Staff Report (3)

State of North Carolina
Division of Water Resources
' Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ® NPDES Unit ❑ Non -Discharge Unit
Attn: (Sergei Chernikov)
From: (Tom Tharrington)
Wilmington Regional Office
ote: This form hz
ES
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 09/20/2016
b. Site visit conducted by: Tom Tharrington
c. Inspection report attached? Z Yes or ❑ No
Application No.: (NC0003298)
Facility name: International Paper- Riegelwood Mill
d. Person contacted: Kimberly Fail and their contact information: (910) 362 - 4753
e. Driving directions: From Wilmington, travel west on US -74 West/US-76 West for 31 miles, take the exit for
NC Highway 87 North to Riegelwood. Turn right onto John L. Riegel Road and follow to the mill entrance.
2. Discharge Point(s):001
Latitude: 34'21'10.41"
Longitude: 78° 12' 09.10"
3. Receiving stream or affected surface waters: Cape Fear River
Classification: C; Sw
River Basin and Subbasin No. 03-06-17
Describe receiving stream features and pertinent downstream uses: Lower reaches of the Cape Fear River
in this Subbasin, with the Lower Cape Fear Coalition monitoring program indicating concern for nutrient
inputs, low dissolved oxygen levels, elevated `turbidity and fecal coliform contamination. This stream may
be used for secondary recreation, notably fishing activities.
FORM: WQROSSR 04-14 Page 1 of 4
MEMMMEMM
FjF ._
FORM: WQROSSR 04-14 Page 1 of 4

III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Patricia C. Soles Certificate #: WW -4, 996989
Backup ORC: Wallace H. Coverdale Certificate #: WW -3, 992622
Backup ORC': Charlie W. Knox Certificate #: WW -4, 1002599
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
If no, please explain:
Description of existing facilities: Facilities are the same as listed in the previous permit
• Dual mechanical bar screens
• Dual primary clarifiers
• Three (3) section aerated lagoon system with bacterial culture injection equipment (if needed)
• Approximately 80 floating surface aerators (75hp & 50hp)
Nutrient injection system (if needed)
• Six (6) sludge settling ponds
• Three (3) sludge screw presses (used to provide fuel for boilers)
• Defoamer and oxygen injection systems located at the effluent point
• Flow measurement and recording equipment
• Effluent sampling equipment _
Proposed flow: 50 MGD
Current permitted flow: 50 MGD
The Riegelwood Mill has just completed a product change, now producing only paper fluff and softwood
pulp and will no longer produce bleached kraft paper. Because of this change the facility will no longer use
hardwoods in the mill and will use only pine. This change has resulted in some process changes, notably an
increase in soap and turpentine production within the pulping process.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No
If no, please explain:
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or ® No
If yes, please explain:
FORM: WQROSSR 04-14 Page 2 of 4
S
MZ..
•
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Patricia C. Soles Certificate #: WW -4, 996989
Backup ORC: Wallace H. Coverdale Certificate #: WW -3, 992622
Backup ORC': Charlie W. Knox Certificate #: WW -4, 1002599
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
If no, please explain:
Description of existing facilities: Facilities are the same as listed in the previous permit
• Dual mechanical bar screens
• Dual primary clarifiers
• Three (3) section aerated lagoon system with bacterial culture injection equipment (if needed)
• Approximately 80 floating surface aerators (75hp & 50hp)
Nutrient injection system (if needed)
• Six (6) sludge settling ponds
• Three (3) sludge screw presses (used to provide fuel for boilers)
• Defoamer and oxygen injection systems located at the effluent point
• Flow measurement and recording equipment
• Effluent sampling equipment _
Proposed flow: 50 MGD
Current permitted flow: 50 MGD
The Riegelwood Mill has just completed a product change, now producing only paper fluff and softwood
pulp and will no longer produce bleached kraft paper. Because of this change the facility will no longer use
hardwoods in the mill and will use only pine. This change has resulted in some process changes, notably an
increase in soap and turpentine production within the pulping process.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No
If no, please explain:
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or ® No
If yes, please explain:
FORM: WQROSSR 04-14 Page 2 of 4

5. Is the residuals management plan adequate? ® Yes or ❑ No
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ❑ Yes or ❑ No ® N/A
If no, please explain:
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
If no, explain and recommend any changes to the groundwater monitoring program:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
If yes, attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
If no, please explain:
10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A
If no, please explain:
H.
Are the meniter-ingwell eeer-dinates eet in BR4S? El Yes D Ne N Tr/n
TF 1 1 t the f ll / d table if +
Monitoring WeU hatitud
L"9"&
a r
rr
a- r
rr
e- r
n
a r
rr
a- r
rr
a r
rr
12. Has a review of all self-monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review: No permit violations in the last 4 Years
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
If yes, please explain:
14. Check all that apply:
® No compliance issues
❑ Notice(s) of violation
❑ Current enforcement action(s) ❑ Currently under JOC
❑ Currently under SOC ❑ Currently under moratorium
Please explain and at4aeh any deeuments that may help elarif-y answer4eemnients (i.e., NONE, NOD, ete.)
if the f4eility has had eemplianee problems dur-ing the permit eyele, please explain the status. Has the RO been
wer-kingwith the Der-niiRee? is ., solution uncle,-xay e in place?
Have all eemplianee dates/eendifiens in the existing pernik been satisfied? E] Yes E] Ne P N�A
ifne, please explain: —
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
If yes, please explain:
16. Possible toxic impacts to surface waters: Dioxin
FORM: WQROSSR 04-14 Page 3 of 4

IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain:
2. List any items that yettwould like the NPDES Unit or Non Disehar-ge Unit Gentfal offiee te ebtain thfough an
Rem Reason
5. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office
❑ Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
® Issue
❑ Deny (Please state reasons: )
6. Signature of report preparer:
Signature of region 1 supervisor:
Date: ()7. I S I
I T
FORM: WQROSSR 04-14 Page 4 of 4

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 2 15 I 3 I NC0003298 I11 121 16/09/20 I17 18 1 o 1 191 G 1 201
21111111111111111111111111111111111111111111 16
Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA -------------------Reserved-----------------
67 70 [ F j 71 I I 72 I N I 73 I I 174 751 1 1 1 1 1 1 180
L_I LJ I I I
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
09:10AM 16/09/20
13/07/01
Riegelwood Mill
865 John L Riegel Rd
Exit Time/Date
Permit Expiration Date
Riegelwood NC 28456
12:15PM 16/09/20
16/11/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Patricia Coleman Soles/ORC/910-362-4729/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Floyd Whitmire,865 John L Riegel Rd Riegelwood NC 28456/Mill
No
Manager/910-362-4883/
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit N Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory Other
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Tom Tharrington WIRO WQ///.
Helen I Perez WIRO WQ//910-796-7387/
rs
Signature of Management Q A Reviewer Agency/Office/Phone and Fax NumDate
Morella Sanchez -King WIRO WQ//910-796-7218/ 011
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. �J
Page#

NPDES yr/mo/day Inspection Type (Cont.) 1
31 NC0003298 111 121 16/09/20 1 17 18 S 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Routine compliance inspection of the Riegelwood Mill site. The mill has just finished transitioning to an
all wood fluff mill and will no longer produce bleached kraft paper at this site. The mill will now only use
soft woods (pine) for fluff production. A review of NPDES required paperwork and records included
DMR reports, dioxin monitoring (fish tissue and effluent) and Cluster Rule BMP program elements. The
site is currently conducting a 6 month data gathering program to revise influent action levels to reflect
recent mill changes.
A cursory laboratory inspection was conducted and the instruments used are the same as the
previous inspection. A Hach 40D Dissolved Oxygem meter and a Yokagawa pH72 portable pH meter
are used to conduct field parameter testing. The laboratory certification number is #140
Wastewater treatment process controls are the same as those mentioned in previous inspections
with the exception of continued refinement of the Cluster Rule BMP program (see question
comments). Effluent discharge volumes are 30-35 MGD.
Page#

Permit: NC0003298 Owner - Facility: Riegelwood Mill
Inspection Date: 09/20/2016 Inspection Type: Compliance Sampling
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
0
❑
❑
❑
application?
■
❑
❑
❑
Is the facility as described in the permit?
0
❑
❑
❑
# Are there any special conditions for the permit?
0
❑
❑
❑
Is access to the plant site restricted to the general public?
0
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment: Permit renewal application was submitted on June 6, 2016. The current permit has special
conditions including Cluster Rule BMP program, effluent and fish tissue sampling for dioxin
and bleach plant effluent monitoring for chlorinated phenolic compounds
Record Keeuin
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain -of -custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
on each shift?
Yes No NA NE
■
❑
❑
❑
■
❑
❑
❑
■
❑
❑
❑
■
❑
❑
❑
■
❑
❑
❑
0
❑
❑
0
0
Comment: Reviewed Cluster Rule BMP documents which included training, spill report forms,
process
0
area conductivity probe check sheets and calibration records and annual tank inspections.
Also confirmed annual dioxin monitoring in effluent and fish tissue was completed
■
❑
❑
❑
❑
❑
■
❑
N
❑
❑
❑
Is the ORC visitation log available and current?
E
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
0
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification? -
0
❑
❑
❑
Is a copy of the current NPDES permit available on site?
E
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
0
❑
Comment: Reviewed Cluster Rule BMP documents which included training, spill report forms,
process
area conductivity probe check sheets and calibration records and annual tank inspections.
Also confirmed annual dioxin monitoring in effluent and fish tissue was completed
Page# 3

Permit: NC0003298 Owner -Facility: Riegelwood Mill
Inspection Date: 09/20/2016 Inspection Type: Compliance Sampling
Other Yes No NA NE
Comment: The site maintains a Cluster Rule BMP proqram to prevent, contain and recycle an
production area spills The program includes employeee training establishing influent action
levels and records and reviews of any production area spills. Part of the program includes
monitoring process areas for conductivity with dedicated instruments. If a high conductivity
is detected it can be attributed to a local spill or upset condition. Alarms are generated into
the control room of that process area and actions are then taken by operations to contain,
recover and recycle the material. The environmental section is currently gathering data from
the BMP monitoring plan in order to revise action plans as directed in Section D.3. and as a
result of mill reconfiguration.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable 0 ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: The Mill staff continue to monitor numerous parameters related to daily wastewater
treatment process controls. Wastewater operations and production staff monitor
wastewater generated from different process areas by sampling operator field checksheets
and from real time pH and conductivity probes. Mill staff use 2 databases to monitor and
control all aspects of treatment plant operation.
Primary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
❑
❑
N
❑
Is the site free of excessive buildup of solids in center well- of circular clarifier?
E
❑
❑
❑
Are weirs level?
E
❑
❑
❑
Is the site free of weir blockage?
E
❑
❑
❑
Is the site free of evidence of short-circuiting?
N
❑
❑
❑
Is scum removal adequate?
❑
❑
E
❑
Is the site free of excessive floating sludge?
E
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the sludge blanket level acceptable?
❑
❑
❑
0
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
❑
❑
❑
N
Comment: The Drimary clarifiers are used to remove wood pulp and debris and return this material to
the production area where it is pressed to remove water so it can be used as fuel. Material
not used as fuel is sent to one of six sludge ponds where it is dewatered before being
disposed of in one of the on-site landfills. Clarifier loading rates and blanket levels are
monitored by measuring the amperage used by each unit, with higher amps indicating a
higher/heavier blanket level.
Aeration Basins
Mode of operation
Yes No NA NE
Ext. Air
Page# 4

Permit: NC0003298
Inspection Date: 09/20/2016
Owner - Facility: Riegelwood Mill
Inspection Type: Compliance Sampling
Type of lagoons?
Aerated
Aeration Basins
Yes No NA NE
Type of aeration system
Surface
Is the basin free of dead spots?
0 ❑
❑
❑
Are surface aerators and mixers operational?
0 ❑
❑
❑
Are the diffusers operational?
❑ ❑
0
❑
Is the foam the proper color for the treatment process?
❑ ❑
0
❑
Does the foam cover less than 25% of the basin's surface?
0 ❑
❑
❑
Is the DO level acceptable?
0 ❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
❑ ❑
❑
0
Comment: Wastewater is directed into a series of aerated stabilization basins (ASB) for treatment.
❑
Are dikes free of seepage?
70-75 floating surface aerators are used in the 42 acre New Bay and in the inlet of the 42
❑
❑
acre South Lagoon to provide the needed oxygen.
Treated wastewater then flows to the 32.5
E
acre North Lagoon which acts as a polishing
pond prior to discharge. Any material that
❑
Are dikes free of burrowing animals?
accumulates in the intermediate "Theo Pond"
or in the other aerated lagoons is periodically
❑
❑
dredged with material placed in the sludge ponds
before landfilling on-site. Sulfuric Acid and
❑
an 20% ammonia solution can be added as needed to the treatment process for pH control
❑
locations?
and nutrient balance. Additional bacteria can also be added via Bacteria Acclimation
Chambers (BAC's) located adjacent to the lagoons.
# If excessive algae is present, has barley straw been used to help control the growth?
❑
❑
Lagoons
Yes No NA NE
Type of lagoons?
Aerated
# Number of lagoons in operation at time of visit?
4
Are lagoons operated in?
Series
# Is a re -circulation line present?
❑
N
❑
❑
Is lagoon free of excessive floating materials?
0
❑
❑
❑
# Are baffles between ponds or effluent baffles adjustable?
0
❑
❑
❑
Are dike slopes clear of woody vegetation?
E
❑
❑
❑
Are weeds controlled around the edge of the lagoon?
0
❑
❑
❑
Are dikes free of seepage?
❑
❑
❑
Are dikes free of erosion?
E
❑
❑
❑
Are dikes free of burrowing animals?
0
❑
❑
❑
# Has the sludge blanket in the lagoon (s) been measured periodically in multiple
N
❑
❑
❑
locations?
# If excessive algae is present, has barley straw been used to help control the growth?
❑
❑
❑
Is the lagoon surface free of weeds?
0
❑
❑
❑
Is the lagoon free of short circuiting?
N
❑
❑
❑
Page# 5

Permit: NC0003298
Inspection Date: 09/20/2016
Lagoons
Owner - Facility: Riegelwood Mill
Inspection Type: Compliance Sampling
Yes No NA NE
Comment: The aerated stablization basins (ASB) currently use 70-75 floating surface aerators. There is
process as
a diversion curtain located in the South Lagoon to prevent short circuiting
within the basin.
needed. Also at the effluent point a defoamer solution and oxygen infection system are
Yes No NA NE
Accumulated material on the bottom of the lagoon is removed as needed,
typically this is
present and used as needed.
❑
Performed annually.
Are the receiving water free of foam other than trace amounts and other debris?
E
Effluent Sampling
Chemical Feed
Yes No NA NE
Is containment adequate?
0 ❑
❑
❑
Is storage adequate?
N ❑
❑
❑
Are backup pumps available?
0 ❑
❑
❑
Is the site free of excessive leaking?
E ❑
❑
❑
Comment: Sulfuric Acid and a 20% aqueous ammonia solution can be added to the
process as
needed. Also at the effluent point a defoamer solution and oxygen infection system are
Yes No NA NE
Is right of way to the outfall properly maintained?
0
present and used as needed.
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
E
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
E
❑
❑
❑
Is sample collected below all treatment units?
N
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
N
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
N
❑
❑
❑
representative)?
Comment: Effluent sampler was clean and eauipped with new opaque silver sampler tubing. The
refrigerated compartment was at 2.0°C.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and E ❑ - El ❑
sampling location)?
Comment: The site is affiliated with the Cape Fear River Monitorinq Coalition which conducts in -stream
monitoring through out the Cape Fear River Basin.
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
0
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
E
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
N
❑
Page# 6

Permit: NC0003298
Inspection Date: 09/20/2016
Owner -Facility: Riegelwood Mill
Inspection Type: Compliance Sampling
Effluent Pipe Yes No NA NE
Comment: Supplemental oxygen can be added during the summer months to enhance in -stream
oxygen concentration in the receivinq stream. A defoamer solution is also added as needed
to prevent excessive foam at the discharge point.
Page#