WQ0008381_Final Permit_19951222

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
C)EHNR
December 22, 1995
Mr. David Massengill, Environmental Engineer
Georgia-Pacific Corporation
133 Peachtree Street, NE
Atlanta, GA 30348-5605
Dear Mr. Massengill:
Subject: Permit No. WQ0008381 Amendment
Georgia-Pacific Corporation
Wilmington, NC
Building Materials Distribution Facility
Groundwater Remediation Facilities
New Hanover County
0
In accordance with the amendment request received from the Division's Groundwater Section, we
are forwarding herewith Permit No. WQ0008381 as amended, dated December 22, 1995, to Georgia-
Pacific Corporation for the continued operation of the subject groundwater remediation facility. The
amendment includes changes in permit conditions IV 2, IV 5, IV 6 and IV.8 to incorporate naphthalene in
the monitoring, and to allow the substitution of the specified alternate groundwater monitoring wells for
some of those originally identified to be monitored. The permittee should deal directly with the Division's
Groundwater Section in regard to the incremental flow criteria specified in condition IV 1. Since the
Engineer's Certificate of Completion was received on April 5, 1995, all conditions referencing the need for
that document have also been removed or modified, as necessary. The remainder of the permit is
unchanged from its original version.
Georgia-Pacific Corporation is expected to show the subject remediation system can successfully
treat and reinfiltrate the subject petroleum -contaminated groundwater at the specific GPD per square foot
rate indicated in this permit. Please note that this permit contains conditions (in section IV) which require
monitoring of the system performance and the addition of facilities if determined to be necessary.
Additionally, please note that all such "system performance" monitoring should be forwarded to the
Groundvi'ater Section of the Division (address listed in section IV).
This permit shall be effective from the date of issuance until November 30, 1998, shall void Permit
No. WQ0008381 issued January 6, 1994, and shall be subject to the conditions and limitations as
specified therein, Please pay particular attention to the monitoring requirements in this permit. Failure to
establish an adequate system for collecting and maintaining the required operational information will result
in future compliance problems.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

If any parts, requirements, or limitations contained in the modified portions of this permit are
unacceptable, you have the right to request an adjudicatory hearing upon written request within thirty (30)
days following receipt of this permit. This request must be in the form of a written petition, conforming to
Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings, P.O. Drawer 27447, Raleigh, NC 27611-7447. Unless such demands are made this permit
shall be final and binding.
If you need additional information concerning this matter, please contact Mr. David Goodrich at
[phone].
Sincerely,
A. Preston Howard, Jr
cc: New Hanover County Health Department
Integrated Science & Technology, Inc.
Wilmington Regional Office, Water Quality Section
Wilmington Regional Office, Groundwater Section
Bob Cheek, Groundwater Section, Central Office
Training and Certification Unit (No Revised Rating)
Facilities Assessment Unit

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
GROUNDWATER REMEDIATION PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Georgia-Pacific Corporation
New Hanover County
Irflam
operation of a 115,200 GPD (80 GPM maximum) groundwater remediation facility consisting of three (3)
35 gpm recovery wells, a 5,000 gallon surge tank, a transfer pump rated at 60 to 100 gpm, a 100 gpm
packed air stripping tower (2.5 feet in diameter, 24 feet in height) with a 900 cfm blower, an 80 gpm
carbon filtration system (as required when necessary), a surge tank to recycle wastewater back through the
air stripper (as required when necessary), an 80 gpm infiltration gallery (150 feet in length, 3 feet wide and.
8 feet deep) with well monitoring and automatic remediation system cut off float switches, and all
associated piping, valves, controls, monitors, alarms and appurtenances to serve Georgia-Pacific
Corporation's Wilmington, North Carolina, Building Materials Distribution Facility, with no discharge of
wastes to the surface waters, pursuant to the Groundwater Section's amendment request received
December 15, 1994, and in conformity with the project plan, specifications, and other supporting data
subsequently filed and approved by the Department of Environment, Health and Natural Resources and
considered a part of this permit.
This permit shall be effective from the date of issuance until November 30, 1998, shall void Permit
No. WQ0008381 issued January 6, 1994, and shall be subject to the following specified conditions and
limitations:
I. PERFORMANCE STANDARDS
This permit shall become voidable if the soils fail to -adequately, assimilate the wastes and
may be rescinded unless the facilities are installed, maintained, and operated in a manner
which will protect the assigned water quality standards of the surface waters and ground
waters.
2. In the event that the facilities fail to perform satisfactorily, including the creation of
nuisance conditions, the Permittee shall take immediate corrective action, including those
actions that may be required by this Division, such as the construction of additional or
replacement treatment or disposal facilities.
3. The issuance of this permit shall not relieve the Permittee of the responsibility for damages
to surface or groundwaters resulting from the operation of this facility.

4. Any residuals generated from these treatment facilities must be disposed in accordance with
General Statute 143-215.1 and in a manner approved by the North Carolina Division of
Environmental Management.
5. Diversion or bypassing of the untreated groundwater from the treatment facilities is
prohibited.
II. OPERATION AND MAINTENANCE_ REQUIREMENTS
1. The facilities shall be properly maintained and operated at all times.
2. Upon classification of the facility by the Certification Commission, the Permittee shall
employ a certified wastewater treatment plant operator to be in responsible charge (ORC) of
the wastewater treatment facilities. The operator must hold a certificate of the type and
grade at least equivalent to or greater than the classification assigned to the wastewater
treatment facilities by the Certification Commission. The Permittee must also employ a
certified back-up operator of the appropriate type and grade to comply with the conditions
of Title 15A, Chapter 8A, .0202. The ORC of the facility must visit each Class I facility at
least weekly and each Class 11,111, and IV facility at least daily, excluding weekends and
holidays, and must properly manage and document daily operation and maintenance of the
facility and must comply with all other conditions of Title 15A, Chapter 8A, .0202.
3. The facilities shall be effectively maintained and operated as a non -discharge system to
prevent the discharge of any wastewater resulting from the operation of this facility.
III. MONITORING Ah�D ,REPORTING REQUIREMF,N,TS
Any monitoring deemed necessary by the Division of Environmental Management to insure
surface and ground water protection will be established and an acceptable sampling
reporting schedule shall be followed.
2. Noncompliance Notification:
The Permittee shall report by telephone to the Wilmington Regional Office, telephone
number 910/395-3900, as soon as possible, but in no case more than 24 hours or on the
next working day following the occurrence or first knowledge of the occurrence of any of
the following:
a. Any occurrence at the wastewater treatment facility which results in the treatment of
significant amounts of wastes which are abnormal in quantity or characteristic, such as
the dumping of the contents of a basin or tank, the known passage of a slug of
hazardous substance through the facility, or any other unusual circumstances;
b. Any process unit failure, due to known or unknown reasons, that renders the facility
incapable of adequate wastewater treatment, such as mechanical or electrical failures of
pumps, aerators, compressors, etc.;
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass
directly to receiving waters without treatment of all or any portion of the influent to
such station or facility; or
d. Any time that self -monitoring information indicates that the facility is not in compliance
with its permit limitations.
Persons reporting such occurrences by telephone shall also file a written report in letter
form within 15 days following first knowledge of the occurrence. This report must outline
the actions taken or proposed to be taken to ensure that the problem does not recur.
4

IV. GROUNDWATER REQUIREMENTS
Each of the three 4-inch diameter PVC water -level monitoring wells will be equipped with a
float -activated high-level shutoff device which will shut down the remediation system when
the water level in the well rises to within one (1) foot of the bottom of the infiltration
trench. The shutoff device will be designed such that the remediation system will remain
off until the water level in that well falls to an elevation two (2) feet below the bottom of the
infiltration trench. The system will be wired so that any of the three wells may shut down
the system.
The water level in the center monitoring well will be measured at least once every day and
this information will be provided to the Groundwater Section, Central Office (Raleigh).
The remediation system will be equipped with an electronic monitor which automatically
records the time and date of every system shutdown event. If more than six (6) float -
activated shutdown events are recorded during a consecutive 30-day period, the system
flow rate will be reduced by 10% of its rate at that time. if the situation persists after the
flow rate has been reduced, a meeting will be held to discuss and resolve the problem.
The system will be allowed to operate at incremental fractions of the total flow permitted
herein, as determined to be appropriate by the Groundwater Section, Central Office.
All system performance reports (quarterly reports, etc.) shall be forwarded to that office at
the following address:
Permits and Compliance Unit
Groundwater Section
P,O. Box 29578
Raleigh, NC 27626-0578.
2 . The influent and effluent from the treatment system shall be sampled for naphthalene (by
EPA Method 610), and for BTEX and MTBE (by EPA Method 602) once every two (2)
weeks for the first three (3) months after permit issuance, and monthly thereafter.
The results of the sampling and analysis shall be sent to the Groundwater Section, Permits
Unit, P.O. Box 29535, Raleigh, N.C. 27626-0535, within 30 days of sample collection.
3. The permittee shall retain copies of records of all monitoring information, including all
calibration and maintenance records, all original strip chart recordings for continuous
monitoring instrumentation and copies of all reports required by this permit, for a period of
at least 3 years from the date of the sample, measurement, report or application. Records
of this monitoring information shall include, but not be limited to, the following:
a. the date, exact place, and time of sampling or measurements,
b . the individual who performed the sampling or measurements,
c . the date the analyses were performed,
d, the analyticattechniques or methods used; and
e. the results of any such sampling, measurements, and analyses.
4. The permittee shall report any monitoring or other information which indicates that any
contaminant may cause an endangerment to an underground source of drinking water and
any noncompliance with a permit condition of malfunction of the injection system which
may cause fluid migration outside the injection zone or area. The information shall be
provided to the Wilmington Regional Office orally within 8 hours of the occurrence and as
a written submission within five days of the occurrence_ The written submission shall
contain a description of the noncompliance and its cause, the period of noncompliance,
including exact dates and times, and if the noncompliance has not been corrected, the
anticipated time it is expected to continue, and any steps taken or planned to reduce,
eliminate and prevent reoccurrence of the noncompliance.

r6i
7.
The following monitor wells shall be sampled every March, June, September and
December;
MW-6
MW-9
MW-10
MW-11
MW-A
MW-C
MW-13
MW-14
MW-15
MW-17
MW-B
Monitor wells shall be sampled for the following parameters:
Benzene
MTBE
pH
Water Levels
Ethylbenzene
Xylenes
Toluene
Naphthalene
The measurement of water levels must be made prior to sampling for the remaining
parameters. The depth to water in each well shall be measured from the surveyed point on
the top of the casing.
The results of the sampling and analysis shall be sent to the Groundwater Section,
Wilmington Regional Office, and to the Groundwater Section, Permits and Compliance
Unit, P.O. Box 29535 Raleigh, N.C. 27626-0535 on Form GW-59 [Compliance
Monitoring Report Form] within 30 days of sample collection.
The groundwater recovery treatment and disposal system shall be inspected weekly. If it is
determined that the system is malfunctioning, all repairs should be made as soon as
possible and reported to the Wilmington Regional Office.
S. Effluent concentrations of contaminants shall not exceed the following Class GA
Groundwater Standards: benzene, 0.001 milligrams per liter; toluene, 1.0 milligram per
liter; ethylbenzene, 0.029 milligrams per liter; zylenes, 0.4 milligrams per liter;
naphthalene, 0.021 milligrams per liter.
9. Isoconcentration maps in both the vertical and horizontal directions shall be developed
using the groundwater monitoring data collected prior to system operations for MTBE and
BTEX. A water level contour map must also be developed on a quarterly basis. These
maps shall be submitted along with all groundwater monitoring data.
10. All components of the groundwater recovery, treatment and disposal system shall be
properly weather -proofed to prevent freezing and failure of the system.
11. The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in
15A NCAC 2L, Groundwater Classifications and Standards. The Compliance Boundary is
for the disposal system constructed after December 31, 1983, is established at either (1)
250 feet from the waste disposal area, or (2) 50 feet within the property boundary,
whichever is closest to the waste disposal area. An exceedance of Groundwater Quality
Standards at or beyond the Compliance Boundary is subject to immediate remediation
action in addition to the penalty provisions applicable under General Statute 143-
215.6A(a)(1).
In accordance with 15A NCAC 2L, a REVIEW BOUNDARY is established around the
disposal systems midway between the Compliance Boundary and the perimeter of the
waste disposal area. Any exceedance of standards at the Review Boundary shall require
remediation action on the part of the permittee.

12. It is the responsibility of the Wilmington Regional Office to enforce all applicable
Groundwater Regulations and to issue appropriate notification to the permittee when
exceedances or violations are observed.
13. Any additional groundwater quality monitoring as deemed necessary by the Division of
Environmental Management shall be provided.
V . INSPECTIONS
1. Adequate inspection, maintenance and cleaning shall be provided by the Permittee to insure
proper operation of the subject facilities.
2. The Permittee or his designee shall inspect the groundwater recovery and treatment
facilities to prevent malfunctions and deterioration, operator errors and discharges which
may cause or lead to the release of wastes to the environment, a threat to human health, or a
nuisance. The Permittee shall maintain an inspection log or summary including at least the
date and time of inspection, observations made, and any maintenance, repairs, or corrective
actions taken by the Permittee. This log of inspections shall be maintained by the Permittee
for a period of three years from the date of the inspection and shall be made available to the
Division of Environmental Management or other permitting authority, upon request.
3. Any duly authorized officer, employee, or representative of the Division of Environmental
Management may, upon presentation of credentials, enter and inspect any property,
premises or place on or related to the disposal site or facility at any reasonable time for the
purpose of determining compliance with this permit, may inspect or copy any records that
must be maintained under the terms and conditions of this permit, and may obtain samples
of groundwater, surface water, or leachate.
VI. GENERAL CONDITIONS
Issuance of this permit does not constitute approval for reimbursement from the Leaking
Petroleum Underground Storage Tank Cleanup Funds (15A NCAC 2P),
2. This permit shall become voidable unless the facilities are constructed in accordance with
the conditions of this permit, the approved plans and specifications, and other supporting
data.
3. This permit is effective only with respect to the nature and volume of wastes described in
the application and other supporting data.
4. This permit is not transferable. In the event there is a desire for the facilities to change
ownership, or there is a name change of the Permittec, a formal permit request must be
submitted to the Division of Environmental Management accompanied by an application
fee, documentation from the parties involved, and other supporting materials as may be
appropriate. The approval of this request will be considered on its merits and may or may
not be approved.
5. A set of approved plans and specifications for the subject project must be retained by the
Permittee for the life of this project.
6. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division of Environmental Management in
accordance with North Carolina General Statute 143-215.6(a) to 143-215.6(c).
7. The annual administering and compliance fee must be paid by the Permittee within thirty
(30) days after being billed by the Division. Failure to pay the fee accordingly may cause
the Division to initiate action to revoke this permit as specified by 15A NCAC 2H .0205
(c)(4).

8. The issuance of this permit does not preclude the Permittee from complying with any and
all statutes, rules, regulations, or ordinances which may be imposed by other government
agencies (local, state, and federal) which have jurisdiction.
9. The Permittee, at least six (6) months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Commission will review the adequacy of the
facilities described therein, and if warranted, will extend the permit for such period of time
and under such conditions and limitations as it may deem appropriate.
Permit issued this the twenty-second day of December, 1995
NORTH CAROLNA ENVIRONMENTAL MANAPEMENT COMMISSION
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission
Permit Number WQ0008381 Amendment