Page 3
6. Table ]footnotes:
a. General Comment: As noted previously, IP-Riegelwood requests that the
numbering of the stormwater outfalls in this footnote section be revised to reflect
letters rather than numbers, e.g. Outfall A, rather than Outfall SW001.
b. General Comment: IP-Riegelwood also asks that each bullet in this footnote
section be re-formatted in the following manner to describe each drainage basin:
"Basin A (Outfall A): Drainage area consists of oil barge unloading, oil unloading
pipeline and mill access road."
c. Outfall SW001 (Basin A): This area does include the oil barge unloading area and
associated pipeline; however,No. 6 fuel oil has not been received by barge since
2015 and the pipeline is maintained in caretaker status. IP-Riegelwood currently
receives all No. 6 fuel oil by truck in an area that drains to the WTS, and there are
no future plans to receive fuel oil via barge.
d. Outfall SWO02 (Basin B): All chemical storage and feed equipment is contained in
secondary containment that drains to the WTS.
e. Outfall SWO06 (Basin F1): IP-Riegelwood requests that the description for Basin
F be modified to include two outfalls, Outfalls F and F1. This bullet incorrectly
identifies the basin as Basin F1.
f Outfall SWO08 (Basin G1) and Outfall SWO09 (Basin G2): IP-Riegelwood
requests that the description for Basin G be modified to include three outfalls,
Outfalls G, G1, and G2. These bullets incorrectly identify the basins as Basins G1
and G2.
g. Outfall SW015 (Basin L): Basin L should be deleted from this listing, per
information submitted with the permit application.
h. Outfall SWO18 (Basin O): All chemical storage is contained in secondary
containment that drains to the WTS.
7. Table 2: IP-Riegelwood respectfully requests that Basin M be removed from the draft
permit for all quantitative monitoring. The methanol tank and unloading area are
located south of the roadway outside and east of the contractor gate; drainage areas
south of this roadway are currently routed to a grassy swale that leads to the WTS. The
containment for the methanol tank is also routed to the WTS. IP-Riegelwood employs
a formal unloading checklist and procedure for the methanol tank(as well as other bulk
tanks on-site) that include the following best management practices (BMPs) to mitigate
releases:
• The gate attendant contacts the IP-Riegelwood unloading point contact to
meet the truck at the delivery point and reviews the safety instructions with
the driver. Both the gate attendant and driver initial the safety instruction
section (Part 1) of the permit.
• The driver proceeds to the delivery point with a copy of the bulk unloading
permit to meet the IP-Riegelwood unloading point contact. In the case of
the methanol tank,the primary IP-Riegelwood unloading point contact is the
Bulk Chemical Unloader, who oversees all chemical deliveries for the pulp
mill area.

Ms. Brianna Young
NC Department of Environmental Quality—DEMLR
Page 4
• The IP-Riegelwood unloading point contact reviews Part 2 of the unloading
permit with the delivery driver, confirms the transfer hose is not damaged,
there is adequate tank volume to accept the delivery, and adequate safety
measures are in place to protect the driver and to prevent a release. Both the
IP-Riegelwood unloading point contact and the driver initial Part 2 of the
unloading permit prior to starting the unloading process. The driver is
required to remain with the truck during the entire unloading process.
• Following successful unloading, the IP-Riegelwood unloading point contact
and the driver inspect for any signs of leakage at the unloading point,
conf rni that valves have been returned to their original positions (and
locked if required) and confirm that the unloading process was completed in
a safe mariner. Both the IP-Riegelwood unloading point contact and the
driver initial Part 3 of the unloading permit prior to the truck disconnecting
and departing the unloading area.
• Prior to departing the Mill site,the driver returns to the access gate. The
gate attendant confirms that the unloading permit has been completed
appropriately and that there is no visible leakage beneath the truck or at the
valves (Part 4 of the permit). Once Part 4 is initialed by the driver and the
gate attendant, the delivery driver may depart from the Mill site, with the
gate attendant maintaining the completed permit.
Please note that all subsequent comments related to table numbering may be
disregarded if Table 2 is omitted from the draft permit. IP-Riegelwood also requests
that the outfall associated with Basin M be referred to as Outfall M,rather than Outfall
SW016.
8. Additional Outfalls (page 15): As noted previously in this letter, IP-Riegelwood
requests that Basin L be included in the listing of basins to be removed from this
permit.
9. D-5 Tier One Response: Single Benchmark Exceedance:
a. IP-Riegelwood requests that language be added to this condition specifying that an
outfall enters Tier 1 status by exceeding a single benchmark parameter on one
occasion.
b. (a) and(d): These requirements should reference Table 3,rather than Table 2.
10. D-6 Tier Two Response: Two Consecutive Benchmark Exceedances
a. (d): IP-Riegelwood requests that the first sentence of this requirement be reworded
as follows: "Two consecutive exceedances of a single benchmark parameter at a
single outfall shall constitute an event that requires a Tier Two response."

Ms. Brianna Young
NC Department of Environmental Quality—DEMLR
Page 5
b. (d): IP-Riegelwood requests clarification as to the meaning of the last sentence in
this condition: "Subsequent events shall not include the same exceedances that
have been addressed in a Tier Two response."
c. (a) and(e): These requirements should reference Table 4,rather than Table 3.
11. D-7 Tier Three Response: Four Benchmark Exceedances Within 5 Years
a. Section Title and(a): IP-Riegelwood requests that the 5-year period be more
specifically defined as the 5-year permit term.
b. IP-Riegelwood requests clarification as to whether events that have been addressed
in Tier One or Tier Two responses should count towards the four exceedances
tallied for a Tier Three response.
c. (a) and 0: These requirements should reference Table 5,rather than Table 4.
12. E-1 Deadlines for Submittal of Discharge Monitoring Reports
a. This requirement should reference Table 6, rather than Table 5.
b. The first quarterly monitoring period should be from January 1 —March 31, rather
than March 30.
c. Table 6: IP-Riegelwood requests clarification on inconsistencies between the Table
6 deadlines and Condition E-4, which requires that the facility submit sampling
results no later than 30 days from the date the facility receives the sampling results.
For example, if a facility takes its first quarterly sample on March 31 but does not
receive the results until May 1, is the first quarter DMR due on May 31, rather than
April 30? In contrast, if the first quarterly sample is taken on January 1 and sample
results are received on February 1, is the first quarter DMR due on March 2, rather
than April 30?
13.Part F.- Other Occurrences that Must be Reported
a. Please correct the spelling of"Occurrences" in the section heading.
b. The first paragraph of this section references Table 6, rather than Table 7.
14. H-6. Required Notice for Bypass or Upset: The first paragraph of this section
references Table 7, rather than Table 8.

Ms. Brianna Young
NC Department of Environmental Quality—DEMLR
Page 6
Thank you again for the opportunity to provide comments on this draft permit. We request the
opportunity to review a second draft that addresses our comments prior to final issuance of our
permit. If you have questions or need additional information regarding the information in this
submittal, please contact Wallace Coverdale (910/362-4590, wallace.coverdale(c�r�,ipaper.com)
or Colleen Cohn(910/362-3339,colleen.cohnPipaper.com) at your convenience.
Sincerely,
Kevin Driscoll
Mill Manager

INTERNATIONAL PAPER
RIEGELWOOD MILL
JOHN L. RIEGEL ROAD
RIEGELWOOD,NC 28456
PHONE [phone]
March 22, 2023
Ms. Brianna Young RECEIVED
Industrial Individual Permits Coordinator
Stormwater Permitting Program MAR 2 8 2013
NC Department of Environmental Quality- DEMLR
1 DEMLR-Stormwaler Program
612 Mail Service Center
Raleigh, NC 27699-1612
Certified Mail: 7018 0680 0002 0722 5747
Subject: Additional information request for stormwater permit renewal
International Paper—Riegelwood Mill
NPDES Permit NCS000101
Dear Ms. Young:
Enclosed is the requested updated information for International Paper's (IP's) renewal
., application for NPDES Stormwater Permit Number NCS000101. IP's renewal application was
submitted to NC DEQ DEMLR on May 15, 2019, which was within 180 days of the permit
expiration date of November 30, 2019. With the submission of a timely renewal application,
IP has continued to operate under the expired permit in accordance with permit condition B.1.
DEQ Request for Supplemental.information (2023)
Per your e-mail requests dated January 31 and February 8, 2023, IP has prepared the following
information:
• Attachment A: Mill Plot Plan— Stormwater Basins. The enclosed stormwater basin
map includes the number of outfalls, outfall coordinates, and a description of industrial
activities that occur in each drainage area.
0 Attachment B: Summary of monitoring data that has been collected since the last
permit issuance (December 1, 2014). Please note that quantitative and qualitative
monitoring data from 2015-2019 was submitted with the original permit renewal
application (May 2019), with supplemental information provided in correspondence
dated January 21, 2020 that included second semester 2019. We are enclosing a copy
of the previous January 2020 correspondence for ease of reference, in addition to a
summary of the quantitative and qualitative monitoring data from. 2020-2022.
• Attachment C: Updated SWPPP Certification
The Mill's SIC code is 2611. No Mill operational changes that could impact stormwater
operations have been implemented since the renewal application was submitted in May 2019.

Upon review of the 2019 renewal application,we believe that the information in this renewal
application is still complete and correct.
In response to your question concerning Basin 1, Basin 1 was related to a construction project
to build a wet wood storage area adjacent to the Mill and was temporarily named as a mill
stormwater outfall in 2007. After construction was completed,the wet wood storage facility
was issued a non-discharge permit by NC DEQ. Cape Fear Woodyard manages this area and
the associated non-discharge permit.
OuViall Monitoring and Corrective Actions
IP has undertaken ongoing,proactive measures since the issuance of the current permit in 2014
to meet its obligations under permit NCS000101 for 20 outfalls. Some of these measures
include,but are not limited to:
• Intensive housekeeping in high traffic and raw material storage areas by Mill personnel
and outside contractors;
• Camera inspections of stormwater conveyance piping to assess integrity;
• Repair, replacement, and cleaning of stormwater drainage piping, catch basins, and
other structural features, as required; and
• Re-shaping of drainage patterns in stormwater basins and installation of pavement,
where appropriate.
IP documented corrective actions throughout the permit term in its semiannual DMR
submittals to NC DEQ, as well as supplemental correspondence to DEQ. At IP's request,DEQ r
representatives visited the Mill on several occasions during the permit term to address
questions regarding tiered status of outfalls. During a May 2018 inspection,NC DEQ's
Wilmington Regional Office relieved Basins B and E of Tier 2 requirements due to proactive
repairs and housekeeping to resolve quality issues; it is our understanding that DEQ's release
documentation for these two outfalls remains in effect through subsequent reissuance of the
permit, as no additional conditions were noted in the inspection report besides continued
housekeeping. In addition, IP requested that NC DEQ consider sampling prior to May 2018
for Basin I as a completed and closed event due to repairs to an underground stormwater
conveyance and plans to assess the integrity of the piping;NC DEQ agreed with this plan of
action. Basin T was added to the Mill's SWPPP in 2015, and IP began discussing intermittent
quality issues at this outfall with local and state DEMLR staff in mid-2015,with continued
housekeeping being the primary recommendation for this area during the permit term. Basin T
entered Tier 2 status in first semester 2019,and monthly sampling has continued since that
time. The Mill is currently evaluating the use of different technologies and best management
practices (BMPs)to effectively meet COD and TSS benchmarks for Basin T.
IP would appreciate the opportunity to review and provide comments on a draft permit from
your section, once available. If you have questions or need additional information,please
contact Wallace Coverdale of my staff at(910) 362-4590.
i''1

I certify, under penalty of law, that this document and all attachments were prepared under my
-�� direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry of the
person or persons who manage the system, or those persons directly responsible for gathering
the information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false
information, including the possibility of fines and imprisonment for knowing violations.
Sincerel ,
Kevin Driscoll
Mill Manager

ATTACHMENT A
MILL PLOT PLAN-STORMWATER BASINS
I''`1

NUMBER
OF COORDINATES
BASIN OUTFALLS OF OUTFALLS BASIN DESCRIPTIONS POSSIBLE POLLUTANTS BMP's
BAST A IS LOCATED NORTH NORTHEAST OF THE MILL
A I 34'21'25'N SELL EN PIPELINE, GWADE,CATCH BASIN,PIPES,
AM IT COVERS ABOUT 0.24 ACRES OF IL D THAT IS ALL RAVEL RPRAR
78'12'3B'W IMPERVIOUS,AT THE ONLY
WL CENT W DOCK. OIL BARGE SEDIMENT
OCCURUNLOADING A THE ONLY MILL ACTIHAS
THAT BARGED
LD
FUEL
OCCUR IN BASIN T THE MILL HAS NOT BRCED NEL
J-- UNLOADING
SINCE 2G5. THE AREA NE AND A MILEINCLUDESACC THE OE
V RUNOFF PASSES ROUGH A CATCHEARNESS NAAND
UNDERGROUND PIPE UNDER THE FENCEINE,THEN IS
• 1� DHEUCRDE BEER VELLRND NPRAP AS IT SHEETS TO
B I 34'21'19'N BASIN 8 IS LOCATED NORTH NORTHEAST OF THE MILL. PROCESS WATER,WATER S6NAGE CEOFABRIC,RAVEL,
AND IT COVERS ABOUT 0.57 ACRES OF LAND THAT IS 60% TREATMENT CHEMICALS IN PIPE,CONCRETE CULVERT,
78'12'32'W IMPEAAOUS. STRMWATER IS DIRECTED NA A BRASSY CONTAINMENT CONCRETE CONTAINMENT,
SWALE,2 CATCH BASINS,DRAINAGE PIPE AND TWO NON-CORRORME
• CULVERTS.THROUGH A COLLECTION EARN MEN ON SUMP TOO AID; COLLECTION CONITANERS
THROUGH THE WOODS TO THE CAPE FEAR RIVER, THE POD,RIPRAP SLOPES,
AREA CONSISTS OF A RREWATER HOUSE,NO.5 GRASSY SWALE.CATCH
NECK DAM COOLING TOWER,ELECTRICAL CONTROL ROOM CR-94, BASINS, TERRACED SLOPE
AND A MILL ACCESS ROAD. CHEMICAL STORAGE AND
FEED EQUIPMENT FOR CORROSION INHIBITOR IN COOLING
WATER RE STORED IN NON-CORROSIVE CONTAINERS
NORTH CONRETE SITU O MILL I WNTS. MUCH OFRTAI THE AREAS ATPRAPPED DRAINS TO
B
GRAVED. AND SLOPES RE ROCKED OR GRASS.
C 1 34'21'27'N BASIN C IS LOCATED NORTH R R MILL AROUND ME HYDRAULIC OIL N SIGNACE,OE CONTAINMENTS,
AND SNOW HILL(83)CHIP DUMP. IT COVENS ABOUT 1.58 CONTAMENT,WOOD CAMPS PAVEMENT.JERSEY DIMOSS,
A'IV N'W ACRES OF LAND,OF WHICH 40%IS IMPERMOUS. CEOTE%TIIE FABRIC,GRAVEL
STORMWATER IS DIRECTED NA A CONCRETE CULVERT AND ROC(INLET,A CULVERT
AND A DRAINAGE PIPE TO N UNNAMED IR16UTRY OF AND PIPE
THE CAPE FEAR RIVER.SOIL IS REINFORCED WTH
GEOTEXRLE FABRIC COVERED WITH ROCK,AND A ROC(
INLET PROTECTION. INDUSTRIAL ACTVITHES IN THIS
COMPETE AREA ARE UNITED TO TRANSFER AND STORAGE OF
IAUCX RUNWAY
N 0 RAW CHIPS,A WOW CHIP TRUCK DUMPER,AND
A PAVED
MILL ACCESS ROW.TRAFFIC WALL AV CONCRETE
ND
JERSEY T OIL KEEPS ARYOO TA PAVEMENT AND
F/ OF SOFT SOIL SECONDARY RESERVOIR
ROUND
THE TRUCKAULD DUMP RIFT IN BC IN CRECR AND THE
}/Fo © " LOSSES FROM
TRUCK E LIFT IN BASIN C ENSURESRESERVOIR
THAT ANY
LOSSES FROM DF TRUCK LIFT OR RESERVOIR PUMP
RE PREVENTED FROM EOWNG OFF-SIT.;
GRASSY SWALE
V i D 1 31V 21'27*Al BASIN 0 IS LOCATED NORTH OF THE MID,NEXT TO WOOD CHIPS SIGNAGE,CONCRETE SWALE
AND BASINS C&E IT COVERS ABOUT 0.37 ACRES OF AND ROAD,JERSEY DIVIDERS,
78'12'43'W LAND THAT IS APPROXIMATELY 24%IMPERVIOUS. PIPE,GEOTEX71LE CLOTH,
STOR891.9E M WATER IS DIRECTED TO OF THE CAPE FEAR RIVER NA H CONCRETE SW UNNAMED ALE AND
EUTARY RFRAP,SMRDIICi
CULVERT.A PIPE, A SMALL RIPRAPPED SETTLING BASIN,
AND A TRAPEZOIDAL CORRUGATED PLASTIC DITCH
(SMRTATCR).SLOPES ARE PROTECTED WITH GRASS
AND ROCK.
TRIAL ACIATY IN THIS AREA
A DITAMERS DIRECT TRAFFIC TO
ONLAET SURFACE O i S PAVED SURFACES
0 TRNYSERSAND STORAGE OF RAW WOW
A _ GIPS,A FIREWATER HOUSE, AND A PAVED MILL
ACCESS ROAD,
DUNS E 1 34'21'27'N BASIN E IS LOCATED NORM OF THE MILL NEXT TO H1NALUC OL IN S WAGE,CONCETE OIL
AND BASINS 0&F. IT COVERS ABOUT C04 ACRES OF RNTAINMENT,WOOD LIPS CONTAINMENT,CONCRETE
R IS COLLECTION BASK on
CLAR) O O IB'12'4Y W LAND,OF ORE 1ED MAIGHA PIPE AND DRAINAGE CHANNELS iTO THE DRNPPES.RAW.
HOUSE
IC UNNAMED TRIBUTARY CAPE FEAR RIVER. SMRTG7C1,GRASSY SLOPE O
SECONDARY CONTAINMENT SURROUNDS THE TRUCK
DUMP HET. RUC OFF FROM
HE THE HYDRAULIC
7RUD1(LUST. RUNOFF E01.1 THE TRUCK AND MILL
V A, ROAD PASSES THROQ A CONCRETE COLLECTION
BASIN AND AN CL/WATER SEPARATOR(OWS)BEFORE
ENTERING THE DISCHARGE CHANNEL ALL RUNOFF
PASSES THROUGH PIPES AND PLASTIC SMARTOITCH
GUARD CHANNELS THAT EMPTY INTO A SMALL RIPRAPPED
HOUSE SETTLING BASIN BEFORE DISCHARGING THROUGH A
0SECOND SMARTNTCH. R SAMPLING POINT IS JUST
ROVE THE SMARMITCH,AT N UPLEO WELDED ONTO
THE BE ARE UNITED
PIPE INDUSTRIAL ACTNTES IN
G
C /f THIS RED ARE LIMED i0 TRANSFER AM STORAGE OF
0 �\ RAW WOOD CHIP£A WOW CHIP TRUCK DIIMPER,AND
y OrCD„,W�SWATS A PAVED NHL ACCESS ROW,
F 2 34'21'25'N BASIN F IS LOCATED NORTH OF THE WILL.NEXT TO WOOD LIPS,ADJACENT D SIANAGE,CONCRETE SWALE,
�I NO BARNS E AND G. RUNOFF IS SAMPLED ON THE EAST PROCESS WATER PAVEMENT AND U-DRAW,
® OCONCRETE78'12'AB'W AND(VEST SIDES OF THE ROAD. R IS FARTHER WEST, PIPE,RPRAR AND GEOTEXTILE
CONCRETE SWALE NEAR THE POTABLE WATER TANK. BASIN F COVERS FABRIC.SNRIDIT]H PAVED
ABOUT 0.48 ACRES OF LAND AND IS APPROXIMATELY FLOW OPPRM FRENCH
A O I 46%IMPERVIOUS RUNOFF FROM THE SOUTH ROWS DRAIN,RUCK SWINE,CHECK
FLOW CVERTP 34'21'26'N DOWN THE EAST SIDE OF THE ROW IN A CONCRETE DAMS
CON(EE SURFACE WNB O AND SWALE,U-DRN, AND RPRR TO THE TWO SMRTOTCH
Cg1EWEST
CG N BNI IONISE _ 78'12'51°W CHANTONS DON THE OTHERELS ABOVE. SIDE OF THE ROA FROM THE D,
A SMALL SETTLING BASIN,THEN DOWN THE INTAKE
ROAR M}lEC1C5 _ -�� ROW ALONG A ROCKY CANNEL NM STONE
LNED DITCH CREEE SWALE DEFLECTORS, WHO CROSSES THE ROW TO THE
E_- O DISCHARGE POINT AT A PAVED DIVER7ER. OUTFALL A:
RUNOFF FROM THE WET OF CM12 IS
TO DIRECTED THROUGH A GRAAVEL BED AND A FRENCH
V', O DRAW TO A ROC(WALE WITH SEVERAL CHECKDNS
ALONG THE MA DRAINAGE CHANNELS TO N UNNAMED TRIBUENCDUNE. RUNOFF DISCHARGES TE RYH
A PIPE UNDER THE FENCE ALL RUNOFF IS DIRECTED
OF THE CAPE FEAR RIVER. INDUSTRIAL ACTNTES IN
BASIN F ARE UNITED TO A CHIP SCREEN,A MILL
OACCESS ROW,N EtEC7PoCP1 CONTROL ROOM, AND
GOW WATER STORAGE
G 3 34'21-25'N BASIN C IS LOCATED NORTH NORTHWEST OF THE MAIL WOCO M HT RALAX OIL N SGWE CONCRETE
NG AND IT COVERS ABOUT 1.12 ACRES OF LAND,OF WENCH CpITAINBNT,ADJACENT TO OOLUMI KI N BASIN.OWS,
78'12'5P W APPROXIMATELY 20%IS IMPERVIOUS, BASIN G PROCESS WATER PAVED ROADWAY,ROCK SWALE
STORMWATER IS DIECTED NA PIPES AND DRAINAGE WEN ROCK CHOCK DAMS,
H CHANNELS 70 AN UNNAMED TRIBUTARY OF THE CAPE GBIIDNLE CLOT,CONCRETE
FEAR RIVER. OUTFALLS GI AND G2 ARE ALONG THE CALL CONTAINMENTS,PIPES,
WEST FENCEUNE. RUNOFF FOR G1 AND G2 DRAINS AFFAIR.WAVE.
so DAWS
AND WRWGIN ORD DISCHARGE PIPES. LLSWALE YAM ROCKEG3 HAS
BEEN DELETED. INDUSTRIAL ACTINTES IN THIS AREA
ARE LIMITED TO TRANSFER OF RAW WOOD CHIPS,
MAINTE14MCE MATERIAL STORAGE,MILL ACCESS ROWS,
AND RAIL LINES. THE WATER TREATMENT PLANT IS
t) ADJACENT TO BASIN G. RUNOFF FROM THE MILL ROW
AND FAIL AREA COLLECTS IN A CONCRETE COLLECTION
BASN,THEN RUNS THROUGH AN GL/WATER
SEPARATOR AND EATS THE WILL THROUGH A CONCRETE
PPE AT OUTFML G. SECONDARY CONTAINMENT
SURROUNDS THE TRUCK DUMP HYDRAUUC RESERVOIR,
MB R HYDRAULIC TRUCK LIFT.AND THE RAILCAR
ER
NUMBER NUNUMBER HYDRAULIC RESERVOIR. THESE THREE CONTAINMENTS
OF COORDINATES 0.T' COORDINATES OF COORDINATES DRAIN MA U-DRAIN TO THE MILL WINES.
BASH) OUTFALLS OF OUVALLS BASIN DESCMPT[ONS POSSIBLE POLLUTANTS BMWs BASIN OUTFALLS OF OUTFALLS BASIN DESCRIPTIONS POSSIBLE POLLUTANTS BMP's BASN) OUTFALLS OF OUTFALLS BASIN DESCRIPTIONS POSSIBLE POLLUTANTS BMP's
H BASIN H HAS BEE DELETED; THEE POTENTIAL POLLUTANTS N
0 200 400 BASN H HAVE BEEN REMOVED. THE AND THE PROCESS
RIND
HAS BEEN CLOSED AND RFMBMATO,AND THE PROCESS
f S 1 34'20'62'N BASN S IS TO BE RDIM RISK SAMPLING AND SEGMENT STORAGE.GEOFAB RIC,GRAVEL, P 1 JC 21'46'N BASIN P IS LOCATED SOUTH OF THE MLL NEXT RID 230T SGNAGE,CEOFIHRIG GRAVEL, K BASN K HAS BEEN DELETIX THERE ARE NO POTENTIAL LIQUOR UNE EE I NG THE PINS HAS ALSO BEEN REMOVED.
AND REPORTING DUE M THE ABSENCE OF POTENTIAL ROCK INLET PROTECTION, AND BASN K. IT COVERS ABOUT 3UM ACRES OF LAN GRATE AT CONCRETE OUTLET POLLUTANTS IN THIS AEA U WAS PREVIOUSLY LOCATED BASN H COVERS ABOUT Us ACRES OF LAND THAT IS
78'13'3S TV POLLUTANTS BASN S M LOCAMI SOUTH OF BASN R COLLECTION BASN,GRASSY 7B'12'02'W THAT IS GRAVELED AND IMPERVIOUS N1115TPoAL STRUCTURE PIPES,RIPRR SOUTH OF THE WILL NEXT TO BASIN P.BETWEEN THE SOUTH RAVELED AND IMPERVIOUS STBRMWATER IS DIRECTED VIA
SCALE, 1.' = 200' ON THE WILL ROAD.N THE MST NW-THIRD OF THE SWALE£DRAINAGE CHANNELS, WTIMTES IN THIS AREA RE LIMIM 10 WxSWW%TMM WALE,MEANDERING STREAM LAMM YARD WHO THE EAST BANK OF THE ACCESS ROW. RAVELED DRANAGE CHANNELS,CHECKDAMS,A PPE,AND
CONTRACTOR PAMMC LOB. MASH S COVERS PIPES,MEANDERING STREAM. AND MAINTENANCE EWPMENT STODGE,CONTRA MITI BASN K COVERS ABOUT IRO ACES OF UND,AND Al IS RIPRR TO AN UNNAMED TNWTARY OF THE CAPE FEAR
ARPROBIAMY 1.05 AIRS AS M WPERMOUS. GRACE TRAILERS,AND CONTRACTOR AMIGAC IMFERAOJs. STRNWATA IS DIRECTED ROUGH GRAVEL TO RIVER. THE AREA CONSSTS OF AN ACCESS ROW FOR
STORMWATER SHEETS Ma BWMEL TOR SOUTH STRMWATER IS DIRECTED NA A DITCH BASN,AFFECT, A RPRAPED SWALE,MEN THOUGH A PIPE UNDER THE UTUTES ANO FOR IRE TIMEPASSTRACKS.
FNDREW AND IS CW,WMBI®MCI A ROCK FILTER AND A RIPRAPPED DRAINAGE CNNIEL CHANNOIBID PAnTRACKS TT AN UNNAMED TRIBUTARY OF UVNGSTR I I 34'20'WN BASIN I IS LOCATED SOUTH OF PS&D,INSDE R WILL WOOD DEBTS FROM WOW SlMtAt COCM BASINS,
INTO A SIMNTATN BASN OM SK THE FENCE RUNOFF PASSES EAST UNDER THEPASSTHACtS\0 A CREEK,AD EWNnAULV D THE CAPE FEAR RIVER. THE AND FENCEUNE,NEXT TO BASN L THE AREA COVERS HIUCQS SRD47. PWK SAMEL,NPRR,
OVERROW FROM THE N flIBNS]TROUGH THE PIPE TO AN UNNAMED TRIBUTARY OF U IMOSION AREA CRESTS OF AN ACCESS ROAD FOR UG UTES AND NE 78-12'54'W ABOUT 1,67 ACRES OF LAND THAT IS PAVED AND IS MARS.PAWN,MNOFF
WDWS NA A MENWND SWEFM 94D ANOTHER CREEK, AND EVENTUALLY TO THE CAPE FEAR 05. RAL PASSTRACKS IMPERVIOUS. STORMWATER IN ONE SECONN ROWS INTO DIAt19Ctl BAFFLE,CONCRETE
GRASSY SCONE RAW M OMMO EAST NA A CONCRETE CATCH BASN AND PIPE,AND THE PC
CONCRETE PIPES AND OMM O'NNWELS TO N L 1 Nr 20'54'N BASN L IS TO BE REMOVED FROM SAMPLING AND SEDIMENT SKI GMTFXB.E FABRIC UNNAMED T®UTARYOF LUMSMEN'CREEK AND AND REPORTNG, WERE ARE NO FORMAL POLLUTANTS IN GRAVEL CATCH BASIN. REMAINDER SHEETS ACROSS THE SURFACE AND
PIPES, THROUGH A SLOTTED CONCRETE T DIFFUSION BAFFLE.
EVENIVMLY ID THE COW FEAR INNER THIS AREA 78-12'48'W THIS AREA. IT IS LOCATED SOUTH OF THE MILL,NEXT CULVERT.COLLECTION POND, RUNOFF FROM BOTH AREAS COMBINES TO BIN ACROSS
CONSISTS OF STAGA M RAIDERS TRANS'WTNG TO BASN I. THE AREA GONERS APPROXIMATELY 2 GRATE ALTERS A GRASSY AREA 10 A SECOND CATCH BASN,THEN
LOGS AND WOOD CHIPS BAR%NAIL MAINTENANCE ACRES OF LAND,WHICH IS COVERED NTH GEREXTIIE EXITS THROUGH A STEEL PIPE TO A COLLECTION POND.
SWIWWNS GQIROLW A MMWMILLW.BASN S IS USED AND GRAVELED,NO IS WERNWS. S70RMWAER IS THIS POND DRANS MA A CONCRETE ARE UNDER THE
FOR CONTRACTOR PRBWG. DIRECTED ROUGH A OATCH BASN THAT IS
LEGEND J4'20'44'N BASN T SLOCATED W S OF T E EMPLOYEE PARKING MOW fBPoS A0 WOW SRAO CONCRETE SURFACE 0 1 34'21'29'N BASN Q IS LOCATED NORTH OF I E MAIL PAST MVMN WRAP INNT BARWASH SGNAGE,GEDANIC,GRAVEL, PROTECTED BY INLET FILTERS AND JERSEY DIMOERSJ ROW,THEN NAVELS ALONG TO AN UNNAMEDAS
THE CATCH BASIN WAMW THROUGH A CONCRETE THE COE OF RIVER.W CHEEK,AND EVENTUALLY IS
AND E.IT COVERS ABW T 0.IS ACHES OF LAID ON Mff PIPE,PAVEMENT,BACKWASH THE CARE FEAR RIVER. INDUSTRIAL ACTIVITIES W THIS
7r LOT,BETWEEN 1E N F MftM APPROXIMATELY
AND THE NOW NIIC(S AND CLNBNC,CH BASK
CULVERT UT A F T E CA POND OUTKING,
T THE MILL
78'12'42'W CAPE FEAR RIVER AND IS APPROXIMATELY 50% VALVES,ROCKED W7FALL AREA RE UNITED TO PRDNC FOR TRAILERS
7B 17 O4'W TRUES GALE BASIN T AMEX.
lMNAT A7ELY 1.33 OLVERTS,CATCH BAW£ MP D ARE I THE ME THE
NINE AND A CULL VEGETATED BANNS FENCE OVERFLOWS
UT THE @MDLINA KING THIS POND FOR SLUNG FINISHED S PRODUCTS.NO A RAIL LINE
ACTS OF MERR HE RBA. SDMW WAY TO A MEGAWE N P STREAM
PIPER, ROW RE IN BASN Q.R WATER PLANT 4S7R AN UNN M5 SOUTH TRIBUTARY A A PIPE UNDER THE ROW,TO fON SOME MILL PRIXESS TEAS.
BASIN O CL/WATER SOUTHYAMI dER 1N OIlpIL�IE MMVEWAY i0 A CURB NENRNNC SEEM BACKWASH POND Is IN BASIN 0.BAIXWASI S VAJIEp EV UXNMFD OTHEC D AR RIVER.
R.CTHE AND
,�, THAT DIRECTS RUNOFF A M A MANNERED DRAINAGE DIRECTLY MGM THE PGNG TO 11E MLL NTA E N1MWS EVENTUALLY TO THE CAME FEAR RIVER. THE AREA J 1 34'21'03"N BASN J IS LDCATD SOUTHWEST OF THE MILL. IT OHEWCALS IN RMIDAS SKAMRE®1BYWIE FABRIC,
BOUNDARY SEPARATOR CHANEL AT TE GATE, NMM WILL$THROUGH A CONSISTS OF PARKING FOR TRAILERS TRANSPORTING
BASN E00131 AREA AND 90 GWILI NHS.THEN THROUGH AND ECING IT FROM
BAR INTO THE RUNOFF.
SIPRLYfJ FINISHED PRODUCTS.
SEPARATING IT FROM S70RLIWAIER RUNOFF. AND COVERS ABOUT 7.77 ARES OF LINO,AL OF WHICH IS PPE$,CMYMEIE NMWMiS,
CONCRETE EWES CMf M M%NW,AM TWO COLLECTION STRMWATER IS DIRECTED THROW G AMM 78'12'%'W THE ES qi GRAVES. STORM WATER IS DIRECTED ON CAM BOW ASS,
BEAM OUTALL POWS TO M LMARM IMMWMBIF OF UNNGSTON CHANNELS TO A DISCHARGE PIPE AND SLEET MODERATE 9GlAC{ SWALE WTK THE NEST SIDE 6Y A RETANWC BERM AND A SEMES GMYB®„ARD PAWED
REEK,AND RDM ME,EO.7NIWNULY TO THE CAPE M 1 3c 21'11'N BASIN M IS LOCATED EAST NORTHEAST OF THE MILL WEGM N WNINWFNf„ OF GRAVES CHANNELS,AND ON THE EAST BY CATCH SI8FXM CWMON PONDS
FEAR RIVER. WD MM&ACBMIIIN INCLUDES WOOD THE Wt7W5 TO THE CAPE FEAR Po1ER. AND AND INCLUDES THE ROADWAY OUTSDE AND EAST OF RONJLS N TRUCKS MULTIPLE DHECKDM£ BASINS AND DRAINPIPES TO AN UNDERGROUND PIPE
CATCH BAWL ❑ PRNWS TRUCK ENTRY AND ASONMXBUBE. 78'It 27'W THE CONTRACTOR GATE. IT COVERS ABOUT 1.36 GAVEL PAVEMENT,CONCRETE THAT RESURFACES SOUTH OF THE ADMINISTRATION
ACRES OF LAND THAT IS ALL IMPERVIOUS. BASIN M CLOSING,APRAP,CONCRETE BUILDING AND CHANNELS FLOW ROUGH A BOOTED
SURFACE RUNOFF PASSES THROUGH A VEGETATED SWALE WITH A CONTAINMENT. AREA RUNOFF THEN PASSES THROUGH CONCRETE
SERIES OF ROCK CHECXDMS AND RPRR AT THE PIPES,CATCH BASINS,AND TWO COLLECTION PONDS TO
C CUTALL.THE BASN M W7FALL FLOWS INTO ME AN UNNAMED TRIBUTARY OF UNNGSTON CREEP, AND
CULVERT POND RAVINE,THROUGH A MEANDERING STREAM,AND ON TO FROM THERE,EVENTUALLY TO CAPE EAR RIVER.
THE CAPE EAR RIVER. BASN M INCLUDES PAVED AND INDUSTRIAL ACTIVITIES IN THIS AREA ARE UNTIED TO
R I 34'20'46'N BASN R IS TO BE REMOVED FROM SAMPLING AND SIYBIi 9GHACE,CEOFABPoC,GRAVEL TOTE
MILL ROWS,A RREHWSE CONTANING A RAIL LINES FOR INCOMING WOOD CHIPS,LOGS, AND
FENCE LONE —X—X— AND REPORTING WE TO THE ABSENCE OF POTENTIAL ROCK FILTER BED,COLLECTION TITS BIN OF FIRE STORAGE TARESSANT,AND A CONTAINED CHEMICAL BYPRODUCTS; ANO MAIL ACCESS ROWS
RIP RR 78'13'22'W POLLUTANTS BASN R IS LOCATED SOUTH OF IRE W POD WITH SOMMER.FREBAY METHNOL NONT TANK. PRE-EXISTING 0U7FAIL 2
AT R CONTAINERYRD,WEST OF THE COIL ROW_ AND RDNFRCEO SPILLWAYS, RUNOFF N NOW D STEM(VAINHED t0 THE WASTEWATER
RAssr SWALE /_ SLOPESAND
oVA+RAFI.OSTsnu (n a yMc sn wA,s>�wA RE Nr
ROCK TIER JM°°` AND ISIMPERVIOUS.ITSTRMWATER SIEEES GAR WALES,BDISCHRGE MANIFOLD,
GRAVEL FROM THE NE CORNER AND THOUGH A SEDIMENT SAGS,CONCRETE CLARIFIERS AND CHARM THE RAW TO THE WWIS.
IMERYOUS FOREBAY NTO A SEDIMENTATION BASN A S MVM PC WIN RINRAPED EDCE,
SURFACE WAND :� DISCHARGES RUNOFF THROUGH SEDWEIIT BAGS IRYAi N 1 34.21'21'N BASN N IS LOCATED NORM NORTHEAST OF THE WILL PROCESS WATER OKU S WAGE,GEOFABRIC,GRAVEL
DR14N ACROSS CONCRETE AND HI P,BEEN NM Iflff MENDERING SCREW ROCK AND NEXT TO BASKS B&01 IT COVERS ABOUT 0.15 TREATMENT OREWCUS M EE AT CONCRETE OUTLET, BASINS K — P CONTINUED LEFT
JERSEY ...... U-RAN LVV OVERROW SIRUCNRE.
WOWS A RBNFRBED SPILLWAY OHFCIS OVEEIMW 78'If 33'W ACES OF LAND AND IS ALL RAVELED AND CONTAINMENT CONCRETE CONTAINMENT,
O ACROSS A ROCK APRON AND IBM THE:WOWS TBS IMPERVIOUS. BASIN N INCLUDESCOOLED
WET.C OL COOLING
DUI-CRROSVE CONTAINERS,
ORDERS ! LOCATION IS VERY RARELY SAMPLED. ALL OISmP� NORM END OF N0. 3 GDWNC TONER.COOING WATER SCUP TO WS
MEANDERING ALLOWS
ECTIONNS MEANDERING
N WSGAND AAMS ROM TWO GRAM SOIL MW STORED ANSS D CHEMICALS NON-CCORROS VE CKNMTAWER, I MILL F' \ /PLOT C ['� BASINS
PLAN
��L AB NNp(+STREW IS THEN DIRECTED UNDER THE PASSIN1NAC S NAMTIRE. HTHN SECONDARY CCNIAINMENT THAT RAINS TO THE T R M W A T E R .0 A J INS
A SMALL AREA IN THE SOUTHWEST CRIER OFDMIN WWI. BASN N RUNOFF DRAINS NA A CONCRETE
IS DIRECTED TO A CATCH BASN AND DWCIED OWE DRAINAGE APRON AND R PIPE,AND NUNS THROUGH
THROUGH A GRASSY WALE RLkW PASSES KM THE THE WOODS TO ME C E EAR RIVER.
SEGMENT BASN OF BASIN S.WHERE ROWS CMW J GENERAL REVISION 3 15 23
FROM THEE STOAMWAIER TRAMS THROUGH IE 0 1 34'20'26'Al BASIN 0 IS LOCATED TH NORTHEAST OF THE LULL PROCA WAIM DER S ENAGE GEOFABRIC,GRAVEL, I GENERAL REVISION 5 15 19
WOODS AND ANOTHER GRASSY SOME.BOTH DICMM AND NEXT TO BARNS B& IT COVERS ABOUT 0.10 WATMENf GDIws W PR AT CONCRETE CURET,LIVIN A�L®PAPER
POINTS MEANDER TO UNNAMED TBUTRES D 78'12'JJ'W ACES OF LAND,P11 WHICH IS RAVELED AND CONTAINMENT OMICE7E CONTAINMENT, H GENERAL REVISION 1 18/19 I N T E R N AT I 0 N
FEAR RVE CHECK RE EVENTUALLY IT)THE CBE IMP S. INWSTAI ACTNTES IN THIS AREA ARE UCH-CORROSIVE CONTAINERS,FEAR RIVER. THIS AREA CONSISTS PR DUCTS. MR E SOUTH END OF NO.3 SMP To wrs G GENERAL REVISION 1/18 12
TRAILERS TRANSPORTING FINISHED GENERALLY
GRIND LIMITED TO ACCESS -WART PROCESS CHEMICALS
IN E TO'ABR. /f�
LANCE MAINTENANCE SIWTWNNS.ROXIMATELY M OF HAS INCLUDE NDCDES N0 OCORROS INHIBITORS,CONTAIN RS. ARE F GENERAL REVISION 2/29/10 VL DILL E
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ATTACHMENT B
MONITORING DATA SUMMARY SINCE LAST PERMIT ISSUANCE:
PERMIT APPLICATION DATA JANUARY 19,2020 (2015-2019)
PERMIT APPLICATION DATA MARCH 22, 2023 (2020-2022)

ATTACHMENT B
MONITORING DATA SUMMARY SINCE LAST PERMIT ISSUANCE (2015-2019)

INTERNATIONAL PAPER
RIEGELWOOD MILL
JOHN L.RIEGEL ROAD
RIEGELWOOD,NC 28456
PHONE [phone]
January 21, 2020
DEMLR—Stormwater Program
Department of Environmental Quality
1612 Mail Service Center
Raleigh, NC 27699-1612
Certified Mail: 1017 1000 0000 9581 0535
Subject: Individual Permit Renewal,NPDES Permit NCS0001 0 1
Dear Stormwater Program:
Enclosed are analytical and quantitative data for 2019, completing International Paper's application for
renewal of NPDES Stormwater Permit 9000101. The renewal application was submitted May 15, 2019,
six months before the current permit expiration, as required, however, analytical and quantitative results
for 2019 were not available at that time. Additionally enclosed is an updated SPPP Development and
Implementation Certification, documenting the change in management. Please add this information to
�• the renewal file. You may contact Wallace Coverdale of my staff if any additional information is
required at 910-362-4590 or [e-mail].
I certify, under penalty of law,that this document and all attachments were prepared under my direction
or supervision in accordance with a system designed to assure that qualified personnel properly gather
and evaluate the information submitted. Based on my inquiry of the person or persons who manage the
system, or those persons directly responsible for gathering the information,the information submitted
is,to the best of my knowledge and belief, true,accurate, and complete. I am aware that there are
significant penalties for submitting false information, including the possibility of fines and
imprisonment for knowing violations.
Sincerely, `
Kevin Driscoll, Mill Manager

�. ANALYTICAL MONITORING RESULTS
INTERNATIONAL PAPER REIGELWOOD OPERATIONS
Spring 2015
Discharge Characteristic Basin Stormwater Sample date Units Result Benchmark
Value
Chemical Oxygen Demand B 6/27/2015 mg/L 60 120
Standard Methods 5220D E 6/27/2015 mg/L 148 120
(Method: Hach 8000) 1 6/27/2015 m /L 70 120
T 6/27/2015 m /L 194 120
Biological Oxygen Demand B 6/27/2015 m /L 6 30
Method: 5-day BOD Test E 6/27/2015 m /L 21 30
Standard Methods: 5210E 1 6/27/2015 m /L 5 30
T 6/27/2015 m /L 23 30
Total Suspended Solids B 6/27/2015 m /L 54 100
Method: Total Suspended Solids E 6/27/2015 m /L 5 100
Standard Methods: 2540D 1 6/27/2015 mg/L 46 100
T 6/27/2015 m /L 25 100
pH B 6/27/2015 su 7.4 6-9
Method: pH Value E 6/27/2015 su 7.1 6-9
Electrometric Method 1 6/27/2015 su 7.8 6-9
Standard Methods 4500 H+ B T 6/27/2015 su 7.6 6-9
ANALYTICAL MONITORING RESULTS
INTERNATIONAL PAPER REIGELWOOD OPERATIONS
Fall 2015
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B 12/7/2015 m /L 53 120
Standard Methods 5220D E 11/2/2015 m /L 131 120
(Method: Hach 8000) 1 11/2/2015 m /L 78 120
T 11/2/2015 m /L 115 120
,,...` Biolo ical Oxygen Demand B 12/7/2015 mg/L 12 30
Method: 5-day BOD Test E 11/2/2015 mg/L 12 30

Standard Methods: 5210B 1 11/2/2015 m /L 3 30 ,t•.ti
T 11/2/2015 m /L ND/5 30
Total Suspended Solids B 12/7/2015 m /L 26 100
Method: Total Suspended Solids E 11/2/2015 m /L 7 100
Standard Methods: 2540D 1 11/2/2015 m /L 90 100
T 11/2/2015 m /L 68 100
pH B 12/7/2015 su 7.2 6-9
Method: pH Value E 11/2/2015 su 7.5 6-9
Electrometric Method 1 11/2/2015 su 8.7 6-9
Standard Methods 4500 H+ B T 11/2/2015 su 8.2 6-9
ANALYTICAL MONITORING RESULTS
INTERNATIONAL PAPER REIGELWOOD OPERATIONS
Spring 2016
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B 5/29/2016 m /L <20 120
Standard Methods 5220D E 1/15/2016 m /L 53 120
(Method: Hach 8000) E 2/24/2016 m /L 73 120
E 3/20/2016 m /L 46 120
E 5/29/2016 mg/L 64 120
1 5/29/2016 m /L 92 120
T 5/29/2016 mg/L 170 120
Biological Oxygen Demand B 5/29/2016 m /L 3 30
Method: 5-day BOD Test E 1/15/2016 m /L 6 30
Standard Methods: 5210B E 2/24/2016 m /L 25 30
E 3/20/2016 m /L 15 30
E 5/29/2016 m /L 10 30
1 5/29/2016 m /L 5 30
T 5/29/2016 mg/L 15 30
Total Suspended Solids B 5/29/2016 m /L 42 100
Method: Total Suspended Solids E 1/15/2016 m /L 5 100
Standard Methods: 2540D E 2/24/2016 m /L 3 100
E 3/20/2016 m /L 5 100
E 5/29/2016 m /L 5 100
1 5/29/2016 m /L 24 100
T 5/29/2016 mg/L 84 100
pH B 5/29/2016 su 6.7 6-9
Method: pH Value E 1/15/2016 su 7.0 6-9
Electrometric Method E 2/24/2016 su 6.6 6-9
Standard Methods 4500 H+ B E 3/20/2016 su 7.4 6-9
E 5/29/2016 su 6.7 6-9

ooks 1 5/29/2016 su 7.1 6-9
T 5/29/2016 su 6.8 6-9
ANALYTICAL MONITORING RESULTS
INTERNATIONAL PAPER REIGELWOOD OPERATIONS
Fall 2016
Discharge Characteristic Basin Stormwater Sample date Units Result Benchmark
Value
Chemical Oxygen Demand B 12/29/2016 m /L 52 120
Standard Methods 5220D E 7/23/2016 m /L 67 120
(Onsite Method: Hach 8000) E 9/19/2016 m /L 41 120
E 12/29/2016 m /L 108 120
1 12/29/2016 m /L 128 120
T 12/29/2016 m /L 36 120
Biological Oxygen Demand B 12/29/2016 m /L 4 30
Method: 5-day BOD Test E 7/23/2016 m /L 8 30
Standard Methods: 5210B E 9/19/2016 m /L 8 30
E 12/29/2016 mg/L 21 30
1 12/29/2016 m /L 4 30
T 12/29/2016 m /L 5 30
Total Suspended Solids B 12/29/2016 m /L 176 100
Method: Total Suspended Solids E 7/23/2016 m /L 3 100
Standard Methods: 2540D E 9/19/2016 m /L 6 100
E 12/29/2016 m /L 11 100
I 12/29/2016 m /L 313 100
T 12/29/2016 m /L 818 100
H B 12/29/2016 su 7.7 6-9
Method: pH Value E 7/23/2016 su 6.6 9-Jun
Electrometric Method E 9/19/2016 su 6.9 6-9
Standard Methods 4500 H+ B E 12/29/2016 su 7.0 6-9
1 12/29/2016 su 8.0 6-9
T 12/29/2016 su 7.8 6-9
ANALYTICAL MONITORING RESULTS
INTERNATIONAL PAPER REIGELWOOD OPERATIONS
Spring 2017
Discharge Characteristic Basin Stormwater Sample date Units Result Benchmark
Value
Chemical Oxygen Demand B 6/22/2017 mg/L 68 120
Standard Methods 5220D E 3/28/2017 mg/L 133 120
Method: Hach 8000 E 6/19/2017 m /L 115 120
1 3/28/2017 m /L 105 120
T 3/28/2017 mg/L 78 120
,..� T 6/19/2017 m /L 131* 120

Biological Oxygen Demand B 6/22/2017 m /L 3 30 ,..,
Method: 5-day BOD Test E 3/28/2017 mg/L 28 30
Standard Methods: 5210B E 6/19/2017 m /L 9 30
1 3/28/2017 m /L 17 30
T 3/28/2017 m /L 16 30
T 6/19/2017 m /L 18 30
Total Suspended Solids B 6/22/2017 m /L 642 100
Method: Total Suspended Solids E 3/28/2017 mg/L 10 100
Standard Methods: 2540D E 6/19/2017 m /L 8 100
1 3/28/2017 m /L 96 100
T 3/28/2017 m /L 31 100
T 6/19/2017 m /L 36 100
pH B 6/22/2017 su 7.9 6-9
Method: pH Value E 3/28/2017 su 7.4 6-9
Electrometric Method E 6/19/2017 su 6.9 6-9
Standard Methods 4500 H+ B 1 3/28/2017 su 7.7 6-9
T 3/28/2017 su 7.8 6-9
T 6/19/2017 su 6.7 6-9
ANALYTICAL MONITORING RESULTS
INTERNATIONAL PAPER REIGELWOOD OPERATIONS
Fall 2017
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B 9/5/2017 m /L 48 120
Standard Methods 5220D B 10/9/2017 m /L 39 120
(Method: Hach 8000) B 12/20/2017 mg/L 24 120
E 7/29/2017 m /L 94 120
E 8/5/2017 m /L 101 120
E 10/19/2017 m /L 48 120
E 12/20/2017 m /L 50 120
1 12/20/2017 m /L 190 120
T 7/29/2017 m /L 188 120
T* 12/20/2017 m /L 313* 120
Biological Oxygen Demand B 9/5/2017 mg/L 7 30
Method: 5-day BOD Test B 10/9/2017 mg/L 4 30
Standard Methods: 52106 B 12/20/2017 m /L 3 30
E 7/29/2017 m /L 19 30
E 8/5/2017 mg/L 29 30
E 10/19/2017 m /L 5 30
E 12/20/2017 m /L 5 30
1 12/20/2017 m /L 14 30
T 7/29/2017 m /L 7 30
T* 12/20/2017 m /L 41* 30
Total Suspended Solids B 9/5/2017 m /L 4 100
Method: Total Suspended Solids B 10/9/2017 m /L 590 100

Standard Methods: 2540D B 12/20/2017 m /L 96 100
E 7/29/2017 m /L 10 100
E 8/5/2017 m /L 4 100
E 10/19/2017 mg/L 9 100
E 12/20/2017 m /L 4 100
1 12/20/2017 m /L 146 100
T 7/29/2017 m /L 53 100
T 12/20/2017 m /L 299* 100
H B 9/5/2017 su 7.3 6-9
Method: pH Value B 10/9/2017 su 6.6 6-9
Electrometric Method B 12/20/2017 su 7.4 6-9
Standard Methods 4500 H+ B E 7/29/2017 su 6.7 6-9
E 8/5/2017 su 6.2 6-9
E 10/19/2017 su 7.9 6-9
E 12/20/2017 su 7.3 6-9
1 12/20/2017 su 7.6 6-9
T 7/29/2017 su 7.2 6-9
T* 12/20/2017 su 6.5 6-9
*Tier 1 sample-report only(1st smp of semester counts)
INTERNATIONAL PAPER REIGELWOOD OPERATIONS
Spring 2018
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B 5/22/2018 m /L 24 120
Standard Methods 5220D E 5/22/2018 m /L 102 120
Method: Hach 8000 1 5/22/2018 m /L 31 120
T 5/22/2018 m /L 79 120
Biological Oxygen Demand B 5/22/2018 m /L 3 30
Method: 5-day BOD Test E 5/2 212 0 1 8 m /L 13 30
Standard Methods: 5210B 1 5/22/2018 m /L 5 30
T 5/22/2018 m /L 16 30
Total Suspended Solids B 5/22/2018 mg/L 22 100
Method: Total Suspended Solids E 5/22/2018 m /L 5 100
Standard Methods: 2540D 1 5/22/2018 mg/L 22 100
T 5/22/2018 m /L 77 100
H B 5/22/2018 su j 7.1 6-9
Method: pH Value E 5/22/2018 su 6.9 6-9
Electrometric Method 1 5/22/2018 su 6.8 6-9
„, Standard Methods 4500 H+ B T 5/22/2018 su 6.9 6-9

INTERNATIONAL PAPER REIGELWOOD OPERATIONS
Fall 2018
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B 12/14/2018 m /L <20 120
Standard Methods 5220D E 12/14/2018 m /L 46 120
(Method: Hach 8000) 1 12/14/2018 m /L 76 120
1 12/20/2018 m /L 95 120
1 12/28/2018 m /L 46A 120
T 12/14/2018 m /L 180 120
T 12/20/2018 mg/L 164* 120
Biological Oxygen Demand B 12/14/2018 m /L 3 30
Method: 5-day BOD Test E 12/14/2018 m /L 9 30
Standard Methods: 5210E 1 12/14/2018 m /L 5 30
1 12/20/2018 m /L 6 30
1 12/28/2018 m /L 3^ 30
T 12/14/2018 m /L 26 30
T 12/20/2018 mg/L 18 30
Total Suspended Solids B 12/14/2018 m /L 6 100
Method: Total Suspended Solids E 12/14/2018 m /L 10 100
Standard Methods: 2540D 1 12/14/2018 m /L 138 100
1 12/20/2018 m /L 214* 100
1 12/28/2018 m /L 88A 100
T 12/14/2018 m /L 225 100
T 12/20/2018 mg/L 170* 100
H B 12/14/2018 su 7.5 6-9
Method: pH Value E 12/14/2018 su 7.5 6-9
Electrometric Method 1 12/14/2018 su 7.9 6-9
Standard Methods 4500 H+ B 1 12/20/2018 su 7.4 6-9
1 12/28/2018 su 7.8^ 6-9
T 12/14/2018 su 7.8 6-9
T 12/20/2018 su 7.7 6-9
*Tier 1 smp-report only(only 1 st smp of sem. counts^ non-rep event, rpt only
INTERNATIONAL PAPER REIGELWOOD OPERATIONS
Spr 2019
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B no flow m /L
Standard Methods 5220D E no flow m /L
(Method: Hach 8000) 1 no flow m /L
T 3/1/2019 m /L 290 120
T 5/12/2019 mg/L 50 120
Biological Oxygen Demand B no flow mg/L
Method: 5-day BOD Test E no flow m /L
Standard Methods: 5210E I no flow m /L
T 3/1/2019 m /L 18 30
T 5/12/2019 mg/L 12 30 /A•
Total Suspended Solids B no flow m /L

Method: Total Suspended Solids E no flow m /L
Standard Methods: 2540D I no flow m /L
T 3/1/2019 m /L 312 100
T 5/12/2019 mg/L 23 100
pH B no flow su
Method: pH Value E no flow su
Electrometric Method I no flow su
Standard Methods 4500 H+ B T 3/1/2019 su 7.6 6-9
T 5/12/2019 su 7.1 6-9
*Tier 1 smp-report only(only 1st smp of sera. counts^ non-rep event, rpt only
INTERNATIONAL PAPER REIGELWOOD OPERATIONS
Fall 2019
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B 11/12/2019 mg/L 35 120
Standard Methods 5220D E 7/3/2019 m /L 135 120
(Method: Hach 8000) 1 7/3/2019 mg/L 136 120
T 7/3/2019 mg/L 168 120
T 11/12/2019 m /L 168 120
T 12/23/2019 mg/L 68 120
Biological Oxygen Demand B 11/12/2019 mg/L 4 30
Method: 5-day BOD Test E 7/3/2019 mg/L 20 30
Standard Methods: 5210B 1 7/3/2019 m /L 14 30
T 7/3/2019 m /L 25 30
T 11/12/2019 m /L 7 30
T 12/23/2019 mg/L 13 30
Total Suspended Solids B 11/12/2019 m /L 4 100
Method: Total Suspended Solids E 7/3/2019 mg/L 7 100
Standard Methods: 2540D 1 7/3/2019 mg/L 227 100
T 7/3/2019 m /L 336 100
T 11/12/2019 m /L 43 100
T 12/23/2019 mg/L 33 100
H B 11/12/2019 su 6.7 6-9
Method: pH Value E 7/3/2019 su 6.7 6-9
Electrometric Method 1 7/3/2019 su 8.2 6-9
Standard Methods 4500 H+ B T 7/3/2019 su 7.8 6-9
T 11/12/2019 su 6.9 6-9
T 12/23/2019 su 7.4 6-9

QUALITATIVE STORMWATER RESULTS: Spring 2015 - Fall 2019
VISUAL INSPECTION: Scale 1 -5 (1=13est),OR Y/N
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER I k(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
A
S15 It gray 3 1 2 n n n y, rd by 3LT
F15 It yellow 2 1 2 n n n n
S16 It tan 2 1 3 n n n n
F16 It yel 2 1 2 n n I n slight
S17 I It gray 3 2 3 n n n y
F17 It gray 2 1 3 n n n y
S18 It gray 2 1 2 n n n n
F18 med br 3 1 2 n n n y
S19 noflow n/a n/a n/a n/a n/a n/a n/a
F19 yellow/brown 2 2 2 n n n slight
B
S15 It gray 2 1 1 n n n n
F15 no smp,constr n/a n/a n/a n/a n/a n/a n/a
S16 off-white 2 1 2 n n n n
F16 It gray 3 1 3 n n n none visible
S17 It gray 3 1 3 n n n searching
F17 9/S/17 It tan 3 1 2 n n n y into pond
F17 12/8/17 It tan 2 1 3 n n n y-at fenceline
F1712/20/17 It gray 2 1 1 n n n n
S18 4/25/18 sl. cloudy wh 1 1 2 n n n n
S185/22/19 sl.white 1 2 1 n n n n
F18 very It gray 1 1 2 n n I n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 pale yellow 1 1 1 n n n n
S15 It.yel 1 1 1 n n n n
F15 dear 1 1 1 n n n n
S16 It yellow 1 1 1 n n n n
F16 very It yel 1 1 1 n n n sl above inlet prot.
S17 pale yellow 1 1 1 n n n n
F17 very It yel 1 1 1 n n n n
S18 clear 1 1 1 n n n n
F18 clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 It yellow 1 2 2 n n n n
S15 pale yel 2 2 1 n n n It. chip debris
F15 clear 1 1 1 n n n n
S16 clear 1 2 1 n n n n
F16 clear 1 1 1 n n n n
S17 It yel 1 1 2 n n n n
F17 very It yel 1 1 1 n n n n
518 clear 1 1 2 n n n n
F18 almost clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 nearly clear 1 1 2 n n n n

QUALITATIVE STORMWATER RESULTS: Spring 2015 - Fall 2019
VISUAL INSPECTION: Scale 1-5 (1=13est), OR Y/N
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(Imd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
E
S15 yellow 1 1 1 n n n n
F15 It tan 1 1 1 n n n n
S16 very It tan 1 1 1 n n n n
F16 7/23/17 sl.yellow 1 1 1 n n n n
F16 9/19/17 It yellow 1 1 2 sl musky n n n
P1612/29/17 It yellow 1 1 2 sl moldy nj n n
S17 3/28/17 med yellow 1 1 2 n n n n
S17 6/19/17 It brown 1 1 2 n n n n
F17 7/29/17 tan 2 1 2 n n n n
F17 8/5/17 It tan 1 1 2 sl musty odor n n n
F17 12/8/17 It tan 2 1 2 n n n n
F1712/20/27 It amber 1 1 1 n n n n
S18 It yel 1 1 1 n n n n
F18 It yel 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 It yellow 2 1 2 oily odor n n n
515 med br 2 2 3 n n n wood debris
$15 It yel 1 1 1 n n n n
F15 almost clear 2 1 2 n n n n
S16 (E) It yellow 1 1 1 n n n n
S16 (W) med br 2 1 2 n n n n
F16 (E) med br 2 2 2 n n n n
F16(W) Ityellow 1 1 1 n n n n
S17(E) It yellow 1 1 1 n n n n
S17(W) It yellow 1 2 1 n n n n
F17(E+W) very It yel 1 1 1 n in n n
S18(E+W) clear 1 1 1 n n n n
F18(E+W) very It br 3 1 3 si oily odor n n y
S19(E+W) no flow n/a n/a n/a n/a n/a n/a n/a
F19(E+W) very It tan 1 1 2 n n n n
F1
515 It yel 1 1 1 In n n n
F15 no flow n/a n/a n/a n/a n/a n/a n/a
S16 pale yellow 1 1 1 n n n n
F16 It yellow 1 1 1 n n n n
S17 It yel 1 1 2 n n n n
F17 no flow n/a n/a n/a n/a n/a n/a n/a
S18 sl. whitish 2 1 2 n n n n
F18 almost clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 It yellow 1 1 2 n n n n
S15 It yel 1 1 1 n n n n
F15 It yel 2 1 1 n n n n
S16 pale yellow 1 1 1 n n nj n

QUALITATIVE STORMWATER RESULTS: Spring 2015 - Fall 2019
VISUAL INSPECTION: Scale 1 -5 (1=13est), OR Y/N
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER I k(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
F16 clear 1 1 1 n n n n
S17 very It yel. 1 1 1 n n n n
F17 clear 1 1 1 n n n n
S18 very It yel 1 1 1 n n n n
F18 clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 It yellow 1 1 1 n n n n
G1
S15 very pale yel 1 1 1 n n n n
F15 It yellow 1 1 1 n n n n
S16 very pale yel 1 1 1 n n n n
F16 clear 1 1 1 n n n n
517 very It yel 2 1 1 n n n n
F17 clear 1 1 1 n n n n
S18 sl.white/cloudy 2 1 1 n n n n
F1$ clear 1 1 1 n n n n
519 no flow n/a n/a n/a n/a n/a n/a n/a
F19 almost clear 1 1 1 n n n n
G2,
515 very pale yel 1 1 1 n n n n
F15 clear It yel 2 1 2 n n n n
S16 off-white 2 1 2 n n n n
F16 almost clear 1 1 1 n n n n
S17 very It yel 1 2 1 n n n n
F17 clear 1 1 1 n n n n
S18 It yellow 1 2 1 n n n n
F18 no flow n/a n/a n/a n/a n/a n/a n/a
519 no flow n/a n/a n/a n/a n/a n/a n/a
F19 very It yellow 1 1 1 n n n n
G3
S15 It yel 2 1 1 nj n n n
F15 It yel 1 1 1 n n n n
516 very It yel 1 1 1 n n n n
F16 very It tan 1 1 1 n n n n
S17 ver It yel 1 1 2 n n n n
F17 clear 1 1 1 n n n n
S18 It tan 1 1 2 n n n n
F18 clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F199 very pale yel 1 1 2 n n n n
S15 nearly clear 1 1 1 n n n n
F15 clear It yel 2 1 1 n n n n
S16 pale yellow 1 1 1 n n n n
F16 clear 1 1 1 n n n n
517 nearly clear 1 1 1 n n n n
F17 1 It amberl 1 11 1 n I n I n n

QUALITATIVE STORMWATER RESULTS: Spring 2015 - Fall 2019
VISUAL INSPECTION: Scale 1-5 (1=Best), OR Y/N
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
S18 clear 1 1 1 n n n n
F18 clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 clear 1 1 1 n n n n
S15 It yel 1 1 1 n n n n
F15 It yel 2 1 2 n n n n
S16 very pale yel 1 1 1 n n n n
F16 dkgray 3 1 3 n n n y(source not visible)
S17 yellow 2 2 2 n n n n
F17 12/8/17 It gray 2 1 2 n n n n
F17 12/20/17 gray 3 1 1 n n n none visible
S18 It tan 2 1 1 n n n n
F18 12/14/18 It gray 4 1 4 n n n n
F18 12/20/18 It brown 3 1 3 n n n y(no visibie source)
F1812/28/18 almost clear 2 1 2 ni n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 gray 3 1 3 foam on pad n n n
S15 clear 1 1 1 n nj n n
F1S It yellow 1 1 1 n n n n "~
S16 pale yellow 1 1 1 n n n n
F16 clear 1 1 1 n n n n
S17 It yel 1 1 2 n n n nyellow
F17 nearly clear 1 1 1 n n n n
S18 clear 1 1 1 n n n n
F18 It tan 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 clear 1 1 1 n n n n
S15 clear 1 1 1 n n n n
F15 very pale yel 1 1 1 n n n n
S16 pale beige 2 1 1 n n n n
F16 clear 1 1 1 n n n n
S17 clear 1 1 1 n n n n
F17 clear 1 1 1 n n n n
S18 clear 1 1 1 n n n n
F18 very It tan 2 1 2 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 It tan 2 1 2 n n n n
515 It gray 2 1 2 n n n slight
F15 It gray 2 1 2 n n n n ..�
S16 very It tan 2 1 1 n n n n
F16 sl off-white 2 1 2 n n n n
S17 3/28/17 med gray 4 11 4 n ni n y
S17 6/19/17 very pale yel I '1 21 1 n nj n n

QUALITATIVE STORMWATER RESULTS: Spring 2015 - Fall 2019
VISUAL INSPECTION: Scale 1 -5 (1=113est), OR Y/N
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER11 dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OIL SHEEN COMMENT
F17 It gray 2 1 2 n n n n
S18 sl off-white 2 1 2 n n n n
F18 1219/19 It tan 3 1 3 n n n y
F1812/14/18 tan 3 1 3 n n n y
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 It tan 1 1 2 n n n n
515 very pale yel 2 1 2 n n n n
F15 It gray 3 1 2 n n n some sed
S16 very pale yel 1 1 1 n n n n
F16 very pale yel 2 1 1 n n n n
S17 3/28/1 It gray 3 2 3 n n n n
S17 6/19/1 It brown 2 2 2 n n n in
F17 It tan 2 1 2 n n n n
S18 sl off-white 1 1 1 in n n n
F18 clear 1 1 1 n n n n
519 no flow n/a n/a n/a n/a n/a n/a n/a
*F19��* �I med brown 3 2 3 n n n n/heavy rain,turbid
N
S15 clear pale yel 1 1 1 n n n n
F15 clear 1 1 1 n n n n
S16 pale yellow 1 1 2 n n n n
F16 clear 1 1 1 n n n n
S17 sl.white 1 2 1 n n n n
F17 clear 2 1 1 n n n n
S18 nearly clear 1 1 1 n n n n
F18 It.yellow 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 It yellow 1 1 1 n n n n
515 clear 1 1 1 n n in n
F15 clear 1 1 1 n n n n
S16 very It yel 2 1 1 n n n n
F16 nearly clear 1 1 1 n n n n
S17 very It tan 2 1 2 n n in n
F17 I clear 21 1 1 n n n n
S18 nearly clear 1 1 1 n n n n
F18 clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 clear 1 1 2 n n n n
515 nearly clear 1 1 1 n n n n
R F15 clear pale yel 1 1 1 n n n n
S16 clear 1 1 1 n n n n
F16 sl white color 2 1 1 n n nj in
r17 1 nearly clear 2 11 11 nj n I nj n
7 clear 1 11 11 n I n I n I n

QUALITATIVE STORMWATER RESULTS: Spring 2015 - Fall 2019
VISUAL INSPECTION: Scale 1-5 (1=13est), OR Y/N
COLOR EROSION/
r-,
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER I k(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
S18 clear 1 i 1 n n n n
F18 clear 1 1 1 n n n n
519 no flow n/a n/a n/a n/a n/a n/a n/a
F19 med yellow 2 1 3 n n n some sed @ fence
S15 very It tan 2 2 1 n n n n
F15 clear pale yel 1 1 1 n n n n
S16 pale yellow 1 1 1 n n n n
F16 nearly clear 1 1 1 n n n n
S17 very It yel 1 1 1 n n n n
F17 nearly clear 1 1 1 n n n n
S18 pale yellow 1 1 2 n n n n
Fig clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 It yellow 1 1 1 n n n n
[S­15--j med gray 3 2 3 n n n y
F15 It yellow 2 2 2 n n n n
S16 It tan 2 2 3 n n n y
F16 It gray 3 1 3 n n n y
S17 4/6/17 It tan 2 1 2 n n n n
517 6/19/17 very pale yel 1 1 2 n n n n
F17 med gray 3 1 3 n n n y
S18 4/25/18 It gray 3 1 3 n n n y(sed)
S18 5/19/18 It gray 3 1 2 n n n y(sed)
F1S 12/9/18 med gray 4 1 4 n n n y(sed)
F1812/14/18 gray 5 1 5 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 It brown 3 1 3 n n n yes(sed)
515 very It yel 1 1 1 n n n n
F15 clear pale yel 2 1 1 n n n n
S16 tan 3 1 3 n n n y
F16 off-white 2 2 2 n n n y slight
S17 It tan 2 1 2 n n n n
F17 no flow n/a n/a n/a n/a n/a n/a n/a
Sig sl off-white 2 1 2 n n n n
F18 almost clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 7/9/19 clear 1 1 1 n n n n
S154 med br. 31 2 3 n nj nj wood debris
F15 beige/It gray 21 2 2 n n n some sed
S16 nearly clear 1 1 2 n n n n
F16 clear 2 2 2 n n n n
S17 3/28/17 It tan 2 1 2 n n n n
S17 6/19/17 It brown 1 1 2 n I n n n

QUALITATIVE STORMWATER RESULTS: Spring 2015 - Fall 2019
VISUAL INSPECTION: Seale 1-5 (1=13est), OR Y/N
COLOR EROSION/
BASIN, lt,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(Imd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
F177/29/17 nearly clear 1 1 2 n n n n
F17 12/8/17 It tan 3 2 3 n n n n
P1712/20/17 med brown 3 2 3 sl sheen n n n
S18 It tan 1 2 1 n n n n
Fla 12/14/18 gray 4 1 4 n n n n
F1812/20/18 tan 3 1 3 n n n n
S19 3/1/19 med br 2 2 3 verysi sheen n n wood pcs
S19 s/12/19 very It br 2 2 2 n n n n
F19 7/3/19 gray 4 4 4 n n n n
F1911/12/19 I It gray/tan 1 21 1 2 n n n n
no;slight rain>16
F1912/23/19 It brown 2 1 2 sl sheen n n hrs,no good flush
#outfall developed to support new mill activities

ATTACHMENT B
PERMIT APPLICATION DATA MARCH 22,2023 (2020-2022)

`amb` ANALYTICAL MONITORING RESULTS
INTERNATIONAL PAPER RIEGELWOOD OPERATIONS
2020-2022
INTERNATIONAL PAPER RIEGELWOOD OPERATIONS
Spr 2020
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B 4/13/2020 m /L 28 120
B 5/5/2020 mg/L 46 120
Standard Methods 5220D E 4/13/2020 mg/L 114 120
Method: Hach 8000 1 4/13/2020 m /L 29 120
T 4/13/2020 m /L 36 120
T 5/5/2020 m /L 46 120
T 6/10/2020 mg/L 46 120
Biological Oxygen Demand B 4/13/2020 m /L 3 30
B 5/5/2020 m /L 4 30
Method: 5-day SOD Test E 4/13/2020 mg/L 17 30
Standard Methods: 5210B 1 4/13/2020 m /L 2 30
T 4/13/2020 mg/L 7 30
T 5/5/2020 m /L 6 30
T 6/10/2020 mg/L 3 30
Total Suspended Solids B 4/13/2020 m /L 135 100
B 5/5/2020 m /L 28 100
Method: Total Suspended Solids E 4/13/2020 m /L 15 100
Standard Methods: 2540D 1 4/13/2020 mg/L 41 100
T 4/13/2020 m /L 55 100
T 5/5/2020 m 1L 103 100
T 6/10/2020 mg/L 114 100
H B 4/13/2020 su 6.7 6-9
B 5/5/2020 su 6.0 6-9
Method: pH Value E 4/13/2020 su 6.6 6-9
Electrometric Method 1 4/13/2020 su 6.8 6-9
Standard Methods 4500 H+B T 4/13/2020 su 6.6 6-9
T 5/5/2020 su 7.9 6-9
T 6/10/2020 su 8.1 6-9

INTERNATIONAL PAPER RIEGELWOOD OPERATIONS too**)
Fall 2020
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B 9/17/2020 m /L <20 120
Standard Methods 5220D E 9/11/2020 m /L 74 120
Method: Hach 8000) 1 9/11/2020 mg/L 49 120
T 9/11/2020 m /L 87 120
120
120
Biological Oxygen Demand B 9/17/2020 m /L 6 30
Method: 5-day BOD Test E 9/11/2020 m /L 4 30
Standard Methods: 5210B 1 9/11/2020 m /L 5 30
T 9/11/2020 m /L 9 30
30
30
Total Suspended Solids B 9/17/2020 m /L 47 100
Method: Total Suspended Solids E 9/11/2020 m /L 6 100
Standard Methods: 2540D 1 9/11/2020 mg/L 91 100
T 9/11/2020 m /L 99 100
100
100
H B 9/17/2020 su 7.1 6-9
Method: pH Value E 9/11/2020 su 7.4 6-9
Electrometric Method 1 9/11/2020 su 8.2 6-9
Standard Methods 4500 H+B T 9/11/2020 su 8 6-9
6-9
6-9
�1

/ORIN INTERNATIONAL PAPER RIEGELWOOD OPERATIONS
Spr 2021
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B 6/2/2021 mg/L 59 120
E 5/12/2021 mg/L 107 120
Standard Methods 5220D 1 5/7/2021 mg/L 95 120
(Method: Hach 8000) T 1/25/2021 mg/L 116 120
T 3/16/2021 mg/L 182 120
T 5/7/2021 mg/L 123 120
T 6/2/2021 mg/L 154 120
Biological Oxygen Demand B 612/2021 mg/L 4 30
E 5/12/2021 mg/L 23 30
Method: 5-day BOD Test 1 5/7/2021 mg/L 8 30
Standard Methods: 5210B T 1/25/2021 mg/L 15 30
T 3/16/2021 mg/L 26 30
T 5/7/2021 mg/L 24 30
T 6/2/2021 mg/L 11 30
Total Suspended Solids B 6/2/2021 mg/L 145 100
E 5/12/2021 mg/L 9 100
Method: Total Suspended Solids 1 517/2021 mg/L 160 100
Standard Methods: 2540D T 1/25/2021 mg/L 120 100
T 3/l6/2021 mg/L 128 100
T 517/2021 mg/L 157 100
T 6/2/2021 mg/L 44 100
pH B 6/2/2021 su 6.7 6-9
E 5/12/2021 su 7.4 6-9
Method: pH Value 1 5/7/2021 su 7.9 6-9
Electrometric Method T 1/25/2021 su 7.5 6-9
Standard Methods 4500 H+ B T 3/16/2021 su 7 6-9
T 5/7/2021 su 8.3 6-9
T 6/2/2021 su 7.5 6-9

INTERNATIONAL PAPER RIEGELWOOD OPERATIONS
Fall 2021
Discharge Characteristic Stonmwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B 8/17/2021 m /L 26 120
E 8/17/2021 m /L 141 120
Standard Methods 5220D 1 8/17/2021 mg/L <20 120
(Method: Hach 8000) T 8/17/2021 mg/L <20 120
T 12/18/2021 m /L 2250 120
120
120
Biological O en Demand B 8/17/2021 m /L 6 30
E 8/17/2021 m /L 31 30
Method: 5-day BOD Test 1 8/17/2021 m /L 3 30
Standard Methods: 5210E T 8/17/2021 m L 13 30
T 12/18/2021 m /L 121 30
30
30
Total Suspended Solids B 8/17/2021 mg/L 6 100
E 8/17/2021 m /L 31 100
Method: Total Suspended Solids 1 8/17/2021 m /L 3 100
Standard Methods: 2540D T 8/17/2021 m /L 33.0 100
T 12/18/2021 m /L 584.0 100
100
100
H B 8/17/2021 su 7.0 6-9
E 8/17/2021 su 7.4 6-9
Method: pH Value 1 8/17/2021 su 7.2 6-9
Electrometric Method T 8/17/2021 su 7.1 6-9
Standard Methods 4500 H+B T 12/18/2021 su 7.2 6-9
6-9
6-9

INTERNATIONAL PAPER RIEGELWOOD OPERATIONS
Spr 2022
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical OWgen Demand B 7/15/2022 m /L 3 120.
Standard Methods 5220D E 4/18/2022 m /L 47 120
(Method: Hach 8000) E 7/15/2022 mg/L 145 120
1 4/18/2022 m /L 25 120
1 7/15/2022 m /L 25 120
T 3/8/2022 m /L 73 120
T 4/18/2022 m /L 44 120
T 6/8/2022 m /L 127 120
T 7/15/2022 mg/L 44 100
Biological Oxygen Demand B 7/15/2022 m /L 26 30
Method: 5-day BOD Test E 4/18/2022 m /L 5 30
Standard Methods: 5210E E 7/15/2022 m /L 12 30
1 4/18/2022 mg/L 3 30
1 7/15/2022 mg/L <20 30
T 3/8/2022 m /L 12 30
T 4/18/2022 mg/L 30 30
T 6/8/2022 m /L 17 30
T 7/15/2022 mg/L 44 30
Total Suspended Solids B 7/15/2022 mg/L 28 100
E 4/l812022 mg/L 11 100
E 7/15/2022 m /L 10 100
.� 1 4/18/2022 m /L 19 100
Method: Total Suspended Solids 1 7/15/2022 mg/L 49 100
Standard Methods: 2540D T 3/8/2022 m /L 40 100
T 4/18/2022 m /L 44 100
T 6/8/2022 m /L 48 100
T 7/15/2022 mg/L 55 100
H B no flow 4/18/2022 su n/a 6-9
B 7/15/2022 su 7.4 6-9
Method: pH Value E 4/18/2022 su 7.1 6-9
Electrometric Method E 7/15/2022 su 7.4 6-9
Standard Methods 4500 H+ B 1 4/18/2022 su 7.2 6-9
1 7/15/2022 su 7.2 6-9
T 3/8/2022 su 7.6 6-9
T 4/18/2022 su 7.5 6-9
T 6/8/2022 su 7.5 6-9
T 7/15/2022 su 7.6 6-9

INTERNATIONAL PAPER RIEGELWOOD OPERATIONS
Fall 2022
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B 12/22/2022 m /L 35 120
E 12/22/2022 m /L 78 120
Standard Methods 5220D 1 12/22/2022 m L 75 120
Method: Hach 8000) T 8/19/2021 m /L 44 120
T 11/10/2022 m /L 119 120
T 11/25/2022 m /L 54 120
T 12/22/2022 mg/L 219 120
Biological Oxygen Demand B 12/22/2022 m /L 2 30
E 12/22/2022 m /L 7 30
Method: 5-day BOD Test 1 12/22/2022 m /L 4 30
Standard Methods: 5210E T 8/19/2021 m /L 8 30
T 11/10/2022 m /L 17 30
T 11/25/2022 m /L 9 30
T 12/22/2022 mg/L 11 30
Total Suspended Solids B 12/22/2022 m /L 79 100
E 12/22/2022 m /L 14 100
Method: Total Suspended Solids 1 12/22/2022 m /L 34 100
Standard Methods: 2540D T 8/19/2021 m /L 30 100
T 11/10/2022 m /L 108 100
T 11/25/2022 m /L 55 100
T 12/22/2022 mg/L 96 100
H B 12/22/2022 su 7.8 6-9
E 12/22/2022 su 6.7 6-9
Method: pH Value 1 12/22/2022 su 6.8 6-9
Electrometric Method T 8/19/2021 su 7.5 6-9
Standard Methods 4500 H+B T 11/10/2022 su 7.2 6-9
T 11/25/2022 su 7.0 6-9
T 12/22/2022 su 6.8 6-9

QUALITATIVE STORMWATER RESULTS: Spring 2020-Fall 2022
VISUAL INSPECTION: Scale 1-5(1=131est),OR Y/N
COLOR EROSION/
BASIN, It,med, FLOATING 5USPENDED DEPOSITION/
SEM STER dk(lmdi CLARITY SOLIDS SOLIDS ODOR FOAM OILSN[EN COMMENT
A
S20 ILbrown 2 1 2 n
P20 sl.off-white 1 1 1 nj nI n n
521 beige 3 1 2 n n n n,na obvious prob
F21 It.yel 2 1 3 m n n n
522 off-white 3 1 2 n n n sm amt sm particles
F22 off-white 2 1 2 n n n n
COLOR EROSION/
BASIN, it,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS FODOR FOAM OLLSHEEN COMMENT
$20 It.gray 3 1 3 n n n y,newly riprapped
S20 very pale yellow 2 1 21 n n n In
F20 sl.white-ish 2 1 1 r: n n n
521 very pale tan 1 1 2 n n n n
F21 It tan 2 1 2 n n n n
S22 clear 1 1 2 n n In n
F22 pale yel 2 1 2 n in n n
C
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSIT{ON/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
S20 paleyellow 1 1 1 n n n n
F20 very It.tan 1 1 1 n n n n
S21 clear 1 1 1 n n n n
F21 very It yel 1 1 1 n n n n
S22 clear 1 f 1 n n n n
F22 clear 1 1 1 n n n n
D
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITiONJ
RIT
SEMESTER dk[Imd} CLAY SOLIDS SOLIDS ODOR FOAM OtL5HEEN COMMENT
520 very pale yellow 1 1 1 nj n n n
F20 clear 1 1 1 n n n n
S21 clear 1 1 1 n n n n
F21 clear 1 1 1 n n n n
S22 clear 1 1 1 m n n n
F22 clear 1 1 1 n n n n
E
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
520 it yellow 2 1 1 si musky odo n n n
F20 It tan 2 1 2 fii—kyocim n n in
S21 Ityelfow 1 1 2 n n n n
s mys cen
F21 ittan 2 1 1 naafi n n n
S22 tan 2 1 2 musty odor n n n
F22 I clear, 1 1 1 n n I n

QUALITATIVE STORMWATER RESULTS: Spring 2020-Fall 2022
VISUAL INSPECTION: Scale 1-5(1=Best),OR YIN
COLOR EROSION/ _
BASIN, lured, I FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
F
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM 011I COMMENT
S20(E+W) clear 2 1 2 n n n n
F20(E of rd) clear 1 1 1 n n n n
F20(W) verypaleyellow 1 1 1 n n n n
S21(E of rd) very pale yellow 1 1 2 n n n n
S21(W) very pale yellow 1 1 2 n n n n
II of rd) It tan 2 1 1 n n n n
F21(W) paletan 2 1 1 n n n n
S22(E of rd) Ityel 1 2 1 n n n n
S22W very It tan 2 2 2 n n very sI sheen r,
F22E pale yel 1 1 1 n n n n
F22W pale yel 1 2 1 n n n n
F1
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
S2 clear 1 1 1 n n n In
F20 noflow r/a n/a n/a n/a n/a n/a n/a
S21 very It.yellow 1 1 1 n n n n
F21 no flow
S22 clear 1 2 1 n n n n
F22 dear 1 1 1 n n n n
G
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY 50LIDS SOLIDS ODOR FOAM CIL SHEEN COMMENT
S20 sl off-white 1 1 1 n n n n
F20 clear 1 1 1 n n n n
S21 clear 1 1 1 very sl musky n n n
F21 very pale yel 1 1 1 R n n n
S22 dear 1 1 1 n n n
F22 dear 1 1 1 n n n n
G1
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEP051TiON/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
S20 nearly clear 1 1 1 n n rn n
F20 clear 1 1 1 n n n n
S21 clear 1 1 1 n n n n
F21 very pale yel 2 1 2 n n n n
S22 It yel 1 2 1 n n n n
F22 ctear 1 1 1 n n n y,no gravel

QUALITATIVE STORMWATER RESULTS: Spring 2020-Fall 2022
VISUAL INSPECTION: Scale 1-5(1=Best),OR Y/N
COLOR EROSION/
BASIN, It,ned, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(Imd} CLARITY SOLIDS SOLIDS ODOR FOAM DILSHEEN COMMENT
G2
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OIL SHEEN COMMENT
S20 very paleyellox 1 1 1 n n In In
F20 no Row n/a n/a n/a n/a n/a n/a n/a
S21 clear 1 1 1 n n n n
F21 no Raw
S22 no Row
F22 no flow
63
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(Imd) CLARITY SOLIDS SOLIDS ODOR FOAM DILSHEEN COMMENT
S20 very pale yel 2 1 1 n n n n
F20 clear 1 1 1 n n n in,
S21 clear 1 1 1 n n In n
F21 very pale yel 1 1 1 n n n n
522 It yel 1 2 1 n n n In
F22 clear 1 1 1 n n In In
Ff
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM DILSHEEN COMMENT
S20 clear 1 1 1 r In n n
F20 clear 1 1 1 r n n n
521 clear 1 1 1 n n n n
F21 sl.off-white 1 1 1 n n n In
S22 clear 1 1 1 n n n In
F22 clear 1 1 I n n In In
1
COLOR EROSION/
8AS1N, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM DILSHEEN COMMENT
S20 very It tan 2 1 1 n n n In
F20 Ityeflow 1 1 2 In In n n
cir,in snip no visible
S21 It gray 2 2 1 In n n source
F21 tan 2 1 2 n In n n
S22 off-white 2 1 2 In In n n
F22 very It br 2 1 2 n n n n
J
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
520 sl yellow 1 1 1 n n In n
F20 nearly clear 1 1 1 n n n In
521 clear 1 1 1 n n In n
F21 nearly clear 1 1 1 n In n In
S22 nearly clear 1 1 1 n n n In
F22 clear 1 1 1 n n n In
K
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SDLIDS ODOR FOAM OIL SHEEN COMMENT
S20 neariyclear 1 11 1 n n In In
F20 clear 1 11 1 nj n In n
some n;unuSw,
ulil'ity ,wnatr nearby,
S21 It yellow-brown 2 1 2 n In n sedimenthagchanged
S21 nearly clear 1 1 1 In In n n resampled;normal
.1721 2 1 2 In n n r, n
522 clear 1 1 1 n n n n
eavy sediment,
F22 It brown 1 1 41 n In n I high traffic

QUALITATIVE STORMWATER RESULTS: Spring 2020-Fall 2022
VISUAL INSPECTION: Scale 1-5{1=Best},OR Y/N
COLOR IEROSION/
BASIN, it,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
L
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dkpmdl CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
S20 It tan 3 1 3 n n n y,cleaned inlet
F20 off-white 2 1 1 n n n n
521 It yellow 2 1 2 n n n n
F21 Ittan 2 1 2 n n n n
H2O standing r1a
S22 stwhitish 2 1 2 n n verysl drain
F22 sl tan tint 1 1 1 n n n n
M
COLOR EROSION/
BASIN, IGmed, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
S20 very It yellow 1 1 1 n nl n n
F20 very pale yeitow 1 1 1 n A n n
S21 nearly clear 1 1 1 n n n n
F21 It yel 1 1 2 n n n n
522 nearly Clear 1 1 1 n n n n
F22 sl tan tint 1 1 1 n n n n
N
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(Imd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
S20 nearly clear 1 1 1 n n n n
F20 clear 1 1 1 n n n n
S21 sl off-white 2 1 1 n n n n
F21 clear 1 1 1 n n n n
S22 clear 1 1 1 n n n In
F22 It tan 3 1 3 n n n V,road sediment
0
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(Imd) CLARITY SOLIDS SOLIDS ODbR FOAM OIL SHEEN COMMENT
S20 sl off-white 1 1 2 n n n n
F20 clear il 1 1 n n n n
$21 nearly clear 1 1 1 n n n n
F21 clear 1 1 1 n n n n
S22 clear 1 1 1 n n n n
F22 clear 1 1 1 n n n n
P
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(Imd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
S20 sl off-white 1 1 1 n n n n
F20 clear 1 1 1 n n n n
S21 med yell"-brown 3 1 3 n In n n
S21 nearly clear 1 1 1 n n n n
F21 no flow
S22 nearly clear 2 2 2 n n n n
F22 off-wh-beige 41. 1 4 n n n y,heavy traffic
ram.

QUALITATIVE STORMWATER RESULTS: Spring 2020-Fall 2022
VISUAL INSPECTION: Scale 1-5(1=Best),OR YIN
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OIL SHEEN COMMENT
R +�
COLOR EROSION
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OIL SHEEN COMMENT
S20 clear 11 1 11 n n n n
F20 clear 1 1 1 n n n n
S21 pale yellow 1 1 1 n n n n
F21 clear 1 1 1 n n n n
S22 clear 1 2 1 n n n n
F22 clear 1 1 1 n n n n
R
COLOR EROSION/
BASIN, It'rned, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OIL SHEEN COMMENT
520 very It tan 2 1 2 n n n n
F20 gray 2 1 3 n n n y,sed fm pk lot
y,manifold cover blew
S21 dk green-gray 5 1 5 n n n of[,9:ed right away
y,re—p much teener.
$21 med.gray, 3 1 3 n n n Still need grading,rock
F21 It gray 1 2 1 n n n n
S22 off-white 3 1 31 n I n n a
F22 clear 1 1 1 n n n y,no gravel
s
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
..� 520 ed green-brown 4 1 4 n n n y.utility eonstr
flo blocked by util
F20 no flow n/a n/a n/a n/a n/a n/a eonstr
521 no Flow n/a n/a n/a n/a n/a n/a n/a
F21 no Flow
S22 no Flaw
F23 off-white 2 1 1 n n n n,flo reversed
T
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
520 It tan z 1 2 n n n n
520 It brown 2 1 2 n n n n
F20 It gray 2 2 3 n n n n
521 It gray 2 1 2 n n n n
S21 med brown 3 2 3 n n n y,sed at gate
S21 Itgray 2 2 2 n n n n
S21 very pale yellow 2 2 j 2 n n n y,wood debris
F21 Itbr 2 2 2 n n n wood debris
522 3/8/22 It tan 2 2 2 n n n sl woody
S22 a/1s/22 very It tan 2 2 2 n n n sl woody
S22618122 Ittan 2 2 2 n n n sl debris
522 7/15/22 qua l only It tan 1 2 2 2 n n n sl debris
F22 It grayl 2 2 2 n n n n
F22 It gray 2 2 2 n n n n
it outfall developed to support new mill activities
e[fe,

ATTACHMENT C
UPDATED SWPPP CERTIFICATION
I¢'1

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources-- 5tormwater Program
Facility Name: International Paper, Riegelwood Mill
Permit Number: NCS000101
Location Address: 865 John L. Riegel Rd.
Riegelwood, NC 28456
County: Columbus
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all
attachments were developed and implemented under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gather and evaluate the information required by the SPPP.
Based on my inquiry of the person or persons who manage the system, or those persons directly responsible
for gathering the information, the information gathered is, to the best of my knowledge and belief, true,
accurate and complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP
has been fully implemented at this facility location in accordance with the terms and conditions of the
stormwater discharge permit."
And
1 am aware that there are significant penalties for falsifying information, including the possibility of fines and
imprisonment for knowing violations."
Sign (according to permit signatory requirements) and return this Certification. DO NOT
SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature Date J-Z2'
Kevin Driscoll Mill Manager
Print or type name of person signing above Title
SPPP Certification 10113

Young, Brianna A
From: Wallace H Coverdale <[e-mail]>
Sent: Thursday, March 9, 2023 11:53 AM
To: Young, Brianna A
Cc: Stephen Greer; Fail, Kimberly; Colleen Cohn
Subject: RE: [External] Riegelwood Mill stormwater permit renewal NCS000101
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Brianna, here is an email I sent earlier.This is our busiest time of year, and International Paper has hired a consultant to
compile the permit submittal update; we will send all the information asap.
From:Young, Brianna A<[e-mail]>
Sent:Wednesday, February 8, 2023 2:01 PM
To:Wallace H Coverdale<[e-mail]>
Cc: Colleen Cohn<[e-mail]>; Stephen Greer<[e-mail]>
Subject: RE: [External] Riegelwood Mill stormwater permit renewal NCS000101
Hello Wallace,
Thank you for your response.After reviewing your response and all information in the permit file history, I have a few
follow-up questions.
• SIC/NAICS: The SIC/NAICS codes are not in our permit file history. Please provide this information. 2611
• In reviewing the permit file history,there is mention made of a Basin 1. Provide more information about Basin
1. Basin 1 was a construction project to build a wet wood storage adjacent to the mill. After construction was
completed,the storage facility was issued a non-discharge permit by the state of NC. A different division of
International Paper owns that facility; it is completely separate from the mill's NPDES permit.
• Please provide the current list of active outfalls with outfall coordinates for each outfall (some basins have
multiple outfalls).There appears to be a number of basins and outfalls,with changes in the renewal application,
so I would like to verify what the current situation is at the facility.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
i

Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: Wallace H Coverdale<[e-mail]>
Sent: Wednesday, February 1, 2023 1:57 PM
To:Young, Brianna A<[e-mail]>
Cc: Colleen Cohn<[e-mail]>; Stephen Greer<[e-mail]>
Subject: [External] Riegelwood Mill stormwater permit renewal NCS000101
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Hello, Brianna, I will go online in the next few days to verify and update the Stormwater Permit Summary Report form;
International Paper does need to update the contact information. In reference to the permit renewal, I submitted all
the requested information with the application renewal, delivered via Fedex on May 15, 2019. The information in the
renewal application is still complete and accurate: there have been no industrial activity changes onsite; outfalls and
coordinates are the same;the description of industrial activity in each drainage area and the SIC (NAISC) codes are
unchanged, and there have been no operational changes since the renewal was submitted. I will send a summary of
additional monitoring data since the permit renewal submission, adding that data to the previous results sent with the
renewal submission. Please contact me if any other information is needed, and I will provide that as quickly as
possible. Thank you for your help to issue our new stormwater permit,Wallace Coverdale
From:Young, Brianna A<[e-mail]>
Sent:Tuesday,January 31, 2023 11:53 AM
To: Hunter M Whiteley<[e-mail]>
Cc: Kevin Burk<[e-mail]>;Tim D Gill <[e-mail]>; Patricia C Soles
<[e-mail]>; Wallace H Coverdale<[e-mail]>
Subject: [External] :Riegelwood Mill stormwater permit NCS000101
Good morning,
I am working on renewing the individual stormwater permit for the Riegelwood Mill (NCS000101). I need
additional information in order to 1) confirm that the information I have is correct and 2) make sure the permit
adequately serves the needs of the facility. Please provide the following:
• Description of industrial activity occurring onsite;
• Confirmation on the number of outfalls and associated coordinates;
• Description of industrial activity in each drainage area;
• SIC (NAICS) code;
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
• Verification that the information in the renewal application is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s)
for the facility. Please review the facility information to make sure it is correct. Information can be updated
using the links provided below, where applicable:
2

• Facility/Company name or ownership: Name/Ownership Change Form
• Owner Affiliation (Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethanyy og ulias
• Stormwater outfall information: Email Bethany Georgoulias
• Visit the eDMR Six Steps website and complete Steps 1 and 2.
• Pay outstanding permit fees: Stormwater ePgMent website
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS (she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/ Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
f i G, ROLINA D
❑rpa rtment 01 EnYlronme nta 14u a l,ty
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
3

11/18/22, 1:58 PM North Carolina Secretary of State Search Results
• File an Annual Report/Amend an Annual Report • Upload a PDF Filing • Order a Document Online -
Add Entity to My Email Notification List • View Filings • Print a Pre-Populated Annual Report form • Print
an Amended a Annual Report form
Business Corporation
Legal Name
International Paper Company
Information
Sosld: 0074970
Status: Current-Active O
Date Formed: 10/13/1941
Citizenship: Foreign
State of Incorporation: NY
Fiscal Month: December
Annual Report Due Date: April 15th
CurrentgnnuaL Report Status:
Registered Agent: CT Corporation System
Addresses
Reg Office Reg Mailing Mailing
160 Mine Lake Ct Ste 200 160 Mine Lake Ct Ste 200 6400 Poplar Avenue
Raleigh, NC 27615-6417 Raleigh, NC 27615-6417 Memphis, TN 38197
Principal Office
6400 Poplar Avenue
Memphis, TN 38197
Officers
Vice President Vice President Vice President Treasurer
Gary Gavin Holly G. Goughnour Errol A. Harris Errol A. Harris
6400 Poplar Avenue 6400 Poplar Avenue 6400 Poplar Avenue 6400 Poplar Avenue
Memphis TN 38197 Memphis TN 38197 Memphis TN 38197 Memphis TN 38197
https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 1/2

11/18/22, 1:58 PM North Carolina Secretary of State Search Results
Vice President Vice President Secretary President
Peter G. Heist Robert M Hunkeler Sharon R. Ryan Mark S. Sutton
6400 Poplar Avenue 6400 Poplar Ave. 6400 Poplar Avenue 6400 Poplar Avenue
Memphis TN 38197 Memphis, TN 38197 Memphis TN 38197 Memphis TN 38197
Stock
Class: 99 SEE CERT
Shares: 0
Par Value 0
https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 2/2

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m 0 z � zN .Z7 (m � OCG7D � Z � r<T1 � D O � � N � TI pCmx >. 2 � C) � Cz Da:) M mnG7 � C = SOD = Npm nOO � Z � o � O � = mOO M: C)
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m 0 M :z 0 .Z7 C C
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m Z I � 07 = = 70mC - Z C _0IT1 � rnrpp C -40 = - = D = pz2C NCD D � N � rrnDKC7 � o = D DN m nmmDMo � Z � c � Z2 z � C � c� � r<iOD � � � C CmCNc) - NNE p CD � � � r,iCD c� � m M C/) Cr O CD 70
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m n O Or mzCmmCD rO m m � ZO � DC = O � Dzm � N 2 mC o7 O z m � roY mDc� -G -nmmD> � Dm O - N Zn" m r ONz
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I—I C I�l (--) N� m m D � urn" m m cC/) m �� N N Z N m cmi)
m

Young, Brianna A
From: Young, Brianna A
Sent: Thursday,July 28, 2022 11:15 AM
To: Wallace H Coverdale
Cc: Kevin Burk; Tran, Kieu M
Subject: RE: [External] :NCS000101 permit renewal
Thank you,Wallace. It was not logged as having been received in our database but I will make sure to log it in now. For
your records, below is an acknowledgement of our receiving the application.
The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program
acknowledges receipt of your renewal application for coverage under NPDES Permit Number NCS000101.
Please continue to comply with all conditions and monitoring requirements in your current NPDES stormwater
permit. As long as you have submitted a complete renewal request package and maintain compliance with those
permit conditions, stormwater discharges from this facility are authorized by that permit until the Division
issues a renewal permit or notifies you of an alternative action. Please note that due to the current backlog and
staff shortages, review of this permit renewal is not scheduled until 2023,however this schedule is subject to
change. Please let me know if you have any questions in the interim.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We
appreciate your patience as we continue to serve the public during this challenging time.
From:Wallace H Coverdale<[e-mail]>
Sent:Thursday,July 28, 2022 11:02 AM
To:Young, Brianna A<[e-mail]>
Cc: Kevin Burk<[e-mail]>
Subject: RE: [External] :NCS000101 permit renewal
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
1

Hey, Brianna. We submitted the renewal application in May, 2019. Additional sample data was sent after the 2019
sampling was completed;that was submitted in January, 2020. Information was also sent to the regional office,to Brian
Lambe. Don't know where it is, but it was submitted long ago.
From:Young, Brianna A<[e-mail]>
Sent:Thursday,July 28, 2022 10:28 AM
To:Wallace H Coverdale<[e-mail]>
Cc:Tran, Kieu M <[e-mail]>
Subject: [External] :NCS000101 permit renewal
Hello Wallace,
It just came to my attention that the permit for the International Paper(NCS000101) expired on November 30, 2019 but
we have not received a renewal application. Please submit a permit renewal application as soon as possible.
Information on how to renew an individual industrial permit can be found on our website at
https://deg.nc.gov/about/divisions/energy-mineral-and-land-resources/stormwater/stormwater-program/npdes-
industrial-program/individual-industrial-permits.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We
appreciate your patience as we continue to serve the public during this challenging time.
2

Young, Brianna A
From: Young, Brianna A
Sent: Thursday,July 28, 2022 1:23 PM
To: Wallace H Coverdale
Subject: RE: [External] :NCS000101 permit renewal
Thank you for this updated information. I will add it to our files.
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We
appreciate your patience as we continue to serve the public during this challenging time.
From: Wallace H Coverdale<[e-mail]>
Sent:Thursday,July 28, 2022 12:54 PM
To:Young, Brianna A<[e-mail]>
Subject: RE: [External] :NCS000101 permit renewal
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Thanks for the acknowledgement; International Paper had to submit further data for the second semester of 2019, after
the application due date; that is attached so you will have the complete application package. Thank you for making sure
the renewal is on record!
From:Young, Brianna A<[e-mail]>
Sent:Thursday,July 28, 2022 11:15 AM
To:Wallace H Coverdale<[e-mail]>
Cc: Kevin Burk<[e-mail]>;Tran, Kieu M <[e-mail]>
Subject: RE: [External] :NCS000101 permit renewal
Thank you,Wallace. It was not logged as having been received in our database but I will make sure to log it in now. For
your records, below is an acknowledgement of our receiving the application.
1

The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program
acknowledges receipt of your renewal application for coverage under NPDES Permit Number NCS000101.
Please continue to comply with all conditions and monitoring requirements in your current NPDES stormwater
permit. As long as you have submitted a complete renewal request package and maintain compliance with those
permit conditions, stormwater discharges from this facility are authorized by that permit until the Division
issues a renewal permit or notifies you of an alternative action. Please note that due to the current backlog and
staff shortages, review of this permit renewal is not scheduled until 2023,however this schedule is subject to
change. Please let me know if you have any questions in the interim.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We
appreciate your patience as we continue to serve the public during this challenging time.
From:Wallace H Coverdale<[e-mail]>
Sent:Thursday,July 28, 2022 11:02 AM
To:Young, Brianna A<[e-mail]>
Cc: Kevin Burk<[e-mail]>
Subject: RE: [External] :NCS000101 permit renewal
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Hey, Brianna. We submitted the renewal application in May, 2019. Additional sample data was sent after the 2019
sampling was completed;that was submitted in January, 2020. Information was also sent to the regional office,to Brian
Lambe. Don't know where it is, but it was submitted long ago.
From:Young, Brianna A<[e-mail]>
Sent:Thursday,July 28, 2022 10:28 AM
To: Wallace H Coverdale<[e-mail]>
Cc:Tran, Kieu M <[e-mail]>
Subject: [External] :NCS000101 permit renewal
Hello Wallace,
2

It just came to my attention that the permit for the International Paper (NCS000101) expired on November 30, 2019 but
we have not received a renewal application. Please submit a permit renewal application as soon as possible.
Information on how to renew an individual industrial permit can be found on our website at
https://deg.nc.gov/about/divisions/energy-mineral-and-land-resources/stormwater/stormwater-program/npdes-
industrial-program/individual-industrial-permits.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We
appreciate your patience as we continue to serve the public during this challenging time.
3

International Paper, Riegelwood Mill
Stormwater NPDES#NCS 000101
Renewal Application 2019
Changes in Industrial Activities 20IS-2019
The Riegelwood Mill has experienced several changes to the industrial process during the term of the
current permit. Some do, and some do not, affect stormwater operations, as noted below.
• The mill woodyard was modernized and expanded to increase the mill's ability to produce its
own chips, resulting in the creation of Outfall T at the new mill wood truck entrance and
scalehouse. Other than the new truck entrance, there is no change in stormwater operations;
other affected areas drain to the mill wastewater treatment system.
• Project Zebra was another mill modernization that changed the process from a pulp/paper mill
to a strictly pulp mill. This large project eliminated dozens of process chemicals from the site,
all in non-stormwater areas. One result of Project Zebra was an increase in containerized pulp
and a corresponding increase in truck traffic, moving the containers of pulp into and out of
Basin R. Another direct result is a switch to strictly pine wood, with no hardwood mix. That
creates a change in the type of wood chips stored and handled in Basins C, D, E, F, and G. More
pine = more turpentine production as a byproduct. No. 1 power boiler was also taken off line as
part of Project Zebra. The entire Zebra project has no impact on stormwater.
• During this period, the mill began burning more natural gas and less fuel oil in its power boilers
and the#4 lime kiln. A corresponding change is the cessation of oil barging at Basin A; the mill
maintains the physical infrastructure to receive barges, but has not barged oil in over 2 years.
• The mill produces potable water, and recently converted the disinfection process from the use
of chlorine to sodium hypochlorite. This has resulted in a large decrease in chlorine onsite, and
will eventually result in the complete removal of chlorine from the site. This switch has no
effect on stormwater.
• In Basin Q, the backwash pond from the water plant filters has been permanently piped to the
intake pumps at the pumphouse, and electrical backup has been provided. This minimizes the
chance of releases of backwash into the stormwater basin.
• The unused underground black liquor line has been removed from Basin H, and the adjacent
black liquor ponds have been emptied and cleaned out, and are no longer in use. Since black
liquor was the potential pollutant at Outfalls H and F3,they have been removed from the
SWPPP.

INTERNATIONAL PAPER
RIEGELWOOD MILL
JOHN L.RIEGEL ROAD
RIEGELWOOD,NC 28456
PHONE [phone]
May 20, 2019
DEMLR—Stormwater Program
Department of Environmental Quality
127 Cardinal Dr. Extension
Wilmington,NC 28504
Subject: Individual Permit Renewal,NPDES Permit NCS000101
Dear Brian:
As requested,enclosed is the 2019 renewal application for Stormwater NPDES Permit Number
NCS000101. This application contains the Renewal Application Form, Stormwater Pollution
Prevention Plan(SWPPP)Development and Implementation Certification,and supplemental
information and checklist. In addition, an updated signatory authority is included.
Changes to the SWPPP are reflected in the attached SWPPP revision and on the updated SWPPP map.
Details are attached to the Renewal Application Form and are included in the narrative of changes in
industrial activities. Changes include the addition of Outfall T due to new industrial activities. In
addition, five stormwater outfalls were deleted because of removal or lack of potential pollutants, or
due to redirection of runoff discharges. These are: Outfalls H, K, G3, Q1, and Rl. SWPPP changes
also include removal of three gravel trailer/container storage areas,Basins L,R, and S, from the
sampling protocol, as we discussed by phone on May 16. 2019.
If you have questions or need additional information,please call Wallace Coverdale at(910)362-4590.
Sincerely,
Wallace Coverdale
Environmental Services Coordinator
910-362-4590 (o)
910-512-6581 (c)
[e-mail]

INTERNATIONAL PAPER
RIEGELWOOD MILL
JOHN L.RIEGEL ROAD
RIEGELWOOD,NC 28456
PHONE [phone]
January 21, 2020
DEMLR—Stormwater Program
Department of Environmental Quality
1612 Mail Service Center
Raleigh,NC 27699-1612
Certified Mail: 1017 1000 0000 9581 0535
Subject: Individual Permit Renewal,NPDES Permit NCS000101
Dear Stormwater Program:
Enclosed are analytical and quantitative data for 2019,completing International Paper's application for
renewal of NPDES Stormwater Permit#000101. The renewal application was submitted May 15,2019,
six months before the current permit expiration, as required,however, analytical and quantitative results
for 2019 were not available at that time. Additionally enclosed is an updated SPPP Development and
Implementation Certification, documenting the change in management. Please add this information to
the renewal file. You may contact Wallace Coverdale of my staff if any additional information is
required at 910-362-4590 or [e-mail].
I certify,under penalty of law,that this document and all attachments were prepared under my direction
or supervision in accordance with a system designed to assure that qualified personnel properly gather
and evaluate the information submitted. Based on my inquiry of the person or persons who manage the
system,or those persons directly responsible for gathering the information,the information submitted
is,to the best of my knowledge and belief,true,accurate, and complete. I am aware that there are
significant penalties for submitting false information,including the possibility of fines and
imprisonment for knowing violations.
Sincerely,
Kevin Driscoll,Mill Manager

International Paper, Riegelwood Mill
Permit# NSC000101 Renewal Application 2019
SWPPP Changes
(Attachment to Renewal Application)
The changes below are the main changes to International Paper's SWPPP. Several Basins were added, or
deleted, and some individual outfall locations were deleted. Details follow:
• Basin T was added to the SWPPP when the mill woodyard was upgraded. A new wood truck
entrance and scalehouse were constructed, and the new outfall was created to include runoff
from this new location of industrial activity.
• Two stormwater basins were removed from the SWPPP, Basins H and K, because of the lack of
potential pollutants. The unused, underground black liquor line has been removed from Basin
H, and the adjacent black liquor ponds have been emptied and cleaned out, and are no longer
in use. Black liquor was the potential pollutant in Basin H. The only mill activities in that area
are a seldom-used, dead-end mill road and a rail spur for wood chip cars. Basin K also has no
potential pollutants, only a little-used access road and an underground natural gas line.
• Several individual outfalls were also removed: G3, F2, and R1. Outfall G3 is similar to Basin H
above, with removal of the black liquor line from the area. The same seldom-used, dead-end
mill road and rail spur for wood chips are the only activities in this area. Outfall F2 has been
removed; runoff has been rechanneled to discharge at F1. Similarly, Outfall R1 was removed
because runoff now discharges through Outfall S.
Further SWPPP proposals (post Brian Lambe discussion 5/16/19)
• Remove graveled storage areas from sampling plan: Basins L, R, S, plus old truck staging
area.
• Add truck staging to plan.
• These areas will remain in the plan and be inspected monthly as usual, but will not be
sampled. Inspections will verify that runoff control measures remain in place and are well-
maintained, and also ensure that only permitted activities take place in these areas.

Ask Brian:
• Product storage areas-the only potential pollutant is sediment—listed as a potential
pollutant in plan and on map? Or, list none?
• Would need to add old truck staging to plan, measure, and get coordinates of outfall.
Post signage at entrance and outfall.
• Brian also suggested Basin P (south laydn yd); however,that area is still used for
maintenance matl storage, incl. some transformers, so I did not include it.
• He also mentioned K(S. access rd), but I already took that out of the plan; I could revisit
that with him, also H (NE of#2 LP),which I also removed from the plan.)
• Need to arrange mo. insp. sheet and responsibility for old truck staging area. PSD?
• No sampling results to log.
• ?Future of P? Probably need to discuss expectations w/Brian in light of above
proposals.
Note: need coordinates for G1, G2, add to plan/map.
Add 2 areas of riprap to plan.

QUALITATIVE STORMWATER RESULTS: Spring 2015 - Fall 2019
VISUAL INSPECTION: Scale 1-5 (1=13est),OR Y/N
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
A
S15 It gray 3 1 2 n n n y, rd by 3LT
F15 It yellow 2 1 2 n n n n
S16 It tan 2 1 3 n n n n
F16 It yel 2 1 2 n n n slight
S17 It gray 3 2 3 n n n y
F17 It gray 2 1 3 n n n y
S18 It gray 2 1 2 n n n n
F18 med br 3 1 2 n n n y
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 yellow/brown 2 2 2 n n n slight
B
S15 It gray 2 1 1 n n n n
F15 no smp;constr n/a n/a n/a n/a n/a n/a n/a
S16 off-white 2 1 2 n n n n
F16 It gray 3 1 3 n n n none visible
S17 It gray 3 1 3 n n n searching
F17 9/5/17 It tan 3 1 2 n n n y into pond
F1712/8/17 It tan 2 1 3 n n n y-at fenceline
F1712/20/17 It gray 2 1 1 n n n n
S18 4/25/18 sl. cloudy wh 1 1 2 n n n n
S18 5/22/19 sl. white 1 2 1 n n n n
F18 very It gray 1 1 2 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 pale yellow 1 1 1 n n n n
S15 It.yel 1 1 1 n n n n
F15 clear 1 1 1 n n n n
S16 It yellow 1 1 1 n n n n
F16 very It yel 1 1 1 n n n sl above inlet prot.
S17 pale yellow 1 1 1 n n n n
F17 very It yel 1 1 1 n n n n
S18 clear 1 1 1 n n n n
F18 clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 It yellow 1 2 2 n n n n
S15 I pale yel 2 2 1 n n n It. chip debris
F15 clear 1 1 1 n n n n
S16 clear 1 2 1 n n n n
F16 clear 1 1 1 n n n n
S17 It yel 1 1 2 n n n n
F17 very It yel 1 1 1 n n n n
S18 clear 1 1 2 n n n n
F18 almost clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 nearly clear, 1 1 2 n I n I n I n

QUALITATIVE STORMWATER RESULTS: Spring 2015 - Fall 2019
VISUAL INSPECTION: Scale 1-5 (1=13est),OR Y/N
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
E
S15 yellow 1 1 1 n n n n
F15 It tan 1 1 1 n n n n
S16 very It tan 1 1 1 n n n n
F16 7/23/17 sl.yellow 1 1 1 n n n n
F169/19/17 It yellow 1 1 2 sl musky n n n
F16 12/29/17 It yellow 1 1 2 sl moldy n n n
517 3/28/17 med yellow 1 1 2 n n n n
S17 6/19/17 It brown 1 1 2 n n n n
F17 7/29/17 tan 2 1 2 n n n n
F17 8/5/17 It tan 1 1 2 sl musty odor n n n
F17 12/8/17 It tan 2 1 2 n n n n
F17 12/20/27 It amber 1 1 1 n n n n
S18 It yel 1 1 1 n n n n
F18 It yel 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 It yellow 2 1 2 oily odor n n n
S15 med br 2 2 3 n n n wood debris
S15 It yel 1 1 1 n n n n
F15 almost clear 2 1 2 n n n n
S16(E) It yellow 1 1 1 n n n n
S16(W) med br 2 1 2 n n n n
F16(E) med br 2 2 2 n n n n
F16(W) It yellow 1 1 1 n n n n
S17 (E) It yellow 1 1 1 n n n n
S17 (W) It yellow 1 2 1 n n n n
F17 (E+W) very It yel 1 1 1 n n n n
S18(E+W) clear 1 1 1 n n n n
F18(E+W) very It br 3 1 3 sl oily odor n n y
S19 (E+W) no flow n/a n/a n/a n/a n/a n/a n/a
F19(E+W) very It tan 1 1 2 n n n n
F1
S15 It yel 1 1 1 n n n n
F15 no flow n/a n/a n/a n/a n/a n/a n/a
S16 pale yellow 1 1 1 n n n n
F16 It yellow 1 1 1 n n n n
S17 It yel 1 1 2 n n n n
F17 no flow n/a n/a n/a n/a n/a n/a n/a
S18 sl.whitish 2 1 2 n n n n
F18 almost clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 It yellow 1 1 2 n n n n
S15 It yel 1 1 1 ni n n n
F15 It yel 2 1 1 nj n n n
S16E4 pale yellow 1 11 1 nj n n n

QUALITATIVE STORMWATER RESULTS: Spring 2015 - Fall 2019
VISUAL INSPECTION: Scale 1-5 (1=13est),OR Y/N
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
F16 clear 1 1 1 n n n n
S17 very It yel 1 1 1 n n n n
F17 clear 1 1 1 n n n n
S18 very It yel 1 1 1 n n n n
F18 clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 It yellow 1 1 1 n n n n
G1
S15 very pale yel 1 1 1 n n n n
F15 It yellow 1 1 1 n n n n
S16 very pale yel 1 1 1 n n n n
F16 clear 1 1 1 n n n n
S17 very It yel 2 1 1 n n n n
F17 clear 1 1 1 n n n n
S18 sl.white/cloudy 2 1 1 n n n n
F18 clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 almost clear 1 1 1 n n n n
G2
S15 very pale yel 1 1 1 n n n n
F15 clear It yel 2 1 2 n n n n
S16 off-white 2 1 2 n n n n
F16 almost clear 1 1 1 n n n n
S17 very It yel 1 2 1 n n n n
F17 clear 1 1 1 n n n n
S18 It yellow 1 2 1 n n n n
F18 no flow n/a n/a n/a n/a n/a n/a n/a
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 very It yellow 1 1 1 n n n n
G3
S15 It yel 2 1 1 n n n n
F15 It yel 1 1 1 n n n n
S16 very It yel 1 1 1 n n n n
F16 very It tan 1 1 1 n n n n
S17 ver It yel 1 1 2 n n n n
F17 clear 1 1 1 n n n n
S18 It tan 1 1 2 n n n n
F18 clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 very pale yel 1 1 2 n n n n
S15 nearly clear 1 1 1 n n n n
F15 clear It yel 2 1 1 n n n n
S16 pale yellow 1 1 1 n n n n
F16 clear 1 1 1 n n n n
S17 nearly clear 1 1 1 n n n n
F17I It amber 1 1 1 n n n n

QUALITATIVE STORMWATER RESULTS: Spring 2015 - Fall 2019
VISUAL INSPECTION: Scale 1-5 (1=13est),OR Y/N
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
S18 clear 1 1 1 n n n n
F18 clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 clear 1 1 1 n n n n
S15 It yel 1 1 1 n n n n
F15 It yel 2 1 2 n n n n
S16 very pale yel 1 1 1 n n n n
F16 dk gray 3 1 3 n n n y(source not visible)
S17 yellow 2 2 2 n n n n
F1712/8/17 It gray 2 1 2 n n n n
F1712/20/17 gray 3 1 1 n n n none visible
S18 It tan 2 1 1 n n n n
F18 12/14/18 It gray 4 1 4 n n n n
F1812/20/18 It brown 3 1 3 n n n y(no visible source)
F1812/28/18 almost clear 2 1 2 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 gray 3 1 3 foam on pad n n n
j
S15 clear 1 1 1 n n n n
F15 It yellow 1 1 1 n n n n
S16 pale yellow 1 1 1 n n n n
F16 clear 1 1 1 n n n n
S17 It yel 1 1 2 n n n nyellow
F17 nearly clear 1 1 1 n n n n
S18 clear 1 1 1 n n n n
F18 It tan 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 clear 1 1 1 n n n n
S15 clear 1 1 1 n n n n
F15 very pale yel 1 1 1 n nj n n
S16 pale beige 2 1 1 n n n n
F16 clear 1 1 1 n n n n
S17 clear 1 1 1 n n n n
F17 clear 1 1 1 n n n n
S18 clear 1 1 1 n n n n
F18 very It tan 2 1 2 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 It tan 2 1 2 n n n n
S15 It gray 2 1 2 n n n slight
F15 It gray 2 1 2 n n n n
S16 very It tan 2 1 1 n n n n
F16 sl off-white 2 1 2 n n n n
S17 3/28/17 med gray 41 1 4 n n n y
11517 6/19/17 kery pale yel 1 11 21 1 n n n n

QUALITATIVE STORMWATER RESULTS: Spring 2015 - Fall 2019
VISUAL INSPECTION: Scale 1-5 (1=13est),OR Y/N
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
F17 It gray 2 1 2 n n n n
S18 sl off-white 2 1 2 n n n n
F18 12/9/18 It tan 3 1 3 n n n y
F1812/14/18 tan 3 1 3 n n n y
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 It tan 1 1 2 n n n n
S15 very pale yel 2 1 2 n n n n
F15 It gray 3 1 2 n n n some sed
S16 very pale yel 1 1 1 n n n n
F16 very pale yel 2 1 1 n n n n
S17 3/28/1 It gray 3 2 3 n n n n
S17 6/19/1 It brown 2 2 2 n n n n
F17 It tan 2 1 2 n n n n
S18 sl off-white 1 1 1 n n n n
F18 clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 I med brown 3 2 3 n n n n/heavy rain,turbid
S15 clear pale yel 1 1 1 n n n n
F15 clear 1 1 1 n n n n
S16 pale yellow 1 1 2 n n n n
F16 clear 1 1 1 n n n n
S17 sl. white 1 2 1 n n n n
F17 clear 2 1 1 n n n n
S18 nearly clear 1 1 1 n n n n
F18 It.yellow 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 It yellow 1 1 1 n n n n
0
S15 clear 1 1 1 n n n n
F15 clear 1 1 1 n n n n
S16 very It yel 2 1 1 n n n n
F16 nearly clear 1 1 1 n n n n
S17 very It tan 2 1 2 n n n n
F17 clear 2 1 1 n n n n
S18 nearly clear 1 1 1 n n n n
F18 clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 clear 1 1 2 n n n n
S15 nearly clear 1 1 1 n n n n
F15 clear pale yel 1 1 1 n n n n
S16 clear 1 1 1 n n n n
F16 sl white color 2 1 1 n n n n
S17 nearly clear 2 1 1 n n n n
F17I clear 1 1 1 n n n n

QUALITATIVE STORMWATER RESULTS: Spring 2015 - Fall 2019
VISUAL INSPECTION: Scale 1-5 (1=13est),OR Y/N
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
S18 clear 1 1 1 n n n n
F18 clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 med yellow 2 1 3 n n n some sed @ fence
S15 very It tan 2 2 1 n n n n
F15 clear pale yel 1 1 1 n n n n
S16 pale yellow 1 1 1 n n n n
F16 nearly clear 1 1 1 n n n n
S17 very It yel 11 1 1 n ni n n
F17 nearly clear 1 1 1 n n n n
S18 pale yellow 1 1 2 n n n n
F18 clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 It yellow 11 1 1 n n n n
S15 med gray 3 2 3 n n n y
F15 It yellow 2 2 2 n n n n
S16 It tan 2 2 3 n n n y
F16 It gray 3 1 3 n n n y
517 4/6/17 It tan 2 1 2 n n n n
S17 6/19/17 very pale yel 1 1 2 n n n n
F17 med gray 3 1 3 n n n y
S184/25/18 It gray 3 1 3 n n n y(sed)
S18 5/19/18 It gray 3 1 2 n n n y(sed)
F1812/9/18 med gray 4 1 4 n n n y(sed)
F1812/14/18 gray 5 1 5 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 It brown 3 1 3 n n n yes(sed)
S15 very It yel 1 1 1 n n n n
F15 clear pale yel 2 1 1 n n n n
S16 tan 3 1 3 n n n y
F16 off-white 2 2 2 n n n y slight
S17 It tan 2 1 2 n n n n
F17 no flow n/a n/a n/a n/a n/a n/a n/a
S18 sl off-white 2 1 2 n ni n n
F18 almost clear 1 1 1 n n n n
S19 no flow n/a n/a n/a n/a n/a n/a n/a
F19 7/9/19 clear 1 1 1 n n n n
S15# med br 3 2 3 n n n wood debris
F15 beige/It gray 2 2 2 n n n some sed
S16 nearly clear 1 1 2 n n n n
F16 clear 2 2 2 n n n n
517 3/28/17 It tanj 2 1 2 n n n n
S17 6/19/17 11 It brown 1 1 1 2 n n nj n

QUALITATIVE STORMWATER RESULTS: Spring 2015 - Fall 2019
VISUAL INSPECTION: Scale 1-5 (1=13est),OR Y/N
COLOR EROSION/
BASIN, It,med, FLOATING SUSPENDED DEPOSITION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN COMMENT
F17 7/29/17 nearly clear 1 1 2 n n n n
F17 12/8/17 It tan 3 2 3 n n n n
F1712/20/17 med brown 3 2 3 sl sheen n n n
S18 It tan 1 2 1 n n n n
F1812/14/18 gray 4 1 4 n n n n
F1812/20/18 tan 3 1 3 n n n n
S19 3/1/19 med br 2 2 3 very sl sheen n n wood pcs
S19 5/12/19 very It br 2 2 2 n n n n
F19 7/3/19,1 gray, 4 4 4 n n n n
F1911/12/19 It gray/tan 2 1 2 n n n n
no;slight rain>16
F1912/23/19 It brown 2 1 2 sl sheen n n hrs,no good flush
#outfall developed to support new mill activities

2010 STORMWATER STATUS SUMMARY
Quality Deteriorating Needs work
Outfall Priority Quality issues Quality/Cond Y/N &amt. Notes
A L Y min
B H det Y maj #
C HH consistently poor Y med
D L Y med
E HH consistently poor YY maj
F M consistently low YY maj
F1 M det Y med
F2 HH consistently very poor Y med
F3** new M Y now **
G L Y min
G1 HH consistently poor YY med
G2 M consistently marginal YY med #
G3 L Y min
G4 L Y min
G5 L Y min
G6 L Y min
G7 M det Y med ^
G8 L Y min
G9 L Y min
G10 L Y min
G11 L Y min
G12 M det Y med ^
G13 L Y med
G14 M det Y med ^
H L Y min
*possibly change
I HH very to qual det Y maj outfall
J L Y min
K L det Y med
^ plan, possibly
L M det Y maj change outfall
M M det Y med ^
N L N
O M det Y min ^
P L Y min
P1 L N
Q L Y min
Q1 L N
Q2**new M now **
R HH to qual Y maj
R1 L Y med
S M erosion corrected det N ^^

PRIORITIES
New outfalls; Numerical
remove** Priority groups Priorities order
F3 top Basin F 1
Q2 top Basin 1 2
#2 Basins E&D 3
Basin Q(need
Worst quality F2 #2 to fix DEF first) 4
1 #2 Basin C 5
#2 Basin R 6
#2 Basin G 7
HH, poor
quality* C #3 Basin B 8
E #3 Basin M 9
F #3 Basin K 10
G1 #3 Basin L 11
R #3 Basin J 12
#4 Basin O 13
#4 Basin A 14
H-Mconsis# B #4 Basin H 15
G2 #4 Basin P 16
M-det^ F1
G7
G12
G14
L
M
O
K
Low A
D
G3-6
G 8-11, 13
H
J
P
Q
R1

INTERNATIONAL PAPER
RIEGELWOOD MILL
JOHN L. RIEGEL ROAD
RIEGELWOOD,NC 28456
PHONE [phone]
May 15, 2019
DEMLR— Stormwater Program MAY 16 201)
Department of Environmental Quality
1612 Mail Service Center DENR-ILMD QUALITY
Raleigh, NC 27699-1612 STARriMVV 1TER PEA fOVI- ING
Certified Mail: 7006 0100 0004 8355 1633
Subject: Individual Permit Renewal,NPDES Permit NCS000101
Dear Stormwater Program:
Enclosed is the completed renewal application for Stormwater NPDES Permit Number NCS000101.
This application contains the Renewal Application Form, Stormwater Pollution Prevention Plan
(SWPPP) Development and Implementation Certification, and supplemental information and checklist.
A current SWPPP Site Map is included, along with a summary of analytical and qualitative results to
date for the sampling period of the 5-year permit. 2019 results will be submitted as they become
available. A summary of Best Management Practices at the site and a narrative of significant changes
in industrial activities are also enclosed. In addition, an updated signatory authority is included.
Changes to the SWPPP include the addition of Outfall T due to new industrial activities. Five
Stormwater outfalls were deleted because of removal or lack of potential pollutants, or due to
redirection of runoff discharges. Details are attached to the Renewal Application Form and are included
in the narrative of changes in industrial activities. These changes are reflected on the attached SWPPP
map.
If you have questions or need additional information, please call Wallace Coverdale at(910)362-4590.
1 certify, under penalty of law, that this document and all attachments were prepared under my direction
or supervision in accordance with a system designed to assure that qualified personnel properly gather
and evaluate the information submitted. Based on my inquiry of the person or persons who manage the
system, or those persons directly responsible for gathering the information,the information submitted
is,to the best of my knowledge and belief, true,accurate, and complete. 1 am aware that there are
significant penalties for submitting False information, including the possibility of fines and
imprisonment for knowing violations.
Sincerely,
z'
Floyd Whitmire, Mill Manager

Permit Coverage
Renewal Application Form
_ National Pollutant Discharge Elimination System NP NC Permit Number
i15'frlJlilriellf Ur
Stormwater Individual Permit S 000to�
Quality
lease provide your permit number in box in the upper right hand corner, complete the information in the space provided
below and return the completed renewal form along with the required supplemental information to the address indicated.
Owner Information * Address to which permit correspondence will be marled
Owner/Organization Name: International Paper
Owner Contact: Kimberly Fail,Environmental Manager
Mailing Address: 865 John L.Riegel Rd,Riegelwood NC 28456
865 John L,Riegel Rd,Riegelwood NC 28456
Phone Number: 910-362-4753
Fax Number: nfa
E-mail address: [e-mail]
Facility Information_
Facility Name: Riegelwood Mill
Facility Physical Address: 865 John L.Riegel Rd
Riegelwood,NC 28456
Facility Contact: Kimberly Fail
Mailing Address: 865 John L.Riegel Rd.
Riegelwood,NC 28455
Phone Number: 910-362-4753
Fax Number: We
E-mail address: [e-mail]
Permit Information
Permit Contact: Wallace coverdale
Mailing Address, 865 John L.Riegel Rd
Riegelwood,NC 28456
`--,"hone Number: 910-362-4590
ax Number: nra
E-mail address: [e-mail] -i� ,f
Discharge Information MA � � ��F� f
Receiving Stream: cape rear River i6lrt L kf J
Stream Class: C;Sw
nENR-LAND QUALITY
Basin: Cape Fear River --- STGRiSri'AIATER PERMIT TING
Sub-Basin:
Number of Outfalls: 21
Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
Facility changes and upgrades are detailed in the Supplemental Information section of the permit application. Tfie main changes are a new mill woodyard and changes in production grades.
There are some changes to the Slormwater Prevention Pollution Plan{SWPPP)which are detailed on an attached page. These changes include addition of Basin T,and removal of Outralls H and K.
Outfall K was removed because of the lack of potential pollutants. Outfall H was removed because of removal of possible contaminants,as was Outfall G3.
Oulfalls F2 and R1 were removed from the SWPPP due to consolidation of Rows with utter ouffalls,
CERTIFICATION
I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief
such information is tru , corY►piete and acquirate.
Signature Date 5 /� /9
Floyd Whitmire Facility Manager
Print or type name of person signing above Title
DEMLR - Stormwater Program
Please return this completed application form Dept. of Environmental Quality
and requested supplemental information to: 1612 Mail Service Center
Raleigh, North Carolina 27699-1612

/IONN International Paper, Riegelwood Mill
Permit# NSC000101 Renewal Application 2019
SWPPP Changes
(Attachment to Renewal Application)
The changes below are the main changes to International Paper's SWPPP. Several Basins were added, or
deleted,and some individual outfall locations were deleted. Details follow:
• Basin T was added to the SWPPP when the mill Woodyard was upgraded. A new wood truck
entrance and scalehouse were constructed, and the new outfall was created to include runoff
from this new location of industrial activity.
• Two stormwater basins were removed from the SWPPP, Basins H and K, because of the lack of
potential pollutants. The unused, underground black liquor line has been removed from Basin
H, and the adjacent black liquor ponds have been emptied and cleaned out,and are no longer
in use. Black liquor was the potential pollutant in Basin H. The only mill activities in that area
,,*41 are a seldom-used, dead-end mill road and a rail spur for wood chip cars. Basin K also has no
potential pollutants, only a little-used access road and an underground natural gas line.
• Several individual outfalls were also removed: G3, F2, and R1. Outfall G3 is similar to Basin H
above,with removal of the black liquor line from the area. The same seldom-used, dead-end
mill road and rail spur for wood chips are the only activities in this area. Outfall F2 has been
removed; runoff has been rechanneled to discharge at F1. Similarly,Outfall R1 was removed
because runoff now discharges through Outfall S.
IA"I,

SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL
NPDES STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete:
(Do not submit the site Stormwater Pollution Prevention Plan)
Initials
1. A current Site Map From the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of materials, disposal areas, process areas and
loading and unloading areas), drainage structures, drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
2. A summary of Analytical Monitoring results during the term of the existing permit
(if your permit required analytical sampling). Do not submit individual lab reports.
The summary can consist of a table including such items as outfall number,
parameters sampled, lab results, date sampled, and storm event data.
3. A summary of the Visual Monitoring results. Do not submit individual monitoring
reports. The summary can consist of a table including such items as outfall number,
parameters surveyed, observations, and date monitoring conducted.
... 4. A summary of the Best Management Practices utilized at the permitted facility.
Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned, please include
information on these BMP's.
5. A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of
work processes, changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
6. Certification of the development and implementation of a Stormwater Pollution
Prevention Plan for the permitted facility (Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal, then the last years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)

ANALYTICAL MONITORING RESULTS
INTERNATIONAL PAPER RIEGELWOOD OPERATIONS
Spring 2015-Spring 2019
Spring 2015
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B 6/27/2015 mg/L 60 120
Standard Methods 5220D E 6/27/2015 mg/L 148 120
Method: Hach 8000 1 6/27/2015 m /L 70 120
T 6/27/2015 m /L 194 120
Biological Oxygen Demand B 6/27/2015 m /L 6 30
Method: 5-day BOD Test E 6/27/2015 m /L 21 30
Standard Methods: 5210B 1 6/27/2015 m /L 5 30
T 6/27/2015 m /L 23 30
Total Suspended Solids B 6/27/2015 m /L 54 100
Method: Total Suspended Solids E 6/27/2015 m /L 5 100
Standard Methods: 2540D 1 6/27/2015 m /L 46 100
T 6/27/2015 m /L 25 100
H B 6/27/2015 su 7.4 6-9
Method: pH Value E 6/27/2015 su 7.1 6-9
Electrometric Method 1 6/27/2015 su 7.8 6-9
Standard Methods 4500 H+ B T 6/27/2015 su 7.6 6-9
ANALYTICAL MONITORING RESULTS
INTERNATIONAL PAPER RIEGELWOOD OPERATIONS
Fall 2015
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B 12/7/2015 m /L 53 120
Standard Methods 5220D E 11/2/2015 m /L 131 120
Method: Hach 8000 1 11/2/2015 m /L 78 120
T 11/2/2015 m /L 115 120
,,•., Biological Oxygen Demand B 12/7/2015 m /L 12 30
Method: 5-day BOD Test E 11/2/2015 m /L 12 30

Standard Methods: 5210B 1 11/2/2015 m /L r 3 30
T 11/2/2015 m /L ND/5 30
Total Suspended Solids B 12/7/2015 m /L 26 100
Method: Total Suspended Solids E 11/2/2015 m /L 7 100
Standard Methods: 2540D 1 11/2/2015 m /L 90 100
T 11/2/2015 m /L 68 100
H B 12/7/2015 su 7.2 6-9
Method: pH Value E 11/2/2015 su 7.5 6-9
Electrometric Method 1 11/2/2015 su 8.7 6-9
Standard Methods 4500 H+ B T 11/2/2015 su 8.2 6-9
ANALYTICAL MONITORING RESULTS
INTERNATIONAL PAPER RIEGELWOOD OPERATIONS
Spring 2016
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B 5/29/2016 m /L <20 120
Standard Methods 5220D E 1/15/2016 m /L 53 120
Method: Hach 8000 E 2/24/2016 m /L 73 120
E 3/20/2016 m /L 46 120
E 5/29/2016 m /L 64 120
1 5/29/2016 m /L 92 120
T 5/29/2016 mg/L 170 120
Biological Oxygen Demand B 5/29/2016 m /L 3 30
Method: 5-day BOD Test E 1/15/2016 m /L 6 30
Standard Methods: 5210E E 2/24/2016 m /L 25 30
E 3/20/2016 m /L 15 30
E 5/29/2016 m /L 10 30
1 5/29/2016 m /L 5 30
T 5/29/2016 mg/L 15 30
Total Suspended Solids B 5/29/2016 m /L 42 100
Method: Total Suspended Solids E 1/15/2016 m /L 5 100
Standard Methods: 2540D E 2/24/2016 m /L 3 100
E 3/20/2016 m /L 5 100
E 5/29/2016 m /L 5 100
1 5/29/2016 m /L 24 100
T 5/29/2016 mg/L 84 100
H B 5/29/2016 su 6.7 6-9
Method: pH Value E 1/15/2016 su 7.0 6-9
�-►. Electrometric Method E 2/24/2016 su 6.6 6-9
Standard Methods 4500 H+ B E 3/20/2016 su 7.4 6-9

E 5/29/2016 su-T- 6.7 6-9
1 5/29/2016 su 7.1 6-9
T 5/29/2016 su 6.8 6-9
ANALYTICAL MONITORING RESULTS
INTERNATIONAL PAPER RIEGELWOOD OPERATIONS
Fall 2016
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B 12/29/2016 m /L 52 120
Standard Methods 5220D E 7/23/2016 m /L 67 120
Onsite Method: Hach 8000 E 9/19/2016 m /L 41 120
E 12/29/2016 m /L 108 120
1 12/29/2016 m /L 128 120
T 12/29/2016 m /L 36 120
Biological Oxygen Demand B 12/29/2016 m /L 4 30
Method: 5-day BOD Test E 7/23/2016 m /L 8 30
Standard Methods: 5210E E 9/19/2016 m /L 8 30
E 12/29/2016 m /L 21 30
1 12/29/2016 m /L 4 30
T 12/29/2016 m /L 5 30
Total Suspended Solids B 1 212 9/2 0 1 6 m /L 176 100
Method: Total Suspended Solids E 7/23/2016 m /L 3 100
Standard Methods: 2540D E 9/19/2016 m /L 6 100
E 12/29/2016 m /L 11 100
1 12/29/2016 m /L 313 100
T 12/29/2016 m /L 818 100
H B 12/29/2016 su 7.7 6-9
Method: pH Value E 7/23/2016 su 6.6 6-9
Electrometric Method E 9/19/2016 su 6.9 6-9
Standard Methods 4500 H+ B E 12/29/2016 su 7.0 6-9
1 12/29/2016 su 8.0 6-9
T 12/29/2016 su 7.8 6-9
ANALYTICAL MONITORING RESULTS
INTERNATIONAL PAPER RIEGELWOOD OPERATIONS
Spring 2017
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B 6/22/2017 m /L 68 120
Standard Methods 5220D E 3/28/2017 m /L 133 120
Method: Hach 8000 E 6/19/2017 m /L 115 120
1 3/28/2017 m /L 105 120
�e T 3/28/2017 m /L 78 120
T 6/19/2017 m /L 131* 120

Biological Oxygen Demand B 6/22/2017 m /L 3 30
Method: 5-day BOD Test E 3/28/2017 m /L 28 30
Standard Methods: 5210E E 6/19/2017 m /L 9 30
1 3/28/2017 m /L 17 30
T 3/28/2017 m /L 16 30
T 6/19/2017 m /L 18 30
Total Suspended Solids B 6/22/2017 m /L 642 100
Method: Total Suspended Solids E 3/28/2017 m /L 10 100
Standard Methods: 2540D E 6/19/2017 m /L 8 100
1 3/28/2017 m /L 96 100
T 3/28/2017 m /L 31 100
T 6/19/2017 m /L 36 100
H B 6/22/2017 su j 7.9 6-9
Method: pH Value E 3/28/2017 su 7.4 6-9
Electrometric Method E 6/19/2017 su 6.9 6-9
Standard Methods 4500 H+ B 1 3/28/2017 su 7.7 6-9
T 3/28/2017 su 7.8 6-9
T 6/19/2017 su 6.7 6-9
*Tier 1 sample-report only(1st smp of semester counts)
ANALYTICAL MONITORING RESULTS
INTERNATIONAL PAPER RIEGELWOOD OPERATIONS
Fall 2017
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B 9/5/2017 m /L 48 120
Standard Methods 5220D B 10/9/2017 m /L 39 120
Method: Hach 8000 B 12/20/2017 m /L 24 120
E 7/29/2017 m /L 94 120
E 8/5/2017 m /L 101 120
E 10/19/2017 m /L 48 120
E 12/20/2017 m /L 50 120
1 12/20/2017 m /L 190 120
T 7/29/2017 m /L 188 120
T* 1 212 0/2 0 1 7 m /L 313* 120
Biological Oxygen Demand B 9/5/2017 m /L 7 30
Method: 5-day BOD Test B 10/9/2017 m /L 4 30
Standard Methods: 5210E B 12/20/2017 m /L 3 30
E 7/29/2017 m /L 19 30
E 8/5/2017 m /L 29 30
E 10/19/2017 m /L 5 30
E 12/20/2017 m /L 5 30
1 12/20/2017 m /L 14 30
T 7/29/2017 m /L 7 30
T* 12/20/2017 m /L 41* 30

/OWN,., Total Suspended Solids B 9/5/2017 m /L 4 100
Method: Total Suspended Solids B 10/9/2017 m /L 590 100
Standard Methods: 2540D B 12/20/2017 m /L 96 100
E 7/29/2017 m /L 10 100
E 8/5/2017 m /L 4 100
E 10/19/2017 m /L 9 100
E 12/20/2017 m /L 4 100
1 12/20/2017 m /L 146 100
T 7/29/2017 m /L 53 100
T 12/20/2017 m /L 299* 100
H B 9/5/2017 su 7.3 6-9
Method: pH Value B 10/9/2017 su 6.6 6-9
Electrometric Method B 12/20/2017 su 7.4 6-9
Standard Methods 4500 H+ B E 7/29/2017 su 6.7 6-9
E 8/5/2017 su 6.2 6-9
E 10/19/2017 su 7.9 6-9
E 12/20/2017 su 7.3 6-9
1 12/20/2017 su 7.6 6-9
T 7/29/2017 su 7.2 6-9
T* 12/20/2017 su 6.5 6-9
*Tier 1 sample-report only(1 st smp of semester counts)
INTERNATIONAL PAPER RIEGELWOOD OPERATIONS
Spring 2018
.� Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B 5/22/2018 mg/L 24 120
Standard Methods 5220D E 5/22/2018 mg/L 102 120
Method: Hach 8000 1 5/22/2018 m /L 31 120
T 5/22/2018 m /L 79 120
Biological Oxygen Demand B 5/22/2018 m /L 3 30
Method: 5-day BOD Test E 5/22/2018 m /L 13 30
Standard Methods: 5210B 1 5/22/2018 m /L 5 30
T 5/22/2018 m /L 16 30
Total Suspended Solids B 5/22/2018 m /L 22 100
Method: Total Suspended Solids E 5/22/2018 m /L 5 100
Standard Methods: 2540D 1 5/22/2018 m /L 39 100
T 5/22/2018 m /L 77 100
H B 5/22/2018 su 7.1 6-9
Method: pH Value E 5/22/2018 su 6.9 6-9
Electrometric Method 1 5/22/2018 su 6.8 6-9

Standard Methods 4500 H+ B T 5/2212 0 1 8 su r 6.9 6-9
INTERNATIONAL PAPER RIEGELWOOD OPERATIONS
Fall 2018
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B 12/14/2018 mg/L <20 120
Standard Methods 5220D E 12/14/2018 mg/L 46 120
Method: Hach 8000 1 12/14/2018 m /L 76 120
1 12/20/2018 m /L 95 120
1 12/28/2018 m /L 46A 120
T 12/14/2018 m /L 180 120
T 12/20/2018 mg/L 164* 120
Biological Oxygen Demand B 12/14/2018 m /L 3 30
Method: 5-day BOD Test E 12/14/2018 m /L 9 30
Standard Methods: 5210B 1 12/14/2018 m /L 5 30
1 12/20/2018 m /L 6 30
1 12/28/2018 m /L 3" 30
T 12/14/2018 m /L 26 30
T 12/20/2018 mg/L 18 30
Total Suspended Solids B 12/14/2018 m /L 6 100
Method: Total Suspended Solids E 12/14/2018 m /L 10 100
Standard Methods: 2540D 1 12/14/2018 m /L 138 100
1 12/20/2018 m /L 214* 100
1 12/28/2018 m /L 88A 100
T 12/14/2018 m /L 225 100
T 12/20/2018 mg/L 170* 100
H B 12/14/2018 su 7.6 6-9
Method: pH Value E 12/14/2018 su 7.5 6-9
Electrometric Method 1 12/14/2018 su 7.9 6-9
Standard Methods 4500 H+ B 1 12/20/2018 su 7.4 6-9
1 12/28/2018 su 7.8A 6-9
T 12/14/2018 su 7.8 6-9
T 12/20/2018 su 7.7 6-9
*Above benchmark, **2nd Tier 1 smp of semester, rpt only, ^non-rep smp-rpt only
INTERNATIONAL PAPER RIEGELWOOD OPERATIONS
Spr 2019
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B mg/L 120
Standard Methods 5220D E mg/L 120
Method: Hach 8000 1 m /L 120
T 3/1/2019 m /L 290 120
T 5/12/2019 mg/L 120
Biological Oxygen Demand B m /L 30
Method: 5-day BOD Test E m /L 30
Standard Methods: 5210B I m /L 30
F T 3/1/2019 m /L 18 30
T 5/12/2019 mg/L 30

Total Suspended Solids B m /L 100
Method: Total Suspended Solids E m /L 100
Standard Methods: 2540D I m /L 100
T 3/1/2019 m /L 312 100
T 5/12/2019 mg/L 23 100
H B su 6-9
Method: pH Value E su 6-9
Electrometric Method I su 6-9
Standard Methods 4500 H+ B T 3/1/2019 su 7.6 6-9
T 5/12/2019 su 6.7 6-9
INTERNATIONAL PAPER RIEGELWOOD OPERATIONS
Fall 2019
Discharge Characteristic Stormwater Sample date Units Result Benchmark
Basin Value
Chemical Oxygen Demand B m /L 120
Standard Methods 5220D E m /L 120
Method: Hach 8000 1 m /L 120
T mg/L 120
Biological Oxygen Demand B m /L 30
Method: 5-day BOD Test E m /L 30
Standard Methods: 5210B I m /L 30
T mg/L 30
/ORIN Total Suspended Solids B m /L 100
Method: Total Suspended Solids E m /L 100
Standard Methods: 2540D I m /L 100
T mg/L 100
H B su 6-9
Method: pH Value E su 6-9
Electrometric Method I su 6-9
Standard Methods 4500 H+ B T su 6-9

QUALITATIVE STORMWATER RESULTS: Spring 2015- Fall 2019
VISUAL INSPECTION, Scale 1 -5 (1=113est), OR Y/N
COLOR
BASIN, It,med, FLOATING SUSPENDED EROSION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OIL SHEEN DEPOSITION
A
S15 It gray 3 1 2 n n n y
F15 It yellow 2 1 2 n n n n
S16 It tan 2 1 3 n n n n
F16 It yel 21 1 2 n n n slight
S17 It gray 3 2 3 n n n y
F17 It gray 2 1 3 n n n y
S18 It gray 2 1 2 n n n n
F18 med br 3 1 2 n n n y
S19
F19
B
S15 It gray 2 1 1 n n n n
F15 no smp;constr n/a n/a n/a n/a n/a n/a n/a
S16 off-white 2 1 2 n n n n
F16 It gray 3 1 3 n n n none visible
S17 It gray 3 1 3 n n n searching
F17 9/5/17 It tan 3 1 2 n n n y into pond
F1712/8/17 It tan 2 1 3 n n n y-at fenceline
F17 12/20/17 It gray 2 1 1 n n n n
.,. 518 a/25/19 sl. cloudy wh 1 1 2 n n n n
S185/22/19 sl.white 1 2 1 n n n n
F18 very It gray 11 1 2 n n n n
S19
FF19��
S15 It.yel 1 1 1 n n n n
F15 clear 1 1 1 n n n n
516 It yellow 1 1 1 n n n n
F16 very It yel 1 1 1 n n n sl above inlet prot.
517 pale yellow 1 I 1 n n n n
F17 very It yel 1 1 1 n n n n
S18 clear 1 1 1 n n n n
F18 clear 1 1 1 n n n n
S19
F19
S15 pale yel 2 2 1 nj n n It.chip debris
F1S clear 1 1 1 nj n n n
516 clear 1 2 1 n n n n
F16 clear 1 1 1 n n n n
S17 It yel 1 1 2 n n n n
F17 very It yel 1 1 1 n n n n
S18 clear 1 1 2 n n n n
F18 almost clear 1 1 1 n n n n
S19
F19

QUALITATIVE STORMWATER RESULTS: Spring 2015- Fall 2019
VISUAL INSPECTION: Scale 1-5 (1=Best), OR Y/N
COLOR
BASIN, It,med, FLOATING SUSPENDED EROSION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OIL SHEEN DEPOSITION
E
S15 yellow 1 1 1 n n n n
F15 It tan 1 1 1 n n n n
S16 very It tan 1 1 1 n n n n
F167/23/17 sl.yellow 1 1 1 n n n n
F16 9/19/17 It yellow 1 1 2 sl musky n n n
F16 12/29/17 It yellow 1 1 2 sl moldyl n n n
517 3/28/17 med yellow 1 1 2 n n n n
S17 6119/17 It brown 1 1 2 n n n n
F17 7/29/17 tan 2 1 2 n n n n
F17 8/5/17 It tan 1 1 2 sl musty odor n n n
F17 12/8/17 It tan 2 1 2 n n n n
F17 12/20/27 It amber 1 1 1 n n n n
518 It yel 1 1 1 n n n n
F18 It yel 1 1 1 n n n n
S19
F19
L
S15 med br 2 2 3 n n n wood debris
S15 It yel 1 1 1 n n n n
F15 almost clear 2 1 2 n n n n
S16(E) It yellow 1 1 1 n n n n
S16 (W) med br 2 1 2 n n n n
F16 (E) med br 2 2 2 n n n n
F16(W) It yellow 1 1 1 n n I n n
S17 (E) It yellow 1 1 1 n n n n
S17(W) It yellow 1 2 1 n n n n
F17(E+W) very It yel 1 1 1 n n n n
S18(E+W) clear 1 1 1 n n n n
F18(E+W) very It br 3 1 3 sl oily odorl n n y
S19
F19
F1
S15 It yel 1 1 1 n n n n
FiS no flow n/a n/a n/a n/a n/a n/a n/a
S16 pale yellow 1 1 1 n n n n
F16 It yellow 1 1 1 n n n n
S17 It yel 1 1 2 n n n n
F17 no flow n/a n/a n/a n/a n/a n/a n/a
S18 sl.whitish 2 1 2 n n n n
F18 almost clear 1 1 1 n n n n
S19
F19
S15 It yel 1 1 1 n n n n
F15 It yel 2 1 1 n n n n
S16 pale yellow 1 1 11 n I n n n

QUALITATIVE STORMWATER RESULTS: Spring 2015 - Fall 2019
VISUAL INSPECTION: Scale 1-5 (1=Best), OR Y/N
COLOR
BASIN, It,med, FLOATING SUSPENDED EROSION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OIL SHEEN DEPOSITION
F16 clear 1 1 1 n n n n
S17 very It yel 1 1 1 n n n n
F17 clear 1 1 1 n n n n
S18 very It yel 1 1 1 n n n n
F18 clear 1 1 1 n n n n
S19
F19
G1
S15 very pale yel 1 1 1 n n n n
F15 It yellow 1 1 1 n n n n
516 very pale yel 1 1 1 n n n n
F16 clear 1 1 1 n n n n
S17 very It yel 2 1 1 n n n n
F17 clear 1 1 1 n n n n
S18 Si.white/cloudy 2 1 1 n n n n
F18 clear 1 1 1 n n n n
S19
F19
G2
515 very pale yel 1 1 1 n n n n
F1S clear It yel 2 1 2 n n n n
S16 off-white 2 1 2 n n n n
F16 almost clear 1 1 1 n n n n
S17 very It yel 1 2 1 n n n n
F17 clear 1 1 1 n n n n
S18 It yellow 1 2 1 n n n n
F18 no flow n/a n/a n/a n/a n/a n/a n/a
519
F19
G3
515 It yel 2 1 1 n n n n
F15 It yel 1 1 1 n n n n
S16 very It yel 1 1 1 n n n n
F16 very It tan 1 1 1 n n n n
S17 ver It yel 1 1 2 n n n n
F17 clear 1 1 1 n n n n
S18 It tan 1 1 2 n n n n
F18 clear 1 1 1 n n n n
S19
F 199
I�
S15 nearly clear 1 1 1 n n n n
F15 clear It yel 2 1 1 n n n n
S16 pale yellow 1 1 1 n n n n
F16 clear 1 1 1 n n n n
517 nearly clear 1 1 1 n n n n
F17 It amber 1 1 1 n n n n

QUALITATIVE STORMWATER RESULTS: Spring 2015 - Fall 2019
VISUAL INSPECTION: Scale 1 -5 (1=13est),OR Y/N
COLOR
BASIN, [t,med, FLOATING SUSPENDED EROSION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OILSHEEN DEPOSITION
S18 clear 1 1 1 n n n n
F18 clear 1 1 1 n n n n
S19
F19
0
S15 It yel 1 1 1 n n n n
F15 It yel 2 1 2 n n n n
S16 very pale yel 1 1 1 n n n n
F16 dk gray 3 1 3 n n n y(source not visible)
517 yellow 2 2 2 n n n n
F17 12/8/17 It gray 2 1 2 n n n n
Fv 12/20/17 gray 3 1 1 n n n none visible
S18 It tan 2 1 1 n n n n
F18 12/14/18 It gray 41 1 4 n n n n
F18 12/20/18 It brown 3 1 3 n n n y(no visible source)
F1812/28/18 almost clear 2 1 2 n n n n
S19
F19
S15 clear 1 1 1 n n n n
F15 It yellow 1 1 1 n n n n
S16 pale yellow 1 1 1 n n n n
F16 clear 1 1 1 n n n n
S17 It yel 1 1 2 n n n nyellow
F17 nearly clear 1 1 1 n n n n
S18 clear 1 1 1 n n n n
F18 It tan 1 1 1 n n n n
519
F19
515 clear 1 1 1 n n n n
F15 very pale yel 1 1 1 n n n n
S16 pale beige 2 1 1 n n n n
F16 clear 1 1 1 n n n n
S17 clear 1 1 1 n n n n
F17 clear 1 1 1 n n n n
S18 clear 1 1 1 n n n n
F18 very It tan 2 1 2 n n n n
S19
F19
I
515 It gray 2 1 2 n n n slight
F15 It gray 2 1 2 n n n n
516 very It tan 2 1 1 n n n n
F16 sl off-white 2 1 2 n n n n
S17 3/28/17 med gray 4 1 4 n n n y
S17 6/19/17 verypaleyell 1 2 1 n n n n

QUALITATIVE STORMWATER RESULTS: Spring 2015 - Fall 2019
VISUAL INSPECTION: Scale 1-5 (1=13est),OR Y/N
COLOR
BASIN, It,med, FLOATING SUSPENDED EROSION/
SEMESTER dk(Imcl) CLARITY SOLIDS SOLIDS ODOR FOAM OIL SHEEN DEPOSITION
F17 It gray 2 1 2 n n n n
S18 sl off-white 2 1 2 n n n n
F18 12/9/18 It tan 3 1 3 n n n y
F1812114/18 tan 3 1 3 n n n y
S19
�F19
'Yu '
S15 very pale yel 2 1 2 n n n n
F15 It gray 3 1 2 n n n some sed
S16 very pale yel 1 1 1 n n n n
F16 very pale yel 2 1 1 n n n n
S17 3/28/1 It gray 3 2 3 n n n n
S17 6/19/1 It brown 2 2 2 n n n n
F17 It tan 2 1 2 n n n n
S18 sl off-white 1 1 1 n n n n
F18 clear 1 1 1 n n n n
S19
F19
N
515 clear pale yel 1 1 1 n n n n
F15 clear 1 1 1 n n n n
S16 pale yellow 1 1 2 n n n n
F16 clear 1 1 1 n n n n
517 sl.white 1 2 1 n n n n
F17 clear 2 1 1 n n n n
S18 nearly clear 1 1 1 n n n n
F18 It.yellow 1 1 1 n n n n
S19
F199
0
S15 clear 1 1 1 n n n n
F1S clear 1 1 1 n n n n
S16 very It yel 2 1 1 n n n n
F16 nearly clear 1 1 1 n n n n
S17 very It tan 2 1 2 n n n n
F17 clear 2 1 1 n n n n
S18 nearly clear 1 1 1 n n n n
F18 clear 1 1 1 n n n n
S19
F19
S15 nearly clear 1 1 ] n n n n
F15 clear pale yel 1 1 1 n n n n
S16 clear 1 1 1 n n n n
F16 sl white color 2 1 1 n n n n
S17 nearly clear 2 1 1 n n n n
F17 clear 1 1 1 n n n n

QUALITATIVE STORMWATER RESULTS: Spring 2015 - Fall 2019
VISUAL INSPECTION: Scale 1-5 (1=13est), OR Y/N
COLOR
^^ BASIN, It,med, FLOATING SUSPENDED EROSION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OIL SHEEN DEPOSITION
S18 clear 1 1 1 n n n n
F18 clear 1 1 1 n n n n
S19
F19
S15 very It tan 2 2 1 n n n n
F15 clear pale yel 1 1 1 n n n n
S16 pale yellow. 1 1 1 n n n n
F16 nearly clear 1 1 1 n n n n
S17 very It yel 1 1 1 n n n n
F17 nearly clear 1 1 1 n n n n
S18 pale yellow 1 1 2 n n n n
F18 clear 1 1 1 n n n n
S19
F19
515 med gray 3 2 3 n n n y
F15 It yellow 2 2 2 n n n n
S16 It tan 2 2 3 n n n y
F16 It gray 3 1 3 n n n y
S17 4/6/17 It tan 2 1 2 n n n n
S17 6/19/17 very pale yel 1 1 2 n n n n
F17 med gray 3 1 3 n n n y
S184/25/18 It gray 3 1 3 n n n y(sed)
S185/19/18 It gray 3 1 2 n n n y(sed)
F18 12/9/18 med gray 4 1 4 n n n y(sed)
Fla 1z/14/1a gray 5 1 5 n n n n
S19
F19
S15 very!t yel 1 1 1 n n n n
F15 clear pale yel 2 1 1 n n n n
S16 tan 3 1 3 n n n y
F16 off-white 2 2 2 n n n y slight
S17 It tan 2 1 2 n n n n
F17 no flow n/a n/a n/a n/a n/a n/a n/a
S18 sl off-white 2 1 2 nj n n n
F18 almost clear 1 1 1 n n n n
S19
FF19
T
S15# med br 3 2 3 nj nj nj wood debris
F15 beige/It gray 2 2 2 n n n some sed
S16 nearly clear 1 1 2 n n n n
F16 clear 2 2 2 n n n n
sv 3/28/17 It tan 2 1 2 n n n n
517 6/19/17 It brown 1 1 21 n n n n

QUALITATIVE STORMWATER RESULTS: Spring 2015 - Fall 2019
VISUAL INSPECTION: Scale 1 -5 (1=Best), OR Y/N
COLOR
BASIN, It,med, FLOATING SUSPENDED EROSION/
SEMESTER dk(lmd) CLARITY SOLIDS SOLIDS ODOR FOAM OIL SHEEN DEPOSITION
F177/29/17 nearly clear 1 1 2 n n n n
F17 12/8/17 It tan 3 2 3 n n n n
F1712/20/17 med brown 3 2 3 sl sheen n n n
S18 It tan 1 2 1 n n n n
F1812/14/18 gray 4 1 4 n n n n
F1812/20/18 tan 31 1 3 n n n n
S19 3/1/19 med br 3 2 3 n n n tiny wood pcs
S19 s/12/19 very It br 2 2 2 n n n sm wood debris
F19
4 outfall developed to support new mill activities
I�

,�.., Stormwater Best Management Practices Summary 2019
NPDES Stormwater Permit NCS000101
International Paper Mill
Riegelwood, NC
At the International Paper Mill, approximately 90% of runoff from the main
mill facility drains to the mill wastewater treatment system (WWTS), and
is treated under the mill's NPDES wastewater permit. Runoff from the
remaining 10% of the mill and from a few outlying areas is covered in the
mill Storm Water Pollution Prevention Plan (SWPPP). The SWPPP
identifies 18 stormwater basins, where numerous Best Management
Practices (BMPs) are used to control or prevent erosion and sediment
runoff.
Non-structural BMPs include numerous mill manuals, plans, and
policies. Spill prevention and response are addressed by the:
Stormwater Pollution Prevention Plan; the Spill Prevention, Control, and
Countermeasures Plan; the Hazardous Waste Handling Program; two
Facility Response Plans; the Chemical Hygiene Plan; Best Management
Practices Plan for Spent Pulping Liquor, Soap, and Turpentine
Management; and the Environmental Manual. All stormwater basins
include signs marking the boundaries of stormwater runoff and the
locations of outfalls. Activities such as chemical storage, painting, and
vehicle maintenance are forbidden in stormwater basins, and this
information is also posted. Basic good housekeeping is enforced, and
numerous mill employees participate in monthly basin inspections.
Annual training is required for all employees working in stormwater
basins. Street and storm drain maintenance is a focus in stormwater
basins. Grasses and other vegetation are maintained wherever feasible.
Mill policies limit the use of pesticides and herbicides to the absolute
minimum needed for personnel safety and establishment and
maintenance of ground cover. No waste operations are allowed in
stormwater basins. Dust control is limited to a water truck.
Structural BMPs and other control measures are used to reduce erosion
and sedimentation while promoting groundwater recharge. Grassy
swales and meandering natural streams carry flow, and geotextile cloth
with gravel or riprap covers bare areas. Jersey dividers protect unpaved
road edges. Earthen collection ponds and basins allow groundwater
infiltration. Rock filters surround several outfalls, and a small French
drain system directs runoff to one outfall. Riprapped swales,•a retaining
berm, rock checkdams, and drainage channels direct flow. A skimmer
and filtering manifold are in use in one basin, and sediment socks and
bags are also used. Hardened spillways are also in place, as well as
riprap swales.

In areas of high traffic and high runoff flow, hardened structural BMPs
direct flow, prevent erosion and pollutants from entering runoff, and
provide flood control. Recent roadway repairs in stormwater basins focus
on reducing erosion from roadways. Concrete and paved surfaces and
roads, as well as plastic ditch liners, harden surfaces. Concrete
containments, sumps, curbing, and two oil/water separators (OWS)
protect against runoff contamination. Runoff is conveyed via pipes and
concrete structures such as catch basins, culverts, U-drains, swales, and
outfall structures. A concrete flow diverter and a concrete flow diffuser
further control flow.
Planned BMPs: Investigations are underway to improve runoff quality in
a Basins R and T, where good runoff quality is difficult to achieve. No
decisions have been reached, but concentrated efforts will continue to
improve and maintain high quality runoff.

International Paper, Riegelwood Mill
Stormwater NPDES#NCS 000101
Renewal Application 2019
Changes in Industrial Activities 2015-2019
The Riegelwood Mill has experienced several changes to the industrial process during the term of the
current permit. Some do, and some do not, affect stormwater operations, as noted below.
• The mill woodyard was modernized and expanded to increase the mill's ability to produce its
own chips, resulting in the creation of Outfall T at the new mill wood truck entrance and
scalehouse. Other than the new truck entrance,there is no change in stormwater operations;
other affected areas drain to the mill wastewater treatment system.
• Project Zebra was another mill modernization that changed the process from a pulp/paper mill
to a strictly pulp mill. This large project eliminated dozens of process chemicals from the site,
all in non-stormwater areas. One result of Project Zebra was an increase in containerized pulp
and a corresponding increase in truck traffic, moving the containers of pulp into and out of
Basin R. Another direct result is a switch to strictly pine wood, with no hardwood mix. That
�► creates a change in the type of wood chips stored and handled in Basins C, D, E, F, and G. More
pine= more turpentine production as a byproduct. No. 1 power boiler was also taken offline as
part of Project Zebra. The entire Zebra project has no impact on stormwater.
• During this period,the mill began burning more natural gas and less fuel oil in its power boilers
and the#4 lime kiln. A corresponding change is the cessation of oil barging at Basin A; the mill
maintains the physical infrastructure to receive barges, but has not barged oil in over 2 years.
• The mill produces potable water, and recently converted the disinfection process from the use
of chlorine to sodium hypochlorite. This has resulted in a large decrease in chlorine onsite, and
will eventually result in the complete removal of chlorine from the site. This switch has no
effect on stormwater.
• In Basin Q,the backwash pond from the water plant filters has been permanently piped to the
intake pumps at the pumphouse, and electrical backup has been provided. This minimizes the
chance of releases of backwash into the stormwater basin.
• The unused underground black liquor line has been removed from Basin H, and the adjacent
black liquor ponds have been emptied and cleaned out, and are no longer in use. Since black
liquor was the potential pollutant at Outfalls H and F3,they have been removed from the
SWPPP.

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources—5tormwater Program
Facility Name: Inlernational Paper Riegelwood Mill
Permit Number: NCS000101
Location Address: 865 John L.Rieget Rd,
Riegelwood,NC 28456
County:
Columbus
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all
attachments were developed and implemented under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gather and evaluate the information required by the SPPP.
Based on my inquiry of the person or persons who manage the system, or those persons directly responsible
for gathering the information, the information gathered is, to the best of my knowledge and belief, true,
accurate and complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP
has been fully implemented at this facility location in accordance with the terms and conditions of the
stormwater discharge permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and
imprisonment for knowing violations."
Sign (according to permit signatory requirements)and return this Certification. DO NOT
SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature J� Date
Floyd Whitmire Facility Manager
Print or type name of person signing above Title
SPPP Certification 10/13

INTERNATIONAL PAPER
RIEGELWOOD M1L1.
JOHN L.RIEGEL ROAD
RIEGELWOOD,NC 28456
February 11,2019
Water Quality Permitting Section
Division of Water Resources
1617 Mail Service Center
Raleigh,NC 27699-1617
Certified Mail: 7017 2620 0000 24115248
Stormwater Permitting Section
Division of Energy, Minerals,and Land Resources
1612 Mail Service Center
Raleigh,NC 27699-1612
Certified Mail: 7017 2620 0000 24115255
Subject: Delegation of Signature Authority
International Paper—Riegelwood Mill
NPDES Permit No. NC0003298 (wastewater) and NCS000101 (stormwater)
To Whom It May Concern:
By notice of this letter, I hereby delegate signatory authority to each of the following
individuals for all permit applications, discharge monitoring reports,and other information
relating to the operations at IP Riegelwood Mill as required by all applicable federal,state, and
local environmental agencies specifically with the requirements for signatory authority as
specified in 15A NCAC 2B.0506 for permit NC 0003298 and Part III.B.3.b of Permit
NCS000101.
Timothy Gill EHS&S Manager
Kimberly Fail Environmental Manager
If you have any questions regarding this letter, please feel free to contact me at 910-362-4880.
Sincerely f
loydrWhitmire
Mill Manager—Riegelwood Mill
Attachment
�.., cc: Brian Lambe,NC DEQ Wilmington Regional Office (via e-mail)
Tom Tharrington,NC DEQ Wilmington Regional Office(via e-mail)
S:IGroupslEnvironmentaPWastewater'.NPDES PermirSignaton-Authority Delegation0elegation ofAuthorin'DWQ SUT
NPDES 021119.doex

UNTERNATI L WER
�/ 6400 Poplar Ave.
Memphis,TN 38197
Clay)Ellis Business(901)419-9000
VICE PRESIDENT OF MANUFACTURING Fax[phone]
NORTH AMERICAN PAPERS&PULP clay.ell Vs )ipaper.com
March 15,2016
Subject: Signatory Authority Delegation-International Paper Riegelwood Mill
To: All Concerned
1,Clay Ellis, Vice President of Manufacturing for International Paper's North American Papers&Pulp Business,
am responsible for principle business functions,policies,and decisions for all North American Papers&Pulp
sites,and do hereby authorize the following:
• The Mill Manager at the Riegelwood Mill is authorized to certify and submit in the name of and on behalf
of International Paper all environmental permit applications,reports,documentation,plans or other
information relative to the Riegelwood Mill as required by federal,state,or local permit issuing
authorities as allowed under appropriate regulations.
• The Environmental Health& Safety Manager at the Riegelwood Mill is authorized to certify and submit
in the name of and on behalf of international Paper all environmental permit applications,reports,
documentation,plans or other information relative to the Riegelwood Mill as required by federal,state,or
local permit issuing authorities as allowed under appropriate regulations.
Please refer any questions or correspondence regarding environmental matters to the local contact.
Sincerer
Clay is
VI I-- PRESIDENT OF MANUFACTURING
�'�--ZTH AMERICAN PAPERS& PULP
INTERNATIONAL, PAPER