WQ0013419_Final Permit_20010824

State of North Carolina
Department of Environment, ILI
Health and Natural Resources A14i
•
Division of Water Quality dod
Michael F. Easley, Governor D E H I V R
William G. Ross Jr., Secretary
Gregory J. Thorpe, Ph.D., Acting Director
August 24, 2001
MR AJAY BADHWAR
RFS ECUSTA INC
PO BOX 200
PISGAH FOREST NC 28768
CIO D MIKE CODY
Subject: Permit No. WQ0013419
RFS Ecusta, Inc.
Ecusta Paper Mill
Surface Disposal of Wastewater Residuals
Transylvania County
Dear Mr. Badhwar:
In accordance with the name change request received on June 23, 2001, we are forwarding
herewith Permit No. WQ0013419, dated August 24, 2001, to the RFS Ecusta, Inc., Ecusta Division for
the construction and operation of a surface disposal site for the purpose of the disposal of wastewater
residuals. This facility was originally approved by the Division Solid Waste under Permit No. NC -88-
01 in 1976. No other conditions have been modified.
This permit shall be effective from the date of issuance until May 31, 2002, shall void Permit No.
WQ0013419 issued July 3, 1997, and shall be subject to the conditions and limitations as specified
therein. Please pay particular attention to the monitoring and reporting requirements contained in this
permit. Failure to establish an adequate system for collecting and maintaining the required operational
information will result in future compliance problems.
If any parts, requirements, or limitations contained in 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 North
Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service
Center, Raleigh, NC 27611-7447. Unless such demands are made this permit shall be final and binding.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

If you need additional information concerning this matte lease contact Thelma Williams at
[phone], extension 556.
Sinc e
Gregory J. Thorpe, Ph.D.
cc: Transylvania County Health Department
Asheville Regional Office, Water Quality Section
Asheville Regional Office, Groundwater Section
Groundwater Section, Central Office
Training and Certification Unit (no rating sheet attached)
Non -Discharge Compliance and Enforcements

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
RALEIGH
SURFACE DISPOSAL 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 THE
RFS Ecusta, Inc.
Transylvania County
FOR THE
expansion of an existing 16.0 acre surface disposal site (originally approved by the Division Solid Waste
under Permit No. NC -88-01) for the disposal of 31,025 dry tons per year of residuals from the P_ H.
Glatfelter Company, Ecusta Division's Ecusta Paper Mill with no discharge of wastes to the surface
waters, pursuant to the application received on January 31, 1997, 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 May 31, 2002, shall void Permit No.
WQ0013419 issued July 3, 1997, and shall be subject to the following specified conditions and
limitations:
I. PERFORMANCE STANDARDS
1. Upon completion of construction and prior to operation of the expansion to the existing
monofill, a certification must be received from a professional engineer certifying that the
permitted facility has been installed in accordance with this permit, the submitted plans
and specifications, and other supporting materials. Mail the Certification to the Non -
Discharge Permitting Unit, 1617 Mail Service Center, Raleigh, NC 27699-1617.
2. The Asheville Regional Office, telephone number [phone], shall be notified at
least forty-eight (48) hours in advance of operation of the installed facilities so that an in-
place inspection can be made. Such notification to the regional supervisor shall be made
during the normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday,
excluding State Holidays.
3. Each monofill shall be effectively maintained and operated as a non -discharge system to
prevent the discharge of any wastes resulting from the operation of this program.

4. 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 program.
5. In the event that any, monofill is not operated satisfactorily, including the creation of
nuisance conditions, the Permittee shall cease disposing of the wastewater residuals to the
monofill and take any immediate corrective actions as may be required by the Division.
6. The following buffer zones shall be maintained:
a. 400 feet between a monofill and any habitable residence,
b. 100 feet between a monofill and any public or private water supply source, all streams
classified as WS or B, waters classified as SA or SB and any Class I or Class II
impounded reservoir used as a source of drinking water,
c. 100 feet between a monofill and any stream, lake, river, or natural drainage way,
d. 50 feet between a monofill and property lines,
e. 10 feet between a monofill and any interceptor drains or surface water diversions
(upslope),
f. 25 feet between a monofill and any interceptor drains or surface water diversions
(downslope),
g. 25 feet between a monofill and any groundwater lowering and surface drainage
ditches.
7. A copy of this permit shall be maintained at the surface disposal site when residuals are
being disposed during the life of this permit. A spill prevention and control plan shall be
maintained at the facility.
8. Prior to disposal in a monofill, the wastewater residuals must meet the Class B pathogen
requirements in 40 CFR Part 503.32(b). Additionally, an evaluation must be performed
which demonstrates the residuals ability to comply with this requirement. Upon request,
a copy of this evaluation must be submitted including all test results and calculations.
II. OPERATION AND MAINTENANCE REQUIREMENTS
1. The facilities and application sites shall be properly maintained and operated at all times.
2. No residuals other than the following are hereby approved for disposal in the monofill in
accordance with this permit:
Permit Volume
Source ounty Number tons/ ear
RFS Ecusta, Ecusta Division Transylvania NCO000078 31,025
3. The pollutant concentrations in the residuals which will be disposed in a monofill shall
not exceed the following Ceiling Concentrations (Dry Weight Basis):
Parameters
_ mg/kg
Arsenic
46
Chromium
300
Nickel
320
2

4. Upon classification of the facility by the Certification Commission, the Permittee shall
employ a certified operator to be in responsible charge (ORC) of the surface disposal site.
The operator must hold a certificate of the type classification assigned to the surface
disposal site by the Certification Commission. The Permittee must also employ a
certified back-up operator of the appropriate type to comply with the conditions of Title
15A NCAC 8A,.0202.
5. A monofill shall not restrict the flow of a base flood.
6. A monofill shall not be located in an unstable area.
7. Appropriate measures must be taken to control public access to the surface disposal site
during active site use and for the 36 -months following closure- of the monofill. Such
controls may include fencing and the posting of signs indicating the activities being
conducted at each site.
8. Adequate provisions shall be taken to prevent any surface runoff from occurring at any
active monofill. If runoff cannot be prevented, a collection system shall be installed with
the capacity to handle runoff from a 24-hour, 25 -year storm event. All collected runoff
shall be disposed in a manner approved by the North Carolina Division of Water Quality.
9. Adequate provisions shall be taken to prevent wind erosion from conveying pollutants or
residuals from the surface disposal site onto the adjacent property or into any surface
waters.
10. Food crops, feed crops and fiber crops shall not be grown on a monofill, unless approval
has been requested and received from the Division of Water Quality.
11. Animals shall not be grazed on a monofill unless approval has been requested and
received from the Division of Water Quality.
III. MONITORING AND REPORTING REQUIREMENTS
Any monitoring (including groundwater, surface water, residuals, soil, or plant tissue
analyses) deemed necessary by the Division of Water Quality to insure protection of the
environment will be established and an acceptable sampling and reporting schedule shall
be followed.
2. Proper records shall be maintained by the Permittee tracking all application activities.
These records shall include, but are not necessarily limited to the following information:
a. volume of residuals disposed in gaIlonslyear, dry tons/year, or kilograms/year
3. A residuals analysis will be conducted annually from the date of permit issuance by the
Permittee and the results maintained on file by the Permittee for a minimum of five years.
If land application occurs at a frequency less than annually, a residuals analysis will be
required for each instance of land application. The residuals analysis shall include but is
not necessarily limited to the following parameters:
Arsenic % Total Solids
Chromium pH
Nickel

4. A Toxicity Characteristics Leaching Procedure (TCLP) analysis will be conducted once,
prior to renewal of this permit by the Permittee, as long as the processes generating the
residuals do not significantly change. Annually, a certification shall be submitted with
the annual report which verifies that the process generating these residuals has not
significantly changed. If such a change occurs, a TCLP analysis of the residuals must be
conducted within six months and annually thereafter.
The TCLP analysis shall include the following parameters (please note the regulatory
level in mg/L in parentheses):
Arsenic (5.0)
Benzene (0.5)
(continued on next page)
Carbon. tetrachloride (0.5)
Chlorobenzene (100.0)
Chromium (5.0)
m -Cresol (200.0)
Cresol (200.0)
1,4 -Dichlorobenzene (7.5)
1, 1 -Dichloroethylene (0.7)
Endrin (0.02)
Hexachlorobenzene (0.13)
Hexachloroethane (3.0)
Lindane (0.4)
Methoxychlor (10.0)
Nitrobenzene (2.0)
Pyridine (5.0)
Silver (5.0)
Toxaphene (05)
2,4,5 -Trichlorophenol (400.0)
2,4,5 -TP (Silvex) (1.0)
Barium (100.0)
Cadmium (1.0)
Chlordane (0.03)
Chloroform (6,0)
o -Cresol (200.0)
p -Cresol (200.0)
2,4-D (10.0)
1,2-Dichloroethane (0.5)
2,4-Dinitrotoluene (0.13)
Heptachlor (and its hydroxide) (0.00$)
Hexachloro-1,3-butadiene (0.5)
Lead (5.0)
Mercury (0.2)
Methyl ethyl ketone (200.0)
Pentachlorophenol (100.0)
Selenium (1.0)
Tetrachloroethylene (0.7)
Trichloroethylene (0.5)
2,4,6 -Trichlorophenol (2.0)
Vinyl chloride (0.2)
5. All residuals included in this permit must be monitored annually, from the date of permit
issuance, for compliance with condition I S of this permit. Data to verify stabilization
and vector attraction reduction of the residuals must be maintained by the Permittee. The
required data is specific to the stabilization process utilized, but should be sufficient to
clearly demonstrate compliance the Class B pathogen requirements in 40 CFR Part 503.
6. Three copies of all required monitoring and reporting requirements as specified in
conditions 1111, 111 2, 1113, 111 4, and III 5 shall be submitted annually on or before March
1 of the following year to the following address:
NC Division of Water Quality
Water Quality Section
Non -Discharge Compliance and Enforcement Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
7. Noncompliance Notification:

The Permittee shall report by telephone to the Asheville Regional Office, telephone
number [phone], 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 with the surface disposal program which results in the disposal of
significant amounts of wastes which are abnormal in quantity or characteristic.
b. Any failure of the surface disposal program resulting in a release of material to
receiving waters.
c_ Any time that self-monitoring information indicates that the facility has gone out of
compliance with the conditions and limitations of this permit or the parameters on
which the system was designed.
d. Any process unit failure, due to known or unknown reasons, that renders the facility
incapable of adequate residual treatment.
e. Any spillage or discharge from a vehicle or piping system transporting residuals to
the disposal site.
Persons reporting such occurrences by telephone shall also file a written report in letter
form within five (5) 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.
IV. GROUNDWATER REOUIREMENTS
1. The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in
15A NCAC 2L, Groundwater Classifications and Standards. The Compliance Boundary
for the disposal system constructed prior to December 31, 1983 is established at either (1)
500 feet from the waste disposal area, or (2) at 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.
2. Any groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
V. INSPECTIONS
1. The Permittee or his designee shall inspect the residuals storage, transport, and disposal
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
5

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 five years from the date of the inspection and shall be made
available to the Division of Water Quality or other permitting authority, upon request.
2_ Any duly authorized officer, employee, or representative of the Division of Water Quality
may, upon presentation of credentials, enter and inspect any property, premises or place
on or related to the surface 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
kept under the terms and conditions of this permit; and may obtain samples of
groundwater, surface water, or leachate.
VI. GENERAL CONDITIONS
1. This permit shall become voidable unless the surface disposal activities are carried out in
accordance with the conditions of this permit, the supporting materials, and in the manner
approved by this Division.
2. This permit is effective only with respect to the nature and volume of wastes described in
the application and other supporting data.
3. This permit is not automatically transferable. In the event that there is a desire for the
facilities to change ownership or a name change of the Permittee, a formal permit request
must be submitted to the Division of Water Quality 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.
4. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division of Water Quality in accordance with
North Carolina General Statute 143-215.6(a) to 143-215.6(c).
5. 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 15 NCAC 2H .0205
(c)(4).
6. 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.
7. 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.
This permit may be modified, or revoked and reissued to incorporate any conditions,
limitations and monitoring requirements the Division of Water Quality deems necessary
in order to adequately protect the environment and public health.

9. The Division must be notified in writing at least 1$0 days prior to closing of the surface
disposal site. A formal closure plan shall be required to be submitted at that time.
Permit issued thi e 24`h day of August, 2001
NTAROLIN V ONMENTAL MANAGEMENT COMMISSION
-/Gregory J. Thorpe, Ph.D. Acting Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0013419

Permit No. WQ0013419
August 24, 2001
ENGINEER'S CERTIFICATION
I, , as a duly registered Professional Engineer in the State of North
Carolina, having been authorized to observe (periodically, weekly, full time) the construction of the
project, , for the
Project Name Location
Permittee hereby state that, to the best of my abilities, due care and diligence was used in the observation
of the construction such that the construction was observed to be built within substantial compliance and
intent of this permit, the approved plans and specifications, and other supporting materials.
Signature
Date
Registration No.