Draft Permit-Response

INTERNATIONAL PAPER
Certified Mail: 7016 3010 0001 1137 0106
January 29, 2018
Mr. Sergei Chernkov, Ph.D
NC DEQ DWR
Complex NPDES Permitting Unit
1611 Mail Service Center
Raleigh, NC 27699-1611
RIEGELWOOD MILL
JOHN L. RIEGEL ROAD
RIEGELWOOD, NC 28456
FEB 0 12018
Water Resources
Permitting Section
Subject: International Paper Response to Draft NPDES Permit NC0003298 dated December 26,
2017
Dear Mr. Chernikov:
We have taken the opportunity to review the International Paper - Riegelwood Mill Draft NPDES
Permit submitted for public notice on December 26, 2017. Below are our comments on this draft.,
Where possible, comments are listed by permit section for ease of reference.
Section A. (1.) Effluent Limitations and Monitoring Requirements
The draft permit cover letter dated December 26, 2017 indicates the addition of total hardness as a
permitted parameter on the Final Effluent from Outfall 001. Further, there are additional requirements
for total hardness testing upstream of Outfall 001.
Additionally, the draft permit cover letter states that, " the NPDES Permitting Unit will need site-
specific effluent hardness data and anstream hardness data, upstream of the discharge, for each facility
monitoring these metals an order to calculate permit limitations." Metals monitoring requirements
were removed from International Paper's NPDES Permit NC0003298 during the last 5 -year renewal
cycle based on the results of the Reasonable Potential Analysis (RPA). Since we do not have existing
metals monitoring requirements, it is our understanding that hardness analysis is not required, and we
respectfully request that the total hardness monitoring requirements (upstream and effluent) be removed
from the permit.
In the draft cover letter, it is also noted that the limits for AOX, TSS, pentachlorophenol,
trichlorophenol, and chloroform were decreased to reflect the most recent production data. The data
used to calculate revised limits was for the period of January through December 2016. As we discussed
prior to issuance of the draft permit, the Riegelwood facility completed a major product conversion
project from paperboard to fluff pulp production in 2016. During the first several months of 2016, the
mill ran at less than 50% production, as one of our production lines was completely revamped to
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Sergei Chernikov, Ph.D
IP Response to Draft NPDES Permit
NC0003298
January 26, 2018
accommodate softwood pulp production (Bleach Plant 3) and fluff pulp (existing paper machine).
Once the conversion project was completed in late April 2016, "shakedown" continued well into the
summer and fall of 2016 Based on the variability in 2016 operations, we believe that the production
data for 2017 is more representative of normal operations for our facility. International Paper requests
that 2017 production data be used in the calculation of production based limits for AOX, TSS,
pentachlorophenol, trichlorophenol and chloroform.
Section A. (4.) Chronic Toxicity Pass/Fail Permit Limit
International Paper's Riegelwood facility followed on a quarterly monitoring frequency for chronic
toxicity during every quarter of the last 5 -year permitting cycle. During every quarterly sampling event
during this time period, the chronic toxicity analysis achieved a status of PASS Based on positive
historical sampling results, International Paper respectfully requests that the chronic toxicity monitoring
frequency be reduced to annually.
Section A. (7.) Dioxin Monitoring
Under the dioxin monitoring requirement, International Paper has been required to perform annual in -
stream fish tissue sampling and analysis. Data included in the most recent fish tissue report submitted
December 22, 2017 indicate that there has been no significant increase in the concentration of
TCDD/DF in fish tissue since the inception of the sampling program in 1990, 27 years ago. This
sampling program was initiated by Special Order by Consent EMC WQ No. 84-30 AD 11 which became
effective July 12, 1990. A search of the NCDEQ on-line archive does not list this as an Active SOC,
and we do not believe that the conditions of the this SOC apply any longer Furthermore, the final
effluent dioxin concentrations have been non -detect for the extent of the most recent 5 -year permitting
cycle Additionally, International Paper's Riegelwood, NC facility has been Elemental Chlorine Free
(ECF) since the late 1990s. International Paper respectfully requests the removal of the fish tissue
monitoring requirement under Section A. (7 ) Dioxin Monitoring.
Section A. (9.) Effluent Guideline Sampling Plan Special Condition (B"
The third paragraph states:
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 chlorophenolic and TCDD/DF sampling Such future requests will be evaluated in
accordance with 15A NCAC 2H. 0114.
Footnote 3 on pages 4 and 5 of the draft permit state.
. 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 waste
stream.
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Sergei Chernikov, Ph D
IP Response to Draft NPDES Permit
NC0003298
January 26, 2018
International Paper requests the Grab and Composite definitions be revised to state:
Grab — collect separate grab samples every 4 -hours for 12 -hour period from both the acrd and
alkaline streams, which will then be composited separately by the lab, and analyzed as separate
12 -hr composite acid and alkaline samples Composite — collect separate grab samples every
4 -hours for 12 -hour period from both the acid and alkaline streams, then prepare and analyze
a single flow proportioned composite of the acid and alkaline waste stream.
Section A. (10.) 1. Electronic Reporting of Discharge Monitoring Reports: Reporting
Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)1
The fourth paragraph states, "Starting on December 21, 2020, the permittee must electronically report
the following compliance monitoring data and reports, when applicable
• Sewer Overflow/Bypass Events Reports,
• Pretreatment Program Annual Reports, and
• Clean Water Act (CWA) Section 316(b) Annual Reports "
Further, in Section A. (11.) Clean Water Act Section 316(b) it states, "The permittee shall comply
with the Cooling Water Intake Structure Rule per 40CFR125 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
1621 Mail Service Center
Raleigh, NC 27699-1621 "
In a letter dated February 25, 2015, NCDEQ requested the following information from International
Paper's Riegelwood, NC facility:
1. The design intake flow for the facility (maximum flow the intake structure is capable of
withdrawing.)
2. Actual intake for the facility (average volume of water withdrawn on an annual basis over the
past three years )
3. Percent of water withdrawn on an actual intake flow basis used exclusively for cooling
purposes.
In a letter dated March 25, 2015, International Paper provided the requested information to NC DEQ
but has not received DEQ's applicability determination for this rule.
Per our 2015 letter, approximately 13% of the intake (2012 through 2014) was used exclusively for
cooling based on measured process cooling water use and an estimate of water used in local air
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Sergei Chernikov, Ph D
IP Response to Draft NPDES Permit
NC0003298
January 26, 2018
conditioning units. CWA Section 316(b) is not applicable as the percent of water withdrawn on an
actual intake flow basis used exclusively for cooling purposes is less than 25% as required in 40 CFR
125.91(a)(3). International Paper respectfully requests the above mentioned conditions be removed
from the permit.
Thank you for your consideration of our comments This submission should be considered timely as it
is being submitted by January 29, 2018. We look forward to continued discussion as the permitting
process moves forward and would welcome a face to face meeting to discuss our comments. If you
have any questions or need clarification on any point, please feel free to contact Kevin Burk (910/362-
3476, kevin burk&i� paper.com) or Kim Fail (910/362-4753, [e-mail]) at your earliest
convenience.
Sincerely,
ry rrow
EHS& Manager
cc Julie Grzyb, NC DEQ DWR
Kevin Burk, International Paper
Kim Fail, P.E., International Paper
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