NCS000101_Compliance Letter_20180518

A F
t, r
Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
May 14, 2018
International Paper Riegelwood Mill
Mr. Gary Morrow, Manager, EHS&S
John L. Riegel Road
Riegelwood, NC 28456
Subject: Compliance Evaluation Inspection
Certificate of Coverage NCS000101
International Paper Riegelwood Mill
Columbus County
Dear Mr. Morrow:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretar,
WILLIAM E.(TOBY) VINSON
Interim Director
RECEIVED
MAY 18 2018
LAND QUALITY
MINING PROGRAM
On May 8, 2018, Brian Lambe and Dan Sams from the Wilmington Regional Office of the Division of
Energy, Mineral, and Land Resources (DEMLR), conducted a compliance evaluation inspection for
International Paper Riegelwood Mill located in Columbus County, North Carolina. The site drains to the
Cape Fear River, which is currently classified as Class C, Sw Waters in the Cape Fear River Basin.
The following observations were noted during the DEMLR inspection (please see the attached
addendum for additional information about your permit):
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and properly
implemented.
Yes ■ No ❑
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
Yes ■ No D
3) Analytical Monitoring
Analytical monitoring has been conducted and recorded in accordance with permit requirements.
Yes ■ No 0
Other Observations:
Tier Two requirements for Basin B and Basin E are relieved.
Request for guidance regarding potential use of truck parking area for shipping crate storage. Please
include as an amendment in the SWPPP, but it is not considered as an outfall.
Thank you for your assistance and cooperation during this inspection. Please be advised that violations
of the NPDES Stormwater General Permit may be subject to a civil penalty assessment of up to
Wilmington Regional Office
127 Cardinal Drive Ext, Wilmington, NC 28405 . Phone: [phone]

International Paper Riegelwood Mill
Page 2 of 2
$25,000.00 per day for each violation. If you have any questions, comments, or need assistance with
understanding any aspect of your permit, please do not hesitate to contact Dan Sams or me at (910)
796-7215.
Sincerely,
an Lambe
Environmental Specialist
Land Quality Section
Attachments:
1. BIMS Inspection Checklist
cc: WiRO Files — Land Quality
Central Files — DWR

Compliance Inspection Report
Permit: NCS000101 Effective: 12/01/14 Expiration: 11/30/19 Owner: International Paper Company
SOC: Effective: Expiration: Facility: Riegelwood Mill
County: Columbus 865 John L Riegel Rd
Region: Wilmington
Riegelwood NC 28456
Contact Person: 4rouis'0 19, Title: Phone: [phone]
WALLACECvvSP,DRLi., Ki he;ry FAIL
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 05/08/2018
Primary Inspector: Brian P Lambe
Secondary Inspector(s):
Entry Time: 09:30AM
Reason for Inspection: Routine
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant Not Compliant
Question Areas:
0 Storm Water
(See attachment summary)
Certification:
Phone:
Exit Time: 02:OOPM
Phone:
Inspection Type: Compliance Evaluation
Page: 1

Permit: NCS000101 Owner- Facility: international Paper Company
Inspection Date: 05/08/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Due to a February 6, 2018 letter from International Paper, an inspection was prompted in which Brian Lambe, with Dan
Sams, met with Ms. Wallace Coverdale and Ms. Kimberly Fail of IP. The letter discusses recent sampling results and IP's
response to the results. The site is delineated into drainage basins A -S, which have representative outfall status with 4
ouffalls in basins B, E, I, and T. IP requests Basin B and E be relieved of Tier two requirements. Due to response (repairs
and housekeeping); this office relieves IP of Tier Two requirements.
Basin B is in Tier 2 for TSS. The latest sample result is under the benchmark value. Repairs have been made to the
damaged pipe. IP may discontinue Tier 2 sampling.
Basin E is in Tier 2 for COD. Recent samples have been under the BMV. The inspection revealed a well maintained area.
The woodchips will always require constant maintenance. In 2016, discussion between this office (Sams and Randall) and
IP included a lift station to the wastewater system (IP) or a regenerative stormwater conveyance or RSC (Randall). IF
stated, during the current inspection, space was a limiting factor in not pursuing the RSC. The outfall is tested on the top of
a hill, after which it enters a ditch lined with corregated plastic pipe, which may help in oxygenating the discharge.
Regardless of any possible BMPs, the sampling results will always be tied directly to housekeeping. IP may discontinue
Tier Two sampling.
Basin I is in Tier One but has received an exceedance in the last sampling event for TSS and COD. IP requests that prior
sampling be considered as a completed and closed event in relation to the pipe failure and subsequent repair. IP stated that
the pipe will be investigated for additional failures. This office agrees with this plan of action and assertion.
Basin T exceeded the COD BMV but remains in Tier One. Housekeeping is essential.
IP is planning to use an area previously used for truck parking as a container storage area. IP is asking if this area should
be considered as part of thier SWPPP and if the outfalls should be considered. This office does not think that the outfalls
should be considered as no industrial process or product is stored (outside of cover) in this location. IP should include the
area in the SWPPP as to inspect for spills and to prevent any process that may be a pollutant source. The SWPPP should
contain an amendment detailing usage and restrictions for the area.
Paae: 2

Permit: NCSDOC101 Owner - Facility: International Paper Company
Inspection Date: 05/08/2018 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?
0
❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices"?
N
❑ ❑ ❑
# 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?
E
❑ ❑ ❑
# Does the Plan include a BMP summary?
0
❑ ❑ ❑
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
E
❑ ❑ ❑
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
M
❑ ❑ ❑
# Does the facility provide and document Employee Training?
0
❑ ❑ ❑
# Does the Plan include a list of Responsible Party(s)?
❑ ❑ ❑
# Is the Plan reviewed and updated annually?
0
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
0
❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented?
E
❑ ❑ ❑
Comment
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? 0 ❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? 0 ❑ ❑ ❑
Comment: Refer to summary regarding Tier Two analyis.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? N ❑ ❑ ❑
# Were all outfalls observed during the inspection? 0 ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? E ❑ ❑ ❑
# Has the facility evaluated all illicit (non stormwater) discharges? 0 ❑ ❑ ❑
Comment:
Page: 3