WQ0015180_Final Permit_19990514

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
May 14, 1999
Louis O. Grissom, Mill Manager
International Paper Riegelwood Mill
John L. Riegel Road
Riegelwood, North Carolina 28456
Dear Mr. Grissom:
1 M?9FA •
NCDENR
NOR7H CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Permit No. WQ0015180
International Paper -Riegelwood
Distribution of Process Soil additives
Columbus County
In accordance with your application received on April 7, 1998, we are forwarding herewith Permit No.
WQ0015180, dated May 14, 1999, to International Paper for the distribution of a process soil additive to
International Paper woodlands.
This permit shall be effective from the date of issuance until April 30, 2004, 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, 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 matte , please contact Joe Pearce at [phone]
extension 544.
cerely
-,L Kerr T. Stevens
cc: Columbus County Health Department
Wilmington Regional Office, Water Quality Section
Technical Assistance and Certification Unit
Non -Discharge Compliance/Enforcement Unit
PO Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] Fax [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
PERMIT FOR THE DISTRIBUTION OF SOIL ADDITIVES OF EXCEPTIONAL QUALITY
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 - Riegelwood
Columbus County
FOR THE
operation of a process soil additives program consisting of the distribution of 100,000 dry tons per year of soil
additives from the sources listed in Condition ld 5, with no discharge of wastes to the surface waters, pursuant
to the application received on September 29, 1998 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 April 30, 2004 and shall be subject to the
following specified conditions and limitations:
I. PERFORMANCE STANDARDS
The distribution of process soil additives program 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.
2. This permit shall become voidable in the event of failure of the soil additives program to
adequately protect the assigned water quality standards of the surface waters and groundwaters.
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 program.
4. In the event that the soil additives 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 Qualiny (Division).
5. Diversion or bypassing of the untreated soil additives or excess water from the soil additive
treatment facilities is prohibited.
6. 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_

FJJ
The following buffer zones shall be maintained:
a) 400 feet from residences or places of public assembly under separate ownership for surface
application method; however, the buffer zone requirement may be reduced to a minimum of
100 feet upon written consent of the owner and approval from the appropriate regional office,
b) 200 feet from residences or places of public assembly under separate ownership for subsurface
soil additive injection method; however, the buffer zone requirement may be reduced to a
minimum of 100 feet upon written consent of the owner and the appropriate regional office,
c) 100 feet from any public or private water supply source, waters classified as SA or SB, and
any Class I or Class 11 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, marsh or coastal waters
and any other Iake or impoundment,
f) 50 feet from property lines;
g) 50 feet from public right of ways,
h) 10 feet from upslope interceptor drains and surface water diversions,
i) 25 feet from do%vnslope interceptor drains, surface water diversions, groundwater drainage
systems and silvacultural drainage ditches.
Soil additives shall only be land -applied on lands which are owned or controlled by international
Paper Woodlands.
A copy of this permit shall be maintained atthe 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.
10. Specific 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.
11. Soil Additive storage at the land application sites shall be limited 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.
12. Maximum slope for soil additive application shall be 10%.
OPERATION AND N AINTENANCE REQUIREMENTS
The facilities and application sites shall be properly maintained and operated at all times.
2. A suitable woodland shall be maintained in accordance with the submitted woodland management
plan outlined by Elwood Black, and approved by this Division.
3. An acceptable pH must be maintained in the soil, soil additive and lime mixture, less than 6.0, on
all land application sites to ensure optimum yield for the woodland.
4. Upon permit renewal, the permittee shall propose a maximum sodium application rate. This rate
shall be based on the amount of sodium required to maintain the exchangeable sodium percentage
below 10 percent in the soil root zone (1 foot).
2

5. No soil additives other than the following are hereby approved for distribution in accordance with
this permit:
100,000 dry tons per year of Wood Ash, Green Liquor Dregs, Slaker Grits, and Primary Clarifier
Solids from the International Paper -Riegelwood Facility in Columbus County.
6. All soil additives shall be adequately stored to prevent runoff into watercourses. 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 application site.
7. No other soil additives other than those specified under Condition 112 above may be distributed.
The Permittee shall request and obtain a permit amendment from the Division for each additional
soil additive source prior to acceptance of that soil additive.
8. For a soil additive to be land applied, the following must be satisfied:
The Ceiling Concentrations (Dry Weight Basis) and the Pollutant Monthly Average
Concentrations (Dry Weight Basis) must be maintained:
Ceiling
Monthly Average
Concentrations
Concentrations
Parameters
mg/kg
Arsenic
75
41
Cadmium
85
39
Copper
4.300
1,500
Lead
840
300
Mercury
57
17
Molybdenum
75
----
Nickel
420
420
Selenium
100
100
Zinc
7,500
2,800
9. Upon classification of the facility by the Water Pollution Control System Operators Certification
Commission (WPCSOCC), the Permittee shall employ a certified residuals operator to be in
responsible charge (ORC) of the soil additives program. The operator must hold a certificate of
the type classification assigned to the soil additives program by the WPCSOCC. The Permittee
must also employ a certified back-up operator of the appropriate type to comply with the
conditions of 15A NCAC 8A .0202.
I0. Adequate procedures shall be provided to prevent surface runoff from carrying any soil additives
into any surface waters.
11. For areas that are prone to flooding or within the 100-year flood elevation, soil additives may be
applied only during periods of dry weather.
12. Soil additives shall not be applied in inclement weather.
13. Soil additives shall not be applied to any land application site that is flooded, frozen or snow-
covered.
14. Soil additives shall not be applied at rates greater than silvacultural rates, unless authorized by the
Division.

15. Rates of application and sodium concentrations of soil amendments shall be reviewed bya North
Carolina Licensed Soil Scientist. Recommendations given by the scientist shall be followed as a
condition of the permit.
III. MONITORING AND REPORTING REQUIREMENTS
1. Any monitoring (including groundwater, surface water, soil additives, soil, or plant tissue
analyses) deemed necessary by the Division 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 soil additive activities. These
records shall include, but are not necessarily limited to the following information:
a. Residual type, volume and analysis for each residual type.
b. Date of residual application
c. location of residual application
d. method of application
e. weather conditions (sunny, cloudy, raining, etc.)
f. soil conditions
An analysis for the mixed dewatered product shall be conducted quarterly from the date of permit
issuance by the Permittee. The results of all analysis shall be maintained on file by the Permittee
for a minimum of five years. The soil additives analysis shall include the following parameters:
Arsenic
Cadmium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Aluminum
Ammonia -Nitrogen
Calcium
Magnesium
Nitrate -Nitrite Nitrogen
% Total Solids
pH
Phosphorus
Potassium
Sodium
TKN
Dioxin(2,3,7,8 TCDD)
—shall be analyzed annually
Plant Available Nitrogen (by calculation)
After the soil additives have been monitored for two years at the above frequency, the Permittee
may submit a request to the Division for a permit modification for the reduction of the frequency
of monitoring for pollutant concentrations and for the pathogen density requirements, but in no
case shall the frequency of monitoring be less than once per year when soil additives are applied to
the land.
4

4. A Toxicity Characteristics Leaching Procedure (TCLP) analysis for the mixed dewatered
product shall be conducted by the Permittee biannually. The TCLP analysis shall include the
following parameters (please note the regulatory level in mg/L in parentheses):
Arsenic (5.0)
Cadmium (1.0)
Chlorobenzene (100.0)
o-Cresol (200.0)
Cresol (200.0)
1,2-Dichloroethane (0.5)
Endrin (0.02)
Hexachlorobenzene (0.13)
Lead (5.0)
Methoxychlor (10.0)
Pentachlorophenol(100,0)
Silver (5.0)
Trichloroethylene (0.5)
2,4,5-TP (Silvex) (1.0)
Barium (100.0)
Benzene (0.5)
Carbon tetrachloride (0.5)
Chlordane (0.03)
Chloroform (6.0)
Chromium (5.0)
rn-Cresol (200.0)
p-Cresol (200.0)
2,4-D (10.0)
1,4-Dichlorobenzene (7.5)
1,1-Dichloroethylene (0.7)
2,4-Dinitrotoluene (0.13)
Heptachlor (and its hydroxide) (0.008)
Hexachloro-1,3-butadiene (0.5)
Hexachloroethane (3.0)
Lindane (0.4)
Mercury (0.2)
Methyl ethyl ketone (200.0)
Nitrobenzene (2.0)
Pyridine (5.0)
Selenium (1.0)
Tetrachloroethylene (0.7)
Toxaphene (0.5)
2,4,5-Trichlorophenol (400.0)
2,4,6-Trichlorophenol (2.0)
Vinyl chloride (0.2)
After the soil additives have been monitored for two years at the above frequency, the Permittee
may submit a request to the Division for a permit modification for the reduction of the frequency
of monitoring for pollutant concentrations and for the pathogen density requirements, but in no
case shall the frequency of monitoring be less than once per 5 year permit cycle.
5. Three copies of all required monitoring and reporting requirements as specified in conditions III 1,
III 2, 1113, and III 4 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/Enforcement Unit
Post Office Box 29535
Raleigh, North Carolina 27626-0535
6. Noncompliance Notification:
The Permittee shall report by telephone to the NVilmington 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 distribution program which results in the land application of
significant amounts of wastes which are abnormal in quantity or characteristic.
b. Any failure of the distribution 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 know or unknown reasons, that render the facility incapable
of adequate soil additive treatment.
e. Any spillage or discharge from a vehicle or piping system during transportation of soil
additives.

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 REQUMEM.ENTS
1. Any groundwater quality monitoring, as deemed necessary by the Division, shall be provided.
2. 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.
V. INSPECTIONS
The Permittee or his designee shall inspect the soil additives storage, transport, 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 five years
from the date of the inspection and shall be made available to the Division or other permitting
authority, upon request.
2. Any duly authorized officer, employee, or representative of the Division may, upon presentation
of credentialsj( enter and inspect any property, premises or place on or related to the treatment 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
This permit shall become voidable unless the distribution activities are carried out in accordance
with the conditions of this permit, the supporting materials, and in the manner approved by this
Division.
This permit is effective only with respect to the nature and volume of soil additives described in
the application and other supporting data.
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 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 in accordance with North Carolina General
Statute 143-215.6A to 143-215.6C.
The annual administering and compliance fee must be paid by the Permittec 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),
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 deems necessary in order to adequately protect the
environment and public health.
Permit issued this to Fourteenth day of May, 1999
NORTH ROLINA E IRON ENTAL MANAGEMENT COMN9SSION
X.
,(l` Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0015180