NC0000272_Complete File - Historical_20210121

The Pigeon R1verAcdon Gran
PO Box 941 Asheville NC 2894z
September,2403
360 MuuEreesbozo Road
Nashville,IN 37210 '
' ,
On behalf of several eit>serts WPM atioas of the Pigeon River vvabetshed and`stivawntiiag
we are writing to express oar concern regarding the enviroamentsl Impacts of the Blue Ride Pap
Pmduets mall(BRPP)in Canton,NC It has come to our attention that ytiur company has packaged
ynur food products in BRPP's Dairy,Pak eoaoaiaem,and as a re 4 this may associate your company
with the negative environmental and health impacts that BRPP is inflicting on the pi,8ean Rive .
WateraImd and the ne�hboriogre&'a- Out coalition suppvste sustainable jabs aid pmduetion in the
WOOD.but Blue Ridge Paper has WTAd to implement aevcruI practical and gEdulable tsachnolo&s to
protect her neighbors or the envlroa memt:Our concems with BRPP's Csakon mill include:
• Pollution of more thou.10•billion gallons per year of the P48M Rkwr a magnificent mountain
stream,contaminating what could be potable water fox towns more than 50=110 dower
trem
Savcral North Carolina towrn,as well ae Hartford and Newputt;Tt;naessne,are forced to
water from od=soluree than the polluted Pigeon that paaaea directly&&ugh thget
em.
• Use of raw wood zoatedals cult I'rosi� a�tad SQ4d eaa fo=36,&eluding pnbyc lands.
tir�tAaiag an itretrersible lobs of aativ�eawildiife,plaits stud halumt;chaawaaei from Bested'
=d xwnadczd areas:for the;people of the South.
• E=63 oa of to=chemkaL%Stu elating aul53e9 (the rotten egg Und-for Which pap=n&are a
f9mous jd%5cxi0 s r0TjMtorY P Oigon.sad smtam),II]C<dgeII d7QdC9 (NOR),and sulfur
dicai8e(SOO,contdbutaag to add precipitation and twdc nitrate laicals,in Soda and s eam,
dupaterling human health and increasing regional haze.
We truer that your company 40e2 not want to be associated with the degm&doa of the Water,
air,forests and quality of life in souditm Appalst'hia. We also trust that you reshe time critical
impomnce of these kupacts,as vaell sa those felt by your cust=ers,yourself and your family.
Pollution of our•vftt x and sit,as wed as destruction Of natural foresta,hm ls®ting effects,subjecting
present-aod future generations w=cMased health hazards and thwarted MMMUnies.
We rinse to contact us with arty questions you have about these environmental imp"a and kcvi_
your cempanp can make a diference in reducing theta. We also encoludge You to express ymu
concem to Blue Ridge Paper. We 100k forward co hearing back from you oa this important.mauu,
Please coat wt us at your earliest:coavenieaae: Hope TBYIM-rjuw s,.pead Water for North Car HA96
at(919)401-96DQ;er Alyx PeM7.Wildlaw SusWinable Forests Pzog=at(928)251-1291,Caraille
Caroar,Dead Pigeon Ritter Count at,[phone].
Tbank you for your jtttention and conceal.
b�z'd 26B9979828:0i T8T99b9B2e ZBdUd 900IN 3nie:Woad zS:9T £002-Te-100

- Will The Pigeon S r can MOW. be dmcled up
.B lu-e _Ri d e
Paper' Pr+od�ucts -if BRPP MV5 rug m,t� M MVila�ftdirk with a [on W mdLdo in WM
DA
N .ff MP teal all gowns gwila 0 lrq�M, a alp.
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1° 7E l�r�oe IBA IP�nr��PF OM Oman
drbri,rtde bhr�5fg by an -
,..: : 'r t na n�nr"s 11 ..17 fly iff* u a IM to noq d ling
Co � _ a Eros urn la�rsn�l T®xR+sel.
{0 ..P�ri NMN A.11M,Mil Mo ADD�Pp[!�6lTei mum ind pa1p�Few �P,
En&zzmd SI1 Aem foresu can by
TIN
o f )'= L
A.BW VM to ieMM 11M pelrsnV of put MMUMV
m ea�nt sdfe dL-ie5Oq
.A RUP WM to rhM ad filer ariginAj ha
edaTe!id.fraft bluing OS aathrrd[ants ind
m fame ill ow S011r,
The Cant= 1 and own nut 9=13 AWN als or sM v+� rah, -3 BW Wale Iith in drip s�1M to ad talWWMble
pulp Pam' m 1 of 81ue wuU Wcarc O Pulp a Paartuarv::0 aaroslaauM UXT. In
Rldge Paper Products (BR PP)'s in a v& - noQ6- I3RPrs Van MM'W is 0 6— ualr+ux' W.W�i�mda do aamreninn-Qt im�n to
o mNrinwraa m Mau0nusaa M an Patina. D M PMMM kw murigomt.od du ore
� ley of Wenern March CaP�na alorgWde ad pwaly rnvaf81 oogP
aim
W the Mpon River. This rlvw has bow con.. IIP
�tuaily deeded by disdjatgds from flue Air lueli in WHC can be improm -
w IMW paper mlti since It was butt in 19G&
BW policies di result in the unnec. I •,,_j directly
Msary destmttlon of natural forests and
...>} OW ph.anvil IPA d IM
0 polluting of our ccrPrtl�wnicies`air and wa � ' � bql
ter. A strong worminy daesult r�eWIM tit l�a�tav n8 a I�edPmtianl Saar round.
to aoaept almomt 3 rnilkmots of toDcTC J1 BRPP idsm aW uu ofcoldtnd fuailpt ID be a
selemes to contaminate minate our communities -' .:, ;" �""' � =: ►mh�tj ad� per
®t#F GERRM rtr rower rP i,gn aoUAea lie
and anWramnent We arm not calling for a IgaUnc E u=Px CIAL BUPA M rum ML mom= -319P a m,taidiam wd l tg= tome tit err in,
shut-down,we are aswng for iusdw-, aN vaurrnpt tags 1N VMC 7W AM ruullra eak�n.3cvm- �addles Ids`fit air fermi'for ail lu5aaara3 u
.. PUM M M mom mr�Snrulig,P�D orsraarrraa,�s�c�IsrNa lera�IIrIHTPI A000t- d9mid-6 f 9m.11s Wd did'idia AdYigry btrtl.

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Hle:l/1Untitled
Don,
Yesterday's Meeting
Keith Haynes and I met with a contingency from BRP yesterday on their plans for testing the application of
white rot fungus in their WWTP for color reduction. As you noted in your recent response to an e-mail I
sent you, white rot has had some "failures" in relation to application to pulp and paper wastewater
treatment. It was clear from our meeting with Bob Williams, Derric Brown and their consultant
microbiologist, Rob Whiteman (Advanced Biological Services--ABS, web site of company:
http://www.waste-water.com/) that they see some potential for this treatment process,but that they are
continuing to evaluate other approaches in accordance with the permit we developed and through the
review summaries of the TRW.
"White Rot" and Other Potential "Next Sta e" Color Reduction Efforts
The next "stage" of color reductions required by the permit, including looking at ZD and 2ond Stage OD
for the pine line, is under way. BRP has been evaluating the possible use of these approaches and others,
and will provide a report on the "next" steps (beyond the "highest probability" of reduction efforts--which
have already been completed and that will be evaluated in our review of their Oct. 1 report) in December
(as required by the permit).
Trion, GA
Bob brought along two small bottles of wastewater from the Trion, GA treatment facility which receives a
large quality of textile dye wastewater. The "influent" sample to the aeration basin had a color level of 950
to 1,000 CU and the "effluent" from the aeration basin(not final effluent) had a color of about 150 CU
(during application of the white rot treatment process). It is important to note that the application of white
rot at this facility did not show this kind of productivity in bench tests or for the first four months of the full
scale test. In fact, the facility was just about ready to "give up" on the trial,when they decided to continue
to try it for just a little longer. That was when they started to see the impressive results noted above. I
realize that the application of white rot at Trion was on "textile dye" wastewater,but the biochemical
processes used by white rot should also be effective on "wood based" color bodies (lignin and tannin
molecules). After all, white rot is a process used by the ecosystem to attack wood material in nature. And
as I will note later,Advanced Biological Services (ABS, not to be confused with ASB) reports the effective
use of white rot in other applications dealing with complex organic materials.
Pulp and Paper Applications of White Rot
The application of white rot at the Rayonier, Jesup Georgia paper mill of white rot did not result in a
successful test(and BRP is well aware of this project),but based on my understanding of the "system" used
at that mill for treatment(ASB) and the "application" procedure used for the white rot material used there,
I'm not convinced that the application there was a valid demonstration project for use of this technology on
pulp and paper waste. Activated sludge systems lend themselves much better to the "feeding" of white rot
fungus into the aeration basin, providing the beneficial biological action within the reactor and the resultant
biomass being removed by clarification. An ASB system presents some really difficult problems in using a
continuous flow "dosing" system for application of white rot material.
White Rot "Test" at the Canton Mill
At this time, I am willing to keep an open mind about white rot at the Canton Mill because I believe it to be
1 of4 9/18/2003 3:10 PM

file://Untitled
a "real" biochemical process with research supporting data that it has application in the treatment of pulp
and paper color. As you well know (as as I believe you share this view), I hate "black box" approaches to
dealing with water pollution problems. The use of questionable technologies that cannot be explained in
any kind of reasonable fashion or evaluated as a "real world" full scale procedure do not appeal to me as
"real" solutions. Based on the discussion with Rob Whiteman,however I believe that white rot has
potential because it is a real biological process with significant research behind it. Rob pointed out that the
US Forest Service and academic institutions like NC State U. have spent quite a bit of time looking at the
beneficial uses of white rot in forestry applications. Rob has also had some very effective experiences (on
different types of wastewater) with this methodology in enhancing biological treatment where white rot has
been used to address "organics" that were interfering with "traditional" biological treatment. The key at
Canton would be to give an opportunity for the technology to be tired. I think BRP is committed to this
trial and is willing to invest some time and effort in making it work.
The specifics of the test process were outlined to Keith and I yesterday. Currently,BRP through ABS has
three "reactor" tanks on site being managed to ferment the white rot material they would feed into the
aeration system of the WWTP. In approximately 3 to 4 weeks enough material should be available(and
the capacity to generate more as needed to make the test "ongoing") to support the introduction of white rot
into the BRP treatment process. Rob indicates that once feeding starts, the system should begin to
"respond" within 5 to 6 weeks. As noted in the Trion application, it took some time to optimize the feeding
rate with the system's "best" color removal response to this treatment protocol, say 4 to 6 months. So by
March or April of 2004 we should have a pretty strong indication of the basic "potential" for this treatment
protocol at the Canton Mill. That, of course,would not give a "full" demonstration of what is essentially
an"enhancement" of the biological systems used in the WWTP to treat the Canton Mill wastewater over a
full "seasonal cycle." Just as with conventional biological treatment, where the system must be managed to
get the proper balance between "food source" and bacteriological organisms (F/M) for BOD and Nitrogen
conversion, the use of an "augmentation flow" of other biological material (white rot in this case) will take
some time to properly"regulate" its application at this treatment facility. Additionally, while other full
scale applications have not had an adverse (in fact,just the opposite--white rot helped the other biological
processes in the system) impact on conventional biological treatment,this will need to be confirmed at
Canton over realistic times and "outside" conditions. As the Canton area experiences some pretty wide
variation in seasonal ambient conditions, I would not want to "count on" any reported color reduction with
white rot until it is effectively demonstrated over that range of"outside" physical conditions likely to be
encountered. What this does mean, however, is that time will be needed to properly evaluate the process if
the initial results are promising.
White Rot and the Upcoming TRW Reviews
In our discussions yesterday,I made it clear(as does the permit)that the "next round" of reductions in color
must be achieved either by the technologies identified by the TRW or by other"demonstrated" methods
"recommended by" the TRW and "approved by"NC DENR. As noted, this current demonstration should
not be(nor is BRP proceeding at this point like it is) the only"egg" in BRP's plans for meeting additional
color reductions required by the NPDES permit. However, it is equally clear from the "timetable" I
summarized above, that the testing/demonstration of white rot technology at the plant will not be complete
before BRP is required to "report" to us their plans for meeting the next round of color reductions (the
December report). This means that the TRW should be prepared to "evaluate" over the coming months the
realistic possibility that white rot treatment "could" be an opportunity to effectively reduce the color in the
Mill's effluent on an ongong basis. I think based on what I heard yesterday and my evaluation of these
"claims" that I'm more optimistic that this is a real technology that has potential.
I think it is very important that you and the EPA resources supporting the TRW process begin to take a
2 of 4 9/18/2003 3:10 PM

file:///Untiilcd
"hard" look at this white rot treatment technology. I provided you with the location of ABS's web site, but
I would also suggest that you and the folks you plan to use to support the TRW's review processes talk
directly with BRP and Rob Whiteman to get your own impression of how this technology is expected to
function, where it has been used successfully and in what ways they plan to use it at the Canton Mill.
Ultimately, under the current permit the TRW will need to determine the viability and long term
applicability at the Canton Mill of any color reduction efforts that we "recommend" be applied at the
facility. This includes process modifications/enhancements in the pulping and paper making activities at
the mill, intermediate treatment procedures and wastewater treatment applications used to address color
reduction. But, it remains BRP's responsibility to implement and operate color reduction
technologies/procedures/processes that will comply with the color reduction requirements in the permit. I
believe that the white rot review underway at the Mill is a reasonable and somewhat promising color
reduction technology. Only time and effort will tell if it actually will work at the site.
Current Color Reduction Status
In relation to the upcoming Oct. 1 BRP Report on the performance of the Mill for additional color
reduction with the application of the "first stage" or"highest probability" color reduction efforts,BRP has
implemented these actions/technologies and showed some impressive color reduction results early in the
process. As I have noted to you previously,the effluent has shown some higher color levels from time to
time reported by BRP as due to "sewer generated color." I have asked BRP to specifically address these
conditions in the Oct. 1 report and to show information that will "relate" the "source distribution"
information (where the color is coming from in the Mill) to the effluent color levels occurring at the "end
of the pipe." During a brief discussion of this report yesterday,BRP indicated they would provide in the
report statistical comparison results using the "overall" period after implementation of these most recent
color reduction efforts and results "excluding"those periods when"sewer generated color" (SGC)
increased dramatically. This should give us a good opportunity to see performance from these two
perspectives. As I noted to you before (and I have not seen or done any numbers specifically), the overall
period may show performance at the Mill outside (above) the next"target" limit level (40,000 to 42,000
"lbs/day" of true color),but that BRP believes that they have addressed SGC for now and that the company
is willing to commit to the expected performance level identified in the permit(noted above).
Work on Next Level (beyond the white rot demonstration) Color Reduction
BRP has been working to evaluate the technologies identified by the TRW and noted in the NPDES
Permit. The cost and potential color reduction results (updated by current color"balance" data) of ZD,
2ond stage OD of the pine line and treatment applications of ozone on certain "sewered" wastestreams
(some of which are in tier three of the color reduction areas identified) along with other approaches are
being updated by BRP for the December report.
The process optimization efforts, better "closure" of BFR, along with just the variation of color mass
balance results in the Mill and the development of better cost figures for implementation of the identified
technologies/processes clearly are "affecting" the potential expectations we identified during the last permit
process. It will be necessary for the TRW to look at these data anew and determine if we need to revise
expectations from those developed in our last report. Some of the identified values of color reduction
potential from the TRW will need to be reviewed before we can respond properly to the Dec. 2004 report.
Other Environmental Actions at the Mill
3 of 4 9/18/2003 3:10 PM

file:H/Untitm
You asked about the air quality efforts at the mill in your last message to me. BRP reports that they are
prepared and will meet the MAC I requirements and that planning for compliance with MAC H is
underway. Additionally, the Mill's boilers fall under NC's "Clean Smokestack" requirements and the
company is planning to have in place by the required deadline the means necessary to meet these
requirements. These are not insignificant efforts and as we noted in our past discussions, funds and
resources needed to meet these "other" environmental requirements do affect the Mill's capability to fund
and support additional water quality improvements. There was no indication at this time that the company
would not be able to move forward will all of its environmental responsibilities, but economics are not
great right now and could change quickly.
I hope this summary is helpful Don and I would like to discuss the next steps for the TRW soon and your
view of the current activities at the Mill. Thanks for your attention.
Forrest
Forrest Westall [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality-Water Quality Section
59 Woodfln Place
Asheville,NC 28801
Tel: [phone]
Fax: [phone]
4 of 4 9/18/2003 3:10 FM

18-92 14: 29 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P91/@6
BLUE RIDGE Clfy-
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ArER PRODUCTS INC
175 MAIN STREET
CANTON , NC 28716
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FACSIMILE TRANSMITTAL SHEET
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COMPANY: DATE:
—1)w (a Ill t$ 2Oo7-
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PRONE NUMBER: SENDER'S REFERENCE NUMBfj:^
RE. YOUR REFERENCE NUMB.&:
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© URGENT ❑POI,A VIEW ❑PLEASE COMMENT ❑PLEASE REPLY ❑PUXSE RECYCLE
NOTES/COMMENTS:
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isconf imt&4prop7iot 3',a&mwypn 5�iandexemptfromdisclosure=d"applica*bw.Ifsbemderofthis
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return,by mail,the original message to us. Thank you.

8-02 14: 29 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P02/06
b F•HY
° STATE OF TENNESSEE
DoN SUNDQMST
GOftMOR
December-11,2002
James Palmer,Administrator The Honorable Roland Dykes
U.S. Environmental Protection Agency Mayor, City of Newport
Region IV P.O.Box 370
Atlanta Federal Center Newport,TN 37821
61 Forsyth Street, S.W.
Atlanta, GA 30303-3104 Mr.Bob Williams
Blue Ridge Paper Products,inc.
Bill Ross, Secretary P.O.Box 1429
North Carolina Dept of Environment 41 Main Street
&Natural Resources Canton,NC 28716
16I7 Mail Service Centex
Raleigh,N.C. 27669-1617 David Jenkins
Director of Conservation &
The Honorable 11iff McMahmi, Jr. Public policy
C.`oilnty Commissioner, Cocke County Amend?n Canoe Association
360-Main Street 7.432•AIban'Station'Blvd. -
Newport;TN 37821 Suite B 232'
Springfield,VA, 22150-2321
Will Calloway
Executive Director
Tennessee Environmental Council
One Vantage Way, Suite D-105
Nashville, TN 37228
Re: Settlement Agreement Dispute
Dear Parties:
This will confirm receipt by the State of Tennessee of the dispute claimed by the
American Canoe Association and the Tennessee Environmental Council against the State
of North Carolina and Blue Ridge Paper Products,each of whom is a party to the 1997
Settlement Agreement.
The di'sputeIs subject to resolution according to Parag'r"a!P"seY9 artd 40 of the agreement_
Tennessee her"e'Uy consents to extension of the informal�resplutior'Penod*'•az d;identifles
David McKinii6y and Paul Davis is its representatives in""Ihat'picicess. Tf'is•certiUn' jy our
wish'tliat•the dispute can'be am'i16ably resolved. '
State Capitol,Nashville, Tennessee 3724"001
Telephone No. [phone] r

8-02 14: 29 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P03/06
Tennessee remains fully committed to achieving further color reductions as soon as
possible. We encourage all parties to enter the resolution process in a spirit of
cooperation toward that objective.
Sin ely,
Justi P.'Wilson
Dep to the Governor for policy

8-92 14: 30 BLUE RIDGE PAPER PRODUCTS IDm8286466892 PO4/06-- �� �- � •b,7rni rivir:rr. a►auuiouv, 91ormoriq G IMUL FlranCn 4494 562SZ24 T-M P.001/001 F-890
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
,, - REGION 4
't Y ATLANTA'EDERAL CENTER
J 61 FORSYTN STREET
.ria „oT� ATLANTA,GEOR,GIA 30303-9960
NOV 0 7 2NZ
Ms. Hope Taylor-Guevara,
Clean Waterfor I-onh Carolina
29 '/'--Page Avenue
A;ci1cville,tiC '9801
Dear Ms.Taylor-Guevara:
Thank vou•for vour letter dated October 24,2002, on bahalf of your vrganiz.t ion and
twelve other enviroTmiezita1 groups,to Admire strator Whitman and Regional Administrator
Pallier Concerning[he wastewater discharge permit for Blue Ridge Paper Products in Gantoj,
�t01.01 Carolina_
A response to your lamr is being prepared by staff in the Water-Vatlageracnt Division ru
addx,,ss your conrems. Duo to the complexity of the comems that you have raiscd,.it is our goal
try provide you with a response by the first of December.
We apoloQ►ze for the delay and appreciate your paTienco. If you have questions lt-t Me
iai ujim,please ic=I free to cOntact Nfx_Marshall Hyatt at 4041562-9304.
Sincerely, •
^�D�. DIrCGTOr
Water Manaao meat Division
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12-L73-02 14:42 TO:BLUE RIDGE PAPER PRODUCTS FROM:[phone] Pd1

8-02 14: 30 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P05106
tiA'ttC� •�•�-n
,f UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ci ATII{NTA FeDEAAL CENTER
61 FURSYTH STREET-
Al LA-NTA GE0F1Gi A 303 M950
DEC -9 2002
:Ws.Hope-Taylor-Guevara
C1e:ln Water for i�rarth Carolina
21) Vi Page Avenue
A shev!Ile. -C 28301
Dear-�&S.Taylor Guevara:
Thank you far your October 24, 2002,leller on behalf of your organization and[wc[ve
Other eliviiOnrnerrtal groups,to Christine Todd Whitman.Administrator of the U.S.
1�nvironmental Protection Agency(EPA). and me,conCeming the wastewater discharge errtit
for Blue Ridge 1'aperProducts(B1!Ie l idge)i;1 Canton.N'Orth Carolina. On behalf of
Administrwor W itrnan,i 3rn providing the following response,
A$ t'Our le'Eer Roles,the color provisions of the 13lue Ridge Vational pol3uMhE Discharo'
E1rrinnatinn SySLe!rl(NPMES)per•nit EeiSsued I>y the NoM Carolina Depaxt=nt of
ZTZIA70nmellta,l and natural Resources(NIC DENR)in November, 2001 resulted from an
evctens:ve process which included many stakeholders. The NTC DENR,with EPA''s assistance,
sots,:t review and advice from a teChfti=1 team of EPA pulp and paper experts,-who co:tidttctc<J a
technical evaluation,of the Mill's color reduction efforts. Mr. Norm Lebergott, a Canadian pulp
atld paper expert recommended by sevenI environmental groups,also conducted an independent
cti aIuati+}rr.
The findings from each party were then assessed a:Id synthesized by the Technology
Revi;,w Work¢roup(TRWI,Consisting of representatives From EPA,NC DENR,the•Tr r111efi;r.e
T i�isior. of Wa[er Pollution Control,and the Tennessee Wildlife Resources Agency. The
'S`RW's recoMmendadons were,in turn,provided to the.NC DENR.as the periniaing aper;cy..
These recortTltmendatiotis formed the basis for the draft permit that went to publir notice:ir!
AuL,ust '00I and for which a public hearing was held in September 200[. Eased on cornrrentc
ti ved,the NC DENR made signircam changes to the draft permit, incorporated thorn ill ,a
prupa,,d final permit in October 2MI,and issued the final p,�mnit in that form in Nlovcmh:or
2001_ The Novembe;-2001 permit became effective in December 200I and was riot
administratively appealed.
i1LT!4T1.1��•''3�i=5 ti�'Ci -"---•�....._ -
PAX TRANSMITTAL �-.- -
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ra•c =ac= •
+baN']S�-•y77�:{'.: 3r59:i.7 J7 ..-'.\•E913.$CnVICar]°.�L'.I:vl: y;, _
Ifflomat Aadm=iURQ•h!tpJlwww apagov
RttYcsw+A-rr�7�n1..Prka.�w�a vy.e�r.43 6�aad k#u,A•oyr�n paper f�ypniftusn'0';Po9lea�yr�pcy
12- 12-Q2 I5 :25 TO-BLUE RIDGE PAPER PRODUCTS FROM:404662M92 P91

8-02 14:31 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P96/06
The pemtir as issued reflected srxbstantial public involvement and independent Sercrtiny
tfiro tushout its&veloptiterlt. We believc that the requirements of Eyre Ridge's +'PDI=S vrll3 rcsuit in 5isniftcant improvements in the water ualit of tho Pi ccm river during 1e rntit
the permit, and that the petrttit meets the regi irements of the Clean Water Act, We shire eyo rt caf
expectarion that efforts will continue over Cite term of the permit ro identify feasible methods r to
reduce color loai±ngs belo,v the levels allowed in the permit,and that these can be factored into
ihO Permit as soon as possible,
Your letter requests that the EPA reopen the:�fPDES perrnit for Blue Ridge to modify the
Provisions of rho permit relating to color. Because The NC DENR is the permitting agency in this
ir.V,MCe,any requesTS for reopening Ns Vertu should be directed To there,aT The following
address: 1617 Maii Service;Center, Raiei,,h, north Carolina,27f99-l61!7.
R'c appreciate and share your sincere concern for the quaiiry of the environment itt this
arza of North Carolira and Tennessee,and hope ro Continue to%v¢rK with you and the States of
North Carolina and Tennessee toward this end, For any additional information,glease do not
1::sit;ire to contact Marshalf [jyatr of my staff at(404)562-9304.
Sincerely,
.L Palr7=,Ji.
Regional Adminiwa.or
CC: William Ross,NIC DENR
!Alan W. Klimek,P.E_,NC DENR
Nib Iton Harnilton,Tennessee Dept.of Environment and Conservation,
Paul E. Davis,-1-ertnessee Dept.of Environment and Conservation
David McKinney,Tennessee Wildlife Resources Agency +
A?Tt ?.- t�?. Is : 26 TQ:ELUE RIDGE PAPER PRODUCTS FAOM:404SS28692 A0 ?

14: 29 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P91/06
BLUE RIDGE
PAPER PRODUCTS INC.
175 MAIN STREET
CANTON , N' C 28716
FACSIMILE TRANSMITTAL SHEET
_i
TO: FROM:
err;t Brz LZ,
COMPANY, DATE: 1 2 f t 2 0O
FAX NUMBER; TOTAL NO.OF PAGES INCLUDING,COVER:
q
PHONE NUMBER: SENDER'S REFERENCE NUMBEA,,
RE•: YOUR REFERENCE NUMBER:
0 URG)�IVT ❑FC)R AF-VIF-W ❑PLEASE COMMENT ❑PLEASE REPLY ❑PY.PgSE RECYCLE
NOTES/COMMENTS:
`"Ihem�erialco�ziairaerlintl�iscoamnacrat�aonuimerrda+lrn�yfrn-th�euseofthe�Itmay��a'rs '
is=fidl=ftApr0pW47y,att07ney pnvilegeel,arul wmpt from d closure undercapplkablelaw.If the r&rder of thu
corrrrrurn=onisrzot&owui rertim;ynaaurehmi7ynonfi&4laanyd:;s=mm-ion,diurzi= mordrsplrcr mofdx
m==a:i==isprdAbad fj`yosa haw rx ivdtmxmmuv aaw wmvr pk=no*xsmpndwybys 0oneand
,return,by mail,the original message to us. Thank you."

14:29 SLUE RIDGE PAPER PRODUCTS ID=8286466892 P92/D6
Mi
A[ a-
S ;
STATE OF TENN'ESSEE
ran••
DOH SUNDgMST
GOVZRNOR
December-11, 2002
r
James Palmer,Administrator The Honorable Roland Dykes
U.S. Envirorunental Protection Agency Mayor, City of Newport
Region IV P.O. Box 370
Atlanta Federal Center Newport,TN 37821'
61 Forsyth Street, S.W.
Atlanta, GA .30303-3104 Mr. Bob Williams
Blue Ridge Paper Products, Inc.
Bill Ross, Secretary P.O. Box 1429
North Carolina Dept ofEnviro=ent 41 Main Street
&Natural Resources Canton,NC 28716
1617.Mail Service Centex
Raleigh,N.C. 27669-1617 David Jenkins
Director of Conservation &
The Honorable 1liffMCMahan, Jr. Public Policy
Cowrit'y Commissioner, Cocke County American Canoe Association
360-Main Street 7432';A1ban Station Blvd.
Ne�+,•vport;TN 37821 Suite B-232'
Springfield, 'VET, 22150-2321
Will Calloway
Executive Director
Tennessee Environmental Council
One Vantage Way, Suite D-105
Nashville, TN 37228
Re: Settlement Agreement Dispute
bear Parties:
This will confirm receipt by the State of Tennessee of the dispute claimed by the
American Canoe Association and the Tennessee Environmental Council against the State
of North Carolina and Blue Ridge Paper Products, each of whom is a party to the 1997
Settlement Agreement.
The dispute-d's subject to resolution according to Para, raphs 39'a'rid 40 of the agreement_
Tennessee her"6'by consents to extension of the inforrrial resolution nod`arid:iclentifes
David.McKinrieF"�ind Paul Davis as fts representatives in•tfidt' rroce§s. It is'cerWW' y our
wisb ilidt the dispute cazr'be amicably resolved.
State Capitol, Nashville, Tennessee 37243-0001
Telephone No. [phone] -�

14: 29 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P03/06
Tennessee remains fixlly committed to achieving further color reductions as soon as
possible. We encourage all parties to enter the resolution process in a spirit of
cooperation toward that objective.
Sin ely,
Justi P.Nilson
Dep to the Governor for Policy

I4: 30 BLUE RIDGE PAPER PRODUCT'S ID=8286466892 PO4/06
u- N:•�vwu � vn-crr, akdnaarqs, mailiTorillC d ML FranCh 4494 5829224 T-812 P-001/001 F-880
'S UNITED STATES ENVIRONMENTAL PROTECTIM AGENCY
REC31ON 4
Zia .Y ATLANTA FEDERAL CENTER
t E;1 FDRSY`TH STREET
nfr�c'Mt.TF AT-ANTA,GZORGIA 30303-49$0
NOV 0 7 2aoz
Ms_ Hope Taylor-Guevara
Clean water-for Nonh Carolina
29 '/a Page Avenue
A,,O ville,NC '_'8SO1
hear Ms_ Taylar-Guevara.
Thank vpirfor your Ietter dated October 24,2002, on behalf of your organization and
twelve otherenvironmental groups,to Administrator Whitman and Regional Administrator
Palmer concerning Ella wastewater discharge permit for Blue Ridge Paper Products in CaTILO.1.
Notch Carolina_
A response,to your lalw is being prepared by staff in the Water Managemcnt Division tc,
s�I(ress your com-erns. Due to the complexiIy of the concerns that you leave raiscd,.it is our dual
to pfovide you with a resp+ r_se by the first of December_
We apologize for the deIay and appreciate your paiiencc_ If you have questions ire tite
interim, please:eel free to contact Mx'. Marshall Hyatt at 4041562-93-04.
Sincerely,
y,
j4
mcs D. Gutting,Diremor
water Manac, ent Division
F _
FALX« -rRANSRIIITTAL
From
.11ilABcTcy ([ I I'170nCE
Fes♦ � r �� � Fiu A -......
y._ N• W49-O,_31�-7388 :QB9-747 0"Liv,-MrMCC6hD14ft8TRh'nC&
1nlamek Addras8(VRL)•htW:/AVww,epagov
Recyotetl�ietyrclahta-p pled Y Ari Vapuble 01 Based inks ors Aecygetl Paper(Minimum 301y.PQ*tC0A3Um9r5
TO: SLUE RIDGE PAPER PRODUCTS FROM:[phone] P&1

14: 30 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P06/06
-- --. - —.•.- w.to..... 1 fRL L. 1 ♦ /•
UNMED STATES ENVIR0MM9t4TAL FROTECTION AGENCY
r AEGION 4
A71ANTA FEDERAL rENTGR. 61 5ORsy-rH STREET-
'_ AT LA.^tTA.GEORGIA WW0 -8960
DEC
tNls. Hope Xavlol'-Guevara
Clean water for 1rorth Carolina
29 ',z Ergo Avif nue
Ashevtlie. NC23801
T)rar NISL Taylor-Guevara-
Thank you for your October 34,2002,lener on behalf of your orgllnization and tw,Il ve
orher groups,to Christine Todd Whitman. Administralor of the U.S.
ErMronMental PrOtcctiOn Aadacy(EIIA), and me,conceming the wastewar;:r dischar3o pem,;t
for Blue Rid-c Paper Producrs(Blue Ridge)in Craton, North Carolina. On hehalf of
Administraior W itman,13rr1 providing the fgllOwitZa resports .
As e'Our leper ItoicS.the color provisions of the Blu'o kidg&national Pollataht Discharge
L:inis,7�ti�+tz SySWin(Nl?D7=S)perrnit reissued by the North Carolina DegartMv_nt of
URvir0nmetlral and Natural 'Resourc cs(.NC DEER)in Novi�mbtr, 2001 resulted from an
e%tens:ve process which inciudecd many stakeholders. The ETC DEN'R, with EPA's assistance,
Sous-a t revitw and advice from a technical ?eam of EPA pulp and paper e.cpetYs,who conducted a
t�chnieai ;.valuation of the r till's color reduction efforts. Mr. Nona,Liebergott, a Canadian pulp
! and paper expeFt reconurtended by severltl environmental groups, r .
a�sotronduc.cd an i
evaluationndeperceient
The rindin s front each party were lhc;n assessed and sy-91hesized by the Technology
Key'= WOrknroup(TRW),consistin¢of representatives fronn EPA,INC DEN'k, the Tertnes,re
Doi visinr. of Water Pollution Control,and the Tenrressee Wildlife Rt :SOurces Agency_ The-
TRW's re-co mendations were, in turn,proV'tt>wd t0 tote:;SIC DENR.as the DZrmittin�2Yo,cy..
Thtse recommctidatiou formed the-basis f01•the draft permit that weir to pub;jr notice ire
August '(l01 and for which a public heating tivas herd ir, september 2001. Based on comment.r,
rix:ct ve d, the INC D,E R.glade signir t chars es to the draft permit, incorporated therm in a
Pr'-)pn:.--d final permit in October 2001,and issued the final Ixrxnit in that form in N0VCrnh,-F
2001- The ;tiovernbx;r 2001 permit became effective in Decer ber 2WI and%vas not
admi inistratively appealed-
:r3 VPMA:=^fir.=5 J._C; --
FAX TRANSMITTAL
rkiL'rwJa�ci .. PnSr.�: s•.
trwmac Amass iURU*hV;jjW w.apa.sov
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1 2- .1 2-02 15 :25 TO 'BLUE RIDGE PAPER PRODUCTS FP,0 i :4045625692. PO t

14: 31 )SLUE RIDGE PAPER PRODUCTS ID=8286466892 P06/06
2
The per it as i8sued reflected svrbslantial Public involvemc;nt and indegendcnt scr�rtinv
tfrr�>u hK�tr its d(-'vCJ0P11W11t, We believe that the requirerra�ztts of$Iue i2icl�e's'w,'RDES
will ;tis«lt in significant improvements in the water gttality of tlta Pigeon River durino,th�te;,m cif
the permit,and that the peal t trteets the requirem6ncs of the Clean Water Act, We Sharc your
expectalion that efforts wvill continue over the term of the per nit to identify feasibWe methods to
reduce color loadings WOW the levels allowed in the Pc=it,and that these can be factored into
111C permit ac soon as possible.
Your fetter regaests that the EPA reopen the NfPDES permit for Blue Ridge to modify the
prrxvisions of the perrilit relating to color. Because the NC DENR is the permitting agency in this
1r.Cr:rnr_e,any requests for reoperrirr r13t8 DG't"[I]it Should be directed to them,g the f6llowin3
cd.�r,ss: 11.617 Maii Service Center, Raieigh, north Caroiina.27699-1617.
NW aPpreciate and share your sincere co-ncerrn for the quality of the environment tit tlti,
ar-la of North Carolina and,Tennessee,and hope ro continue to wvorK with you and the States of
:worth Carolina and Tennessee tolvard this end. For any additiona? information, p#ease do yiot
l:•sitaze to contact Marshal i Hyatt of'tny staff at(404)562-9304.
Sincerely,
Palmer,Jz_
Re_giional Administrator
cc: ��rr[Irar ROSS. NC DEN,R
Alan W. Klimek,RE_,XC DEl
Milton Hamilton, Tennessee Dept.of Environment and Conservati00
Dayis, Tennessee Dept.of Environment and Conservation
David I'VIcKinney,Tennessee Wildlife RtsOurce�g Agency
] 5 ' 26 TO:SLUE RIDGE PAPER PRODUCTS FROM:4045628692 PEA 2

4 l y
BLUE RIDGE
PAPER PRODUCTS INC.
March 25, 2002
North Carolina Department of Environment as �
and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Attn: Central Files
Re: Best Management Practices 2001 Annual Report
Please find the attached data summary of Best Management Practices (BMP) daily
monitoring for BIue Ridge Paper Product's Inc., Canton Mill. This submission is
required by Special Condition A(6.)Best Management Practices, Section E4 and Section
F1, of our NPDES Permit No. NC0000272.
There were three consecutive days of action level exceedances in December 2001. The
Canton Mill's BMP Plan specifies that investigative and corrective action will occur
when either the lower or upper action level is exceeded for two consecutive days. In this
instance, the lower action level was exceeded on December 8`h, and the upper action
levels were exceeded on December 9`h and 101h. However, the elevated color was
determined to be from the bleach plant and turbidity interferences in the color test
method,both of which are non-BMP sources. The non-turbidity causes were corrected.
Please call Derric Brown at(828) 646-2318 or myself at(828) 646-6749 if you have any
questions or concerns regarding this information.
Sincerely,
Melanie Samuels
Environmental Engineer
Xc: Derric Brown
Keith Haynes
Michael Myers
arrest Westa
Bob Williams
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716
Phone: [phone] • Pax: 828-646-6892
Raising Your Expectations

Blue Ridge Paper Products Inc.
NPDES Permit #NC0000272
Date Primary. Influent Color(Ibslday)
1-Dec-01 52558
2-Dec-01 42141
3-Dec-01 46873
4-Dec-01 45371
5-Dec-01 55781
6-Dec-01 27550
7-Dec-01 41242
8-Dec-01 72996*
9-Dec-01 83499*
10-Dec-01 78673*
11-Dec-01 35898
12-Dec-01 30963
13-Dec-01 27000
14-Dec-01 35962
15-Dec-01 50674
16-Dec-01 56116
17-Dec-01 43973
18-Dec-01 67844
19-Dec-01 47219
20-Dec-01 46079
21-Dec-01 39797
22-Dec-01 35293
23-Dec-01 65498
24-Dec-01 55737
25-Dec-01 35282
26-Dec-01 54913
27-Dec-01 53922
28-Dec-01 60429
29-Dec-01 57533
30-Dec-01 56660
31-Dec-01 73391
*Elevated color was determined to be from the bleach plant and turbidity interferences in
the color test method, both of which are non-BMP sources.
The non-turbidity causes were addressed and corrected.
Annual Best Management Plan Report
March 2002

BLUE RIDGE d _
PAPER PRODUCTS INC. 4 2002
March 1, 2002
lr'JAi1 R UAL14 i Y_CI10'~
ASFiA LLC RF�lOiitL uFF C4 �
Mr. Paul Muller
North Carolina Department of Environment and Natural Resources
Division of Air Quality
59 Woodfin Avenue
Asheville, NC 28801
RE: Changes to the Metals Removal Process (MRP) at Blue Ridge Paper Products Inc.,
Facility ID No. 4400159.
Dear Paul:
I am writing you to inform you of changes that Blue Ridge Paper Products Inc. is planning to
make in the Metals Removal Process (MRP), which is part of the Bleached.Filtrate Recycle
(BFR) process at the Canton Mill. The BFR process was permitted by the Western North
Carolina Regional Air Pollution Control Agency(WNCRAPCA) in May 2000, and subsequently
included in the operating permit(Permit No. 08961R01) for the facility issued by the Division of
Air Quality (DAQ) in September 2001.
As the name implies, the BFR process recycles filtrates within the Pine Bleach Plant in order to
remove color from the wastewater discharge. The MRP portion of the BFR process removes
scale-forming dissolved minerals, such as calcium and magnesium, from the filtrates to prevent
build-up in the recycle loop of the production process. The BFR process is required to meet the
stringent requirements of the NPDES wastewater permit for the Canton Mill. In November
2001, a new NPDES permit,Permit No.NC0000272, became effective for the Canton Mill. In
condition A(8.)5., this new permit requires Blue Ridge to implement specific actions, including
"MRP reliability improvement"to increase the effectiveness of the BFR process.
The MRP system was originally installed as a full-scale demonstration process designed to
operate at a sustainable bleach plant recycle rate of 1,000 gallons per minute (gpm) and a short-
term peak rate of 1400 gpm. However, unlike during the initial demonstration period, the process
has not been able to reliably maintain that rate for long periods over the last few years. In 2001,
the MRP process was only able to run an annual average of 499 gpm, less than half the design
rate. This diminished capability is due to the longer-than-expected and more-frequent-than-
expected backwash and regeneration requirements of the media filters and the softener units.
The original construction also used several materials of construction that cannot withstand the
harsh conditions experienced in this process and have resulted in frequent outages to perform
maintenance and parts replacements.
The NW reliability improvement project that is planned includes:
• Installing one new media filter, identical to the existing three units;
175 Main Street • P.O. Box 4000
Canton, North Carolina 28716
Phone: [phone] • Fax: [phone]
Raising Your Expectations

Mr.Paul Muller
March 1,2002
Page 2 of 2
• Installing one new softener unit, identical to the existing two units;
• Replacing the existing CPVC piping on the three existing media filters with
stainless steel piping;
• Upgrading the existing MRP feed pump, Media Filter Pump, and Media Filter
Backwash Pump; and
• Enlarging the MRP building to house this new equipment.
These changes will allow the MRP system to operate at the original design capacity of 1,000
gpm. This will not increase capacity above the original design of the MRP system, nor will it
result in any increased capacity within the bleach plant. The new equipment will allow the
Canton Mill to run the BFR process at an increased closure rate (i.e., increased filtrate recycle
rate) with greater sustained reliability to meet the requirements of the:new NPDES permit.
The proposed MRP reliability improvement project will not increase air emissions above the
levels associated with the permitted maximum short-term MRP throughput rate of 1,400 gpm.
Potential emissions from the process, as documented in the April 24, 2000 BFR permit
application, are based on maximum pulp mill and bleach plant production rates and source test
derived emission factors. Source testing in support of the BFR permit application was conducted
with the process running at near design capacity. As such, the reliability improvement project,
designed to restore BFR closure to its original design rate,will not contravene current air permit
conditions or the North Carolina toxic air pollutant (TAP) compliance demonstration conducted
as part of the original BFR permit application. Based on these project facts and our analysis of
regulatory requirements, we have concluded that these changes do not require a permit to
construct pursuant to NCAC 2Q. 0300.
Current plans call for beginning the building structure changes in April,with changes to the
process beginning during the No. 2 Pulp Mill annual outage in October of this year. Process
changes will be completed by mid-2003. In order to meet this schedule, process equipment
components will be ordered this spring.
Please let us know if you have any comments on our analysis. If you have any questions or
concerns regarding this project, or if you need any additional information, please fell free to
contact me.
Sincerely,
Daryl J. Whitt, P.E.
Senior Air Quality Engineer
Blue Ridge Paper Products Inc.
cc: Forrest Westall, Asheville Regional Office/Water Quality Section
Derric Brown, Blue Ridge

T E N N E S S E E WI L D L I FE RESOURCES
ELLINGTON AGRICULTURAL CENTER
P. o. BOX 40747 MAR �- 8 2002 't�
NASHVILLE,TENNESSEE 37204
y"
WATER Q QQ UA.IiYSE
EINt�11ru']C ERGAL OASHEIILL
March y al
5, 2002
Ms. Beverly H. Banister
Director, Water Management
U.S. Environmental Protection Agency
Region IV
Atlanta Federal Center
61 Forsythe Street, SW
Atlanta, GA 30303-8909
re: 1998 Pigeon River Settlement Agreement, Part V `
Dear Ms. Banister:
The Tennessee Wildlife Resources Agency appreciates the EPA Region IV effort to
fulfill the requirements of Part V (attached) of the 1988 Pigeon River Settlement
Agreement. When completed, the comprehensive database of Pigeon River
information, as prepared by TVA, will allow the review panel of scientific experts, as
convened by EPA, to complete the task of making recommendations regarding
ecological risk and human health risk from contaminants in the Pigeon. River system.
There was a general agreement among the parties to defer Part V efforts until
completion of the most recent NPDES permit process for the Blue Ridge Paper
Products Mill in Canton, North Carolina. Now that the permit is issued and finalized, it
is our expectation that EPA will refocus on Part V. Remaining task(s) include
completion of the comprehensive database, appointment of the independent review
panel of science experts, distribution of the comprehensive database to the review
panel, establishment of a schedule for the review panel, completion of panel's final
report and recommendation. Please find attached 1998 correspondence from TWRA
to EPA regarding recommendations for selection of the review panel.
It is absolutely essential that EPA establish and commit to a Part V schedule that
provides for the timely completion of Part V; toward that end, we recommend the
following schedule:
1. April 15, 2002: Identify missing items in the comprehensive database.
2. April 30, 2002: Finalize the expert panel selection process.
3. May 30, 2002: Distribute completed comprehensive database.
The State of Tennessee

4. June 30, 2002: Finalize expert panel and establish an interim schedule.
5. January 30, 2003: Distribute the draft final report from the expert panel.
6. March 30, 2003: Publish the Final Report and Recommendations from the
expert panel.
The narrative title of Part V is a concise statement of the intent of the Settlement
Agreement. Tennessee looks forward to working with the parties to Part V of the 1988
Settlement Agreement to complete this commitment. If you have questions, please
contact me at 615/781-6643.
Sin crel�
—A brey D. McKinney, Chief
Efimental Services Division
ADM/bjs
Enclosure
cc: Gary Myers
Justin Wilson
Paul Davis
Forrest Westall
Barry Turner
Telephon e:615/781-6643
Fax:615:781-6667
[e-mail]

SETTLEMENT AGREEMENT REGARDING 1996 WATER QUALITY
COLOR VARIANCE AND 1996 NPDES PERMIT ISSUED
TO CHAMPION INTERNATIONAL CORPORATION
V. ECOLOGICAL ASSESSMENT OF THE PIGEON RIVER
SYSTEM AND THE WATERVILLE RESERVOIR
33. Over the years, a number of studies have been conducted by various
entities on the health of the aquatic biological community in the Pigeon River and, in
particular, analysis of fish flesh contamination. However, EPA believes that a more
current evaluation of the level of contaminants remaining in the system and the overall
health of the river and of the Waterville Reservoir should be undertaken. EPA will lead,
in cooperation with North Carolina and Tennessee, an independent evaluation of
current information on the Pigeon River. The evaluation will include convening a group
of.scientists to evaluate existing data, to identify additional data needed, and, if
necessary, to conduct an ecological assessment. EPA agrees to take the lead in
convening the scientific panel. The information gathered from such an assessment
Would be used to determine whether any significant ecological or health risks exist, and,
if so, what, if any, steps could and should be taken to address those risks.

.cxicr�•_ar"_4
STATE OF TENNESSEE
Dorn Su guisT
GovERNOR
June 2, 1998
Mr. Gary Guzy
Counselor to Administrator
Environmental Protection Agency
401 M. Street, SW
West Tower, Room 1204
Washington, DC 20460
Dear Gary:
I am enclosing a letter that David McKinney of our Wildlife agency is circulating.
I believe his proposal Gives real credibility to our settlement agreement.
1,
Very best wishes,
Sincerely
Justin P. Wilson
Deputy to the Governor for Policy
JP W:bS
3tVi e CapUol. Nashville, Tennessee 37243-0001
Telephone ilo. (615) :4I-2001

TENNESSEE WILDLIFE RESOURCES AGENCY
ui�6l]L ��ll5 mm an ELLINGTON AGRICULTURAL.CENTER
P.O. SOX 40747
NASHVILLE, TENNESSEE 37204
May 28, 1 998
Mr. Robert F. McGhee
Director, Water Management
U.S. Environmental Protection Agency
Region IV
Atlanta Federal Center
61 Forsythe Street, SW
Atlanta, GA 30303-3909
re: Pigeon River Settlement Items, Data Management System
and River Assessment
Dear Mike:
The following recommendations are related to our recent conference call concerning
Part V of the Pigeon River Settlement Agreement.
With regard to existing information, pulling together a usable, useful data base for the
Pigeon River will be a very difficult task; one ideally suited for a work group whose
main expertise is data management. Ideally, this final product will be on a Geographic
Information System (GIS), capable of assembling selected data from the whole, and
capable of accommodating incoming data annually. This will be a difficult assignment
requiring specialized expertise and continuity of effort. While staff from our respective
agencies will assist in gathering all available studies, documents, testimony, texts, etc.,
the responsibility for constructing, maintaining, and servicing a Pigeon River data base
should be invested in experts who can provide a base product and updated versions for
the foreseeable future. likewise, we believe it is very important that the product of this
effort be useabie and accessible for both resource management agencies and the
The State of Tennessee
l cGUAL GPPORT?,;NE,y EMPLOYER

interested public. Finally, we believe the quality of the review by the panel of experts
will, in part, depend on the quality of the data base made available for their
consideration.
With regard to the independent review of Pigeon River data by a panel of experts, we
agree that EPA's Office of Science and Technology (OST) is an appropriate place to
begin the Part V process. It is, however, our expectation that the U.S. Environmental
Protection Agency (EPA)will bring to this task the best science available. Toward that
end, in addition to CST, we suggest EPA contact the Society of Environmental
Toxicology and Chemistry (SE.TAC) for candidate review panel members from among
their associate members. This review panel should include expertise in human health
risk assessment, ecological risk assessment, aquatic and riparian ecology, and the
environmental toxicology and chemistry of paper mill effluents. This approach would
assist in fulfilling the public's expectation that this will be a significant effort conducted
by qualified, independent experts.
Tennessee looks forward to a productive effort on these two issues and appreciates the
opportunity to make these recommendations.
S
incer
ely'
� 6Y .
Aubr McKinney, Chief
Environmental Services Division
ADMlbjs
CIC: Mr. Justin Wilson
Mr. Paul Davis
Mr. Barry Turner
Mr. Forrest Westall

Date sent: Mon, 12 Jul 1999 15:20:34 -0400
From: "Greeson, Mick" <[e-mail]>
Subject: FW: Walter's Lake Turnover
To: ""[e-mail]"'
<forrest [e-mail]>
Mick Greeson
Water&Natural Resources
Environmental Services
Caronet: 772-3550
Mail: HEEC
Caronet Fax: [phone]
-----Original Message-----
From: Crutchfield, John
Sent: Monday, July 05, 1999 10:46 AM
To: Bryson, W. T. (Buzz); Greeson, Mick; Wheeler, Cam
Subject: FW: Walter's Lake Turnover
Mr. McCarthy's followup request after telephone conversation with me during
the week of June 28th.
John Crutchfield
Environmental Services Section
Biological Assessment Unit
3932 New Hill-Holleman Road, Box 327
New Hill, NC 27562-0327
CARONET 772-3557, BELL 919-362-3557
FAX [phone]
-----Original Message-----
From: John F. McCarthy [mailto:[e-mail]]
Sent: Friday, July 02, 1999 4:28 PM
To:[e-mail]
Cc:[e-mail]
Subject: Walter's Lake Turnover
Forrest Westall -- 1 -- Mon, 12 Jul 1999 17:35:06

Hi Jim --
I had a nice talk with John Crutchfield about the mixing of deep and
shallow water in Walter's Lake. If you remember, you helped me find John
after our raft trip on the Pigeon River.
In the course of discussions, I asked John if it would be possible to get
access to the Lake to make some measurements. He suggested that I contact
you.
We are interested in the dynamics of hydrophobic contaminants (particularly
dioxins and dibenzofurans) in the whole river system. We've been working on
an approach that allows us to identify sources and sinks for contaminants
and wanted to use the Walter's Lake as one of our test cases. We've done
this for PCBs in the watershed draining the Dept of Energy facilities in
Oak Midge. We were able to determine how much PCB exits each DOE facility
and compare it to the flux in the Clinch River(which receives all the
drainage from DOE). One of the DOE plants (Y-12) was the major contributor
to DOE releases, but all the DOE releases taken together were only a small
fraction of the PCBs in the Clinch River upstream of DOE. We've also done
this on a small scale within the Y-12 Plant and found that in-place
contaminants in the sediment are the major source of their releases, rather
than current discharges. Walters Lake would be intermediate between these
regional and local spatial scales.
Walter's Lake would also be an interesting case because the Reservoir could
be either a source or a sink for dioxins, and whether it is one or the
other may change seasonally. We hypothesize that when a thermocline
develops in the summer(hot upper water isolated from cold deep water), the
contaminated sediments are isolated from the water exiting the dam. In the
winter, as the upper water cools and mixes with throughout the water
column, contaminants may be released.
We wanted to get access to the Lake to test this. Operationally, we would
want to place passive dioxin samplers in 4 spots in the lake: at the stream
entering Walter's Lake, at two locations within the lake (one deep site and
one shallow site), and near where the water exits into the tunnel. The
samplers are encased in a perforated metal box that is about 16"x6"x6", and
we would either anchor them to the bottom or suspend them with small
Forrest Westall -- 2 -- Mon, 12 Jul 1999 17:35:06

floats. We would deploy the samplers 2-3 times a year. The samplers remain
in the water for a 28-day period. So we would make 4-6 trips to deploy and
retrieve the samplers. During those visits, we would also measure the depth
profile the temperature of the water.
We have boats and everything we need(and are Coast Guard certified!). We
just need access.
I should point out that the dioxin analyses will be conducted by Jim
McKinney's folks in case there is any sensitivity. Dave thought the data
might be useful for EPA's assessment of the river.
The study should also complement and extend the work John and his
colleagues are already doing. For example, it would also be very +
interesting to compare our data with CP&L's data on dioxins in fish. Our
samplers only measure the dissolved dioxins, not those bound to particles.
Thus, we measure only the dioxin that can enter the fish through the gills.
Comparison of the fish data and my data might indicate the'contribution of 1 ✓
the food chain to dioxin uptake in the fish.
Would it be possible to get access to Walter's Lake for this work? If you
need more information, or would prefer a more formal proposal, please let
me know.
Thanks for your help. Have a nice 4th. i
John
John F. McCarth <jj ornl. ov> l
�r�'. JJJ G� g
Environmental Sciences Division W
Oak Rid e National Laborato
P.O. Box 2008, Bethel Valley Road r G
Oak Ridge TN 37831-6036
g
PHONE [phone] �•
FAX [phone]
eAl J
Forrest Westall -- 3 -- Mon, 12 Jul 1999 17:35:06

• ' f
Making i ur mark for you.
SLUE RIDGE PAPER PRODUCTS INC.
November 19,1999 �s
Nod
Mr. Forrest Westall yyq Fp 0
North Carolina Department 9 asy�yjQG�(, 9
EnvironmentalW and
Natural Resources
Division
59 Woodfin Place
eF
Asheville,NC 28801
Re: December 1,1999 Report
Hardwood Fiberline Color Management
Eo Recycle Evaluation and Potential for Full BFRTm Implementation on the Hardwood Line
Dear Mr. Westall:
Please find attached the referenced report. With the submission of this report this completes
implementation of the technologies collectively referred to in the permit as the "Near Term
Package".As you know the Canton Mill is no longer part of Champion International Corporation. As of
May 14, 1999 the mill became privately owned and operates under Blue Ridge Paper Products
Inc. Blue Ridge is an employee owned enterprise. The company is comprised of
approximately 2200 employees with 70% of these employees residing in Haywood County.
Blue Ridge produces uncoated free-sheet paper for printing and writing applications and
paperboard for liquid packaging. The Canton Mill is the primary asset of the new company.
If you have any questions regarding this report please contact me at(828) 646-2033.
Sincerely, z L
�bofV,Wx&w1w
Robert V. Williams
Director,Environmental,Health and Safety Affairs
xc: Mr. Don Anderson
U.S. Environmental Protection Agency
Mail Code 4303
Room 915A,East Tower
401 M Street,SW
Washington,D.C. 20460
175 Main Street • P.O. Box 4000 • Canton, North Carolina 28716 828-646-2000

N. C. DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
' DIVISION OF WATER QUALITY
S WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
59 WOODFIN PLACE
QUnM� '# ASHEVILLE, NORTH CAROLINA 28801
PHONE : [phone] FAX: [phone]
TO:
11 (1�
FAX # :
FROM:
DATE:
# OF PAGES INCLUDING THIS COVER: 12
MESSAGE: If questions, please call 828/251--6208 .

N. C . DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
DIVISION OF WATER QUALITY
= WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
4rhIL 12 076r 59 WOODFIN PLACE
* CQUAM ASHEVILLE, NORTH CAROLINA 28801
PHONE : [phone] FAX: [phone]
t-
TO: OYU
FAX #:
FROM:
DATE:
# OF PAGES INCLUDING THIS COVER:
MESSAGE: if questions, please call 828/251--6208 .

Blue Ridge Paper,NPDES Public Hearing lnformaion
Subject: Blue Ridge Paper, NPDES Public Hearing Informaion
Date: Tue, 09 Oct 2001 17:53:32 -0400
From: Forrest Westall <[e-mail]>
Organization: NC DENR- Asheville Regional Office
To: Larry Blazer<[e-mail]>, Bradley Davis <[e-mail]>,
Diane Keys <[e-mail]>, Roland Dykes <[e-mail]>,
Alton Higgins <[e-mail]>,
Jay Hinson<[e-mail]>,
Jack Horton<[e-mail]>,
Jonathan Key<[e-mail]>, Dave Popiel <[e-mail]>,
Pat Smathers <smathlaw@b ell south.net>, Ray Snader<[e-mail]>,
Bill Upton<[e-mail]>, Gay Webb <gwebb 199 [e-mail]>,
Dean Williams <[e-mail]>, Patsy Williams <[e-mail]>,
Tim Dockery<[e-mail]>
CC: Bob Williams <[e-mail]>,
Paul Estill Davis <[e-mail]>, [e-mail]
As part of NC's effort to communicate with the groups
established by the Permit Agreement, the Watershed Advisory
Committee (WAC) and the Community Advisory Committee (CAC) ,
I have attached the NPDES/Variance Public Hearing documents
that resulted from the September 6, 2001 Hearing. The two
documents attached to this e-mail are the Hearing officer's
Report and the Hearing Record Report (in Word 97 format) .
The recommendations listed in both are the same
recommendations (those of the Hearing Officer, Ms. Marion
Deerhake) . Several of you attended the Public Hearing, so I
thought you would be interested in this information. As you
will note, several recommendations for improving the Canton
Mill Permit were made and we have redrafted the permit to
reflect the attached reports. The NC- Environmental
Management Commission NPDES Committee will take up the Blue
Ridge Permit issue at a meeting tomorrow in Raleigh_ The
information provided in these attached summary reports will
be the basis of reissuing the Blue Ridge Paper NPDES Permit
for the Canton Mill and for the color Variance. Each of the
parties to the 1996 Permit Agreement will receive a copy of
the decision made by the NPDES Committee. The hearing
record reports (earlier drafts) and the final draft color
requirement have been presented to the State of Tennessee
for review in the last few days and I think that Mr. David
Harbin has contacted some of the the Cocke County and
Newport representatives about this review.
As the Hearing Officer has recommended and the final permit
will reflect, Blue Ridge, NC and Tennessee will continue to
maintain communication on the Mill's efforts to improve the
Pigeon River with the interest groups developed during this
last permit cycle. We appreciate the efforts that all of
you have made to serve on these groups and to provide
thoughtful comments on this process and the efforts being
made to improve the water quality of the Pigeon. Thank you
for your participation.
I secured all the e-mail contact information I could for the
membership of the CAC and the WAC. For those that did not
specify an e-mail address, I have forwarded your copy by
fax. If I didn't have either, I attempted to contact the
members to let them know that this information was
available.
1 of 2 10/9/2001 5:57 PM

Blue Ridge Paper,NPDES Public Hearing Informaion
Forrest Westall
Forrest Westall - [e-mail]
North Carolina Dept. of Environment and Natural Resources
Asheville Regional Office
Division of Water Quality - Water Quality Section
59 Woodfin Place
Asheville, NC 28801
Tel: [phone]
Fax: [phone]
Name: BRP Hearing Officer Report, 2001.doc
;BRP Hearing Officer Report. 2001.doc Type: Winword File (application/rnsword)
-- — Encoding: base64
Download Status: Not downloaded with message
Name: BRP Hearing Record Report, 2001.doc
'= BRP Hearin Record Re ort, 2001.doc Type: Winword File (application/msword)
=' g- - p Encoding: base64
Download Status:Not downloaded with message
Forrest Westall cForrest.Westall c(.,ncmail.net>
NC DENR-Asheville Regional Office
Division of Water Quality-Water Quality Section
2 of 2 10/9/2001 5:57 PM

Ja�Ar
10 Sr4,,,S
r
UNITED STATES ENVIRONMENTAI. PROTECTION AGENCY
� -� REGION 4
cLU
ATLANTA FEDERAL CENTER61 ,
RSYTH STREET
yf4(PROISC'to ATLANTAOGEORG A 30303-8960
I'DEC
Mr. Will Callaway, Executive Director ! JAN ` 9 2UU3 i
Tennessee Environmental Council
1700 Hayes Street, Suite 101
Nashville,TN 37203
Mr. David Jenkins, Director
Conservation and Public Policy
American Canoe Association,Inc.
7432 Alban Station Boulevard;Suite B-226
Springfield, VA 22150-2311
SUBJ: Response to November 19, 2002, Correspondence
Dear Mr. Callaway and Mr. Jenkins:
The Environmental Protection Agency (EPA) has received your November 19, 2002,
correspondence referenced above; in which you invoice informal dispute'resolution pursuant to '
the provisions of the 1997 Settlement Agreement (Agreement).•
The Agreement was entered into to resolve then-outstanding concerns over the 1996 color
variance and the 1996 National Pollutant Discharge Elimination System (NPDES) permit issued
to Champion International (now Blue Ridge Paper) by the North Carolina Department of
Environment and Natural Resources (NCDENR). It included requirements and commitments for
the development of the next NPDES permit to be issued to the mill. That permit was ultimately
issued in November 2001 and was not administratively appealed.
EPA must respectfully disagree with your assertion that the concerns now raised by you
with regard to the 2001 NPDES permit issued to Blue Ridge Paper can be addressed in the
context of a dispute under the Agreement. Consequently, the Agency cannot agree to your
request to "help mediate this informal phase of dispute resolution."
EPA recognizes and shares the longstanding commitment of all parties toward improving
the water quality of the Pigeon River and believes that continued cooperation among all parties is
the best way to further this common goal. We would, therefore, be happy to meet with you and
other interested parties to,explore more fully the issues and'concerns expressed in your
November 19, 2002, correspondence and how they might be addressed through the bontext of the
provisions of the 2001 NPDES permit.
Intemet Address(URL)• http://www.apa.gov
Recycled/Recyclable•Pdnted with Vegetable Oil Based Inks on Recycled Paper(Minimum 30%Postconsumer)

2
Please contact Mr. Scott Gordon, Chief,Permits, Grants, and Technical Assistance
Branch, at(404) 562-9741 to arrange a meeting or if you have additional questions.
Sincerely,
J . a±t
James D. Giattina, Director
Water Management Division
cc: William G. Ross, Jr., Secretary,NCDENR
Justin Wilson, Deputy to the Governor for Policy, State of Tennessee
Honorable Roland Dykes, Mayor of Newport, TN
Honorable Iliff McMahan, Cocke County Executive
Bob Williams, Blue Ridge Paper Products Inc.

Ja�3ea sr,r�s UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
r� .X REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET •
Syr}(PROS ATLANTA, GEORGIA 30303-8 0
OFFICF ";,y
OEC Q 6 2003 i-----
Mr. Will Callaway, Executive Director i J
Tennessee Environmental Council t- --- _w
1700 Hayes Street, Suite 101iv4'
Nashville,TN 37203S
Mr. David Jenkins, Director
Conservation and Public Policy
American Canoe Association, Inc.
7432 Alban Station Boulevard, Suite B-226
Springfield, VA 22150-2311
SUBJ: Response to November 19, 2002, Correspondence
Dear Mr. Callaway and Mr. Jenkins:
The Environmental Protection Agency (EPA) has received your November 19, 2002,
correspondence referenced above, in which you invoke informal dispute resolution pursuant to
the provisions of the 1997 Settlement Agreement(Agreement).
The Agreement was entered into to resolve then-outstanding concerns over the 1996 color
variance and the 1996 National Pollutant Discharge Elimination System (NPDES) permit issued
to Champion International (now Blue Ridge Paper) by the North Carolina Department of
Environment and Natural Resources (NCDENR). It included requirements and commitments for
the development of the next NPDES permit to be issued to the mill. That permit was ultimately
issued in November 2001 and was not administratively appealed.
EPA must respectfully disagree with your assertion that the concerns now raised by you
with regard to the 2001 NPDES permit issued to Blue Ridge Paper can be addressed in the
context of a dispute under the Agreement. Consequently, the Agency cannot agree to your
request to "help mediate this informal phase of dispute resolution."
EPA recognizes and shares the longstanding commitment of all parties toward improving
the water quality of the Pigeon River and believes that continued cooperation among all parties.is
the best way to further this common goal. We would, therefore, be happy to meet with you and
other interested parties to explore more fully the issues and concerns expressed in your
November 19, 2002, correspondence and how they might be addressed through the context of the
provisions of the 2001 NPDES permit.
Intemet Address(URL)• http:tlwww.epa.gov
Recycled/Recyclable•Printed with vegeiabte o1 Based Inks on Recycled Paper(Minimum 30%Postconsumer)

2
Please contact Mr. Scott Gordon, Chief, Permits, Grants, and Technical Assistance
Branch, at [phone] to arrange a meeting or if you have additional questions.
Sincerely,
J . �� a, -
James D. Giattina,Director
Water Management Division
cc: William G. Ross, Jr., Secretary,NCDENR/
Justin Wilson, Deputy to the Governor for Policy, State of Tennessee
Honorable Roland Dykes,Mayor of Newport,TN
Honorable Iliff McMahan, Cocke County Executive
Bob Williams, Blue Ridge Paper Products Inc.

P