NC0003298_PERMIT ISSUANCE_20070321

NPDES DOCUMENT SCANNING COVER SHEET
NPDES Permit:
NC0003298
Riegelwood Paper Mill
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Correspondence
Monitoring Report
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date:
March 21, 2007
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NCDENR
Mr. Floyd Whitmire, Mill Manager
International Paper Company
Riegelwood Mill
865 John L. Riegel Road
Riegelwood, North Carolina 28456
Dear Mr. Whitmire:
Michael F. Easley
Governor
William G. Ross; Jr,, Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
March 21, 2007
Subject: Issuance of NPDES Permit
NC0003298
Riegelwood Mill
Columbus County
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 May 9, 1994 (or as subsequently amended).
This final permit includes the following major changes from the draft permit sent to
you on October 25, 2006:
• Outfall 002 was added to the permit to allow sand filter backwash discharge from
the surface water treatment plant (WTP) .
• The mercury sample type was changed to Grab to be consistent with method EPA-
1631E requirements.
• The summer period was changed to June 1 through October 31 to correct an error
(this summer period was granted by the North Carolina Division of Environmental
Management as a variance in 1992).
• The 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 data that demonstrated no
detectable levels.
The Division has also reviewed International Paper's comments in response to the Draft
Permit and the Division's answers are summarized below:
1) Section A. R.). The Division cannot grant your request to change the sample type to
grab for the following parameters: AOX, BOD, TSS, NH3-N, TP, TN, Chronic Toxicity,
Cr, Ni, and Zn. Various state rules and regulation require composite sampling for
these parameters for major industrial facilities. This is also consistent with the
sampling requirements for other pulp and paper plants in North Carolina.
N. C. Division of Water Quality 1 NPDES Unit Phone: [phone]
1617 Mail Service Center, Raleigh, NC 27699-1617 fax: [phone]
Internet h2o.enr.state.nc.us DEN Customer Service Center: 1 800 623-7748

Letter to Mr. Whitmire, page 2.
2) Section A. (L) Note 5. and Section A. (7.). Dioxin monitoring of the sludge, wastewater
treatment plant influent and landfill leachate was eliminated. Your request to change
dioxin sampling to grab cannot be granted for the reasons specified above.
3) Section A (2.). and (3.), Footnote_4. Your request to change the time period for BAT
sampling cannot be granted. This requirement is based on the EPA Permit Guidance
Document for Pulp, Paper and Paperboard Manufacturing (EPA-821-B-00-003, May
2000) and is consistent with the sampling requirements for other pulp and paper
plants in North Carolina.
During the next permit renewal the1acility should provide the 'ustifcation for continuing
the variance defining the summer veriod as June 1 -- October 31.
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
filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North
Carolina 27699-6714). Unless such demand is made, this decision shall be final and
binding.
Please note that this permit is not transferable except after notice to the Division. The
Division may require modification or revocation and reissuance of the permit. This permit
does not affect the legal requirements to obtain 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 Chernikov
at telephone number [phone], extension 594.
Sincerely,
J e�lrl
1_,4,�,T_Alan W. Klimek, P.E.
cc: NPDES-Files )
Wilmington Regional Office / Surface Water Protection
Aquatic Toxicology Unit
Mr. Roosevelt Childress, EPA Region IV
Environmental Sciences Section, Biological Assessment Unit

Permit No. NCO003298
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
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 conditions set forth in
Parts I, II, III, IV, and V hereof.
This permit shall become effective May 1, 2007.
This permit and authorization to discharge shall expire at midnight on November 30, 2011
Signed this day March 21, 2007.
Alan Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit No. NCO003298
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are
hereby revoked. As of this permit issuance, any previously issued permit bearing this
number is no longer effective. Therefore, the exclusive authority to operate and discharge
from this facility arises under the permit conditions, requirements, terms, and provisions
included herein.
International Paper Company, Inc.
Riegelwood Facility
is hereby authorized to:
1. Continue to operate existing treatment facilities (outfall 001) consisting of
dual bar screens and primary clarifiers, nutrient addition facilities, 173
acres of aerated lagoons with re -circulation, sludge holding lagoons,
sludge dewatering presses, oxygen injection facilities, flow measurement
and recording equipment located at NC Highway 87, in Riegelwood,
Columbus County, operate surface water treatment plant and sand filter
backwash (Outfall 002), 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.

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Facility Information
atitudeu f • 4° 21' 10" Latitude lOutfa110021:_34° 21' 51"
i ude (Ontfa11002):78° IVIV Longitude (Outfall 002,): 7$° 12' 70"
uad ##: 3 26 SW
Imam Class: C-Swamp
cceiviniz Stream Cape Fear River
ub-Bash 03-06-17
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aste Ponds
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Permit No. NC0003298
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration,. the Permittee is authorized
to discharge from outfall(s) serial number 001. Such discharges shall be limited and monitored by the Permittee as
s ecified below.
sk 5
SM.�
MONIT _ Ri'
�S men
$ ..
G UTREM
p
S`�asnple
3rpe.I.ocapon
Sarx�'p e ,
Flow (MGD)
50.0
Continuous
Recordin ..
E
BOD, 5-day, 200C
Summer).
5,000 lbs/day
10,000 lbs/day
Daily
Composite
E, I
BOD, 5-day, 200C
inter
1000 lbs/day
20,000 lbs/day
Daily
Composite
E, I
Total Suspended Solids
65,720 lbs/da -
122,033 lbs/day
Daily
Composite
E, I
NH3-N
Weekly
Composite
E
Temperature o
Daily
Grab
E
Dissolved Oxygen2
D!ilX
Grab
E, U, D
H3
Daily
Grab
E
Total Phosphorus /L
Monthly
Composite
E
Total Nitrogen
(NO2+NO3+TI<N)
/L
Monthly
Composite
E
Chronic Toidcity4
Quarterl
Composite
E
Dioxins
0.9 /L
Quarterlv
Composite
E
AOX6
2,740lb/day
4,1831b/dap
Daily
Composite
E
Trichloro henol7
38.7 lb/day
Weekly
Composite
E
Pentachloro henol7
6.2 lb/day
Weep
Composite
E
Total Mercury
2/Month
Grab
E
Total Chromium
gjjarterly
Composite
E
Total Nickel
Quarterly I
Composite
1 E
Total Zinc
Quartedy.
Composite
E
Salmi
See Note 1
Grab
U, D
1. Sample Locations: E — Effluent, I — influent, U.— upstream at the International Paper water intake, D — downstream
at the DuPont water intake. Stream samples shall be collected three times per week during June, July, August, and
September and once per week during the remaining months of the year. As a participant in the lower Cape Fear
Monitoring Coalition, the instream monitoring is not required. Should the membership in the Coalition be
m terminated, you steal notify Division immediately and begin instreamonitoring as specified in this permit.
2• The daily average dissolved oxygen effluent concentration shall not be less than 5.0 mg/L.
3. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
4. Chronic Toxicity (Ceriodaphnia) P/F at 8.0%; January, April, July, and October; see item A. (5.) of the Supplement to
Ej7uent Limitations and Monitoring page.
5. See Section A. (8.) of the Supplement to E,fkeni Limitations and Monitoring page.
6. AOX data shall be submitted on a quarterly basis along with other Cluster Rule chemical data; refer to A. (10)
Effluent Guideline Sampling'Plan Special Condition.
7. 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.
Summer shall mean June 1 - October 31, while winter shall mean November 1 - March 31.

Permit No. NCO003298
A- (2.) EFFLUENT LIMITATIONS AND -MONITORING REQUIREMENTS.
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 in A. (10.) Effluent Guideline Sampling Plan Special Condition:
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-Sam elLocatio n �k
Flown
Weekly
Calculated
Effluent
Chloroform
9.0 lb/day
15.0 lb/day
Weekly
Grab
Effluent
2,3,7,8 Tetrachloro-
dibenzo-p-dioxin
CDD
< 10 pg/L
Monthly
Composite
Effluent
2,3,7,8 Tetrachloro-
dibenzo- -futan CD
31.9 pg/L
Monthly
Composite
Effluent
Trichlorosyringol
< 2.5 RJL4
Monthly
Composite
. Effluent
3,4,5-Trichlorocatechol
< 5.0 µg/L4
Monthly
Composite
Effluent
3,4,6-Trichlorocatechol
< 5.0 µg/L4
Monthly
Composite
Effluent
3,4,5-Trichloroguaiacol
< 2.5 µg/L4
Monthly
Composite
Effluent
3,4,6-Trichloroguaiacol
< 2.5 }tg/L4
Monthly
Composite
Effluent
4,5,6-Trichloroguaiacol
< 2.5 pg/L4
Monthly
Composite
Effluent
2,4,5-Trichlorophenol
< 2.5 µg/L4
Monthly
Composite
Effluent
2,4,6-Trichlorophenol
< 2.5 µg/L4
Monthly
Composite
Effluent
Tetrachlorocatechol
< 5.0 µg/L4
Monthly
Composite
Effluent
Teirachloroguaiacol
< 5.0 µg/L4
Monthly
Composite-
Effluent
2 3 4 6-
T i63chlorophenol
< 2.5 µg/L4
Monthly
Composite
Effluent
Pentachlorophenol
< 5.0 µg/L4
Monthly
Composite
Effluent
F
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. (10) Effluent Guideline Sampling Plan Special
Condition
2. Monitoring and flow calculations shall be in accordance with the condition A. (10.). Chemical results for Effluent
Guideline parameters as prepared by the permittee (internal Outfall 004 parameters + AOX from Outfa11001) shall be
reported on a quarterly basis or more frequently, refer to A. (10.) Effluent Guideline Sampling Plan Special Condition.
3. Sample Type: Calculated- calculate separate flows for alkaline and acid sewers by water balance or flow meters, and
report total bleach plant 1 and 2 flow (acid + alkaline wastestreams) in DIARs. Grab- collect separate grab samples every
4-hours for 24-hour period from both the acid and alkaline streams, which will then be composited separately by the lab,
and analyzed as separate 24-hr composite acid and alkaline samples. Composite- collect separate grab samples every 4
hours for 24-hour period from both the acid and alkaline streams, then prepare and analyze a single flow -proportioned
composite of the acid and alkaline wastestream. .
4. Limits are based on Minimum Levels (NM) specified in 40 CFR 430.01. ,
5. For compliance purposes, the permittee must report total chloroform mass loading.
Definitions: -
lb/dap — Pounds per day
pg/L — Picograms, per liter
µg/L — Micrograms per liter
ADT — air dried ton of pulp product

Permit No. NC0003298
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
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
Permittee as specified below and in A. (10.) Effluent Guideline Sampling Plan Special Condition:
.4Dfdkti- 4/
e�n C. ",ti
A
s
iS
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7UJ. '�3L2.NID.Ye9lir' +`.cx5+1.
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1VIaXi trir[t ;
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T 3 . ;
Ga a
II1 ��LON "Aag AM',
Flow2
Weekly
Calculated
Effluent
Chloroform
9.2lb/day
15.4lb/day
Weekly
Grab
Effluent
8 Tetrachloro-
dibenzo-p-dioxin
CDD
< 10 pg/L
Monthly
Composite
Effluent
2,3,7,8 Tetrachloro=
dibenzo- -furan CD
31.9 pg/L
Monthly
Composite
Effluent
Trichlorosyringol
< 2.5 µg/L4
Monthly
Composite
Effluent
3,4,5-Trichlorocatechol
< 5.0 µg/L4
Monthly
Composite
Effluent
3,4,6-Trichlorocatechol
< 5.0 µg/L4
Monthly
Composite
Effluent
3,4,5-Trichloroguaiacol
< 2.5 µg/L4
Monthly
Composite
Effluent
3,4,6-Trichloroguaiacol
< 2.5 µg/L4
Monthly
Composite
Effluent
4,5,6-Trichloroguaiacol
< 2.5 µg/L4
Monthly
Composite
Effluent
2,4,5-Trichlorophenol
< 2.5 µg/L4
Monthly
Composite
Effluent
2,4,6-Trichlorophenol. _ :
< 2.5 µg/L4
Monthly
Composite
Effluent
Tetrachlorocatechol
< 5.0 µg/L4
Monthly
Composite
Effluent
Tetrachloroguaiacol
< 5.0 11g/L4
Monthly
Composite
Effluent
2 3 4 6-
TI irachlorophenol
< 2.5 µg/L4
Monthly
Composite
Effluent
Pentachlorophenol
< 5.0 jig/L41
Monthly I
Composite
Effluent
Footnotes:
1. Sample Location: Effluent is composed of bleach plant effluent -acid (collected from acid sewer ) and bleach
plant effluent -alkaline (collected from alkaline sewer). See A. (10.) Effluent Guideline Sampling Plan Special
Condition
2. Monitoring and flow calculations shall be in accordance with the condition A. (10). Chemical results for Effluent
Guideline parameters as prepared by the permittee (Internal Outfall 005 parameters + AOX from Outfall 001) shall
be reported on a quarterly basis or more frequently, refer to A. (10.) Effluent Guideline Sampling Plan Special
Condition.
1 Sample Type: Calculated- calculate separate flows for alkaline and add sewers by water balance or flow meters, and
report total bleach plant flow (acid + alkaline wastestreams) in DMRs. Grab- collect separate grab samples every 4-
hours for 24-hour period from both the acid and alkaline streams, which will then be composited separately by the
lab, and analyzed as separate 24-hr composite acid and alkaline samples. Composite- collect separate grab samples
every 4 hours for 24-hour period from both the acid and alkaline streams, then prepare and analyze a single flow -
proportioned composite of the add and alkaline wastestream.
4. Limits are based on Minimum Levels (ML) specified in 40 CFR 430.01.
5. For compliance purposes, the pemuttee must report total chloroform mass loading.
Definitions:
lb/day — Pounds per day µg/L -- Micrograms per liter
pg/L — Picograms per liter ADT — air dried ton of pulp product

Permit No. NCO003298
A. (4.): EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration, the Permittee is
authorized to discharge sand filter backwash from outfall(s) serial number 002. Such discharges shall be limited and
monitored by the Permittee as specified below:
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Notes
1. Sample locations: E — Effluent
2. The pH shall not be less than 6.8 standard units or greater than 8.5 standard units.
3. Zinc shall be monitored if the Permittee uses any zinc -based additive in the water treatment process.
4. Limit and monitoring is applicable only if facility use chlorine for disinfection. Facility is allowed 18 months
from the effective date of the permit to comply with the total residual chlorine limit This time period is
allowed in order for the facility to budget and design/construct the dechlorination or alternative disinfection
systems.
* The flow is not limited. The facility is allowed 12 months to install a flow meter and conduct a complete
investigation of all the sources of the flow (and their volumes) into the discharge pipe. These findings should be
submitted to the Division. The Division will add a flow limit during the next permit renewal.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

Permit No. NCO003298
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A. (5.) 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 test 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 (Mk l) for the months in which tests were performed, using the parameter code TGP3B,for
the pass/fail results and THP313 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 Branch no later than 30
days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and all
concentration/response data, and be certified by laboratory supervisor and ORC .or approved designate
signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is
employed for disinfection of the waste stream.

Permit No. NCO003298
SUPPLEMENT TO EFFLUENT LIMITATIONS
` AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS (Continued).
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
Branch 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 in 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.

Permit No. NC0003298
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS,
SPECIAL CONDITIONS (Continued)
A. (6.) BIOCIDE CONDITION
The Pennittee shall obtain authorization from the Division of Water Quality prior to utilizing any biocide in
the cooling water. The Permittee shall notify the Director in writing not later than -ninety (90) days prior to
instituting use of any additional biocide used in cooling systems which may be toxic to aquatic life or other
than those previously reported to the Division of Water Quality. 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
From 101 with Supplemental Metals Analysis worksheet.
A. (7.) 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. SThe 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. (8.) 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/High Resolution Mass Spectrometry, EPA, 1987
(EPA Method 1613), or another equivalent analytical protocol approved by DWQ. A single sample may be
analyzed to determine compliance with the daily maximum effluent limitation. Alternatively, a sample
volume may be collected to. -enable the sample to be split (duplicate analysis). If the analysis of either split
sample is below the detection limit, the quantity, for the purposes of compliance evaluation, is considered to
be zero. If both splits are positive, the results of the two analyses shall be averaged to determine compliance
with the daily maximum effluent limitation. If the measurement is below detection limits, the quantity for
the purposes of compliance evaluation is considered to be zero. The detection limit using these methods for
the purpose of compliance evaluation is considered to be 10 picogranis per liter. The dioxin isomer to be

Permit No. NCO003298
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS (Continued)
10. The permittee must conduct wastewater monitoring to detect leaks and spills, to track the effectiveness
of the BMPs, and to detect trends in spent pulping liquor losses. Such monitoring must be performed in
accordance with Section E.
Section B. BMP Plan Requirements
1. The permittee must prepare and implement a BMP Plan. The BMP Plan must be based on a detailed
engineering review as described in this section.. The BMP Plan must specify the procedures and the
practices required for the mill to meet the requirements of Section A, the construction the mill
determines is necessary to meet those requirements including a schedule for such construction, and the
monitoring program. (including the statistically derived action levels) that will be used to meet the
requirements of Section E. The BMP Plan also must specify the period of time that the mill determines
the action levels established under Section D may be exceeded without triggering the responses specified
in Section E.
2. The permittee must conduct a detailed engineering review of the pulping and chemical recovery
operations --including but not limited to process equipment, storage tanks, pipelines and pumping
systems, loading and unloading facilities, and other appurtenant pulping and chemical recovery
equipment items in spent pulping liquor, soap, and turpentine service --for the purpose of determining the
magnitude and routing of potential leaks, spills, and intentional diversions of spent pulping liquors, soap,
and turpentine during the following periods of operation: (i) Process start-ups and shut downs; (ii)
Maintenance; (iii) Production grade changes; (iv) Storm or other weather events; (v) Power failures;
and (vi) Normal operations.
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; (ii) The need for process wastewater
diversion facilities to protect end -of -pipe wastewater treatment facilities from adverse effects of spills
and diversions of spent pulping liquors, soap, and turpentine; (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.
4. The-permittee must amend its BMP Plan whenever there is a change in mill design, construction,
operation, or maintenance that materially affects the potential for leaks or spills of spent pulping liquor,
turpentine, or soap from the immediate process areas.
5. The permittee must complete a review and evaluation of the BNIP Plan five years after the first BMP
Plan is prepared and, except as provided in Section B.4., once everyfive 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.

Permit No. NCO003298
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS (Continued)
6.. The BMP Plan, and any amendments thereto, must be reviewed by the senior technical manager at the
mill and approved and signed by the mill manager. Any -person signing the BMP Plan or its amendments
must certify to the Division under penalty of law that the BMP Plan (or its amendments) has been
prepared in accordance with good engineering practices and in accordance with this. regulation. The
permittee is not required to obtain approval from the Division of the BMP Plan or any amendments
thereto. -
Section C. B_MP Recordkeeping Requirements
1. The permittee must maintain on its premises a complete copy of the current BMP Plan and the records
specified in Section C.2 and must make such BMP Plan and records available to the Division for review
upon request.
2. The pennittee 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: y
■ Monitoring parameters., The permittee must collect 24-hour composite samples and analyze the samples
for a measure of organic content (e.g., Chemical Oxygen Demand (COD) or Total Organic Carbon
(TOC)). Alternatively, the mill may use a measure related. to spent pulping liquor losses measured
continuously and averaged over 24 hours (e.g., specific.conductivity or color).
• Monitoring locations. The permittee must conduct monitoring at the point influent enters the wastewater
treatment system. For the purposes of this requirement, the permittee may select alternate monitoring
point(s) in order to isolate possible sources of spent pulping liquor, soap, or turpentine from other
possible sources of organic wastewaters -that are tributary to the wastewater treatment facilities
bleach plants, paper machines and secondary fiber operations).
3. By August 1, 2007 or permit effective date, the permittee must complete an initial six-month monitoring
program using the procedures specified in Section D and must establish initial action Ivels 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 trigger the investigation requirements

Permit No. NCO003298
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS (Continued)
monitored and limited by this permit is 2, 3, 7, 8, TCDD.
The Permittee shall perform the following analysis for dioxin:
.—:.-:...-:--.._W_.__....._.-----.'-Annual Composite - .....:....... ....... - ..
2. Fish tissue 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.
The chlorodibenzo dioxins and f urns to be monitored are (this requirement applies for fish tissue
monitoring only):
DIOXIN
Isomer.
2,3,7,8 TCDD
1,2,3,7,8 PeCDD
1,2,3,4,7,8 HxCDD
1,2,3,7,8,9 HxCDD
1,2,3,6,7,8 HxCDD
1,2,3,4,6,7,8 HpCDD
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. (9.) 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. BUTS 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. BNT iMplementation Requirements
1. The permittee must return spilled or diverted spent pulping liquors, soap, and turpentine to the process to
the maximum extent practicable as determined by the mill, recover such materials outside the process, or
discharge spilled or diverted material at a rate that does not disrupt the receiving wastewater treatment
system.

Permit No. NCO003298
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS (Continued)
2. The permittee must establish 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. formitigating 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 penruttee 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 pIT) monitors and alarms.
4. The permittee must establish 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.
5.. The permittee must prepare a brief report that evaluates each spill of spent pulping liquor, soap, or
turpentine that is not contained at the immediate process area and any intentional diversion of spent
pulping liquor, soap, or turpentine that is not contained at the immediate process area. The report must
describe the equipment items. involved, the circumstances leading to the incident, the effectiveness of the
corrective actions taken to contain and recover the spill or intentional diversion, and.plans to develop
changes to equipment and operating and maintenance practices as necessary to prevent recurrence.
Discussion of the reports must be included as part of the annual refresher training.
6. The permittee must establish 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 secondarycontainment 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.

Permit No. NC0003298
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS (Continued)
described in Section E, and an upper action level, which if exceeded will trigger the, corrective action
requirements described in Section E.
4. By February 1, 2008, 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. The initial action levels shall remain in effect until replaced byrevised 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. BUT 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 BUT
Plan, the permittee must conduct an investigation to determine the cause of such exceedance. Whenever
monitoring results exceed the upper action level for the period of time specified in the BMP Plan, the
permittee must_ complete corrective action to bring the wastewater treatment system influent mass
loading below the lower action level as soon as practicable.
3. Although exceedances of the action levels will not constitute violations of an NPDES permit, failure to
take the actions required by Section E.2 as soon as practicable will be a permit violation. .
4. The permittee must report to the Division the results of the daily monitoring conducted pursuant to
Section E. 1. Such reports must include a summary of the monitoring results, the number and dates of
exceedances of the applicable action levels, and brief descriptions of any corrective actions taken to
respond to such exceedances. Submission of such reports shall be annually, by March 31"` of the
following year. ;
Section F. BMP Compliance Deadlines
1. The permittee is subject to the following BUT deadlines:'
■ Prepare BMP Plans and certify to the Division that the BMP Plan has been prepared in accordance with
this regulation not later, than six month from the permit effective date.
■ Implement all BNIPs specified in Section A that do not require the construction of containment or
diversion structures or the installation of monitoring and alarm systems not later than six month from the
permit effective date.
■ Establish initial action levels required by Section D not later than six month from the permit effective
date. .
■ Commence operation of any new or upgraded continuous, automatic monitoring systems that the mill
determines to be necessary under Section A (other thanthose associated with construction of
containment or diversion structures) not later than six month from the permit effective date.

Permit No. NC0003298
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS (Continued)
Complete construction and commence operation of any spent pulping liquor, collection, containment,
diversion, or other facilities, including any associated continuous monitoring, systems, necessary to fully
implement BMPs specified in Section A not later than six months from the permit effective date.
Establish revised action levels required by Section D as soon as possible after fully implementing the
BMPs specified in Section A, but not later than one year from the permit effective date.
Submit Annual Reports required by Section EA to the Division by March 31" of the following year.
Section G. 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
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.'

Permit No. NCO003298
SUPPLEMENT TO EFFLUENT LIMITATIONS
AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS (Continued)
A. (10.) 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 I,
A(2) in accordance with EPA Method 1653. A single sample may be analyzed to determine compliance
with the daily maximum effluent limitation. Alternatively, a sample volume may be collected to enable the
sample to be split (duplicate analysis). If the analysis of either split sample is below the Minimum Level
(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 permittee may request future monitoring modifications to the Cluster Rule requirements, including 1)
use of ECF certification in lieu of monitoring for chloroform in the bleach plant effluent (Outfall 004 and
Outfall 005) when this rule is promulgated by EPA; 2) demonstrating compliance using samples collected
less frequently .than every four hours; 3) using automated composite volatile samplers for chloroform
sampling; and 4) using automated composite samplers for chlorophenolic and TCDD/DF sampling. Such
future requests will be evaluated in accordance with 15A NCAC 2H.0114.
The flow calculations for internal Outfalls 004, and 005 shall not be subject to accuracy requirements
specified under Part II, Section D.3. This exclusion is similar to that provided for pump log flow
calculations.
Chemical data for Cluster Rule parameters (all Outfall 004, and 005 parameters + AOX from Outfall 001)
shall be submitted to the Division on a quarterly basis (January- 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 forms, with a separate form provided for each month.

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0003298, International Paper Company (IP)
Riegelwood Facility
Facility Information,
Applicant Facility Name:
International Paper - Riegelwood Facility
A licant Address:
865 John L, Riegel Road, Riegelwood, NC 28456
FacilityAddress:
865 John L. Riegel Road Riegelwood, NC 28456
Permitted Flow
50 MGD
Type of Waste:
99.8 % Industrial 0.2% Domestic
Facility/ Permit Status:
Major Indust • Renewal; First inclusion of the cluster rules
County:..Columbus
Miscellaneous
Receiving Stream:
Cape Fear River
Regional
Office:
WiRO
Stream Classification: ..
C-Sw
Quad.
J26SW
303(d) Listed?:
Yes - DO and
biological
Permit Writer:
Sergei Chernikov
Subbasin:
030617
Date:
October 20, 2006
Drainage Area mil :
5 301
Summer.7Q 10 cfs :
856
Winter 7Q10 (cfs):
1101
Average Flow cfs :
5330
IWC % :
8.3%
Primary, SIC Code:
2611 Pulp/Kraft
Mill, 2621 Paper Mill
SUMMARY
The International Paper (1P) 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 new
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 and concluded that "2,3,7,8 TCDD, 2378 TCDF, and TEV dioxin results
were well below the current NC action levels, and 2005 results are consistent with previous
annual results, which show fish dioxin level decreasing and remaining below levels of concern
since 1992".
Outfall 001
This outfall contains wastewater associated with the all industrial operations, landfill leachate,
and sanitary sewer wastewater.
Outfall 00land 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 1 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 NCOOD3298
NPDES Renewal
Page 1

TOXICITY TESTING:
Current Requirement: Chronic P/F at 8.0%, January April, July, October.
Proposed Requirement: Chronic P/F at 8.0%, January April, July, October.
The facility has had good toxicity monitoring record for the past 4.5 years (only one test
resulted in failure, see attached).
RPA:
The Reasonable Potential Analysis (RPA) was conducted for Cr, Hg, Ni, and Zn (see attached).
COMPLIANCE SUMMARY:
The DMRs were reviewed for the period 01 / 01 / 03 through 9 / 01 / 03. The facility has a relatively
good compliance record. Only two NOVs were issued: 10/ 14/05 - WET failure, and 12/8/03-Hg
limit violation.
INSTREAM MONITORING:
IP is required to perform stream sampling for D.O. 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.
PROPOSED CHANGES:
• 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 1 and 2,
and Outfall 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.
• 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.
See attached spreadsheet for calculations.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: Nov. 9, 2005 (est.)
Permit Scheduled to Issue: Jan. 2, 2006 (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] ext. 594.
International Paper Riegelwood NC0003298
NPDES Renewal
Page 2

CHANGES IN THE FINAL PERMIT:
1) 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
2) Mercury sample type was changed to Grab to be consistent with method EPA-
1631E requirements.
3) Summer period was changed to June I through October 31 to correct an error
(this summer period was granted by North Carolina Division of Environmental
Management as a variance in 1992).
4) 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.
International Paper Riegelwood NC0003298
NPDES Renewal
Page 3

imap:Hsergei.che [e-mail]:993/
Subject: Re: Fw: permit
From: William H Roy <[e-mail]>
Date: Mon, 12 Mar 2007 13:23:31 -0400
To: Sergei Chernikov <[e-mail]>
CC:. Edward J Kreul <Edward.Kreull @ipaper.com>, Peter A Fritz <[e-mail]>
Sergei - Your solution described below, concerning our Water Treatment
Plant Backwash Discharge, works with us. Your understanding is correct, "
the vast majority of the flow in the discharge pipe is filter backwash, and
various small streams associated with the water treatment". We will use
the 12 months to tie up all loose ends and to install a flow meter. Thanks
- Billy
William H. Roy
Environmental Operations & Analytical Supervisor
International Paper - Riegelwood, North Carolina
Office 910.362.4753
Cell 910.512.0608
FAX 910,342,2865
[e-mail]
Sergei Chernikov
<sergei.chernikov
oncmail.net>
C�
To
William H Roy
03/12/2007 09:40 <[e-mail]>
AM cc
Subject
Re: Fw: permit
I think that you would need some additional time to investigate all the
sources of the flow. My understanding is that the vast majority of the
flow in the discharge pipe is filter backwash, and various small streams
associated with the water treatment. We think that we can issue a permit
without flow limit and give you 12 months to install flow meter and
investigate all the sources of the flow and their volumes. During the
next permit renewal we will add the flow limit to the permit.
Please let me know if this solution will work for you.
Thank you!
Sergei
William H Roy wrote:
1 of 8 3/13/2007 9:05 AM

irnap://sergei.chernikov%40dwq. deny. [e-mail]. net:9931...
Sergei - I wanted to update you on our progress in determining sources and
volumes contributing to our "water Treatment Plant's Sand Filter Backwash
Discharge Outfall".
All flows are best estimates.
Using the attached "Filter Plant Sand Filter Backwash Sewer Diagram" from
3-3-07:
#1 manhole
A is sandfilter backwash flowing at approximately 3 MGD as determined from
process information.
B is a roof downspout and had no flow.
C is a drain from the pipe gallery floor and contains process water from
water operated pistons and from water getting by valve packing. Its flow
rate is approximately 23,000 gallons per day as determined with a 5 gallon
bucket -stopwatch.
D has no flow. We have yet to determine its origin but will continue
investigating.
E is a pipe gallery floor drain and is flowing at 7,500 gallons per day.
It also contains process water from water operated pistons and from water
getting by valve packing. Our Maintenance Department may be able to help
reduce the flow from the pipe gallery floor drains by repacking some of
the
valves.
F is a roof downspout and had now flow.
#2 manhole
This manhole is in a roadway, has been paved over and is unaccessible.
Based on drawings, it's inputs are the upstream sewer main flow and one
drain from a process water meter vault. Based on visual inspection around
the vault, there is no evidence of leakage to indicate flow. we plan.to
excavate the area around the #2 manhole, hopefully next week, and visually
verify the piping.
#3 manhole
A is the input from the upstream main.
B is a pipe that has been sealed with concrete.
C is a raw water valve vault drain and has no flow.
D is drainage from the Water Plant's clear well reservoir. This week we
divers verify that the drain valve is not leaking. However, the water
level
is above the overflow pipe and is leaking into the #3 manhole. Its flow
rate is undetermined, but plans are to extend the overflow pipe vertically
eliminating the overflow.
E is a pipe that has been sealed with concrete.
F is a pipe that has been sealed with concrete.
G is a raw water valve vault drain and had no flow.
#4 manhole
We were able to locate and open this manhole. We found an additional pipe
entering from the east, not listed on your drawing. It is shown on
drawings
to be a new backwash line. It appears that the sewer main divides between
#1 manhole and #3 manhole, then rejoins at #4 manhole. I'll insert it on
our drawing, once we excavate the area at #2 manhole to verify, and get a
copy to you. It will be labeled D. The total sandfilter backwash remains
approximately 3 MGD.
A is the input from the upstream main.
B is shown on drawings to be a reservoir drain. However, this drain pipe
cannot be seen in the manhole. It will be eliminated on the new drawing.
C is the reservoir overflow and had no flow..
D is the new backwash line. The above paragraph explains its origin.
2 of 8 3/13/2007 9:05 AM

imapa/sergei.chernikov%40dwq.denr. [e-mail]:993/...
#5 manhole
A is the input from the upstream main.
B is the service pump pit drain and has,a flow rate of less than 1 gpm.
In summary, we have identified all of the contributors and best -estimate
flows entering the the Sand Filter Backwash Sewer Main that discharges
into
our intake canal, with the exception of 41 manhole - pipe D. There was no
flow coming from it. We will continue investigating its source with the
possibility of sealing it with concrete. Also, we will excavate the area
around the #2 manhole and visually confim the piping. I will stay in
contact with you and provide you with any information that you need.
Thanks - Billy
William H. Roy
Environmental Operations & Analytical Supervisor
International Paper - Riegelwood, North Carolina
Office 910.362.4753
Cell 910.512.0608
FAX [phone]
[e-mail]
----- Forwarded by William H Roy/Commercial Printing & Imaging/IPAPER on
03/09/2007 10:32 AM -----
William H
Roy/Commercial
Printing & To
Imaging/IPAPER Sergei Chernikov
user [e-mail]>
03/02/2007 03:56 cc
PM Edward J Kreul/Commercial Printing &
Imaging/IPAPER@IPAPER, Peter A
Fritz/Commercial Printing &
Imaging/IPAPER@IPAPER
Subject
Re: permit(Document link: William H.
Roy)
3 of 8 3/13/2007 9:05 AM

irmp:Ilsergei. chemikov%40dwq.denr. ncmai [e-mail]. net:993/..
Sergei -
Based on the conversations this week between you and me, the International
Paper's Riegelwood Mill has decided to manage the Water Treatment Plant's
sand filter "backwash" discharged at the mill's water intake canal as a
separate discharge outfall.
GPS coordinates at the discharge outfall are N 34o 21.507' and W 78o
12.697'.
As you and I discussed, there are some additional inflows to the backwash
outfall. To obtain accurate information on these additional inflows, the
Water Treatment Operator -In -Responsible -Charge (ORC) and I examined all
six
of the manholes along the discharge pipe route. At the first manhole we
found 6 influents. The majority of flow into the manhole is backwash water
from the sand filters. The backwash pipe gallery floor drains and two roof
downspouts flow into this manhole as well. The pipe gallery floor drain
flow is very low and flow from the roof drains is, of course,
intermittent.
The sources of minor flow in two other pipes in this manhole are yet to be
determined. We will be investigating this next week. The second manhole
contains one roof downspout with intermittent flow. The third manhole has
six discharge pipes. These consist of two raw water valve vault drains,
the
Water Plant's clearwell drain and three other lines permanently sealed
with
concrete. Be advised, there is some leakage through the clearwell drain
valve that we will resolve shortly. We have divers scheduled to be in the
mill March 5, 2007 to investigate and correct this leakage. The fourth
manhole has the drain and overflow pipes from our main water reservoir.
The
fifth manhole has a service pump pit drain pipe entering it.
We will get better flow estimates to you as soon as possible and I will
update you before March 9, 2007.
Also, as I mentioned to you, I found that the sandfilters are backwashed
with water from the Water Treatment Plant's clearwell which contains some
chlorine.
Based on our discussions, I understand our permit will include:
1) Weekly grab samples for TSS, Total Aluminum, Total Manganese, Total
Iron, pH and Total Residual Chlorine and continuous flow measurement.
2) The monthly average flow limit will be finally determined once we get a
more accurate measurement.
3) TSS-limits will be 30.0 mg/L monthly average with 45.0 mg/L daily
maximum.
4) Total Residual Chlorine -daily maximum limit will be 28 ug/L.
5) Total Iron, Total Manganese and Total Aluminum will be measured but
will
have no limits.
6) The pH limits will be > 6.0 and < 9.0.
7) We will begin sampling April 1, 2007 and we will have 18 months to meet
all requirements.
I am attaching a scanned file of a current hand drawn flow schematic. I
will have our draftsmen put together a more polished one for you Monday.
I'll be in touch with you next week. If you need any additional
information, please let me know.
Thanks. Billy
(See attached file: SCAN1777 OOO.tif)
4 of 8 3/13/2007 9:05 AM

imap:Hsergei. chemikov%40dwq. denr. nemail. net@cros. ncmai I. net:993/...
William H. Roy
Environmental operations & Analytical Supervisor
International Paper - Riegelwood, [forth Carolina
Office 910.362.4753
Cell 910.512.0608
FAX [phone]
[e-mail]
Sergei Chernikov
<sergei.cherniko
[e-mail]
William H Roy
02/19/2007 11:05 <[e-mail]>
AM
Re: permit
To
cc
Subject
Billy,
Attached is the right copy of Effluent Page example, please disregard the
previous example.
Sergei
William H Roy wrote:
Good Morning Sergei - I'll give you some historical information
concerning
our Water Treatment Plant's backwash as you requested along with
some
follow-up information.
Our Water Treatment Plant treats on average 40 million gallons of
, 5 of 8 3/13/2007 9:05 AM

imap://sergei. chernikov%40dwq. [e-mail]:993/...
a
the
NPDES
and
water per
day drawn from the Cape Fear River. Alum is added to this untreated
water
to aid in settling of solids. The majority of these solids drop out
in
settling basins, which are washed weekly to the wastewater treatment
system. The clean water then goes through sand filters to remove any
remaining solids. These sand filters are backwashed daily and on
occasions
twice per day. The backwash contains small amounts of river water
solids
and alum. The sand filter backwash water originally discharged into
nearby branch. In 1976, a backwash holding settling pond was built
and put
into service. The overflow from this holding pond, discharges into
our mill
intake canal just ahead of the bar screen and is pulled back into
mill's water intake. The flow is approximately 3.0 MGD.
This backwash was addressed as item 112" in a December30, 2002 "NPDES
Permit
Renewal Application Amendments Permit NCO003298" letter to Mr. David
Goodrich of the NC-DWQ. We also addressed it as item 112" in the
General
Comments section of our November 22, 2006 "IP Response to Draft
Permit NCO00329" letter and it is listed on the updated "Wastewater
Stream
Flow Schematic" attached to the letter.
I am attaching 2 scanned files, 1) the 2002 letter to Mr. Goodrich
and 2) a
2002 email from IP's Mr. Edward Kruel to NC-DWQ's Mr. Rick Shiver on
the
subject.
I'll give you a call to make sure you were able to open the files
will
be happy to provide any additional information to aid the permitting
process.
(See attached file: SCAN1758_000.tif)(See attached file:
SCAN1759 000.tif)
Thanks— Billy
William H. Roy
Environmental Operations & Analytical Supervisor
International Paper - Riegelwood, North Carolina
Office 910.362.4753
Cell 910.512.0608
FAX [phone]
[e-mail]
To
Sergei Chernikov
<sergei.cherniko
[e-mail]
William H Roy
6 of 8 3/13/2007 9:05 AM

imap://serge i. chemikov%40dwq.denr.ncmail. net@cros,ncmail.net:993/...
02/16/2007 01:02 <[e-mail]>
PM
cc
Subject
Billy,
Susan A Wilson
<Susan.A.Wilson®ncmail.net>
permit
I have received the staff report from Wilmington Regional Office,
which
indicates that you have an unpermitted direct discharge to the Cape
Fear
from the water treatment system. This issue has to be addressed in
the
final permit. We need to obtain all the information regarding this
water
treatment system, including the type of the system, volume of the
water
being treated, volume of the backwash, the date when discharge
originally started. Please submit this information as soon as
possible.
We need to evaluate it and make a decision on how to proceed.
Thank you!
Sergei
Sergei Chernikov wrote:
Billy,
Your permit will be issued by the end of February with an
effective
date of April 1, it is done in response to your request.
Sergei
Sergei Chernikov, Ph.D.
Environmental Engineer
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
phone: [phone] ext. 594
fax: [phone]
7 of 8 3/13/2007 9.05 AM

pmot
27
ON
O'c;r
1 :54-',417

To: NPDES Permitting Unit
Surface Water Protection Section CEC c Z006
Attention: Jackie Nowell
Date: December 18, 2006 IENR - WATER QUALITY
POINT SOURCE BRAN H
NPDES STAFF REPORT AND RECOMMENDATION
County: Columbus
Permit No.: NCO003298
PART I -GENERAL INFORMATION
1. FaciflU and Address:
Owner Name:
International Paper Company, Inc.
Facility Name:
Riegelwood Mill WWTP
Physical Address:
865 John L. Riegel Road
Riegelwood, NC 28456
Mailing Address:
865 John L. Riegel Road
Riegelwood, NC 28456
2. Date oLInyestigation: 09/15/06
3. Report Prepared by: Thomas F. Moore
4. Persons Contacted and Telephone Number:
Name: Ed KTuel, Environmental Manager '
Billy Roy, ORC
Telephone: [phone]
5. ' Directions to Site: The facility is located west of Wilmington. Take Hwy 74176 east
approximately 35 miles to Riegelwood, NC. Turn right onto Hwy 87 and travel approximately 5
miles. Turn right at intersection of Hwy 87 and John L. Riegel Road. Follow John L. Riegel
Road into the plant entrance.
6. Discharge Point (List for all discharge points):
The facility has two (2) discharge points:
• Outfall 001 — treated wastewater discharge
• Unpermitted Discharge — backwash from water treatment system
Latitude: 34' 21' 10" Longitude: 78' 12' 10"
U.S.G.S. Quad No: S50 U.S.G.S, Quad Name: Acme
Page I of 6

7. Tupophy (relationship to flood plain included): The site is approximately 18 to 42 Feet above
mean sea level and does not appear to be within the flood plain.
8. Location of nearest dwelling: There nearest dwellings are located within 1 mile of the facility.
9. Receivin .stream or affected surface waters: The facility discharges into the Cape Fear River.
a) Classification: Class C - Swamp
b) River Basin and Subbasin No.: Cape Fear (03-06-17)
c) Describe receiving stream features and pertinent downstream uses: The river is used for
recreational activities, boating. and fishing. The river becomes tidal further downstream and
is also used for shipping. There are numerous wastewater discharges downstream of the
facility.
PART II - BACKGROUND AND HISTORY
This facility was originally owned and operated by Federal Paperboard Company and began
operations in 1951. Since opening, the Riegelwood Mill has undergone continuous upgrades and
renovations, more than doubling its size of operation. In 1996, International Paper Company
purchased the Federal Paperboard Company. The Riegelwood Mill employs 900+ employees.
The primary operations of this facility are the manufacture of bleached kraft pulp and
paperboard. The Riegelwood Mill uses a 100% Elemental Chlorine -Free (ECF) bleaching
process and manufactures approximately 2400 tons/day of solid bleached paperboard, bristols,
and market pulp. The manufacturing process includes two (2) paper machines; one (1) pulp drier
and three (3) bleach plants. The process also houses the world's largest kiln to reclaim and reuse
calcium oxide used in the pulping process. The facility supplies drinking water to Riegelwood.
HoltraChem Manufacturing (HCM) Company (formerly owned by Honeywell, Inc.) operated a
manufacturing facility in Riegelwood, North Carolina. The facility operated from 1963 to 1999
as a chlor-alkali manufacturing plant using the mercury cell process. Mercury served as an
electrode, and the electrolytic cell split brine (salt) into chlorine gas. Other products included
sodium hydroxide (also called caustic soda or alkali), bleach and hydrogen gas. The site is a 26-
acre facility that includes by manufacturing equipment, buildings, warehouses, ponds, and
disposal areas. The site is bordered by the Cape Fear River and wetlands to the east while the
International Paper facility borders the north, south, and west sides. Widespread mercury
contamination has been identified in surface and subsurface soils, wastewater ponds, and
buildings. The wastewater discharge from the HCM facility was discharged into process
wastewater sewer system of the International Paper (IP) facility, which is ultimately conveyed to
the IP wastewater treatment system. Process wastewater from the HCM operations ceased in
1999 and HCM Company applied for dissolution in August 2000. Wastewater discharge
associated with non -process activities such as stormwater and remediation continue to be
discharged to the IP wastewater treatment system. The HCM discharge consists of three streams:
1. Decommissioning water from the decommissioning of the mercury cell chlor-alkali plant;
2. Stormwater; and
3. Sanitary waste water
Page 2 of 6

The U. S. Environmental Protection Agency has begun a Superfund hazardous substance removal
at the HoltraChem Site in Riegelwood, Columbus County, North Carolina. The removal is a
short-term cleanup intended to stabilize or clean up a site that poses an imminent and substantial
threat to human health or the environment due to mercury contamination. Honeywell
International, Inc. has voluntarily entered into an Administrative Order on Consent (AOC) with
EPA and will be performing the removal action at the site. A removal site'evaluation began in
January 2002.
In April 2002, an integrated Expanded Site Inspection / Removal Assessment was conducted by
the North Carolina Department of Environment and Natural Resources (NC DENR) and EPA. As
a result, EPA issued an Enforcement Action Memorandum in July 2002 for a Time Critical
Removal. An Administrative Order on Consent (AOC) was negotiated with Honeywell
Intemational, Inc. Honeywell and its contractors began the Time Critical Removal Action at the
Site in January 2003, with oversight provided by EPA. This action included removal of mercury
from the 24 cells in the old cell building, dismantling and removing the cells and old cell
building, and removing various hazardous chemicals as well as some tanks, piping, asbestos, and
other miscellaneous debris from the Site.
PART III - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1) Volume ofwaslewater to be permitted:
As per permit application:
• Outfall 001 — 50 MGD
• Unpermitted discharge — I MGD (has not been permitted and not included in application)
2) What is the current ermltted ow Limit?
• Outfall 001 — 50.0 MGD
• Unpermitted discharge — not permitted
3) Actual treatment capacity -of the current facility? The current facility is designed treatment
capacity of 50.0 MGD.
4) Dute(s)_and construction aclivities allowed by previous Authorizations to Construct issued in 1he
previous two ears: None
5) Please provide a description oLexisting or substanlially constructed wastewater treatment
acilities: The facility treats 100% industrial wastewater and has a treatment capacity of 0.1
MGD. The facility has two (2) discharge points. The discharges of treated wastewater from a
wastewater treatment facility continue to be discharged through Outfall 001. There has also been
a second discharge of water treatment system backwash through a second discharge point, which
has not been included in previous permits. The discharges and associated treatment systems are
as follows:
Outfall 001
The following is a description of the wastewater treatment facility with the associated capacities
and components:
Page 3 of 6

E�l
Treatment Unit
Capacity
Dual mechanical bar screens
-----
Dual primary clarifiers
-----
Aqueous Ammonia Nutrient addition facilities
2,414 lbs/day
Bacteria addition facilities
-----
pH neutralization facilities
-----
Aerated treatment lagoons with recirculation
142 acres
Sludge holding lagoons
45 acres
Sludge dewatering presses
-----
Effluent defoamer addition system
382 Ibs/day
Oxygen injection system
10,000 lbs/day
Effluent flow meter with recorder
The aerated treatment lagoons are unlined and configured with four (4) bays (3 lagoons and 1
settling pond) in series. The wastewater effluent from the primary clarifiers combines prior to
the treatment lagoons and enters the first lagoon, New Bay. The New Bay is 42 acres in size
with approximately 78 aerators. The wastewater passes from the New Bay to a settling pond.
The wastewater exits the settling pond and enters the South Lagoon, which has approximately 15
aerators. The wastewater'then enters the North Lagoon, which is the final stage of the treatment
lagoon system. The North Lagoon has four (4) aerators to provide post -aeration. The final
effluent exits the North Lagoon where defoamer is added prior to discharge to the Cape Fear
River. River water is also pumped from an upstream location above the effluent discharge and
injected with pure oxygen. The oxygenated river water is then pumped back to the river just
downstream of the effluent discharge.
The treatment facility also includes 6 sludge ponds, which are approximately 45 acres in total
size. There is also an on -site landfill, lime mud pond, and asbestos burial site within the
boundaries of the treatment lagoon system.
Unpermitted water treatment system backwash
During the site visit, the backwash from the water treatment system was found to be discharging
directly into the Cape Fear River and has not been previously permitted. The discharge is located
at the intake for the cooling water, which is located approximately'/z mile upstream from Outfall
001. Please see attached map for specific location.
According the plant personnel, this discharge is continuous and discharges approximately
MGD. It appears the water treatment system is a conventional ion -exchange type system.
6) Please provide a description of proposed wastewater treatmentfacilities:
7) Possible toxic impacts 10 surface waters: dioxin, mercury, chromium, nickel, zinc, chlorine
8) Pretreatment Program LPOTWy. only): N/A
9) Residuals handling and utilization/disposal scheme: Residuals removed from the primary
clarifiers are dewatered in screw presses and dried solids are used as a fuel in the boilers.
Page 4 of 6

10) Compliance history or this facilitv within the post permit cycle is as allows: The
compliance history has been good with the exception of the following:
• January 2003
• 9-Daily Maximum Limit violations for Total Mercury
The possible cause for these violations could be attributed to the HoltraChem site, which is
located just north of the North Lagoon. The HoltraChem site began remediation activities for
mercury contamination in 2002 in which the wastewater from the site discharges to the 1P
wastewater treatment system.
The facility has continued to operate and maintain the wastewater treatment process in a
fashion to'ensure optimum efficiency.
11) Treatment plant classification: Type: WW (Biological Wastewater)
Class: 4
12) SIC Code(s): 2631
PART IV - OTHER PERTINENT INFORMATION
I. Is this facility being constructed with Construction Grant Funds or are any public monies
(munidpals only) involved? NIA
2. Special monitoring or limitations (including toxicity) requests:
• Quarterly chronic toxicity monitoring
• "Cluster Rule" effluent limitations and requirements
3. Important SOC JOC or Com liance Schedule dates: N/A
4. Alternative Analysis Evaluation: NIA
5. Other Special Items: None
PART V - EVALUATION AND RECOMMENDATIONS
This facility is located in the Lower Cape Fear sub -watershed and has a permitted flow of 50.0
MGD. As specified in the Lower Cape Fear Permitting Strategy, facilities with a permitted flow
limit of > 1.0 MGD should include a once per month monitoring requirement for Total N and
Total P. This facility already includes these monitoring requirements and should remain. The
permit should also include a re -opener Special Condition allowing the Division to add or modify
limits and related conditions if necessary to implement the TMDL to address dissolved oxygen in
the Lower Cape Fear River. The renewal of this permit should include a review of the Lower
Cape Fear Strategy to determine the applicability of these requirements to this facility.
The backwash from the water treatment system discharges directly to surface waters and is
current y an u I tea dischar . is type of discharge is require to be permitte and should
be c u ed m t e permit renewal as Outfall 002. The facility indicated that this issue was
brought to the attention of Division personnel in the prior permit renewal, which began in 2001.
A review of the permit files should be conducted to determine if this information has previously
Page 5 of 6

been submitted. In 2002, a technical subcommittee was developed to study the impacts of
membrane and sodium cycle cationic ion exchange WTPs on receiving waters. Based on the
results of the analytical study, a permitting strategy was adopted for all WTPs using membrane
and ion exchange technologies. The minimum monitoring requirements for these types of water
treatment facility discharges are specified in the document entitled "Permitting Strategy for
Reverse Osmosis and Ion Exchange WTPs" which was issued in January 2004. In accordance
with this permitting strategy, these requirements should be incorporated into the renewal of this
permit for this new discharge.
New federal guidelines known as the "Cluster Rule" (40 CFR 430) apply to the bleaching process
filtrates of this facility. These new guidelines require the application of effluent limitations to
untreated process effluents, which will require internal wastewater outfalls to be identified. These
guidelines will set limits for these outfalls, require routine monitoring and require implementation of
best management practices. This facility has been operating under an expired permit since November
30, 2001. The facility has identified where these requirements apply and have implemented many of
these monitoring requirements. The facility has also provided much of this information in prior
meetings and correspondence to provide the necessary information for the Division to include in the
renewal of the permit. The applicable requirements of the "Cluster Rule" should be incorporated
into this permit renewal as it relates to the effluent limitation's applicable to this facility.
Special consideration should also be given to the mercury monitoring and limitation requirements in
accordance with the Cape Fear River Basinwide Monitoring Plan and permitting strategy. The
HoltraChem site is a designated Superfund site, which begun remediation activities in 2002. The
HoltraChem site will continue to discharge wastewater to the International Paper wastewater
treatment facility until remediation of the site is completed. In January 2003, the IP facility
experienced numerous Mercury limit violations and it warrants an in depth review of the mercury
monitoring requirements as it relates to the Cape Fear River Basinwide Monitoring Plan.
In accordance with the "Total Residual Chlorine Policy for NPDES Permits' dated June 19, 2003,
the renewed permit should incorporate the requirements of this policy. The facility does have a
water treatment process, which includes chlorination. There are other potential sources of chlorine
from process chemicals such as those used in cooling water and boiler treatment as well as the
discharge from the HoltraChem site. It warrants an evaluation and passible monitoring requirements
to determine if there are significant concentrations of TRC in the effluent.
The Wilmington Regional Office recommends reissuance of the permit in accordance with the Cape
Fear River Basinwide permitting strategy, and provided no significant adverse public comment is
received. The Wilmington Regional Office also requests that the recommendations provided herein
are considered in the reissuance of Permit No. NC0023256.
ngnature of R ort Preparer
Water Quality Regional Supervisor
cc: WiRO NPDES Permit File
Central Files — DWQ/NPDES
/a//g 1 166
Date
I
19- /0
Date
Page 6 of 6

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INTERNATIONAL PAPER
November 22, 2006
Sergei Chernikov
NC DENR / DWQ NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: IP Response to Draft NPDES Permit NCO003298
Mr. Chernikov:
RIEGELWOOD MILL
JOHN L. RIEGEL ROAD
RIEGELWOOD, NC 28456
NOV 2 8 2006 a
DER - WATER Q : _m
We have taken the opportunity to review the International Paper Riegelwood Mill Draft NPDES Permit
public noticed October 28, 2006, Below are our comments on that draft. Where possible, comments are
listed by permit section for ease of reference.
Section A.(1)
ti -PLPer EPA guidelines, we ask that the final effluent samples listed below be collected as grab samples
" is rather than composites.
`" • Daily AOX
� . • Daily BOD
• Daily Total Suspended Solids
• Weekly NH3-N
• Monthly Total Phosphorus
• Monthly Total Nitrogen
-0 �� • Quarterly Chronic Toxicity �
• Twice monthly Mercury (note: current NPDES permit ask that sample is a composite. EPA
Method 245.1 allowed the sample to be a composite. In September 2003, we were required to
begin using the low-level mercury method EPA Method 1631 E, in which the sample collected
is a grab).
• Quarterly Total Chromium
• Quarterly Total Nickel
• Quarterly Total Zinc
The EPA "Application Form 2C — Wastewater Discharge Inf-ormation - Consolidated Permits Program"
has guideline instructions for sampling. In Item V-B Sampling: the guideline allows one grab sample to
be a representative of holding ponds or other impoundments with a retention period of greater than 24
hours. Our final effluent holding pond has a 2.4 day retention time and overall our wastewater treatment
system retention time is about six days; which allows good mixing of the effluent before discharge.
Page 1 of 4

Sergei Chernikov
NC DENR / DWQ NPDES Unit
IP Response to Draft NPDES Permit
NCO003298
Section A.(1)
We ask that the decimal be removed from the limits on BOD, TSS and AOX. As the data used to
calculate these mass discharges have no more than three significant figures, anything beyond the
decimal is meaningless.
Section A.(1) Note 1.
"Federal Paperboard" should be changed to "International Paper"
Section A. (1)
The draft permit lists the summer period as April 1 through October 31. The summer period in our
current permit is June 1 through October 31 per a variance granted to Federal Paperboard by the North
O Carolina Division of Environmental Management in 1992. We request that the summer period remain
June 1 through October 31.
Section AM Note 5. and Section A. (7.)
We request that the quarterly samples of (1) sludge, (2) landfill leachate, (3) effluent and (4) wastewater
influent be tested for dioxin by grab samples rather than composites. Our rationale for this request is as
follows:
(1) The sludge sample is taken at our sludge dewatering system after being pumped from our clarifier.
The retention time in the clarifier is approximately 6.5 hours. The sludge takes additional time to settle
and to be raked to the center of the clarifier. By the time the sludge from the center of the clarifier is
pumped to the dewatering system for sampling, it has been in the clarifier from several hours to several
days and a grab sample should be adequately representative.
(2) The landfill leachate sample is taken from a pipe that drains 14 acres of landfill. A series of
underdrain pipes collect water beneath the landfill and channel it to that one effluent pipe from which
the landfill leachate sample is taken. By the time all of the drain pipes connect and discharge a good
representative sample of the landfill leachate is exiting the pipe.
(3) The North Basin, which is the last holding basin before the treated wastewater is discharged, has a
retention time of 2.4 days and overall our wastewater treatment system retention time is about six days
providing ample mixing before sample collection and discharge.
(4) The influent sample to the biological treatment system is taken after the clarifier. Since the clarifier
sludge is being tested for dioxin and because of the long retention time and mixing in the clarifier, a
grab downstream of the clarifier should be a representative sample of system influent.
.Z' Section A. (1) Footnote 6, A. (2) and (3) Footnote 2
We are not familiar with the March 19, 2001 "Sampling Plan for Cluster Rule Parameters" referenced
and suggest that it be omitted if it is not necessary. If it is necessary, please advise so we can obtain a
copy for review.
Sections A.(2) and (3)
`J The measurement frequency of "Suspended" and the footnote for chloroform appear to be incorrect.
Is
Sections A.(2) and (3), Footnote 4
We ask that you consider a period shorter than the specified 24 hours for BAT sampling. As the
bleaching process is quite steady, nothing should be lost by allowing a shorter sampling period and we
propose eight hours. Virginia, South Carolina and Georgia have allowed alternative periods from eight
and twelve hours.
-ice Page 2 of 4

Sergei Chernikov
NC DENR / DWQ NPDES Unit
IP Response to Draft NPDES Permit
NCO003298
Section A(5)
w
This section appears to apply to cooling water discharges directly to receiving waters. As we have no
such discharges we ask that this provision either be removed or clearly state applicability to untreated
cooling water discharges.
Section AM
As bleach plant effluents are already being sampled under this permit we feel whole wastewater
treatment plant influent sampling for dioxin is unnecessary and ask that it be removed from the permit.
Ff We also request that quarterly dioxin sampling of sludge and landfill leachate be removed or the
ffi frequency reduced to no more thanannuallybased on a long record on sampling without detection. .
a` Section AM, Section A. BMP Implementation Requirements
2. (i) We request that "Regular daily visual inspections" be changed to "Regular visual inspections
(e.g., once per day)" as the language appears in 40 CPR 430.03(c)(2)(i).
Section FM, BNTP Compliance Deadlines
We request that "Prepare BMP Plans and certify to the Division that the BMP Plan has been prepared in
accordance with this regulation not later than August 1, 2007 or permit effective date." be changed to
"Prepare BMP Plans and certify to the Division that the BMP Plan has been prepared in accordance
with this regulation not later than six months from the permit effective date."
We request that "Implement all BMPs specified in Section A that do not require the construction of
containment or diversion structures or the installation of monitoring and alarm systems not later than
August 1, 2007 or permit effective date." be changed to "Implement all BMPs specified in Section A
that do not require the construction of containment or diversion structures or the installation of
monitoring and alarm systems not later than six months from the permit effective date."
We request that "Establish initial action levels required by Section D not later than August 1, 2007 or
permit effective date." be changed to "Establish initial action levels required by Section D not later than
six months from the permit effective date."
We request that "Commence operation of any new or upgraded continuous, automatic monitoring
systems that the mill determines to be necessary under Section A (other than those associated with the
construction of containment or diversion structures) not later than August 1, 2007 or permit effective
date." be changed to "Commence operation of any new or upgraded continuous, automatic monitoring
systems that the mill determines to be necessary under Section A (other than those associated with the
construction of containment or diversion structures) not later than six months from the permit effective
date."
We request that "Complete construction and commence operation of any spent pulping liquor,
collection, containment, diversion, or other facilities, including any associated monitoring systems,
necessary to fully implement BMPs specified in Section A not later than January 1, 2008." be changed
to "Complete construction and commence operation of any spent pulping liquor, collection,
containment, diversion, or other facilities, including any associated monitoring systems, necessary to
fully implement BMPs specified in Section A not later than eleven months from the permit effective
date."
Page 3 of 4

Sergei Chernikov
NC DENR / DWQ NPDES Unit
IP Response to Drag NPDES Permit
NC0003298
We request that "Establish revised action levels required by Section D as soon as possible after fully
implementing the BMPs specified in Section A, but not later than January 15, 2008." be changed to
"Establish revised action levels required by Section D as soon as possible after fully implementing the
BMPs specified in Section A, but not later than one year from the permit effective date."
General Comments
1. The draft permit cover letter gives the likely effective date of the permit as February 1, 2006.
This was no doubt meant to read February 1, 2007 and as there are a number of quarterly sampling
requirements, we suggest the effective date be moved to the beginning of the second quarter, April
1, 2007.
2. The December 30, 2002 NPDES permit renewal application amendments letter to Mr. David
Goodrich addressed the return of sand filter backwash from our surface water treatment plant to the
mill's raw water intake canal. This al runs appro ix mately 200 feet from the Cape Fear River to
the mill's water intake bar screen. The sand filter backwash empties into the canal at the intake
screen and is pulled back into the mill with the intake flow. We saw no reference to this in the draft
permit and want to make sure it has been considered in assembling the draft permit. A copy of the
original amendment letter is enclosed for your convenience.
3. There were no details on the basis and calculation of discharge limits in the materials provided.
We would like this information for review and inclusion in our records.
4. The analytical results with the resubmitted application completed on Form C as you requested
included the same parameters as had been run for the original application. As Mr. Roy of our
environmental staff discussed with you, we are willing to run any additional parameters upon your
request.
5. For your records, find enclosed updated drawings that include our recently installed softwood
washer and press which started up in October, 2006 as well as some other revisions to provide more
detail. Also enclosed are laboratory analysis results received since the application was submitted.
If you have questions or need additional information, please call William Roy or Edward Kreul of my
staff at [phone] and [phone] respectively. Thank you for the opportunity to provide
these comments and your overall cooperation.
Sincerely,
4J5cott es
ill Manager
Page 4 of 4

x
LIQUOR TANK CONTAINMENT STORMWATER
SUMP
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PAPER MILL EXCESS WW
INTERNATIONAL
®PAPER
NOTER
RIECELWOOD MILL
1. SANITARY WASTE FROM MR1 FACILITIES
DRAWN
KEFFER
MILL -WIDE
ARE DIRECTED TO PROCESS SEWERS AND
ARE TREATED IN WASTEWATER TREATMENT SYSTEM.
CHECKED
WBP/KJM
2. DRAWING SER AS A GENERAL GUIDE
APPROVED
WHR
SEWER
SUBJEC„
11/22/06
REv o.3/12/99
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1 REV12/20/DD
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g110012 3
REv 02 12/99
REv
IL

I
3.0 E MGD BACKWASH
SEPT 2005 / AUG 2006 YEARLY
AVERAGE FLOWS
RECIRC.
INTAKE TREATMENT
SCREEN 0.9 MGD
38.0 MGD PLANT
ROOM
WOODYARD
1.5 E MGD
STORMWATER
RUNOFF
7.4 MGD
PAPER MACHINES
#5 RECOVERY
0.1 MGD
5 EVAPORATOR
0.4 MGD
PULP DRYER
2.5 E MGD
LIME KILNS
NOS. 1,2,3 16.2 E MGD
BLEACH PLANTS
1.0 E MGD
NOS. 2 de 5
23.1 (E) MGD
1.3(E) MGD
POWER BOILER
1.0 MGD
SCRUBBERS
ASH POND
KNOT LINE 0.8 MGD
02 DELIG
TREATED
WASTEWATER
0.8 E MGD
EFFLUENT
CAUSTICIZING
RECYCLE
LANDFILL CELL 1 2.1 E MGD
LEACH ATE NOA
ow
LIQUOR CYCLE NOS. 1,2.3 SSW
PULP MILL 2.1 MGD TOTAL
PRIMARY
BATCH DIGESTERS
#4 RECOVERY .6 E MGD 2.7 MGD
CLARIFIER
NO. 4 RECOVERY
0.2 MGD
KAMYR DIGESTER
TOTAL MILL WATER - 38.0
RAW WATER - 1.6
BASIN RETURN - 1.3
0.6 E MGD
NO.4 BSW
L-AREA
1.5 E MGD
CHILLER BLDG
NOS. 2 k 3 SVP
NOT
1. ALL FLOWS WERE AVERAGED FROM SEPT 2005/ AUG 2006
HOLTRACHEM .04 MGD
2. TOTAL MILL EFFLUENT FLOW CAN BE DIRECTED TO EITHER CLARIFIER,
THE BLEACH PLANT FLOW CAN BYPASS THE CLARIFIERS.
CAR WASH
12.1 (E) MGD
NO.2
PRIMARY
CLARIFIER

SGS ENVIRONMENTAL SERVICES, INC.
Results for Volatiles
by GCMS 8260E
Client Sample ID: Effluent Analyzed By: MJC
Client Project ID: Date Collected; 8/30/2006 10:30
Lab Sample ID: G489-37-1A Date Received, 8/30/2006
Lab Project ID: G489-37 Matrix: Water
Result
Quantitation
Dilution
Date
Compound
UGIL
Limit UGIL
Factor
Analyzed
Acrolein
BQL
25.0
1
9/12/2006
Acrylonitrile
BQL
25.0
1
9/12/2006
Benzene
BQL
1.00
1
9/12/2006
6romodichloromethane
SQL
1.00
1
9/12/2006
Bromoform
BQL
1.00
1
9/12/2006
Bromomethane
BQL
1.00
1
9/12/2006
Carbon tetrachloride
BQL
1.00
1
9/12/2006
Chlorobenzene
BQL
1.00
1
9/12/2006
Chloroethane
BQL
1.00
1
9/12/2006
2-Chloroethyl vinyl ether
BQL
12.5
1
9112/2006
Chloroform
BQL
1.00
1
9/12/2006
Chioromethane
BQL
1.00
1
9/12/2006
Dibromochloromethane
BQL
1.00
1
9/12/2006
1,1-Dichloroethane
BQL
1.00
1
9/12/2006
1,1-Dichloroethane
BQL
1.00
1
9/12/2006
1,2-Dichloroethane
BQL
1.00
1
9/12/2006
trans-1,2-Dichloroethane
BQL
1.00
1
9/12/2006
1,2-Dichloropropane
BQL
1.00
1
9/12/2006
cis-1,3-Dichioropropene
BQL
1.00
1
9/12/2006
trans-1,3-Dichloropropene
BQL
1,00
1
9/12/2006
Dichlorodifluoromethane
BQL
1.00
1
9/12/2006
Ethylbenzene
BQL
1.00
1
9/12/2006
Methylene chloride
BQL
1.00
1
9/12/2006
1,1,2,2-Tetrachloroethane
BQL
1.00
1
9/12/2006
Tetra ch loroethene
BQL
1.00
1
9/12/2006
Toluene
BQL
1.00
1
9/12/2006
Trichloroethene
BQL
1.00
1
9/12/2006
1,1,1-Trichloroethane
BQL
1.00
1
9/12/2006
1,1,2-Trichloroethane
BQL
1.00
1
9/12/2006
Trichlorofluoromethane
BQL
1.00
1
9/12/2006
Vinyl chloride
BQL
1,00
1
9/12/2006
Spike
Spike
Percent
Added
Result
Recovered
4-Bromofluorobenzene
10
10.4
104
1,2-Dichloroethane-d4
10
8.74
87
Toluene -dB
10
10.2
102
Comments:
Flags:
Reviewed By: &,�__
Page 1 of 1 Copy of GCMS_L1M3 Q 95
N.C. CERTIFICATION #481 2 of 8

SGS ENVIRONMENTAL SERVICES, INC.
Client Sample ID: Effluent
Client Project ID. -
Lab Sample ID: G489-37-1 Q
Lab Project ID: G489-37
Compound
Acenaphthene
Acenaphthylene
Anthracene
Azobenzene'
Benzo[a]anthracene
Benzo[a]pyrene
Benzo[b]fiuoranthene
Benzo[g,h,i]perylene
Benzo[k]fluoranthene
Bis(2-chloroethoxy)methane
B is(2-chloroethyl )ether
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
4-bromophenyl phenyl ether
Butylbenzylphthalate
2-Chloronaphthalene
2-Chlorophenol
4-Chloro-3-methylphenol
4-Chlorophenyl phenyl ether
Chrysene
Dibenzo[a,h]anthracene
Di-n-Butylphthalate
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
3,3'-Dichlorobenzidine
2,4-Dichlorophenol
Diethylphthalate
Dimethylphthalate
2,4-Dimethylphenol
Di-n-octylphthalate
4,6-Dinitro-2-methylphenol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Diphenylamine'
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
I ndeno(1, 2,3-c, d )pyrene
Isophorone
Results for Semivolatiles
by GCMS 625
Analyzed By: EAW
Date Collected: 8/30/2006 10:30
Date Received: 8/30/2006
Date Extracted: 9/6/2006
Matrix: Water
Result
RL
Dilution
Date
ug/L
ug/L
Factor
Analyzed
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
20.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
50.0
1
9/11/2006
BQL
50.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
20.0
1
9/11/2006
BQL
10.0
1
9/11/2006
BQL
10.0
i
9/11/2006
BQL
10.0
1
9/11/2006
Page 1 of 2
a270-uMs_V2.00.x4
N.C.
CERTIFICATION W1
3 of 8

SGS ENVIRONMENTAL SERVICES, INC.
Results for Semivolatiles
by GCMS 625
Client Sample ID: Effluent
Client Project ID:
Lab Sample ID: G489-37-10
Lab Project ID: G489-37
Analyzed By: EAW
Date Collected: 8/30/2006 10:30
Date Received: 8/30/2006
Date Extracted: 9/6/2006
Matrix: Water
Result
RL
Dilution
Date
Compound
ug/L
ug/L
Factor
Analyzed
Naphthalene
BQL
10.0
1
9/11/2006
Nitrobenzene
BQL
10.0
1
9/11/2006
2-Nitrophenoi
BQL
10.0
1
9/11/2006
4-Nitrophenol
BQL
50.0
1
9/11/2006
N-N itrosodimethyla mine
BQL
10.0
1
9/11/2006
N-Nitrosodl-n-propylamins
BQL
10.0
1
9/11/2006
Pentachlorophenol
BQL
50.0
1
9/11/2006
Phenanthrene
BQL
10.0
1
9/11/2006
Phenol
BQL
10.0
1
9/11/2006
Pyrene
BQL
10.0
1
9/11/2006
1,2,4-Trichlorobenzene
BQL
10.0
1
9/11/2006
2,4,6-Trichlorophenol
BQL
10.0
1
9/11/2006
Spike
Spike
Percent
Added
Result
Recovered
2-Fluorobiphenyl
10
7
70
2-Fluorophenol
10
6.5
65
Nitrobenzene-d5
10
8.4
84
Phenol-d6
10
6.1
61
2,4,6-Tribromophenol
10
9.2
92
4-Terphenyl-d14
10
8.1
81
Comments:
` N-Nitrosodiphenylamine is reported as the breakdown product Diphenylamine.
• 1,2-Diphenylhydrazine is reported as the breakdown product Azobenzene.
Flags:
BQL = Below Quantitation Limits.
Page 2 of 2
Reviewed By: -4
8270_LIMS_V2.00.0s
N.C. CERTIFICATION #481
4 of 8

Client Sample ID: Effluent
Client Project ID:
Lab Sample ID: G489-37-1
Lab Project ID: G489-37
Analyte
Color
Cyanide
Fluoride
MBAS
Nitrate+Nitrite
Phenol
Phosphate
Sulfate
Sulfide
SGS ENVIRONMENTAL SERVICES, INC.
Analytical Results
Result RL
650
5
BQL
0,005
0.2
0.1
0.096
0.02
BQL
0.025
0.045
0.004
0.64
0.02
426
5
BQL
0.01
Comments
BQL = Below Quantitation Limits
DF = Dilution Factor
RL = Report Limit
Samples reported on dry weight basis.
Units Method
units
110.2
mg/L
335.2
mg/L
340.2
mg/L
425.1
mg/L
353.3
mg/L
SM 510 A,C
mg/L
365.2
mg/L
375.4
mg1L
SM 4500D
N.C. CERTIFICATION #481
Date Collected: 8/30/2006
Date Received: B130/2006
Matrix: Water
Date
Analyst
Analyzed
8/30/2006
Envirochem
9/1312006
Envirochem
8/31/2006
Envirochem
8/30/2006
Envirochem
9/8/2006
Envirochem
9/712006
Envirochem
9/512006
Envirochem
9/8/2006
Envirochem
8/31 /2006
Envirochem
Reviewed By:
subou1_LIMS_v1.2
5 of 8

SGS ENVIRONMENTAL SERVICES, INC.
Results for Metals
Client Sample ID:
Effluent
Client Project ID:
Lab Sample ID:
G489-37-1
Lab Project ID:
G489-37
Batch ID:
6129 6165
Analyzed By:
PSW
Date Collected:
8/30/2006 10:30
Date Received:
8/30/2006
Matrix:
WATER
Metals
Result
RL
DF
Units
Method
Date
Analyzed
Antimony
BQL
0.0600
10
MG/L
6020
9118/2006
Arsenic
0.0509
0.0100
1
MGIL
6010B
9/18/2006
Beryllium
BQL
0.0100
1
MGIL
60108
9/11/2006
Cadmium
BQL
0.0100
1
MGIL
60108
9/11/2006
Chromium
BQL
0.0100
1
MGIL
6010E
9/11/2006
Copper
BQL
0,0200
1
MGIL
6010E
9/11/2006
Lead
BQL
0,0100
1
MGIL
6010B
9/11/2006
Mercury
BQL
0,000285
1
MGIL
7470
9/11/2006
Nickel
BQL
0.0400
1
MGIL
6010E
9/11/2006
Selenium
BQL
0.0200
1
MGIL
6010B
9/11/2006
Silver
BQL
0,0100
1
MGIL
6010B
9/11/2006
Thallium
BQL
0.0100
1
MGIL
6010E
9/18/2006
Zinc
0.0398
0.0200
1
MGIL
6010B
9/11/2006
Comments
BQL = Below Quantitation Limits
DF = Dilution Factor
J = Between MDL and RL
B= Amount in Prep Blank > MDL
N.C. CERTIFICATION #481
Reviewed By: yJ
MET_LIMS_� I ALS
6of8

SGS ENVIRONMENTAL SERVICES, INC.
Analytical Results
Client Sample ID: Effluent
Client Project ID:
Lab Sample ID: G489-38-1
Lab Project ID: G489-38
Date Collected: 9/20/2006
Date Received: 9/20/2006
Matrix: Water
Analyte Result RL Units Method Date Analyst
Analyzed
Fecal Coliform 30 est. 1 Colonies SM 18 9222D 9120/2006 Envirochem
HEM Oil & Grease , 6.9 5 mg/L 1664A 9124/2006 Pace
Comments
BQL = Below Quantitation Limits
DF = Dilution Factor
Rt_ = Report Limit
H£M=Hexane Extractable Material
N.G. CERTIFICATION #481
Reviewed By: a"
*ubovt_41M5 v1.7,Ab
2 of 4

imap:[e-mail]:143/...
Subject: Re: question
From: Luanne Williams <Luanne. Willi ams@ncmai l.net>.
Date: Thu, 02 Nov 2006 13:32:40 -0500
To: Sergei Chernikov <sergei.chern iko v@ncmail. net>
I have attached our protocol for issuance of fish consumption advisories for
dioxins/furans which includes all 17-congeners. In order to assess the additive risk
from consuming dioxins and furans from fish, all 17 congeners would need to be
analyzed in the fish tissue. Then, you would multiply the toxicity equivalency factor
(TEF) to each of the 17 congeners to get the TCDD equivalent concentration and
compare this concentration to our action level of 4 ppt. I only need the 17
con eners for fish tissue in order to assess I am not
recommending all 17 congeners for other media. Right now there are no dioxin furan
advisories near Riegeiwood or InternaE Yonal Paper. Are they required to do
dioxin/furan testing of fish on a routine basis? If so, all 17 would need to be done
for the fish tissue samples. Also, carp and catfish would be the species of choice
to sample.
Sergei Chernikov wrote:
Luanne,
I am working on the renewal of the international Paper (IP) Permit (NCOG03298), it
was recently re -assigned to me from'Jackie Nowell. She told me that you requested
that IP monitors all 17 dioxin cogeners in fish tissue. I would like to confirm that
with you. Do you want the monitoring to be conducted in influent and effluent of
the treatment plants, sludge, and landfill leachate? If so, is there any specific
rule or regulation that requires it?
The IP has a dioxin limit in the permit, but this limit only applies to 2,3,7,8 -
TCDD, because it is based on WQ standard. We don't have WQ standards for other
cogeners. I think there is a federal criterion for dibenzofuran, but it's much
higher than our dioxin standard. I think we can require monitoring of all 17
cogeners, but the limit will still be based on 2,3,7,8 - TCDD. I would also greatly
appreciate if you could provide me the reference for a rule/regulation that
requires monitoring of 17 cogeners.,,
Thank you!
Sergei
Dr. Luanne K. Williams <Luanne.Williams rr ncmail.net>
Toxicologist
NC Occupational and Environmental Epidemiology Branch
Phone [phone] Fax [phone]
1 of 1 11/2/2006 3:02 PM

imap://sergei.chemikov%40dwq. denr. ncmail.net@c ms.ncma il.net:143/
Subject: re International Paper (NC0003298)
From: [e-mail]
Date: Mon, 30 Oct 2006 09:14:17 -0500
To: [e-mail]
we will not be reviewing this permit. thanks.
1 of 1 10/31/2006 9.02 AM

AFFIDAVIT OF PUBLICATION
STATE OF NORTH CAROLINA
COUNTY OF NEW HANOVER
5fiould"?;.the "Dfvisloi
receive =" a' ` significant;,
:degree of public interest. •,r!
'6plei of the iliaft permli,3
and ; �otfier _° suppporting
Info OW, file used•,
nd payment of.+
of reproduction..
nments' ; .pn��or
ior
4CI"Dlld"? }}nntormatlon'•,
n! °of"
uality Est r theb
itess, or call Ms. ,i
ryant (919} 733•=
.enslow,31 3.1 orb
ces Candeiirlat;
r. cso-733-5083,:�
'520 :at ,'the'-
Diirce r..,Branch.
lude the NPDES .
Before the undersigned, a Notary Public of Said County and State,
T. Weil-Tallmadge
Who, being duly sworn or affirmed, according to the law, says that he/she is
CLASSIFIED ADVERTISING MANAGER
of THE STAR -NEWS, a corporation organized and doing business under the Laws of the State of
North Carolina, and publishing a newspaper known as STAR -NEWS in the City of Wilmington
PUBLIC NOTICE STATE OF NORTH CAROLINA ENVIRONMENTAL MANAGEMENT
COMMISSION/NPDES UNIT 1617 MAIL SERVICE CENTER RALEIGH, NC 27699-1617
NOTIFICATION OF INTENT TO ISSUE A NPDES WASTEWATER PERMIT On the basis
of thorough staff review and application of NC Gen
was inserted in the aforesaid newspaper in space, and on dates as follows:
101281x
And at the time of such publication Star -[News was a newspaper meeting all the requirements and
qualifications prescribed by Sec. No. 1-597 G.S. of N.C.
s / • �i%�i(,,re + 4W&AdT
Title: CLASSIFIED ADVER. MGR
Sworn or affirmed to, and subscribed before me this 5T day of
0 (1 N 00 (w tt"6re1u+�� , A.D., _�� E . S
In Testimony Whereof, I have hereunto set my hand and affixed my ,
year aforesaid r �• �O
160
AU8 y
My commission expires day of A U 6, 20--0 q
he aforegoing affidavit with the advertisement thereto annexed it is adjudged by the Court that the said
'd properly made and that the summons has been duly and legally served on the defendant(s).
the hours of '8:00'�a,mr?
:and.5:00,p.m.•:to- review ly of
.Information on file. ;. a.
'International 'Paper
I �;
PePer�
,Company, ,.;:,::•,, . Inc.,
. Rle elwood,, ,,, Feclllty, '
,NP8B5 A. permit'
NC0003298, has :applied
Jar'renewal of Its permit
discharging . 50 MGD to''
;the �Cape,,Fear River in
G the .Cape ,.' Fear -. River 1
_:Basin: ;:.-_This .'Jacllity
operates :', Outfali--.,00
(treated.'. wastewater),
,;Currently'• 80D, dissolved
oxygen;; and' dloxin,° ro'
.water quality I mited.'This i
discharge mayffect I
future allocations .in ;this
portion. of„ the ,Cape .Fear.
Eau r' Lc ,
NOV 0 7
DENR • WA'�R 0lJAL Ty ` r Otlanda & Skurmwaler 8ranrh
Clerk of Superior Court

imap:Hsergei.chemikov%40dwq:denr.ncma [e-mail]:143/...
Subject: Re: question
From: Mark Hale <mark,[e-mail]>
Date: Tue, 17 Oct 2006 11:06:23 -0400
To: Sergei Chernikov <[e-mail]>
CC: Jeff Deberardinis <[e-mail]>
Sergei:
I reviewed the fish tissue report for NCO003298 and have the following comments:
Fish were collected at stations consistent with previous facility studies.
Target species collected were consistent with previous facility studies.
,Fish samples were of acceptable size and weight and within the range of what would be
consumed in the area. 2378TCDD, 2378TCDF, and TEV dioxin results were well below the
current NC action levels.
2005 results are consistent with previous annual results which show fish dioxin
levels decreasing and remaining below levels of concern since 1992.
Let me know if you have any further questions. Thanks
Mark
Sergei•Chernikov wrote:
Mark,
The International Paper Permit (NCO003298) was recently reassigned to me from
Jackie Nowell. I have been reviewing the files and found Dioxin Monitoring of Fish
Tissue Report that was submitted to us on December 19, 2005. The facility staff told
me that they have sent you a copy. I was wondering if you had a chance to review
this report and make any conclusions? I am sorry if Jackie already requested this
information before, but she had a surgery and now on a medical leave.
Sergei
Mark T. Hale
NCDWQ Environmental Sciences Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Phone: [phone]
Fax: [phone]
1 of 1 12/13/2006 10:51 AM

imap:Hsergei.chemikov%40dwq.denr.ncmail.net@cros. ncmail.net:143L..
Subject: Re: IP plant (NC0003298)
From: [e-mail]
Date: Fri, 13 Oct 2006 10:20:10 -0400
To: Sergei Chernikov <[e-mail]>
The Cluster Rule allows flexibility regarding sampling locations for
bleach plant parameters. What you described is OK.
Unless prohibited by the mill's construction, chloroform must be
monitored in the separate acid and alkaline streams at the point closest
to where bleach plant wastewater is discharged from process equipment.
I highly recommend the permit provide details to the sampling location
--even a schematic showing the locations, if necessary.
Karrie-Jo Robinson -Shell, P.E.
Sergei Chernikov
<sergei.cherniko
[e-mail]> To
Karrie-Jo Shell/R4/USEPA/USSEPA
10/13/2006 08:58 cc
AM Marshall Hyatt/R4/USEPA/US@EPA
Subject
IP plant (N00003298)
Karrie-Jo,
The IP permit (NC0003298) was reassigned to me recently. They have a
situation that is similar to the Weyerhaeuser Plymouth Plant. There are
there bleach plants, the sewer systems for plants #1 and 42 are combined
and the facility is not able to sample each plant separately, which is
required by cluster rule. I was wondering if you can give them
permission to have a combined effluent point for bleach plant #1 and
bleach plant #2? They will have a separate sampling point for bleach
plant #3.
Thank you!
Sergei
1 of 1 t2/13/2006 10:58 AM

INTERNATIONALS
PAPER
September 29, 2006
Sergei Chernikov
NC DENR 1 DWQ NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: NPDES Renewal Application
Mr. Chernikov:
RIEGELWOOD MILL
JOHN L, RIEGEL ROAD
RIEGELWOOD, NC 28456
ff @--F= ow 1111
IOCT 3 2006
DENR - WATER QUALITY
As Jackie Nowell requested, enclosed is a resubmittal of our NPDES renewal application using
Forms 1 and 2C. Also, as requested, a new chemical analysis was performed including all of the
parameters listed for the pulp and paper facilities. A few of the analyses results are not yet
available. As I receive additional information, i.e. laboratory analyzes, I will forward to you.
Be advised that vacuum drum washers on our #1, #2 and #3 brown stock washer lines are being
replaced with a single vacuum washer and press. This upgrade should reduce water usage and
will change the sewer flows from those indicated in the diagram of the application. As you desire,
we can update that diagram after we have sufficient operating history in the new configuration.
You and I discussed the testing required in Section V Part B of Form 2C. After reviewing the
application, please give me a call at your convenience and we will determine what, if any,
additional parameters need to be tested.
If you have questions or need additional information, please call me at [phone]
Sincerely,
William H. Roy
Environmental Operations and Analytical Supervisor

HOU iA
BAR SCREEN
BAR 91xtED1
mm.
TOTAL MILL EFF1LEXT FLOW CAN BE DfRECSED TO
f]71ER CLARIFIER AND THE BLEACH PLANT WAY
fIfO1V WALLY BYPASS THE CLAIBFER(5).
1Z WGD (EST)
313 TPD 911D[F Pm
1-5N SOLIDS (EAffnam)
N041
SURFACE AREA:
906746 M
Fii50BICE TTLfE:
9.3 HM
1.0E Wm SLUDGE
F1LIRATE SCREW
P�
30-40X SOLD
06 TPD
N(X2E5
PONQt
GROUP: Pulp and Paper
DMSION/SUBSIDWRY: Manufacturing
MILL/PLANT: Riegelwood Mill
H2SO4
(IF 0)
11.E YGD
ASB
AS
(NMI
A�RAT10N MW) .
((1EE1A0.ARR2
A�RA110N�NP
AIL: °
36.5 WW
Sumo
sURc� AREA:
1.a�101ooD F
VOUfLE:
1,134aaD F'Tx
VOLUME-
tlLao
24.9 UGOD
TtifE:
2.6 DAYS
TYeE
25 DAYS
NHs t
AIERNATANT
RMCRCLLA710N
240 MOD
F11L4HIIG POND
ri
BACTERIA
SURF( Il
(lF NEEDED)
1.414700 FT
o
IIOLLM _
B92
7WE:
2.4 DAYS
DEFOAWEit ...
.
OKYGEN PAR91ALL
10.00E LBSAAY
3E 1 MOD
CAPE FEAR RIVER
DRAWN BY: CEW SCALE DRAWING NO.
WASTEWATER FLOW INTERNATIONAL ® PAPER V110012
DATE 12-20-00 N/A mEGmwom MILL

SEPT 2005 / AUG 2006 YEARLY AVERAGE FLOWS
RUNOFF
15 �•M,
#5 EYAPMAM
2.5
NOS 2 & 5--1 1.0 E MGO
POMIiIi BOIIER ASH POND 1.0 IttA
PULP MLL 21 mm
PULP Dwfm
NOB. 1.2.3 1&2 E MW
25.9 (E) 1iKU
02 DEW
N0.1
PFMAMY
C LAiiIM
Q2 MW. TOTAL MIL WrA7M — 380
AYYR OIG£S1ER __ -. RAMP WA7M — 1_6
EAM BERM — 1.3
NQ4 BW me E MGO NO7E:
ALL FU MM5 MERE AVEPAM FROM SEPT 2005 / AUG 20O8
• WM- IWAL MU EFFUB1i RM CAN BE G==EG 70 UDGR MM
L—AREA 1.5 MG0 AND 11E GLEAM PLA11i MAY IODMVUY UWASS IHE CLARF L
CNRLER BLOC
CAR WASH
12.1 I) MW
N0.2
PRWARY
CLARWIER

SPILLWAY
— ELECTRICAL CONTROL. STATIONS
Cl 50HP AERATORS x 9 = 450 TOTAL HP
O 20HP AERATORS x 7 = 140
_ ® 75HP AERATORS x BO = 6000
6590 SUBTOTAL HP
REGRCULATION PUMPS 60.5 MGD x 4 = 242 MGD
PLANT �i 3.0 I]AYS REr. O 42MGD RET. ACRESo� �' �., T. ACRES
� � � � O 42YGD
r owe om � y
o� 1 !ow r
NEW LANDFILL 45 ACRw d`1 a w !
3.0DAYS RELO427
s
�� id' s 1 1
(ID! CLOSUR'RDOCESS)
an
W� '� * ea1'e� ou
SLUDGE PONDS i
�$ 35 ACRES ` ~
A
d"F LIME MUD
#2 POND oa
+•: i 1
C
W � °a
a �®
U O
O 0�
INTERNATIONAL PAPER
RIEGELWOOD MILL
DRAWN JDC WASTE
CHECKED DES
APPROVED DES TREATMENT
,E„ _12/20/00 Rev s/4/03 SYSTEM
FIE„ 29MAY94 REV SISEPT96 om um qEv
Mv 20Auc96 „ v 13MAR97 A 12 0 0 0 3 5

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0003298, International Paper Company (IP)
Riegelwood Facility
Facility Information
-Applicant Facility Name:
International Paper - Riegelwood Facility
_Applicant Address:
865 John L. Riegel Road Riegelwood, NC 28456
Facility Address:
865 John L. Riegel Road Riegelwood, NC 28456
Permitted Flow
50 MGD
Type of Waste:
99.8 % Industrial, 0.2% Domestic
FacilitylPermit Status:..
Major Industry; Renewal; First inclusion of the cluster rules
County:
Columbus
Miscellaneous
Receiving Stream:
Cape Fear River
Regional
Office:
WiRO
Stream Classification:
GSw
Quad
J26SW
303(d) Listed?:
Yes - DO and
biological
Permit Writer:
Sergei Chernikov
Subbasin:
030617
Date:
October 20, 2006
Drainage Area mil :
51301
! .•
Summer 7Q 10 cfs :
856
Winter 7Q 10 (cfs):
1101
Average Flow cfs :
5330
IWC % :
8.3%
Primary SIC Code:
2611 Pulp/Kraft
Mill, 2621 Paper Mill
SUMMARY
The International Paper (1P) 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 I 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 new
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 and concluded that "2,3,7,8 TCDD, 2378 TCDF, and TEV dioxin results
were well below the current NC action levels, and 2005 results are consistent with previous
annual results, which show fish dioxin level decreasing and remaining below levels of concern
since 1992".
Outfall 001
This outfall contains wastewater associated with the all industrial operations, landfill leachate,
and sanitary sewer wastewater.
Outfall 00land 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

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 good toxicity monitoring record for the past 4.5 years (only one test
resulted in failure, see attached).
RPA:
The Reasonable Potential Analysis (RPA) was conducted for Cr, Hg, Ni, and Zn (see attached).
COMPLIANCE SUMMARY:
The D MRs were reviewed for the period 01 / 01 / 03 through 9 / 01 / 03. The facility has a relatively
good compliance record. Only two NOVs were issued: 10/ 14/05 - WET failure, and 12/8/03-Hg
limit violation.
INSTREAM MONITORING:
IP is required to perform stream sampling for D.O. 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.
PROPOSED CHANGES:
• 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 1 and 2,
and Outfall 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.
• 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. (8.) was added to the permit in accordance with the provisions of
the Cluster Rule (40 CFR 430.03).
• Special condition A. (9.) 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. (6.)).
• Biocide special condition was added to the permit (See A. (5.)).
• Special Condition A. (7.) 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.
See attached spreadsheet for calculations.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: Nov. 9, 2005 (est.)
Permit Scheduled to Issue: Jan. 2, 2006 (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] ext. 594.
International Paper Riegelwood NC0003298
NPDES Renewal
Page 2

P., REASONABLE POTENTIAL ANALYSIS
International Paper WWTP
nc0003298
Tare Period =084-moos
Ow (MGD)
50
7010S (dfs)
on
7010W (Cfs)
1101
30Q2 (03)
0
Avg. Stream Flow, QA Ws)
5330
RecYing Stream Cape Fear River
WVVTP Class IN
MC (96) 0 7010S 8.3021
7Q10W 8.5762
03002 NIA
QA 1.4332
Stream Class C SW
Outfall 001
Ow = 50 MGD
STANDARDS&
PARAMETER
TYPE
CRITERIA 12)
P OL
Units
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
{11
NCWQSI %FAVI
Chmak Acah
n tDst AirPnd4ir A/sb or4Lti
Acute: 1,022
Max. pred. <chronic end acute allowable cons. Recomme
Chromium
NC
50 1,022
ug1L.
30 27
22.7
deletion of monthly monitoring.
_ _
Chronic: -- 602
- AA
Acute: NIA
Recommend continued quarterly monitoring bas on dust
Dioxin
C
1.4E-08
uglL
10 10 NIA
rule and pulp and paper mill discharge.
Note: nc12--
_ _ _
Chron�:ti
-------.--.---- —-----_— ---
Limited data set
Acute: N/A
Max. pred. c chronic and acute allowable cons. Recomme
Mercury
NC
0,012
0.0002
u911-
128 128
0.1109
deletion of monthly man_horing.
_ _ _ _ _
Chronic: 0.1445
n jl &WAA
Acute: 261
Max. prod. c chronic and acute allowable cones. Recomme
Nickel
NC
88 261
uglL
30 30
45.9
deletion of monthy monitoring.
_ _
ChronlC_: 1-j60
--- 'J --------------
Acute: 67
Max. pred. .< chronic and acute allowable cons. Recomme
Zinc
NC
50 AL 67
uglL
30 30
130.3
deletion of monthly monitoring.
_ _ _ _ _ _
Chronic: - 802
— _
-1 ----------
3
+ P-------l yv-�
'Legend:
C = Carnirtogentc
NC = Non-cardnogenic
A = Aesthetic
— Freshwater Discharge
J
3298rpa2006,rpa
7124/2006

REASONABLE POTENTIAL ANALYSIS
4
5
Chromium
Dioxin
Date Data
BDL=1/2DL
Results
Date Data
BDL=1/2DL
Results
1
8
8.0
Std Dev.
2.6397
1
0
0.0
Std Dev.
0.0000
2
6
6.0
Mean
7.8500
2
0
0.0
Mean
0.0000
3
7
7.0
C.V.
0.3363
3
0
0.0
C.V.
#DIV/0!
4
7
7.0
n
30
4
0
0.0
n
10
5
c 5
2.5
5
0
0.0
6
a 5
2.5
Mult Factor =
1.5100
6
0
0.0
Mult Factor =
N/A
7
Dec-2005 9
9.0
Max. Value
15.0 ug/L
7
0
0.0
Max. Value
0.0 ug/L
8
8
8.0
Max. Pred Cw
22.7 ug/L
8
0
0.0
Max. Pred Cw
N/A ug/L
9
7.0
7.0
9
0
0.0
10
10.0
10.0
10
0
0.0
11
10.0
10.0
11
12
6.0
6.0
12
13
10.0
10.0
13
14
9.0
9.0
14
15
6.0
6.0
15
16
15.0
15.0
16
17
10.0
10.0
17
18
9.0
9.0
18
19
8.0
8.0
19
20
7.0
7.0
20
21
9.0
9.0
21
22
12.0
12.0
22
23
7.0
7.0
23
24
9.0
9.0
24
25
8.0
8.0
25
26
8.0
8.0
26
27
7.0
7.0
27
28
6.0
6.0
28
29
s 5
2.5
29
30
10.0
10.0
30
31
31
32
32
33
33
34
34
35
35
36
36
37
37
38
38
39
39
40
40
41
41
42
42
43
43
44
44
45
45
46
46
47
47
48
48
49
49
50
50
51
51
52
52
53
53
54
54
55
55
56
56
57
57
58
58
59
59
60
60
61
61
62
62
63
63
64
64
65
65
66
66
67
67
68
68
69
69
3298rpa2006, data
1 7/24/2006

REASONABLE POTENTIAL ANALYSIS
Nickel
Date
Data
BDL=112DL
Results
Date
Data
BDL=112DL
Results
1
Jun-2006
0.0177
0.0177
Std Dev.
0.0123
1
16
16.0
Std Dev.
2
0.0142
0.0142
Mean
0.0214
2
12
12.0
Mean
3
0.0109
0.0109
C.V.
0.5756
3
15
15.0
C.V.
4
0.0137
0.0137
n
128
4
16
16.0
n
5
May-2006
0.0080
0.0080
5
18
18.0
6
0.0075
0.0075
Mutt Factor =
1.3200
6
21
21.0
Mull Factor =
7
0.0089
0.0089
Max. Value
0.0840 ug/L
7 Dec-2005
18
18.0
Max. Value
8
0.0078
0.0078
Max. Pred Cw
0.1109 ug/L
8
20
20.0
Max. Pred Cw
9
0.0212
0.0212
9
13
13.0
10
Apr-2006
0.0078
0.0078
10
18
18.0
11
0.0160
0.0160
11
14
14.0
12
0.0104
0.0104
12
13
13.0
13
0.0076
0.0076
13
17
17.0
14
Mar-2006
0.0107
0.0107
14
21
21.0
15
0.0095
0.0095
15
20
20.0
16
0.0070
0.0070
16
25
25.0
17
0.0094
0.0094
17
29
29.0
18
Feb-2006
0.0154
0.0154
18
19
19.0
19
0.0136
0.0136
19
19
19.0
20
J 0.0127
0.0127
20
17
17.0
21
0.0188
0.0188
21
20
20.0
22
0.0147
0.0147
22
27
27.0
23
0.0136
0.0136
23
21
21.0
24
0.0127
0.0127
24
23
23.0
25
0.0188
0.0188
25
20
20.0
26
0.0147
0.0147
26
19
19.0
27
Dec-2005
0.0125
0.0125
27
31
31.0
28
0.0110
0.0110
28
28
28.0
29
0.0145
0.0145
29
33
33.0
30
0.0144
0.0144
30
24
24.0
31
0.0140
0.0140
31
32
0.0104
0.0104
32
33
0.0076
0.0076
33
34
0.0099
0.0099
34
35
0.0100
0.0100
35
36
0.0138
0.0138
36
37
0.0177
0.0177
37
38
0.0059
0.0059
38
39
0.0106
0.0106
39
40
0.0151
0.0151
40
41
0.0130
0.0130
41
42
0.0161
0.0161
42
43
0.0133
0.0133
43
44
0.0204
0.0204
44
45
0.0154
0.0154
45
46
0.0148
0.0148
46
47
0.0204
0.0204
47
48
0.0183
0.0183
48
49
0.0281
0.0281
49
50
0.0320
0.0320
50
51
0.0163
0.0163
51
52
0.0172
0.0172
52
53
0.0380
0.0380
53
54
0.0410
0.0410
54
55
0.0514
0.0514
55
56
0.0494
0.0494
56
57
0.0270
0.0270
57
58
0.0150
0.0150
58
59
0.0207
0.0207
59
60
0.0239
0.0239
60
61
0.0214
0.0214
61
62
0.0151
0.0151
62
63
0.0210
0.0210
63
64
0.0172
0.0172
64
65
0.0230
0.0230
65
66
0.0200
0.0200
66
67
0.0180
0.0180
67
68
0.0203
0.0203
68
69
0.0226
0.0226
69
5.3284
20.2333
0.2633
30
1.3900
33.0
45.9
3298rpa2006, data
-3- 7/24/2006

REASONABLE POTENTIAL ANALYSIS
70
0.0224
0.0224
70
71
0.0000
0.0001
71
72
0.0182
0,0182
72
73
0.0177
0.0177
73
74
0.0138
0.0138
74
75
0.0186
0.0186
75
76
0.0253
0.0253
76
77
0.0191
0.0191
77
78 Dec-2004
0.0206
0.0206
78
79
0.0170
0.0170
79
80
0.0187
0.0187
80
81
0.0173
0.0173
81
82
0.0199
0.0199
82
83
0.0187
0.0187
83
84
0.0126
0.0126
84
85
0.0191
0.0191
85
86
0.0148
0.0148
86
87
0.0244
0.0244
87
88
0.0154
0.0154
88
89
0.0177
0.0177
89
90
0.0223
0.0223
90
91
0.0244
0.0244
91
92
0.0274
0.0274
92
93
0.0286
0.0286
93
94
0.0199
0.0199
94
95
0.0209
0.0209
95
96
0.0299
0.0299
96
97
0.0432
0.0432
97
98
0,0432
0.0432
98
99
0.0386
0.0386
99
100
0.0575
0.0575
100
101
0.0434
0.0434
101
102
0.0343
0.0343
102
103
0.0294
0.0294
103
104
0.0400
0.0400
104
105
0.0250
0.0250
105
106
0.0406
0.0406
106
107
0.0516
0.0516
107
108
0.0840
0.0840
108
109
0.0456
0.0456
109
110
0.0020
0.0020
110
111
0.0219
0.0219
111
112
0.0382
0.0382
112
113
0.0342
0.0342
113
114
0.0364
0.0364
114
115
0.0332
0.0332
115
116
0.0340
0.0340
116
117
0.0275
0.0275
117
118
0.0202
0.0202
118
119
0.0245
0.0245
119
120
0.0188
0.0188
120
121
0.0250
0.0250
121
122
0.0236
0.0236
122
123
0.0360
0.0360
123
124
0.0046
0.0046
124
125
0.0174
0.0174
125
126
0M39
0.0239
126
127
0.0222
0.0222
127
128
0.0278
0.0278
128
129
129
130
130
3298rpa2006, data
- 4 - 7/24/2006

REASONABLE POTENTIAL ANALYSIS
16
Zinc
Date Data
BDL=112DL
Results
1
79
79.0
Std Dev.
14.1089
2
38
38.0
Mean
68.2000
3
42
42.0
C.V.
0.2069
4
48
48.0
n
30
5
70
70.0
6
91
91.0
Mult Factor =
1.2900
ug/L 7
Dec-2005 68
68.0
Max. Value
101.0 ug/L
ug/L 8
78
78.0
Max. Pred Cw
130.3 ug/L
9
65
65.0
10
78
78.0
11
54
54.0
12
74
74.0
13
62
62.0
14
55
55.0
15
71
71.0
16
82
82.0
17
101
101.0
18
79
79.0
19
Dec-2004 72
72.0
20
63
63.0
21
54
540
22
72
72.0
23
78
78.0
24
78
78.0
25
67
67.0
26
45
45.0
27
70
70.0
28
64
64.0
29
72
72.0
30
76
76.0
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
62
63
64
65
66
67
68
69
3298rpa2006, data
- 5 - 7/24/2006

imap:l/serge i.chemikov%40dwq. derv. ncnm it.net@cros. ncmail. net:143L .
Subject: Re: question
From: Mark Hale <mark, h ale@ncm ail. net>
Date: Tue, 17 Oct 2006 11:06:23 -0400
To: Sergei Chernikov <[e-mail]>
CC: Jeff Deberardinis <[e-mail]>
Sergei:
I reviewed the fish tissue report for NC0003298 and have the following comments:
Fish were collected at stations consistent with previous facility studies.
Target species collected were consistent with previous facility studies.
Fish samples were of acceptable size.and weight and within the range of what would be
consumed in the area. 2378TCDD, 2378TCDF, and TEV dioxin results were well below the
current NC action levels.
2005 results are consistent with previous annual results which show fish dioxin
levels decreasing and remaining below levels of concern since 1992.
Let me know if you have any further questions. Thanks
Mark
Sergei Chernikov wrote:
Mark,
The International Paper Permit (NC0003298) was recently reassigned to me from
Jackie Nowell. I have been reviewing the files and found Dioxin Monitoring of Fish
Tissue Report that was submitted to us on December 19, 2005. The facility staff told
me that they have sent you a copy. I was wondering if you had a chance to review
this report and make any conclusions? I am sorry if Jackie already requested this
information before, but she had a surgery and now on a medical leave.
Sergei
Mark T. Hale
NCDwQ Environmental Sciences Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Phone: [phone]
Fax: [phone]
I of 1 10/17/2006 11:31 AM

Hunter F Anderson/Printing & William H Roy/Commercial Printing &
Communications To Imaging/IPAPER a@IPAPER
Papers/I PAPER cc
10/11/2006 11:12 AM bcc
Subject 2003-2005 BP Prod - Air Dry Bleached Tons
2003 ADBT
2004 ADBT
2006 ADBT
#1 BP
Pine Hdwd
231,697 0
232,655 0
228,975 0
#2 BP
Pine
Hdwd
149,834
8,277
140,039
f 16,662
145,966
t 5,797
N
#3 BP
Hdwd Pine
354,068 0
417,860 0
415,352 0

International Paper Company - Riegelwood, Pulp and Paper Facility
Bleach plant and bleach plant 2 have a combined sewer system
calculations are based on 355 days of operatrion per year
Environmentally Bleached Kraft
Air Dried Tons (english)
Average per
year
Average
(tons/day)
Average
(pounds/day)
Bleach Plants
2003 2004 2005
Bleach plant 1+2
Bleach plant 3
389,808 389,356 380,738
354,068 417,860 415,352 .
386,634
395,760
1,089.10
1,114.80
2,178,219.60
2,229 ' 63380
Total
743,876
807,216
796,090
782,394.00
2,203.9
4,407,853.4
Limits for chloroform for each bleach plant are calculated in accordance with Subpart B effluent guidelines I
Bleach plant 9 + 2
Chloroform daily max = 6.92 g/kkg * 988 kkg = 6.8 kg = 15.0 lb/day
Chloroform monthly average = 4.14 g/kkg * 988 kkg = 4.1 kg = 9.0 lb/day
Bleach plant 3
Chloroform daily max = 6.92 g/kkg * 1011.3 kkg = 7.0 kg = 15.4 lb/day
Chloroform monthly average = 4.14 g/kkg * 1011.3 kkg = 4.2 kg = 9.2 lb/day
Effluent limits for external outfall are calculated in accordance with Subpart B effluent guidelines (430.24)
AOX daily max = 0.951 kg/kkg * 1,999.4 kkg = 1,901.4 kg = 4,183.1 lb/day
AOX monthly average = 0.623 kg/kkg * 1,999.4 kkg = 1,245.6 kg = 2,740.4 lb/day
Pentachlorophenol daily max = 0.0014 kg/kkg * 1,999.4 kkg = 2.8 kg = 6.2 lb/day
Trichlorophenot daily max = 0.0088 kg/kkg * 1,999.4 kkg =17.6 kg = 38.7 lb/day
As summaried 10/21/2005 3298-production data-2006 As summarized by Diane Hardison

Average
(kg/day)
988,023.80
1,011,344.9
1,999,368.7
(430.24)
As summaried 10/21/2005 3298-production data-2006 As summarized by Diane Hardison

International Paper -Riegelwood
NCO003298
Columbus County V"Y it P..A
Ceriodaphnia dubia Chronic WET limit at 8% es Wvaw-(- P�fl ve x
Monitoring Months: January, April, July, October
No previous WET noncompliance since began monitoring in 1988
Test Results
7/8/05 Failure of pass/fail test-25% reduction in e roduction from control, no mortalit '
.Ve(-M - q[,eA148/12/05 Invalid test (Control organism reproduction variability exceeds guideline)
8/31/05 Multi -dilution test produces ChV=5.7%-Non Compliant k-
9/23/05 "Split" Multi -dilution test produces ChV=>3 2%-C ompli ant OK
DWQ Response
NOVs issued for 7/8 and 8/31 non compliances
✓ No civil penalty assessed due to average of ChVs > limit (18.8%>8%)
International Paper Response
9/28/05 letter makes argument questioning test results based on laboratory performance
11/9/05 conference call between Matt/Kevin and facility reps Ed Kreul and William Roy.
International Paper reiterates concerns with laboratory; Matt/Kevin address each issue
outlined in letter.
11 /30/05 Kreul emails Alan and again questions test results; requests face-to-face
meeting on 1211
12/1/05 Alan and Matt meet with Kreul, review data and DWQ's position. NOVs will not
be withdrawn.
Rationale for DWQ Position
• Both tests met all EPA and DWQ test acceptability criteria
• Review of laboratory bench sheets indicated no irregularity with either test
• Laboratory was certified
• Laboratory reference toxicant testing data (organism QC tests) indicated organisms
were responding with appropriate sensitivity to toxicants during this time
• There was no other WET test data produced for the facility with which to evaluate
compliance during the months in question
• "Split" analysis conducted 9/23/05 by facility's old lab and another lab produced the
same test result
DWQ's response was consistent with EPA Region 4 and Office of Water policy:
minimum response for WET permit violation is NOV

International Paper (IP)- Riegelwood Plant
CPF17 (030617)
Cape Fear River
C Sw
Dioxin Monitoring Report
12/2005
IP's collection and analysis of fish tissue for the presence of dioxin (2,3,7,8-TCDD) and
furans (2,3,7,8-TCDF). The NC Water quality standard for dioxin to protect human
health from carcinogens through the consumption of fish and shellfish in is 0.000014
ng/1. Federal criteria for dibenzofuran (?) is 94 ug/l.
The IP dioxin monitoring program collects at three stations in the Cape Fear River, one
upstream of the discharge point, and two downstream stations. The highest
concentration of dioxin was 0.583 ppt from common carp at Station 2. The highest
concentration was 0.757 ppt from common carp at Station 2.
Report states that DWQ action level of dioxin in edible fish fillets is 3 ppt. (?). "Dioxin
concentrations below this amount are considered safe and acceptable by NCDWQ". No
samples submitted for analysis in 2005 contained dioxin cone. above the 3 ppt level.
Report indicates that average dioxin cone. have been below the 3 ppt level for the past 14
years.
Note: Dr. Luanne Williams of DHHS has requested that all seventeen (17) 2,3,7,8 —
substituted tetra- through octa-chlorinated dibenzo-p- Dioxin and dibenzofuran congeners
should be analyzed. Asked that we included all 17 congeners in our renewal of pulp and
paper mill permits.

Fig 2.' ,'2002-2003
http://www.unewil.edu/crosr/aquaticecology/lcfrpfWQ%...
10
9
B
7
3
F1
0
NC11 AC DP IC NAV FIB BRR M61 M54 M42 M35 M23 M18 NCF117 NCFS 8210 BBT
Figure 2.2 Mean dissolved oxygen concentrations at the Lower Cape Fear River Program
channel stations.
■ July 2002-June 2003
o June 1995-June 2003
ate
and
1 of 1 6/9/2004 6:01 PM

Table 2.1, 2002-2003
http://www.uncwil.edu/cmsr/aquaticecology/lcfrp/WQ%20Reports/02t-03/S...
Table 2.1 Water Temperature CC) at the Lower Cape Fear River Program stations for the 2002-2003 monitoring period.
DWQ# 59 74 IDWQ# I i
73 75 1 86 87 88 90 H 91 93 61 92
ipjontb�,INAV
:,----7[29.5
JUL
HIB 1 BRR M61 I.
N M54
M42 M35
-��M�3
[29.2 F28.9 28.4
� Fi8.5
Mi� -I SPI)
j
28.2 28.2
28
28.0 -2
month INC11-1 IVC DP BBT
......... ... ­­ . ...... . .. ..... .. ... ..... ..
JUL 30.2 .129.6 29.8 29.&129.8
AUG '1. 30.0 129 .5 129.9 29.41 29.5
i
... .. .. .. .. ... .. ........ ....... .. . ................. .. .. ..
29.9 29.6 30.1 29.7
AUG
SEP
!'F27.0
29.7 3 0. 0
29.4
-�29-6
F27.ij 27.4 1 27.8 27.8
11
128.1 28.3.-., 28.0 Ej
26-8 .7.i�
26.5 H
.. ... ........ ...
i117.1 17.41 17.8
28,0 28.3
4 26
...26-8.
. ...... .... .. .. .. ..
18.1 17.0
;;
SEP 25.3 24.426.626.7 2i.
2 �2 F26.6 .26.4�'25.9
OCT 27,1 6
NOV 14.2 14.5F-14.5 14.9: 14.7
! 'OC
T
F2 6.4j 26.6126 7 i 27.3 26.9
I -NOV
16.0 116.0; 16.1 :d1 16.8 17.0
i DEC
F9.671 95 f 91 1
­
10.2
1110.01
9.6 103E 107
85 F9 8 9.0
11.4 10.3
..... .. .. .
11.3 9.8
F: DEC F1 0.0 9.9 0. 3 9.4.9.0
. ............. .. .. .. .
JAN 7.5 7.1 1 7.6 7.6 7.4
JNT
79 8 5 8.0 8.5 8.5
FEB[7.
7.5
9.5 9.9 1
[]
7�
7.9..8..3.
I .. .8....7.....
110.9 10.6 10.9
8....... 6..... ..... ..
11.1 11.0
FEB 7.2 ..7.2 �i 7.2 7.3
1 F
MAR 8.4 8.8 8.5 8,7.: 10.2
9.8 1 10.0 10.4
APR
[13.9 [1 14.3
14*7
jl. 14.8
.. .. .... .. .. ..
li�FT . .. ..... 14.8 15.4 14.9
- ----
Fii� TiIi 23.4 23.2 23.7
APR 1 13.8 ii
. ...... ...........
MAY 22.8
15.9 1 13.9 14.2 14.8
24.3 �23.6: 23.6
--
F-
11 MAY: 23.6 F23.7 F23.5 23.8 1 2 3.5
JUN F21 0 F21 0 s
mean 18.4118711186
21.6
19.0
22.1
19.0
1 24.0
119.1 19.3 19.2
24.0 7
23,
19.5 19.2
-JUN 20.6 209 120.6 '20.6 20.9
mean 8 18.2 18.2 18.2118.3
71 85 70
84
IC 1NCF6.$210:2NCF117
. .. ......... .........
28.6
29.2
E
30.2 1 30.1 ai
29.4 E 29.4 7 8 F29
........ ..... .. .. ..
26.9 272 125.3 1
26.1
26.3 26.4 125.4
. .. ......... ...
15,0 1 16.5 14.3
25.7
17.4
9.4 11.2 7.5
9.9
7.8 1 8.8 6.8
8.2
7.1 :1 8 3 86
7.4
9.4 i 12.8 ,11.6
11.5
14.5 17.3 16.6
16.5
23.7 i 24.0 122.3 j
24.3
20.8 21.6 21.4 i
21.1
18.4 19.5 18.0
18.9
std 8.48.3 8.5 8.3 8.28.1 7.8 7.7 7.3 7.7 std dev'8.5 [8.38.4
A8.5 8.4 8.5 77 7.8
dev
.... .. .. .. ------
max 29.7 Ii9I30.0 30.1 29.7 29.6 --2---9--.-0--- --­2--8i.-5 28.2 28.3 max 30.2 29.6 -299 '29.8 29.8 30,2 30.1 28.6
8.6 90 min 7.1 7.1 7.2 7.2 7.3 7.1 8.3 6.8
min 7-3 7.6 7
.9 F83 8.7 8.7
69 k 79 h 78 94 77
:month 'ANC
�SARI�
GS INC40
JUL 123,8
25.1
- - ----- ---- --
25.7
- ------
26.2
AUG:' 24.8
27.0
.. . ........ ....
SEP .123.1 (22.9 23.4
23.2:'
OCT '121.9
22.6'
22.9.�
23.5
..........
-8-0-- F81 83 .1 82
PB
JLRC IROC SCIITIBCRR.
26.9
30.5 28.1
25.0 23.5
28.6
-4
26
26.5 24.3
25.4 'I
23.7 23.3
F
22.7 235
28.8
24.1
I ..-. 1,---­[=
24.9 226
DWQ#:; 65 F64 63 62 i 66 67 68
it it
month
16RC
L--co G CO.;i SR -_HAM
COL
11 1 -UL
-25.7 .[26
4
�-
26.5 j 26.2!
24.4 25.8
7 AUG
22.7 [��.0.
23.5; ; 5_F23 6­
----------
23.3
SEP
OCT
25.1 1 '246
1 23. 1 23.8
. ... . .............
-
24.4 23.9 F25.9,:
23.1 Ii3.0 F23.6
24.6
22.5
253
7.8
29.4
All
stations
mean
27.8
27.4
25.6
041p]
I of 2 6/9/2004 6:03 PM

Table 2.3, 2002-2003 http://www.uncwil.edu/cmsr/aquaticecology/lcfrp/WQ%20Reports/02-03/S...
Table 2.3 Conductivity (mS/cm) at the Lower Cape Fear River Program stations for the 2002-2003 monitoring period.
74 6 i 92 71
F 90
DWQ# 72 73 75 86 87 88 A" 89 93 i !DWQ# 70 84
- - --------- - .. ... . ... .. .. ... .. .. .. .. .. ........ .. .
month BRR M61 M54 M42 �'35 -N[FiE3
HB
M18 'I SPD H month INCILVC I AC tDPOBBt: IC INCF6:1210 NCF117.
30.23 38.4 518 .05�123.39��24.85�' JUL 44.03
52.34 1 JUL
0.22 0.24d 0.43 �'03U 1 3.92 118.75110.09 1 0.21
. .. .. .....
f---[47
AUG 18.07::2 3.5 6� 24.07 E' 31.80 7132.95.35.21.41.32
27
49.69 148.6 1" AUG
0.21 0.40 0.55 1 0. 30 5.17 123.35 10.11 0.62
SEP 0.29. 3.21 4.20 11071 .22.6�
1.,:�11
F�1.34 lj
45.3642.8 1
'SEP
0.12 1 0.20 ��0.2Z! 0.22 0,24 3.97 !0.14 0.20
OCT 7.33 -13.90416.94F23.27 26.6829.43 35.143.42
NOV 0.21 0.21 2.81 9.05 .18.11'26.25 39.12'
47.31 H44.56
OCT
0.16 ,..00.470.410.220.32 1.05 10.13 0.227
1:43.30,
42,701
NOV
DEC1
FO. 15 71 0.26 10.21 il 0. 16 0.17 6.42 ., 0.12 0.29
. .. ... ... ....... . ..
0.13 10.14 0.38 :0. 18,;'0, 16 0.18 0.36 0.1 ] 0.21
-:r
[ DEC 5,20
.80 4:3.89 11.78 15.25;':16.95127.3 7
JAN
r!
:' --1- �4.16 1703
10 12��2W 0.51 3.10
7 ,18 0
.... .. .. .. ..... ......
1 .14
44.55!;27.81�
JAN
.1
0 12T 0 .12:b.12i�0.10�' 0.11 0.24 0.10 0.16
.10.3 FEB
7 1.13 0.35 5.20 1 1.7518.00 28.26
[43.84
47.84 i438.961
FEB
0.11 50. 18 0. 15:10.15r
0. 14 0.15 2.09 10.1 0 0.17
MAR 4
0.09.fl 0.09: 0.1 3 12.31 11 8.18
-r25.5 8
. ..... .. .. .. .... .. ..... .. ........... .. ... . . ..... .. . ------ ----
(27.44 91 MAR
112 7.7
0.08 0. 14 0.09 �j O.W
0.09 0.09 1 0.16 !10.09 0.13
--- ---------- ----
APR
0.09 0.10:1 0-09; 0.10 0.1 11 1.22
17.13
39.92 APR
0 -087.,[ 0. 1-6 0. 0 9 1�",
�01
�,70.0ij 09 0.11 0.07 0.11
0.
L MAY A.0,09:�
0. 10 0.18 2.20 3.80 6.94 1 3
0. 1
131.15: MAY
10 .68; jo.lo;,
0 09 0.10 1 0.22 0.07 1 0.11
JUN 0.07;! 0.07 0.071: 0.08 0.09 0.24 3.33
mean 4.2 5.8 6.5 11 10.5 113.3116.1 23.1�
... . ....... ....
8.7 Ir 12.8 13.2 'F
std dev 9.2 11.3
6.6 11.9:
111.0
32.9
20.59 15.041 JUN
40.6 11 36A mean
0.08 i
0.1 0.2 0.2 10.2
0.-O-8'
1
-0.-0-6 0.07 0.07 0-05 0.07
0.2 0.
0-9 4.7 1 0.2
. . ... ..... ...
13-2
1_51.1 tj
F, 0-67: 10.7 std dev
0.2 0.2 10.1
0.1 1.7 7,6 0.0 0.1 1
max 18.1
F2 0 '1
23.5 24.9 31.8 33 2: 38.2 144.0
52.3 1151.0 max
0.7 11 0.5
0.4 6.3 0.6 �.2 --233
....... ....... .... .... .... ..
min 0.1
--j
A
j 0.1 0,1 :; i
0.1 0.1 0.2 3.3
11.1
20.6 15.0 min
0.1 F6:�] Fo -1
0.1 0.1
lo:� -ol Fo-o
L-J
9 69 7
78 11 94 77 80
. ................
83
82 :DWQ#
65 [63
64
All
6 67 68
6
1 stations
H;!�
month ANC SAR
'I:1 PB ! ! C
GS NC403iLRCROC
0.200 0.65 17.7 111 0.170.36
BC1171
0.95
1 0.84
0.16 j
BCRR": month
0.20 JUL
0.19 UG
AUG32
:1
0.27 j SEP
-
F6RC 'LCOF 'GCO�
i
F0. 13 0 08 0.28 110.
0.15 0.0810
0.13 0.101� 0.17
-;R!Wki�!�RAMFCOL 'j mean
1 311i 0. 12 10.20 11.5
F id 0 21 0.58 11.2
91, -6.5
�o 4 0. 19 5. 18 F.�(
JUL 0.11- 0.16!
F-AUG 0. 12 0. 30
r S -EP �010 10.33
0.31 0.45 3.43 0.15'10.52
0.3 I'd 0.23 0.61 0. 11 O�28
A
OCT 1' 0. 18.1 0.28
0. 26 j 0.71 5.02 11 0,20,I3
0.9
0.33 OCT
0.13 0.09110.24 '0.
17 0. 15 0.20
0.14
8.6
I NOV 0.20 0.24
10.24!1 0.64 12.95 0. 17
FO.75
1.03
0.27 _I NOV _
1.0.12 0.09 IFC2TLFO
. 0. 16 0.20
---------- -
0.1 0
6.1
1 of 2 6/9/2004 6.05 PM

Table 2.5, 2002-2003
http://www.uncwil.edu/cmsr/aquaticecology/lcfrp/WQ%20Reports/02-03/S...
Table 2.5 Dissolved Oxygen (mgIL) at the Lower Cape Fear River Program stations for the 2002-2003
monitoring
period.
NC standard is 5.0 mg/L for
surface waters except swarnpwater which is 4.0 mg[L.
DWQ#
73 -75
86
87 88 89 90
91
DWQ#
59 1� 74
61 92
85
70 i
84
month
INAV: IIB' IBRR'
M61
"]M5t'M42:jM35j M23
I M18 '�SPD!
month
FBii I C �'NCF61B21WNCF1171
kll LVC'
AC
P
4.4 5.6 1 5.7
6.2
8.0 1 8,2 7.2 6.5
6 5 [...51
JUL
7.7 7.4
.2
4.4
4.3 .6
6.6
5 .5
5.1
AUG
3.7 3.9 5.2 P
... ... .. .. . T---AUG4 2 6.2
6,0 4.9
A
6.3 4.5
4.4
1
4.3 4.1
4.6
1 2.9
5.7
SEP
43 1 4.1 3.9
3.7
.3
3.7 4.2 5 5.6
j......
5.8 4.4
SEP
42
6.3
F5.7
4.4 5.0
4.8
4.7
4.3
OCT
i.4 3.6 3.8
4.2
4.8 5.4 d 5.8 6.0
6.1 4-5
OCT
5- --1
5k "1 5.6
6.3
3.3
3.3 3.3
4.5
4.3
3.5
NOV
8.2 8.7
8.2........
8.1
7,5 7.7
-7A.. 7.4_-_ ......
6.9j
OV
10.1 9.8
9.9
9.
9. 8.5 :1
0
7 .5
. ... .............
8.1
6.2
DEC
10.7 10-7'�
10.6
11.4: 11.41 10.2 10.8
--
10.4 4[10.41
DEC
11.2 10.6.
-
0 .4
9
F9 J
10.0 9.7
8.6
10, 6,
8.6
JAN
12A 11.8 Ii 12 3
12
1.2.211 12.4 .8
10.2 11.3
JAN__
1_1-8--] -8.
11.5 11,6:
0.7 11.0.1
10.0
111,1:1
9.8
FEB
FF, 7;11.7!;12.6!
11.3
111.7.511.6 1 .2
1 10.5
10.3 11 o
FEB
13.0 1112.7
12 .9 9
1 11.6
2,5 12.8
11.21
11.7
MAR
10.8 10.8 110.8 [1
......
10.6
] 10.6 1 10.9 10.6
10.5 10.5
JI MAR
.7 .311.4.
1.5
8,9
1 9.5
8.7
APR--F&�-[
--
9.1 8.6 1
8.2
.1 8.3 8.7 9.6
F8-
.3 8.7
APR
4 f 7.3
5.7
6.9
5.4
8.9 21 7.0
8. 6
Y
MAY
6 0 6.0 6.3
6.0
6.2 1 6.6 75
6-7T^i
75 66
MAY
7.7 6.9
-
6.1
7..-1--
5.6 5.8
5.5
5,4
4.7
JUN
5.8 5.9 6.2
5.5
5-9 5.8 6.1 1
6.6
JUN
:1
7.1 6.8
6.9
8
4.4
1 6.0
4.5
mean
7.6 .1 7.9
7.6 8.0 :1 8-3 8.2 8A
6
8.1 7.;...... ..
.. . mean
9.0 79 .
V.
8.6
2 7.4
6.9
7.2
6. 5
Ad dev
3.1 3.0 3.0
2.9
2.8 1 2.6 A 2.1 2. 1'
1 .8 2.5 j
std dev
2.5 3.1
3. 30
2.3
51 2.7
2.5
2.4 16
max
12.1 4111.8;1 12,6:�
::
121
. -, -
112.2 J 12. 1. 4
4d
.1 1 -- -- ..;,
10.5 1 L 3
---- '
max :
13.0 12.7
-' ---
12.9
.. ... ... ..
12 .5 12.8
11.6
11.2
11.7
min
364 :1 3.6 3.8
3.7
3.7 4.2 5.3 5.6
5.8 4.4
--F5.6
min
4.2
4.4 13---[3.3
3.3
4 .4
2.9 1
3.5
.. ... ... ..
DW0#
69 79 78
94
77 80 81 83
82
D
65 64
'F
63 62
--- F
66
68
'I
All
stations
i month
SAR
AN'jROC-I , BCRR
GS !NCa03! LRC�B41�7
month
6R&',iCO.jGCO
IiRN FIiAM. COL
mean
[SR
JUL
0.4 2,2
14 7
i 1.8 .
1- _,:16.8 .9
- ------
22 H
--r-
i JUL
4.3
f.2
1 1.4
5.0
5.5
AUG
0.6 4.2 1.1 1
0.8
1 2.8 9. .9 4.1
F-
.1 AUG
6.2 t 6.1
5.7
9.0 6.6 1
4.3
4.8
SEP
0.3 j 4.025
0.1
3.2 6.9 5.4 .4
1' 0
j SEP
6.1
0.8
2.9-1
3.3
5 5
4.5
OCT
0.7 6.5 0.7
0.9
16.0 9.5 3.7 6.8
T
OC
--- 6
6.6
4.9
0.4
F
--F13
Fj .4
6.2
4.8
1 of 2 6/9/2004 6:06 PM

Table 2.26, 2002-2003 http://www.uncwil.edu/cmsr/aquaticecology/lcfrp/WQ%20Reports/02*03/S...
Table 2.26 Biochemical Oxygen Demand (mg/L) at the Lower Cape Fear River Program stations for the
2002-2003 monitoring period.
........... .. ... .... .. ......
5-Day Biochemical Oxygen
Demand
. ......... . a
DWQ#
59
74
J70
84
65
64
63
66
67
68
All
stations
month 'NC11
LVCBBT "
B210'INCF117
.. .. .. .. .. ... ... .. ... .
.. .. . .. .. .. ... ... .. ... .. .. . . . ... ... ---------
6RC
-------------- -
LCO'l
GCO
BRN: HAW
Ti COL
mean
JUL
1.9
12
0.7
1.5
1.2
1.6
2.0
2.9
2.3
1.6
AUG 1
1.7
A --
F
0.8
0.4
0.7
0.8
12
........ .. ..... .. ....... ......
1.0
1.1
2.1
3.4
1.5
SEP
1.4
1.6
1.2
1.1
1.3
0.8
1.9
1.6
j
61.1
1.7
1.4
I
1.6
OCT
.. ... . .. .. ... .. ... ... . .. .. .... .....
1.3
2.3
1.2
1.1
1.3
.1
0.8
2.5
1.0
1.5
1.3
.. .... .. . .. ...... .. .. ..... ....
F'. ..
1.4
.. .. .. . .. .. ........... .. .. .. .. ...........
NOV
0.7
- - - - - - -
1.2
0.8.....,
.. .. .. .. .......
0.7 +
..... .... ..... ... ........ ....... .. .
0.5
- - ----------- ------ -
1.3 -1
1.2
1.2
1 1
2.2
1 .5
1.1
DEC
1.1
2 3
1 1
1.3
1.1
1.3
0.8
1 0.9
0.8
1.0
1 2 0.9
1.2
JAN
J. 7�
1.3
0.8
0.9
1.3
1 2.3
0.7 0.9
09
0.5
1.1
FEB 1.0 1.47
MAR 8- 10 13
-F
0.8
0.5
.
09
0.8
1.0
0.6
0.9
..... .. ..
.. 08
0.3
--T -7
1.4 1.6 0.6
.. .. . .. .. ...
.
1.6 03S.
....... .. ..
1.1
11
APR
1.4
.
.2.5
.... . .......
0.9
12
18
2.1
1.1
0.8
0.7
1. 4
MAY
1.2 4.2 71
1.3
1.1
1.2
1. 1
20
1.1
�T-J�
1.2
1.5
i UN
1.2
1.5 1.8
1.1
1.0 ....... ... .
1.0. .
1.4 1
. .. .. .. .. .... .......
1.3
1.0
1.2
1.6
.. .. . ....... .. ...........
0.9
1.3
1 median. 1.2
1.5
1.0
0.9 11
1.3
1 1.3
1.1
1 of 3 6/9/2004 6:08 PM

Table 2.13, 2002-2003
http: //www.unc wil.edu/crosr/aquaticecology/lefrp/WQ%20Reports/02+03/S...
Table 2.13 Total Phosphorus (mg/L) at the Lower Cape Pear River Program stations for the 2002-2003 monitoring period.
DWQ#
72 73 75
I 86
87
88 89 90
91
93
�1DW�Q#
59
1 74
61 92
71
S 7 84
month
NAV'
HB `BRR'
M61
M54rM42
M3S M23
M18 SPD:r
j month ;NCll
LVC
AC DP
IC
;NCF6` B210 `NCF117—
JUL
130-
11 0 70
80 70
._ 80 30 30
_20
40
�I JUL
250
1190
280 190 ^;
170
i 50 1 0 110
AUG
14o
100 250 80-
80
110 ; 50
20
C
LAUG
210
290
310 ` 180E
170T
I_ 70
(1 0
80 I-
SEP
200 '
170 170,
130
110:
mm,140
90 70 m' ^50
30 -
-40
50 I
: I�SEP Ai
210
0
180 j 190
200
�- 0
80 T 50 j�-
�- —
OCT
1180
--
124
120 W�
90
90
-
f 80 60 - 40
34^
50 T~1
OCT
�230
; 220
270 230
200
80
1 0
NOV
1160
160
150
12D
110 it
90 100 40
40
50
Fr NOV
130
160
140 . 130 150
i 120 1i
70
70 I
DEC
120
1D0 100
110
110
-- _-
9D $0 60
50
40
I DEC
90
70
1110 ,'^-
80
80
14
j 30 1
70
JAN
170
60
80
120
i 120
(110 60 '- -50
-10
10-I
�E JAN :
100
20
110 ; 110
90
60 1�
2 40
�B
1110
ll0
120
90
90
170 60 ---40 _
-30 40
FEB
100
120
110 110= 100
j 70
20 50
MAR
60
140
10
]00
j 130 j
140 ., 80 . -
60 F
60
[MAR „-340
170
..1.60 150 4
1.30-
APR
80
80
90
80
100
100 90_. ,- 60....-
f ..... *`'..
501
__
PAR
100
90
120 100
80
0
5-
MAY
IZO
1D0
11.0
130
�1101r90
_
70 _ 50
50 1
30_.:1
MAY
I10
_
240
I.... 110 120
120
130
—
r 90 90 -- ! -
_
100 .. 80......
60._ 1-_60..,
f -` JUN.....__
_
110....:.-11U
I..110.120._
. 1.00
.1....120
`...70. 110--
mean
123
113 123 :
103
r104
97--,, 73 60
37 43 f
�; mean f
165_.1
143
I W168 143
133W�
95
�70 I ~-73
de
41
30
47
18
F
18 22 28
II{[II!-
15
13 . f
Ad
dev
77
81 LL'
- 73 43
43
31
40
23
max
200 :r170
250 '
130
1130
140 110 140
60
60
max
340
290
310 230
200
140
l50 110
min
160
60
70
80
70
70 30 30
l0
10
min
90
20
110 80
80
50
20
I 40
[
11
r.
_
69
F117
8D 839
I:
;DWQ65
66
�
67
$
F
All64
stations
�
NC403
!BC117
_
LCOGCO
RRmonth
HCOLF6RC
mean�PBLRCRANC1
JUL
l00
70
230
380
320
50 670 -4,740
290
JUL
130
120
570 t 14
110
! 2 0
40-- - -- 312
AUG
1100
170
l90
1,570
4801
50 1,200'-3,610
330 I
;
AUG
240
90
8l0 _9070--�_
0
40 _-`358
I SEP
140
...........
140
110
f.... _
740
300.
70 1 030 570
280
! , _YSEP...
-,310.-...-70
1,400
f1, 00 0
60
91 0
30
256
1 of 2 6/9/2004 6:12 PM