WQ0005207_Staff Report_20231109

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 5

To: NPDES Unit Non-Discharge Unit Application No.: WQ0005207
Attn: Leah Parente Facility name: Jackson Paper Manufacturing – Sylva CLRS

From: Melanie Kemp
Asheville Regional Office

Note: This form has been adapted from the non-discharge facility staff report to document the review of both non-
discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.

I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? Yes or No
a. Date of site visit: February 24, 2023
b. Site visit conducted by: Melanie Kemp
c. Inspection report attached? Yes or No In LF
d. Person contacted: Carr Tyndall and their contact information: [e-mail] ext.
e. Driving directions: From US Hwy 23 South, take exit 85 to Sylva. Turn right at the second light on to
Business Hwy 23. Plant is approximately 100 yards on the right.
2. Discharge Point(s):
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters:
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
II. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
Proposed flow:
Current permitted flow:
2. Are the new treatment facilities adequate for the type of waste and disposal system? Yes or No
If no, explain:
3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? Yes No N/A
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? Yes No N/A
If no, please explain:
5. Is the proposed residuals management plan adequate? Yes No N/A
If no, please explain:
DocuSign Envelope ID: EB46E2E5-D539-45E4-9DEF-CB3C43E5A35A
FORM: WQROSSR 04-14 Page 2 of 5
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? Yes No N/A
If no, please explain:
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? Yes or No
If yes, attach a map showing conflict areas.
8. Is the proposed or existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? Yes No N/A
If yes, attach list of sites with restrictions (Certification B)
Describe the residuals handling and utilization scheme:
10. Possible toxic impacts to surface waters:
11. Pretreatment Program (POTWs only):

III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A
ORC: NA Certificate #: Backup ORC: Certificate #:
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? Yes or No
If no, please explain:
Description of existing facilities:
This has been updated based on renewal application:
Wastewater treatment and closed-loop recycle facility consisting of a 2,015 gallon supply tank with a 50
horsepower (hp) primary clarifier supply pump and a 30 hp pump conveying excess water to the South
basin; a 110,000 gallon primary clarifier with a 7.5 hp underflow pump and a top mounted skimmer; a
500,000 gallon aeration basin with four 25 hp surface aerators and two 7.5 hp lift pumps; a 330 gallon tote
of concentrated polymer fed through a ready to use make-down unit used in conjunction with a small
metering pump; a 13,500 gallon secondary clarifier with a 7.5 hp underflow pump; a top mounted
skimmer; a 500 gallon polymer mixing tank with a one hp chemical feed pump; a 400 gallon scum tank
with a 7.5 hp underflow pump; two 25,000 gallon sludge tanks with a 7.5 hp pump; a belt dewatering press
with a 7.5 hp pump; two 200 gallon polymer tanks for the Advanced Polymer Activation System with a 1
hp pump and a spare 0.75 hp pump; a 2,630 gallon seal water supply tank with two 25 hp discharge
pumps; a 2,300 gallon belt press shower tank with one 10 hp motor; a 300,000 gallon basin with two 25 hp
surface aerators and two 75 hp water supply pumps; two 36,900 gallon boiler scrubber settling basins with
two 30 hp scrubber supply pumps; and all associated piping, valves, controls, and appurtenances; and the
continued operation of a sand filer basin recycle system consisting of sand filters; a 30 hp pump; a 23,500
gallon basin with a 15 hp pump; a 300,000 gallon basin; and all associated piping, valves, controls, and
appurtenances
Proposed flow: NA
Current permitted flow: NA
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership, etc
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? Yes or No
If no, please explain:
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? Yes or No
If yes, please explain: The permit renewal outlines three changes that have been reflected in the facility
description above.
DocuSign Envelope ID: EB46E2E5-D539-45E4-9DEF-CB3C43E5A35A
FORM: WQROSSR 04-14 Page 3 of 5
5. Is the residuals management plan adequate? Yes or No
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? Yes or No N/A
If no, please explain:
7. Is the existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? Yes or No
If yes, attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? Yes or No
If no, please explain: Facility description above has been adjusted based on renewal application.
10. Were monitoring wells properly constructed and located? Yes No N/A
If no, please explain:
11. Are the monitoring well coordinates correct in BIMS? Yes No N/A
If no, please complete the following (expand table if necessary):
Monitoring Well Latitude Longitude
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
12. Has a review of all self-monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? Yes or No
Please summarize any findings resulting from this review:
The site has had no reporting requirements.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
13. Are there any permit changes needed in order to address ongoing BIMS violations? Yes or No
If yes, please explain:
14. Check all that apply:
No compliance issues Current enforcement action(s) Currently under JOC
Notice(s) of violation Currently under SOC Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place?
Have all compliance dates/conditions in the existing permit been satisfied? Yes No N/A
If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
Yes No N/A
If yes, please explain:
16. Possible toxic impacts to surface waters:
17. Pretreatment Program (POTWs only):

DocuSign Envelope ID: EB46E2E5-D539-45E4-9DEF-CB3C43E5A35A
FORM: WQROSSR 04-14 Page 4 of 5
IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? Yes or No
If yes, please explain:
2. List any items that you would like the NPDES Unit or Non-Discharge Unit Central Office to obtain through an
additional information request:
Item Reason

3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason

4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason

5. Recommendation: Hold, pending receipt and review of additional information by regional office
Hold, pending review of draft permit by regional office
Issue upon receipt of needed additional information
Issue
Deny (Please state reasons: )
6. Signature of report preparer:
Signature of regional supervisor:
Date:

DocuSign Envelope ID: EB46E2E5-D539-45E4-9DEF-CB3C43E5A35A
11/9/2023
FORM: WQROSSR 04-14 Page 5 of 5

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The permit modification outlines the following changes to the facility operations:
 The current permit mentions a 12,400-gallon anaerobic selector tank which has been removed and is
obsolete.
 The current permit mentions a 500-gallon polymer mixing tank with a one hp chemical feed pump. It has
been removed and replaced with a 330- gallon tote of concentrated polymer, which is fed through a ready
to use make-down unit used in conjunction with a small metering pump.
 The current permit mentions two 500-gallon polymer mixing tanks. Both have been removed and replaced
with two 200- gallon capacity polymer tanks for the Advanced Polymer Activation System ("ADPAS")
with a 1 hp pump and spare .75 hp pump.
DocuSign Envelope ID: EB46E2E5-D539-45E4-9DEF-CB3C43E5A35A