WQ0015180_Final Permit_20140319

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North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder
Governor Director
March 19, 2014
FLOYD E. WHITMIRE — MANAGER
INTERNATIONAL PAPER. COMPANY
POST OFFICE BOX i 10
RIEGELWOOD, NORTH CAROLINA 28456
Dear Mr. Whitmire:
John E. Skvaria, III
Secretary
Subject: Permit No. WQ0015180
Riegelwood Mill Distribution
Program
Distribution of Residual Solids
(503 Exempt)
Columbus County
In accordance with your permit renewal request received February 6, 2014, we are forwarding
herewith Permit No. WQ0015180 dated March 19, 2014, to International Paper Company for the
continued operation of the subject residuals management program. Please note that this renewed permit
shall become effective on August 1, 2014 (i.e- the day after the expiration date of the existing permit).
This permit shall be effective from August 1, 2014 until July 31, 2019, shall void Permit No.
WQ0015180 issued August 26, 2005, and shall be subject to the conditions and limitations as specified
therein. Please pay particular attention to the monitoring requirements listed in Attachment A for they
may differ from the previous permit issuance. Failure to establish an adequate system for collecting and
maintaining the required operational information shall result in future compliance problems.
Please note that on September 1, 2006, North Carolina Administrative Code Title 15A
Subchapter 02T — Waste not Discharged to Surface Waters was adopted. Accordingly, this permit
incorporates the requirements of these rules, therefore, please tale the time to review this permit
thoroughly.
Please note the following permit conditions have been removed since the last permit
issuance dated August 26, 2005:
➢ OId Condition I-5_ — This condition has been removed because it is inherently covered under
Condition N.2.
➢ Old Condition 11.9. — This condition has been removed because it is inherently covered under
Condition II.1.
WATER QUALITY PERMITTING SECTION
1636 Mail service Center, Raleigh, North Carolina 27699-1636
Location: 512 N. Salisbury St., Raleigh, North Carolina 27604
Phone: 91M07-64641 FAX: 91 M07-6496
lntemet: htt0Uoortal.ncdenr.o191web1wu
An Equal Opporlunily %Affirmative Action Employer

Mr. Floyd E. Whitmire
March 19, 2014
Page 2 of 2
Please note the following permit conditions and attachments are new since the last permit
issuance dated August 26, 2005:
➢ Condition II.6. ---- PIease review this condition to note several new setback requirements that
were adopted with North Carolina Administrative Code Title 15A Subchapter 02T — Waste
not Discharged to Surface Waters.
➢ Condition III.2. — This condition lists the requirements for an Operation and Maintenance
Plan in accordance with 15A NCAC 02T .1110.
➢ Condition 111.9. — This condition notes several new requirements for when the residuals
cannot be land applied in accordance with the requirements adopted in North Carolina
Administrative Code Title 15A Subchapter 02T — Waste not Discharged to Surface Waters.
➢ Condition V.I. — This condition requires the Permittee to provide adequate inspection and
maintenance of the subject facilities.
➢ Condition VL7. -- This condition notes that the facilities in this permit may not be expanded if
the Permittee exemplifies any of the criteria in 15A NCAC 02T .0120(b).
If any parts, requirements or limitations contained in this permit are unacceptable, the Permittee
has the right to request an adjudicatory hearing upon written request within 30 days following receipt of
this permit. This request shall 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 at 6714 Mail
Service Center, Raleigh, NC 27699-6714. Unless such demands are made, this permit shall be final and
binding.
If you need additional information concerning this matter, please contact Nathaniel Thornburg at
[phone] or nathaniel.thornburglncdenr.gov.
Sincerely,
P,- /ThoZA--Recder
cc: Columbus County Health Department
Wilmington Regional Office, Water Quality Regional Operations Section
Beth Buffington, Public Water Supply Section Protection and Enforcement Branch
Permit File WQ0015190
Notebook File WQ0015190

NORTH CAROLINA
ENVfRONMENTAL 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
Internati®nai Paper Company
Columbus County
FOR THE
continued operation of a residuals management program for International Paper Company and consisting
of the distribution and land application of residuals (i.e., sludge, grit, dregs and wood ash) generated by
the approved facilities listed in Attachment A with no discharge of wastes to surface waters, pursuant to
the application received February 6, 2014, and in conformity with other supporting data subsequently
filed and approved by the Department of Environment and Natural Resources and considered a part of
this permit. The use and disposal of residuals are regulated under Title 40 Code of Federal Regulations
Part 257. This permit does not exempt the Permittee from complying with the federal regulations.
This permit shall be effective from August 31, 2014 until July 31, 2019, shall void Permit No.
WQ0015180 issued August 26, 2005, and shall be subject to the following specified conditions and
limitations:
L SCHEDULES
No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted, will renew the permit for such period of
time and under such conditions and limitations as it may deem appropriate. Please note Rule 15A
NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal
application.
it. PERFORMANCE STANDARDS
The subject residuals management program shall be effectively maintained and operated at all times
so there is no discharge to surface waters, nor any contravention of groundwater or surface water
standards. In the event the facilities fail to perform satisfactorily, including the creation of nuisance
conditions due to improper operation and maintenance, the Permittee shall immediately cease
distribution of the residuals, contact the Wilmington regional office supervisor, and take any
immediate corrective actions.
2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or
surface water resulting from the operation of this residuals management program.
WQ0015180 Version 3.0 Shell Version 140210 Page I of 8

3. Only residuals generated by the facilities listed in Attachment A are approved for distribution and
land application in accordance with this permit.
4. Residuals shall only be applied on land owned or controlled by the Permittee.
5. Pollutant concentrations in the residuals distributed or applied to any land application site shall not
exceed the following Ceiling Concentrations or Monthly Average Concentrations (i.e., dry weight
basis):
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
n/a
Nickel
420
420
Selenium
100
100
Zinc
75500
2,800
6. Setbacks for residual land application sites shall be as follows:
Setback Description
Setbacks (ft)
Surface
Application
Injection /
Incorporation
Habitable residence or place of public assembly under separate
ownership or not to be maintained as part of the project site
400
200
Habitable residence or places of public assembly owned by the
Permittee, the owner of the land, or the lessee/operator of the land to
be maintained as part of the ploject site
0
0
Property lines
50
50
Public right of way
50
50
Private or public water supply
100
100
Surface waters (streams — intermittent and perennial, perennial
waterbodies, and wetlands)
100
50
Surface water diversions (ephemeral streams, waterways, ditches)
25
25
Groundwater lowering ditches (where the bottom of the ditch
intersects the SHWT)
25
25
Subsurface groundwater lowering system
0
0
Wells with exception to monitoring wells
100
100
Bedrock outcrops
25
25
Top of slope of embankments or cuts of two feet or more in vertical
height
15
is
Building foundations or basements
0
0
Water lines
0
0
Swimming pools
100
100
Nitrification fields
0
0
7. Land application areas shall be clearly marked on each site prior to and during any. residuals
application event.
WQ0015180 Version 3.0 Shell Version 140210 Page 2 of 8

8. Due to the high concentration of sodium in the residuals produced at this facility, land application
rates shall be determined such that the rate of sodium application does not exceed 200 pounds of
sodium per acre.
9. The compliance boundary for the residual land application sites shall be specified in accordance with
15A NCAC 02L .0107(b). These sites were individually permitted on or after December 30, 1983;
therefore, the compliance boundary is established at either 250 feet from the residual land application
area, or 50 feet within the property boundary, whichever is closest to the residual land application
area. An exceedance of groundwater standards at or beyond the compliance boundary is subject to
remediation action according to 15A NCAC 02L .0106(d)(2) as well as enforcement actions in
accordance with North Carolina General Statute 143-215.6A through 143-215.6C.
10. In accordance with 15A NCAC 02L .0108, the review boundary shall be established midway between
the compliance boundary and the residual Iand application area. Any exceedance of groundwater
standards at the review boundary shall require action in accordance with 15A NCAC 02L .0106.
OPERATION AND MAINTENANCE RFQUH?EMENTS
The residuals management program shall be properly maintained and operated at all times_ The
program shall be effectively maintained and operated as a non -discharge system to prevent any
contravention of surface water or groundwater standards.
2. The Permittee shall maintain an approved Operation and Maintenance Plata (O&M Plan.) pursuant to
15A NCAC 02T .1110. Modifications to the O&M Plan shall be approved by the Division prior to
utilization of the new plan. The O&M Plan, at the minimum, shall include:
a) Operational functions;
b) Maintenance schedules;
c) Safety measures;
d) Spill response plan;
e) Inspection plan including the following information:
i. Names and/or titles of personnel responsible for conducting the inspections;
H, Frequency and location of inspections, including those to be conducted by the ORC, and
procedures to assure that the selected location(s) and inspection frequency are representative
of the residuals management program;
iii_ Detailed description of inspection procedures including record keeping and actions to be
taken by the inspector in the event that noncompliance is observed pursuant to the
noncompliance notification requirements under the monitoring and reporting section of the
permit;
f) Sampling and monitoring plan including the following information:
i. Names and/or titles of personnel responsible for conducting the sampling and monitoring;
H. Detailed description of monitoring procedures including parameters to be monitored;
iii. Sampling frequency and procedures to assure that representative samples are being collected.
Fluctuation in temperature, flow, and other operating conditions can affect the quality of the
residuals gathered during a particular sampling event.
WQ0015180 Version 3.0 She11 Version 140210 Page 3 of 8

3. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC)
classification of the facility, the Permittee shall designate and employ a certified operator in
responsible charge (ORC) and one or more certified operators as back-up ORCs in accordance with
15A NCAC 08G .0201. The ORC or their back-up shall visit the facilities in accordance with 15A
NCAC 08G. 0204, or as specified in the most recently approved O&M plan (i.e., see Condition
III.2.), and shall comply with all other conditions of 15A NCAC 08G. 0204. For more information
regarding classification and designation requirements, please contact the Division of Water Resources
at [phone].
4. The Permittee shall maintain a copy of this permit and the O&M Plan at the site during application
events.
5. The Permittee shall maintain a copy of the spill control provisions in all residuals transport and land
application vehicles.
6. Residuals storage at the land application sites shall be limited to the volume being applied to the
particular tract; shall be removed or applied within 90 days of original placement; and the storage site
shall be restored to its original contour.
The Permittee shall take adequate measures to prevent wind erosion and surface runoff from
conveying residuals from the land application sites onto adjacent properties or into surface waters.
8. The Permittee shall maintain a suitable woodland in accordance with the Division -approved
management plan submitted on April 7, 1998.
9. Residuals shall not be land applied under the following conditions:
a. If the residuals are likely to adversely affect a threatened or endangered species listed under
section 4 of the Endangered Species Act or its designated critical habitat;
b. If the application causes prolonged nuisance conditions;
c_ If the land fails to assimilate the residuals or the application causes the contravention of surface
water or groundwater standards;
d. If the Iand is flooded, frozen or snow-covered, or is otherwise in a condition such that runoff of
the residuals would occur;
e. Within the 100-year flood elevation, unless the residuals are injected or incorporated within a 24-
hour period following a land application event;
f. During a measurable precipitation event (i.e., greater than 0.01 inch per hour), or within 24 hours
following a rainfall event of 0.5 inches or greater in a 24-hour period;
g. A slope greater than 10%;
h. If the soil pH is not maintained at 6.0 or greater, unless sufficient amounts of lime are applied to
achieve a final soil pH of at least 6.0, or if an agronomist provides information indicating that the
pH of the soil and residuals are suitable for the specified crop. Any approved variations to the
acceptable soil pH (6.0) will be noted in this permit;
i. If the vertical separation between the seasonal high water table and the depth of residuals
application is less than one foot;
j. If the vertical separation of bedrock and the depth of residuals application is less than one foot;
and
k_ Application exceeds silvicultural rates.
10. This permit shall become voidable if operation of the disposal sites causes contravention of surface
water or groundwater standards, and may be revoked unless the disposal sites are maintained and
operated in a manner that will protect the assigned surface water and groundwater quality standards_
WQ0015180 Version 3.0 Shell Version 140210 Page 4 of 8

11. The residuals 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.
12. Diversion or bypassing of untreated or excess water from the treatment facilities is prohibited.
13. All excess water from the treatment facilities shall be reused as a wetting agent for the processing of
the wood ash, or routed to the head of the treatment plant (Permit No. NC0003298).
IV. MONITORING AND REPORTING RE UIItEMENTS
Any Division required monitoring (including groundwater, plant tissue, soil and surface water
analyses) necessary to ensure groundwater and surface water protection shall be established, and an
acceptable sample reporting schedule shall be followed.
2. Residuals shall be analyzed to demonstrate they are non -hazardous under the Resource Conservation
and Recovery Act (RCRA). The analyses [corrosivity, ignitability, reactivity, and toxicity
characteristic leaching procedure (TCLP)] shall be performed at the frequency specified in
Attachment A, and the Permittee shall maintain these results for a minimum of five years. Any
exceptions from the requirements in this condition shall be specified in Attachment A.
The TCLP analysis shall include the following parameters (the regulatory level in milligrams per liter
is in parentheses):
Arsenic (5.0)
1,4-Dichlorobenzene (7.5)
Nitrobenzene (2.0)
Barium (I00.0)
1,2-Dichloroethane (0.5)
Pentachlorophenol (100.0)
Benzene (0.5)
1, 1 -Dich loroethylene (0.7)
Pyridine (5.0)
Cadmium (1.0)
2,4-Dinitrotoluene (0.13)
Selenium (1.0)
Carbon tetrachloride (0.5)
Endrin (0.02)
Silver (5.0)
Chlordane (0.03)
Hexachlorobenzene (0.13)
Tetrachloroethylene (0.7)
Chlorobenzene (100.0)
Heptachlor (and its hydroxide)
(0.00$
Toxaphene (0.5)
Chloroform (6.0)
Hexachloro-1,3-butadiene (0.5)
Trichloroethylene (0.5)
Chromium (5.0)
Hexachloroethane (3.0)
2,4,5-Trichlorophenol (400.0)
m-Cresol (200.0)
Lead (5.0)
2,4,6-Trichlorophenol (2.0)
o-Cresol (200.0)
Lindane (0.4)
2,4,5-TP (Silvex) (1.0)
p-Cresol (200.0)
Mercury (02)
Vinyl chloride (0.2)
Cresol (200.0)
Methoxychlor (10.0)
2,4-D (10.0)
Methyl ethyl ketone (200.0)
Once the residuals have been monitored for two years at the frequency specified in Attachment A, the
Permittee may submit a permit modification request to reduce the frequency of this monitoring
requirement. In no case shall the monitoring frequency be less than once per permit cycle.
WQ0015180 Version 3.0 Shell Version 140210 Page 5 of 8

3. An analysis shall be conducted on the residuals from each source generating facility at the frequency
specified in Attachment A, and the Permttee shall maintain the results for a minimum of five years.
The analysis shall include the following 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) — Annually
4. Laboratory parameter analyses shall be performed on the residuals as they are distributed, and shall
be in accordance with the monitoring requirements in 15A NCAC 02B .0505.
5. The Permittee shall maintain records tracking all residual distribution or land application events
performed by the Permiee. At a minimum, these records shall include the following:
a. Source of residuals;
b. Date of land application;
c. Amount of residuals land applied;
d. Intended use of residuals;
e. Method of land application;
f. Weather conditions (e.g., sunny, cloudy, raining, etc.);
g. Location of land application;
6. Three copies of an annual report shall be submitted on or before March 1'. The annual report shall
meet the requirements described in the Instructions for Residuals Application Annual Repartin
Forms. Instructions for reporting and annual report forms are available at
http://portal.nr-denr.orglweb/wqlaps/lauJreporting, or can be obtained by contacting the Non -
Discharge Permitting Unit directly. The annual report shall be submitted to the following address:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
WQ0015180 Version 3.0 Shell Version 140210 Page 6 of 8

7. Noncompliance Notification
The Permittee shall report by telephone to the Wilmington Regional Office, telephone number (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:
a. Any occurrence with the distribution program resulting in the land application of significant
amounts of wastes that are abnormal in quantity or characteristic.
b. Any failure of the distribution program resulting in a release of material to surface waters.
c. Any time self -monitoring indicates the facility has gone out of compliance with its permit
limitations.
d. Any process unit failure, due to known or unknown reasons, rendering the facility incapable of
adequate residual treatment.
e. Any spill or discharge from a vehicle or piping system during residuals transportation.
.Any emergency requiring immediate reporting (e.g., discharges to surface waters, imminent failure of
a storage structure, etc.) outside normal business hours shall be reported to the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone].Persons
reporting such occurrences by telephone shall also file a written report in letter form 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.
V. INSPECTIONS
1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the
subject facilities and shall be in accordance with the approved O&M Plan.
Prior to each residuals land application event, the Permittee or his designee shall inspect the residuals
storage, transport and application facilities to prevent malfunctions, facility deterioration and operator
errors resulting in discharges, which may cause the release of wastes to the environment, a threat to
human health or a public nuisance. The Permittec shall maintain an inspection log that includes, at a
minimum, the date and time of inspection, observations made, and any maintenance, repairs, or
corrective actions taken. The Permittee shall maintain this inspection log for a period of five years
from the date of inspection, and this log shall be made available to the Division upon request.
3. Any duly authorized Division representative may, upon presentation of credentials, enter and inspect
any property, premises or place on or related to the land application sites or facilities permitted herein
at any reasonable time for the purpose of determining compliance with this permit; may inspect or
copy any records required to be maintained under the teens and conditions of this permit; and may
collect groundwater, surface water or leachate samples.
WQ0015I80 Version 3.0 SMI Version 140210 Page 7 of 8

VI. GENERAL CONDITIONS
1. Failure to comply with the conditions and limitations contained herein may subject the Permittee to
an enforcement action by the Division in accordance with North Carolina General Statutes 143-
215.6A to 143-215.6C.
2. This permit shall become voidable if the residuals land application events are not carried out in
accordance with the conditions of this permit.
This permit is effective only with respect to the nature and volume of residuals described in the
permit application and other supporting documentation.
4. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other jurisdictional government agencies
(e.g., Iocal, state, and federaI). Of particular concern to the Division are applicable river buffer rules
in 15A NCAC 02B .0200; erosion and sedimentation control requirements in 15A NCAC Chapter 4
and under the Division's General Permit NCG010000; any requirements pertaining to wetlands under
15A NCAC 02B .0200 and 02H .0500; and documentation of compliance with Article 21 Part 6 of
Chapter 143 of the General Statutes.
In the event the residuals program changes ownership or the Permittee. changes their name, a formal
permit modification request shall be submitted to the Division. This request shall be made on official
Division forms, and shall include appropriate documentation from the parties involved and other
supporting documentation as necessary. The Permittee of record shall remain fully responsible for
maintaining and operating the residuals program permitted herein until a permit is issued to the new
owner.
6. This permit is subject to revocation or unilateral modification upon 60 days notice from the Division
Director, in whole or part for the requirements listed in 15A NCAC 02T .0110_
Unless the Division Director grants a variance, expansion of the _permitted residuals program
contained herein shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC
02T .0120(b).
The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to
pay the annual fee accordingly shall be cause for the Division to revoke this permit pursuant to 15A
NCAC 02T .0105(e)(3).
Permit issued this the 19a' day of March 2014
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
A�
homiWA. Reeder, Director
Division of Water Resources
By Authority of the Environmental Management Commission
Permit Number WQ0015180
WQO015180 Version 3.0 Shell Version 140210 Page 8 of 8

ATTACHMENT A - Approved Residual Sources
International Paper Company
Certification Date: March 14, 2014
Permit Number: WQ0015180 Version: 3.0
Owner
FacilityName
County
Permit
Number
Biological
Residuals
Maximum
Dry Tons
Per Yearr
Monitoring
Frequency for
Nan -hazardous
Characteristics 2
Monitoring
Frequency for
Metals and
Nutrients 3,4
Monitoring
Frequency for
Pathogen
Reduction
Approved
Mineralization
Rate
Internationai Paper Company
Riegelwood Mill
Columbus
NC0003298
No
100,000
Twice per Year
See Table Below
N/A
N/A
Total
100,000
1. Maximum Dry Tons per Year is the amount of residuals approved for land application from each permitted facility.
2. Analyses to demonstrate that residuals are non -hazardous (i.e., TCLP, ignitability, reactivity, and corrosivity) as stipulated under permit Condition IV.2.
3. Testing of matals and nutrients as stipulated under permit Condition IV.3.
4. Monitoring frequencies aee based on the actual dry tons applied per year using the table below, unless specified above.
Dry Tons Generated
short tons peryear)
Monitoring Frequency
Established in 40 CFR 503 and 15A NCAC 02T .1111
<319
11Year.
=>319 - <I,650
1/ uarter 4 times per ear
=>1,650 - <16,500
1/60 Da s 6 times per ear
=> 16 500
1 month 12 times per ear
If no land application events occur during a required sampling period (e.g. no land application occur during an entire year when annual monitoring is required), then no
sampling data is required during the period of inactivity. The annual report shall include an explanation for missing sampling data. Those required to submit the annual
report to EPA may be required to make up the missed sampling, contact the EPA for additional information and clarification.
Page 1 of I

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Figure 2 — Directional Map
WQ0015180
865 John Riegel Rd., Riegelwood NC 28456
International Paper Company
Latitude: 34.350985'
Riegelwood Mill Distribution Program
Longitude:-78.206235'
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