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HomeMy WebLinkAboutWQ0005207_Renewal Application - 2019_20190102 Central Files: APS _ SWP 1/2/2019 Permit Number WQ0005207 Permit Tracking Slip Program Category Status Project Type Non-discharge In review Renewal Permit Type Version Permit Classification Closed-Loop Recycle B Individual Primary Reviewer Permit Contact Affiliation ranveer.katyal Nicki Slusser /Chief Officer Operating President Coastal SWRuIe Permitted Flow Facility Facility Name Major/Minor Region Jackson Paper Manufacturing-Sylva CLRS Minor Asheville Location Address County 152 W Main St Jackson Facility Contact Affiliation Sylva NC 28779 Owner Owner Name Owner Type Jackson Paper Manufacturing Company Non-Government Owner Affiliation Timothy L.Campbell PO Box 667 Dates/Events Sylva NC 28779 Scheduled Orig Issue App Received Draft Initiated Issuance Public Notice Issue Effective Expiration 11/15/1991 1/2/2019 Regulated Activities Requested/Received Events Pulp and paper manufacture Region comments on draft requested Region comments on draft received RO staff report received RO staff report requested 1/2/19 Additional information requested Additional information received Outfall Waterbody Name StreamIndex Number Current Class Subbasin ;�STAT�ti 4: `', . . rtoy COOPER kF �1 J MICHAEL S.BEGAN sweaty irectiar NORTH CAROLINA environmental Quality January 2,2019 CARR TYNDALL—VICE PRESIDENT OPERATIONS JACKSON PAPER MANUFACTURING COMPANY 152 W.MAIN ST. SYLVA,NORTH CAROLINA 28779 Subject: Acknowledgement of Application No. WQ0005207 Jackson Paper Manufacturing- Sylva CLRS Closed-Loop Recycle System Jackson County Dear Mr. Tyndall: The Water Quality Permitting Section acknowledges receipt of your permit application and supporting documentation received on January 2, 2019. Your application package has been assigned the number listed above, and the primary reviewer is Ranveer Katyal. Central and Regional Office staff will perform a detailed review of the provided application, and may contact you with a request for additional information. To ensure maximum efficiency in processing permit applications, the Division of Water Resources requests your assistance in providing a timely and complete response to any additional information requests. Please note that processing standard review permit applications may take as long as 60 to 90 days after receipt of a complete application. If you have any questions, please contact Ranveer Katyal at(919) 707-3661 or ranveer.katyal@ncdenr.gov. Sincerely, Nathaniel D. Thornburg, Supervisor Division of Water Resources cc: Asheville Regional Office,Water Quality Regional Operations Section Permit File WQ0005207 j 9 North Carolina Department of Environmental Quality I Division of Water Resources I Non-Discharge Branch 512 North Salisbury Street 11617 Mail Service Center I Raleigh,North Carolina 27699-1617 919.707.3654 Re. :4' i11I. JACKSON PAPER MANUFACTURING NORTH CAROLINAS LARGEST PRODUCER OF RECYCLED PAPER December 18, 2018 NCDEQ— Division of Water Resources Water Quality Permitting Section, Non-Discharge Branch 1617 Mail Service Center Raleigh, NC 27669-1617 RE: Non-Discharge Wastewater System Renewal Application RECEIVEDI NCDECIDWR Permit No.WQ0005207 JAN - 2 2019 Dear Non-Discharge Branch: Non-Discharge o tt Please find enclosed the renewal application, with required maps, for Jackson FPaN P uracfuring Company's (Jackson Paper's) non-discharge wastewater system permit. This permit renewal is due six months prior to permit expiration on June 30, 2019. There is one small change to be noted in the facility writeup in paragraph one of the permit: The current permit mentions a 500,000 gallon aeration basin with two 25 horsepower floatation aerators and two 25 horsepower surface aerators. The two floatation aerators have been replaced with two 25 horsepower surface aerators, therefore the description should be amended accordingly, to reflect that there are now a total of four 25 horsepower surface aerators. Also enclosed is a letter clarifying that Jackson Paper Manufacturing Company as listed in the Secretary of State's records, and as named on the current Non-Discharge Wastewater System Permit is the same as the Jackson Paper Manufacturing, as listed on the Property Deed. Please contact me at (828) 586-5534 if you have any questions or need any additional information. Sincerely, 744,11/1„.„, Kiesha Bridges Manager of Safety, Environmental &Technical Jackson Paper Manufacturing Company xc: Mary Barton; Ram boll US Corporation Enclosures: Form NDSR 09-18 Permit No. WQ0005207 Facility Name Clarification Letter Site Map Site Contour Map NORTH CAROLINA'S LARGEST RECYCLED PAPER PRODUCER 152 WEST MAIN STREET PO BOX 667 SYLVA,NC 28779 TEL(828)586-5534 FAX(828)586-6755 DWR Division of Water Resources State of North Carolina Department of Environmental Quality Division of Water Resources NON -DISCHARGE SYSTEM RENEWAL FORM: NDSR 09-18 This form is for renewal without modification for all non -discharge system permits, except Residuals Management and Single - Family Residence Wastewater Irrigation System permits. For more information, visit the Water Quality Permitting Section's Non -Discharge Branch. I. PERMITTEE INFORMATION: 1. Permittee: Jackson Paper Manufacturing Company 2. Signature authority's name: Carr Tyndall per 15A NCAC 02T .0106(b) Title: Vice President Operations Primary Telephone number: (828) 586-5534 Select Secondary number: (_) _- Select Email Address: ctvndallna,jacksonpa even r.net 3. Permittee's mailing address: 152 West Main Street City: Sylva state: NC Zip: 28779- RECEI` EDINCDEGUNR 4. Billing address (if different from above): JAN _ 2 2019 City: State: Zip: - 5. Contact person's name (if different from signature authority): Kiesha Bridges Title: Manas_ er of c, f__.,,-Env0o'nnf ental & Technical Primary Telephone number: (828) 586-5534 Select Secondary number: (828) 508-3264 Select Email Address: kbridges(a jacksonpaper.net II. PERMIT INFORMATION: 1. Existing permit number: WQ0005207 2. Has the facility been constructed? ® Yes or ❑ No If yes, has the facility been constructed in accordance with the permit and the Division -approved plans and specifications? j 15A NCAC 02T .0110] ® Yes or ❑ No If no, a formal permit modification request shall be submitted to the Division. 3. Has any of the property ownership within the facility and/or disposal area changed from what is indicated in the current permit (Attachment B — disposal field owner/lessee)? ❑ Yes or ® No Has the Permittee had a name change or has the permit changed ownership? ❑ Yes or ® No If yes to either, a permit modification request shall be submitted to the Division. 15A NCAC 02T .0105] 4. Is this facility a Privately -Owned Public Utility? ❑ Yes or ® No If yes, provide two copies of the Certificate of Public Convenience and Necessity from the North Carolina Utilities Commission demonstrating the Applicant is authorized to hold the utility franchise for the area to be served by the non -discharge system. 115A NCAC 02T .0115(a)(1')] 5. Is the Permittee a Home/Property Owners' Associations or Developers of lots to be sold? ❑ Yes or ® No If yes, provide the following: • For Home/Property Owners' Associations — Operational Agreement (FORM: HOA) and a copy of the proposed or approved Articles of Incorporation, Declarations, and By-laws [15A NCAC 02T .0115(c)] • For Developers of lots to be sold —Operational Agreement (FORM: DEV} [15A NCAC 02T .0115(h)] FORM: NDSR 09-18 Page 1 of 3 DWR Division of Water Resources III. SITE MAP: State of North Carolina Department of Environmental Quality Division of Water Resources NON -DISCHARGE SYSTEM RENEWAL FORM: NDSR 09-18 1. Provide an updated site map in accordance with 15A NCAC 02T .0105.I d) that shows the following: Boundaries and physical features not under purview of other licensed professions shall be provided by a professional land surveyor ® Legend, north arrow, scale, and legible in black and white ® Topographic contour intervals not exceeding 10 feet or 25 percent of total site relief ❑ Soil mapping units on all disposal sites ® All facility -related structures and fences within the treatment, storage, and disposal areas ® All habitable residences and places of assembly within 500 feet of all treatment, storage, and irrigations sites ® Location of all wells, streams (ephemeral, intermittent, and perennial), springs, lakes, ponds, ditches, and other surface drainage features within 500 feet of all waste treatment, storage, and disposal site(s) ❑ Location and identification of each monitoring well (identify any background/upgradient wells) ❑ Latitude and longitude coordinates of all monitoring wells (decimal degrees to 6 digits) ❑ Location and identification of major components of the waste disposal system ❑ The wetted perimeter of all irrigation fields with field names (named according to the approved permit) ❑ Location and ownership of property boundaries within 500 feet of the disposal area (including road/rail right-of-ways) ® The delineation of compliance and review boundaries ❑ Distance measurements verifying all setbacks are being met ® Stormwater drainage controls ❑ 100-year floodplain (if applicable) IV. SETBACK WAIVERS, EASEMENTS, AND LEASES: 1. Does the permit have any setback waivers, easements, or leases? ❑ Yes or ® No If yes, provide copies of all documents and complete the table below: Document Type Grantor or Parcel No. Grantee Expiration Date County Registered Deed Book Document Deed Page Description 1 Select Select Select Select Select Select Select Select Select Select Select 1. The document description shall list any reduced setbacks with distance, etc. FORM: NDSR 09-18 Page 2 of 3 State of North Carolina DWR Division of Water Resources Department of Environmental Quality Division of Water Resources NON -DISCHARGE SYSTEM RENEWAL FORM: NDSR 09-18 Applicant's Certification per 15A NCAC 02T .0106(b): I, attest that this renewal application has been reviewed by me, and is accurate and complete to the best of my knowledge. I understand that any unauthorized discharge of wastewater from this non -discharge system to surface waters or the land may result in an enforcement action that may include civil penalties, injunctive relief, and/or criminal prosecution. I will make no claim against the Division of Water Resources should a condition of this permit be violated. I also understand that if all required parts of this application are not completed, this application may be returned to me as incomplete. I further certify that the Applicant or any parent, subsidiary, or other affiliate of the Applicant has not been convicted of an environmental crime, has not abandoned a wastewater facility without proper closure, does not have an outstanding civil penalty where all appeals have been exhausted or abandoned, are compliant with any active compliance schedule, and does not have any overdue annual fees. NOTE — In accordance with General Statutes 143-215.6A and 143-215.6B, any person who knowingly makes any false statement, representation, or certification in any application package shall be guilty of a Class 2 misdemeanor, which may include a fine not to exceed $10,000 as well as civil penalties up to $25,000 per violation. The Applicant's Certification shall be signed in accordance with 15A NCAC 02T .0106(b). Per 15A NCAC 02T .0106(c), an alternate person maybe designated as the signing official if a delegation letter is provided from a person wh iieets the criteria in 15A NCAC 02T .0106(b) Signature: ��— Date: z _ $ i'8 THE COMPLETED APPLICATION AND SUPPORTING DOCUMENTATION SHALL BE SUBMITTED TO: NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER RESOURCES WATER QUALITY PERMITTING SECTION NON -DISCHARGE BRANCH By U.S. Postal Service: By Courier: BN Email: Non -Discharge Branch Non -Discharge Branch — Archdale 640D Non-Discharge.Reportsla ncdenngov 1617 Mail Service Center 512 N. Salisbury St. Raleigh, NC 27699-1617 Raleigh, NC 27604 TELEPHONE NUMBER: (919) 707-3654 FORM: NDSR 09-18 Page 3 of 3 NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES ll - CLOSED -LOOP RECYCLE SYSTEM PERMIT In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as amended, and other applicable Laws, Rules and Regulations PERMISSION IS HEREBY GRANTED TO Jackson Paper Manufacturing Company Jackson County FOR THE operation of a wastewater treatment and closed -loop recycle facility consisting of the: continued operation of a wastewater pretreatment effluent recycling system consisting of: a 2,015 gallon supply tank with a 50 horsepower (lip) primary clarifier supply pump and a 30 hp pump conveying excess water to the South Basin; a 110,000 gallon primary clarifier with a 7.5 hp underflow pump conveying waste to the two sludge tanks, and a top mounted rake system that skims to a scum tank; a 12,400 gallon anaerobic selector tank; a 500,000 gallon aeration basin with two 25 hp floatation aerators, two 25 hp surface aerators and two 7.5 hp lift pumps conveying flow to the secondary clarifier; a 500 gallon trisodium phosphate tank with a 1 hp chemical feed pump to the aeration basin; a 13,500 gallon secondary clarifier with a 7.5 hp underflow pump conveying waste to the two sludge tanks, and a top mounted rake system that skims to a scum tank; a 500 gallon polymer mixing tank with a 1 hp chemical feed pump to the secondary clarifier; a 400 gallon scum tank with a 7.5 hp underfloor pump conveying waste to the two sludge tanks; two 25,000 gallon sludge tanks with a 7.5 hp pump conveying flow to the belt press; a belt dewatering press with a sump and a 7.5 hp pump conveying effluent to the primary clarifier (dewatered solids are removed and combusted onsite in the wood fuel / biomass boiler; two 500 gallon polymer mixing tanks with a 1 hp pump and a spare % hp pump providing polymer to the belt press; a 2,630 gallon seal water supply tank with two 25 hp discharge pumps supplying seal water to pumps and agitators throughout the facility; a 2,300 gallon belt press shower tank with one 10 hp motor; a 300,000 gallon basin (i.e., South Basin) with two 25 hp surface aerators and two 75 lip mill water supply pumps; two 36,900 gallon boiler scrubber settling basins with two 30 hp scrubber supply pumps; and all associated piping, valves, controls and appurtenances; and the continued operation of a sand filter basin recycle system consisting of. dual Culligan sand filters; a 30 hp creek pump; a 23,500 gallon basin with a 15 hp discharge pump; a 300,000 gallon basin (i.e., North Basin); and all associated piping, valves, controls and appurtenances to serve Jackson Paper Manufacturing Company, with no discharge of wastes to surface waters, pursuant to the application received January 3, 2014, and in conformity with the project plans, specifications, and other supporting data subsequently filed and approved by the Department of Environment and Natural_ Resources and considered a part of this permit. WQ0005207 Version 3.0 Shell Version 140324 Page 1 of 5 This permit shall be effective from July 1, 2014 until June 30, 2019, shall void Permit No. WQ0005207 issued July 5, 2005, and shall be subject to the following specified conditions and limitations: I. SCHEDULES 1. Gauges to monitor waste levels in the 300,000 gallon South Basin and 300,000 gallon North Basin shall be installed within 60 days of the effective date,of this permit. 2. No later than six months prior to the expiration of this permit, the Permittee shall request renewal of this permit on official Division forms. Upon receipt of the request, the Division will review the adequacy of the facilities described therein, and if warranted, will renew the permit for such period of time and under such conditions and limitations as it may deem appropriate. Please note Rule 15A NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal application. II. PERFORMANCE STANDARDS 1. The subject non -discharge facilities shall be effectively maintained and operated at all times so there is no discharge to the surface waters, nor any contravention of groundwater or surface water standards. In the event that the facilities fail to perform satisfactorily, including the creation of nuisance conditions due to improper operation and maintenance, the Permittee shall take immediate corrective actions including Division required actions, such as the constriction of additional or replacement wastewater treatment or recycle facilities. 2. This permit shall not relieve the Permittee of their responsibility for damages to groundwater or surface water resulting from the operation of this facility. M. OPERATION AND MAINTENANCE REQUIREMENTS 1. The facilities shall be properly maintained and operated at all times. The facilities shall be effectively maintained' and operated as a non -discharge system to prevent the discharge of any wastewater resulting from the operation of this facility. The Permittee shall maintain an Operation and Maintenance Plan pursuant to 15A NCAC 02T .1007, which at a minimum shall include operational functions, maintenance schedules, safety measures and a spill response plan. 2. Upon the Water Pollution Control System Operators Certification Commission's (WPCSOCC) classification of the subject non -discharge facilities, in accordance with 15A NCAC 08G .0200 the Permittee -shall designate and employ a certified operator in responsible charge (ORC) and one or more certified operator(s) as back-up ORC(s). The ORC or their back-up shall visit the facilities in accordance with 15A NCAC 08G .0200, and shall comply with all other conditions specified in the previously cited rules. 3. Public access to the wastewater treatment facilities and closed -loop recycle system shall be prohibited. 4. The residuals generated from the wastewater treatment facilities shalt be disposed or utilized in accordance with 15A NCAC 02T .1100. The Pennittee shall maintain a residual management plan pursuant to 15A NCAC 02T .1008. 5. Diversion or bypassing of untreated or partially treated wastewater from the treatment facilities is prohibited. 6. Freeboard in the 300,000 gallon South Basin and 300,000 gallon North Basin shall not be less than two feet at any time. WQ0005207 Version 3.0 Shell Version 140324 Page 2 of 5 7. Gauges to monitor waste levels in the 300,000 gallon South Basin and 300,000 gallon North Basin shall be provided. These gauges shall have readily visible permanent markings, at inch or tenth of a foot increments. IV. MONITORING AND REPORTING REQUIREMENTS 1. Any Division required monitoring (including groundwater, plant tissue, soil and surface water analyses) necessary to ensure groundwater and surface water protection shall be established, and an acceptable sampling reporting schedule shall be followed. 2. Per 15A NCAC 02H .0800, a Division certified laboratory shall conduct all laboratory analyses for the required effluent, groundwater or surface water parameters. 3. Freeboard (i.e., waste level to the lowest embankment elevation) in the 300,000 gallon South Basin and 300,000 gallon North Basin shall be measured to the nearest inch or tenth of a foot, and recorded weekly. Weekly freeboard records shall be maintained at the facility for a period of no less than five years, and shall be made available to the Division upon request. 4. A record shall be maintained of all residuals removed from this facility. This record shall be maintained at the facility for a period of no less than five years, and shall be made available to the Division upon request. At a minimum, this record shall include: a. Name of the residuals hauler; b. Non -Discharge permit number authorizing the residuals disposal, or a letter from a municipality agreeing to accept the residuals; c. Date the residuals were hauled; and d. Volume of residuals removed. 5. A maintenance log shall be maintained at this facility. This log shall be maintained at the facility for a period of no less than five years, and shall be made available to the Division upon request. At a minimum, this log shall include: a. Visual observations of the plant and plant site; and b. Record of preventative maintenance (e.g., changing of equipment, adjustments, testing, inspections and cleanings, etc.). 6. NoncompIiance Notification: The Permittee shall report by telephone to the Asheville Regional Office, telephone number (828) 296-4500, as soon as possible, but in no case more than 24 hours, or on the next working day following the occurrence or first knowledge of the occurrence of any of the following: a. Any occurrence at the facility resulting in the treatment of significant amounts of wastes that is abnormal in quantity or characteristic, including the known passage of a- hazardous substance. b. Any process unit failure (e.g., mechanical, electrical, etc.), due to known or unknown reasons, rendering the facility incapable of adequate wastewater treatment. c. Any facility failure resulting in a by-pass directly to receiving surface waters. d. Any tune self -monitoring indicates the facility has gone out of compliance with its permit limitations. Any emergency requiring immediate reporting (e.g., discharges to surface waters, imminent failure of a storage structure, etc.) outside normal business hours shall be reported to the Division's Emergency Response personnel at telephone number (800) 662-7956, (800) 858-0368, or (919) 733-3300. Persons reporting such occurrences by telephone shall also file a written report in letter form within five days following first knowledge of the occurrence. This report shall outline the -actions taken or proposed to be taken to ensure the problem does not recur. WQ0005207 Version 3.0 Shell Version 140324 Page 3 of 5 V. INSPECTIONS 1. The Permittee shall provide adequate inspection and maintenance to ensure proper operation of the wastewater treatment and recycle facilities. 2. The Permittee or their designee shall inspect the wastewater treatment and recycle facilities to prevent malfunctions, facility deterioration and operator errors resulting in discharges, which may cause the release of wastes to the enviromnent, a threat to human health or a public nuisance. The Permittee shall maintain an inspection log that includes, at a minimum, the date and time of inspection, observations made, and any maintenance, repairs, or corrective actions taken. The -Permittee shall maintain this inspection log for a period of five years from the date of the inspection, and this log shall be made available to the Division upon request. 3. Any duly authorized Division representative may, upon, presentation of credentials, enter and inspect any property, premises or place on or related to the wastewater treatment and recycle facilities permitted herein at any reasonable time for the purpose of determining compliance with this permit; may inspect or copy any records required to be maintained under the terms and conditions of this permit, and may collect groundwater, surface water or leachate samples. VI. GENERAL CONDITIONS I. Failure to comply with the conditions and limitations contained herein may subject the Permittee to an enforcement action by the Division in accordance with North Carolina General Statutes 143- 215.6A to 143-215.6C. 2. This permit shall become voidable if the permitted facilities are not constructed in accordance with theconditions of this permit, the Division approved plans and specifications, and other supporting documentation. 3. This permit is effective only with respect to the nature and volume of wastes described in the permit application, Division approved plans and specifications, and other supporting documentation. No variances to applicable rules governing the construction or operation of the permitted facilities are granted, unless specifically requested and approved in this permit pursuant to 15A NCAC 02T .0105(n). 4. The issuance of this permit does not exempt the Permittee from complying with any and all statutes, rules, regulations, or ordinances, which may be imposed by other jurisdictional govenunent agencies (e.g., local, state, and federal). Of particular concern to the Division are applicable river buffer rules in 15A NCAC 02B .0200; erosion and sedimentation control requirements in 1SA NCAC Chapter 4 and under the Division's General Permit NCGO 10000; any requirements pertaining to wetlands under 15A NCAC 02B .0200 and 02H .0500; and. documentation of compliance with Article 21 Part 6 of Chapter 143 of the General Statutes. 5. In the event the permitted facilities change ownership or the Permittee changes their name, a fonnaI permit modification request shall be submitted.to the Division. This request shall be made on official Division forms, and shall include appropriate property ownership documentation and other supporting documentation as necessary. The Permittee of record shall remain fully responsible for maintaining and operating the facilities permitted herein until a permit is issued to the new owner. 6. The Permittee shall retain a set of Division approved plans and specifications for the life of the facilities permitted herein. 7. The Permittee shall maintain this permit until all permitted facilities herein are properly closed or permitted under another permit issued by the appropriate permitting authority pursuant to 15A NCAC 02T .01050). WQ0005207 Version 3.0 Shell Version 140324 Page 4 of 5 8. This permit is subject to revocation or unilateral modification upon 60 days notice from the Division Director, in whole or part for the requirements listed in 15A NCAC 02T .0110. 9. Unless the Division Director grants a variance, expansion of the permitted facilities contained herein shall not be granted if the Permittee exemplifies any of the criteria in 15A NCAC 02T .0120(b). 10. The Permittee shall pay the annual fee within 30 days after being billed by the Division. Failure to pay the annual fee accordingly shall be cause for the Division to revoke this permit pursuant to 15A NCAC 02T .0105(e)(3). Permit issued this the 13`b day of May 2014 NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION om . Reeder, Director Divisio of Water Resources By Authority of the Environmental Management Commission Permit Number WQ0005207 WQ0005207 Version 3.0 Shell Version 140324 Page 5 of 5 ;• �cks+�rr�°3p�er Ma7ufaciu:r4 u :cirnSylva Srke lit An t � -k tj 2 — Directional WQ0005207 152 West Main Street, Sylva, NC 28779 Jackson Paper Manufacturing Company Latitude: 35.375257° Jackson Paper Manufacturing Company — Sylva Site Longitude:-83.216978' Tf- Ngo I G1 IEEE 6 It ti fC`� ray l ?��t= 1 A41 Rt' nr y' - ITS 44 h` t Jackson County Board-EdUcalion - etr., 1437 N Jack -F Lipper zs ,rr a' Ice Cream ® t pf 7$3 rw1i Ave 1781 1. I ?AY1 I"I i +j C• f f�yn o uti h `T oil; 02014 Goa le Map data 02014 Gott le i "r : of Use JACKSON PAPER MANUFACTURING December 13, 2018 NCDEQ — Division of Water Resources Water Quality Permitting Section, Non -Discharge Branch 1617 Mail Service Center Raleigh, NC 27669-1617 RE: Facility Name Clarification Dear Non -Discharge Branch: In the process of renewing the NPDES non -discharge system permit for our Sylva facility, we were asked to clarify whether the Jackson Paper Manufacturing Company facility on record with the Secretary of State's Business Registration Department is the same exact facility as the Jackson Paper Manufacturing facility listed on the Property Deed. This letter is to provide the clarification that the two entities are in fact the same. Please contact me at (828) 586-5534 if you have any questions or need any additional information. Sincerely, jal"ll" Vice President Chief Financial Officer Jackson Paper Manufacturing Company NORTH CAROLINA'S LARGEST RECYCLED PAPER PRODUCER 152 WEST MAIN STAEETO PO BOX 6670 SYLVA, NC 28779 TEL (828) S86-5534 FAX (828) 586-6755 "P� �MVYIF 7M WHIMY, 4 I- L 20, Mn- 01' MEW, 7.11 - - -, -MA IDATE: 12/14/201 D RESIDENTIA BILLBOARD / COMPANY PUT-DOWN jt AREA �+ VTf UCK { /� /'COWWNER �i CO �'`T STORAGE Q/ REPUBLIC �! f §EI VICES IU am 4�ti O Q ��U RECYCLED O ;I� BALE STORAGE :O REJECTS / PAD _ _.RECYCLE. WVJT WOOD "BUILDING FACILITY;,j�,i TRUCK RESIDENTIAL l DUMP [ �� AREAN W�OD CHIPPER - 1 �I BAILER BOILER ASH SURFACE WATEj27-y� FIRE '� WATER RA Dt' TREATMENT ],,_• f TANK ASH �\ PONDS, PAPER RESIDENTIAL �f ASH MACHINE BUILDING PILE_' NORTH AND I' "._SOUTH -BASINS FIRE DEPARTMENT �1 FINISHING1'. VJAREH OUSE SURFACE WATER INTAKE , JUNK' YARD BbDY Ji ,,;_si 1OP i 1; a1 RESIDENTIAL FUNERAL. HOME aLU STREET LEGEND: -- PROPERTY BOUNDARY (APPROXIMATE) SOURCE: GAS,_ > rl AERIAL IMAGERY: GoogleT"" Earth; October 2015. Mi*iN 5 RESTAURANt STATIdN CO RETAILIA� `' 0 400 r SCALE IN FEET SITE LAYOUT FIGURE JACKSON PAPER MANUFACTURING COMANY 2 152 WEST MAIN STREET SYLVA DRAFTED BY: RGM DATE: 12/17/2018 , NORTH CARD LINA PROJECT: 1690006708