HomeMy WebLinkAboutNC0003298_Final Permit_20181105ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
Mr. Gary Morrow, EHS8vS Manager
International Paper
865 John L. Riegel Rd.
Riegelwood, North Carolina 28456
Dear Mr. Morrow:
NORTH CAROLINA
Environmental Quality
November 9, 2018
Subject: Issuance of NPDES Permit
Permit NC0003298
Riegelwood Mill WWTP
Columbus County
Class WW-4
Division personnel have reviewed and approved your application for renewal of the
subject permit. This permit renewal is issued pursuant to the requirements of North Carolina
General Statute 143-215A and the Memorandum of Agreement between North Carolina and the
U.S. Environmental Protection Agency dated October 15, 2007 (or as subsequently amended).
This final permit includes the following significant changes from the draft permit previously sent to
International Paper on December 26, 20170
➢ The Special Condition A. (11.) Clean Water Act Section 316(b) has been removed
from the permit since the facility uses only 139/o of the intake water for the cooling
purposes and is not subject to the 316(b) rule.
The Division is unable to grant your request for removal of the hardness monitoring since
the facility is required to report numerous metals on the renewal application and the Division
will use the metals data to conduct the Reasonable Potential Analysis to determine the need for
the metal limits.
The Division is unable to grant your request for reduction in Chronic Toxicity Monitoring
(WET). The monitoring frequency for WET is established in 15A NCAC 2B .0500 and defined "as a
minimum of quarterly".
The Division is unable to grant your request for removal of the Dioxin Monitoring in fish
tissue. NCDHHS has raised concerns about the data quality and stated in their evaluation that
more sampling is needed to ensure protection of the health of people consuming fish caught
from this waterway".
The Division is unable to grant your request for changing the definition of Grab and
Composite samples, the Division uses the standard definition of the samples in the permit.
If any parts, measurement frequencies or sampling requirements contained in this permit
are unacceptable to you, you have the right to an adjudicatory hearing upon written request
within thirty (30) days following receipt of this letter. This request must be in the form of a
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written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed
with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina
27699-6714). Unless such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The
Division may require modification or revocation and reissuance of the permit. This permit does
not affect the legal requirements to obtain any other Federal, State, or Local governmental
permit that may be required.
If you have any questions concerning this permit, please contact Dr. Sergei Chernikov at
telephone number (919) 707-3606, or via email [sergei.chernikov@ncdenr.gov].
Sincerely,
Ynda Culpepper
i
Interim Director, Division of Water Resources
cc: Central Files
NPDES files
Wilmington Regional Office/Water Quality
e-copy: EPA
WSS/Aquatic Toxicology Unit
WSS/Ecosystems Branch/Monitoring Coalition Coordinator
Page 2 of 2
Permit NC0003298
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
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 December 1, 2018.
This permit and authorization to discharge shall expire at midnight on July 31, 2023.
Signed this day December 9, 2018.
L Culpeppe�,,I'nt�ri'rh Director
i 'sion of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 17
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:
1. 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 Highway 87, in Riegelwood, Columbus County, and
2. Discharge from said treatment works at the location 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 17
Permit NC0003298
Part I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
Grade 4 Biological Water Pollution Control System
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 monitoreds
by the Permittee as specified below:
EFFLUENT
LIMITS
MONITORING REQUIREMENTS
CHARACTERISTICS
Monthly
Weekly iii!
Daily Maximum
Measurement
Sample
Sample '
Average
Average
Frequency
Type
Location1
Flow GD
50.0
Continuous
Recording
E
BOD, 5-day, 200C
500 lbs/day
10,000 lbs/day
Daily
Composite
E
Summer
BOD, 5-day, 200C
10,000 lbs/day
20,000 lbs/day
Daily
Composite
E
inter
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
Dail
Grab
E, U, D
Total Hardness, m /L
Monthly
Grab
E
Total Hardness, m /L9
Quarterly
Grab
U
H3
Daily
Grab
E
Total Phosphorus m /L
Monthly
Composite
E
Total Nitrogen
Monthly
Composite
E
(NO2+NO3+TKN)
m /L
Chronic Toxicity4Quarterly
Composite
E
Dioxins
0.9 p /L
Annually
Composite
E
AOX6
25179.41b/day
3,326.81b/day
Daily
Composite
E
Trichloro henol7
30.81b/da
Weekly
Composite
E
Pentachloro henoh
4.89 lb/day
Weekly
Composite
E
SalinitySee
Note 1
Grab I
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 Monitoring page.
5. See Section A. (7.) of the Supplement to Effluent Limitations and Monitoring 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.
Page 3 of 17
Permit NCO003298
7. Monitoring is suspended for these compounds as long as chlorophenolic-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.).
9. The Permittee shall sample instream hardness, upstream of the facility's discharge. The sample shall be representative
of the hardness in the receiving stream: If the Permittee is a member of the Monitoring Coalition Program, sampling
for instream hardness may be waived as long as the Monitoring Coalition agrees to sample hardness at the nearest
upstream location, at a minimum frequency of quarterly, and the Permittee has obtained approval from DWR -
NPDES Permitting Unit that the upstream station being monitored by the Coalition is representative of the receiving
stream for this discharge. The Permittee is responsible for submitting instream hardness test results with its DMRs as
results are received from the Coalition. If Coalition membership is cancelled or the Monitoring Coalition terminates
instream hardness sampling at the approved station, the Permittee will immediately notify the Division and resume
sampling for instream hardness, upstream of its discharge, as required in this permit.
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 4 of 17
Permit NC0003298
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
Grade 4 Biological Water Pollution Control System
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 limited
and monitored6 by the Permittee as specified below and in A. (9.) Effluent Guideline Sampling Plan Special Condition:
EFFLUENT
LIMITS
MONITORING REQUIREMENTS2
CHARACTERISTICS
Monthly
Daily
Daily
Measurement
Sample
Sample Location'
Average
Average
Maximum
Frequency
Type3
F1ow2
Weekly
Calculated
Effluent
Chloroforms
8.62lb/day
14.41b/day
Quarterly
Grab
Effluent
2,3,7,8 Tetrachloro-
< 10 pg/L
Quarterly
Composite
Effluent
dibenzo-p-dioxin
CDD
2,3,7,8 Tetrachloro-
31.9 pg/L
Quarterly
Composite
Effluent
dibenzo- -furan CD
Trichlorosyringol
< 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-Trichloroguaiacol
< 2.5 µg/L4
Quarterly
Composite
Effluent
3,4,6-Trichloroguaiacol
< 2.5 µg/L4
Quarterly
Composite
Effluent
4,5,6-Trichloroguaiacol
< 2.5 µg/L4
Quarterly
Composite
Effluent
2,4,5-Trichlorophenol
< 2.5 µg/L4
Quarterly
Composite
Effluent
2,4,6-Trichlorophenol
< 2.5 µg/L4
Quarterly
Composite
Effluent
Tetrachlorocatechol
< 5.0 µg/L4
Quarterly
Composite
Effluent
Tetrachloroguaiacol
< 5.0 µg/L4
Quarterly
Composite
Effluent
2 3 4
T'et6- rachlorophenol
< 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 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.
Page 5 of 17
4. Limits are based on Minimum Levels (ML) specified in 40 CFR 430.01. Permit NC0003298
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
Page6of17
Permit NC0003298
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[15A NCAC 02B .0400 et seq., 02B .0500 et seq.]
Grade 4 Biological Water Pollution Control System
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 monitored6 by
the Permittee as specified below and in A. (9.) Effluent Guideline Sampling Plan Special Condition:
EFFLUENT
LIMITS
MONITORING REQUIREMENTS2
CHARACTERISTICS
Monthly
Daily
Daily
Measurement
Sample
Sample:Location'
Average
Avera a
Maximum
Fxe uenc
T e3
F1ow2
Weekly
Calculated
Effluent
Chloroforms
5.841b/day
9.81lb/day
Quarterly
Grab
Effluent
2,3,7,8 Tetrachloro-
< 10 pg/L
Quarterly
Composite
Effluent
dibenzo-p-dioxin
CDD
2,3,7,8 Tetrachloro-
31.9 pg/L
Quarterly
Composite
Effluent
dibenzo- -furan CD
Trichlorosyringol
< 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-Trichloroguaiacol
< 2.5 µg/L4
Quarterly
Composite
Effluent
3,4,6-Trichloroguaiacol
< 2.5 µg/L4
Quarterly
Composite
Effluent
4,5,6-Trichloroguaiacol
< 2.5 µg/L4
Quarterly
Composite
Effluent
2,4,5-Trichlorophenol
< 2.5 µg/L4
Quarterly
Composite
Effluent
2,4,6-Trichlorophenol
< 2.5 µg/L4
Quarterly
Composite
Effluent
Tetrachlorocatechol
< 5.0 µg/L4
Quarterly
Composite
Effluent
Tetrachloroguaiacol
< 5.0 µg/L4
Quarterly
Composite
Effluent
2 3,4,6-
T t'rachlorophenol
< 2.5 µg/L4
Quarterly
Composite
Effluent
Pentachlorophenol
< 5.0 µg/L4 Quarterly Composite
Effluent
Footnotes:
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. Limits are based on Minimum 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.).
Page 7 of 17
Permit NC0003298
Definitions:
lb/day — Pounds per day
pg/L — Picograms per liter
µg/L — Micrograms per liter
ADT — air dried ton of pulp product
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, uarterl monitoring using test procedures outlined in the "North Carolina
Coiodapbnia 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 during 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 TGP313 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 filed 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 maybe re -opened and modified 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
Page 8 of 17
Permit NC0003298
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
[G.S. 143-215.1(b)]
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 toxic to aquatic life or other than those
previously 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
[G.S. 143-215.1(b)]
Pursuant to N.C. Gen. Stat. Section 143-215.1 and the implementing rules found in Title 15A of the North
Carolina Administrative Code, Subchapter 2H, specifically, 15A NCAC 2H.0112(b)(1) and 2H.0114(a), and Part II
sections B-12 and B-13 of this Permit, the Director of DWR may reopen this permit to requite 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
[G.S. 143-215.1(b)]
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 limited by this permit is 2, 3, 7, 8, TCDD.
The Permittee shall perform the following analysis for dioxin:
1. Effluent Annual Composite
Page 9 of 17
2. Fish tissue
Permit NC0003298
DWR 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
1,2,3,6,7,8 HxCDD
1,2,3,4,6,7,8 HpCDD
A. (8.) CLUSTER RULE BMPs
[G.S. 143-215.1(b)]
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
2,3,4,6,7,8 HxCDF
1,2,3,4,6,7,8 HpCDF
1,2,3,4,7,8,9 HpCDF
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 turpentine. 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; (ii) 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 time to identify those equipment items where upgrade or replacement may be
warranted based on frequency and severity of leaks, spills, or failures.
3. The perch ttee 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
Page 10 of 17
Permit NC0003298
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 immediate 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.
7. The permittee must install and maintain secondary containment (i.e., containment constructed of materials
impervious to pulping liquors) for spent pulping 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; (ii) Maintenance; (iii) Production grade changes;
(iv) Storm or other weather events; (v) Power failures; and (vi) Normal operations.
IAs part of the engineering review, the permittee must determine whether existing spent pulping liquor
containment facilities 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; (ii) 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; (1) The potential for contamination of storm water from the immediate
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Permit NC0003298
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 significantly the likelihood of spent pulping 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 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 Recordkeeuing Reauirements
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;
(ii) Records of initial and refresher training conducted in accordance with Section A; (iii) Reports prepared in
accordance with Section A; and (iv) Records of monitoring required by Sections A and E.
Section D. Establishment of Wastewater Treatment Svstem 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 (IOC)),
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
point(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
Page 12 of 17
Permit NC0003298
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.
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 mill, 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 mill for any purpose including, but not limited
to, maintenance, grade changes, or process shutdowns.
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Permit NC0003298
6. Mill: 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
[G.S. 143-215.1(b)]
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,
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 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 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 Minimum Level (NIL), 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 Minimum 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 chlorophenolic 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 �anuary- March, April- June, July- September, October -
Page 14 of 17
Permit NC0003298
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 forNPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5) Monitoring Reports
1. Reporting Requirements [Supersedes Section D (2) and Section E (5 �(al�
The permittee shall report discharge monitoring data electronically using the NC DWR's Electronic Discharge
Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous months) 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 internet. Until such time 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 276994617
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 less 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:
Page 15 of 17
Permit NC0003298
• Sewer Overflow/Bypass Event Reports;
® Pretreatment Program Annual Reports; and
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:
httos://ww�v.federalrePister.Pov/(1()CT]Pnetlrc/?()1K/(r)n1r� 9AOFnA
elimination 4yste�z�-nt)dc..5-electecxiuc-renorting-rule --
Electronic submissions must start by the dates listed in the "Reporting Requirements" section above.
3. How to Request a Waiver from Electronic Reporting
4.
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 begin
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 -applies 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.ne.gov/about/divisions/water-resources ednzr
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.
Page 16 of 17
5.
Permit NC0003298
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: //dea •nc•gav /�bouti divisions /w� ter -resources mt
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 cent, under pezzalty of lazy, that thi document and all attachments were prepared under ny direction or supervision in
accordance zvith a sy tem designed to assure that qualified personnel pzbpezlygathe 4 and evaluate the iz fozmation submitted Based
on my inquig of the per rorz or persons who manage the ystem, or those persons directy responsible forgathering the information,
the iz fozmation submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there air
significantpenalties for submitting false information, including the possibility of fines and in pzzsonment for knoraing violations. "
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 122.411.
Page 17 of 17
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J00003298 —International Paper Compan
atitude (Outfall 0014• 34° 21' 10" Latitude (Outfa11002)• 340 21' 51"
ongitude (Outfall 001)• 780 12' 10" Longitude (Outfa11002)• 780 12' 70"
SGS Ouad Acme, N.C.
bream Class: C-Swamp, PNA-HQW
eceiving Stream: Cape Fear River
AmBasin: 03-06-17
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Facility
Location
�� Riegelwood Mill
Columbus Countv