NCS000295_Fact sheet binder_20231101

DEQ / DEMLR
FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL
STORMWATER PERMIT DEVELOPMENT
Basic Information for Permit Issuance and Renewals:
Permit Writer/Date Brianna Young 10/23/2023
Permit Number NCS000295
Owner/Facility Name Jackson Paper Manufacturing Company/Jackson
Paper Manufacturing Company—S lva Plant
SIC AICS Code/Category 2631 /Paperboard mill—Cardboard recycling
Basin Name/Sub-basin number Little Tennessee/04-04-02
Receiving Stream/HUC Scott River/0601020303
Stream Classification/Stream Segment C; Tr/2-79-39
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? No
New expiration date 11/30/2028
Comments on Draft Permit? See Section 6 below
Section 1. Facility Activities and Process:
The Jackson Paper Manufacturing Company operates a facility that produces roll stock medium grade
paper from 100%recycled corrugated containers and operates a closed-loop WWTP. Chemicals stored
on site include fuel, WWT chemicals, and material used in paper production.
Per information provided by Jackson Paper via email July 2023, tractor trailer storage and an employee
parking area were added on the northern end of the property. The trailers are owned by a third-party
contractor and are not stored coupled to the tractor. The trailers are typically empty but may contain
finished paper rolls or bales of cardboard; no liquid material will be stored in the trailers. There will be
no material loading or unloading; truck cleaning, fueling or maintenance conducted in this area.
Stormwater from the gravel lot discharges through a new drainage ditch which goes underneath the
existing railroad tracks and discharges into Scotts Creek. Because there are no industrial activities
occurring that have the potential to impact stormwater, this area and the discharge point would not be
considered a stormwater discharge outfall.
In correspondence dated 7/24/2023, an NCDOT road project may impact the outfalls. Project details are
not yet known by the permittee (they have contacted NCDOR for more information). The potential
impacts include:
• Outfall 001 is located at a catch basin in the middle of the facility's front parking area.
Stormwater discharges from both Jackson Paper and the public road flow to a common pipe on
the property that gravity flows under West Main Street. Portions of West Main Street slope
toward the facility so that stormwater from this section of the roadway discharges toward Outfall
001.
o Potential Impact: Unforeseen stormwater comingling from roadway during and after
construction.
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• Outfall 002 is located adjacent to West Main Street at the edge of the Shipping and Finishing
Warehouse. The outfall also collects incidental groundwater from under the facility due to the
pipe structure being level to or below the water table.
o Potential Impact: Sampling location may need to be moved as this location will likely be
taken under eminent domain. Unforeseen stormwater comingling from roadway during
and after construction
• Outfall 003 is located to the west of the Shipping and Finishing Warehouse. The outfall collects
runoff from the areas around the boiler and sawdust/fuel receiving and storage, boiler ash pit and
boiler ash ponds, the recycle pulp facility,paper bale receiving dock and storage, several
masonry storage buildings for spare equipment and the railroad tracks that service the facility.
o Potential Impact: Sampling location may need to be moved if location is taken under
eminent domain. Unforeseen stormwater comingling from roadway during and after
construction.
Outfall SW001:
Drainage area consists of a dumpster, loading docks, parking areas, roof drains from the office building,
and portions of an adjacent roadway. Potential pollutants include oils/greases and TSS.
Outfall SWO02:
Drainage area consists of roof drains from the shipping and finishing warehouse, roof drains from the
paper machine building, railroad shipping dock, railroad tracks, wastewater treatment aeration basins
and clarifiers, kerosene storage tank, scrap metal storage, dryer can bearing storage, and incidental
groundwater. Potential pollutants include TSS, kerosene, BOD, COD, and metals.
Outfall SWO03:
Drainage area consists of the boiler building, recycle pulp facility,paper bale receiving platform,
railroad tracks, recycle bale storage building, obsolete materials storage building, plastic baling area,
delivery area, three (3) cardboard storage areas, gasoline and diesel fuel ASTs, truck dump hydraulic oil
storage tank,plastic baler hydraulic tank oil tank, sawdust piles, ash pad, boiler ash pit and boiler ash
ponds, scrap materials boneyards, masonry storage buildings, tractor trailer storage, and a parking lot.
Potential pollutants include TSS, hydraulic oil, BOD, COD, O&G, gasoline, and metals.
Additional Outfalls:
Outfall SWO04:
Drainage area consists of a parking area. Stormwater discharges to a catch basin. Potential pollutants
include oils/greases and TSS.
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
waste waters (as defined at part 401 of this chapter); sites used for the storage and maintenance of
Page 2 of 9

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:
• April 2017 to May 2023, benchmarks exceeded for:
o 001: TSS 8x, COD 7x
o 002: TSS Ix
o 003: TSS 11x, COD 15x
o 004: TSS 5x
o Upstream of mill: TSS 5x
o Downstream of mill: TSS 6x,pH min not reached Ix
• February 2020 DEMLR inspection report showed the facility was not in compliance
o An excessive amount of debris and waste from the industrial process was observed to be
accumulating around the exterior of the facility. The main source of this debris was an
area where waste material is loaded on to waiting truck and shipped.
• August 2020 DEMLR inspection report showed the facility was compliant as the issues
described in the previous inspection report were resolved
303(d) listing:
att Creek -7 39 C;Tr is. F Miles
875 From source to Tuckasegee River
PARAMETER IR CATEGORY CRITERIA STATtREASON FOR RATING 303Q YEAR
Fecal Coliform (GM 200/40D 5 in 30,REC,FW) F5_jjEKceeding Criteria Pathogen Indicator Standards 200
�Exceedance
Threatened/Endangered Species:
There are no threatened or endangered species at the discharge location, however there are species of
concern including: Ski-tipped Emerald(Somatochlora elongate; NC status: SR), Zebra Clubtail
(Stylurus scudderi;NC status: SR), Eastern Hellbender(Cryptobranchus alleganiensis alleganiensis;
NC status: SC), and Little Tennessee Crayfish(Cambarus georgiae;NC status: SC).
Section 3. Proposed Monitoring for Stormwater Discharges:
The Division considered potential pollutants from past and present industrial activities and data was
submitted for April 2017 to May 2023. Quantitative sampling included pH, TSS, O&G, turbidity, and
COD.
Page 3 of 9

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 Jackson Paper Manufacturing site.
Outfalls SWO01 and SWO04
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
Outfalls SWO02 and SWO03
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness
(TSS) indicator. Instream monitoring required per previous permit requirement.
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 4 of 9

Quarterly monitoring
Turbidity BASIS: Discharge potential indicator. Instream monitoring required per
previous permit requirement.
Quarterly monitoring
Total Copper BASIS: Discharge potential indicator as metals are present in the drainage
area
Quarterly monitoring
Total Lead BASIS: Discharge potential indicator as metals are present in the drainage
area
Quarterly monitoring
Total Zinc BASIS: Discharge potential indicator as metals are present in the drainage
area
Quarterly monitoring
Total Hardness BASIS: Monitoring for hardness dependent metals present
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
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
Page 5 of 9

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 50 mg/L Based on '/2 standard benchmark of 100 mg/L
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
Copper Total 10 /L Acute Aquatic Criterion, %a FAV
Lead Total 75 /L Acute Aquatic Criterion, '/2 FAV
Zinc Total 126 /L Acute Aquatic Criterion, %2 FAV
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.
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.
Page 6 of 9

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
• Feasibility study requirement removed per updated stormwater program requirements
• eDMR requirement added
• Boilerplate language moved into body of the permit; boilerplate no longer attached
• Outfall-specific monitoring been implemented to reflect industrial activity and potential
pollutants specific to each discharge area
• Outfall SWO04 monitoring added based on information provided in renewal application
• Monitoring for COD, turbidity, and instream TSS removed from SW001 due to lack of related
industrial activity
• Monitoring for BOD added for SWO02 and SWO03 based on information provided with the
permit renewal application
o Removed in 2017 permit renewal for an unknown reason
• Monitoring for copper, lead, and zinc added for SWO02 and SWO03 as metals are present in the
drainage areas
• Monitoring for total hardness added for SWO02 and SWO03 as monitoring for hardness
dependent metals is required
• Benchmarks updated for parameters per guidance from DWR Standards group on stormwater
benchmarks
Section 5. Changes from draft to final:
• SWO04 removed from monitoring requirements per comments received on draft permit
Page 7 of 9

Section 6. Discussions with the Facility and Regional Office:
• Initial contact with facility: 6/2/2023
• Initial contact with Regional Office: 6/2/2023
• Draft sent to CO peer review: 7/12/2023
• Draft sent to Regional Office: 9/13/2023
• Final permit sent for supervisor signature: 10/25/2023
Section 7. Comments received on draft permit:
• Kiesha Bridges (Jackson Paper Manufacturing Company; via email 10/12/23):
o Part D-1: Jackson Paper requests that the tracking only apply to the specific drainage
areas in which Oil and Grease activities are conducted regarding this tracking
requirement. Further Tables 1 and 2 indicate Oil & Grease testing is only required in
drainage areas that use> 55 gallons/month of oil on average.
■ DEMLR response: Oil and grease is a standard pollutant parameter monitored in
stormwater permits. If Jackson Paper does not meet the permit qualifications for
reporting oil and grease, then this parameter is not required to be monitored for.
o Table 1: Jackson Paper does not believe that the activities within the drainage basin for
Outfall SWO04 meet the definition of stormwater discharges associated with industrial
activity. The area in this basin is limited to an employee parking lot. Currently, no
industrial activities take place in Outfall SW004. Jackson Paper does not believe that
quarterly monitoring of Outfall SWO04 is warranted and proposes to discontinue
sampling of this outfall. The facility requests that the permit condition be modified to
note that quarterly sampling is only required if industrial activities occur.
■ DEMLR response: Monitoring for SWO04 was included as the application
identified potential pollutants in the discharge. As the drainage area only consists
of a parking lot, monitoring for outfall SWO04 will be removed from the permit.
o Table 1. Non-Polar Oil & Grease: The facility has historically been required to test for
non-polar oil and grease (O&G) for Outfalls SW001 and SW004. Activities in drainage
area SW001 includes a dumpster, loading docks, employee parking areas, and roof drains
from the office building. Activities in drainage area SWO04 includes only employee
parking. Jackson Paper neither uses nor stores motor or hydraulic oil in either of these
drainage areas. There is no vehicle washing or maintenance conducted in these drainage
areas. Furthermore, available analytical data from April 2017 through August 2023 has
shown all results to be non-detect for O&G from these outfalls. The fact sheet provided
by NC DEQ indicates that the basis for O&G monitoring is the potential pollutant from
lubricants. There are no industrial activities in either of these drainage areas that involve
lubricants. Therefore, Jackson Paper respectfully requests that the oil tracking and O&G
analytical sampling requirement be removed from Table 1 for Outfalls SW001 and
SW004.
■ DEMLR response: Oil and grease is a standard pollutant parameter monitored in
stormwater permits. If Jackson Paper does not meet the permit qualifications for
reporting oil and grease, then this parameter is not required to be monitored for.
o Table 2. Total Copper; Total Lead; Total Zinc; and Total Hardness: The facility has not
altered industrial activities on site as part of the renewal application. Jackson Paper has
not historically been required to test for metals based on the industrial activities
conducted on site. Metal and hardness testing has been added to SWO02 and SWO03
Page 8 of 9

based on the note from NC DEQ that discharge potential indicator as metals are present
in the drainage area. Jackson Paper does not expect significant levels of metals in these
drainage areas. The facility requests that the sampling condition be updated to reflect a
scaled approach to sampling frequency based on analytical results. If testing of metals
indicates consistent results below benchmarks, the facility requests an option to reduce
testing within the permit term. This will prevent an undue financial burden if early results
indicate there are no metals in the stormwater discharge.
■ DEMLR response: The presence of scrap metal stored in the drainage areas is a
concern to the Stormwater Permitting Program. As long as scrap metal is stored in
these areas, exposure to stormwater is possible, therefore monitoring for metal
sand total hardness shall remain in the permit.
o Table 2. BOD: NC DEQ added a BOD analytical testing requirement to Outfall SW002
and SW003 based on information provided with the permit renewal application. As
mentioned previously, there have been no major changes to outdoor industrial activities
based on this renewal. NC DEQ noted in the fact sheet that this monitoring requirement
was removed in 2017 permit renewal for an unknown reason. Jackson Paper previously
had a requirement to test for BOD from these two outfalls. An NPDES Stormwater
Permit Compliance Inspection was conducted on March 20, 2012 by Linda Wiggs and
Susan Wilson of the NC DEQ. In the follow up inspection letter dated April 13, 2012,
NC DEQ recommended that monitoring be reduced or eliminated from both outfalls due
to historical analytical data below the benchmarks. In the next permit issuance,NC DEQ
had removed the BOD analytical sampling requirement from Jackson Paper's individual
permit. Historic analytical data from 2009 through early 2012, when BOD monitoring
ceased, indicated all BOD testing from SW002 and SW003 was below the benchmark
value of 30 mg/L. Based on historical data indicating the drainage areas did not have an
adverse effect on Scott's Creek, the facility respectfully requests that the BOD analytical
monitoring requirement be removed from SW002 and SW003.
■ DEMLR response: Due to the types of materials stored in SW002 and SW003
drainage areas, BOD is a pollutant of concern. Monitoring for BOD shall remain
in the permit as long as materials have the potential for exposure to stormwater.
o Tier One, Tier Two, Tier Three Response: Jackson Paper recommends that the following
language be added to the "Within two weeks"rows of Tables 3, 4, and 5: "If the cause of
the exceedance is identified to not be the result of Jackson Paper industrial activities but
rather caused by NC DOT Project 5600 or stormwater runoff from the highway, then
Jackson Paper shall notify the Division's Asheville Regional Office of its findings and
this non-industrial exceedance will not result in the increase of status of the outfall or
require any further action on the part of Jackson Paper."NCDOT Project 5600 has the
potential to cause pollutants to be found in Jackson Paper's stormwater outfalls which
originate from non-industrial activity such as highway stormwater runoff. The proposed
language provides Jackson Paper with the ability to prove that any benchmark
exceedances are not due to the onsite industrial process and/or originating on the site.
Once established, this should not result in an increased tier for any outfall or require a
response from Jackson Paper beyond notifying NCDEQ of its findings.
■ DEMLR response: Language in the permit regarding Tier Response already
allows permittees to ask for Tier Response relief. If you see benchmark
exceedances after sampling,you may contact the Asheville Regional Office with
documentation to discuss possible Tier Relief of any affected outfalls.
Page 9 of 9

LocaliQ
Georgia/North Carolina PO Box 631697 Cincinnati,OH 45263-1697
South Carolina
GANNETT
PROOF OF PUBLICATION NORTH CA OLINA COMM SS ONIRONMENTAL INTENT TO ISSUE MANAGEMENT
NPDES STORMWATER DISCHARGE PERMITS
Joyce Sanford The North Carolina Environmental Management Commission
Deq Div Of Water Resources proposes to issue NPDES stormwater discharge permit(s)to
the person(s) listed below. Public comment or objection to
1617 Mail Service Car the draft permits is invited.Written comments regarding the
Raleigh NC 27699-1617 proposed permit will be accepted until 30 days after the
Publish date of this notice and considered in the final deter-
mination regarding permit issuance and permit provisions.
The Director of the NC Division of Energy,Mineral,and
STATE OF WISCONSIN, COUNTY OF BROWN Land Resources (DEMLR) may hold a public hearing should
there be a significant degree of public interest. Please mail
comments and/or information requests to DEMLR at 1612
Before the undersigned, a Notary Public, duly Mail Service Center, Raleigh, NC 27699-1612.
•Jackson Paper Manufacturing Company (PO Box 667, — —
commissioned,qualified and authorized by law to SVIva, NC 28779-06681 has requested renewal of permit
administer oaths, personally appeared said legal clerk, NCS000295 for the Jackson Paper Manufacturing Company—
P Y Pp g ,who, Plant in Jackson County.This facility discharges to
being first duly sworn, deposes and says: that he/she is the Scott Creek in the Little Tennessee River Basin.
legal clerk of The Asheville Citizen-Times,engaged in Interested persons may visit DEMLR a1512 N.Salisbury
street, Raleigh, NC 27604 to review information on file.Addi-
publication of a newspaper known as The Asheville Citizen- tional information on NPDES permits and this notice may be
Times, published, issued and entered as first class mail in found on our .govwebs/ab
P reso ces/stormw/about/divisions/energromistormwater ntl-
the city of Asheville, in Buncombe County, State of North resources/stormwaterontacting r canna Young or by contacting Bnipnna Young at
Carolina;that he/she is authorized to make this affidavit D1i9PAfl.youn99deg ps gpy or 919-707-3647.
9/20123
and sworn statement;that the notice or other legal 9283934
advertisement, a true copy of which is attached here to,
was published in said newspaper in the issues dated:
09/20/2023 RECEIVED
That said newspaper in which said notice, paper, document
or legal advertisement was published was,at the time of C;,I 2 2023
each and every publication,a newspaper meeting all the DEMLR-stormwater Program
requirements and qualifications of Section 1-597 of the
General Statutes of North Carolina and was a qualified
newspaper within the meaning of Section 1-597 of the
General Statutes of North Carolina.
Sworn to and subscribed before on 09/20/2023
Legal Cier
Notary,Stay o W ,C X
f B�Owi
My commision expires
Publication Cost: $163.26
Order No: 9283934 N of Copies:
Customer No: 948986 2
PO 19:
THIS IS NOT AN INVOICE! N ICOLE JACOBS
Please do nol use thlsformforpmment renduance. 1 Notary Public
State of Wisconsin Pagel of 1

o Jackson Paper Mfg. 152 W Main St.
s VsrA1NABLE BUSINESS FOR THE UU--1 Sylva, NC 28 19
CEIVE
October 12, 2023D
Ms. Brianna Young OCT 17 2023
Industrial Individual Permits Coordinator _II--ML€R-StormwaterPrograr��
Stormwater Permitting Program
NC Department of Environmental Quality — DEMLR
1612 Mail Service Center
Raleigh, NC 27699-1612
RE: NPDES Individual Stormwater Permit NCS000295
Draft Permit Comments
Jackson Paper Manufacturing Company
Dear Ms, Young:
Jackson Paper Manufacturing Company (Jackson Paper) received the draft individual
stormwater permit electronically on September 13, 2023. Jackson Paper appreciates the
opportunity to review and provide comments on the draft permit. Please see draft permit
conditions in italics and response comments outlined below.
Part D: Analytical Monitoring Requirements. D-1. Required Baseline Sampling
(b) In addition to the grab samples, the average monthly usage of new motor and
hydraulic oil for the facility shall be tracked, recorded, and reported to the Division if it
exceeds an average of 55 gallons per month over the previous twelve (12) months.
Jackson Paper requests that the tracking only apply to the specific drainage areas in which Oil
and Grease activities are conducted regarding this tracking requirement. Further Tables 1 and 2
indicate Oil & Grease testing is only required in drainage areas that use >55 gallons/month of oil
on average.
Table 1. Summary of Quarterly Baseline Sampling Requirements for Stormwater
Discharges for Outfalls SW001 and SWO04
Jackson Paper does not believe that the activities within the drainage basin for Outfall SWO04
meet the definition of stormwater discharges associated with industrial activity. The area in this
basin is limited to an employee parking lot. Currently, no industrial activities take place in Outfall
SW004. Jackson Paper does not believe that quarterly monitoring of Outfall SWO04 is
warranted and proposes to discontinue sampling of this outfall. The facility requests that the
permit condition be modified to note that quarterly sampling is only required if industrial activities
occur.
Q (828) 586-5534 o@ Info@Jackson Paper.net @ JacksonPaper.net

0�� :� Jackson Paper Mfg. 152 WMain St,
s_',_r.: ]« L� UU�.I I,— ,,,. Sylva, NC 28779
Table 1. Summary of Quarterly Baseline Sampling Requirements for Stormwater
Discharges for Outfalls SW001 and SWO04
Parameter. Non-Polar Oil & Grease for drainage areas that use >55 gallons/month of oil
on average per EPA Method 1664 (SGT HEM)
The facility has historically been required to test for non-polar oil and grease (O&G) for Outfalls
SWO01 and SW004. Activities in drainage area SWO01 includes a dumpster, loading docks,
employee parking areas, and roof drains from the office building. Activities in drainage area
SWO04 includes only employee parking. Jackson Paper neither uses nor stores motor or
hydraulic oil in either of these drainage areas. There is no vehicle washing or maintenance
conducted in these drainage areas. Furthermore, available analytical data from April 2017
through August 2023 has shown all results to be non-detect for O&G from these outfalls. The
fact sheet provided by NC DEQ indicates that the basis for O&G monitoring is the potential
pollutant from lubricants. There are no industrial activities in either of these drainage areas that
involve lubricants. Therefore, Jackson Paper respectfully requests that the oil tracking and O&G
analytical sampling requirement be removed from Table 1 for Outfalls SWO01 and SW004.
Table 2. Summary of Quarterly Baseline Sampling Requirements for Stormwater
Discharges for Outfalls SWO02 and SWO03
Parameter Total Copper; Total Lead; Total Zinc; and Hardness— Total as[CaCO3 or
(Ca + Mg)]
The facility has not altered industrial activities on site as part of the renewal application. Jackson
Paper has not historically been required to test for metals based on the industrial activities
conducted on site. Metal and hardness testing has been added to SWO02 and SWO03 based on
the note from NC DEQ that discharge potential indicator as metals are present in the drainage
area. Jackson Paper does not expect significant levels of metals in these drainage areas. The
facility requests that the sampling condition be updated to reflect a scaled approach to sampling
frequency based on analytical results. If testing of metals indicates consistent results below
benchmarks, the facility requests an option to reduce testing within the permit term. This will
prevent an undue financial burden if early results indicate there are no metals in the stormwater
discharge.
Table 2. Summary of Quarterly Baseline Sampling Requirements for Stormwater
Discharges for Outfalls SWO02 and SWO03
Parameter. Biochemical Oxygen Demand (BOD5)
NC DEQ added a BOD analytical testing requirement to Outfall SWO02 and SWO03 based on
information provided with the permit renewal application. As mentioned previously, there have
been no major changes to outdoor industrial activities based on this renewal. NC DEQ noted in
the fact sheet that this monitoring requirement was removed in 2017 permit renewal for an
unknown reason. Jackson Paper previously had a requirement to test for BOD from these two
�, (828) 585-5534 @ [e-mail] @ JacksonPaper.net

I
o Jackson Paper Mfg. 152 W Main St,
SUSTAINAME 6USINr3'_,, 1-1�;, T­ II,L,:._ Sylva, NC 28779
outfalls. An NPDES Stormwater Permit Compliance Inspection was conducted on March 20,
2012 by Linda Wiggs and Susan Wilson of the NC DEQ. In the follow up inspection letter dated
April 13, 2012, NC DEQ recommended that monitoring be reduced or eliminated from both
outfalls due to historical analytical data below the benchmarks. In the next permit issuance, NC
DEQ had removed the BOD analytical sampling requirement from Jackson Paper's individual
permit. Historic analytical data from 2009 through early 2012, when BOD monitoring ceased,
indicated all BOD testing from SWO02 and SWO03 was below the benchmark value of 30 mg/L.
Based on historical data indicating the drainage areas did not have an adverse effect on Scott's
Creek, the facility respectfully requests that the BOD analytical monitoring requirement be
removed from SWO02 and SW003.
Table 9: Tier One Response for a Benchmark Exceedance (P. 17)
Table 4: Tier Two Response for Two Consecutive Benchmark Exceedances (P. 18)
Table 5: Tier Three Response for Four Benchmark Exceedances within 5 Years (P. 19).
Jackson Paper recommends that the following language be added to the "Within two
weeks" rows of Tables 3, 4, and 5:
If the cause of the exceedance is identified to not be the result of Jackson Paper
industrial activities but rather caused by NCDOT Project 5600 or stormwater runoff from
the highway, then Jackson Paper shall notify the Division's Asheville Regional Office of
its findings and this non-industrial exceedance will not result in the increase of status of
the outfall or require any further action on the part of Jackson Paper."
NCDOT Project 5600 has the potential to cause pollutants to be found in Jackson Paper's
stormwater outfalls which originate from non-industrial activity such as highway stormwater
runoff. The proposed language provides Jackson Paper with the ability to prove that any
benchmark exceedances are not due to the onsite industrial process and/or originating on the
site. Once established, this should not result in an increased tier for any outfall or require a
response from Jackson Paper beyond notifying NCDEQ of its findings.
This language is designed to help Jackson Paper comply with its permit during and after the
completion of NCDOT's road project while not placing undue burden on Jackson Paper, a
private entity, to conduct tests for pollutants found as the result of a government project. In other
words, the costs associated with responding to an exceedance should not be borne by Jackson
Paper if Jackson Paper is not the cause of the exceedance.
Finally, the presence of certain discharges informs future permits. To ensure that Jackson
Paper's permit is suited to Jackson Paper activities, it is important to distinguish between
pollutants added by stormwater runoff from the highway verses those caused by Jackson
Paper's industrial activities.
�, (828) 586-5534 @ [e-mail] @ Jackson Paper.net

J Jackson Paper Mfg. 152 W Main St,
SVSTAiNABLE BUSINESS FOR THE .U, Sylva, NC 28779
Jackson Paper appreciates the opportunity to provide comments on the draft stormwater permit.
We request the opportunity to have a conference call with you and Asheville Regional Office
DEMLR staff prior to issuance of the final permit to discuss our comments. If you have
questions or need additional information regarding the information in this submittal, please
contact me at [phone] or via email at [e-mail].
Sincerely,
A�1�4L��
Kiesha Bridges
Manager of Safety, Environmental & Technical
Jackson Paper Manufacturing Company
1� (828) 586-5534 [a [e-mail] JacksonPaper.net

Young, Brianna A
From: Kiesha Bridges <[e-mail]>
Sent: Thursday, October 12, 2023 3:33 PM
To: Young, Brianna A
Subject: RE: [External] RE: External Sender: Draft NPDES Permit NCS000295
Attachments: Jackson Paper NPDES SW Permit NCS000295 Draft Permit Comments.pdf
Importance: High
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 Brianna,
Please see attached draft permit comments. A paper copy will be sent through the mail
to your attention.
Thank you,
Kiesha Bridges
Manager of Safety, Environmental & Technical
cc!�111 Jackson Paper Mfg.
152 W. Main Street, Sylva, NC 28779
O. 828-586-5534 Ext. 226
F. 828-631-3314
From:Young, Brianna A<[e-mail]>
Sent:Thursday, October 5, 2023 11:20 AM
To: Kiesha Bridges<KBridges@jacksonpa per.net>
Subject: RE: [External] RE: External Sender: Draft NPDES Permit NCS000295
Good morning,
A copy of the fact sheet is attached.
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
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
1

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: Kiesha Bridges<[e-mail]>
Sent:Thursday, October 5, 2023 11:16 AM
To:Young, Brianna A<[e-mail]>
Subject: [External] RE: External Sender: Draft NPDES Permit NCS000295
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 morning, Brianna,
Can you send the corresponding fact sheet for the draft permit NCS000925 to aid in our
review?
Thank you,
Kiesha Bridges
Manager of Safety, Environmental & Technical
Jackson Paper Mfg.
152 W. Main Street, Sylva, NC 28779
O. 828-586-5534 Ext. 226
F. 828-631-3314
From:Young, Brianna A<[e-mail]>
Sent:Wednesday, September 13, 2023 8:31 AM
To: Carr Tyndall <ctyndall@iacksonpa per.net>; Kiesha Bridges<[e-mail]>
Subject: External Sender: Draft NPDES Permit NCS000295
Good morning,
Please find attached a copy of the draft NPDES stormwater permit for the Jackson Paper Manufacturing Company—Sylva
Plant (NCS000295). A hard copy of this draft permit will be placed in the mail to Carr Tyndall. Please provide any
comments on the draft permit by October 13, 2023.
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
2

**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.
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.
This message is intended only for the individual or entity to which it is addressed and contains information that is
proprietary to The Jackson Paper Mfg. Company and/or its affiliates, or may be otherwise confidential. If the reader of
this message is not the intended recipient, or the employee agent responsible for delivering the message to the
intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify the sender immediately by return e-
mail and delete this message from your computer.
This message is intended only for the individual or entity to which it is addressed and contains information that is
proprietary to The Jackson Paper Mfg. Company and/or its affiliates, or may be otherwise confidential. If the reader of
this message is not the intended recipient, or the employee agent responsible for delivering the message to the
intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify the sender immediately by return e-
mail and delete this message from your computer.
This message is intended only for the individual or entity to which it is addressed and contains information that is
proprietary to The Jackson Paper Mfg. Company and/or its affiliates, or may be otherwise confidential. If the reader of
this message is not the intended recipient, or the employee agent responsible for delivering the message to the
intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify the sender immediately by return e-
mail and delete this message from your computer.
This message is intended only for the individual or entity to which it is addressed and contains information that is
proprietary to The Jackson Paper Mfg. Company and/or its affiliates, or may be otherwise confidential. If the reader of
this message is not the intended recipient, or the employee agent responsible for delivering the message to the
intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify the sender immediately by return e-
mail and delete this message from your computer.
3

Jackson Paper Mfg. 152 W Main St,
SU6TP INTBLE BVSINE 65 FOfl iME FUTURE SylVa, NC 28779
October 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
RE: NPDES Individual Stormwater Permit NCS000295
Draft Permit Comments
Jackson Paper Manufacturing Company
Dear Ms. Young:
Jackson Paper Manufacturing Company (Jackson Paper) received the draft individual
stormwater permit electronically on September 13, 2023. Jackson Paper appreciates the
opportunity to review and provide comments on the draft permit. Please see draft permit
conditions in italics and response comments outlined below.
Part D:Analytical Monitoring Requirements. D-1. Required Baseline Sampling
(b) In addition to the grab samples, the average monthly usage of new motor and
hydraulic oil for the facility shall be tracked, recorded, and reported to the Division if it
exceeds an average of 55 gallons per month over the previous twelve (12) months.
Jackson Paper requests that the tracking only apply to the specific drainage areas in which Oil
and Grease activities are conducted regarding this tracking requirement. Further Tables 1 and 2
indicate Oil &Grease testing is only required in drainage areas that use >55 gallons/month of oil
on average.
Table 1. Summary of Quarterly Baseline Sampling Requirements for Stormwater
Discharges for Outfalls SW001 and SW004
Jackson Paper does not believe that the activities within the drainage basin for Outfall SW004
meet the definition of stormwater discharges associated with industrial activity. The area in this
basin is limited to an employee parking lot. Currently, no industrial activities take place in Outfall
SW004. Jackson Paper does not believe that quarterly monitoring of Outfall SW004 is
warranted and proposes to discontinue sampling of this outfall. The facility requests that the
permit condition be modified to note that quarterly sampling is only required if industrial activities
occur.
l` (828) 586-5534 @ [e-mail] ® JacksonPaper.nel

o Jackson Paper Mfg. 152 W Main St,
SUSTRINTBLE BU$INE88 FON THE FU.U.E Sylva, NC 28779
Table 1. Summary of Quarterly Baseline Sampling Requirements for Stormwater
Discharges for Outfalls SW001 and SW004
Parameter. Non-Polar Oil& Grease for drainage areas that use >55 gallons/month of oil
on average per EPA Method 1664 (SGT-HEM)
The facility has historically been required to test for non-polar oil and grease (O&G) for Outfalls
SW001 and SW004. Activities in drainage area SW001 includes a dumpster, loading docks,
employee parking areas, and roof drains from the office building. Activities in drainage area
SW004 includes only employee parking. Jackson Paper neither uses nor stores motor or
hydraulic oil in either of these drainage areas. There is no vehicle washing or maintenance
conducted in these drainage areas. Furthermore, available analytical data from April 2017
through August 2023 has shown all results to be non-detect for O&G from these outfalls. The
fact sheet provided by NC DEQ indicates that the basis for O&G monitoring is the potential
pollutant from lubricants. There are no industrial activities in either of these drainage areas that
involve lubricants. Therefore, Jackson Paper respectfully requests that the oil tracking and O&G
analytical sampling requirement be removed from Table 1 for Outfalls SW001 and SW004.
Table 2. Summary of Quarterly Baseline Sampling Requirements for Stormwater
Discharges for Outfalls SW002 and SW003
Parameter.: Total Copper, Total Lead; Total Zinc; and Hardness— Total as[CaCO3 or
(Ca + Mg)]
The facility has not altered industrial activities on site as part of the renewal application. Jackson
Paper has not historically been required to test for metals based on the industrial activities
conducted on site. Metal and hardness testing has been added to SW002 and SW003 based on
the note from NC DEQ that discharge potential indicator as metals are present in the drainage
area. Jackson Paper does not expect significant levels of metals in these drainage areas. The
facility requests that the sampling condition be updated to reflect a scaled approach to sampling
frequency based on analytical results. If testing of metals indicates consistent results below
benchmarks, the facility requests an option to reduce testing within the permit term. This will
prevent an undue financial burden if early results indicate there are no metals in the stormwater
discharge.
Table 2. Summary of Quarterly Baseline Sampling Requirements for Stormwater
Discharges for Outfalls SW002 and SW003
Parameter: Biochemical Oxygen Demand(BOD5)
NC DEQ added a BOD analytical testing requirement to Outfall SW002 and SW003 based on
information provided with the permit renewal application. As mentioned previously, there have
been no major changes to outdoor industrial activities based on this renewal. NC DEQ noted in
the fact sheet that this monitoring requirement was removed in 2017 permit renewal for an
unknown reason. Jackson Paper previously had a requirement to test for BOD from these two
1`, (828) 586-5534 @ InfoQJacksonPaper.net ® JacksonPaper.net

o Jackson Paper Mfg. 152 W Main St,
SNSTq...... ..SINES$ FOP THE .....E SylVa, NC 28779
outfalls. An NPDES Stormwater Permit Compliance Inspection was conducted on March 20,
2012 by Linda Wiggs and Susan Wilson of the NC DEQ. In the follow up inspection letter dated
April 13, 2012, NC DEQ recommended that monitoring be reduced or eliminated from both
outfalls due to historical analytical data below the benchmarks. In the next permit issuance, NC
DEQ had removed the BOD analytical sampling requirement from Jackson Paper's individual
permit. Historic analytical data from 2009 through early 2012, when BOD monitoring ceased,
indicated all BOD testing from SWO02 and SWO03 was below the benchmark value of 30 mg/L.
Based on historical data indicating the drainage areas did not have an adverse effect on Scott's
Creek, the facility respectfully requests that the BOD analytical monitoring requirement be
removed from SWO02 and SW003.
Table 3: Tier One Response for a Benchmark Exceedance (P. 17)
Table 4: Tier Two Response for Two Consecutive Benchmark Exceedances (P. 18)
Table 5: Tier Three Response for Four Benchmark Exceedances within 5 Years (P. 19).
Jackson Paper recommends that the following language be added to the "Within two
weeks" rows of Tables 3, 4, and 5:
If the cause of the exceedance is identified to not be the result of Jackson Paper
industrial activities but rather caused by NCDOT Project 5600 or stormwater runoff from
the highway, then Jackson Paper shall notify the Division's Asheville Regional Office of
its findings and this non-industrial exceedance will not result in the increase of status of
the outfall or require any further action on the part of Jackson Paper."
NCDOT Project 5600 has the potential to cause pollutants to be found in Jackson Paper's
stormwater outfalls which originate from non-industrial activity such as highway stormwater
runoff. The proposed language provides Jackson Paper with the ability to prove that any
benchmark exceedances are not due to the onsite industrial process and/or originating on the
site. Once established, this should not result in an increased tier for any outfall or require a
response from Jackson Paper beyond notifying NCDEQ of its findings.
This language is designed to help Jackson Paper comply with its permit during and after the
completion of NCDOT's road project while not placing undue burden on Jackson Paper, a
private entity, to conduct tests for pollutants found as the result of a government project. In other
words, the costs associated with responding to an exceedance should not be borne by Jackson
Paper if Jackson Paper is not the cause of the exceedance.
Finally, the presence of certain discharges informs future permits. To ensure that Jackson
Paper's permit is suited to Jackson Paper activities, it is important to distinguish between
pollutants added by stormwater runoff from the highway verses those caused by Jackson
Paper's industrial activities.
L`, (828) 586-5534 @ [e-mail] ® JacksonPaper.net

Jackson Paper Mfg. 152 W Main St,
SUSTAINABLE BUSINESS FOR THE FUTURE Sylva, NC 28779
Jackson Paper appreciates the opportunity to provide comments on the draft stormwater permit.
We request the opportunity to have a conference call with you and Asheville Regional Office
DEMLR staff prior to issuance of the final permit to discuss our comments. If you have
questions or need additional information regarding the information in this submittal, please
contact me at [phone] or via email at [e-mail].
Sincerely,
lz�4-��
Kiesha Bridges
Manager of Safety, Environmental &Technical
Jackson Paper Manufacturing Company
l`, (828) 586-5534 @o [e-mail] @ JacksonPaper.net

Young, Brianna A
From: Kiesha Bridges <[e-mail]>
Sent: Monday,July 24, 2023 9:21 AM
To: Young, Brianna A
Subject: [External] General Guidance Request Related to Roadway Project
Attachments: NPDES Guidance Request Related to Roadway Project.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 morning, Brianna,
I am copying you on this letter that Jackson Paper submitted to Mr. Mike Smith at the
Asheville Regional Office. Please see attached.
Kind Regards,
Kiesha Bridges
Manager of Safety, Environmental & Technical
Jackson Paper Mfg.
152 W. Main Street, Sylva, NC 28779
O. 828-586-5534 Ext. 226
F. 828-631-3314
This message is intended only for the individual or entity to which it is addressed and contains information that is
proprietary to The Jackson Paper Mfg. Company and/or its affiliates, or may be otherwise confidential. If the reader of
this message is not the intended recipient, or the employee agent responsible for delivering the message to the
intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify the sender immediately by return e-
mail and delete this message from your computer.
i

0J : Jackson Paper Mfg. 152 W Main St,
sVSTAINA©LE DUSINEss FOR THE rLpTVAE Sylva, NC 28779
July 20, 2023
Mike Smith
Assistant Regional Engineer--Stormwater Program
Asheville Regional Office
2090 U.S. 70 Highway
Swannanoa, NC 28778
Subject: NPDES Stormwater Individual Permit
General Guidance Request Related to Roadway Project
Jackson Paper Manufacturing Company—Sylva Plant
Permit No. NCS000295
Dear Mr. Smith:
Jackson Paper Manufacturing Company—Sylva Plant (Jackson Paper) owns and operates a
recycled paper manufacturing facility at 152 West Main Street in Sylva, Jackson County, North
Carolina. The facility operates under the North Carolina Department of Environmental Quality
(NC DEQ) National Pollutant Discharge Elimination System (NPDES) individual stormwater
permit No. NCS000295, which expired on February 28, 2022. Jackson Paper submitted a
complete NC DEQStormwater Renewal Package on August 26, 2021 which is currently in review
with the NC DEQ and therefore, coverage under this existing permit has been extended until a
new permit is issued. The purpose of this letter is to:
(a) provide notice to NC DEQ of an NC DOT Project which: (i) has the potential to
significantly alter the nature or quantity of pollutants discharged; or (ii) result in
noncompliance with the permit as required by Part III, Section E (5) and (6) of the
current permit;
(b) request that any such altered discharges caused by the NC DOT Project be
considered when deciding upon the conditions, benchmarks, and requirements
of the new permit; and
(c) request guidance from NC DEQ as to how to maintain compliance.
1� (82B) 586-5534 dal InfoWacksonPaper.net 0 JacksonPaper.net

Jackson Paper Mfg. 152 W Main St,
SV STAIYJABLE BL151fJE5S FOR THE FVTIi IiE
5ylva, NC 28779
The facility is located adjacent to West Main Street (Highway 107). Stormwater discharges from
the facility via four outfalls into Scott Creek (Index 2-79-39, Class C for Trout Waters [C; Tr];
Little Tennessee River Basin) which flows south, southwest off the property and under West
Main Street. The North Carolina Department of Transportation (NC DOT) has notified Jackson
Paper that the department will be widening West Main Street under Road Project R5600. To
complete the project, NC DOT will take a portion of the facility's property along West Main
Street for public use eminent domain. While the exact location has not been settled on by NC
DOT, it is possible that this area of land may include the location of current stormwater outfalls
Moreover, as stated below, we are concerned that stormwater discharges from the roadway
will commingle with Jackson Paper stormwater discharges thereby producing unrepresentative
samples which inflate and do not accurately reflect Jackson Paper's contribution of pollutants.
Jackson Paper has three outfalls which are located near West Main Street. A brief description of
their current location and potential impact from the road widening project is described below:
• Outfall 001 is located at a catch basin in the middle of the facility's front parking area.
Stormwater discharges from both Jackson Paper and the public road flow to a common
pipe on the property that gravity flows under West Main Street. Portions of West Main
Street slope toward the facility so that stormwater-from this section of the roadway
discharges toward 0utfaI1 001.
Potential Impact: Unforeseen stormwater comingling from roadway during and after
construction.
• Outfall 002 is located adjacent to West Main Street at the edge of the Shipping and
Finishing Warehouse. The outfall also collects incidental groundwater from under the
facility due to the pipe structure being level to or below the water table.
Potential Impact: Sampling location may need to be moved as this location will likely be
taken under eminent domain. Unforeseen stormwater comingling from roadway during
and after construction
• Outfall 003 is located to the west of the Shipping and Finishing Warehouse. The outfall
collects runoff from the areas around the boiler and sawdust/fuel receiving and storage,
boiler ash pit and boiler ash ponds,the recycle pulp facility, paper bale receiving dock
and storage, several masonry storage buildings for spare equipment and the railroad
tracks that service the facility.
Potential Impact: Sampling location may need to be moved if location is taken under
eminent domain. Unforeseen stormwater comingling from roadway during and after
construction.
A site map is included as Appendix A for reference.
d (828) 586-5534 @ Info@JacksonPaper,net ( JacksonPaper.net

Jackson Paper Mfg. 152 WMain St,
SUSTAINABLE BUSINJ[SS i��I FOR THE FUTORE Sylva, ' C 28779
Planning for the road project is currently underway, including business closures and building
demolitions in the affected surrounding areas. Jackson Paper has requested information from
NC DOT related to specific aspects of the project that have the potential to impact the facility's
stormwater but have yet to receive a direct response. The facility is unaware of the full impact
the proposed project will have on its stormwater drainage system and outfalls. Jackson Paper is
concerned that changes may be implemented without the facility's prior consent or
understanding and that the facility will have to reactively ensure they remain in compliance
with the requirements set forth in the individual stormwater permit due to circumstances
outside of its control.
Jackson Paper is requesting guidance from NC DEQ regarding how to maintain compliance with
the stormwater permit in lieu of potential unforeseen changes made by the NC DOT. We
propose a call with NC DEQ to discuss the project and understand the department's
expectations related to incorporating any changes made to the site into the stormwater permit
and Stormwater Pollution Prevention Plan (SPPP).
We appreciate your consideration of the information we are providing in response to the
ongoing DOT road widening project. Please contact me at 828-586-5534 or by email at
[e-mail].
Sincerely,
Carr Tyndall
President
Jackson Paper Manufacturing Company
Attachments
cc: Brianna Young, Industrial Program Individual Permit Coordinator, NC DEQ
cc: Kiesha Bridges, Manager of Safety, Environmental &Technical, Jackson Paper
`L (828) 586-5534 @ [e-mail] C Jackson Paper.net

Young, Brianna A
From: Kiesha Bridges <[e-mail]>
Sent: Monday,July 10, 2023 8:59 AM
To: Young, Brianna A
Cc: Carr Tyndall
Subject: [External] RE: External Sender: RE:Jackson Paper Manufacturing Company Sylva Plant
stormwater permit NCS000295
Attachments: JP Stormwater Monitoring Results 2017-2023 - Permit Renewal.xlsx
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 morning, Brianna,
See list of requested information below. Jackson Paper responses are listed in bold.
• Description of industrial activity occurring and chemicals stored onsite;
Jackson Paper produces roll stock medium grade paper from old corrugated containers. The mill
reuses 100% recycled paper as its feed stock. The facility operates a wastewater treatment plant
(WWTP) which is considered closed-loop; no wastewater discharges to the municipal sanitary
sewer. Chemicals stored on site include fuel,WWT chemicals, and material used in paper
production.
• Confirmation on the number of outfalls and associated coordinates;
The outfall information and associated coordinates in the NPDES SW Permit Summary Report
are correct. Jackson Paper added a tractor trailer storage and employee parking area on a portion
of the northern end of the property. The trailers are owned by a third party contractor and are
not stored coupled to the tractor. The trailers are typically empty but may contain finished paper
rolls or bales of cardboard; no liquid material will be stored in the trailers. There will be no
material loading or unloading; truck cleaning,fueling or maintenance conducted in this area.
Stormwater from the gravel lot discharges through a new drainage ditch which goes underneath
the existing railroad tracks and discharges into Scotts Creek. Because there are no industrial
activities occurring that have the potential to impact stormwater, this area and the discharge point
would not be considered a stormwater discharge outfall. A discussion of this area will be added to
the facility's SWPPP.
• Description of industrial activity in each drainage area;
Outfall 001 —runoff from employee and visitor parking areas, roof drains from the Office
Building, and deliver truck loading/unloading docks. Portions of West Main Street, located to the
east of the facility, slopes toward the facility so that stormwater from this section of the roadway
runs toward Outfall 001.
Outfall 002 —building roof drains from the Warehouse and Paper Machine building and a catch
basin that collects stormwater from a parking area between the paper machine building and
around the WWTP. The outfall also collects incidental groundwater from under the facility due to
the pipe structure being level to or below the water table.
1

Outfall 003 —areas around the boiler and sawdust/fuel receiving and storage,boiler ash pit and
boiler ash ponds, the recycle pulp facility, paper bale receiving dock and storage, several masonry
storage buildings for spare equipment and the railroad tracks that service the facility.
Outfall 004—parking area between the Paper Machine Building and the WWTP area. The
stormwater discharges to a catch basin and extends below grade to the east.
• SIC (NAICS) code;
2631
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
A spreadsheet summarizing analytical and qualitative monitoring data is attached. This data
includes monitoring results from the effective date of current permit through April 2023.
• Verification that the information in the renewal application is still complete and correct
The information in the renewal application submitted is still complete and correct.
• An explanation of any operational changes since the renewal application was submitted.
There have been no operational changes at the facility since the renewal application was
submitted.
Please let me know if you have any questions or need anything additional information.
Sincerely,
Kiesha Bridges
Manager of Safety, Environmental & Technical
V 0 1 C Jackson Paper Mfg.
152 W. Main Street, Sylva, NC 28779
O. 828-586-5534 Ext. 226
F. 828-631-3314
From:Young, Brianna A<[e-mail]>
Sent: Friday,July 7, 2023 11:07 AM
To: Carr Tyndall <[e-mail]>
Cc: Kiesha Bridges<KBridges@jackson paper.net>
Subject: External Sender: RE:Jackson Paper Manufacturing Company Sylva Plant stormwater permit NCS000295
Importance: High
Good morning,
I am following up on my previous email.To date I have not received any of the requested information.This information
is required in order to proceed with reviewing the permit renewal. Please let me know if you have any questions or need
assistance on the request.
Thank you,
2

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: Friday,June 2, 2023 10:23 AM
To: [e-mail]
Cc: Kiesha Bridges<KBridges@iackson paper.net>
Subject:Jackson Paper Manufacturing Company Sylva Plant stormwater permit NCS000295
Good morning,
The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program
acknowledges receipt of your renewal application for coverage under NPDES Permit Number NCS000295.
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.
I am working on renewing the individual stormwater permit for the Jackson Paper Manufacturing Company
Sylva Plant(NCS000295). 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 and chemicals stored 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:
3

• 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 Bethany og ulias
• Stormwater outfall information: Email Bethany Geor_og ulias
• Visit the eDMR Six Steps website and complete Steps I and 2.
• Pay outstanding permit fees: Stormwater ePayment 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)PLEASE NOTE NEW EMAIL
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.
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.
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.
This message is intended only for the individual or entity to which it is addressed and contains information that is
proprietary to The Jackson Paper Mfg. Company and/or its affiliates, or may be otherwise confidential. If the reader of
this message is not the intended recipient, or the employee agent responsible for delivering the message to the
intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
4

strictly prohibited. If you have received this communication in error, please notify the sender immediately by return e-
mail and delete this message from your computer.
This message is intended only for the individual or entity to which it is addressed and contains information that is
proprietary to The Jackson Paper Mfg. Company and/or its affiliates, or may be otherwise confidential. If the reader of
this message is not the intended recipient, or the employee agent responsible for delivering the message to the
intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify the sender immediately by return e-
mail and delete this message from your computer.
5

Jackson Paper Manufacturing Company
Sylva,NC
NPDES Permit No.NCS000295
Summary of Visual Monitoring Results
Outfall 001 Outfall 002 Outfall 003 Outfall 004
5 _ `0 .26 5
Ao = v — ° EE E _
— E
"Month Sample Date
-
Apr-17 4/3/17 Light Brown None 2 1 2 No No No No Clear None 1 1 = 1 No No No No Light Earthy 2 1 =2 No No No No Clear None 1 1 = 1 No No No No
Brown
Sep-17 9/16/17 Clear None 1 1 2 No No No No Clear None 1 1 1 No No No No a own None 3 1 3 No No No No Clear None 1 1 1 No No No No
Dec-17 12/5/17 Light Grey None 2 1 2 No No No No Clear None 1 1 2 No No No No B nowt None 1 1 1 No No No No Light None 1 1 2 No No No No
gre
Mar-18 3/6/18 Clear None 1 1 1 No No No No Clear one 1 1 1 No No No No Light None 2 1 2 No No No No Clear one 1 1 1 No No No No
Brown
May-18 5/16/18 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No Med None 3 1 3 No No No No Clear None 1 1 1 No No No No
ey
Sep-18 9/10/18 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No Light Brown None 2 1 2 No No No No Clear None 1 2 1 No No No No
Dec-18 12/14/18 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No
Dec-18 12/20/18 Dingy None 3 1 3 No No No No - - - I - - I - I - - I - I Clear None 1 I 1 1 No No No No Clear None 1 1 1 1 No No No No
Feb-19 2/28/19 Med Grey None 3 1 3 No No No No Clear None 1 1 1 No No No No Clear None 1 1 2 No No No No Clear None 1 1 1 No No No No
Apr-19 4/26/19 Med Grey None 2 1 3 No No No No
May-19
Jun-19 6/7/19 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No Light None 2 1 2 Yes No No No Clear None 1 1 1 No No No No
Brown
Jul-19 7/22/19 Clear None 1 1 1 No No No No
Aug-19 8/27/19 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No Light None 1 2 1 2 1 No No No No I Clear None 1 1 1 No No No No
Grey
Sep-19
Oct-19 10/16/19 Light None 1 1 1 No No No No
Grey
Nov-19 11/27/19 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No Light None 3 1 3 No No No No Clear None 1 1 1 No No No No
Grey
Dec-19 12/9/19 Clear None 1 1 1 No No No No
Jan-20 1/24/20 Clear None 1 1 1 No No No No Clear one 1 1 1 No No No No Light None 3 1 3 No No No No Clear None 1 1 1 No No No No
Brown
Feb-20 2/24/20 Light Earthy 2 1 2 No No No No
Brown
Mar-20 3/23/20 Light None 1 1 1 No No No No
Brow
Apr-20 4/23/20 Light None 2 2 2 No No No No
Brown
May-20 5/20/20 Light None 1 1 1 No No No No
Brow
Jun-20 6/23/20 Clear None 1 1 1 No No No No Clear one 1 1 1 No No No No Light
Grey None 2 1 2 No No NO No Clear one 1 1 1 No No No No
Jul-20 7/23/20 Clear None 1 1 1 No No No No
Aug-20
Sep-20 9/17/20 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No Light None 1 1 1 No No No No Clear None 1 1 1 No No No No
brow
Dec-20 12/4/20 Light Grey None 3 1 3 No No No No Clear None 1 2 1 No No No No Clear None 1 1 1 No No No No Clear None 2 1 2 No No No No
Mar-21 3/16/21 Light Grey None 2 1 2 No No No No Clear None 1 1 1 No No No No Med None 3 1 3 No No No No Clear None 1 1 1 No No No No
Brown
Apr-21
May-21 5/3/21 Clear None 1 1 1 No No No No
Jun-21 6/11/21 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No Brown None 2 2 2 No No No No Clear None 1 1 1 No No No No
Jul-21 *
Aug-21 8/4/21 Clear None 1 1 2 No No No No Clear None 1 1 1 No No No No B oewn None 3 2 3 No No No No Clear None 1 1 1 No No No No

Jackson Paper Manufacturing Company
Sylva,NC
NPDES Permit No.NCS000295
Summary of Visual Monitoring Results
Outfall 001 Outfall 002 Outfall 003 Outfall 004
5 _ `0 .26 5
> - - E z°w E E > - - �'i E - �'z° E > - - �'i w E E
o o a N
c °' o `
Month Sample Date - r 6 - - - - - -
Noy-21 11/4/21 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No Light None 1 1 1 No No No No Clear None 1 1 1 No No No No
Brown
Feb-22 2/3/22 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No own None 2 1 3 No No No No Clear None 1 1 1 No No No No
Mar-22 3/16/22 Light Grey None 2 1 2 No No No No Light None 1 1 2 No No No No
Brown
May-22 5/6/22 Light Grey None 1 1 1 No No±NoNoClear None 1 1 1 No No No No Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No
Aug-22 8/1/22 Clear None 1 1 1 No NoClear None 1 1 1 No No No No LightNone 2 1 2 No No No No Clear None 1 1 1 No No No No
Brown11/15/22 Clear None 1 1 1 No NoClear None 1 1 2 No No No No Clear None 1 1 1 No No No No Clear None 1 1 1 No No No jNo
4/14/23 Clear None 1 1 1 No NoNone None 1 1 1 No No No No Brown None 3 1 3 No No No No Clear None 1 1 1 No No No

Jackson Paper Manufacturing Company
Sylva,NC
NPDES Permit No.NCS000295
Summary of Analytical Monitoring Results
Outfall 001 Outfall 002 Outfall 003 Outfall 0D4 Scott's Creek Pre-Mill Scott's Creek Post Mill
Rainfall TSS COD O&G Turbidity T55 COD O&G Turbidity T55 COD O&G Turbidity T55 COD O&G Turbidity T55 COD O&G Turbidity T55 COD O&G Turbidity
Month Sample Date inches (mg/L) P (mg/L) (mg/L) (NTU) (mg/L) pH (mg/L) (mg/L) (NTU) (mg/L) pH (mg/L) (mg/L) (NTU) Img/L) pH (mg/L) (mg/L) (NTU) (mg/L) pH (mg/L) (mg/L) (NTU) (mg/L) pH (mg/L) (mg/L) (NTU)
Apr-17 4/3/2017 0.30 107 8 447 ND N/A 14 7 36 NO N/A 5 8 55 ND N/A 149 8 68 NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Sep-17 9/6/2017 0.46 27 7 48 ND N/A 4 7 40 NO N/A 244 8 267 ND N/A 17 7 45 NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Dec-17 12/5/2017 0.48 61 8 ND ND N/A 26 7 NO NO N/A NO 8 47 ND N/A 84 7 90 NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Mar-18 3/6/2018 0.15 22 7 34 ND N/A NO 8 NO NO N/A 17 8 58 ND N/A 9 7 NO NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
May-18 5/16/2018 0.41 32 9 ND ND N/A 4 7 NO NO N/A 242 7 78 ND N/A NO 8 NO NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Sep-18 9/10/2018 0.56 35 8 31 NO N/A 62 7 63 NO N/A 5 8 33 NO N/A 99 7 35 NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Dec-18 12/14/2018 0.23 NO 7 NO NO N/A 10 7 52 NO N/A
Dec-18 12/20/2018 0.80 181 7 132 NO N/A 490 7 37 NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Feb-19 2/28/2019 0.01 125 7 197 ND N/A 8 7 NO NO N/A 14 7 255 NO N/A 28 6 41 NO N/A
Apr-19 4/26/2019 0.15 351 6.9 357 ND 45 25 6 NO ND 3 24 6 NO NO 4
Jun-19 6/7/2019 0.70 7 6 56 ND 7 3 7 NO NO 3 143 7 97 NO 275 8 6 NO NO 4 60 6 29 ND 30 72 6 31 NO 47
Jul-19 7/22/2019 0.46 17 6 NO NO 1 17 6 NO NO 2 27 6 63 NO 4
Aug-19 8/27/2019 0.37 27 7 NO NO 27 NO 7 NO NO NO 59 7 80 NO 83 6 7 NO NO 7 21 7 NO NO 16 23 7 NO NO 12
Sep-19
Oct-19 10/16/2019 0.06 13 8 NO NO 33 7 6 NO NO 7 10 7 NO NO 8
Nov-19 11/27/2019 0.63 14 6 NO NO 6 NO 7 NO NO NO 208 7 144 NO 262 24 6 NO NO 10 124 6 27 NO 63 146 6 29 NO 89
Dec-19 12/9/2019 0.28 1 13 7 61 ND 27 15 6 ND ND 6 17 6 NO NO 7
Jan-20 1/24/2020 0.38 64 7 25 NO 18 5 7 NO NO 5 216 7 200 ND 474 34 6 25 NO 16 12 6 ND ND 2 17 6 NO NO 7
Feb-20 2/24/2020 0.80 7 7 103 ND 30 7 6 ND ND 3 7 6 NO NO 3
Mar-20 3/23/2020 0.31 37 7 139 ND 65 179 6 ND ND 35 127 6 NO NO 45
Apr-20 4/23/2020 0.32 20 7 179 NO 53 27 6 NO NO 13 29 6 NO NO 14
May-20 5/20/2020 0.50 36 7 109 NO 83 24 7 NO NO 30 29 7 NO NO 12
Jun-20 6/23/2020 0.20 52 7 NO NO 4 3 7 NO NO 1 4 7 36 ND 7 74 7 36 NO 8 22 7 ND ND 3 49 7 NO NO 4
Jul-20 1 7/23/2020 0.20 3 7 NO NO 9 31 7 NO NO NO 81 7 NO NO 6
Aug-20
Sep-20 9/17/2020 0.69 38 7 NO NO 15 5 7 NO NO 19 44 7 74 NO 92 20 7 NO NO 17 79 7 28 NO 56 90 7 26 NO 63
Dec-20 12/4/2020 0.05 264 8 279 ND 136 58 7 NO NO 8 7 7 NO NO 28 101 7 119 NO 50 4 7 NO NO NO 3 5 NO NO 1
Mar-21 3/16/2021 0.40 61 7 45 NO 19 26 7 26 NO 18 200 7 163 NO 269 26 7 NO NO 13 185 7 56 NO 53 169 7 80 NO 81
Apr-21
May-21 5/3/2021 0.50 29 8 NO NO 18 56 8 NO NO 19 133 8 26 NO 42
Jun-21 6/11/2021 0.24 11 7 43 NO 16 1 13 8 108 NO 83 240 7 157 NO 351 3 7 NO NO 4 34 6 NO NO 1 23 37 7 1 NO NO 27
Jul-21
Aug-21 8/4/2021 0.45 61 7 42 NO 9 11 7 85 NO 36 480 7 249 NO 811 18 8 NO NO 8.9 140 6 50.8 NO 104 139 7 28 NO 88.3
Sep-21
Oct-21
Nov-21 11/4/2021 0.2 40 7 42 NO 15 M42
NO 14.5 8.9 7 NO NO 13.3 86 6 60.6 NO 35.6 2.6 7 ND ND 1.4 3.1 7 ND NO 1.6
Dec-21
Jan-22
Feb-22 2/3/2022 0.8 47 6 39 ND 57 NO 23 202 7 165 NO 283 160 7 93 ND 125 145 6 42 NO 98 170 6 49 NO 105
Mar-22 3/16/2022 0.30 279 6 132 NO 97 NOT IN TIER 2 ji 33 7 137 NO 49 NOT IN TIER 2 10 7 NO NO 4 13 7 NO NO 4
Apr-22
May-22 5/6/2022 0.50 169 8 295 NO 34 39 7 33 NO 4 3 7 NO NO 4 92 7 51 NO 19 16 6 N
ONO66 6 33 NO 7
Jun-22
Jul-22
Aug-22 8/1/2022 0.50 20 8 ND NO 23 21 7 NO NO 12 138 7 150 NO 52 11 8 27 NO 17 17 7 20 7 NO NO 4

Jackson Paper Manufacturing Company
Sylva,NC
NPDES Permit No.NCSOOO295
Summary of Analytical Monitoring Results
Outfall 001 Outfall 002 Outfall 003 Outfall 004 Scott's Creek Pre-Mill Scott's Creek Post Mill
Rainfall TSS COD O&G Turbidity T55 COD O&G Turbidity T55 COD O&G Turbidity T55 COD O&G Turbidity T55 COD O&G Turbidity T55 COD O&G Turbidity
Month Sample Date inches (mg/L) PR (mg/L) (mg/L) (NTU) (mg/L) PR (mg/L) (mg/L) (NTU) (mg/L) PR (mg/L) (mg/L) (NTU) (mg/L) PR (mg/L) (mg/L) (NTU) (mg/L) PR (mg/L) (mg/L) (NTU) (mg/L) PR (mg/L) (mg/L) (NTU)
Sep-22
Oct-22
Nov-22 11/15/2022 0.90 131 8 66 ND 110 102 6 73 ND 57 6 8 45 ND 10 123 8 90 ND 8 4 6 ND ND 4 10 6 ND ND 7
Dec-22
Jan-23
Feb-23
Mar-23
Apr-23 4/14/2023 0.65 51 7 31 1 ND 1 20 1 34 7 47 ND 1 59 1 364 1 7 1 256 1 ND 1 645 1 5 1 8 1 28 ND 6 14 7 ND ND 3 1 21 1 7 1 ND ND 6
May-23
Notes
NO=Non detect
N/A=not tested
*=No opportunities during normal business hours to collect samples during this month.
Cells highlighted grey indicate testing was not completed for this outfall,either because it was not subject to the Tier 2 schedule,or because there were no testing opportunities during normal business hours.

Jackson Paper Manufacturing Company
Sylva,NC
NPDES Permit No.NCS000295
Summary of Visual Monitoring Results
Outfall 001 Outfall 002 Outfall 003 Outfall 004
go
> - o It'z°w E .g E _ > - — �'z° E .g E _ > - — �'z° E .g E _
° ° m �+ �+ °' c `o
Month Sample Date ° a _ " " o = > v «„ a � � o� �� C �� �� ; = - _ � _ - _ � _ -
Apr-17 4/3/17 Light Brown None 2 1 2 No No No No Clear None 1 1 1 No No No No Light Earthy 2 1 =2 No No No No Clear None 1 1 = 1 No No No No
Brown
Sep-17 9/16/17 Clear None 1 1 2 No No No No Clear one 1 1 1 No No No No B wn None 3 1 3 No No No No Clear one 1 1 1 No No No No
Dec-17 12/5/17 Light Grey None 2 1 2 No No No No Clear None 1 1 2 No No No No Light None 1 1 1 No No No No Light None 1 1 2 No No No No
Brown grey
Mar-18 3/6/18 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No Light None 2 1 2 No No No No Clear one 1 1 1 No No No No
Brown
May-18 5/16/18 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No Geed None 3 1 3 No No No No Clear one 1 1 1 No No No No
Sep-18 9/10/18 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No Light None 2 1 2 No No No No Clear None 1 2 1 No No No No
11 Brown
Dec-18 12/14/18 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No
Dec-18 12/20/18 Dingy None 3 1 3 No No No No - - - - - - - - - Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No
Feb-19 2/28/19 Mod Grey None 3 1 3 No No No No Clear None 1 1 1 No No No No Clear None 1 1 2 No No No No Clear None 1 1 1 No No No No
Apr-19 4/26/19 Mad Grey None 2 1 3 No No No No
May-19 "
Jun-19 6/7/19 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No Light None 2 1 2 Yes No No No Clear None 1 1 1 No No No No
Brown
Jul-19 7/22/19 Clear None 1 1 1 No No No No
Aug-19 8/27/19 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No Light None 2 1 2 No No No No Clear None 1 1 1 No No No No
Grey
Sep-19 "
Oct-19 10/16/19 Light None 1 1 1 No No No No
Grey
Noy-19 11/27/19 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No Light None 3 1 3 No No No No Clear None 1 1 1 No No No No
Grey
Dec-19 12/9/19 Clear None 1 1 1 No No No No
Jan-20 1/24/20 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No Light None 3 1 3 No No No No Clear None 1 1 1 No No No No
Brown
Feb-20 2/24/20 Light Earthy 2 1 2 No No No No
Brown
Mar-20 3/23/20 Light None 1 1 1 No No No No
Brow
Apr-20 4/23/20 Light None 2 2 2 No No No No
Brown
May-20 5/20/20 Light None 1 1 1 No No No No
Brown
Jun-20 6/23/20 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No Light None 2 1 2 No No No No Clear None 1 1 1 No No No No
Grey
Jul-20 7/23/20 Clear None 1 1 1 No No No No
Aug-20 EL
Sep-20 9/17/20 Clear None 1 1 1 No No No No Clear one 1 1 1 No No No No Light None 1 1 1 No No No No Clear None brown
1 1 1 No No No No
Dec-20 12/4/20 Light Grey None 3 1 3 No No No No Clear one 1 2 1 No No No No Clear None 1 1 1 No No No No Clear one 2 1 2 No No No No
Mar-21 3/16/21 Light Grey None 2 1 2 No No No No Clear one 1 1 1 No No No No Mod None 3 1 3 No No No No Clear None 1 1 1 No No No No
Brown
Apr-21
May-21 5/3/21 Clear one
1 1 1 No No No No
JUn-21 6/11/21 Clear one 1 1 1 No No No No Clear None 1 1 1 No No No No Brown None 2 2 2 No No No No Clear None 1 1 1 No No No No
lUl-21 *
Aug-21 8/4/21 Clear None 1 1 2 No No No No Clear None 1 1 1 No No No No B oewn None 3 2 3 No No No No Clear None 1 1 1 No No No No

Jackson Paper Manufacturing Company
Sylva,NC
NPDES Permit No.NCS000295
Summary of Visual Monitoring Results
Outfall 001 Outfall 002 Outfall 003 Outfall 004
go a
°�v v _ 3 t. °'�^v v _ 3
> - — �'z°w E .g E _ > - — �'z° E � E _ > - — K'z° E .g E _ > - z° E � E
o c c
o c m c i
Month Sample Date t 2 B 6 _ - — - —
Noy-21 11/4/21 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No Light None 1 1 1 No No No No Clear None 1 1 1 No No No No
Brown
Feb-22 2/3/22 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No BWn None 2 1 3 No No No No Clear one 1 1 1 No No No No
Mar-22 3/16/22 Light Grey None 2 1 2 No No No No Light None 1 1 2 No No No No
Brown
May-22 5/6/22 Light Grey jNone 1 1 No aN. N.
None 1 1 1 No No No No Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No
8/1/22 Clear 1 1 No None 1 1 1 No No No No Light None 2 1 2 No No No No Clear None 1 1 1 No No No No
B11/15/22 Clear 1 1 No None 1 1 2 No No No No Cleallo
Clear
4/14/23 Clear 1 1 No None 1 1 1 No No No No B oewn None 3 1 3 No No No No Clear None 1 1 1 No No No No

Jackson Paper Manufacturing Company
Sylva,NC
NPDES Permit No.NCS000295
Summary of Analytical Monitoring Results
Outfall 001 Outfall 002 Outfall 003 Outfall 004 Scott's Creek Pre-Mill Scott's Creek Post Mill
Rainfall TSS COD O&G Turbidity T55 COD O&G Turbidity T55 COD O&G Turbidity T55 COD O&G Turbidity T55 COD O&G Turbidity T55 COD O&G Turbidity
Month Sample Date inches Img/L) PN (mg/L) (mg/L) (NTU) (rug/L) PH (rug/L) Img/L) (NTU) (mg/L) PH
(mg/L) (mg/L) (NTU) (mg/L) PH (mg/L) (mg/L) (NTU) (mg/L) PH (mg/L) (mg/L) (NTU) (mg/L) PH
(rug/L) (mg/L) (NTU)
Apr-17 4/3/2017 0.30 107 1 8 1 447 ND N/A 14 7 36 1 NO N/A 5 1 8 55 ND N/A 149 8 68 NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Sep-17 9/6/2017 0.46 27 7 48 ND N/A 4 7 40 NO N/A 244 8 267 ND N/A 17 7 45 NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Dec-17 12/5/2017 0.48 61 8 ND ND N/A 26 7 NO NO N/A ND 8 47 ND N/A 84 7 90 NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Mar-18 3/6/2018 0.15 22 7 34 ND N/A NO 8 NO NO N/A 17 8 58 ND N/A 9 7 NO NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
May-18 5/16/2018 0.41 32 9 ND ND N/A 4 7 NO NO N/A 242 7 78 ND N/A NO 8 NO NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Sep-18 9/10/2018 0.56 35 8 31 ND N/A 62 7 63 NO N/A 5 8 33 ND N/A 99 7 35 NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Dec-18 12/14/2018 0.23 NO 7 NO NO N/A 10 7 52 ND N/A
Dec-18 12/20/2018 0.80 181 7 132 ND N/A 490 7 37 NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Feb-19 2/28/2019 0.01 125 7 197 ND N/A 8 7 NO NO N/A 14 7 255 ND N/A 28 6 41 NO N/A
Apr-19 4/26/2019 0.15 351 6.9 357 ND 45 25 6 ND ND 3 24 6 NO NO 4
Jun-19 6/7/2019 0.70 7 6 56 ND 7 3 7 NO NO 3 143 7 97 ND 275 8 6 NO NO 4 60 6 29 ND 30 72 6 31 NO 47
Jul-19 7/22/2019 0.46 17 6 ND ND 1 17 6 ND ND 2 27 6 63 NO 4
Aug-19 8/27/2019 0.37 27 7 ND ND 27 NO 7 NO NO ND 59 7 80 ND 83 6 7 NO NO 7 21 7 ND ND 16 23 7 NO NO 12
Sep-19
Oct-19 10/16/2019 0.06 13 8 ND ND 33 7 6 ND ND 7 10 7 NO NO 8
Nov-19 11/27/2019 0.63 14 6 ND ND 6 NO 7 ND ND ND 208 7 144 ND 262 24 6 NO ND 10 124 6 27 ND 63 146 6 29 NO 89
Dec-19 12/9/2019 0.28 13 7 61 ND 27 15 6 ND ND 6 17 6 NO NO 7
Jan-20 1/24/2020 0.38 64 7 25 ND 18 5 7 NO NO 5 216 7 200 ND 474 34 6 25 NO 16 12 6 ND ND 2 17 6 NO NO 7
Feb-20 2/24/2020 0.80 7 7 103 ND 30 7 6 ND ND 3 7 6 NO NO 3
Mar-20 3/23/2020 0.31 37 7 139 ND 65 179 6 ND ND 35 127 6 NO NO 45
Apr-20 4/23/2020 0.32 20 7 179 ND 53 27 6 ND ND 13 29 6 NO NO 14
May-20 5/20/2020 0.50 36 7 109 ND 83 24 7 ND ND 30 29 7 NO NO 12
Jun-20 6/23/2020 0.20 52 7 ND ND 4 3 7 NO NO 1 4 7 36 ND 7 74 7 36 NO 8 22 7 ND ND 3 49 7 NO NO 4
Jul-20 7/23/2020 0.20 3 7 ND ND 9 31 7 ND ND NO 81 7 NO NO 6
Aug-20
Sep-20 9/17/2020 0.69 38 7 ND ND 15 5 7 NO NO 19 44 7 74 ND 92 20 7 NO NO 17 79 7 28 ND 56 90 7 26 NO 63
Dec-20 12/4/2020 0.05 264 8 279 ND 136 58 7 NO NO 8 7 7 ND ND 28 101 7 119 NO 50 4 7 ND ND NO 3 5 NO NO 1
Mar-21 3/16/2021 0.40 61 7 45 ND 19 26 7 26 NO 18 200 7 163 ND 269 26 7 NO NO 13 185 7 56 ND 53 169 7 80 NO 81
Apr-21
May-21 5/3/2021 0.50 29 8 ND ND 18 56 8 ND ND 19 133 8 26 NO 42
Jun-21 6/11/2021 0.24 11 7 43 ND 16 13 8 108 NO 83 240 7 157 ND 351 3 7 NO ND 4 34 6 ND ND 23 37 7 NO NO 27
Jul-21
Aug-21 8/4/2021 0.45 61 7 42 ND 9 11 7 85 NO 36 480 7 249 ND 811 18 8 NO NO 8.9 140 6 50.8 ND 104 139 7 28 NO 88.3
Sep-21
Oct-21
Nov-21 11/4/2021 1 0.2 40 7 42 ND 15 5 7 NO NO 14.5 8.9 7 ND ND 13.3 86 6 60.6 NO 35.6 2.6 7 ND ND 1.4 3.1 7 NO NO 1.6
Dec-21
Jan-22
Feb-22 2/3/2022 0.8 47 6 39 ND 57 42 7 67 NO 23 202 7 165 ND 283 160 7 93 NO 125 145 6 42 ND 98 170 6 49 NO 105
Mar-22 3/16/2022 0.30 279 6 132 ND 97 NOT IN TIER 2 33 7 137 ND 49 NOT IN TIER 2 10 7 ND ND 4 13 7 NO NO 4
Apr-22
May-22 5/6/2022 0.50 169 8 295 ND 34 39 7 33 ND 4 3 7 ND ND 4 92 7 51 NO 19 16 6 ND ND 2 66 6 33 NO 7
Jun-22
Jul-22
Aug-22 8/1/2022 0.50 20 8 ND ND 23 21 7 ND ND 12 138 7 150 ND 52 11 8 27 ND 17 17 7 ND ND 4 20 7 ND ND 4

Jackson Paper Manufacturing Company
Sylva,NC
NPDES Permit No.NCSOOO295
Summary of Analytical Monitoring Results
Outfall 001 Outfall 002 Outfall 003 Outfall 004 Scott's Creek Pre-Mill Scott's Creek Post Mill
Rainfall TSS COD O&G Turbidity T55 COD O&G Turbidity T55 COD O&G Turbidity T55 COD O&G Turbidity T55 COD O&G Turbidity T55 COD O&G Turbidity
Month Sample Date inches (mg/L) PR (mg/L) (mg/L) (NTU) (mg/L) PR (mg/L) (mg/L) (NTU) (mg/L) PR (mg/L) (mg/L) (NTU) (mg/L) PR (mg/L) (mg/L) (NTU( (mg/L) PR (mg/L) (mg/L) (NTU) (mg/L) PR (mg/L) (mg/L) (NTU)
Sep-22
Oct-22
Nov-22 11/15/2022 0.90 131 8 66 ND 110 102 6 73 ND 57 6 8 45 ND 10 123 8 90 ND 8 4 6 ND ND 4 10 6 ND NO 7
Dec-22
Jan-23
Feb-23
Mar-23
Apr-23 4/14/2023 0.65 51 7 31 1 ND 20 1 34 7 47 ND 1 59 1 364 1 7 1 256 1 ND 1 645 1 5 1 8 1 28 1 NO 6 14 7 ND ND 3 1 21 1 7 1 ND PEP]
May-23
Notes
NO=Non detect
N/A=not tested
*=No opportunities during normal business hours to collect samples during this month.
Cells highlighted grey indicate testing was not completed for this outfall,either because it was not subject to the Tier 2 schedule,or because there were no testing opportunities during normal business hours.

�T1F STATE a,
_psi' l�lj I
ROY COOPER 5
Governor t
C
MICHAEL S.REGAN z
Secretary ,4irui
BRIAN WRENN NORTH CAROLINA
Acting Director Environmental Quality
August 31, 2020
Jackson Paper Manufacturing Company
Attention: Keisha Bridges
Post Office Box 667
Sylva, North Carolina 28779
Subject: Compliance Evaluation Inspection
Individual Stormwater Permit: NCS000295
Jackson County, North Carolina
Dear Ms. Bridges:
Enclosed please find a copy of the Compliance Evaluation Inspection Report for the
inspection I conducted at the subject facility on August 13, 2020.
The report should be self-explanatory; however, should you have any questions
concerning this report, please do not hesitate to contact me at [phone] or by email
at [e-mail].
Sincer ,
Isaiah Reed, CPSW , CEPSCI, MS4CECI
Environmental Specialist
Land Quality Section
Enclosure: Inspection Report
�� North Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources
Asheville Regional Office E 2090 U.S.Highway 70 I Swannanoa,North Carolina 28778
NORTH CAaourun
Oepann[entoF Fnvironmenla! ua11$ 828.296.4500

Compliance Inspection Re Dort
Permit:NCS000295 Effective: 03/01/17 Expiration: 02/28/22 Owner: Jackson Paper Manufacturing Company
SOC: Effective: Expiration: Facility: Sylva plant
County:Jackson PO Box 667
Region: Asheville
Sylva NC 28779
Contact Person:Kiesha Bridges Title: Phone:[phone] Ext.226
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 08/13/2020 Entry Time 10:30AM Exit Time: 12:00PM
Primary Inspector:Isaiah L Reed Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: 0 Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCS000295 Owner-Facility:Jackson Paper Manufacturing Company
Inspection Date: 08/13/2020 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On August 13, 2020 this facility was inspected for compliance. I met with Keisha Bridges on site. During the inspection, the
following items were discussed:
1)The housekeeping in the rear of the facility has been greatly improved. However, I would strongly recommend that the
permittee continue to re-evaluate and improve the materials handling practices on site to reduce stormwater contamination.
2)Additional containment structures have been added to provide for better handling of ash material on site.
3)A"basement area"on site is functioning as stormwater retention. Ms. Bridges described that this basement area may be
demolished in the future. It is my recommendation that some consideration be given to the possible use of this area as
stormwater storage in the future.
Issues described in the previous inspection report have been resolved.
if you have any questions, please contact this office at(828)296-4614.
Page 2 of 3

Permit: NCS000295 Owner-Facility:Jackson Paper Manufacturing Company
Inspection Date: 08/13/2020 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Page 3 of 3

sq STATf o,,
ROY COOPER
Governor
C
MICHAEL S.REGAN `' ti
Secretary
BRIAN WRENN NORTH CAROLINA
Acting Director Environmental Quality
February 25, 2020
Jackson Paper Manufacturing Company
Attention: Keisha Bridges
Post Office Box 667
Sylva, North Carolina 28779
Subject: Compliance Evaluation Inspection
Individual Stormwater Permit: NCS000295
Jackson County, North Carolina
Dear Ms. Bridges:
Enclosed please find a copy of the Compliance Evaluation Inspection Report for the
inspection I conducted at the subject facility on February 19, 2020.
The report should be self-explanatory; however, should you have any questions
concerning this report, please do not hesitate to contact me at [phone] or by email
at [e-mail].
Sinc y,
Isaiah Reed, CPSWQ, CEPSCI, M54CECI
Environmental Specialist
Land Quality Section
Enclosure: Inspection Report
DNorth Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources
EQ7> Asheville Regional Office j 2090 U.S.Highway 70 1 Swannanoa,North Carolina 28778
Naarri craouw, �
oepenmentorftimnmenlaluual y 828.296.4500

Compliance Inspection Report
Permit: NCS000295 Effective: 03/01/17 Expiration: 02/28/22 Owner: Jackson Paper Manufacturing Company
SOC: Effective: Expiration: Facility: Sylva plant
County:Jackson PO Box 667
Region: Asheville
Sylva NC 28779
Contact Person: Kiesha Bridges Title: Phone: [phone] Ext.226
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 02/19/2020 Entry Time: 10:45AM Exit Time: 12:15PM
Primary Inspector: Isaiah I-Reed Phone: [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: NCS000295 Owner-Facility:Jackson Paper Manufacturing Company
Inspection Date: 0 211 9/2 0 20 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On February 19, 2020 this facility was inspected for compliance. I met with Keisha Bridges on site. During the inspection,
an excessive amount of debris and waste from the industrial process was observed to be accumulating around the exterior of
the facility.The main source of this debris was an area where waste material is loaded on to waiting truck and shipped.
Allowing this material to continue to accumulate in and around the stormwater conveyances is in violation of Part 111, Section
A of the Individual Stormwater Permit.The permittee is directed to address the accumulation of pollutants around the facility.
This facility will be re-inspected on or after March 31,2020. If the above issue has not been addressed,further action will be
taken.
If you have any questions,please contact this office at(828)296-4614
Page 2 of 3

Permit: NCS000295 Owner-Facility:Jackson Paper Manufacturing Company
Inspection Date: 0211 912020 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? 0 ❑ ❑ ❑
#Does the Plan include a General Location(USGS)map? E ❑ ❑ ❑
#Does the Plan include a"Narrative Description of Practices"? E ❑ ❑ ❑
#Does the Plan include a detailed site map including outfall locations and drainage areas? 0 ❑ ❑ ❑
#Does the Plan include a list of significant spills occurring during the past 3 years? 0 ❑ ❑ ❑
#Has the facility evaluated feasible alternatives to current practices? 0 ❑ ❑ ❑
#Does the facility provide all necessary secondary containment? 0 ❑ ❑ ❑
#Does the Plan include a BMP summary? N ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan(SPRP)? 0 ❑ ❑ ❑
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? 0 ❑ ❑ ❑
#Does the facility provide and document Employee Training? N ❑ ❑ ❑
#Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑
#Is the Plan reviewed and updated annually? E ❑ ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? N ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? ❑ ■ ❑ ❑
Comment: Preventative maintenance and good house-keeping practices have resulted in an excessive
amount of debris and waste from the industrial process to be accumulating around the exterior
of the facility.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? ■ ❑ ❑ ❑
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:
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? ❑ ❑ ❑ ❑
Comment:
Page 3 of 3

6/2/23, 10:20 AM 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
JACKSON PAPER MANUFACTURING COMPANY
Information
Sosld: 0351551
Status: Current-Active O
Date Formed: 9/9/1994
Citizenship: Foreign
State of Incorporation: DE
Fiscal Month: December
Annual Report Due Date: April 15th
Currentgnnual Report Status:
Registered Agent: CT Corporation System
Addresses
Mailing Principal Office Reg Office
152 West Main Street 152 West Main Street 160 Mine Lake Ct Ste 200
Sylva, NC 28779-2928 Sylva, NC 28779-2928 Raleigh, NC 27615
Reg Mailing
160 Mine Lake Ct Ste 200
Raleigh, NC 27615
Off icers
https://www.sosnc.gov/online services/search/Business_Registration_Results 1/2

6/2/23, 10:20 AM North Carolina Secretary of State Search Results
Chief Financial Officer President
Tammy Francis Lemuel Carr Tyndall
152 West Main Street 152 West Main Street
Sylva NC 28779 Sylva NC 28779
Stock
https://www.sosnc.gov/onIine_services/search/Business_Registration_ResuIts 2/2

o Jackson Paper Mfg. 152 W Main St,
9USIAIN/lG-L 3NSINLSS -mF rii- ��:TN ii Sylva, NC 28779
September 1, 2022
Brianna Young
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ / Division of Energy, Mineral, and Land Resources (DEMLR)
Subject: NPDES Stormwater Individual Permit, Updated Statement of Significant
Changes
Jackson Paper Manufacturing Company- Sylva Plant
Permit No. NCS000295
Dear Ms. Young,
Jackson Paper Manufacturing Company - Sylva Plant (Jackson Paper) is submitting
this updated statement of significant changes at the facility. A renewal application
was submitted for Permit NCS000295 on August 26, 2021. Per your email on
August 29, 2022, the current permit expired on February 28, 2022 and due to a
backlog of other permits is scheduled for renewal review in late 2023. Currently
there are four stormwater discharge outfalls designated as Outfall 001, Outfall 002,
Outfall 003, and Outfall 004. Outfall 001 is located in the vicinity of the
southeastern property boundary with West Main Street. Outfall 002 is located in the
vicinity of the southern property boundary with West Main Street. Outfall 003 is
located in the southeastern portion of the site adjacent to Scott's Creek. The
outfalls are locations where stormwater ultimately exits the site, and include
manholes, pipes, ditches, junction boxes, catch basins, swales, etc.
We will be adding a fifth outfall near the northern end of the property. The land
area is approximately 4 acres and will be used to store tractor trailers. Latitude of
planned Outfall 005: 35.37828, Longitude of planned Outfall 005: -83.21600. The
town of Sylva has an existing stormwater pipe in this area (Chipper Curve Road)
that drains onto a portion of the property. We will install 2 small catch basins and
tie into a portion of the town's stormwater pipe. The pipe will go underneath the
railroad tracks and discharge into Scott's Creek. There will be no industrial activity
in this area. It will be a graveled parking area solely used to store tractor trailers.
We plan to have the discharge pipe and additional Outfall installed by November of
L� (828) 586-5534 @ [e-mail] ® JacksonPaper.net

Jackson Paper Mfg. 152 W Main St,
SUSTAINABLE BUSINESS FOR THE FUTURE Sylva, NC 28779
2022. Once installed, we will perform quarterly analytical monitoring and quarterly
qualitative monitoring at Outfall 005.
If you have any questions, please contact me at 828-586-5534 ext. 226 or
kbridgesO)jacksonpaper.net.
Sincerely,
Kiesha Bridges
Manager of Safety, Environmental & Technical
L� (828) 586-5534 @ [e-mail] ® JacksonPaper.net

Young, Brianna A
From: Kiesha Bridges <[e-mail]>
Sent: Thursday, September 1, 2022 11:29 AM
To: Young, Brianna A; Georgoulias, Bethany
Subject: RE: [External] Jackson Paper NPDES Permit NCS000295 Question
Attachments: Jackson Paper Permit No. NCS000295 Updated Statement of Significant Changes.docx
Importance: High
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Brianna,
I have updated our statement of significant changes in the attached letter. Thank you
for your help.
Sincerely,
Kiesha Bridges
Manager of Safety, Environmental & Technical
cc!�111 Jackson Paper Mfg.
152 W. Main Street, Sylva, NC 28779
O. 828-586-5534 Ext. 226
F. 828-631-3314
From:Young, Brianna A<[e-mail]>
Sent:Wednesday,August 31, 2022 12:08 PM
To: Kiesha Bridges<KBridges@jacksonpa per.net>; Georgoulias, Bethany<[e-mail]>
Subject: RE: [External] Jackson Paper NPDES Permit NCS000295 Question
Kiesha,
As a renewal application has already been submitted for the permit, at this time we will just need an updated statement
of significant changes at the facility (with the total number of outfalls and outfall coordinates)to amend the existing
permit application.The facility may continue operating under their existing permit until the renewal is addressed in
2023.The facility will be responsible for reporting data to eDMR for all outfalls (including any new outfalls). Please let
me know if you have any additional questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
1

[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: Kiesha Bridges<KBridges@iackson paper.net>
Sent: Wednesday,August 31, 2022 9:41 AM
To:Young, Brianna A<[e-mail]>; Georgoulias, Bethany<[e-mail]>
Subject: RE: [External] Jackson Paper NPDES Permit NCS000295 Question
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning, Brianna,
Can you send me a link to the specific forms we will need to complete to do a permit
modification?
Thank you,
Kiesha Bridges
Manager of Safety, Environmental & Technical
Jackson Paper Mfg.
152 W. Main Street, Sylva, NC 28779
O. 828-586-5534 Ext. 226
F. 828-631-3314
From:Young, Brianna A<[e-mail]>
Sent: Monday,August 29, 2022 12:10 PM
To: Kiesha Bridges<KBridges@iackson paper.net>; Georgoulias, Bethany<[e-mail]>
Subject: RE: [External] Jackson Paper NPDES Permit NCS000295 Question
Hello Kiesha,
Based on the information provided in your email, I concur with Bethany that this sounds like a modification of the
existing individual permit NCS000295 and no additional general permit coverage is needed. How soon would you need
the permit modification by?The current permit expired on February 28, 2022, but due to a backlog of other permits
ahead of this one, NCS000295 is not on my schedule for renewal review until late 2023 (although this schedule is subject
to change). Is this something that could wait and be handled with the current schedule of permit renewal review, or are
you looking to make these changes sooner?
2

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: Kiesha Bridges<KBridRes@iackson paper.net>
Sent: Monday,August 29, 2022 11:24 AM
To: Georgoulias, Bethany<[e-mail]>
Cc:Young, Brianna A<[e-mail]>
Subject: RE: [External] Jackson Paper NPDES Permit NCS000295 Question
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Thank you, Bethany.
Kiesha Bridges
Manager of Safety, Environmental & Technical
Jackson Paper Mfg.
$41i:r%+INA{51.1 114!y:4L.!1!i 1 !}1{ IIII )11.kiM
152 W. Main Street, Sylva, NC 28779
O. 828-586-5534 Ext. 226
F. 828-631-3314
From: Georgoulias, Bethany<[e-mail]>
Sent: Monday,August 29, 2022 11:21 AM
To: Kiesha Bridges<KBridRes@iackson paper.net>
Cc:Young, Brianna A<[e-mail]>
Subject: RE: [External] Jackson Paper NPDES Permit NCS000295 Question
Hi, Kiesha,
3

I'm going to put you in touch with Brianna Young, our Individual Permits coordinator. At first read, it sounds like this is
probably only a modification for your NCS000295 permit. Usually another separate General Permit is not necessary for
something like this, but Brianna can help give you more guidance.
Best regards,
Bethany Georgoulias (she/her)
Environmental Engineer
Stormwater Program,Division of Energy,Mineral, and Land Resources
N.C.Department of Environmental Quality
919 707 3641 office
[e-mail]
512 N. Salisbury Street, Raleigh,NC 27604 (location)
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
Website: htt12://deq.nc.gov lab out/divisions/energy-mineral-land-resources/stormwater
NpfT i i CAF�n Y
Rsplllnw.t W Enbanw�nhl O.Wl�
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.To accommodate these staffing changes, all DEQ office locations are limiting public access to
appointments only. 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: Kiesha Bridges<KBridges@iackson paper.net>
Sent: Monday,August 29, 2022 11:14 AM
To: Georgoulias, Bethany<[e-mail]>
Subject: [External] Jackson Paper NPDES Permit NCS000295 Question
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning Bethany,
I'm reaching out to you today regarding Jackson Paper's NPDES Stormwater Permit
NCS000295. Jackson Paper is located at 152 West Main Street, Sylva NC. I'm looking for
guidance regarding what our next steps need be to ensure we're doing all that is
required.
We currently have 4 stormwater outfalls included in our permit that we are required to
monitor. Recently, we have done some clean up improvement work on a portion of the
northern end of our property. We then plan to store some tractor trailers in this area.
The town of Sylva has a stormwater pipe in this area (Chipper Curve Road) that drains
onto this portion of our property. We plan to install a couple of small catch basins and tie
4

into a portion of the town's stormwater pipe. After the 2nd catch basin, the stormwater
pipe will go underneath the railroad tracks, and discharge into Scott's Creek. The
railroad has given us permission to do this. Before proceeding, we wanted to contact
DEQ to see what the requirements were to move forward. Our initial plan is to submit a
NCG080000 Transit Notice of Intent since the only activity in this area will be storage of
tractor trailers. If the discharge point will be considered an additional outfall, I assume
we will also need to request a permit modification.
Your guidance would be greatly appreciated. My apologies if you are not the appropriate
contact for this but hoping maybe you could point me in the right direction. I can be
reached by email or at the number below at your convenience.
Thank you,
Kiesha Bridges
Manager of Safety, Environmental & Technical
Jackson Paper Mfg.
152 W. Main Street, Sylva, NC 28779
O. 828-586-5534 Ext. 226
F. 828-631-3314
This message is intended only for the individual or entity to which it is addressed and contains information that is
proprietary to The Jackson Paper Mfg. Company and/or its affiliates, or may be otherwise confidential. If the reader of
this message is not the intended recipient, or the employee agent responsible for delivering the message to the
intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify the sender immediately by return e-
mail and delete this message from your computer.
This message is intended only for the individual or entity to which it is addressed and contains information that is
proprietary to The Jackson Paper Mfg. Company and/or its affiliates, or may be otherwise confidential. If the reader of
this message is not the intended recipient, or the employee agent responsible for delivering the message to the
intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify the sender immediately by return e-
mail and delete this message from your computer.
This message is intended only for the individual or entity to which it is addressed and contains information that is
proprietary to The Jackson Paper Mfg. Company and/or its affiliates, or may be otherwise confidential. If the reader of
this message is not the intended recipient, or the employee agent responsible for delivering the message to the
intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify the sender immediately by return e-
mail and delete this message from your computer.
This message is intended only for the individual or entity to which it is addressed and contains information that is
proprietary to The Jackson Paper Mfg. Company and/or its affiliates, or may be otherwise confidential. If the reader of
this message is not the intended recipient, or the employee agent responsible for delivering the message to the
intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify the sender immediately by return e-
mail and delete this message from your computer.
This message is intended only for the individual or entity to which it is addressed and contains information that is
proprietary to The Jackson Paper Mfg. Company and/or its affiliates, or may be otherwise confidential. If the reader of
this message is not the intended recipient, or the employee agent responsible for delivering the message to the
5

intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify the sender immediately by return e-
mail and delete this message from your computer.
This message is intended only for the individual or entity to which it is addressed and contains information that is
proprietary to The Jackson Paper Mfg. Company and/or its affiliates, or may be otherwise confidential. If the reader of
this message is not the intended recipient, or the employee agent responsible for delivering the message to the
intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify the sender immediately by return e-
mail and delete this message from your computer.
This message is intended only for the individual or entity to which it is addressed and contains information that is
proprietary to The Jackson Paper Mfg. Company and/or its affiliates, or may be otherwise confidential. If the reader of
this message is not the intended recipient, or the employee agent responsible for delivering the message to the
intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify the sender immediately by return e-
mail and delete this message from your computer.
6

JACKSON PAPER
MANUFACTURING
August 26, 2021
Suzanne McCoy
1612 Mail Service Center
Raleigh, NC 27699-1612
Subject: NPDES Stormwater Individual Permit Renewal Application
Jackson Paper Manufacturing Company— Sylva Plant
Permit No. NCS000295
Dear Ms. McCoy:
Jackson Paper Manufacturing Company— Sylva Plant (Jackson Paper) is submitting this renewal
application for coverage under the permit. As per Section B.1. of the permit, the permittee must submit
forms and fees as required by the agency no later than 180 days prior to the expiration date. Permit
NCS000295 expires February 28, 2022. This application includes the NCS Renewal Forms Package
and required supporting documentation. There have been no changes to the facility or activities since
issuance of the permit.
If you have any questions about the included information, please contact me at 828.586.5534, Ext 226
or [e-mail], or Rachel Velthuisen of TRC Environmental Corporation (TRC) at
919.671.0032 or [e-mail].
Sincerely,
GA 1` 1jc�
Kiesha Bridges
Manager of Safety, Environmental &Technical
Attachments
cc: Rachel Velthuisen, TRC
NORTH CAROLINA'S LARGEST RECYCLED PAPER PRODUCER
152 WEST MAIN STREET® PO Box 6670 SYLVA. NC 28779 TEL[phone] FAX[phone]

Permit Coverage
Renewal Application Form
_ National Pollutant Discharge Elimination System NPDES Permit Number
Environmental
Stormwater Individual Permit NCS 000295
Quality
Please 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 mailed ���...+++
Owner/Organization Name: Jackson Paper Manufacturing Company ���'�'��
Owner Contact: Carr Tyndall WWW
Mailing Address: 152 West Main Street,Sylva,NC 28779 O 2021
152 West Main Street,Sylva,NC 28779 p,UG LUL
Phone Number: 828-586-5534
Fax Number: p�NR-LAi�p QUAI-'�`�0
E-mail address: [e-mail] STORMWATtRPERM
Facility Information
Facility Name: Jackson Paper Manufacturing Company
Facility Physical Address: 152 West Main Street
Sylva,NC 28779
Facility Contact: Kiesha Bridges
Mailing Address: 152 West Main Street
Sylva,NC 28779
Phone Number: 828-586-5534 EXT 226
Fax Number:
E-mail address: [e-mail]
Permit Information
Permit Contact: Kiesha Bridges
Mailing Address: 152 West Main Street
Sylva,NC 28779
Phone Number: 828-586-5534 EXT 226
Fax Number:
E-mail address: [e-mail]
Discharge Information
Receiving Stream: Scott creek
Stream Class: C;Tr
Basin: Little Tennessee
Sub-Basin:
Number of Outfalls: 4
Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
No changes
CERTIFICATION
I certify that I am familiar with the i formation contained in the application and that to the best of my knowledge and belief
such informatio true et d accurate.
Signature �-^� Date $&L/"z
Carr Tyndall President/Chief Operating Officer
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

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
CT l. 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.
CT 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.
CT 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.
CT 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.
CT 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.
CT 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)

APPROXIMATELY
100 FOOT BUFFER ` ♦
i \ CATTAILS
\ b ` ♦ UNNAMED
SPRING
r
4 b %
f ~ ;?
SILT
r
FENCING C:C> SILT
AND CAT E----—---— —--
FENCING
TAILS AND CAT
I �
TAILS
© 9
' — TRUCKSCALE Q
i 13� ®
16
% 11 RECYCLE
3 BUILDING I
RECEIVING �
j a PLATFORM
' BOILER OBSOLETE MATERIALS f
—••--•f. G�Outtall BUILDING RECYCLE BALE STORAGE BUILDING
1. ®_ �i•�._�. _
STORAGE BUILDING
(36.374888, ^---.._....—..-
a3217764)
RAILROAD SHIPPING DOCK /Y I
S ? APPROXIMATE SITE BOUNDARY 1
o f
j SHIPPING AND O 1 97, ,ER Potentially Exposed Material Locations:
FINISHINGPAPER MACHINE BUILDING SWAREHOUSE a ,' 1.Trash Dumpster
outran
2.Delivery Truck Loading/Unloading Docks
.._..___.• C �CREEK
3.Parking Area Between Paper Machine Building and WWT
-83.217178 -_'r"'"—"-� gyp..� 5 t'
1 CLARIFIERS LEGEND 4.Scrap Metal Dumpster
5.Kerosene Storage Tank
4
outtae®
' 2 6.Scrap Metal Storage
(36.374819.I y t CATCH BASIN i— RAILROAD 7.Dryer Can Bearing Storage
-8321W52)'I �—___ 8.Plastic Baling Area
- .
♦ ♦ —�'� OUTFALL WATER SYSTEM 9.Delivery Area
L) d 10.Cardboard Storage Area
RUN-OFF FLOW DIRECTION SW001 11.Gasoline and Diesel Fuel ASTs
�P 4 12.Truck Dump Hydraulic Oil Storage Tank
vk (36.376800, — —-03.216763; DRAINAGE PIPE SWO02 13.Plastic Baler Hydraulic Tank Oil Tank
-
4 14.Sawdust Piles
U-DRAIN SWO03 15.Ash Pad
d� GGEgS 16.Ash Pond and Ash Pit
17.Scrap Materials Boneyard
E j RUN ON STORM WATER CULVERT SWO04
DRAINAGEAREA' �DRAI NAGE AREA PERCENT
Na. OUTFACE
�`` �': SWALE DRAINAGE DITCH (ACRES) IMPERVIOUS
j
E 'r I sW001 1.69 84
o II SWO02 5.43 26
S WO03 20.45 39
I
- � IV SWD04 I 1.62 100
STORM WATER FLOW AND POTENTIALLY EXPOSED MATERIALS MAP
ENVIRON Engineers of North Carolina, PC Jackson Paper
152 West Main Street
DRAFTED BY:HDT DATE:5/1/2017 - SylVa, North Carolina IM

Jackson Paper Manufacturing Company
Sylva, NC
NPDES Permit No. NCS000295
Summary of Analytical Monitoring Results
Outfall 001 Outfall 002 Outfall 003
Rainfall TSS COD O&G Turbidity TSS COD 0&G Turbidity TSS COD O&G Turbidity
Month Sample Date (inches) (mg/L) pH (mg/L) (mg/L) (NTU) (mg/L) pH (mg/L) (mg/L) (NTU) (mg/L) pH (mg/L) (mg/L) (NTU)
Apr-17 4/3/2017 0.30 107 8 447 ND N/A 14 7 36 ND N/A 5 8 55 ND N/A
Sep-17 9/6/2017 0.46 27 7 48 ND N/A 4 7 40 ND N/A 244 8 267 ND N/A
Dec-17 12/5/2017 0.48 61 8 ND ND N/A 26 7 ND ND N/A ND 8 47 ND N/A
Mar-18 3/6/2018 0.15 22 7 34 ND N/A ND 8 ND ND N/A 17 8 58 ND N/A
May-18 5/16/2018 0.41 32 9 ND ND N/A 4 7 ND ND N/A 242 7 78 ND N/A
Sep-18 9/10/2018 0.56 35 8 31 ND N/A 62 7 63 ND N/A 5 8 33 ND N/A
Dec-18 12/14/2018 0.23 ND 7 ND ND N/A 10 7 52 ND N/A
Dec-18 12/20/2018 0.80 181 7 132 ND N/A
Feb-19 2/28/2019 0.01 125 7 197 ND N/A 8 7 ND ND N/A 14 7 255 ND N/A
Apr-19 4/26/2019 0.15 351 6.9 357 ND 45
Jun-19 6/7/2019 0.70 7 6 56 ND 7 3 7 ND ND 3 143 7 97 ND 275
Jul-19 7/22/2019 0.46 17 6 ND ND 1
Aug-19 8/27/2019 0.37 27 7 ND ND 27 ND 7 ND ND ND 59 7 80 ND 83
Sep-19
Oct-19 10/16/2019 0.06 13 8 ND ND 33
Nov-19 11/27/2019 0.63 14 6 ND ND 6 ND 7 ND ND ND 208 7 144 ND 262
Dec-19 12/9/2019 0.28 13 7 61 ND 27
Jan-20 1/24/2020 0.38 64 7 25 ND 18 5 7 ND ND 5 216 7 200 ND 474
Feb-20 2/24/2020 0.80 7 7 103 ND 10
Mar-20 3/23/2020 0.31 37 7 139 ND 65
Apr-20 4/23/2020 0.32 20 7 179 ND 53
May-20 5/20/2020 0.50 36 7 109 ND 83
Jun-20 6/23/2020 0.20 52 7 ND ND 4 3 7 ND ND 1 4 7 36 ND 7
Jul-20 7/23/2020 0.20 3 7 ND ND 9
Aug-20
Sep-20 9/17/2020 0.69 38 7 ND ND 15 5 7 ND ND 19 44 7 74 ND 92
Dec-20 12/4/2020 0.05 264 8 279 NO 136 58 7 ND ND 8 7 7 ND ND 28
Mar-21 3/16/2021 0.40 61 7 45 ND 19 26 7 26 ND 18 200 7 163 ND 269
Apr-21
May-21 5/3/2021 0.50 29 8 ND ND 18
Jun-21 6/11/2021 0.24 11 7 43 ND 16 13 8 108 ND 83 240 1 7 157 ND 351
Jul-21
Aug-21 8/4/2021 0.45 61 7 42 ND 9 11 7 85 ND 36 480 1 7 249 ND 811
Notes
ND=Non detect
N/A=not tested
*=No opportunities during normal business hours to collect samples during this month.
Cells highlighted grey indicate testing was not completed for this outfall,either because it was not subject to the Tier 2 schedule,or because there were no testing opportunities during normal business hours.

Jackson Paper Manufacturing Company
Sylva, NC
NPDES Permit No. NCS000295
Summary of Analytical Monitoring Results
Outfall 004 Scott's Creek Pre-Mill Scott's Creek Post Mill
Rainfall TSS COD 0&G Turbidity TSS COD O&G Turbidity TSS COD O&G Turbidity
Month Sample Date (inches) (mg/L) PH (mg/L) (mg/L) (NTU) (mg/L) PH (mg/L) (mg/L) (NTU) (mg/L) PH (mg/L) (mg/L) (NTU)
Apr-17 4/3/2017 0.30 149 8 68 ND N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Sep-17 9/6/2017 0.46 17 7 45 ND N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Dec-17 12/5/2017 0.48 84 7 90 ND N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Mar-18 3/6/2018 0.15 9 7 NO ND N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
May-18 5/16/2018 0.41 ND 8 NO ND N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Sep-18 9/10/2018 0.56 99 7 35 I ND I N/A N/A I N/A N/A N/A N/A N/A N/A N/A N/A N/A
Dec-18 12/14/2018 0.23
Dec-18 12/20/2018 0.80 490 7 37 NO N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A
Feb-19 2/28/2019 0.01 28 6 41 ND N/A
Apr-19 4/26/2019 0.15 25 6 ND ND 3 24 6 ND NO 4
Jun-19 6/7/2019 0.70 8 6 ND ND 4 60 6 29 ND 30 72 6 31 ND 47
Jul-19 7/22/2019 0.46 17 6 ND ND 2 27 6 63 NO 4
Aug-19 8/27/2019 0.37 6 7 ND ND 7 21 7 ND ND 16 23 7 ND ND 12
Sep-19
Oct-19 10/16/2019 0.06 7 6 NO ND 7 10 7 NO ND 8
Nov-19 11/27/2019 0.63 24 6 NO ND 10 124 6 27 ND 63 146 6 29 ND 89
Dec-19 12/9/2019 0.28 15 6 ND ND 6 17 6 ND ND 7
Jan-20 1/24/2020 0.38 34 6 25 ND 16 12 6 ND ND 2 17 6 ND NO 7
Feb-20 2/24/2020 0.80 11 7 6 ND ND 3 7 6 ND NO 3
Mar-20 3/23/2020 0.31 179 6 ND ND 35 127 6 ND ND 45
Apr-20 4/23/2020 0.32 27 6 ND ND 13 29 6 ND ND 14
May-20 5/20/2020 0.50 24 7 ND NO 10 29 7 ND ND 12
Jun-20 6/23/2020 0.20 74 7 36 ND 8 22 7 ND ND 3 49 7 ND ND 4
Jul-20 7/23/2020 0.20 31 7 NO ND NO 81 7 NO ND 6
Aug-20
Sep-20 9/17/2020 0.69 20 1 7 1 ND NO 17 79 7 28 ND 56 90 7 26 ND 63
Dec-20 12/4/2020 0.05 101 7 119 ND 50 4 7 ND ND I ND 3 5 ND I ND I 1
Mar-21 3/16/2021 0.40 26 7 ND ND 13 185 7 56 ND 53 169 7 80 NO 81
Apr-21
May-21 5/3/2021 0.50 56 8 ND ND 19 133 8 26 ND 42
Jun-21 6/11/2021 0.24 3 7 ND ND 4 34 6 ND ND 23 37 7 ND ND 27
Jul-21
Aug-21 8/4/2021 0.45 18 1 8 ND ND 8.9 140 6 50.8 ND 104 139 7 28 ND 88.3
Notes
NO=Non detect
N/A=not tested
*=No opportunities during normal business hours to collect samples during this month.
Cells highlighted grey indicate testing was not completed for this outfall,either because it was not subject to the Tier 2 schedule,or because there were no testing opportunities during normal business hours.

Jackson Paper Manufacturing Company
Sylva, NC
NPDES Permit No. NCS000295
Summary of Visual Monitoring Results
Outfal 1001 Outfall 002
> O CO > O C
w v
° a v o
° 01 4 3
a �' w v o
V v°i w` ° v u N > w ° o.
`o ` u °Sample 'o z w E on c=
E
o > z N z 3
Month Date " o - - -
u o u �n �° �' ,° o w o o u 'o u �, �° :,' �; 3 �� LL o
Light
Apr-17 4/3/17 Brown None 2 1 2 No No No No Clear None 1 1 1 No No No No
Sep-17 9/16/17 Clear None 1 1 2 No No No No Clear None 1 1 1 No No No No
OR t
Dec-17 1 12/5/17 Grey None 2 1 2 No No No No Clear None 1 1 2 No No No No
Mar-18 3/6/18 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No
May-18 5/16/18 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No
Sep-18 9/10/18 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No
Dec-18 12/14/18 Clear None 1 1 1 No No No No
Dec-18 12/20/18 Dingy None 3 1 3 No No No No
Med
Feb-19 2/28/19 Grey None 3 1 1 3 No No No No Clear None 1 1 1 No No No No
Jun-19 6/7/19 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No
Aug-19 8/27/19 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No
Nov-19 11/27/19 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No
Jan-20 1/24/20 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No
Jun-20 6/23/20 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No
Sep-20 9/17/20 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No
Light
Dec-20 12/4/20 Grey None 3 1 3 No No No No Clear None 1 2 1 No No No No
Light
Mar-21 3/16/21 Grey None 2 1 2 No No No No Clear None 1 1 1 No No No No
Jun-21 6/11/21 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No
Aug-21 8/4/21 1 Clear None 1 1 1 2 No No I No No Clear I None 1 1 1 No No No No

Jackson Paper Manufacturing Company
Sylva, NC
NPDES Permit No. NCS000295
Summary of Visual Monitoring Results
Outfall 003 Outfall 004
> s s
o o
> o o > o o
o
u w u° ^ 'o wn aN N
Sample do E> z z E aE a oDate to — n
O � u u —O w o Month ooA `o
O v,
Light
Apr-17 4/3/17 Brown Earthy 2 1 2 No No No No Clear None 1 1 1 No No No No
Me
Sep-17 9/16/17 Brown None 3 1 3 No No No No Clear None 1 1 1 No No No No
Lig t Light
Dec-17 12/5/17 Brown None 1 1 1 No No No No grey None 1 1 2 No No No No
Lig t
Mar-18 3/6/18 Brown None 2 1 2 No No No No Clear None 1 1 1 No No No No
Med
Ma -18 5/16/18 Grey None 3 1 3 No No No No Clear None 1 1 1 No No No No
Light
Se -18 9/10/18 Brown None 2 1 2 No No No No Clear None 1 2 1 No No No No
Dec-18 12/14/18 - - - - - - - - - Clear None 1 1 1 No No No No
Dec-18 12/20/18 Clear None 1 1 1 No No No No Clear None 1 1 1 No No No No
Feb-19 2/28/19 Clear None 1 1 2 No No No No Clear None 1 1 1 No No No No
Light
Jun-19 6/7/19 Brown None 2 1 2 Yes No No No Clear None 1 1 1 No No No No
Light
Aug-19 8/27/19 Grey None 2 1 2 No No No No Clear None 1 1 1 No No No No
Light
Nov-19 11/27/19 Grey None 3 1 3 No No No No Clear None 1 1 1 No No No No
Light
Jan-20 1/24/20 Brown None 3 1 3 No No No No Clear None 1 1 1 No No No No
Light
Jun-20 6/23/20 Grey None 2 1 2 No No No No Clear None 1 1 1 No No No No
Light
Sep-20 9/17/20 brown None 1 1 1 No No No No Clear None 1 1 1 No No No No
Dec-20 12/4/20 Clear None 1 1 1 No No No No Clear None 2 1 2 No No No No
Med
Mar-21 3/16/21 Brown None 3 1 3 No No No No Clear one 1 1 1 No No No No
Jun-21 6/11/21 Brown None 2 1 2 1 2 No No No No Clear None 1 1 1 No No No No
e
Aug-21 8/4/21 Brown Nonet 3 2 3 No No No No Clear None 1 1 1 No No No No

Jackson Paper Manufacturing Company
Sylva, NC
NPDES Permit No. NCS000295
Summary of Best Management Practices (BMPs)
Location Pollutant of Concern In-Place BMPs
Annual training to educate employees on the type of materials that should not be placed in the
Trash compactor Oils/greases,solids,BOD, compactor.Routine inspection of area to prevent litter/solids from entering stormwater runoff and
COD to ensure waste is being picked up routinely and no waste is stored/placed just outside of the
compactor.
Delivery truck loading docks Oils/greases,BOD,COD, Routine inspection of area to prevent residual oils/greases or litter from entering the stormwater
solids system.Loading/unloading should remain within the designated area.
Parking Area between Paper Oils/greases,BOD,COD, Routine inspection of area to prevent residual oils/greases or litter from entering the stormwater
Machine building and WWT solids system.Loading/unloading should remain within the designated area.
Scrap metal dumpster Solids Scrap metal must be in kept in good condition,i.e.,free from rust or removed from the site.
Regularly inspect to ensure waste is being picked up routinely.
Filling operations are conducted by an off-site contractor under facility personnel supervision.The
contractor will stick the tank prior to filling to ensure that it can contain the contents to be placed
Kerosene Storage Tank Kerosene,COD into the tank.Any overflow is retained in the concrete containment area.Any precipitation in the
area remains until a valve is opened.The valve is maintained in a locked position.Facility personnel
will inspect the contents for a sheen before opening the valve to release precipitation.
Scrap metal storage Areas Solids Scrap metal must be in kept in good condition,i.e.,free from rust or removed from the site.
Regularly inspect to ensure waste is being picked up routinely.
Dryer Can Bearing storage Solids Dryer can bearings must be in kept in good condition,i.e.,free from rust or relocated to covered
areas.
Plastic baling area Solids Routine inspections of the area to assess the conditions.
Plastic baler hydraulic tank Hydraulic oil,BOD,COD, Routine cleaning out of the area beneath the hydraulic tank to prevent the drain from clogging.
oil tank O&G
Truck entrance/sawdust
delivery area Solids Monitoring the area to ensure drivers keep gates closed.
Cardboard storage areas Solids Routine inspections of the area to assess the conditions.
Gasoline and Diesel Fuel Gasoline,BOD,COD Routine inspections of the area to assess the conditions.
ASTs
Truck dump hydraulic oil Hdliil BOD Storage tanks are located within secondary containment structure.Ensuring the BMPs outlined in
storage tank yrauc o , ,COD the facility's Spill Prevention Control and Countermeasures(SPCC)Plan are adhered to.
Sawdust piles Solids Routine inspections of the area to assess the conditions.
Ash pad Solids,metals Routine inspections of the area to assess the conditions.
Ash pond and ash pit Solids,metals Routine inspections of the area to assess the conditions.
Scrap materials boneyard Solids Scrap metal must be in kept in good condition,i.e.,free from rust or removed from the site.

Jackson Paper Manufacturing Company
Sylva, NC
NPDES Permit No. NCS000295
Summary of Best Management Practices (BMPs)
General Housekeeping BMPs
Daily pickup and disposal of windblown waste (plastic and cardboard) on days when the site is in operation.
Conduct routine vehicle and equipment inspections for fluid leaks on large vehicles.
Routine visual inspections of all potential pollutant sources.
Promptly contain and clean up solid and liquid pollutant leaks and spills including oils,fuels, and hazardous
chemicals from manufacturing operations on any exposed soil,vegetation,or paved area.
Promptly repair or replace all substantially cracked or otherwise damaged paved secondary containment, high-
intensity parking, and any other drainage areas subject to pollutant material leaks or spills.
Inspect outdoor solid waste containers (trash compactors) to ensure they are maintained in an orderly condition
(i.e., containers are not overfilled)
Do not hose down or pressure wash those areas that contain potential stormwater contaminants. If conducting
washing in exterior areas, ensure the water can be captured and routed to the on-site wastewater treatment area.
Significant materials used on-site are stored in appropriate (covered) containers and are maintained indoors and/or
within secondary containment.
If pressure washing of a parking/loading area is conducted, ensure that no spills or hazardous materials have
occurred.
When possible, building overhead doors are kept closed during rain events.
Stormwater structures(e.g., catch basins,grassy areas) are cleaned and maintained for ensure proper operation.
Routine facility-wide inspections for and removal of waste,garbage, and floatable debris.
Indoor areas are kept clean from spills of oil, chemicals that may be tracked to exterior areas.
Facility areas are cleaned by manual methods only.Water is not used to "hose off' outdoor areas.
Roof top areas are inspected and kept clean.

Jackson Paper Manufacturing Company
Sylva, NC
NPDES Permit No. NCS000295
Summary of Best Management Practices (BMPs)
Preventative Maintenance BMPs
Stormwater diversion and control structures are maintained as needed to ensure proper operation.
Equipment and areas that have the potential for failures or spills have been identified and are inspected.
Immediately clean up spills and leaks(e.g., using absorbents,vacuuming,etc.)to prevent the discharge of
pollutants.
Use drain covers to cover catch basins that are adjacent to the south and east of the wood pile.
Clean out ditch east of the diesel fuel and gasoline ASTs and place a lining over the cover of the inlet to filter large
plastics.
Install a tarp around the eastern portion of the exposed cardboard storage building to prevent loose materials
from escaping the building.
Loading/Unloading operation structures are updated as needed to ensure proper operation.
Built-up sediment is removed from rip rap lining, drainage swales, drainage culverts,and culvert inlets to ensure
proper operation of stormwater structures.
Preventive maintenance performed on equipment (with potential of spills/leaks)to provide for proper operation
and detection of potential spills/leaks before they occur.
Inspections are conducted for the presence of non-stormwater discharges annually and that all unauthorized
discharges have been eliminated.

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources—Stormwater Program
Facility Name: Jackson Paper Manufacturing Company
Permit Number: NCS000295
Location Address: 152 West Main Street
Sylva,NC 28779
County: Jackson
"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 PO LUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature Date g_ IT 7�hJ
Carr Tyndall President/Chief Operating Officer
Print or type name of person signing above Title
SPPP Certification 10/13

JACKSON PAPER
MANUFACTURING
August 26, 2021
Suzanne McCoy
1612 Mail Service Center
Raleigh, NC 27699-1612
Subject: NPDES Stormwater Individual Permit Renewal Application
Jackson Paper Manufacturing Company — Sylva Plant
Permit No. NCS000295
Dear Ms. McCoy:
Jackson Paper Manufacturing Company— Sylva Plant (Jackson Paper) is submitting this renewal
application for coverage under the permit. As per Section B.1. of the permit, the permittee must submit
forms and fees as required by the agency no later than 180 days prior to the expiration date. Permit
NCS000295 expires February 28, 2022. This application includes the NCS Renewal Forms Package
and required supporting documentation. There have been no changes to the facility or activities since
issuance of the permit.
If you have any questions about the included information, please contact me at 828.586.5534, Ext 226
or [e-mail], or Rachel Velthuisen of TRC Environmental Corporation (TRC) at
919.671.0032 or [e-mail].
Sincerely, ,
Kiesha Bridges
Manager of Safety, Environmental & Technical
Attachments
cc: Rachel Velthuisen, TRC
NORTH CAROLINA'S LARGEST RECYCLED PAPER PRODUCER
152 WEST MAIN STREET®PO BOX 667®SYCVA, NC 28779 TEL[phone] FAX[phone]