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HomeMy WebLinkAboutDraft PermitWater Resources Environmental Quality December 26, 2017 Mr Gary Morrow, EHS&S Manager International Paper 865 John L Riegel Rd Riegelwood, North Carolina 28456 Dear Mr Morrow ­ ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Intel in; Director Subject: Draft NPDES Permit Permit NC0003298 Riegelwood Mill WWTP Columbus County Facility Class IV Enclosed with this letter is a copy of the draft permit for your facility. Please review the draft very carefully to ensure thorough understanding of the conditions and requirements it contains The draft permit contains the following significant changes from your current permit: • Limits for AOX, TSS, Pentachlorophenol, trichlorophenol, and chloroform were decreased to reflect the most recent production data • Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015 The requirement to begin reporting discharge monitoring data electronically using the NC DV/R's Electronic Discharge Monitoring Report (eDMR) internet application has been added to your final NPDES permit. [See Special Condition A. (10.)] For information on eDMR, registering for eDMR and obtaining an eDMR user account, please visit the following web page. http//dTg nc gov/about/divisions/water-resources/edmr For more information on EPA's final NPDES Electronic Reporting Rule, please visit the following web site https //w-,vw federalregister gov/documents/2015/10/22/2015-24954/national-pollutant- dis charge-elimination-sys tem-np des -electronic -rep orting-rule The NC 2007-2014 Water Quality Standard (WQS) Triennial Review was approved by the NC Environmental Management Committee (EMC) on November 13, 2014 The US EPA subsequently approved the WQS revisions on April 6, 2016 with some exceptions The NC Division of Water Resources NPDES Permitting Unit is required to implement the new dissolved metal standards in all permits public noticed after April 6, 2016 The new standards for most metals include acute standards Further, the freshwater standards for several metals are expressed as the dissolved form of the metals, and seven metals have hardness -dependent equations As a result, the NPDES Permitting Unit will need site-specific effluent hardness data and instream hardness data, upstream of the discharge, for each facility monitoring these metals in order to calculate permit limitations Effluent hardness and instream hardness sampling, upstream of the discharge, has been added to this permit at a monitoring frequency of month14 [See A (111 -�"—' Nothing Compares =,._ State of North Carolina I Environmental Quality 1611 Mail Service Center I Raleigh, North Carolina 27699-1611 919-707-9000 • The Clean Water Act Section 316(B) Special Condition was added to the permit to reflect the new regulations [See Special Condition A. (11.)] Please provide any comments you have regarding the draft permit to this office by January 29, 2018. At flus time, the Division is also publishing a notice in the newspapers of general circulation in Columbus County, inviting public comment on the draft permit. Following the 30 -day comment period, we will review all pertinent comments received and take appropriate action on the permit renewal The NPDES Standard Conditions (Parts II, III, and IV) are not included with this draft. They can be found at the following link if you would like to review them in conjunction with this draft permit http //ncdenr s3 amazonaws com/s3fs- pubhc/Water%20Ouahty/Surface%20Water%20Protection/NPDES /MISC/NPDES%20Standard%20Cond itions-Boilerplate-DWR-SWP-NPDES-20150410 pdf If you have any questions about the NPDES permit process, please contact me at the following e-mail address: sergei chernikov(2ncdenr gov, or telephone number. 919-807-6386 Sincerely, 'Y' q Sergei Chernikov, Ph.D. Environmental Engineer II Complex NPDES Permitting Unit cc NPDES Files EPA Region IV (e -copy) Wilmington Regional Office / Surface Water Protection (e -copy) Aquatic Toxicology Unit (e -copy) TACU (e -copy) Permit NC0003298 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER RESOURCES Draft PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, International Paper Company, Inc. is hereby authorized to discharge wastewater from a facility located at NC Highway 87 in Riegelwood Columbus County to receiving waters designated as the Cape Fear River in the Cape Fear River Basin in accordance with effluent limitations, monitoring requirements, and other applicable conditions set forth in Parts I, II, and III hereof. This permit shall become effective This permit and authorization to discharge shall expire at midnight on November 30, 2021 Signed this day Linda Culpepper, Interum Director Division of Water Resources By Authority of the Environmental Management Commission Page 1 of 15 Permit NC0003298 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. International Paper Company, Inc. Riegelwood Facility is hereby authorized to: Continue to operate existing treatment facilities (outfall 001) consisting of dual bar screens and primary clarifiers, nutrient addition facilities, 173 acres of aerated lagoons with re -circulation, sludge holding lagoons, sludge dewatering presses, oxygen injection facilities, flow measurement and recording equipment located at NC IAighway 87, in Riegelwood, Columbus County, and 2. Discharge from said treatment works at the locations specified on the attached map into the Cape Fear River which is classified C -Swamp waters in the Cape Fear River Basin. Page 2 of 15 Permit NC0003298 Part I A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge combined wastewaters from outfall(s) serial number 001 Such discharges shall be limited and monitored8 by the Permittee as specified below - EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Locationl Flow GD 50.0 Continuous Recording E BOD, 5 -day, 200C Summer 5,000 lbs/day 10,000 lbs/day Daily Composite E BOD, 5 -day, 200C inter 10,000 lbs/day 20,000 lbs/day Daily Composite E Total Suspended Solids 41,628 8 lbs/day 77,485 6 lbs/day Daily Composite E NH3-N, mg/L Weekly Composite E Temperature(OC) Daily Grab E Dissolved Oxygen2, m /L Daily Grab E, U, D Total Hardness, m /L Monthly Grab E, U H3 Daily Grab E Total Phosphorus (mg/L Monthly Composite E Total Nitrogen (NO2+NO3+TKN) m /L Monthly Composite E Chronic Toxicity4 Quarterly Composite E Dioxins 0.9 /L Annually Composite E AOX6 2,179 4 lb/day 3,326 8 lb/day Daily Composite E Trichloro henol7 30.8 lb/day Weekly Composite E Pentachloro henol7 4 89 lb/day Weekly Composite E Salinity I See Note 1 Grab U, D Notes.• 1. Sample Locations- E — Effluent, I — influent, U — upstream at the International Paper water intake, D — downstream at the DuPont water intake Stream samples shall be collected three times per week during June, July, August, and September and once per week during the remaining months of the year. As a participant in the lower Cape Fear River Monitoring Coalition, the instream monitoring is not required Should the membership in the Coalition be terminated, you shall notify Division immediately and begin instream monitoring as specified in this permit 2 The daily average dissolved oxygen effluent concentration shall not be less than 5 0 mg/L 3 The pH shall not be less than 6 0 standard units nor greater than 9 0 standard units 4 Chronic Toxicity (Ceriodaphnia) P/F at 8 0%, January, April, July, and October, see item A. (4.) of the Supplement to Effluent Limitations and Monitonng page. 5 See Section A (7 ) of the Supplement to Effluent Lsmitahons and Monitonng page 6 AOX data shall be submitted on a quarterly basis along with other Cluster Rule chemical data, refer to A (9.) Effluent Guideline Sampling Plan Special Condition. 7 Monitoring is suspended for these compounds as long as chlorophenohc-containing biocides are not used at the facility 8. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR application system Please See Special Condition A (10.) There shall be no discharge of floating solids or visible foam in other than trace amounts. Summer shall mean June 1 - October 31, while winter shall mean November 1 - May 31 Page 3 of 15 Permit NC0003298 A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning upon the effective date of the permit and lasting until expiration, the discharge of wastewater from bleach plant 1 and bleach plant 2 to the wastewater treatment plant through internal outfall 004, shall be hmmted and momtored6 by the Permittee as specified below and in A (9 ) Effluent Guideline Sampling Plan Special Condition. EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS2 Monthly Average Daily Average Daily Maximum Measurement Frequency Sample Type3 Sample Location' F1ow2 Weekly Calculated Effluent Chloroforms 8 62 lb/day 14.4 lb/day Quarterly Grab Effluent 2,3,7,8 Tetrachloro- dmbenzo-p-dmoxmn CDD < 10 pg/L Quarterly Composite Effluent 2,3,7,8 Tetrachloro- dmbenzo- -furan CD 31.9 pg/L Quarterly Composite Effluent Trichlorosyrmngol < 2 5 µg/L4 Quarterly Composite Effluent 3,4,5-Trichlorocatechol < 5 0 µg/L4 Quarterly Composite Effluent 3,4,6-Trichlorocatechol < 5 0 µg/L4 Quarterly Composite Effluent 3,4,5-Trichloroguamacol < 2 5 µg/L4 Quarterly Composite Effluent 3,4,6-Trichloroguamacol < 2 5 gg/L4 Quarterly Composite Effluent 4,5,6-Trzchloroguamacol < 2.5 µg/L4 Quarterly Composite Effluent 2,4,5 -Trichlorophenol < 2 5 gg/L4 Quarterly Composite Effluent 2,4,6 -Trichlorophenol < 2 5 µg/L4 Quarterly Composite Effluent Tetrachlorocatechol < 5 0 µg/L4 Quarterly Composite Effluent Tetrachloroguamacol < 5 0 µg/L4 Quarterly Composite Effluent 2 3,4,6- T'el achlorophenol < 2.5 µg/L4 Quarterly Composite Effluent Pentachlorophenol < 5 0 µg/L4 Quarterly Composite Effluent Footnotes: 1 Sample Location Effluent is composed of bleach plants 1 and 2 effluent -acid (collected from acid sewer) and bleach plants 1 and 2 effluent -alkaline (collected from alkaline sewer) See A (9) Effluent Guideline Sampling Plan Special Condition 2. Monitoring and flow calculations shall be in accordance with the condition A (9.) Chemical results for Effluent Guideline parameters as prepared by the permittee (Internal Outfall 004 parameters + AOX from Outfall 001) shall be reported on a quarterly basis or more frequently, refer to A (9) Effluent Guideline Sampling Plan Special Condition. 3. Sample Type Calculated- calculate separate flows for alkaline and acid sewers by water balance or flow meters, and report total bleach plant 1 and 2 flow (acid + alkaline wastestreams) in DMRs Grab- collect separate grab samples every 4 -hours for 24-hour period from both the acid and alkaline streams, which will then be composmted separately by the lab, and analyzed as separate 24 -hr composite acid and alkaline samples Composite- collect separate grab samples every 4 hours for 24-hour period from both the acid and alkaline streams, then prepare and analyze a single flow -proportioned composite of the acid and alkaline wastestream 4 Limits are based on Mmmmum Levels (ML) specified in 40 CFR 430.01 5 For compliance purposes, the permittee must report total chloroform mass loading. 6. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR application system Please See Special Condition A. (10.). Definitions: lb/day — Pounds per day pg/L — Picograms per liter µg/L — Micrograms per liter ADT — air dried ton of pulp product Page 4 of 15 Permit NC0003298 A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning upon the effective date of the permit and lasting until expiration, the discharge of wastewater from bleach plant 3 to the wastewater treatment plant through internal outfall 005, shall be limited and monitored by the Pernuttee as si3ecified below and in A (9 ) Effluent Guideline Sampling Plan Special Condition EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTSz Monthly Average Daily Average Daily Maximum Measurement Frequency Sample Type3 Sample Location' Flown Weekly Calculated Effluent Chloroforms 5 84 lb/day 9 81 lb/day Quarterly Grab Effluent 2,3,7,8 Tetrachloro- dibenzo-p-dioxin CDD < 10 pg/L Quarterly Composite Effluent 2,3,7,8 Tetrachloro- dibenzo- -furan CD 319 pg/L Quarterly Composite Effluent Trichlorosyringol < 2 5 jig/L4 Quarterly Composite Effluent 3,4,5-Trichlorocatechol < 5.0 gg/L4 Quarterly Composite Effluent 3,4,6-Tnchlorocatechol < 5 0 gg/L4 Quarterly Composite Effluent 3,4,5-Tnchloroguaiacol < 2 5 gg/L4 Quarterly Composite Effluent 3,4,6-Trichloroguatacol < 2 5 gg/L4 Quarterly Composite Effluent 4,5,6-Trichloroguaiacol < 2 5 gg/L4 Quarterly Composite Effluent 2,4,5 -Trichlorophenol < 2 5 [1g/L4 Quarterly Composite Effluent 2,4,6 -Trichlorophenol < 2.5 gg/L4 Quarterly Composite Effluent Tetrachlorocatechol < 5 0 gg/L4 Quarterly Composite Effluent Tetrachlorogualacol < 5.0 gg/L4 Quarterly Composite Effluent 2346 TI t'rachlorophenol < 2 5 gg/L4 Quarterly Composite Effluent Pentachlorophenol < 5 0 gg/L4 Quarterly Composite Effluent jkFootnotes. 1 Sample Location- Effluent is composed of bleach plant effluent -acid (collected from acid sewer) and bleach plant effluent -alkaline (collected from alkaline sewer) See A (9) Effluent Guideline Sampling Plan Special Condition 2 Monitoring and flow calculations shall be in accordance with the condition A (9.). Chemical results for Effluent Guideline parameters as prepared by the permittee (Internal Outfall 005 parameters + AOX from Outfall 001) shall be reported on a quarterly basis or more frequently, refer to A (9) Effluent Guideline Sampling Plan Special Condition 3. Sample Type Calculated- calculate separate flows for alkaline and acid sewers by water balance or flow meters, and report total bleach plant flow (acid + alkaline wastestreams) in DMRs. Grab- collect separate grab samples every 4 - hours for 24-hour period from both the acid and alkaline streams, which will then be composited separately by the lab, and analyzed as separate 24 -hr composite acid and alkaline samples Composite- collect separate grab samples every 4 hours for 24-hour period from both the acid and alkaline streams, then prepare and analyze a single flow - proportioned composite of the acid and alkaline wastestream 4. Li ruts are based on Minimum Levels (NIL) specified in 40 CFR 430 01 5 For compliance purposes, the permittee must report total chloroform mass loading 6. The permittee shall submit Discharge Monitoring Reports electronically using NC DWR's eDMR application system. Please See Special Condition A (10 ) Definitions: lb/day — Pounds per day pg/L — Picograms per hter gg/L — Micrograms per liter ADT — air dried ton of pulp product Page 5of15 Permit NC0003298 A. (4.) CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY) [15A NCAC 02B .0200 et seq.] The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 8.0%. The permit holder shall perform at a minimum, monitoring using test procedures outlined in the "North Carolina Cenodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be performed dunng the months of January, April, July, and October Effluent sampling for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes If the quarterly test procedure results in a failure or ChV below the permit limit, then multiple -concentration testing shall be performed at a minimum, in each of the two following months as described in "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -December 2010) or subsequent versions. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR -1) for the months in which tests were performed, using the parameter code TGP3B for the pass/fail results and THP313 for the Chronic Value. Additionally, DWR Form AT -3 (original) is to be sent to the following address. Attention- North Carolina Division of Water Resources Water Sciences Section/Aquatic Toxicology Branch 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filen with the Water Sciences Section no later than 30 days after the end of the reporting period for which the report is made Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month/year of the report with the notation of "No Flow" in the comment area of the form The report shall be submitted to the Water Sciences Section at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Assessment of toxicity compliance is based on the toxicity testing month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit may be re -opened and mochfied to include alternate monitoring requirements or limits NOTE Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival, minimum control organism reproduction, and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. A. (5.) BIOCIDE CONDITION The Permittee shall obtain authorization from the Division of Water Resources prior to utilizing any biocide in the cooling water. The Permittee shall notify the Director in writing not later than ninety (90) days prior to instituting use of any additional biocide used in cooling systems which may be tonic to aquatic life or other than those previously Page 6 of 15 Permit NC0003298 reported to the Division of Water Resources. Such notification shall include completion of Biocide Worksheet Form 101 and a map locating the discharge point and receiving stream. Concentrations of chromium, copper or zinc added to biocides shall not exceed applicable water quality standards or action levels in the receiving stream, as determined by calculations from the Biocide Worksheet Form 101 with Supplemental Metals Analysis worksheet. A. (6.) PERMIT RE -OPENER: NUTRIENT CONTROLS Pursuant to N.C. Gen. Stat. Section 143-215.1 and the implementing rules found in Title 15A of the North Carolina Admimstrative Code, Subchapter 2H, specifically, 15A NCAC 2H 0112(b)(1) and 2H.01 14(a), and Part II sections B-12 and B-13 of tlus Permit, the Director of DWQ may reopen this permit to require supplemental nutrient monitoring of the discharge The additional monitoring will be to support water quality modeling efforts within the Cape Fear River Basin, and shall be consistent with a monitoring plan developed jointly by the Division and affected stakeholders. A. (7.) DIOXIN MONITORING For compliance purposes, the point of compliance shall be defined as the final effluent before discharge. Compliance with the daily maximum permit limit shall be demonstrated by determining the TCDD concentration at the final discharge point. Adequate sample volume shall be collected to perform the analysis. The total sample volume shall be collected and preserved in accordance with Part II, Section C Monitoring and Records. The sample shall be analyzed in accordance with the appropriate method of analysis specified in Analytical Procedures and Quality Assurance for Multimedia Analysis of Polychlorinated Dibenzo-para-dioxins and Polychlorinated Dibenzofurans by High Resolution Gas Chromatography/High Resolution Mass Spectrometry, EPA, 1987 (EPA Method 1613), or another equivalent analytical protocol approved by DWQ. A single sample may be analyzed to determine compliance with the daily maximum effluent limitation. Alternatively, a sample volume may be collected to enable the sample to be split (duplicate analysis). If the analysis of either split sample is below the detection limit, the quantity, for the purposes of compliance evaluation, is considered to be zero. If both splits are positive, the results of the two analyses shall be averaged to determine compliance with the daily maximum effluent limitation. If the measurement is below detection limits, the quantity for the purposes of compliance evaluation is considered to be zero. The detection limit using these methods for the purpose of compliance evaluation is considered to be 10 picograms per liter. The dioxin isomer to be monitored and hrruted by this permit is 2, 3, 7, 8, TCDD. The Permittee shall perform the following analysis for dioxin: 1. Effluent 2. Fish tissue Annual Composite DWQ approved monitoring plan Fish tissue analysis will be performed in accordance with the Division of Water Resources approved monitoring plan. The monitoring plan is an enforceable part of this permit. All dioxin data collected as part of this monitoring requirement will be reported within two months of receiving the finalized analyses from the data collection. The chlorodibenzo dioxins and furans to be monitored are (this requirement applies for fish tissue monitoring only): DIOXIN Isomer 2,3,7,8 TCDD 1,2,3,7,8 PeCDD 1,2,3,4,7,8 HxCDD 1,2,3,7,8,9 HxCDD Page 7 of 15 DIBENZOFURAN Isomer 2,3,7,8 TCDF 1,2,3,7,8 PeCDF 2,3,4,7,8 PeCDF 1,2,3,4,7,8 HxCDF 1,2,3,7,8,9 HxCDF 1,2,3,6,7,8 HxCDF 1,2,3,6,7,8 HxCDD 1,2,3,4,6,7,8 HpCDD Permit NC0003298 2,3,4,6,7,8 HpCDF 1,2,3,4,6,7,8 HpCDF 1,2,3,4,7,8,9 HpCDF A. (8.) CLUSTER RULE BMPs The permittee must implement the BMPs specified in Section A below. The primary BMP objective is to prevent leaks and spills of spent pulping liquors, soap, and tApentine. A secondary objective is to contain, collect, and recover at the immediate process area, or otherwise control, those leaks, spills, and intentional diversions of spent pulping liquor, soap, and turpentine that do occur. BMPs must be developed according to best engineering practices and must be implemented in a manner that takes into account the specific circumstances at the mill. Section A. BMP Implementation Requirements 1. The permittee must return spilled or diverted spent pulping liquors, soap, and turpentine to the process to the maximum extent practicable as determined by the mill, recover such materials outside the process, or discharge spilled or diverted material at a rate that does not disrupt the receiving wastewater treatment system. 2. The permittee must maintain a program to identify and repair leaking equipment items. This program must include: (i) Regular visual inspections (e.g., once per day) of process area with equipment items in spent pulping liquor, soap, and turpentine service; (u) Immediate repair of leaking equipment items, when possible. Leaking equipment items that cannot be repaired during normal operations must be identified, temporary means for mitigating the leaks must be provided, and the leaking equipment items repaired during the next maintenance outage; (iii) Identification of conditions under which production will be curtailed or halted to repair leaking equipment items or to prevent pulping liquor, soap, and turpentine leaks and spills; and (iv) A means for tracking repairs over tune to identify those equipment items where upgrade or replacement may be warranted based on frequency and severity of leaks, spills, or failures. 3. The permittee must operate continuous, automatic monitoring systems that the mill determines are necessary to detect and control leaks, spills, and intentional diversions of spent pulping liquor, soap, and turpentine. These monitoring systems should be integrated with the mill process control system and may include, e.g., high level monitors and alarms on storage tanks, process area conductivity (or pH) monitors and alarms; and process area sewer, process wastewater, and wastewater treatment plant conductivity (or pH) monitors and alarms. 4. The permittee must maintain a program of initial and refresher training of operators, maintenance personnel, and other technical and supervisory personnel who have responsibility for operating, maintaining, or supervising the operation and maintenance of equipment items in spent pulping liquor, soap, and turpentine service. The refresher training must be conducted at least annually and the training program must be documented. 5. The permittee must prepare a brief report that evaluates each spill of spent pulping liquor, soap, or turpentine that is not contained at the iinmechate process area and any intentional diversion of spent pulping liquor, soap, or turpentine that is not contained at the immediate process area. The report must describe the equipment items involved, the circumstances leading to the incident, the effectiveness of the corrective actions taken to contain and recover the spill or intentional diversion, and plans to develop changes to equipment and operating and maintenance practices as necessary to prevent recurrence. Discussion of the reports must be included as part of the annual refresher training. 6. The permittee must maintain a program to review any planned modifications to the pulping and chemical recovery facilities and any construction activities in the pulping and chemical recovery areas before these activities commence. The purpose of such review is to prevent leaks and spills of spent pulping liquor, soap, and turpentine during the planned modifications, and to ensure that construction and supervisory personnel are aware of possible liquor diversions and of the requirement to prevent leaks and spills of spent pulping liquors, soap, and turpentine during construction. Page 8 of 15 Permit NC0003298 7. The permittee must install and maintain secondary containment (i e, containment constructed of materials impervious to pulping liquors) for spent pulpmg liquor bulk storage tanks equivalent to the volume of the largest tank plus sufficient freeboard for precipitation. An annual tank integrity testing program, if coupled with other containment or diversion structures, may be substituted for secondary containment for spent pulping liquor bulk storage tanks. 8. The permittee must install and maintain secondary containment for turpentine bulk storage tanks. 9. The permittee must install and maintain curbing, diking or other means of isolating soap and turpentine processing and loading areas from the wastewater treatment facilities. 10. The permittee must conduct wastewater monitoring to detect leaks and spills, to track the effectiveness of the BMPs, and to detect trends in spent pulping liquor losses. Such monitoring must be performed in accordance with Section E. Section B. BMP Plan Requirements 1. The permittee must prepare and maintain a BMP Plan. The BMP Plan must be based on a detailed engineering review as described in this section. The BMP Plan must specify the procedures and the practices required for the mill to meet the requirements of Section A, the construction the mill determines is necessary to meet those requirements including a schedule for such construction, and the monitoring program (including the statistically derived action levels) that will be used to meet the requirements of Section E. The BMP Plan also must specify the period of time that the mill determines the action levels established under Section D may be exceeded without triggering the responses specified in Section E. 2. The permittee must conduct a detailed engineering review of the pulping and chemical recovery operations -- including but not limited to process equipment, storage tanks, pipelines and pumping systems, loading and unloading facilities, and other appurtenant pulping and chemical recovery equipment items in spent pulping liquor, soap, and turpentine service --for the purpose of determining the magnitude and routing of potential leaks, spills, and intentional diversions of spent pulping liquors, soap, and turpentine during the following periods of operation- (i) Process start-ups and shut downs; (u) Maintenance; (in) Production grade changes; (iv) Storm or other weather events; (v) Power failures; and (vi) Normal operations. 3. As part of the engineering review, the permittee must determine whether existing spent pulping liquor containment facihties are of adequate capacity for collection and storage of anticipated intentional liquor diversions with sufficient contingency for collection and containment of spills. The engineering review must also consider. (i) The need for continuous, automatic monitoring systems to detect and control leaks and spills of spent pulping liquor, soap, and turpentine; (u) The need for process wastewater diversion facilities to protect end -of -pipe wastewater treatment facilities from adverse effects of spills and diversions of spent pulping liquors, soap, and turpentine; (in) The potential for contamination of storm water from the immediate process areas; and (iv) The extent to which segregation and/or collection and treatment of contaminated storm water from the immediate process areas is appropriate. 4. The permittee must amend its BMP Plan whenever there is a change in mill design, construction, operation, or maintenance that materially affects the potential for leaks or spills of spent pulping liquor, turpentine, or soap from the immediate process areas 5. The permittee must complete a review and evaluation of the BMP Plan five years after the first BMP Plan is prepared and, except as provided in Section B.4., once every five years thereafter. As a result of this review and evaluation, the permittee must amend the BMP Plan within three months of the review if the mill determines that any new or modified management practices and engineered controls are necessary to reduce sigmficandy the likelihood of spent pulpmg liquor, soap, and turpentine leaks, spills, or intentional diversions from the immediate process areas, including a schedule for implementation of such practices and controls. 6. The BMP Plan, and any amendments thereto, must be reviewed by the senior technical manager at the mill and approved and signed by the mill manager. Any person signing the BMP Plan or its amendments must certify to the Division under penalty of law that the BMP Plan (or its amendments) has been prepared in accordance Page 9 of 15 Permit NC0003298 with good engineering practices and in accordance with this regulation. The permittee is not required to obtain approval from the Division of the BMP Plan or any amendments thereto. Section C. BMP Recordkeeping Requirements 1. The permittee must maintain on its premises a complete copy of the current BMP Plan and the records specified in Section C 2 and must make such BMP Plan and records available to the Division for review upon request. 2 The permittee must maintain the following records for three years from the date they are created: (i) Records tracking the repairs performed in accordance with the repair program described in Section A; (u) Records of initial and refresher training conducted in accordance with Section A; (in) Reports prepared in accordance with Section A, and (iv) Records of monitoring required by Sections A and E. Section D Establishment of Wastewater Treatment System Influent Action Levels 1. The permittee must conduct a monitoring program per Section D.2, for the purpose of defining wastewater treatment system influent characteristics (or action levels), described in Section D.3, that will trigger requirements to initiate investigations on BMP effectiveness and to take corrective action. 2. The permittee must employ the following procedures in order to develop the action levels required by Section D: Monitoring parameters. The permittee must collect 24-hour composite samples and analyze the samples for a measure of organic content (e.g., Chemical Oxygen Demand (COD) or Total Organic Carbon (TOC)). Alternatively, the mill may use a measure related to spent pulping liquor losses measured continuously and averaged over 24 hours (e.g., specific conductivity or color). Monitoring locations. The permittee must conduct monitoring at the point influent enters the wastewater treatment system. For the purposes of this requirement, the permittee may select alternate monitoring pomt(s) in order to isolate possible sources of spent pulping liquor, soap, or turpentine from other possible sources of organic wastewaters that are tributary to the wastewater treatment facilities (e.g., bleach plants, paper machines and secondary fiber operations) 3. The permittee must maintain an influent action levels monitoring program using the procedures specified in Section D and must maintain initial action levels based on the results of that program. A wastewater treatment influent action level is a statistically determined pollutant loading determined by a statistical analysis of six months of daily measurements The action 'Levels must consist of a lower action level, which if exceeded will trigger the investigation requirements described in Section E, and an upper action level, which if exceeded will trigger the corrective action requirements described in Section E. 4. The permittee must complete a second six-month monitoring program using the procedures specified in Section D and must establish revised action levels based on the results of that program based on Section D5 requirements. The initial action levels shall remain in effect until replaced by revised action levels. 5. Action levels developed under this Section must be revised using six months of monitoring data after any change in mill design, construction, operation, or maintenance that materially affects the potential for leaks or spills of spent pulping liquor, soap, or turpentine from the immediate process areas Section E. BMP Monitoring, Corrective Action, and Reporting Requirements 1. The permittee must conduct daily monitoring of the influent to the wastewater treatment system in accordance with the procedures described in Section D for the purpose of detecting leaks and spills, tracking the effectiveness of the BMPs, and detecting trends in spent pulping liquor losses. Page 10 of 15 Permit NC0003298 2. Whenever monitoring results exceed the lower action level for the period of time specified in the BMP Plan, the permittee must conduct an investigation to determine the cause of such exceedance. Whenever monitoring results exceed the upper action level for the period of time specified in the BMP Plan, the permittee must complete corrective action to bring the wastewater treatment system influent mass loading below the lower action level as soon as practicable. 3. Although exceedances of the action levels will not constitute violations of an NPDES permit, failure to take the actions required by Section E 2 as soon as practicable will be a permit violation. 4 The permittee must report to the Division the results of the daily monitoring conducted pursuant to Section E.1. Such reports must include a summary of the monitoring results, the number and dates of exceedances of the applicable action levels, and brief descriptions of any corrective actions taken to respond to such exceedances Submission of such reports shall be annually, by March 31" of the following year. Section F. BMP Definitions 1. Action Level: A daily pollutant loading that when exceeded triggers investigative or corrective action. Mills determine action levels by a statistical analysis of six months of daily measurements collected at the mill. For example, the lower action level may be the 75th percentile of the running seven-day averages (that value exceeded by 25 percent of the running seven-day averages) and the upper action level may be the 90th percentile of the running seven-day averages (that value exceeded by 10 percent of the running seven-day averages). 2. Division North Carolina DEQ, Division of Water Resources, 1617 Mail Service Center, Raleigh, North Carolina 27699-1617. 3. Equipment Items in Spent Pulping Liquor, Soap, and Turpentine Service- Any process vessel, storage tank, pumping system, evaporator, heat exchanger, recovery furnace or boiler, pipeline, valve, fitting, or other device that contains, processes, transports, or comes into contact with spent pulping liquor, soap, or turpentine. Sometimes referred to as "equipment items." 4. Immediate Process Area: The location at the mill where pulping, screening, knotting, pulp washing, pulping liquor concentration, pulping liquor processing, and chemical recovery facilities are located, generally the battery limits of the aforementioned processes. "Immediate process area" includes spent pulping liquor storage and spill control tanks located at the mull, whether or not they are located in the immediate process area. 5. Intentional Diversion: The planned removal of spent pulping liquor, soap, or turpentine from equipment items in spent pulping liquor, soap, or turpentine service by the mull for any purpose including, but not limited to, maintenance, grade changes, or process shutdowns. 6. Mall: The owner or operator of a direct or indirect discharging pulp, paper, or paperboard manufacturing facility subject to this section. 7. Senior Technical Manager- The person designated by the mill manager to review the BMP Plan. The senior technical manager shall be the chief engineer at the mill, the manager of pulping and chemical recovery operations, or other such responsible person designated by the mill manager who has knowledge of and responsibility for pulping and chemical recovery operations. 8. Soap: The product of reaction between the alkali in kraft pulping liquor and fatty acid portions of the wood, which precipitate out when water is evaporated from the spent pulping liquor. 9. Spent Pulping Liquor For kraft and soda mills "spent pulping liquor" means black liquor that is used, generated, stored, or processed at any point in the pulping and chemical recovery processes. 10. Turpentine: A mixture of terpenes, principally pinene, obtained by the steam distillation of pine gum recovered from the condensation of digester relief gases from the cooking of softwoods by the kraft pulping process. Sometimes referred to as sulfate turpentine. A. (9.) EFFLUENT GUIDELINE SAMPLING PLAN SPECIAL CONDITION The bleach plant effluent sample shall be analyzed for 2,3,7,8-TCDD in accordance with EPA Method 1613. A single sample may be analyzed to determine compliance with the daily maximum effluent limitation. Alternatively, Page 11 of 15 Permit NC0003298 a sample volume may be collected to enable the sample to be split (duplicate analysis). If the analysis of either split sample is below the Minimum Level (ML), the quantty is considered to be zero for compliance evaluation. If both splits are positive, the results of two analyses shall be averaged to determine compliance The Minimum Level for 2,3,7,8-TCDD by EPA Method 1613 is 10 pg/L. The bleach plants effluent sample shall be analyzed for the 12 chlorinated phenolic compounds in Part I, A(2) in accordance with EPA Method 1653. A single sample may be analyzed to determine compliance with the daily maximum effluent limitation. Alternatively, a sample volume may be collected to enable the sample to be split (duplicate analysis). If the analysis of either split sample is below the Mintinu n Level (ML), the quantity is considered to be zero for compliance evaluation. If both splits are positive, the results of two analyses shall be averaged to determine compliance. The Minima n Levels for each of the 12 chlorinated compounds are the same as the Daily Maximum concentrations listed in Part I, A.(2.) and A. (3.). The final wastewater treatment plant effluent sample (Outfall 001) shall be analyzed for AOX in accordance with EPA Method 1650, or subsequent test methods approved by the Division. The permittee may request future monitoring modifications to the Cluster Rule requirements, including 1) use of ECF certification in lieu of monitoring for chloroform in the bleach plant effluent (Outfall 004 and Outfall 005) when this rule is promulgated by EPA; 2) demonstrating compliance using samples collected less frequently than every four hours; 3) using automated composite volatile samplers for chloroform sampling; and 4) using automated composite samplers for chlorophenohc and TCDD/DF sampling. Such future requests will be evaluated in accordance with 15A NCAC 2H.0114. The flow calculations for internal Outfalls 004, and 005 shall not be subject to accuracy requirements specified under Part II, Section D.3. This exclusion is similar to that provided for pump log flow calculations. Chemical data for Cluster Rule parameters (all Outfall 004, and 005 parameters + AOX from Outfall 001) shall be submitted to the Division on a quarterly basis Qanuary- March, April- June, July- September, October - December). Quarterly submissions shall be due 60 days following the last day of each quarter (Due dates = May 31, August 31, November 30, February 28). Chemical data shall be submitted on Division -approved DMR forms, with a separate form provided for each month. A. (10.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS [G.S. 143-215.1(b)] Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports. The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015. NOTE- This special condition supplements or supersedes the following sections within Part II of this permit (Standard Conditions for NPD -ES Permits) • Section B. (11.) • Section D. (2.) • Section D. (6.) • Section E. (5.) Signatory Requirements Reporting Records Retention Monitoring Reports 1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)] The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application. Page 12 of 15 Permit NC0003298 Monitoring results obtained during the previous month(s) shall be summarized for each month and submitted electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring data and submit DMRs electronically using the innternet. Until such tune that the state's eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation (CROMERR), permittees will be required to submit all discharge monitoring data to the state electronically using eDMR and will be required to complete the eDMR submission by printing, signing, and submitting one signed original and a copy of the computer printed eDMR to the following address: NC DEQ / Division of Water Resources / Water Quality Permitting Section ATTENTION: Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-1617 If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being physically located in an area where les's than 10 percent of the households have broadband access, then a temporary waiver from the NPDES electronic reporting requirements may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be submitted to the mailing address above. See "How to Request a Waiver from Electronic Reporting" section below. Regardless of the submission method, the first DMR is due on the last day of the month following the issuance of the permit or in the case of a new facility, on the last day of the month following the commencement of discharge. Starting on December 21, 2020, the permittee must electronically report the following compliance monitoring data and reports, when applicable: • Sewer Overflow/Bypass Event Reports; • Pretreatment Program Annual Reports; and • Clean Water Act (CWA) Section 316(b) Annual Reports. The permittee may seek an electronic reporting waiver from the Division (see "How to Request a Waiver from Electronic Reporting" section below) 2. Electronic Submissions In accordance with 40 CFR 122.41(1) (9), the permittee must identify the initial recipient at the time of each electronic submission. The permittee should use the EPA's website resources to identify the initial recipient for the electronic submission. Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity (EPA or the state authorized by EPA to implement the NPDES program) that is the designated entity for receiving electronic NPDES data [see 40 CFR 127.2(b)]. EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each type of electronic submission and for each state. Instructions on how to access and use the appropriate electronic reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting Rule is found at: Page 13 of 15 Permit NC0003298 https. / /www.federalregister.gov/documents /2015 / 10 /22 /2015-24954 /national-pollutant-discharge- ehtnmation-system-npdes-electromc-reportuig-rule Electronic submissions must start by the dates listed in the "Reporting Requirements" section above. 3. How to Request a Waiver from Electronic Reporting The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to the Division. Requests for temporary electronic reporting waivers must be submitted in writing to the Division for written approval at least sixty (60) days prior to the date the facility would be required under this permit to begun submitting monitoring data and reports. The duration of a temporary waiver shall not exceed 5 years and shall thereupon expire. At such time, monitoring data and reports shall be submitted electronically to the Division unless the permittee re-apphes for and is granted a new temporary electronic reporting waiver by the Division. Approved electronic reporting waivers are not transferrable Only permittees with an approved reporting waiver request may submit monitoring data and reports on paper to the Division for the period that the approved reporting waiver request is effective. Information on eDMR and the application for a temporary electronic reporting waiver are found on the following web page: http://deq.nc.gov/about/dmsions/water-resources/edmr 4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) (Q All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II, Section B. (11.)(a) or by a duly authorized representative of that person as described in Part II, Section B. (11.)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting purposes. For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and login credentials to access the eDMR system For more information on North Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the following web page: http: / /deq.nc.gov/about/chvisions/water-resources /edmr Certification Any person submitting an electronic DMR using the state's eDMR system shall make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED. "I cert, under penalty of lazy, that this document and all attachments were prepared tinder my direction or supervzszon in accordance with a ystem designed to assure that quaked personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible forgathenng the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are sign f cant penalties for submitting false information, including the possibility of fines and imprisonment for knowzng violations. " Page 14 of 15 Permit NC0003298 5. Records Retention [Supplements Section D. (Q] The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These records or copies shall be maintained for a period of at least 3 years from the date of the report. This period may be extended by request of the Director at any time [40 CFR 122 41]. A. (11.) CLEAN WATER ACT SECTION 316(b) The permittee shall comply with the Cooling Water Intake Structure Rule per 40 CFR 125.95. The permittee shall submit all the materials required by the Rule with the next renewal application. Copies of all the study plans, study results, and any other applicable materials should be submitted to: 1) Electronic Version Only (pdf and CD) Division of Water Resources WQ Permitting Section - NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 2) Electronic Version (pdf and CD) and Hard Copy Division of Water Resources Water Sciences Section 1621 Mail Service Center Raleigh, NC 27699-1621 Page 15 of 15 hV' Oo =25-- a i_ Outfall 001 t�� 4 J f// W O C Ltut tyston Cr. O n) I NC0003298 — International Paper Compa Latitude (Outfall 001): 34° 21' 10" Latitude (Outfall 002): 34° 21' 51" Longitude (Outfall 001): 78° 12' 10" Longitude (Outfall 002): 78° 12' 70" USGS Quad: Acme, N.C. Stream Class: C -Swamp, PNA-HQW Receiving Stream: Cape Fear River Sub -Basin: 03-06-17 Facility Location NQ}ll Riegelwood Mill Columbus County