WQ0015180_Final Permit_20050826

OF NNkr RQ Michael F. Easley, Govemar
ti0 G William G. Ross Jr., Secretary
7 North Carolina Department of Environment and Natural Resources
�t Alan W. Klimek, P.E., Director 6
Division of Water Quality
August 26, 2005
MR. J. SCOTT GRIMES, MILL MANAGER
INTERNATIONAL PAPER COMPANY
JOHN L. RIEGEL ROAD
RIEGELWOOD, NORTH CAROLINA 28456
Subject: Permit No. WQ0015180
International Paper Company
IP RiegeIwood Ash Distribution Program
Distribution of Residual Solids (503 Exempt)
Columbus County
Dear Mr. Grimes:
In accordance with your permit renewal application package received on November 3, 2003 as
well as the additional information received March 19, 2004, we are forwarding herewith a renewed
Permit No. WQ0015180, dated August 26, 2005, to International Paper Company for the subject ash
distribution/land application program as a soil additive on lands owned by the company.
This permit shall be effective from the date of issuance until July 31, 2010; shall void Permit No.
WQ0015180, issued on May 14, 1999; and shall be subject to the conditions and limitations as specified
therein. Make note of this permit's expiration date and the fact that'a permit renewal application is due to
the Division of Water Quality (Division) no later than six months prior to that date (i.e., see Condition VI.
7.), as the Division does not send reminders to apply for permit renewal.
This permit has been issued to approve the operation of International Paper Company's ash
distribution program for another five-year cycle. As always, remember to take the time to review this
permit thoroughly, as some of the conditions contained therein may have been added, changed, or
deleted since the last issuance. Pay particular attention to the monitoring requirements in this permit.
Please be aware that failure to establish an adequate system for collecting, maintaining, and submitting
the required operational information will result in future compliance problems.
If any parts, requirements, and/or limitations contained in this permit are unacceptable, you have
the right to request an adjudicatory hearing upon written request within 30 calendar days following
receipt of this permit. This request shall be in the from of a written petition, conforming to Chapter 150B
of the North Carolina General Statutes and filed with the Office of Administrative Hearings at 6714 Mail
Service Center, Raleigh, North Carolina 27699-6714. Unless such demands are made, this permit shall be
final and binding.
No°C Carolina
A0711y
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
lntemet: httpalt}2o.enrstate,nc.us 2728 Capital Boulevard Raleigh, NC 27604 Fax [phone]
Fax [phone]
An Equal OpportunitylAttirmative Action Employer -501/16 Recycted110% Post Consumer Paper

Mr. J. Scott Grimes
August 26, 2005
Page 2
If you need any additional information concerning this matter, please cgntact J R Joshi by
telephone at [phone], or via e-mail [e-mail]. 7
Lor Alan W. Klimek, P.E.
cc: Mr. Elwood Black, LSS, PO Box 3244, Cary, NC 27511
Columbus County Health Department
Wilmington Regional Office - Aquifer Protection Section
Technical Assistance and Certification Unit
APS Central Files
APS Files
LAU Residuals Program Coordinator

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
DISTRIBUTION OF RESIDUAL SOLIDS (503 EXEMPT) 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
International Paper Company
Columbus County
FOR THE
continued operation of a program, for the distribution of up to 100,000 dry tons of ash (i.e., wood ash,
slaker grits, green liquor dregs, and primary clarifier solids) as a soil additive generated from the facilities
listed in Condition 11.4 for the uses listed in Condition II.5 with no discharge of waste to surface waters
occurs, pursuant to the permit renewal application package received on November 3, 2003 as well as all
additional information received March 19, 2004, and in conformity with the project plan, specifications,
and other supporting data subsequently filed and approved by the Department of Environment and
Natural Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until July 31, 2010; shall void Permit No.
WQ0015180, issued to International Paper Company on May 14, 1999; and shall be subject to the
following specified conditions and limitations:
I. PERFORMANCE STANDARDS
The distribution of ash as soil additive program shall be effectively maintained and operated
as a non -discharge system to prevent the discharge of any wastes to waters of the state
resulting from the operation of this facility or program.
2. This permit shall become voidable in the event of failure of the ash soil additive distribution
program to adequately protect the assigned water quality standards of the surface waters and
groundwater.
3. The issuance of this permit shall not relieve the Pemiittee of the responsibility for damages to
surface water or groundwater resulting from the operation of this ash distribution program.

4. In the event that the ash distribution program is not operated satisfactorily, including the
creation of nuisance conditions, the Permittee shall take any immediate corrective actions as
may be required by the Division of Water Quality (Division).
No ash that tests or is classified as a hazardous or toxic waste under 40 CFR Part 261 shall be
sold or given away under the conditions of this permit.
6. Diversion or bypassing of untreated ash soil additive or excess water from the ash treatment
facilities is prohibited.
7. All excess water must be reused as a wetting agent for the processing of soil additives or
routed to the head of the treatment plant.
H. OPERATION AND MAINTENANCE REQUIREMENTS
The ash distribution program shall be properly operated and maintained at all times.
Upon classification of the ash distribution program by the Water Pollution Control System
Operators Certification Commission (WPCSOCC), the Permittee shall employ a certified
operator to be in responsible charge (ORC) of the program. The operator shall hold a
certificate of the type classification assigned to the program by the WPCSOCC. The
Permittee shall also employ a certified back-up operator of the appropriate type to comply
with the conditions of 15A NCAC 8G .0202.
When land applying ash as soil additive to any land application site, the following buffer
zones shall be maintained at all times:
a. 400 feet from residences or places of public assembly under separate ownership for
surface application methods; however, the buffer zone requirement may be reduced to a
minimum of 100 feet upon written consent of the owner and approval from the Aquifer
Protection Section of the appropriate Division's regional office in Attachment B of this
permit;
b. 200 feet from residences or places of public assembly under separate ownership for
subsurface application methods; however, the buffer zone requirement may be reduced to
a minimum of 100 feet upon written consent of the owner and approval from the Aquifer
Protection Section of the appropriate Division's regional office in Attachment B of this
permit;
c. 100 feet from any public or private water supply source, waters classified as SA or SB,
and any Class I or Class II impounded reservoir used as a source of drinking water for
both methods;
d. 100 feet from any streams classified as WS or B, any other stream, canal, marsh or
coastal waters and any other lake or impoundment for surface application;
e. 50 feet from any streams classified as WS or B, any other stream, canal, marsh or coastal
waters and any other lake or impoundment for subsurface application;
f 50 feet from property lines for both surface and subsurface application methods;
g. 50 feet from public right of ways for both surface and subsurface application methods;
2

h. 10 feet from upslope interceptor drains and surface water diversions for both surface and
subsurface application methods; and
25 feet from downslope interceptor drains, surface water diversions, groundwater
drainage systems, and surface drainage ditches for both surface and subsurface
application methods_
4. No ash other than those generated by the following residuals source -generating facilities shall
be approved for distribution under the ash distribution program in accordance with this
permit:
Residuals
Permit
Permittee
Source -Generating
County
Facility
Number
International Paper Company
Riegelwood Mill
Columbus
NCO003298
5. Ash as a soil additive shall only be land -applied on lands that are owned or controlled by the
International Paper Company.
6. No other ash soil additive other than that from the residuals source -generating facilities
specified in Condition H. 4. shall be distributed under this permit. No other uses of the
distributed ash other than those specified in Condition II. 5. shall be allowed. The Permittee
shall request and obtain a permit amendment from the Division for each additional residual
source -generating facility and use prior to distribution through the approved ash distribution
program.
7. All ashsoil additive shall be adequately stored to prevent runoff into watercourses prior to and
following distribution and use. The finished product may be placed on a concrete pad, placed
under shelter, placed on the "old" landfill area or covered until such time as it is delivered to
the appropriate site.
Adequate provisions shall be taken to prevent wind erosion and surface runoff from
conveying ash from the location of use adjacent property or into any surface waters.
Adequate provisions shall be taken to ensure that the transportation of ash soil additive does
not cause nuisances and hazards to public health and safety or otherwise cause an adverse
impact (e.g., transport wet ash in leak -proof trucks or cover dry ash.
10. A suitable woodland shall be maintained in accordance with the woodland management plan
submitted on April 7, 1998 with the original application package that was approved by the
Division.
11. An acceptable pH (< 6.0) must be maintained in the soil, soil additive and lime mixture, on
all land application sites to ensure optimum yield for woodland.
12. Ash soil additives shall not be land applied to any land application site that is flooded, frozen,
or snow-covered.
13. For land application sites that are prone to flooding or within the 100-year flood elevation,
ash soil additives shall be land applied only during periods of dry weather.

14. Ash soil additives shall not be land applied during inclement weather or until 24 hours
following a rainfall event of 0.5-inch or greater in 24 hours. Any emergency land application
measures shall first be approved in writing by the Division.
15. Ash soil additive shall not be applied at application rates greater than silvicultural rates,
unless authorized by the Division.
16. A copy of this permit shall be maintained at the land application site when soil additives are
being applied during the life of this permit. A spill prevention and control plan shall be
maintained in all soil additives transport and application vehicles.
17. Specific ash soil additive application area boundaries shall be clearly marked on each site
prior to and during application. For established stands of trees, the front of the stand shall
serve as the buffer marking.
18. Ash soil Additive storage at the land application sites shall be Iimited to the volume being
applied to the particular tract, shall be removed within 90 days of original placement, and the
storage site shall be restored to its original contour.
19. Maximum -slope for ash soil additive application shall be 10%.
20. Because of high concentration of sodium in the ash produced at this facility, care must be
taken to limit the application of sodium to the land application sites. Land application rates of
ash soil additives shall be determined such that the rate of sodium application does not exceed
2001bs. of sodium per acre of land.
21. For ash soil additive to be distributed as soil additive through the approved ash distribution
program, the following shall be satisfied:
The Ceiling Concentrations (Dry Weight Basis) and the Pollutant Monthly Average
Concentrations (Dry Weight Basis) shall be maintained:
Parameter
Ceiling Concentration
(milligrams per kilogram)
Monthly Average
Concentration
(milligrams per kilogram)
Arsenic
75
41
Cadmium
85
39
Copper
4,300
1,500
Lead
840
300
Mercury
57
17
Molybdenum
75
nla
Nickel
420
420
Selenium
100
100
Zinc
7,500
2,800
4

M. MONITORING AND REPORTING REQUIREMENTS
Any monitoring (i.e., including groundwater, surface water, residuals, soil, or plant tissue
analyses) deemed necessary by the Division to ensure protection of the environment shall be
established and an acceptable sampling and reporting schedule shall be followed.
2. Proper records shall be maintained by the Permittee to track all ash soil additive distribution
activities. These records shall include, but are not necessarily limited to, the following
information:
a. Source and type of ash soil additive land applied.
b. Date of ash soil additive land application.
c. Amount of ash soil additive land applied and the intended use.
d. Method of land application.
e. Weather condition at the time of land application.
f Location of land application.
3. The ash soil additive from each residuals source -generating facilities Iisted in Condition H. 4.
shall be analyzed to demonstrate that they are non -hazardous under the Resource
Conservation and Recovery Act (RCRA). A corrosivity, ignitability, and reactivity analysis
as well as a Toxicity Characteristics Leaching Procedure (TCLP) analysis shall be conducted
by the Permittee biannually, and the results of the analyses shall be maintained on file by the
Permittee for a minimum of five years.
The TCLP analysis shall include the following parameters (i.e., note the regulatory level in
milligrams per liter in parentheses):
Arsenic (5.0)
Barium (100.0)
Benzene (0.5)
Cadmium (1.0)
Carbon tetrachloride (0.5)
Chlordane (0.03)
Chlorobenzene (100.0)
Chloroform (6.0)
Chromium (5.0)
m-Cresol (200,0)
o-Cresol (200.0)
p-Cresol (200.0)
Cresol (200.0)
2,4-D (10.0)
1,4-Dichlorobenzene (7,5) Nitrobenzene (2.0)
1,2-Dichloroethane (0.5)
Pentachlorophenol (100.0)
1,1-Dichloroethylene (0.7)
Pyridine (5.0)
2,4-Dinitrotoluene (0.13)
Selenium (1.0)
Endrin (0.02)
Silver (5.0)
Hexachlorobenzene (0.13)
Tetrachloroethylene (0.7)
Heptachlor (and its hydroxide) (0.008)
Toxaphene (0.5)
Hexachloro-1,3-butadiene (0.5)
Trichloroethylene (0.5)
Hexachloroethane (3.0)
2,4,5-Trichlorophenol (400.0)
Lead (5.0)
2,4,6-Trichlorophenol (2.0)
Lindane (0.4)
2,4,5-TT (Silvex) (1.0)
Mercury (0.2)
Vinyl chloride (0.2)
Methoxychlor (10.0)
Methyl ethyl ketone (200.0)
5

4. An analysis shall be conducted by the Permittee on the ash soil additive from each residuals
source -generating facilities listed in Condition II. 4. at a frequency that is dependent on the
dry tons of ash distributed or expected to be distributed during the calendar year. - The
monitoring frequency schedule shall be as stipulated in the following; table:
Amount of Product
Amount of Product
Distributed
(metric tons per
Distributed
(short tons per
Monitoring Frequency
365-day period)
365-day period)
0 < mDT/yr < 290
0 < DT/yr < 319
Once per Year
290 :5 mDT/yr < 1,500
319 < DT/yr < 1,650
Once per Quarter
(Four Times per Year)
1,500 5 mDT/yr < 15,000
1,650 < DT/yr < 16,500
Once per 60 Days
(Six Times per Year)
15,000 5 mDT/yr
16,500 < DT/yr
Once per Month
(12 Times per Year)
The results of all analyses shall be maintained on file by the Permittee for a minimum of five
years. The analysis shall include the following minimum parameters:
Arsenic
Magnesium
Phosphorus
Barium
Mercury
Potassium
Cadmium
Manganese
Selenium
Calcium
Molybdenum
Silver
Chromium
Nickel
Sodium
Copper
pH
Zinc
Lead
Dioxin (2,3,7,8 TCDD) shall be
analyzed annually.
5. Laboratory analyses and/or operational data, as required by Condition III. 3. and Condition
111. 4. shall be performed/gathered on the ash soil additive as it is to be distributed.
Furthermore, analytical determinations made pursuant to the monitoring and reporting
requirements of this permit shall be made by a laboratory certified by the Division for the
required parameter(s) under 15A NCAC 2H .0800 or 15A NCAC 2H .1100.
6. Three copies of all required monitoring and reporting requirements as specified in Condition
IIL 1., Condition III. 2., Condition 111. 3., and Condition III, 4. shalI be submitted annually on
or before March I" of the year following any distribution event to the following address:
NCDENR-DWQ
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
8. Noncompliance Notification:
The Pennittee shall report by telephone to the Aquifer Protection. Section of the appropriate
Division's Wilmington Regional Office at 910-796-7215, 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:
ri

a. Any occurrence with the ash distribution program that results in the distribution of
significant amounts of wastes which are abnormal in quantity or characteristic.
b. Any failure of the ash distribution program resulting in a release of material to receiving
waters.
c. Any time that self -monitoring information indicates that the ash distribution program 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 render the ash
distribution program incapable of adequate operation.
e. Any spillage or discharge from a vehicle oK piping system (i.e., greater than incidental)
during transportation of ash.
Persons reporting such occurrences by telephone shall also file a written report -in letterform
within five days following first knowledge of the occurrence. This report shall outline the
actions taken or proposed to be taken to ensure that the problem does not recur.
IV. GROUNDWATER REQUIREMENTS
1. Applicable Boundary Requirements:
a. The COMPLIANCE BOUNDARY for residuals land application programs is specified
by regulations in 15A NCAC 2L (i.e., "Groundwater Classifications and Standards").
The Compliance Boundary for each land application site is established at either 250 feet
from the residuals land application area or 50 feet within the property boundary,
whichever is closest to the residuals land application area. An exceedance of
Groundwater Quality Standards at or beyond the Compliance Boundary is subject to
immediate remediation action according to 15A NCAC 2L .0106 (d)(2).
b. The REVIEW BOUNDARY shall be established around each land application site
midway between the Compliance Boundary and the perimeter of the residuals land
application area. Any exceedance of Groundwater Quality Standards at the Review
Boundary shall require action in accordance with 15A NCAC 2L .0106 (d)(2).
Other Requirements:
a. Any groundwater quality monitoring, as deemed necessary by the Division, shall be
provided.
V. INSPECTIONS
The Permittee or his designee shall inspect the facilities related to the ash distribution
program (i.e., including the ash storage and transport 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 five years from the date of the
inspection and shall be made available to the Division or other permitting authority, upon
request.
7

2. Any duly authorized officer, employee, or representative of the Division may, upon
presentation of credentials, enter and inspect any property, premises, or place on or related to
the ash distribution program 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 ash distribution program are operated in
accordance with the conditions of this permit, the supporting materials, and in the manner
approved by the Division.
2. This permit shall be effective only with respect to the nature of ash described in the
application and other supporting data.
3. Failure to abide by the conditions and limitations contained in this permit may subject the
Permittee to an enforcement action by the Division in accordance with North Carolina
General Statutes § 143-215.6A through § 143-215.6C.
4. The annual administering and compliance fee shall be paid by the Permittee within 30
calendar 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).
5. The issuance of this permit does not preclude the Permittee from complying with any and all
statutes, rules, regulations, or ordinances that may be imposed by other government agencies
(i.e., local, state, and federal) which have jurisdiction, including, but not limited to, applicable
river buffer rules in 15A NCAC 2B .0200, soil erosion and sedimentation control
requirements in 15A NCAC Chapter 4 and under the Division's General Permit NCG010000,
and any requirements pertaining to wetlands under 15A NCAC 2B .0200 and 15A NCAC
.0500.
6. This permit may be modified, revoked, and/or reissued to incorporate any conditions,
limitations and monitoring requirements the Division deems necessary in order to protect the
environment and public health adequately.
7. The Permittee, at least six months prior to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Division shall review the adequacy of the ash
distribution program described therein, and if warranted, shall extend the permit for such
period of time and under such conditions and limitations as it may deem appropriate.
This permit shall not be automatically transferable. In the event that there is a desire for the
ash distribution program to change ownership or to change the name of the Permittee, a
formal permit request shall be submitted to the Division documentation from the parties
involved and other supporting materials as may be appropriate. The approval of this request
shall be considered on its merits and may or may not be approved.

Permit issued this the twenty-sixth day of August, 2005.
NORTH CAR)OVINA ENVIRONMENTAL MANAGEMENT COMMISSION
Lor Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0015180
0