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
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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
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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
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DRAFTED BY: RGM DATE: 12/17/2018 , NORTH CARD LINA
PROJECT: 1690006708