NC0003298_PERMIT ISSUANCE_20130607

NPDES DOCUMENT SCANNINS COVER SHEET
NPDES Permit:
NC0003298
Riegelwood Paper Mill
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Speculative Limits
Monitoring Report
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date:
June 7, 2013
This document is prated an r+01Mse paper - ignore any
C axitent axk the reuersfa side

NCD
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P. E. John E.
Governor Director
June 7, 2013
Mr. Floyd Whitmire, Mill Manager
International Paper Company
Riegelwood Mill
865 John L. Riegel Road
Riegelwood, North Carolina 28456
Dear Mr. Whitmire:
Skvarla, Ill
Secretary
Subject: Issuance of NPDES Permit
NCO003298
Riegelwood Mill
Columbus County
Facility Class IV
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to
the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as
subsequently amended).
The following changes have been incorporated into this permit renewal:
0 Lim_its for Chloroform were calculated in accordance with 40 CFR 430 Subpart B based on 3 years of
production data and added to Outfall 004 and Outfall 005.
• Limits for AOX were calculated in accordance with 40 CFR 430 Subpart B based on 3 years of
production data and added to Outfall 001.
0 Li-mits for Pentachlotophenol and Trichloroplicnol were calculated in accordance with 40 CFR
430.100 and 40 CFR 430.20 and added to Outfall 001.
• Limits for TSS were calculated in accordance with 40 CFR 430.22 and added to Outfalll 001.
• Outfall 002 was eliminated from the permit due to the elimination of the discharge.
• The influent monitoring requirements for BOD and TSS were eliminated (Outfall 001).
• Monitoring for Total Chromium, Total Mercury, Total Nickel and Total Zinc was removed from the
permit based on the results of the Reasonable Potential Analysis.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury 61, Raleigh, North Carolina 27604
Phone: 91 M07-63001 FAX: [phone]
Internet; www.rmat_ _erpuality,om
NonrthCarolina
Naturally
ff
An Equal Opportunity 1 Affirmative Action Employer

Monitoring for the internal outfalls parameters (except for flow) were reduced to Quarterly in '
accordance with the 40 CFR 430.02.
w
Please note that the receiving waterbody has been designated as Primary Nursery Area (PNA)
waters by the NC Marine Fisheries Commission. Such a designation may trigger a supplemental stream
classification of High Quality Waters (HQW) with additional NPDES requirements for new and
expanding wastewater discharges (per 15A NCAC 2B.0224), upon formal adoption of HQW class by the
NC Environmental Management Commission,
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 written petition, conforming to
Chapter 150B of the North Carolina General Statutes, and fled 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 other permits which may be required by the Division of Water Quality or permits
required by the Division of Land Resources, the Coastal Area Management Act or any other Federal. or
Local governmental permit that may be required. If you have any questions concerning this permit, please
contact Sergei Cherniltov at telephone number [phone].
Sincerely,
harles Wakild P.E.
cc: OPDES Files
Central Iles
Wilmington Regional Office / Surface Water Protection
Ms. Karrie-Jo Shell, EPA Region IV (e-copy)
Environmental Sciences Section, Ecosystems Unit (e-copy: Steve Kroeger and Carrie Kuhlman)
Aquatic Toxicology Unit (e-copy)

r
Permit No. NC0003298
..�--�
DEPARTMEN ENVIRONMENT. HEALTH_ AND NATURAL RESOURCES
ATER QU.
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 July 1, 2013
This permit and authorization to discharge shall expire at midnight on November 30, 2016
Signed this day June 7, 2013
iarles Wakild P.E., Director
i Division of Water Quality
By Authority of the Environmental Management Commission
Page 1 of 13

Permit No. 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:
Continue to operate existing treatment facilities (out£all 001) consisting of dual bar screens and
primary clarifiers, nutrient addition facilities,173 acres of aerated lagoons with re -circulation, sludge
holding Iagoons, 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 locations 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 13

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NC0003298 - International Paper Company
Latitude (Outfall 001): 34' 21' 10" Latitude (Outfall 002): 34' 21' 51"
Longitude (Outfall O011: 78' 12' 10" Longitude (Outfall002): 78' 12' 70"
USGS Quad: Acme, N.C.
Stream Class: C-Swamp, PNA-HQW
Receiving Stream: Cape Fear River
Sub -Basin: 03-06.17
Facility
Location
,fir Riegelwood Mill
✓Y Columbus County

Permit NCO003298
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [001]
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 001. Such discharges shall be limited and monitored by the Permittee
as specified below:
-PARAMETER
4? y y
"LIMITS
,'MONITORING REQUIREMENTS
Monthly Average
w t
k
Daily 1Vlaximum
Measurement
Frequency"
Sample ' E
'TyP e
Sample
I:ocatibni
Flow (MGD)
50.0
Continuous
Recording
Effluent
BOD, 5-day, 200C
une 1 — October 31
5,000 pounds/day
10,000 pounds/day
Daily
Composite
Effluent
BOD, 5-day, 200C
(November 1 -- May 31
10,000
pounds/day
20,000 pounds/day
Daily
Composite
Effluent
Total Suspended Solids
55,371
ounds/dapounds/day
103,063
Daily
Composite
Effluent
NH3-N
Weekly
Composite
Effluent
Temperature oC
Daily
Grab
Effluent
Dissolved Ongen
Doly averse > 5.0 m /L
Daily
Grab
Effluent
Dissolved Oxygen
I
Daily
Grab
U & D
H
> 6.0 and c 9.0 standard units
Daily
Grab
Effluent
Total Phosphorus m /L
Monthly
Composite
Effluent
Total Nitrogen (mg/L)
(NO2+NO3+TKN)
Monthly
Composite
Effluent
Chronic Toxici 2__Quarterly
Comj2osite
Effluent
Dioxin3
0.9 /L
Annually
Composite
Effluent
AOX4
2,899 pounds/day
4,425 pounds/day
Daily
Composite
Effluent
Trichloro henol5
40.9pounds/day
Weekly
Composite
Effluent
Pentachloto henol'
6.51 ounds/da
Weekly
Composite
Effluent
Salim
See Note 1
Grab,
U & D
Notes:
1. U: upstream at the International Paper water intake. D: downstream at the DuPont water intake. Instream 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. NOTE: As a participant in the loaner Cape Fear River Monitoring Coalition, instream monitoring
is not required Should the membershp in the Coalition be terminated, the Permittee shall not the Division immediately and be
instream monitoring as specified in this permit.
2. Chronic Toxicity (Ceriodaphnia) P/F at 8.0% with testing in January, April, July, and October [see A. (4)].
3. See A. (7) for derails.
4. AOX data shall, be submitted on a quarterly basis along with other Cluster Rule chemical data [see A. (9)].
5. Monitoring is suspended for these compounds as long as chlorophenolic-containing biocides are not used at the
facility.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Page 3 of 13

Permit NCO003298
A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [004]
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 monitored by the Permittee as specified below and detailed in partA. (9) of this permit:
PARAMETER
.Limits
Monitaring Re'qui'rementsz
Monthly
Average.,,
} 'Daily
t Average'`
Daily
Minimum,
Measurement
Ftequeney,
' ' Sam' plc
Type3` ' .
,Sample
Location'
Flown
Weekly
Calculated
Effluent
Chloroforms
10.4
pounds/day
17.4 pounds/day
Quarterly
Grab
Effluent
2,3,7,8 Tetrachloro-
dibenzo-p-dioxin
CDD
< 10 pg/L
Quarterly
Composite
Effluent
2,3,7,8 Tetrachloro-
dibenzo- -furan CD
31.9 pg/L
Quarterly
Composite
Effluent
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� trachlorophenol
< 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)].
2. Monitoring and flow calculations shall be in accordance with A. (9). Chemical results for Effluent Guideline parameters
as prepared by the perrnittee (Internal Outfall 004 parameters -+• AOX from Outfall 001) shall be reported on a quarterly
basis or more frequently.
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 wastestrearn.
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.
Definitions:
µg/L — Micrograms per liter pg/L — Picograms per liter ADT — air dried ton of pulp product
Page 4of13

0i
Pcrnut NCO003298
A• (3) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 1005]
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 monitored by the
Pennittee as specifier] below and detailed in part A. (9) of this permit:
TARAM'ETER1., ,:
•,•
' ';' :y. :.t• � �, ,,� €j
{
, ,,�,; ,, :Limit's• , , , , ;
+ "'• 't" •"' • •' r .t' _
_ ;; ,, ; ! Monitoring, Requirementss< .
� i.'tY*�..4_' ri ..a: '�1 _�s
.Monthly-, ,
Average-
�� Daily'
Average'
Daily, Maximum
1' , :
;'Wa'suremeiiit••
,;Frequency;;
I`• 'Sample
r�;' T,ype
'Sample
Location'`"
Flow2
Weekly
Calculated
Effluent
Chloroforms
8.8
pounds/day
14.8 pounds/day
Quarterly
Grab
Effluent
2,3,7,8 Tetrachloro-dibenzo-p-
dioxin CDD
< 10 pg/L
Quarterly
Composite
Effluent
2,3,7,8 Tetmchloro-dibenzo-p-
furan CD
31.9 pg/L
Quarterly
Composite
Effluent
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/U
Quarterly
Composite
Effluent
2,3,4,G-Tetrachlorophenol
< 2.5 µg/L4
Quarterly
Composite
Effluent
Pentachlorophenol
< 5.0 µg/L4
Quarterly
Composite
Effluent
Footnotes:
1. Effluent is composed of bleach plant effluent -acid (collected from acid sewer) and bleach plant effluent -
alkaline (collected from alkaline sewer) [see A. (9)].
2. Monitoring and flow calculations shall be in accordance with A. (9). Chemical results for Effluent Guideline
parameters as prepared by the pexmittee (Internal Outfall 005 parameters + AOX from Outfall 001) shall be
reported on a quarterly basis or more frequently.
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 wastestrenins) in DMRs.' Grab- collect separate grab samples evei-T 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 pexmittee must report total chloroform mass loading,
Definitions:
µg/L -- Micrograms per liter pg/L — Picograms per liter
Page 6 of 13
ADT —air dried ton of pulp product

Permit NCO003298
A. (4) CHRONIC TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY)
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, quarterly monitoring using test procedures outlined in the "North Carolina
Ceriodaphnia 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 test procedure performed as the first rest of any single quarter 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 -February 1998) or subsequent
versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration
having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable
impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes,
and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised -February 1998) 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 TGP3B for the pass/fail results and
THP3B for the Chronic Value. Additionally, DWQ Form AT-3 (original) is to be sent to the following address:
Attention: NC DENR / DWQ / Environmental Sciences Section
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later titan 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 Environmental 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. Should any test data from this monitoring requirement or tests performed by the North
Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be 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
require immediate follow-up testing to be completed no later than the last day of the month following the month of the
initial monitoring.
Page 6 of 13

Permit NCO003298
A: (5) 'BIOCIDE CONDITION
The Permittee shall obtain authorization from the Division 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. 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
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 DWQ may reopen this permit to require 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
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/1-Iigh 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
2. Fish tissue
Annual Composite
DWQ approved monitoring plan
Fish tissue analysis will be performed in accordance with the Division of Water Quality 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.
Page 7 of 13

Permit NC0003298
The chlorodibenzo dioxins and furans to be monitored are (this requirement applies for fish tissue monitoring I
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
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
A. (8) CLUSTER RULE BMPs
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. Bh2 Implementation Requirements
I. 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 gust 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
Snit. ting 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 permittee 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
service. The refresher training must be conducted at least annually and the training program must be
documented.
S. 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
Page 8 of 13

Permit NC0003298
items involved, the circumstances leading to the incident, the effectiveness of the corrective actions taken to
contA 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 Iosses. Such monitoring must be performed in accordance
with Section E.
Section B. BMP Plan Requirements
1. The permittee must prepare and maintain a BMW 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.
3. As 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; (i.i) 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; (iii) The potential for contamination of storm water from the immediate 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.
Page 9 of 13

Permit NC0003298
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.
S. 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 BA., 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 tinder 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 Recordkeeping Requirements
I. 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 System 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:
Monitoringparameters. 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 (TOC)). Alternatively, the mill may use a measure related to spent pulping liquor lnsses
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 pertittee 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
months of daily measurements. The action levels must consist of a lower action level, which if exceeded will
Page 10 of 13

Permit NCO003298
trigger the investigation requirements described in Section E, and an upper action level, which if exceeded will
r 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. I. 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" o£ 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 DENR, Division of Water Quality, 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.
Page 11 of 13

Permit NCO003299
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.
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
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 1, 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 (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 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 permittec 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 H, Section D.3. This exclusion is similar to that provided for pump log flow calculations.
Page 12 of 13

Permit NCO003298
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 Qanuary- March, April- June, July- September, October -
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 fortes, with a
separate form provided for each month.
Page 13 of 13

DENR/ DWQ
FACT SHEET FOR NPDES. PERMIT DEVELOPMENT
NPDES No. NC0003298, International Paper Company (IP)
Riegelwood Facility
F aciliti Irifor atio>n
A licant Facili , Name::.
International Paper - Riegelwood Facility
A° licant`Address: ;: tj
865 John L. Riegel Road, Riegelwood, NC 28456
Facili .. Address:
865 John L. Riegel Road, Riegelwood, NC 28456
"P6rmitted Flow..;
50 MGD
'e of Waste'::
99.8 % Industrial, 0.2% Domestic
Facility/Permit Status:--'.;' "
Major Indust • Renewal; First inclusion of the cluster rules
Columbus
Miscellaaeous'.;
Receivmg;Stream ,r `i
Cape Fear River
Regional;' „
WiRO
Stream Classification:; ;''
C-Sw
;:Quad°
J26SW
303(dJ'LMisted? `
Yes- DO and
biological
Per mit;Writer~ t'
Sergei Chernikov
�Subbasin:
030617 18-63-a
Date r'�;,1 ,. ��,;
January 9, 2013
:IDrama`e'Area` mil
5,301
Siirhiner 7Q10'. cfs < ;
856
a Winter.7Q1.0!(6f§) ...`
01
Ave`ra "e Flow` cfs
5330
Prima y`SIC.Code ""`
2611 Pulp/Kraft
Mill, 2621 Paper Mill
SUMMARY
The International Paper (IP) Company - Riegelwood Facility is located near Wilmington. iP
takes the raw material (logs/chips) and produces paperboard (bleached product), and fluff pulp
(bleached product). Facility operates three bleach plants, Bleach Plant 1 process softwood
(pine primarily), Bleach Plant 3 process -hardwood, and Bleach Plant 2 switches between
hardwood and softwood depending on the production needs. Facility operates one external
outfall (Outfall 001),and two newly established internal outfalls (Outfall 004 and Outfall 005).
The internal outfalls were established to implement Cluster Rules.
The facility is required to monitor for dioxin in fish tissue. The ESS staff evaluated the latest
report submitted by IP in 2010 and concluded that "over the past 16 years, 1996-2009, all
dioxin concentrations have been below the state advisory criterion of 4 parts per trillion".
Outfall 001
This outfall contains wastewater associated with the all industrial operations, landfill leachate,
and sanitary sewer wastewater.
Outfall 001 and the newly established Internal Outfall 004 (combines effluent from Bleach
Plant 1 and Bleach Plant 2) and 005 (effluent from Bleach Plant 3) are subject to the Cluster
Rules - the modifications expressed by 40 CFR 430, Subpart B (430.20) - Bleached
Papergrade Kraft and Soda (promulgated April 15, 1998).
In accordance with the Cluster Rules each Bleach Plant should be monitored for numerous
parameters. However, due to the configuration of deep sewer lines the permittee was unable to
access effluent from Bleach Plant I and Bleach Plant 2 separately. EPA has granted a request
from the permittee to establish one sampling point for both plants. However, acid waste and
alkaline waste will be sampled separately. Bleach Plant 3 has a separate sampling point.
The current oxygen consuming waste limits (BOD5) are water quality limited. The dioxin limit
(0.9 pg/L) is also a water quality based limit. These limits will remain in the permit.
International Paper Riegelwood NC0003298
NPDES Renewal
Page 1

In 1992, the facility has requested. to a variance from -the Environmental Management
Commission to redefine the summer period. The Environmental Management Commission has
granted a variance request, the summer for this facility is now defined as June 1 - October 31.
International Paper has requested the continuation of the variance with this renewal, the
request was granted.
TOXICITY TESTING:
Current Requirement: Chronic. P/ Fat 8.0%, January April, July, October.
Proposed Requirement: Chronic P/F at 8.0%, January April, July, October.
The facility has had a good toxicity monitoring record for the past 4.5 years, they passed all the
tests.
RPA:
The Reasonable Potential Analysis (RPA) was conducted for Cr, Hg, Ni, and Zn (see attached).
The results indicate that the limits for these parameters are not necessary.
COMPLIANCE SUMMARY:
The DMRs were reviewed for the period 12/01/2007 through .12/01/12. The facility had only
one limit violation, BOD on 09/30/2010.
MERCURY EVALUATION:
The mercury evaluation was conducted in accordance with the Permitting Guidelines for
Statewide Mercury TMDL.
Year
2008
2009
2010
2011
2012
Annual average
3.9
6.2
3.2
2.3
2.1
concentration n L
Maximum sampling
18.6
9.8
15.7
6.7
7.8
result n ' I;
Allowable concentration for this facility is 144.6 ng/L. All Annual average mercury
concentrations are below allowable and no single value exceeds TBEL of 47 ng/L. Based on
the Permitting Guidelines for Statewide Mercury TMDL, the limit and monitoring for mercury is
not required.
INSTREAM MONITORING:
IP is required to perform stream sampling for D.Q. and salinity with their current permit.
Stream sampling is conducted 3/week during June - September and 1/week during the
remainder of the year. As a participant in the lower Cape Fear Monitoring Coalition, the
instream monitoring is not required. Should the membership in the Coalition be terminated,
the facility must notify Division immediately and begin instream monitoring as specified in this
permit.
Due to the significant number of dischargers in that segment of Cape Fear River it is difficult to
separate influence of IP discharge on water quality in the receiving stream.
CHANGES IN THE 2007 PERMIT
In 2007 there were a number of significant changes in the permit due to the application of the
Cluster Rule requirements. The changes are described below:
In accordance with the Cluster Rule (40 CFR 430 Subpart B) two new internal outfall
have been established: Outfall 004 for combined effluent from bleach plants I and 2,
and.Outfa1l 005 for effluent from Bleach Plant 3.
Limits for Chloroform were calculated in accordance with 40 CFR 430 Subpart B based
on 3 years of production data and added to Outfall 004 and Outfall 005.
Limits for AOX were calculated in accordance with 40 CFR 430 Subpart B based on 3
years of production data and added to Outfall 001.
International Paper Riegelwood NCO003298
NPDES Renewal
Page 2

•
Limits for Pentachlorophenol and Trichlorophenol were calculated in accordance with
40 CFR 430.100 and 40 CFR 430.20 and added to Outfall 001.
•
Special Condition A. (9.) was added to the permit in accordance with the provisions of
the Cluster Rule (40 CFR 430,03),
•
Special condition A. (10.) was added to the permit in accordance with the provisions of
the Cluster Rule (40 CFR 430).
•
In accordance with the Division's new Permitting Strategy for the Cape Fear River
Basin, the Nutrient Controls Re -Opener condition was added to the permit (See A. (7.)).
•
Biocide special condition was added to the permit (See A. (6.)).
•
Special Condition A. (8.) ,Dioxin Monitoring was updated to reflect current DEH
requirements.
•
Mercury limits were eliminated from the permit based on a statistical analysis of
the effluent data. The monitoring frequency for Mercury was reduced to
2/Month.
•
The monitoring frequency for Chromium, Nickel, and Zinc were reduced to
Quarterly based on a statistical analysis of the effluent data.
•
Outfall 002 was added to the permit to allow sand filter backwash discharge
from the surface water treatment plant (WTP). The discharge also contains
small amount of stormwater from the roof of the water treatment plant, and
small leaks from the various seals in the WTP building
•
Mercury sample type was changed to Grab to be consistent with method EPA-
1631E requirements.
•
Summer period was changed to June 1 through October 31 to correct an error
(this summer period was granted by North Carolina Division of Environmental
Management as a variance in 1992).
•
Dioxin monitoring frequency in the effluent was changed to Annual and, dioxin
monitoring of the sludge, wastewater treatment plant influent and landfill
leachate was eliminated based on the long term monitoring without detection.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: January 29, 2013 (est.)
Permit Scheduled to Issue: March 25, 2013 (est.)
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please
contact Sergei Chernikov at [phone] or [e-mail].
PROPOSED CHANGES:
• Limits for Chloroform were calculated in accordance with 40 CFR 430 Subpart B based
on 3 years of production data and added to Outfall 004 and Outfall 005.
• Limits for AOX were calculated in accordance with 40 CFR 430 Subpart B based on 3
years of production data and added to Outfall 001.
• Limits for Pentachloro phenol and Trichlorophenol were calculated in accordance with
40 CFR 430.100 and 40 CFR 430.20 and added to Outfall 001.
• Limits for TSS were calculated in accordance with 40 CFR 430.22 and added to Outfall
001.
• Outfall 002 was eliminated from the permit due to the elimination of the discharge.
• The influent monitoring requirements for BOD and TSS were eliminated (Outfall 001).
• The classification of the receiving stream was updated to C-Swamp PNA-HQW based on
the information from the Division of the Marine Fisheries.
• Monitoring for Total Chromium, Total Mercury, Total Nickel and Total Zinc was removed
from the permit based on the results of the reasonable Potential Analysis.
• Monitoring for the internal outfalls parameters (except for flow) were reduced to
Quarterly in accordance with the 40 CFR 430.02.
International Paper Riegelwood NC0003298
NPDES Renewal
Page 3

The Division is unable to grant the facility's request to eliminate monitoring for chloroform,
chlorinated phenolics and dioxins in Outfalls 004 and 005, and AOX in Outfall 001. The ,
Cluster Rule 40 CFR 430.02 requires continuing monitoring of these parameters. '
CHANGES IN THE FINAL PERMIT:
• The PNA classification was removed from the permit based on the legal advice.
international Paper Riegelwood NC0003298
NPOES Renewal
Page 4

International Paper Company - Riegelwood, Pulp and Paper Facility
Bleach plant 1 and bleach plant 2 have a combined sewer system
calculations are based on 355 days of operatrion per year
Bleached Kraft
Air Dried Tons (english)
Average per
year
Average
(tons/day)
Average
(pounds/day)
Average
(kg/day)
Bleach Plants
2008 2009 2010
Bleach plant 1+ 2
Bleach plant 3
430,869 1 427,999 481,358
393,463 340,717 403,306
446,742
379,162
1,258.40
1,068.10
2,516,856.30
2,136,123.90
1,144,025.60
970,965.4
Total
824,332
1 768,716
1 884,664
1 825,904.00
1 2,326.51
4,652,980.3
2,114,991.01
Limits for chloroform for each bleach plant are calculated in accordance with
Subpart B effluent guidelines (430.24)
Bleach plant 9 + Bleach plant 2
Chloroform daily max = 6.92 glkkg * 1,144 kkg = 7.92 kglday =17.4 lb/day
Chloroform monthly average = 4.14 glkkg * 1,144 kkg = 4.74 kglday =10.4 lb/day
Bleach plant 3
Chloroform daily max = 6.92 9/kkg * 971 kkg = 6.72 kg/day =14.8 Iblday
Chloroform monthly average = 4.14 glkkg * 971 kkg = 4.02 kg/day = 8.8 lb/day
Effluent limits for external outfall are calculated in accordance with
Subpart B effluent guidelines (430.24)
AOX daily max = 0.961 kglkkg * 2,115 kkg = 2,011.4 kglday = 4,425 lb/day
AOX monthly average = 0.623 kglkkg * 2,115 kkg=1,317.6 kglday = 2,899 lb/day
Pentachlorophenol daily max = 0.0014 kglkkg * 2,115 kkg = 2.96 kg/day = 6.61 Iblday
Trichlorophenol daily max = 0.0088 kglkkg * 2,115 kkg =18.6 kg/day = 40.9 lb/day
TSS daily max = 22.15 kglkkg * 2,115 kkg = 46,847 kglday=103,063 Iblday
TSS monthly average =11.9 kglkkg * 2,115 kkg = 25,168.5 kg/day = 55,371 lb/day
As summaried 10/21/2005 3298-production data-2011.xls As summarized by Diane Hardison

International paper REASONABLE POTENTIAL ANALYSIS
NCO003298
Qw(&fGD)= 50.00
WWTPAVTPClass: IV
1Q10S (cfs)= 68&2$
1WC @ IQIOS = 10.12!G
7QI0S(cfs)= 856.00
IWC ®7QIOS= 8.30%
7QIOW (cls)= 1101.60
IWC @ 7QIOW = 6.58%
30Q2(cfs)= NO 3OQ2 DATA
IWC@ 30Q2= NIA
Avg. Stream Flow, QA (cis) — 5330.00
IWC @ QA = 1.43;6
Receiving Stream: Cape Fear River
Stream Class: C-SW
Outfaw 001
Ow = 50 MGD
CHRONIC TEST CONCENTRATION = 8.3%.
PARAMETER
STANDARDS S CRITERIA (2)
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
TYPE
-A
to
(1)
NC WQS / Applied 1/2FAV /
a
Z
D
n 4 Det. Max Fred Allowable Cw
Chronic Standard Acute
Cw
Acute: 10,098.8
Chromium
NC
50 FW(7QIOs) 1022
ug1L
12 10
25.8
_
602 _'w-
Chronic: 4
remove moiiltolia4 "
No value > Allowable Cw
s,....
Acute: NO WQS51
: T
Mercury
NC
12 FW(7QIOs)
0.5
nglL
117 92
30.7_-
Chronic: 144.E
rernave miingcrinQ "
No value > Allowable Cw
"'
Acute_ 2,579.1
no
Nickel
NC
88 FW(7QIOs) 261
ug1L
12 lZ
43.7
_ _ _ _ _
_ - 1
Chronic: 11060-2::--
- _—_-
No value > Allowable Cw==.---
Acute: 662.1M.
Zinc (AL)
NC
50 FW(7QIOs) 67
ugfL
12 12
296-4
_ _
Chronic: 6@.4
remove monWrrg - - =
No value > Allowable Cw
- -
320& RPA- 2011.xism, rpa
Page 1 of 1 U712013

REASONABLE POTENTIAL ANALYSIS
Date Data
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
18
17
18
19
20
21
27
28
29
30
31
32
33
34
35
36
37
1
38
39
y 40
51
52
53
Chromium
8DI-012DL
Results
2.5
Std Dev.
2.5
Mean
11
C.V.
10
n
10
5
Mult Factor
12
Max. Value
10
Max. Pred Cw
7
8
7
5
7.5000
0,4302
12
2,15
12.0 ug1L
25.8 uglL
1
2
3
4
5
8
7
8
9
10
1i
12
13
14
15
18
17
is
19
20
21
22
23
24
25
26
27
28
29
30
$1
32
33
34
3$
38
37
38
39
40
41
42
43
44
45
45
47
48
49
5D
51
62
63
54
55
58
57
58
59
5o
a1
62
63
64
65
66
67
88
89
70
Mercury
Date Data
8DL■112DL
Results
5.4
5.4
Sic! Dev.
9: cst
9.4
9.4
Mean
�•„''
18.5
18.5
C.V.
1.2
1.2
n
•c= ..: �: �' i
8.4
8.4
:
4.1
4.1
Mult Factor
4.3
4.3
Max. Value
:
9
9
Max. Pred Cw
10
18
10.8
10.8
1
1
�r1E a;
2.5
2.5
3.4
3.4
3.3
33
II't E;1riI;,
8.2
3.9
3.9
fln;ial re
µjiis7i,:W =n
1.7
1.7
GiE'S
3.3
3.3
3
3
s ;1.1lki
1.8
1.6
2.3
2.3
€, tMa for
2.2
2.2
0.5
0.6
0.7
0.7
€j'
3i;t is
1.3
1.3
..p k
3A
3.1
is
5
5
3.5
3.5
<,
2.54
2.54
I
2.52
2.52
3.9
2.5
3.9
2.5
5
5
2.5
2.5
2.5
2.5
2.5
2.5
6.0
3.2
3.2
d,'
5
t,4 >:;
5
5
3.8
3.6
41p=,`ylE,iw;
2.5
2.5
U01 �a,=, i1>
3.6
3A
2.5
2.5
2.5
2.5
2.5
2.5
itr ,y: 4;
2.5
2.5
2.5
2.5
2.5
2.5
l-t :
2.5
2.5
t tu- �:-'I- -u
15.7
15.7
AI . 4-.,
2.5
2.5
*�'_i:'
. T - r
4.79
4.79
5.7
5.7
1.35
1.35
2.5
2.5
3.3985
1,0890
117
1.65
18.6 ng/L
30.7 ng/L
4-
3298- RPA• 2011.Asm, data
117=13

REASONABLE POTENTIAL ANALYSIS
71;,;'
72
73,,'p �.
741 to
75SE,,11 141 4
764 1i
77 l,j78
4
79
80 IL
82 t I
8a'I 84'�1, til�Ij�j
I'
85
8667 '88
89,
ISE Iota;
e
90r
91 :t rr,:1
92 jj`clibil
93 '.. 11 1 + ir),
94 �EiPPi
95
98 y li if lit'
97
98 -: • Ir' i� 3i
99
1011ilit
102104
105
1071.,:
108
109'33'�£Iel�'
110 it'4 I�. s"i'si
111 'jl` IA:
i'.
112�ii�!,V'
113 !: iE €
1144'"
117
119 „i'l311
120
121
122
123 :jw
124
125
126 t;, !ilr Y A:
127gt"3=' IE'°il
3t4I,;Il.t
129
130
131
132C� r
133 �1
134
135.'i'?t {
136j
,38j';'=lA k
139 y :;
140.-
141
142t ,'s
143, jqi `i6f,yil;
144E -I_ I i:r";
2A7
3.15
2.5
4.12
6.7
0.5
3.9
2.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
2.29
1.14
0.5
0.5
2.52
0.5
0.5
1.08
1.88
0.5
0,5
0.5
0.5
0.5
0.5
0.5
7.96
6.15
0.5
0.5
6.8
5
0.5
5-04
0.5
2.5
3,17
2.47
3.15
2.5
4.12
6.7
0.25
3.9
2.5
0.25
0.25
0.25
0.25
0.25
0.26
0.25
0.25
0.25
0.25
0.25
0.25
2.29
1,14
0.25
0.25
2.52
0.25
0.25
1.08
1.88
0.25
0.25
0.25
0.25
0.25
0.25
0.25
7.96
6.15
0.5
0, 5
6.8
5
0.5
5.04
0.25
2.5
3.17
5-
3298- RPA- 2011.xtsm, data
11712013

REASONABLE POTENTIAL ANALYSIS
Nickel
BDL=1120L
Results
16
Std Dev.
14
Mean
24
C.V.
25
n
26
26
Mull Factor =
16
Max, Value
27
Max, Pred Cw
24
16
14
16
20.3333
0.2622
12
1.82
27.0 uglL
43.7 uglL
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
18
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
64
65
66
67
68
Be
70
361
65'
A
ta
I
Zinc (AL)
BDLOI12DL
ReaultS
43
Std Dev.
41
Mean
56
C.V.
34
n
31
103
Mull Factor
123
Max. Value
44
Max, Pred Cw
46
55
38
55
56.0000
0.5008
12
2.41
123.0 ug1L
296.4 ug1L
-7-
3298- RPA- 2011,x1sm, data
1/7/2013

INTERNATIONAL PAPER
Riegelwood, NC
Production Stats - Paper Machines 2008-2010
Bleached Board = Paper Machine 15
Bristols = Paper Machine 18
Pulp = Pulp Dryer
2008 2009 2010
Units
Finished Tons Manufactured - Total Al Tons
7,,96,568;'
71C,06 .•"
829,585
Bleached Board Al Tons
209,724
190,285
223,684
Bristols Al Tons
180,894
141,794
202,721
Pulp Al Tons
405,890
382,731
403,180
Production Stats - Pulp (2008-2010)
2008 2009 2010
Tons Manufactured - Total Units F 824,332 768,716 884,664
Unbleached Pine ADT 399,798 426,301 477,456
kkvUnbleached Hardwood - Batch ADT 31,071 1,698 3,902
n leached ardwood-Kamyr ADT 393,463 340,717 403,306
Tons Manufactured - Total =,772,541 -.. 703J50 .812,563
Bleached Pine ADT 372,044 393,803 433,524
Bleached Hardwood ADT ' 400,497 309,347 379,039
S:\Groups\Environmental\Wastewater\NPDES Permit Info\2011 Application\2010-2011 Prod Stats.xlsx

INTERNATIONAL(& PAPER
Riegelwood, NC
Production Stats - Paper Machines (2008-2010)
Bleached Board = Paper Machine 15
Bristols = Paper Machine 18
Pulp = Pulp Dryer
2008 2009 2010
Units
Finished Tons Manufactured - Total Al Tons
796,508
_Y714,810
7829;585
Bleached Board Al Tons
209,724
190,285
223,684
Bristols Al Tons
180,894
141,794
202,721
Pulp Al Tons
405,890
382,731
403,180
Production Stats - Pulp (2008-2010)
2008 2009 2010
Tons Manufactured - Total
Units
824,332
768,715
884664
Unbleached Pine
ADT
399,798
426,301
477,456
Unbleached Hardwood - Batch
ADT
31,071
1,698
3,902
Unbleached Hardwood-Kamyr
ADT
393,463
340,717
403,306
Tons Manufactured - Total
772,541. ;
703,15U
;: 812,563
Bleached Pine
ADT
372,044
393,803
433,524
Bleached Hardwood
ADT
400,497
309,347
379,039
S:\Groups\Environmental\Wastewater\NPDES Permit Info\2011 Application\2010-2011 Prod Stats.xlsx

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
�z REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
yf�� FROS�C, ATLANTA, GEORGIA 30303-8960
M INR 4 2013
Mr. Jeff Poupart
Supervisor, NPDES Unit
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Draft Permit Review
International Paper Company - Riegelwood Mill
National Pollutant Discharge Elimination System Permit No. NC0003298
Dear Mr. Poupart:
This letter is to notify you that the U.S. Environmental Protection Agency has completed its review of
the draft National Pollutant Discharge Elimination System (NPDES) permit referenced above, which is
an existing source discharger. The draft permit and application materials were transmitted by your office
to the EPA on February 4, 2013. Pursuant to Section IV.B.7 of the North CarolinatEPA NPDES
Program Memorandum of Agreement and 40 Code of Federal Regulations (C.F.R.) § 123.44(a) and (b),
this letter will serve as the EPA's comments pertaining to the issuance of this permit.
The EPA commends North Carolina for implementing our September 6, 2012, recommendations to
address statewide mercury impairment and North Carolina's approved mercury Total Maximum Daily
Load. The permit's fact sheet includes the results of a mercury evaluation conducted by North Carolina
which shows that the allowable concentration for this facility is 144.6 nanograms per liter (ng/l) and that
all the annual average mercury concentrations for 2008-2012 are below a technology based effluent limit
of 47 ng/l. However, as we noted in that recommendation letter, North Carolina should still assess
reasonable potential to cause or contribute to the state's existing total mercury water column standard of
12 ng/l.
Your draft fact sheet showed that the facility's previous mercury monitoring only requirements for
Outfall 001 were deleted based on results of the statistical analysis of the data. Your statistical analysis
concluded that based on 117 samples, the maximum predicted effluent concentration of 30.7 ng/1 for
total mercury has no reasonable potential to cause an exceedance of this standard. The background
concentration was assumed to be zero, and the calculated instream waste stream at 7Q 10 conditions is
8.3 percent. As stated in our September 6, 2012, letter to you, because North Carolina's Clean Water Act
Section 303(d) list identifies every water body in the State as impaired for mercury, the EPA Region 4
believes that it is inappropriate to assume background is zero for this pollutant. If there are no '
background data in the receiving water body for total mercury, we recommend that North Carolina use
the authority under 40 C.F.R. § 122.21(e) and corresponding state NPDES regulations to request the
permittee collect site specific upstream receiving water total mercury concentration data during the
permit term and include this data as supplemental information to the subsequent permit application.
Intamet Address (URL) • http://www.opa,gov
R&gyvted/R"VdabW .PAnted with Vegetable 04 Sued tnks on Ft"ded Paper (Mk*num 3M Postearmmet)

Alternatively, North Carolina could utilize instream mercury concentrations that have been documented
in nearby waters. If you are unable to obtain site -specific instream mercury data as described above, the
EPA recommends that you also include a 12 ng/l weekly average limit in the final permit (ref: 40 C.F.R_
I 22.44(d)(1)(i)).
If you have any questions, please contact Ms. Karrie-Jo Shell of my staff at [phone].
Sincerel ,
Christopher B. Th as, Chief
Pollution Control and Implementation Branch
Water Protection Division
cc: Mr. Floyd Whitmire
Mill Manager
International Paper Company - Riegelwood Mill

INTERNATIONAL PAPER
February 21, 2013
RIEGELWOOD MILL
JOHN L. RIEGEL ROAD
RIEGELWOOD, NC 28456
Certified Mail: 7011 2000 0001 63d0.�4-40
Mr. Sergei Chernikov, Ph.D.
%�
M
Fnvirnnrrlental F,n�irlPPr TI
��
�
Complex NPDES Permitting Unit
Division of Water Quality
1617 Mail Service Center,
Raleigh, NC 27699-1617
Subject: Comments on Draft NPDES Permit NCO003298
International Paper Company - Riegelwood Mill, Columbus County
Dear Mr. Chernikov:
We have only one comment on the draft permit to offer at this time. As I believe you and my
staff have already discussed, the permit cover letter, the Supplement to the Permit Cover Sheet,
and the Fact Sheet indicate that the classification of the Cape Fear River at the point of
discharge is Class C-Swamp PNA-HQW. However, according to the officially adopted
classifications of the Cape Fear River by the Environmental Management Commission
referenced in 15A NCAC 0213.0311, this portion of the Cape Fear River is classified as Class
C-Swamp.
If you have any questions or would like to discuss anything related to the draft permit, please
do not hesitate to call Ed Kreul at [phone].
Sincerely,
Floyd .Whitmire
Mill Manager — Riegelwood Mill
cc: Edward Kreul
Emily Henderson

AFFIDAVIT OF PUBLICATION
NORTH�CAROLI NA
Cumberland County
� r Pu6lK NWi<c
North Carolina knvinmmcnlnl
Mutx*cinrta Cutimi.xlim1NP171i't l4,it
1617 hlail lkervlce Cenler
Ralcigh, NC 27647 c 1617
Naliee ad Intent h, I— n NPI i8
1, MIewaler Permit
The N�th Carolina Eevitonmenial Man-
n�g%cmcl CZ,mmusi,n rrnr—. k, k sue a
NIZZA7 wsmew:aer dtachargc p, m4 to
the l+crxe,n(a) litkd hllow. Wtitten cmm-
mt. n:batdinp, the ppro�re,,1 I+�rmit will
be �rrptxsl tnttl 30 days tfter IIu puNixfi
date of Ihix notice: The Direct- of the NS:
Divixim f Water Qualily (DW9) may lu,ld
a puhlie hra.ing xlmuN them l+e n xignifi-
cant doggm, tf puhlir inks-sl. 11eose n,yl
cnmmcnlr an&mn lnfnnmtlea regt to to
VW(2 at the. A— nddtxac Intmemed per-
b. may vigil the DNVQ to 512 N. SAix-
butw z L, Raleigh. NC k, mirw infixnta-
fiim nn rma file. Additional inf dcm
NI'DU9 pcimil.x and shin wxicc ,noy be
fnrntd im t,ur wcbaiw htpll nU.ncdrnr.
n&CFJxglxurl� InpdvdLakndu. r by
c rag ,(919) flit 7.6, 911. fntunati,mal Pnper
C' my teyucakd- runeval ,f pprram,
"I NO fix Riegelwn„d Mill in Cnlum-
Aux (.'gun ly Ihia !acuity di,x-hmSe is Leal-
ed industna] warkwat ,r In Cape fear Riv-
Cupe 1 c- River liastn
Before the undersigned, a Notary Public of said County and state, duly
commissioned and authorized to administer oaths, affirmations, etc.,
personally appeared. CINDY L. OROZCO
Who, being duly sworn or affirmed, according to law, doth depose and say
that he/she is LEGAL SECRETARY
of THE FAYETTEVILLE PUBLISHING COMPANY, a corporation organized
and doing business under the Laws of the State of North Carolina, and
publishing a newspaper known as the FAYETTEVILLE OBSERVER, in the
City of Fayetteville, County and State aforesaid, and that as such he/she
makes this affidavit; that he/she is familiar with the books, files and
business of said Corporation and by reference to the files of said publication
the attached advertisement of CL Legal Line
NOTICE OF INTENT TO ISSUE A NPDES WASTEWATER
PERMIT -INTERNATIONAL PAPER CO.
of NC DIVISION OF WATER QUALITY
was inserted in the aforesaid newspaper in space, and on dates as follows:
2/4/2013
and at the time of such publication The Fayetteville Observer was a
newspaper meeting all the requirements and qualifications prescribed by
Sec. No. 1-597 G.S. of N.C.
The above is correctly copied from the books and files of the aforesaid
corporation and publication. N
LEGAL SECRETARY
Title
Cumberland County, North Carolina
Sworn or affirmed to, and subscribed before me, this 5 day
of February, A.D., 2013.
In Testimony Whereof, I have hereunto set my hand and affixed my
official seal, the day and year aforesaid.
H. Walters, Notary Public
IMy commission expires 5th day of December, 2015.
MAIL TO: NC DIVISION OF WATER QUALITY
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-00001617
0003902238

To: NPDES Permitting Unit
Surface Water Protection Section
Attention: Sergei Chernikov
Date: September 27, 2011
NPDES STAFF REPORT AND RECOMMENDATION
County: Columbus
Permit No. NCO003298
PART I - GENERAL INFORMATION:
Facility: International Paper
Riegelwood Mill
865 John L. Riegel Road
Riegelwood, NC 28456
Mailing: Edward J. Kreul, Manager EHS&S
See address above
1. Date of Investigation: Inspection date September 22, 2011
2. Report Prepared by: Linda Willis
Facility Contact: Edward Kruel 910-362-4883 (o), 910-612-2504 (c)
Wallace Coverdale B/U operator 910-362-4590
Kim Fail 910-362-4753 (o), 910-512-0608 (c)
Pat Soles WW3
4. Directions to Site: From WiRO, travel west on Hwy 74/76 approximately 35 miles to
Riegelwood. Turn right on Hwy 87, travel approximately 5 miles. Turn right at
intersection of Hwy 87 and John L. Riegel Road to plant entrance.
Discharge Point: The facility has one discharge point (34021' 10"N and 78012' 10"W)
6. Receiving stream or affected surface waters: Cape Fear River
a. Classification: Class C Sw **PNAIHQW** Impaired for DO and Biological
b. River Basin and Subbasin No.: 03-06-17 AU # 18-63-(a) Segment length: 3.8 miles
c. Describe receiving stream features and pertinent downstream uses: -Secondary
recreation. No rating for aquatic life. There are two ambient monitoring stations in this
segment of the river. According to CFR Basinwide WQP October 2005, chlorophyll a is
noted . as a stressor with 33.3 % of the samples exceeding standard. There are 41
permitted wastewater discharges in this subbasin, and seven registered swine operations.
Impairments include low dissolved oxygen, turbidity and low pH. Since the TMDL
model suggests wastewater inputs to the Cape Fear River contribute very little to the
low DO condition overall, it might be instructive to consider what impacts to dissolved

oxygen many large wastewater inputs in smaller segments impose,
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS:
1.
0
3.
4.
5.
6.
7.
8.
9.
a. Volume of wastewater to be permitted: 50 MGD
b. What is the current permitted flow limit? 50 MGD
C. Actual treatment capacity of the current facility? Not specified.
d. Date(s) and construction activities allowed by previous Authorizations to Construct
issued in the previous two years: NIA
Please provide a description of existing or substantially constructed wastewater treatment
facilities:
This facility is composed of dual mechanical bar screens, dual primary clarifiers, earthen
sludge ponds and three sludge screw presses, a series of three aeration lagoons with a
total of 87x75HP aerators and 9x50HP aerators (WiRO requested verification of number
and sizes of aerators during site visit) with one settling pond, nutrient and defoamer
addition facilities, oxygen injection facilities, flow measurement and recording
equipment.
Please provide a description of proposed wastewater treatment facilities: N/A
Possible toxic impacts to surface waters:
carcinogens, PCBs, pesticides,
Pretreatment Program (POTWs only): N/A
metals, dioxin, Beta emitters, various
Residuals handling and utilization/disposal scheme: NIA
Compliance History: quarterly monitoring violations exist
Treatment plant classification: WW4
SIC Code(s): 2611, 2621, previous staff reports indicate 2631 as well.
PART III - EVALUATION AND RECOMMENDATIONS:
The permittee requests relief from daily influent BOD and TSS monitoring and states the percent
reduction limits do not apply to their facility. W1RO is not in support of the removal of the
influent monitoring for either parameter unless the permitting unit determines that the regulation
requiring such has been misapplied.

The permittee requested that the monitoring associated with the Cluster Rule for Chloroform,
chlorinated phenolics and dioxins in the internal outfalls as well as adsorbable organic halides
(AOX) in outfall 001, be removed from the permit. WiRO has no objections to this request
should the Rule allow relief. Any of the parameters associated with the Cluster Rule that have
water quality based limits, and are expected to be present, should remain in the permit.
The permittee requests that the outfall 002 be removed from the permit since the outfall has been
eliminated. WiRO concurs that this outfall is no longer in existence and that the discharge has
been removed permanently. The discharge has been rerouted directly to IP's intake pump station
for reuse in the water treatment plant. WiRO recommends this outfall be removed from the
permit.
The permittee has provided their written rationale for continuation of the summer period
variance. WiRO would like the NPDES Permitting Unit to take into consideration the recent and
historically unusual algal blooms that are taking place in the Cape Fear River when making their
decision for this request since these algal blooms have an impact on the DO in the river. They
are becoming more prevalent and are impacting longer distances in the river. Also, IP does have
the ability to add more aerators to their wastewater treatment system. There are only 5 aerators
in their north lagoon (the last lagoon prior to discharge to the river).
Please be sure to correct the classification of the receiving stream to reflect PNA/HQW.
WiRO supports the reissuance of the NPDES Permit in accordance with the Cape Fear River
Basinwidc Plan, provided the concerns outlined herein are addressed and no adverse public
comments are received on the draft permit.
ignature of Report Preparer
ter uality Regional upervisor
Enclosure
Date
0 kq_
Date
cc: DWQ WiRO NPDES Permit File NC0003298 Columbus County (w/att)
DWQ Central Files (wlatt)

- �-'-- � — � - � - �-'--•�-.- - -- , --- � ..1 l � T r� Nook r �- o.-r ' � •
�t f� •� `l Yynrf.nw y
ra --- Sit,
T1i".,I leaf o •+ 7y - _=.fir- ! � �\ \ , F� ,� \_I- _f r� ,
i Y� _ � ;•/Path f'
Is
io
Is and
slan
�.-'�?�IF/ +1 L Cape dear River j ,
J�
don Crnl, Land,n)r
lea R
(� r} ss I Mielul COO dtrnnfwcY - / ;� pia
rlrxrrg Cape Fear River
5r -
„
f '-ii4,` ' I �� ; � /.' f _ _ `•I, , { _ JET \ \
�4
41 .. .'tom 1 j M1 � • - `�_r � 1 -rl I
I i C't 1 � �
{
This map was produced for illustrative purposes as a general guide to
assist the public. Informational data used for this map were collected
from federal, state, county, and private organizations. While every
effort Is made to keep this map accurate and up to -date, it Is not r';`
Intended to replace any official source. Under no circumstances shall the L (' ` �`• '�+ ` - `'
State of North Carollne be Ilable for any actions taken or omissions made
from reliance on any Information contained herein from whatever source nor J� pid4�^ "� '� It
� 70w�r �, 1� � '
shall the State be liable for any other consequences from any such reliance. i I �a f 1 �•'
lk
f ��-
Background Imagery are U.S. Geological Fishery Nursery Areas FisheryNurse Areas
Survay 1: 1 00.000-scale planimetrk: maps. ® Primary Nursery
Permanent Secondary Map Datum: NADa3
Special Secondary Map Proje0on: NC Stata Plane
Map Data: July20013 MARINE
® Military Danger 1000 0 1000 2000 Yards HSHUM
Zones and
Restricted Areas
locator map 0.7 0 0.7 1.4 Mlles
= inland w6ters(WRCJurisdiction) Map 24

INTERNATIONALQ PAPER
RIEGELWOOD MILL
865 JOHN L. RIEGEL ROAD
RIEGELWOOD, NC 28456
PHONE [phone]
May 31, 2011
Ms. Dina Sprinkle
NC DENR / DWQ Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: NPDES Permit NCO003298 Reissuance
Summer Season Variance Justification
In the transmittal letter of International Paper's (IP's) NPDES permit issued in 2007, the
Division of Water Quality (DWQ) asked that IP provide justification during its next permit
renewal cycle for continuance of the 1992 variance allowing a summer period of June through
October rather than April through October. I am writing in response to provide the requested
support for the variance and ask that it be continued. Below you will find a summary of the
basis for the 1992 variance and more recent information supporting the rationale upon which
the variance was granted.
Background
EPA issued NPDES Permit NCO003298 to Federal Paper Board in 1973 with a compliance
schedule to meet limits of 5,000 lb/day BOD5 in summer (defined as June through October) and
10,000 lb/day in winter (November through May). All permits issued after this permit were
challenged by Federal Paper, effectively staying these limits or negotiating Special Orders by
Consent.
In 1991, Federal Paper completed a study evaluating different treatment and disposal
alternatives. The study also included water quality monitoring and modeling as part of a Use
Attainability Analysis. The study recommended the limits included in the original 1973
NPDES permit be maintained.
In 1992, Federal Paper submitted a variance request from the State's definition of summer and
winter contained in 15A NCAC 02B.0404(c); the variance was approved by the Environmental
Management Commission (EMC) and incorporated within Federal Paper's NPDES permit in
1993.

NPDES Permit NC0003298 Reissuance
Summer Season Variance Justification
The rationale supporting continuance of this winter season variance centers on these key
points:
Lower Cape Fear River Dissolved Oxygen (DO) - North Carolina's ongoing evaluation
of impacts from point and nonpoint sources and natural background conditions
indicates minimal effect from point sources. Historically, DO concentrations in the
Lower Cape Fear in April and May have been consistently above current water quali ty
standards.
Treatment - IP's wastewater treatment system is and has been among the best in the
industry for BOD removal efficiency. Any additional BOD removal would be minimal
and come only through major changes to the treatment system.
Variance - The granted variance is not a variance from water quality standards subject
to EPA review and thus has no specific recurrence.
Further information on each of these points is provided below.
Dissolved Oxygen Issues in Cape Fear River
DWQ currently considers the Lower Cape Fear River as impaired for dissolved oxygen. DWQ
has been working with the Lower Cape Fear River Program (I P is a member of the Program) to
evaluate water quality issues in the lower river. DWQ hired Dr. Jim Bowen to develop a water
quality model of the river to identify pollutant reduction loads to achieve water quality
standards. Dr. Bowen's report indicates that DO is lower than the standard approximately 32
percent of the time, and removing point sources would only reduce this frequency to 27
percent. The report also concluded that removing 100 percent of the point source loads would
result in an approximate increase in DO of 0.3 mg/L in times of lower DO concentrations. The
removal of all the WWTPs changed the median DO concentration by approximately 0.1 mg/L.
Exhibit 1 (from Dr. Bowen's report) illustrates these conclusions.
]'age 2 of 5

N PDES Permit NCO003298 Reissuance
Summer Season Variance justification
'EXHIBIT 1
Percentile Plot of Model Predicted Dissolved Oxygen Concentrations During the Summer 2004 for the Base Case
and Three Wastewater Treatment Plant Load Reduction Scenarios. The y-axis indicates the fraction of values below
the corresponding DO concentration (mgfL) indicated on the x-axis.
Source: Bowen et al.,
1
0.8
0.6
8A
0.2
0
April through October Simulated Dissolved OxyM Concentrations
fw the Impaired Area, Loner Cape Fear River Estuary
.,._. Base Case................ i................... a...................
4....,...._,..,.._..r,..,,.,,_,...,r.
All WWTPs off
Wdrn. WWTPs off
�` fP WWTP oiI ..,.....,.r...... .....,r....... p....,,..r...........,,............ ...........,..
_.................F...................}....._ .. _.. ............. .........
r........... ...................................... ............... ...�..�_�.......
................ .................... ................
...5................... 5................... ....................
...i,......_................ ..,.. i.............. ................. ....................
L
......r...........................O.a...,....x.u....Y.r...r_...rY.r.....r..r..a...._i_r...r.n..r.....r.Y......... _.n...............n_.......
.r......._,..,.� ...................6. ............., ..,...,.........., .o..............,..,_d. ,.............,,., .,,.....,.,......
i
3 3.9 4 4.5 S 6.5 .6 6.5 7
2009 Dissolved Oxygen (mg/L)
Dr. Bowen's report, based on very detailed hydrodynamic and water duality modeling, draws
conclusions very similar to those of the less complex modeling used to support Federal Paper
Board's Use Attainability Analysis and variance request in the early 1990s. Based on Dr.
Bowen's work, DWQ has determined that an alternative water quality standard may be
appropriate for the Lower Cape Fear River and is evaluating options. Until this work is
complete, IP should continue to maintain its variance from the definition of summer.
Three stations monitored by the LCFRP were evaluated for actual DO performance in the
months of April and May. Box plots along the Cape Fear River compiled by DWQ in its 2009
Cape Fear River Basin Assessment Report indicate the dissolved oxygen sag occurs near
Navassa and Horseshoe Bend at Wilmington. Based on this finding, LCFRP data from the
following stations downstream of IP were chosen for review:
• B9030000c -Cape Fear River Indian Creek Phoenix
• B9050025c - Cape Fear River Railroad Bridge Navassa
• B9050100c -Cape Fear River Horseshoe Bend Wilmington
Page 3 of 5

NPDES Permit NC0003298 Reissuance
Summer Season Variance justification
The April and May data for each station were evaluated for 1996-2010. Exhibit 2 below
summarizes the data.
EXHIBIT 2
Summary of April and May DO Data Collected (1996-2010)
Number of
Number of
Samples <
Samples <
Minimum
Standard
Standard
DO
Station
DO Standard
Observed
(2007- Present)
0
(1996 -Present)
B9030000c
4.0
4.3
0
(5/29/2007)
B9050025c
5.0
4.8
1
1
(5/29/2007)
B9050100c
5.0
5.1
0
0
Over the 15 year period reviewed, one sampling date from two stations had DO less than 5
mg/L and no DO values were Iess than 4 mg/L. It should also be noted that the station furthest
upstream (B9030000c) is classified as C Sw. There were no observations below the DO
standard of 4.0 at that sampling location.
Based on in -stream data that indicate that DO values are generally not below the standard in
April and May and that DWQ is still evaluating DO issues in the Lower Cape Fear River, IP
should continue to maintain its variance from the definition of summer until further research is
completed. At that time, the variance can be re-evaluated if the site -specific data and resulting
programs to protect the Lower Cape Fear River warrant it.
Treatment System
IP's treatment system consists of primary clarification followed by aerated stabilization basins
(ASBs). The system is operated efficiently but its temperature is significantly affected by
weather, due to the long residence time needed to achieve high removal efficiency. IP has
complied with its monthly average effluent BOD limits, but if summer limits had been imposed
in April and May, the limit would have been exceeded in May 2008, as well as four other
occasions in April/May from 2003-2007.
In 1991, Federal Paperboard submitted a report to DWQ in which it evaluated several
treatment alternatives to meet lower BOD limits as well as effluent discharge alternatives. That
analysis showed that this system performed extremely well when compared to other systems at
pulp and paper facilities throughout the world. Activated sludge treatment was evaluated and
was not projected to provide better treatment for summertime conditions. This analysis
indicated that activated sludge may improve treatment in April and May but the high cost of
conversion was determined to be unwarranted by the minimal potential water quality benefit.
Page 4 of 5

NPDES Permit NCO003298 Reissuance
Summer Season Variance Justification
Variance
The variance is not a variance from water quality standards but from the State's definition of
"summer and winter". In November 1993, EPA submitted a letter to the Division of
Environmental Management Director on the state's triennial review in which they established
priority areas to review. in that letter, EPA acknowledged two actions taken by the EMC that
had been included in the state's triennial review package. One of those actions was the
variance for the definition of summer and winter for Federal Paperboard. EPA's letter
acknowledged that the variance was a variance to permitting requirements set forth in DWQ's
rules and not a variance to the state's water quality standards. Therefore, EPA did not consider
the variance to be part of the state's triennial revisions.
Summary
The most important considerations are that the Lower Cape Fear [fiver TMDL for DO is still in
development and work to date shows very limited impact from point source discharges, April
and May DO concentrations are consistently higher than the DO standards and the existing
variance is not a variance to water quality standards. Therefore, we strongly believe the
variance from the definition of summer in IP's NPDES permit is well conceived, causes no
detriment and we request that the variance continue.
If you have any questions or would like to discuss this or any related matter, please don't
hesitate to call Kim Fail at [phone] or me directly at [phone].
Yours truly,
Edward J. Kr
Manager — Environment, Health, Safety and Sustainability
cc: Kim Fail, P.E., International Paper
Ruth C. Rouse, CH2M Hill
Page 5 of 5

INTERNATIONALO PAPER
May 31, 2011
Ms. Dina Sprinkle
NC DENR Division of Water Quality — Point Source Branch
North Carolina Department of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Dear Ms. Sprinkle:
RIEGELWOOD MILL
865 JOHN L. RIEGEL ROAD
RIEGELWOOD, NC 28456
PHONE [phone]
1�0
.�T
JUN 2 2011
DENR-WATER QUALITY
POINT SOURCE MANCH
International Paper (IP) operates a wastewater treatment facility at its Riegelwood, North
Carolina mill under NPDES Permit NC0003298. As part of this permit, we are required to
submit a permit renewal application 180 days prior to the permit expiration date of November
30, 2011. (i.e., by June 3, 2011). This submittal constitutes our formal permit renewal application
and consists of the following parts:
• Attachment A: Application Forms 1 and 2C
• Attachment B: Figures
• Attachment C: Sludge Management Plan Narrative
As part of the renewal process, International Paper also requests that several permit conditions
be revised as follows:
Please remove influent daily monitoring requirements for biological oxygen demand
(BOD) and total suspended solids (TSS), as shown in Section A.1 of the permit. We do
not have influent or percent reduction limits for either constituent, and we are not aware
of any state or federal requirement that requires monitoring of these parameters in the
influent.
• It is our understanding that the provisions of bleach plant and effluent monitoring for
Cluster Rule compliance were only required for one five-year permit term, per 40 CFR
430.02(b)(1). The five-year term for our NPDES permit will end in March 2012, and we
? } �, , iti�' �•l jl./ ;Z. �" cL� i � J I i� j 1n,1J, � �,ll kv ��. 1' ��.R,+,
S:/Groups/EnviranmentallWastewater/NPDES Permit Info/NPDES Permit Renewal Cover tetterOS3111.do)
J �

request that the monitoring requirements for the following constituents be eliminated
after this date:
o Chloroform, chlorinated phenolics and dioxins in Outfalla 004 and 005 (Bleach
Plants 1, 2, and 3); and
o Adsorbable organic halides (AOX) in Outfall 001 (effluent).
• We request that Outfall 002, which has been eliminated, be removed from our permit.
As requested in the NC DENR cover letter for the March and October 2007 NPDES permits, IP-
Riegelwood is also submitting its rationale for continuing the existing summer period variance
under separate cover.
We look forward to working with you during this permit renewal process. Should you have
any questions on this submittal, please contact me at 910/362-4883,
Sincerely,
Edward J.ul
EHS&5 anager
cc: Ruth C. Rouse, CH2M Hill
Kim Fail, P.E., International Paper
S:/Groups/Environmental/Wastewater/NPOES Permit Info/NPOES Permit Renewal Cover Letter 053111. doc

INTERNATIOfdAL® PAPER
Riegelwood, NC
Production 5tats - Paper Machines (April 2M 0 - March 2011)
Bleached Board = Paper Machine 15
Bristols = Paper Machine 18
Pulp = Pulp Dryer
2010
Units
ABE
Finished Tons Manufactured - Total
Al Tons
69,522
Bleached Board
Al Tons
20,430
Bristols
Al Tons
16,%4
Pulp
Al Tans
32,148
2010
2010
2010
2010
2010
2010
2010
2010
2011
2011
2011
12-Month
May
L
Lft
Aug
ft
Qq
N-
Dec
L
Feb
Mar
Total
37,100
74,430
77,608
73,326
73,629
71,164
73,674
74,335
72,048
64,413
72,680
833,929
12,606
18,911
19,8Z7
19,293
18,"5
19,698
18,837
19-W
17,787
15,874
19,124
220,811
12,052
18,609
18,886
18,798
16,2%
16,894
17,679
17,154
17,593
16,182
17,845
204,894
12,442
36,910
38,895
35,246
38515
34,572
37,159
37,601
36,668
32,357
35,711
408,224
Production 5tats - Pulp (Atari] 2010 - March 20111
2010
2010
2010
W10
2010
2010
2010
2010
2010
2011
2011
2011
12-Month
units
APT
May
L
L
Au¢
s�
IQq
Nov
Dec
jan
Feb
mar
Total
Tons Manufactured - Total
74,065
41,283
78,531
83,182
77,500
78,100
77,163
78,3M
79,613
77,156
69,276
76,951
891,150
Unbleached Pine
ADT
38,831
18,679
42,292
44,174
41,924
42,749
41,381
43,289
43,211
41,467
37,806
41,524
477,327
Unbleached Hardwood - Batch
ADT
391
89
676
249
622
356
2,383
Unbleached Hardwood•Kamyr
ADT
35,234
22,604
36,239
39,008
35,185
35,262
35,782
34,365
36,402
35,440
30,848
35,071
411,440
Tons Manufactured - Total
67,942
35,945
72,494
76,585
71,393
71,949
70,877
72,309
73,464
71,154
63,569
71,175
t3i6i
Bleached Pine
ADT
35,612
15,264
38,651
40,256
38.186
39,024
37,391
39,587
39,522
37,922
34,165
38,036
Bleached hardwood
ADT
32,330
20,681
33,843
36,329
33,207
32,925
33,486
32,722
33,942
33,232
29,404
33,139
385,240
.a
S:1Groupsj[r ironmentak\Wastewater\NMES Permit Info\2011 Application12010-2011 Prod Stats.xlsx

URSFILE
N0,
INTERNATIONAL PAPER
11RSCorporation - North Carolina
SITE LAYOUT AND
31827122
RIEGELWOOD, NORTH
r600 P, rive
SURROUNDING
CAROLINA
A'artrr Carob)Park
Morrisville, A'rrr7h Cmnliuu 77560
Telephone [phone] Fax[phone]
TOPOGRAPHY
FIG. NO.
SCALE:
DRAWN BY: AMM
DATE: 3,22/04
2 2
CHECKED BY:
I DATE:

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PLANT NORTH
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INTERNATIONAL ®PAPER
RIEGELWOOD MILL
DRAWN CEW WASTE
CHECKED WHIR TREATMENT
APPROVED WHIR
REV 12/20/00 REV 5/4/03 SYSTEM
,y 2/1/07 Ey 115EPT96 DAC. NO. REV
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SCRU88ERS
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TREATED
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0.8 (E) MGD
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lip CAUSTICIZING
SCREEN O.S MGD
ROOM
PAPER MACHINES 7.5
PULP DRYER 8 MGD
NOS. i,2,3 14.7 E MGD
BLEACH PLANTS
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02 DELIG
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► CHiLLER BLDG
INOS. 2 & 3 SVP
ROILS:
1. ALL FLOWS WERE AVERAGED FROM APR 2010 TO MAR 20111
HOLTRACHEM .04 MGD
2. TOTAL MILL EFFLUENT FLOW CAN BE DIRECTED TO EITHER CLARIFIER.
THE BLEACH PLANT FLOW CAN BYPASS THE CLARIFIERS.
O.2 E) MGD
WFI CAR WASH
,
19.3 (E) MGD
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1Q.7 MGD
BAR SCREEN
(IF NEEDH2504ED)
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313 TPD SLUDGE PONDS
1-5X SOLIDS (EARTHEN)
3
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GROUP: Pulp and Paper r`
DIVISION/SUBSIDIARY: Monufactoring -
MILL/PLANT: Riegelwood Mill
1.5 MGD
NO.1 ASS
NO 2 ASS
d[ SETTLING POND
(EARTHEN)
(EARTHEN)
SURFACE AREA:
.3 MGD
C3333.3 MGD
SURFA AREA: 34,8 w1GD
RE
45 ACRES
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VOLUM
VOLUM
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1.670 LBS/DAT
RESIDENCE TIME:
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DAYS
2.5 DAYS
NH3 �
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NEEDED
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RECIRCULATION
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VOLUM
89.2 Mgol
RES�1 CE ME:
DAYS
DEfOAMER 37E
7.0 MGD RIVER WATER
NOTE: 430-4101XICSOUDS
1 TOTAL MILL EFFLUENT FLOW CAN BE DIRECTED TDEITHER CLARIFIER AND THE BLEACH PLANT MAY PARSHALL
INDIVIDUALLY BYPASS THE CLARIFIER(S). 6 TPOXYGEN FLUME
ip,000 LBS/DAYLERS
IF OUTFACE 3.8 MGD
CAPE FEAR RIVER
TITLE DRAWN BY: CEW SCALE DRAWING NO,
WASTEWATER FLOW INTERNATIONAL (?N PAPER V1 10012
DATE i 2-20-00 N/A RIEGELWOOD MILL

F
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IF STRIPPED
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AURACEL CHEST DWRFLOWS
PAPER MILL EXCESS WW
49
STARCH
R
A
TI R
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INTERNATIONAL
®PAPER
—
RIECELWOOD MILL
NOTES
1. SANITARY WASTE FROM SILL FACILITIES
'A
y
DRAWN
KEFFER
MILL -WIDE
ARE DIRECTED TO PROCESS SEWERS AND
RwErO
-r:r4rFFN FIT
CHECKED
WBP/KJM
ARE TREATED IN WASTEWATER TREATMENT SYSTEM.Z�n
GUIDE 2. DRAWING
SERVES A GENERAL
SEWER
SUBJECT Tb NC E_
APPROVED
WHR
_
REV 11/22/06
,T,;v03/12/99
F L O W S H E E T
REV 06/11/96
Rcv 12/20/00
DWG. NO.
REv
A 110 012 3
REW 02/12/9s
REV
,�OFTI

ATTACHMENT C
SLUDGE MANAGEMENT PLAN NARRATIVE
Sludge from the two primary clarifiers may be routed to either (1) sludge presses for mechanical
dewatering or (2) one of three sludge dewatering ponds for settling (Ponds A, B, or C).
Dewatered sludge from the sludge presses is routed to the power boilers for use as fuel.
Primary sludge removed from the sludge ponds is typically landfilled in IP-Riegelwood's on -
site landfill. The mill also has the option to land apply primary clarifier solids, per Land
Application Permit WQ0015180 and its land management application plan (Wood Ash, Green
Liquor Dregs, Slaker Grits, and Primary Clarifier Solids Soil Additive Program, International Paper,
Riegelwood, NC, February 1998). However, IP-Riegelwood has not performed any land
application during this permit term and has instead elected to manage the primary clarifier
sludge in its on -site landfill or as boiler fuel.
Effluent from the New Bay flows into a small settling pond of approximately 8 acres via a
spillway, identified by the mill as the Theodorakis Settling Pond. Secondary sludge from this
settling pond is dredged periodically and placed in any of the sludge dewatering ponds (Ponds
A, B, C, 1, 2, or 3). After removal from the sludge dewatering pond(s), secondary sludge is
placed in IP-Riegelwood's on -site landfill.
The mill does not maintain a formal sludge management plan for its on -site sludge
management activities.
.5 /Jf ( iI
Floyd Whitmire, Mill Manager Date
S:/Groups/£nvironmentaVWostewoter/NPDES Permit )nfa/NPDF5 Permit Renewol Cover Letter 033111.doc