NCS000101_DEQ Report Sludge Line Leak_20210118

INTERNATIONAL Q PAPER
RIEGELWOOD MILL
JOHN L. RIEGEL ROAD
RIEGELWOOD, NC 28456
January 18, 2021
Ms. Morella Sanchez -King, P.E.
Water Resources Supervisor
North Carolina Department of Environmental Quality
Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, North Carolina 28405
SUBJECT: Sludge Line Leak and Release — January 08, 2021
International Paper — Riegelwood Mill
NPDES Permit Nos. NC0003298 (wastewater) and NCS000101 (stormwater)
Incident No. 202100174
Dear Ms. Sanchez -King:
This submittal constitutes a follow-up written report to telephone conversations and e-mail
communications with you and your staff on January 08, 2021. At 11:36 am on January 8, 2021,
Richard Moore, the onsite manager of the neighboring Holtrachem facility notified International Paper
(IP) that a pipe had failed and was flooding onto their property. The pipe was a sludge line running
from the waste water treatment system (WTS) primary clarifiers east of the mill to the sludge presses on
the west side of the mill. The release was controlled at approximately It: 52 am, with a duration of 16
minutes. An estimated 30,000 gallons was lost during the line failure; visual assessment was that about
one-third of the loss flowed north to Holtrachem, about one-third was captured by a u-drain leading to
the WTS, and one-third was split between a ditch to the WTS and an NPDES stormwater outfall. This
estimate is slightly higher than what was reported to DEQ on January 8, which was based on the best
available information at that time.
Mill environmental staff determined that roughly 5,000 gallons reached an on -site stormwater outfall
(Outfall M). The concrete/dirt swale leading to this outfall runs from west to east along the south fence
line of Holtrachem, which is landlocked by our mill site. The dirt portion of the swale contains multiple
rock check dams that caught the vast majority of the sludge solids. The swale discharges into a ravine
in a wooded area that borders Holtrachem's eastern fence line. Mill environmental staff hiked the
length of the stream to the Cape Fear River to determine how far the sludge had migrated into the
wooded area towards the river. Traces of sludge ended about 50 feet from the tributary's entry into the
Cape Fear River, which was very high that day, reaching far up into the ravine.
A large amount of sludge encroached on a concrete pad on Holtrachem's property, which is adjacent to
the failed pipe. Ms. Morella Sanchez -King of NC DEQ Wilmington Regional Office was contacted at
1:53 pinto discuss the sludge release to Outfall M. Subsequent conversations between Mr. Tom
Tharrington of NC DEQ and IP staff occurred at 2:17 and 4:27 pm to provide updates on the cleanup.
At the time of the last update, IP's contractor gate area had been cleared and reopened to traffic, and the
Holtrachem site was cleaned up. The concrete and earthen swales in Basin M were cleaned up, and the
response crew was in the process of cleaning the drainage channel in the ravine past Outfall M. By
6:30 pm, the cleanup was completed in all areas, and the response crew left the site. About 12,000
gallons were recovered with the vac trucks, plus one dumptruck of about 10 tons of solids. The
following Monday, January 11, 2021, erosion at Holtrachem was repaired as the last action to close the
response.
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A sample was collected from the Holtrachem property adjacent to the pipeline, from the stream flowing
to their stormwater collection pond. The pH at this sample location was 7.5, which is well within
surface water standards. The COD concentration of the sample was 789 ppm, while the BOD
concentration of this sample was 261 ppm. TSS was 430 ppm, which would be expected from a sample
of this type. Safety data sheets (SDSs) and Toxicity Characteristic Leaching Procedure (TCLP) test
results maintained by IP denote that the wastewater sludge is a non -hazardous material.
The failed carbon steel piping section was replaced with stainless steel last week and was placed back
into service on January 15. This event will be noted as a wastewater bypass on our January 2021
monthly discharge monitoring report (DMR), as well as an unpermitted discharge in our first semester
2021 stormwater report. Per a subsequent conversation with Tom Tharrington of DEQ on January 14,
our e-mail communication with DEQ on January 8 met the intent of filing a 5-day written report, and
this specific submittal's intent is to provide additional analytical results and detail to our January 8 e-
mail communication.
If you have questions or need additional information, please contact Wallace Coverdale (910-362-4590,
wallace.coverdale&ipaper.com), Kevin Burk (910-362-3476, [e-mail]) or me (910-362-
4753, [e-mail]) at your convenience.
Sincerely,
Kimberly W. Fail, P.E.
Environmental Compliance Manager
Attachments
cc: Wallace Coverdale, IP
Kevin Burk, IP
Tim Gill, IP
Tom Tharrington, NC DEQ
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Attachment A
Photos — 01/08/21 Bypass Event and Clean Up Efforts
Holtrachem immediately across the
fence line from the line break.
Estimate about 1/3 of the total flow.
Nearly complete cleanup of
Holtrachem site.
S:IGroupslEnvironmentallWastewaterlReleases11.8.211ReportlnfoUPRWSludgeLineLeak010821-Final.docx

Image of the flow into the
Holtrachem stormwater collection;
sampled beside trailer.
S:IGroupslEnvironmentallWastewaterlReleases11.8.211ReportlnfoUPRWSludgeLineLeak010821-Final.docx

Toward Outfall M immediately
after sludge pump was shut down.
Clean up progress at the
Contractor Gate.
S:IGroupslEnvironmentallWastewaterlReleases11.8.211ReportlnfoUPRWSludgeLineLeak010821-Final.docx

Scraped Outfall M
Clean up of the roadway.
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Sludge residue on the ground after
the storm water swale in the
"Ravine". To be cleaned up via
vac truck or shovel.
Evidence of cleanup of "Ravine"
ditch.
S:IGroupslEnvironmentallWastewaterlReleases11.8.211ReportlnfoUPRWSludgeLineLeak010821-Final.docx