NC0000272_Historic_2005_2007_20210125

Re:TDEC's comments on proposed edits to the TRW Memo
Subject: Re: TDEC's comments on proposed edits to the TRW Memo
From: [e-mail]
Date: Thu, 7 Feb 2008 15:21:44-0500
To: "Dave McKinney" <[e-mail]>, "Paul.Estill Davis"
<[e-mail]>, "[e-mail]" <[e-mail]>,
[e-mail], [e-mail], [e-mail]
All -
That is exactly the time I was going to propose - starting at 2:00 pm; I
trust we will not take more than 90 minutes to complete our business.
Here are the teleconf. specifics: call in #: 1 (866) 299-3188; conf.
code: 2025661021#
BTW, I trust all of you received the comments from Region 4. If not,
pls let me know.
I look forward to our discussion,
Don
"Dave McKinney"
<Dave.McKinney@s
tate.tn.us> To
DonaldF Anderson/DC/USEPA/US@EPA,
02/07/2008 02:55 "Paul.Estill Davis"
PM <[e-mail]>
cc
Marshall Hyatt/R4/USEPA/US@EPA,
Karrie-Jo Shell/R4/USEPA/US@EPA,
<[e-mail]>,
"[e-mail]"
<[e-mail]>
Subject
Re: TDEC's comments on proposed
edits to the TRW Memo
Don Paul and I' will be available Friday afternoon. Would 2:00 PM
eastern ( 1:30 PM central) work for everyone ? If not, please give us
an alternative time . Thank You.
1 oft 2/8/2008 1:34 PM

onse to NC's comments on draft TRW memo
Subject: Reg 4 response to NC's comments on draft TRW memo
From: [e-mail]
Date: Wed, 6 Feb 2008 15:20:09 -0500
To: [e-mail]
CC: [e-mail],[e-mail],[e-mail], Sergei
Chernikov <[e-mail]>, [e-mail]
sorry for the delay in getting these to you . . . .
Region 4 has concerns with some of NC' s comments and suggested changes.
If not mentioned specifically below, Region 4 agrees with NC's proposed
changes.
Last sentence on pg. 2: changing "..makes additional improvement at -- 44t
this time and in the future appropriate and possible" to "..makes
additional improvement in the future appropriate". / su
EPA disagrees with the proposed deletion. This implies that no U
reduction may occur during the upcoming permit, which we view as highly
unlikely.
e
- Why has the NC Environmental Management Commission' s NPDES
Sub-Committee been deleted as an addressee? The 1997 Settlement has ,e�or{..G7
several provisions where the TRW provides recommendations or information
directly to the NPDES Sub-Committee. Also, the previous 2001 TRW letter
was addressed to the NPDES Sub-Committee.
- pg. 4 - addition of the phrase "technically, economically and - lay ; � 1 ( y
operationally feasible" in several places ._.r -cc0.
Region 4 does not agree with the use of this phrase for several reasons. ))
First, the previous 2001 TRW letter stated "As the purpose of the TRW is ' 7
to provide a review of the possible technology options available to the a"
Mill to further reduce the color discharge to the Pigeon River. . ."
Region 4 believes this is still the purpose of the TRW - to evaluate '! a
possibleoptions. Assuming that NC and TN agree that that it is still
our purpose, exploring possibleoptions 'already implies that some options
may not be implemented for a variety of reasons.
Second, use of this phrase is redundant and adds a level of uncertainty
about what will actually be implemented. The very first sentence in the
recommendation section already begins with "The options needing further
study..." Use of that introductory phrase already indicates that the TRW
does not necessarily expect that all the options will automatically be
implemented.
Third, use s phrase is not needed because the introductory
paragraph inn the the recommendation section already ends with "...or identify
other options that would result in similar increments of color
reduction." This requirement is re-stated just above item 2. NC, TN,
and EPA have already agreed that BRPP will be required to achiev e
color reductions specified whether the initial suite of i is
implemented or not. Use of NC's phrase is superfluou ased on this
agreed-to requirement.
- pg. 4, item 1.A - deletion of "covering also white and green liquor
1 of 2 2/7/2008 7:32 AM

nse to NC's comments on draft TRW memo
sources in the recovery cycle" from "further improvements in leak and
spill prevention and control (BMPs)"
Region 4 strongly disagrees with this deletion. The EPA Tech Team �..�ir-, oGt�,l�. ;-"4
report indicated likely improvements in addressing white and green 2 •"� ��y"7� ^� "�''
liquor sources are well known and can be implemented. The EPA Tech Team
report repeated this recommendation several times.
- pg. 5, item 2.C.1 - deletion of references to chlorine dioxide
pretreatment and activated sludge
n
Region 4 disagrees with these deletions. We believe both areas should -
be specifically evaluated. /-.-
- pg. 5, item 2.D - inclusion of "possible" and "may be possible" to ,
,6 i Gl. va FnV u�sewer generated color 'iA�couur \
discussion
Region 4 disagrees with the need for these terms of uncertainty to be
added. Sewer generated color needs sustained attention to understand
and control and should be evaluated during the upcoming permit term.
- pg. 5 - Item 2.E - "evaluate improving color removal..." rather than
"improving color removal"
• 4
Region 9 does not support use of "evaluate". Region 4's view of the-EPA-T� ��.
Tech Team report is that the specific bullets mentioned here can and A4uvd j " `'"'
should be implemented by BRPP. TiA�
- pg. 5 - Item 6- a daily maximum color limit in the upcoming permit a4 e&'u`T"`Z'X _
should be consideredby NC and evaluated in relation to its potential
benefits
Region 4 strongly disagrees with NC's proposed changes. Use of=a._.daily
maximum limit is mandated by 40 CFR Part 122.45(d) (1) - the regulations
do not allow for consideration of potential benefits. Region' 4 recalls
from the October .Asheville meeting that NC agreed with inclusion of
daily maximum color limits at that time and acknowledged the NPDES '
regulation cited above. Daily maximum limits should be applied at the
beginning of the upcoming permit term and then revised at the end of
that cycle to reflect the improvement (s) made in the interim.
- pg. 6 - Item 9 - NC's suggested changes in the membership of the TRW �p� -.4,v-Guj/JJp"`"
and that TRW recommendations should be provided on a set schedule
Region 4 does not agree with NC's proposed changes to the TRW's �/` �" /4�
membership. Region 4 believes the existing TRW membership has worked
well during the previous times it was involved in this process.
Previous TRW recommendations have always been unanimous. Region 4 is
not aware of any assertion of conflict of interest or bias based on the
existing TRW membership. Region 4 also does not believe that it is -D^
practical or possible. to provide TRW recommendations on a set schedule,
although that should be its goal.
44,a a
2 of 2 2/7/2008 7:32 AM

. .s on proposed edits to the TRW Memo
Subject: TDEC's comments on proposed edits to the TRW Memo
From: "Paul.Estill Davis" <[e-mail]>
Date: Mon, 04 Feb 2008 23:57:17 -0600
To: <[e-mail]>, <[e-mail]>,
<[e-mail]>,<[e-mail]>, "Sergei Chemikov"
<[e-mail]>, "Dave McKinney" <[e-mail]>
All - this will set out TDEC's comments on the TRW memo and changes proposed by
NCDWQ. I have discussed these comments with Tennessee's other TRW member, David
McKinney of TWRA, and I believe we are in full agreement. But I will leave it to
David to add any further comments he might wish to present.
I will limit my review here to the "TRW Recommendations" part of the memo.
Generally, I find many of the proposed changes to be matters of style, not
representing substantive change. This includes edits such as changing from
"discharge color" to "color" and rewriting the "2008 - 2013 term" as the "upcoming
permit cycle." I don't see those changes as necessary, but neither do I find them
objectionable. Several of the more substantive proposed changes are at odds with
Tennessee's position that this permittee must continue to make the best possible
progress toward full protection of our waters. As set out below, I can't agree to
those changes.
My comments are organized by the recommendation numbers in the original document.
Introductory Paragraph and Recommendation 1 - TDEC cannot agree to these proposed
changes. NCDWQ accepted the recommended effluent color target range, and did not-
propose to change the recommendation that If any recommended technologies cannot be
implemented, ". . .BRPP should be required to identify other options that would result
in similar increments of color reduction." The recommendation as drafted provides
sufficient latitude for BRPP to assert that technologies are infeasible, with such
assertion then to be reviewed by the TRW. So there would seem to be no need to add
additional and potentially confusing conditioning phrases such as ". . .when -
technically, economically and operationally feasible. . ." and ". . .provided these '-
items are found to be technically, economically and operationally feasible. . .".
Recommendation 3 - TDEC objects to the proposed change regarding periods of low
streamflow. During recent low flows color in the Tennessee portion of the river has
been particularly objectionable.
Recommendation 7 - TDEC objects to the proposal that we should drop the
recommendation for a maximum day effluent limit for color to a recommendation that
such limitation be considered. NPDES rules require daily mass limits for this
discharge. And,, since this is a very significant flow in relation to the receiving
stream, it's appropriate to protect against slug loading.
Recommendation 8 - TDEC can't agree to delete the recommendation that monthly and
daily limitations should be developed during the coming permit term.
Recommendation 10 - TDEC favors the original language in this section. We can at
some point discuss whether a different composition of the Tech Team and Workgroup
better serves the process. I don't at this point see why that should change, but
would be open to discussion. I don't object to deleting the phrase "requests the
opportunity to" in the second sentence.
I'm holding most of this Friday in case we will be doing a conference call to
discuss.
Paul E. Davis, P.E.
Director, Division of Water Pollution Control
Tennessee Department of Environment and Conservation
615/532-0632
1 of 4 2/5/2008 7:43 AM

s on proposed edits to the TRW Memo
[e-mail]
t <[e-mail]> 1/30/2008 12:09 PM >>> l � l
Sergei -
TN and R4 have agreed to give us comments. Then we will have a conf.
call to discuss and act on all of them re: the content of the final TRW
memo.
Don
Sergei Chernikov
<sergei.cherniko
[e-mail]> To
DonaldF Anderson/DC/USEPA/US@EPA
01/29/2008 09:19 cc
AM
Subject
Re: TRW Memo
Don,
Why are we scheduling a conference call? We already discussed our
comments and agreed that now it's time for Tennessee and EPA to provide
comments. Then, it would make sense to have a discussion of the new
comments.
Sergei
[e-mail] wrote:
All -
Please let me know when you will have time within the next few days as
options for scheduling a conference call to discuss NC's comments and
the TRW's next steps. Thx,
Don
Sergei Chernikov
<sergei.cherniko
2 of 4 2/5/2008 7:43 AM

on proposed edits to the TRW Memo
[e-mail]> To
DonaldF Anderson/DC/USEPA/US@EPA
01/23/2008 09:16 cc
AM Roger Edwards
<[e-mail]>, Ahmar
Siddiqui/DC/USEPA/US@EPA, Betsy
Bicknell
<[e-mail]>,
[e-mail],
[e-mail],
[e-mail], Maryt
Smith/DC/USEPA/US@EPA, Richard
Reding/DC/USEPA/US@EPA, Karrie-Jo
Shell/R4/USEPA/US@EPA, Marshall
Hyatt/R4/USEPA/US@EPA,
NN:[e-mail],
[e-mail],
Susan Wilson
<[e-mail]>
Subject
TRW Memo
1
3 of 4 2/5/2008 7:43 AM

on proposed edits to the TRW Memo
Don,
Attached is the TRW Memo with our suggested corrections. Sorry for not '
delivering it last Friday! It took a few days to get it through the
chain for command, and holiday on Monday did not help. If these
corrections are acceptable, we will proceed with the permitting
process.
Sergei
Sergei Chernikov, Ph.D.
Environmental Engineer
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
phone: [phone] ext. 594
fax: [phone]
[attachment "DWQ comments on TRW recommendations-l.doc" deleted by
DonaldF Anderson/DC/USEPA/US]
Sergei Chernikov, Ph.D.
Environmental Engineer
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617 ,
phone: [phone] ext. 594
fax: [phone]
TRWrcmndtnBRPP2007121907.doc; Content-Type: application/msword
Content-Encoding: base64
Content-Type: application/msword
!DWQ comments on TRW recommendations-Ldoc
Content-Encoding: base64
4 of 4 2/5/2008 7:43 AM

AIS Document Retrieval Pagel of 3
[Code of Federal Regulations]
[Title 40, Volume 211
[Revised as of July 1, 2007]
From the U.S. Government Printing Office via GPO Access
[CITE: 4OCFR122.451
[Page 225-2271
TITLE 40--PROTECTION OF ENVIRONMENT
CHAPTER I--ENVIRONMENTAL PROTECTION AGENCY (CONTINUED)
PART 122 EPA ADMINISTERED PERMIT PROGRAMS: THE NATIONAL POLLUTANT
DISCHARGE ELIMINATION SYSTEM--Table of Contents
Subpart C_Permit Conditions
Sec. 122.45 Calculating NPDES permit conditions (applicable to State NPDES programs, see Sec. 123.25) .
(a) Outfalls and discharge points. all permit effluent limitations,
standards and prohibitions shall be established for each outfall or
discharge point of the permitted facility, except as otherwise provided
under Sec. 122.44(k) (BMPs where limitations are infeasible) and
paragraph (i) of this section (limitations on internal waste streams) .
(b) Production-based limitations. (1) In the case of POTWs, permit
effluent limitations, standards, or prohibitions shall be calculated
based on design flow.
(2) (i) Except in the case of POTWs or as provided in paragraph
(b) (2) (ii) of this section, calculation of any permit limitations,
standards, or prohibitions which are based on production (or other
measure of operation) shall be based not upon the designed production
capacity but rather upon a reasonable measure of actual production of
the facility. For new sources or new dischargers, actual production
shall be estimated using projected production. The time period of the
measure of production shall correspond to the time period of the
calculated permit limitations; for example, monthly production shall be
used to calculate average monthly discharge limitations.
(ii) (A) (1) The Director may include a condition establishing
alternate permit limitations, standards, or prohibitions based upon
anticipated increased (not to exceed maximum production capability) or
decreased production levels.
(2) For the automotive manufacturing industry only, the Regional
Administrator shall, and the State Director may establish a condition
under paragraph (b) (2) (ii) (A) (1) of this section if the applicant
satisfactorily demonstrates to the Director at the time the application
is submitted that its actual production, as indicated in paragraph
(b) (2) (i) of this section, is substantially below maximum production
capability and that there is a reasonable potential for an increase
above actual production during the duration of the permit.
(B) If the Director establishes permit conditions under paragraph
(b) (2) (ii) (A) of this section:
(1) The permit shall require the permittee to notify the Director at
least two business days prior to a month in which the permittee expects
to operate at a level higher than the lowest production level identified
in the permit. The .notice shall specify the anticipated level and the
period during which the permittee expects to operate at the alternate
level. If the notice covers more than one month, the notice shall
specify the reasons for the anticipated production level increase. New
notice of discharge at alternate levels is required to cover a period or
production level not covered by prior notice or, if during two
consecutive months otherwise covered by a notice, the production level
at the permitted facility does not in fact meet the higher level
designated in the notice.
(2) The permittee shall comply with the limitations, standards, or
prohibitions that correspond to the lowest level of production specified
in the permit, unless the permittee has notified the Director under
paragraph (b) (2) (ii) (B) (1) of this section, in which case the permittee
shall comply with the lower of the actual level of production during
each month or the level specified in the notice.
(3) The permittee shall submit with the DMR the level of production
that actually occurred during each month and the limitations, standards,
or prohibitions applicable to that level of production.
(c) Metals. All permit effluent limitations, standards, or
prohibitions for a metal shall be expressed in terms of "total
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WAIS Document Retrieval Page 2 of 3
recoverable metal' ' as defined in 40 CFR part 136 unless:
(1) An applicable effluent standard or limitation has been
promulgated under the CWA and specifies the limitation for the metal in
the dissolved or valent or total form; or
(2) In establishing permit limitations on a case-by-case basis under
Sec. 125.3, it is necessary to express the limitation on the metal in
the dissolved or valent or total form to carry out the provisions of the
CWA; or
(3) All approved analytical methods for the metal inherently measure
only its dissolved form (e.g., hexavalent chromium) .
[[Page 226))
(d) Continuous discharges. For continuous discharges all permit
effluent limitations, standards, and prohibitions, including those
necessary to achieve water quality standards, shall unless impracticable
be stated as:
(1) Maximum daily and average monthly discharge limitations for all
dischargers other than publicly owned treatment works; and
(2) Average weekly and average monthly discharge limitations for
POTWs.
(e) Non-continuous discharges. Discharges which are not continuous,
as defined in Sec. 122.2, shall be particularly described and limited,
considering the following factors, as appropriate:
(1) Frequency (for example, a batch discharge shall not occur more
than once every 3 weeks) ;
(2) Total mass (for example, not to exceed 100 kilograms of zinc and•
200 kilograms of chromium per batch discharge) ;
(3) Maximum rate of discharge of pollutants during the discharge
(for example, not to exceed 2 kilograms of zinc per minute) ; and ,
(4) Prohibition or limitation of specified pollutants by mass,
concentration, or other appropriate measure (for example, shall not
contain at any time more than 0.1 mg/l zinc or more than 250 grams (\1/
4\ kilogram) of zinc in any discharge) .
(f) Mass limitations. (1) All pollutants limited in permits shall
have limitations, standards or prohibitions expressed in terms of mass
except:
(i) For pH, temperature, radiation, or other pollutants which cannot
appropriately be expressed by mass;
(ii) when applicable standards and limitations are expressed in
terms of other units of measurement; or
(iii) If in establishing permit limitations on a case-by-case basis
under Sec. 125.3, limitations expressed in terms of mass are infeasible
because the mass of the pollutant discharged cannot be related to a
measure of operation (for example, discharges of TSS from certain mining
operations), and permit conditions ensure that dilution will not be used
as a substitute for treatment.
(2) Pollutants limited in terms of mass additionally may be limited
in terms of other units of measurement, and the permit shall require the
permittee to comply with both limitations.
(g) Pollutants in intake water. (1) Upon request of the discharger,
technology-based effluent limitations or standards shall be adjusted to
reflect credit for pollutants in the discharger's intake water if:
(i) The applicable effluent limitations and standards contained in
40 CFR subchapter N specifically provide that they shall be applied on a
net basis; or
(ii) The discharger demonstrates that the control system it proposes
or uses to meet applicable technology-based limitations and standards
would, if properly installed and operated, meet the limitations and
standards in the absence of pollutants in the intake waters.
(2) Credit for generic pollutants such as biochemical oxygen demand
(BOD) or total suspended solids (TSS) should not be granted unless the
permittee demonstrates that the constituents of the generic measure in
the effluent are substantially similar to the constituents of the
generic measure in the intake water or unless appropriate additional
limits are placed on process water pollutants either at the outfall or
elsewhere.
(3) Credit shall be granted only to the extent necessary to meet the
applicable limitation or standard, up to a maximum value equal to the
influent value. Additional monitoring may be necessary to determine
eligibility for credits and compliance with permit limits.
(4) Credit shall be granted only if the discharger demonstrates that
the intake water is drawn from the same body of water into which the
discharge is made. The Director may waive this requirement if he finds
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+AIS Document Retrieval Page 3 of 3
that no environmental degradation will result.
(5) This section does not apply to the discharge of raw water
clarifier sludge generated from the treatment of intake water.
(h) Internal waste streams. (1) When permit effluent limitations or
standards imposed at the point of discharge are impractical or
infeasible, effluent limitations or standards for discharges
[[Page 227)]
of pollutants may be imposed on internal waste streams before mixing
with other waste streams or cooling water streams. In those instances,
the monitoring required by Sec. 122.48 shall also be applied to the
internal waste streams.
(2) Limits on internal waste streams will be imposed only when the
fact sheet under Sec. 124.56 sets forth the exceptional circumstances
which make such limitations necessary, such as when the final discharge
point is inaccessible (for example, under 10 meters of water), the
wastes at the point of discharge are so diluted as to make monitoring
impracticable, or the interferences among pollutants at the point of
discharge would make detection or analysis impracticable.
(i) Disposal of pollutants into wells, into POTWs or by land
application. Permit limitations and standards shall be calculated as
provided in Sec. 122.50.
(48 FR 14153, Apr. 1, 1983, as amended at 49 FR 38049, Sept. 26, 1984;
50 FR 4514, Jan. 31, 1985; 54 FR 258, Jan. 4, 1989; 54 FR 18784, May 2,
1989; 65 FR 30909, May 15, 20001
http://frwebgate.access.gpo.gov/cgi-bin/get-cfr.cgi 2/7/2008

• IU/`��I �Cnvl r A� ^ r^�-�,i„a . %.LiL�/.LsCR✓n.C�sk`' . L',d�
J��tfD a{gTFs M D
G UNITED STATES ENVIRONMENTAL PROTECTION � VJ
REGION 4
y� a ATLANTA FEDERAL CENTER ool
syr �Da 61 FORSYTH STREET
qc ra ATLANTA, GEORGIA 30303-8960 QC�
OCT 19 2007 11Nts101A0FWATEROUAUTY
DIRECTORS Off10E
t
Ms. Coleen Sullins
Director CYLf� a
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Subject: Pigeon River Blue Ridge Paper 1996 NPDES Permit Settlement Agreement
Paragraph 33: Ecological Assessment of the Pigeon River System
Dear Ms. Sullins:
This letter is in response to correspondence from Alan Klimek dated June 9, 2006,
regarding a report prepared for the U.S. Environmental Protection Agency (EPA) entitled
"Pigeon River Science Panel Data Review and Recommendations". As you are aware,
during the negotiations regarding the 1996 NPDES permit for the Champion Paper mill,
located irkCanton, North Carolina,EPA, the States of North Carolina and Tennessee, and
other parties entered into a Settlement Agreement that contained certain stipulations
related to issuance of the permit. Section V,Paragraph 33 of the Settlement Agreement,
Ecological Assessment of the Pigeon River System and the Waterville Reservoir, was
one of the requirements of this agreement. The report in question was prepared by a
contractor to assist EPA in determining the potential for completing the requirements of
Paragraph 33, which included evaluating existing information to determine if ecological
or health risks exist is the river.
EPA appreciates your review and comments on this report. Specifically, your
review indicated that the report excluded North Carolina data in the data analysis. This
was an oversight, and EPA realizes that North Carolina has always readily shared
available data when requested. Unfortunately, some of the problems with data analysis
and document preparation were due to time and contractual constraints. The purpose of
the report was to assist EPA and the States in completing the requirements of Paragraph
33 and was not intended to be used as a stand alone decision document without
consultation with both states to reach a consensus on matters related to Paragraph 33. • .
Due to the issues that you and others have identified, the utility of the report for this
effort will be limited. D PE
D
OCT 3 0 2007
E,,R-`NATER OiIALITY
\ SURFACE"diGra'R TECTIO_ N� SECT
Internet Address(URL) •http://w .epa.gov
RecycledlRecyclable•Printed with Vegetable Oil Based Inks on Recycled Paper(Minimum 30%Pcstconsumer)

EPA believes that the requirements of Paragraph 33 have not been fully
completed and discussion between representatives from EPA,North Carolina, and
Tennessee are needed to develop a strategy to complete the commitment outlined in the
Settlement Agreement. EPA is proposing a meeting of representatives from the
Tennessee Division of Water Pollution Control, Tennessee Wildlife Resources Agency,
Y
and North Carolina Division of Water Quality to discuss the status of Paragraph 33. The
objective of this meeting will be to develop a project plan to complete the terms of
Paragraph 33. Please provide us with contact information for the appropriate
representatives from your agency for this planning meeting.
We look forward to cooperating with you on this issue and are hoping to schedule
this meeting within the next few months. If you have any questions, please contact me or
Mr. David Melgaard of my staff at 404-562-9265.
Sincerely,
James D. Giattina
Director
Water Management Division
cc: Paul E. Davis,TN Division of Water Pollution Control
A.David McKinney, TN Wildlife Resources Agency

Clean
Water t
fog°
North Carolina October 19, 2007
29 %2 Page Avenue
Asheville, NC 28801
Ms. Coleen Sullins, Director
Division of Water Quality
Ms. Susan A. Wilson
Western NPDES Unit Supervisor
Dr. Sergei Chernikov
Permit Engineer, Western NPDES Unit
512 S. Salisbury St.
Raleigh,NC 27601
Re: Comments on EPA Tech Team Report and Forthcoming NPDES Permit Process for
Evergreen Packaging Canton Mill
Dear Ms. Sullins,Ms. Wilson and Dr. Chernikov:
I am writing you on behalf of Clean Water for North Carolina to offer some comments on
the EPA Tech Team's August 14 report, and the need to finally implement NC `s
Narrative Standards for surface waters in preparation for the planned meeting of the
Technical Review Workgroup on October 23, 2007.
Clean Water for North Carolina(previously Clean Water Fund of NC)has been involved
in NPDES permits for Champion, International and Blue Ridge Paper Products for at
least four permit cycles. We supported the employee buyout to form Blue Ridge Paper
Products in 1999 in hopes that at least partial worker ownership would improve
stewardship for air and water and substantive progress for western NC and eastern TN
communities impacted for nearly 100 years.
We recognize that significant progress was made by the"Canton modernization" in the
early 1990's and again following a 1997 Settlement Agreement and revised 1998 permit,
but we stated that the 2001 NPDES fell short of requiring Canton Mill performance that
would protect the designated uses for the Pigeon River, and would thus not provide the
basis for removal of the long-standing variance. We stated to EPA Region 4 officials that
the permit and variance issued by the NC Division of Water Quality actually undermined

the stated commitment of all signatories to the Settlement Agreement to continue to
improve water quality"at the quickest possible pace." The sole reason that advocacy
groups did not challenge that permit was because the rippling market effects of the events
of September 11, 2001 and the anthrax letter poisonings had severely and visibly
impacted Blue Ridge's production of airline food containers and envelope papers,with
credible threats of majority owner private equity firm KPS Special Situations Fund
withdrawing support from the company.
We recognize that some efforts to improve water quality and reliability of Bleached
Filtrate Recycling have been made by the Canton Mill under the 2001 permit. Without
significant regulatory leverage in the permit's annual average limits,however, and with
continued agency failure to implement numerical in-stream color standards, meeting
compliance limits has required only limited efforts, inadequate studies and little progress
for water quality or downstream users. Based on contacts to our organization from
downstream residents, it appears that a combination of drought conditions and Evergreen
Packaging mill management completely unresponsive to community concerns, water
quality has actually significantly degraded in recent months. Residents, including several
from Haywood County,have independently decried these conditions publicly and will
provide more detailed comments during the public comment period,but the TRW should
be aware of the broader public context in which this permitting will take place.
The process of renewing this permit has already been delayed for over a year, further
delaying progress in reducing color discharge to the Pigeon River beyond the low
expectations of the 2001 permit. We hope that with the cooperation of all parties, the
remainder of the process will move quickly, with optimized public notification. Clean
Water for North Carolina calls at this point, before issuance of the draft permit, for public
hearings on the draft permit in both western NC and east TN.
We strongly support the continued involvement of the EPA Tech Team and Technical
Review Workgroup in Canton Mill permitting for the indefinite future, until conditions in
the Pigeon River have been declared by consensus to be supporting the River's
designated uses, and until there are both enforceable and enforced standards to assure that
the Canton Mill is not causing impairments to North Carolina and Tennessee waters. This
will necessarily include promulgation of long-avoided enforceable narrative standards
and continued oversight by state, regional and federal authorities responsible for
protecting downstream waters. Only then will the public be confident that we can move
forward into the 21s`century with a commitment to meet the long-overdue goals of the
Clean Water Act, and the full use and enjoyment of the public's waters. Advocates for
public waters respectfully ask that the TRW be mindful, as you meet, of the gravity of its
role in fiilfilling that legislative mandate for one of the nation's longest polluted rivers.

Specific Comments on the Tech Team Report
Current Color Compliance Limit:
The introduction to the Tech Team report states that the"current" annual average color
limit is 42,000 lb/day. We contend that this is incorrect. Based on the Special Color
Provision for the 2001 final NPDES permit for Blue Ridge Paper, the compliance date for
meeting an annual average discharge limit for color of 34,000-39,000 lb/day was March
1, 2006. If the TRW reached a consensus that this limit could not be met, the permit
allowed for modification of this limit,but this would have required public notification. If
the Director of the NC Division of Water Quality failed to provide written notice of this
compliance deadline, that is no excuse for failure to implement the stated final
compliance limit, as such responsibility was specifically stated in the permit.
We will not accept a repeated failure to require a starting compliance limit for the
renewal permit that reflects previous compliance limits or actual mill performance. In
preparation for the 2001 permit,when actual mill performance was in the range of
42,000-43,000 lb/day, the starting limit was set at 48,000 lb/day, allowing the Mill
essentially a"free ride" for the first phase of the permit, then requiring only a further
3,000 lb/day reduction in the second phase. Coupled with low expectations limits for
color reductions, a failure to prescribe the implementation of one or more reasonable
certainty processes, the inadequate studies by Blue Ridge Paper of process changes such
as a second stage of Oxygen Delignification or ozone/chlorine-dioxide bleaching stage,
little progress was required or achieved under the 2001 permit. The TRW must clarify
that the current compliance limit is 39,000 lb/day and that the successor in interest's
renewal permit must include a starting compliance limit of 39,000 lb/day or LOWER,
and then call for rapid implementation of other in-plant improvements to satisfy the
imperatives of the 1997 Settlement Agreement.
Need for Rapid Implementation of Highest Certainty Technologies:
Many of the recommendations of the Tech Team during this and the prior permitting
cycles are not highly technical or expensive and could have been implemented more than
a decade ago. Inadequate technical studies, coupled with a 2001 permit that was not
(despite NC DWQ statements to the contrary) structured in a manner consistent with the
goals of the 1997 Settlement Agreement or with the significant reductions required by the
rewritten 1998 permit, have allowed excessive color impacts to the Pigeon River to
continue.
The Tech Team's report has clearly pointed out that the mill's contracted studies of
second stage Oxygen Delignification were inadequate, in keeping with our own earlier
review of those studies and comments by our formerly contracted mill expert, Dr.
Norman Liebergott. We contend that the TRW should have required further study before
the end of the current permit term (November 30, 2006), and are disappointed that the
TRW failed to hold the mill in violation of its permit terms for failure to carry out
adequate studies of those technologies. At least one of those in-plant process changes
should have been prescribed by the previous permit, as well as color reductions
reasonably expected with those changes. The review by the EPA Tech Team concretizes

the fact that those studies did not satisfy a reasonable level of scientific methodology and
do not support Blue Ridge's contentions that they could not cost-effectively be
implemented in the 2001-2006 permit term. This critique by the Tech Team of Blue
Ridge's contracted studies of"reasonable certainty" process changes should further
motivate the TRW to take compensatory action to make up for lost time in restoring
water quality in the Pigeon River in the current permit renewal process.
The Tech Team has now identified second stage OD as a"highest certainty"rather than
"reasonable certainty"process change, and therefore implementation must be prescribed
and required quickly in the renewal permit, given the earlier delays, with a compliance
deadline and appropriate reduced color limits of no later than the end of 2008, a date that
reflects the one hundredth year of pollution due to pulping operations on the Pigeon. Also
required within the first year of the permit should be implementation of BMPs to capture
and prevent spills and leaks projected to produce at least 4,000 lb/day in influent color
and studies to determine in detail the source of color generated by mixing of influent
sewer waste streams. While we understand that the limited resources of the Tech Team
did not allow a more detailed recommendation for implementation of a ZD stage for the
hardwood line, the inadequacies identified in the contracted study must be addressed and
a more credible study required on this and another significant in-plant process changes
within the first two years of the permit, in order to identify all further in plant reductions
that can be-accomplished by the end of the coming permit term, with motivation for
further color reductions and reliability driven by continued tighter limits
Only compliance limits based on reasonable expectations for readily implementable
BMPs and process changes, coupled with an opportunity to reopen the permit (to allow
the permittee to make the case that it is unable to comply with the limits),will result in
substantial progress for water quality in the river. We therefore call for a starting limit of
no more than 39,000 lb/day on an annual average basis, for an interim compliance limit
of no greater than 34,000 lb/day with immediate implementation of all highest certainty
process changes and a compliance deadline of Nov. 30, 2008. Based on the Tech Team's
study, those highest certainty processes include: installing second stage OD on the pine
line; several additional BMPs that the Tech Team has identified; achieving a 20-25%
reduced kappa factor to reduce bleaching chemical needs and allow recycling of more
filtrates and color removal, as well as increased peroxide or oxygen charge in D1 stages.
The comment by Blue Ridge/Evergreen that it is seeking to increase its percentage of
high brightness pulps does not constitute a reason for regulators to decrease expectations
for reducing color releases to the river. A 5,000 lb/day reduction from 39,000 lb/day is a
very conservative estimate of the color reductions that can be achieved in the first year of
the coming permit. 34,000 lb/day would have been a reasonable final compliance limit
for March 1, 2006, if a justifiable starting limit had been used for the 2001 permit, and
the full range of BMPs and one of the"reasonable certainty"processes identified in the
2001 Tech Team report had been required. It is a reasonable public expectation that
unannounced independent sampling and monitoring of parameters including color, whole
effluent toxicity, BOD, toxic compounds and spectrum of coliform bacteria released and

in downstream sediments be included in the permit to restore public trust of an agency
viewed as advocating for under-regulation of the Canton Mill.
Staged Compliance Schedule,Final Compliance:
As in previous permits, a staged compliance schedule is appropriate, but only with far
more rigorous and enforceable daily and monthly limits. As the Tech Team has pointed
out, even without use of Bleached Filtrate Recycling, the Gladfelter mill has been held
accountable for better color performance on a production-normalized basis. While this
has depended to some extend on use of end-of-pipe polymer treatments atGladfelter, we
believe that the filtrate recycling technologies available to Evergreen, in addition to other
technologies and BMPs identified by the Tech Team and Blue Ridge/Evergreen's own
consultants will ensure achievement of color discharge performance even lower per ton
of pulp production and more reliable than the PA mill.
A final compliance limit for this permit of under 30,000 lb/day would be readily
achievable at current production levels for this permit. This would still be more than
10,000 lb/day above levels needed to comply with EPA's proposed 50 true color unit in-
stream color standard at 30Q2 flow, calculated as of 2001 for the Pigeon. In addition to
the highest certainty changes we believe must be implemented immediately in this permit
renewal, the Tech Team has recommended that the Canton Mill do more extensive
studies on the highly colored CRP waste stream and the mechanism of color generation
upon mixing of influent waste streams.Both of these latter pursuits, as well as further
BMP's, show significant potential for further color reductions and improved reliability,
but the public understands that the resulting operational changes will only be acheived as
the result of a regime of steadily decreasing daily and monthly color limits.
However, even achieving this level of performance will not be sufficient to assure that in-
stream acceptable color will be achieved in low flow conditions, based on calculations
carried out for 30Q2 flows as of 2001, indicating that consistently achieving 50 color
units or less requires reducing color discharge to about 19,000 lb/day(see attached).
Given the current drought conditions, 30Q2 flow numbers will probably also need to be
lowered. Further, we contend that there is no scientifically justifiable reason to limit the
governance of in-stream water quality standards to any specified low flow, whether 30Q2
or 7Q10. In addition to the implementation of a range of BMPs and process changes, the
development of a clear,well-managed and enforceable protocol for production decreases
under low flow conditions, rather than a"contingency plan," MUST be required in the
coming permit to ensure protection of daily in-stream conditions.
Daily limits, Iustream Limits, and the Color Variance:
Clean Water for North Carolina finds the following statement by the Tech Team to be
strangely inconsistent with their own analysis showing that the proposed daily limits
would only have resulted in only two days in violation during the performance in 2006
during PREVIOUS permit term:
"Daily maximum and maximum 30-day average permit limits would enhance the
consistency of day-to-day in-stream water quality, and would be consistent with limits for
other parameters controlled in the present BRPP permit(BODBSB, TSS, AOX, etc). "

Instead, to enhance the desired consistent protection of water quality, we call for more
rigorous daily and monthly limits than those recommended by the EPA Tech Team,
rather than considering it acceptable to risk only two violations during a permit that must
be requiring REDUCED levels of color discharge. If the stated goal is risking less than
some percentage of non-compliance,say 1%, then that means the mill should be at risk
for .01 x 365 days/year or about 4 days per year, with a requirement for the agency to
take action for violations. To motivate further improvements, we contend that the mill
must be at risk for 5% of operating days, consistent with prior evaluations that identified
95% performance levels. Thus, the daily and monthly limits proposed by the EPA Tech
Team fall significantly short of motivating needed improvements in reliability for color
discharges.
The variance for color in the Pigeon River has been renewed for over 20 years without
requiring credible economic analysis from the Canton Mill, or implementing any
mechanism for determining compliance. EPA should not allow the perpetual renewal of
variances by states, but must require the development of enforceable standards, permit
changes and TMDL's in order to phase them out quickly. The impacts of this mill on
designated uses of recreation and aquatic habitat have been allowed to linger far too long,
an ongoing failure to fulfill the requirements of the Clean Water Act. By the end of this
permit term, a combination of in plant process changes,BMP's and enforceable
requirements for production changes under low flows must have achieved daily
compliance with a numerical in-stream standard enforceable for all stream flows and
approved by EPA. We disagree with the EPA Tech Team that such production reductions
should only be viewed as a last resort. Instead,by achieving further documented and
substantial in-plant reductions, a return pulp production toward normal levels in low
flows may be permitted.
The color variance on this permit must not be lifted until an enforceable numerical color
standard has been promulgated by North Carolina and approved by federal EPA, and the
mill has been in 100% daily compliance with that standard for at least one year. We call
for TN and all Region 4 states to similarly implement a broad based color standard and
credible enforcement of narrative standards, rather than specific limits for selected pulp
mill permits. Clean Water for NC has proposed simple spectrophotometric regulatory
approaches to establishing and monitoring in-stream color limits during the last two NC
Triennial Reviews of Water Quality Standards for a broad range of colored effluents (see
attachment). We believe that the most equitable and flexible method of implementing
such standards involves allowing no more than a small increase in % optical density at a
specified wavelength over an upstream reference point, or a specific increase in a defined
color unit over an upstream reference measurement. These proposals have been dismissed
by the NC Division of Water Quality as impracticable with no further study. We would
be glad to discuss these further with all parties to this permitting process, but feel they
have far broader application for all public waters impacted by colored discharges.

Impacts further downstream that may further impair TN waters:
We believe that some of the colored compounds in the Canton Mill's discharge may be
experiencing chemically reducing conditions in Walters Lake and may be discharged at
higher color levels or with greater odor or foam than when water flows into the lake at
Hepco. The failure to fully monitor, limit and assess the impacts of Biological and
Chemical Oxygen Demand may be reflected in some of the chemistry taking place in the
reservoir, both in the water column and in the Lake sediments. We call for color
measurements of influent water to the Lake and effluent discharged directly from
Progress Energy turbines, with a daily limit of no greater than 5 color units above the
measured levels at Hepco, as well as detailed studies on the chemical changes in Walters
Lake that may be affecting color, odor, foam and other observed water quality problems
below the Progress Energy powerhouse and into Tennessee's impaired reach of the River.
Conclusion: A Renewal of Rapid Progress or Required Immediate Compliance?
Finally, the overall comments above reflect a willingness on the part of our organization
to accept a step by step,but justifiably aggressive process to further reduce the Canton
Mill's impact on public waters in western NC and east TN, but only with a demonstrated
renewal of good faith and substantive commitments made by all parties under the 1997
Settlement Agreement. It has been more than 20 years since EPA first demanded
compliance with an in-stream color standard that we contend would have been too lenient
to protect and restore the River's designated uses. If we do not see a clear and
enforceable commitment to rapid further improvements in the Pigeon River on the part of
the NC Division of Water Quality or Evergreen Packaging, we will have no choice but to
call for immediate daily, monthly and annual average compliance with a long overdue
numerical standard, and a move to return the permitting process to US EPA.
Thank you for the opportunity to offer these comments on the Tech Team's report and
present our perspective for the coming public process for the Evergreen Packaging
permit, and the recovery of the Pigeon River.
Best wishes,
Hope C. Taylor
Executive Director, Clean Water for North Carolina
Asheville, Durham hone a cwfnc.orQ 919-401-9600

Information for 3 pm Callon 10-17
Subject: Information for 3 pm Call on 10-17
From: [e-mail]
Date: Wed, 17 Oct 2007 13:45:37 -0400
To: [e-mail], [e-mail]
CC: [e-mail], [e-mail], [e-mail]
l0/17/`;Z OD 7
Roger and Keith -
Information related to this morning's telephone discussion-
The Canton Mill wastewater plant had a biological solids upset starting Sat evening 10/13 and ending
on Monday evening 10/15.
Effluent TSS levels for these days were elevated but remain below daily max permit limits.
Keith Haynes of the DWQ was notified by telephone on the morning of 10/16 with these facts.
We called the DWQ at 10 am today(10/17) to report the following information:
Pigeon River flow at Canton for the past several days by the USGS gauge has held steady at 58 cfs=
37.5 mgd, which is essentially the 7-Q-10 (38 mgd).
The initial DO reading above Clyde (RM 57.7) at 9:50 am on 10/16 was 4.3 mg/l. For the two weeks
prior to 10/16, DO readings above Clyde ranged from 5.1 to 6.2 mg/l.
The Canton Mill started the Site E (Thickety) oxygen station at 2 pm on 10/16 and continued to
monitor DO above Clyde on the evening of 10/16 until midnight. The average DO above Clyde for
10/16 calculates out to 4.95 mg/l.
Effluent DO since 10/13 has ranged from 15 to 18 mg/1 (supersaturated). DOs measured at
Fiberville (RM 62.9) since 10/13 have ranged from 6.6 to 8.6 mg/l.
Permit limits for Fiberville and Clyde (Conditions A.5 and A.10 of permit NC 0000272) are daily
average not less than 5.0 mg/1 and daily minimum not less than 4.0 mg/l. The permit limits are
expressed with one decimal.
Information that you requested for our 3 pm call today:
The DO reading above Clyde at 10:50 am today (10/17) was 6.4 mg/l. DO reading at Fiberville at
8:05 am today was 8.5 mg/l.
1 of 2 10/17/2007 3:01 Pl`

Iformatibn for 3 pm Call on 10-17
The Site E oxygen station continues to run.
The DO field meter that we are currently using is a HACH HQ30D + LDO101-30 DO probe. The
manufacturer's accuracy for the DO probe is 0.05 mg/I DO. The method accuracy from our River
Runner field procedures is 0.1 mg/I DO. Copies are attached.
Based on meter accuracy and significant digits in the permit, the average DO for Clyde for 10/16
works out to 5.0 mg/l.
Paul Dickens
Manager, Environmental Affairs
Blue Ridge.Paper Products, Inc.
[e-mail]
828-646-6141 FAX [phone]
Field DO Method and Accuracy.PDF Content-Type: application/octet-stream
Content-Encoding: base64
2 of 2 10/17/2007 3:01 PM

DENR/DWQ LABORATORY CERTIFICATION
LABORATORY NAME: Blue Ridge Paper Products Inc. CERTIFICATE# 198 DATE: 2007
Analyst(s): River Runner
DISSOLVED OXYGEN
I. Methods: Standard Methods, 201h Edition 4500-0 G, 4500-0 C
Ref: Standard Methods, 20t' Edition, Method 4500-0 G and C
II. Equipment Reply
A. What type of device is used?
1. Model #(if a meter is used): Hach H030d
2.
B. What decimal point range Is used on the device(or meter)? 0.01
Notes: Inspector
1. Normal calibration is 0-10 mg/L
2. Accuracy 0.1 mg/L
3.Sample must be stirred continuously.
4. Probe problems:compare to Winkler Method.
C. What equipment is used for titration method? Wa
Notes: Inspector
1. Preservation for Winkler: (a) 2 ml of MnSO4 and 2 ml alkaline iodide-azide per sample bottle.
2. Store at temperature of collection or water-sealed at 10-200C in the dark.
3. Or(b)0.7 ml H2SO4 and 1-ml sodium azide solution per sample bottle.
4. New holding time: 4-8 hours after preservation.
Ill. Procedure: Reply
A. How is the meter calibrated? Saturated air calibration — automatically adjusted for barometric
pressure G(2) 1. a.
1. How often and when is the meter recalibrated? Daily- before use
2. Where is this documented? River Logbook (3) (a) (H)
B. How is the dissolved oxygen measured each day? In stream at permit locations
Membrane Electrode Method:
C. How does the analyst compensate for salt-water samples? N/a
Notes: Inspector
1. Conversion factors for seawater and brackish water maybe calculated from dissolved oxygen
saturation versus salinity data.
2. Longterm exposure to chlorine=desensitize the probe.
3. Chlorine will depolarize the cathode=high probe-output.
Both methods:

f i
. . _.
Dissolved Oxygen
Page 2
D. How is thesample measurement documented? Recorded in logbook
E. How do you meet the holding time? N/a analyzed immediately
Winkler Method: (360.2.7. Procedure)
Notes: Inspector
1. To 300-ml BOD bottle add: (a)2-ml MnSO4 and 2 ml alkaline iodide-azide.
2. Mix well with stopper In bottle.Allow manganese hydroxide to settle first time.
3. Mix well again. Allow to settle to the point that 200 ml of clear supernatant is present.
4. Add 2 ml cone. H2SO4(or may substitute 3 grams of sulfamic acid).
5. Mix until iodine is distributed throughout the bottle. .
6. Transfer to 500-ml flask and titrate the sample with .0375 N thiosulfate (or .0375 N
phenylarsine oxide)to pale straw color.
7. Add 1-2 ml of starch solution(or 0.1 gram of powdered indicator).
8. Continue titration until the blue color disappears.
9. (If iron interference)Add 1 ml KF before acidification.
10.(if'persistent brown or black precipitant) Add a few more drops of H-SO4.
11.
Calculation: (360.2 8. Calculation)
1. Each ml of sodium thiosultate (or PAO) is equivalent to 1 mg DO when the entire bottle is
titrated.
2. Final DO per 300 ml e?
IV. OualitV Assurance:
A. Per analysis day how many samples are analyzed in duplicate? Nov-Mar (9/30) samples. Apr-
Oct(11/32)samples
B. How is the temperature compensation device compared to meet NIST requirements?
Verified against NIST certified thermometer daily& documented in river logbook
C. How often is the device compared? daily
D. Where is the comparison documented? River logbook
V. Inspector Comments:

Hach Method 10360 — Luminescence Measurement of
Dissolved Oxygen {LDO° in Water and Wastewater
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LEDPwlov& .
LED ;
,
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Hach Method 10360
Luminescence Measurement of Dissolved Oxygen in Water and Wastewater
Revision 1.1
January 2006
1.0 Scope and Application
1.1 This method is for the determination of dissolved oxygen (DO)in surface and ground water,and
municipal and industrial wastewater.
1.2 The method may be used as a replacement for the modified Winkler and membrane electrode
procedures for the measurement of DO in wastewater treatment processes such as aeration and
biological nutrient basins,effluent outfalls, receiving water,and in Biochemical Oxygen Demand
(BOD)determinations where It is desired to perform nondestructive DO measurements.
1.3 The method is for use In the Environmental Protection Agency's (EPA's)survey and monitoring
programs under the Clean Water Act.
1.4 This method is capable of measuring DO in the range of 0.20 to 20 mg/L.
1.5 For this method,the Method Detection Limit(MDL;40 CFR 136,Appendix B)has been determined
as 0.05 mg/L and the Minimum Level(ML; Reference 15.4)has been set at 0.20 mg/L.
2.0 Summary of Method
2.1 This luminescence-based sensor procedure measures the light emission characteristics from a
luminescence-based reaction that takes place at the sensor-water interface. A light emitting diode
(LED)provides incident light required to excite the luminophore substrate. In the presence of
dissolved oxygen the reaction is suppressed. The resulting dynamic lifetime of the excited
luminophore is evaluated and equated to DO concentration.
3.0 Interferences
3.1 There are no known interferences at normal wastewater concentrations that interfere with DO
detection and quantification using this method.
4.0 Safety
4.1 This method does not address all safety issues associated with its use. The laboratory is
responsible for maintaining a safe work environment and a current awareness file of OSHA
regulations regarding the safe handling of any chemicals specified In this method. A reference file
of material safety data sheets (MSDSs)should be available to all personnel involved in these
analyses. Additional information on laboratory safety can be found in References 15.5-15.6.
5.0 Equipment
Note: Brand names,suppliers,and pert numbers are for filustrative purposes only. No endorsement is Implied. Equivalent
performance may be achieved using apparatus and materials other than those specified here,but demonstration of
equivalent performance that meets the requirements or this method is the responsibility of the laboratory.
I
i
5.1 Luminescent dissolved oxygen meter and sensor (Hach Company LDO®, Hydrolab LDO®, or
equivalent).
5.1 BOD bottle 300-mL
5.2 Magnetic Stirring plate(optional)
5.3 Magnetic stirring device(optional)
6.0 Standards
6.1 Initial Calibration—add approximately 1/4 inch of reagent water to a clean BOD bottle and stopper.
6.1.1 Shake vigorously for—30 seconds.
6.1.2 Allow 30 minutes for the BOD bottle and its contents to equilibrate to room temperature.
1

,
Hach Method 1030V—Luminescence Measurement of Dissolved Oxygen in Water and Wastewater
6.1.3 The stopper may now be removed from the BOD bottle and the probe inserted for calibration
purposes.
6.2 Calibration Verification, Initial Precision and Recovery, and On-going Precision and Recovery, -
Add approximately 15V0mLof organic-free water too2'Lbeaker.
O2.1 Allow the water tn equilibrate tu room temperature(t2^C).
6.2.2 Using a steady stream of air I=10—40 mL per minute)aerate the water for a minimum of 30
minutes. .
6.2.3 At the completion of aeration,let water re-equilibrate to room temperature(±2*C)for 30 �
minutes and note the barometric pressure of the laboratory during preparation. i
6.2.4 Transfer the aerated water to a BOD bottle until overflowing and stopper. i
6.2.5 Calculate the theoretical dissolved oxygen concentration using a dissolved oxygen table such
asMitchman(197O).
0.3 Method Detection Limit—Preparing dissolved oxygen reference water at concentrations other than
air-saturated water requires specialized equipment and expertise not generally available to routine
analysis laboratories. |tis recommended that these samples bo obtained through acommercial
source.
6.3.1 Using a NIST traceable source of oxygen and nitrogen,saturate reagent water to a desirable
DO concentration.
0.32Co/|oot the prepared water in0O0'mLB0D bottles and stopper.
7.0 Sample Collection Preservation and Storage
7.1 See Title 40 of the Code of Federal Regulations Part 136.3,Table 11 (Section 15.3)for information
regarding required sample collection containers, preservation techniques and holding times,
8.8 Quality Control
0.1 |tinrecommended that each laboratory that uses this method bo required 1n operate aformal
quality assurance program(Reference 15.1). The minimum requirements of this program consist of
an initial demonstration of laboratory capability and ongoing analyses nf laboratory prepared water
standards as a test of continued performance to assess accuracy and precision. Laboratory
performance is compared to established performance criteria to determine if the results of analyses
meet the performance characteristics of the method.
' 8.1.1 The analyst shall make an initial demonstration of the ability to generate acceptable accuracy
and precision with this method. This ability is established as described in Section 8.2.
8.1.2 The laboratory shall, on an ongoing basis, demonstrate through calibration verification and
analysis of the ongoing precision and recovery sample that the analysis system is in control.
These procedures are described in Sections 0.3 and 0.4. respectively.
8.1.3 Accompanying QC for the determination f DO is required per analyticalhtohAanalytical
batch is a set of samples processed during a contiguous 8-hour period. Each analytical
batch must bo accompanied hya calibration verificalinn and ongoing precision and recovery
sample, resulting|no minimum nf three analyses(1 CV, 1 sample,and 1OPR).
8.2 Initial demonstration cf laboratory capability.
8.2.1 Method Detection Limit(MDL)—The MDL and ML for DO is not a requirement in Method
10360. However, its demonstration is recommended as a part of the laboratory's overall QC
program.
0.2.2An achieved W\DLand ML less than nr equal io the YWDL and W1Lin Table 2isrecommended
prior to the practice of this method. The ML is established by multiplying the MDL by 3.18
and rounding to the number nearest 1n(1. 2. nr5)x1V".where nisa positive ornegative
integer.
2 |

Hach Method 10360—Luminescence Measurement of Dissolved Oxygen in Water and Wastewater
8.2.3 Initial precision and recovery(IPR)-To establish the ability to generate acceptable precision
and accuracy,the analyst shall,perform the following operations:
8.2.3.1 Prepare and measure four samples of the IPR standard (Section 6.2)according to
the procedure beginning in Section 10.
8.2.3.2 Using the results of the set of four analyses, compute the average percent recovery
(X)and the standard deviation of the percent recovery(s)for DO. Use the following
equation for calculation of the standard deviation of the percent recovery:
1
xZ
x"--
s= n
n-I
where:
n=Number of samples
x=Concentration in each sample
8.2.3.3 Compare s and X with the corresponding limits for Initial precision and recovery in
Table 1. If s and X meet the acceptance criteria,system performance is acceptable
and analysis of samples may begin. If,however, s exceeds the precision limit or
falls outside the range for recovery, system performance is unacceptable. In this
event correct the problem,and repeat the test.
8.3 Calibration verification—DO calibration is performed immediately prior to sample analysis.
8.3.1 Prepare a calibration verification standard(Section 6.2)with each analytical batch. Analyze
according to the procedure beginning in Section 10 and compare the recovery results to
those In Table 3. Actual average recovery and standard deviation should be within the
specifications in Table 1.
8.4 Ongoing calibration and precision and recovery-To demonstrate that the analysis system is in
control, and acceptable precision and accuracy is being maintained with each analytical batch,the
analyst shall perform the following operations:
8.4.1 Prepare a precision and recovery standard (Section 6.2)with each analytical batch according
to the procedure beginning in Section 10.
8.4.2 At the end of each analytical batch of samples, analyze a precision and recovery standard
and compare the concentration recovery with the limits for ongoing precision and recovery in
Table 1. If the recovery is in the range specified, measurement process is in control and
analysis of samples may proceed. If, however,the recovery is not in the specified range,the
analytical process is not in control. In this event,correct the problem, recalibrate and verify
the calibration and reanalyze analytical batch, repeating the ongoing precision and recovery
test.
8.4.3 The laboratory should add results that pass the specification in Table 1 to IPR and previous
OPR data and update QC charts to form a graphic representation of continued laboratory
performance.The laboratory should also develop a statement of laboratory data quality for
each analyte by calculating the average percent recovery(R)and the standard deviation of
the percent recovery(sr).Express the accuracy as a recovery interval from R 2sr to R+2sr.
For example, if R=95% and sr=5%,the accuracy is 85%to 105%.
8.5 Depending upon specific program requirements,field replicates may be required to assess the
precision and accuracy of the sampling and sample transporting techniques.
3

Hach Method 10360—Luminescence Measurement of Dissolved Oxygen in Water and Wastewater
9.0 Calibration and Standardization
9.1 Because of the possible diversity of future LDO instrument hardware,no detailed operating
conditions are provided. The analyst Is advised to follow the recommended operating conditions
provided by the manufacturer. It is the responsibility of the analyst to verify that the instrument
configuration and operating conditions satisfy the analytical requirements of this method and to
maintain quality control data verifying Instrument performance and analytical results.
9.2 Water-saturated air(Section 6.1) is used for instrument calibration.
9.3 Calibration verification (Section 8.3)is performed with air-saturated water prior to any DO sample
measurements to the method specifications.
10.0 Procedure
10.1 Instrument Setup and Sample Analysis—follow the instrument manufacturers instructions for
instrument setup and sample analysis.
11.0 Data Analysis and Calculations
11.1 Follow instrument manufacturer's instructions.
12.0 Method Performance
Acceptance Criterion Section Limit
/iU✓i1�y!/f/ Method Detection Limit 8.2.2 0.05 mg/L
Minimum Level 8.2.2 0.20 mg/L
Initial Accuracy 8.2.3 95%to 105%
Initial Precision 8.2.3 2.1%
Ongoing Accuracy 8.2.3 95%to 105%
Ongoing Precision 8.2.3 2.1%
I
13.0 Pollution Prevention
13.1 There are no standards or reagents used in this method that pose any threat to the environment.
14.0 Waste Management
14.1 It is the laboratory's responsibility to comply with all federal,state, and local regulations governing
waste management, particularly the hazardous waste identification rules and land disposal
restrictions, and to protect air,water,and land by minimizing and control all releases from fume
hoods and bench operations. Compliance with all sewage discharge permits and regulations is
also required.
14.2 For further information on waste management, consult"The Waste Management manual for
Laboratory Personnel",and Less is Better: Laboratory Chemical Management for Waste
Reduction", both available from the American Society's Department of Government relations and
Science Policy, 1155 16''Street N.W.,Washington, D.C.20036.
15.0 References
15.1 Handbook of Analytical Quality Control in Water and Wastewater Laboratories,"USEPA, EMSL-CI,
Cincinnati, OH 45268, EPA-600-4-79-019, March 1979.
15.2 Hitchmen, M.L. (1978) Chemical analysis.Vol.49. Measurement of Dissolved Oxygen.Wiley and
sons,New York.
15.3 Title 40, Code of Federal Regulations(40 CFR), Part 136.
15.4 Protocol for EPA Approval of New Methods for Organic and Inorganic Analytes in Wastewater and
Drinking Water@ (EPA-821-B-98-003,March 1999).
4

Hach Method 10360-Luminescence Measurement of Dissolved Oxygen in Water and Wastewater
I
15.5 "OSHA Safety and Health Standards, General Industry,"(29 CFR 1910),Occupational Safety and
Health Administration, OSHA 2206(Revised,January 1976)
15.6 "Safety in Academic Chemistry Laboratories,"American Chemical Society, Committee on Chemical
Safety, 3rd Edition, 1979.
16.0 Tables
16.1 Acceptance Criteria for Performance tests-The QC performance criteria for this method was
performed with a Hach Company HQ10 LDO®meter using the ambient use sensor mode (see
Hach Company Instrument Manual). Calibration was performed with water-saturated air.
Table 1. Initial Precision and Recovery Method Performance
IPR IPR DO Cone. 97.5%Lower Limit 97.5% Upper Limit 95%Upper Limit
Range m /L of Recovery % of Recovery % of Precision
Low 1.72-1.74 95.0 104.0 2.07
Hi h 7.22-9.23 95.8 104.8 1.26
Table 2.Method Detection and Minimum Limit Performance
MDL Test DO Concentration MDL MIL
0.07 m /L-0.09 m /L 0.05 0.20
Table 3.Calibration Verification Performance
Average% %Standard %Relative Standard
Cv DO Concentration Recove Deviation Deviation
7.22 m /L-9.23 m /L 100.1 1 2.5 2.5
17.0 Glossary of Definitions and Purposes
The definitions and purposes are specified to this method but have been conformed to common
usage as much as possible.
17.1 Units of weight and measure and their abbreviations
17.1.1 Symbols
°C degrees Celsius
17.1.2 Alphabetical characters
mg/L milligram per liter
17.2 Definitions,acronyms,and abbreviations
17.2.1 LDO®-Luminescence dissolved oxygen
17.2.2 BOD: Biological oxygen demand
17.2.3 60: Dissolved oxygen
17.2.4 iV Calibration verification
17.2.5 MDL: Method detection limit
17.2.6 ML: Minimum level
17.2.7 IPR: Initial precision and recovery
17.2.8 OPR: On-going precision and recovery
5
f
1

S ,
Hach Method 10360—Luminescence Measurement of Dissolved Oxygen In Water and Wastewater
i
Appendix
J`�asEO spTfa
'^ (1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
$ g WASHINGTON.D.C. 20460
JUL 26 W
OFFICE OF
MEMORANDUM WRYER
SUBJECT: Recommendation for Use of Hach Method 10360(Revision 1.1,January 2006]
(ATP Case No.N04-0013)
FROM: Robin K.Oshim,Ph.D.
--
ATP Coordinator
Engineering and Analytical Support Branch(4303 T)
TO: USEPA Regional Administrators(all Regions)
We have reviewed the Hach Method 10360(Revision 1.1,January 2006,Luminescence'
Measurement ojDissolved Oxygen in Water and Wastewater),and the supporting validation data
in ATP Case No.N04-0013. We have determined that this method meets all requirements for
measurements of dissolved oxygen in water and wastewater. That is,the performance of this
method is substantially similar to part 136 methods for measurement of dissolved oxygen(DO)
in wastewater. We believe that this method also may be used to measure DO when a Pail 136
method requires measurement ofDO in determining biochemical oxygen demand in wastewater.
We will recommend that this method be included in future regulatory actions in which we
periodically update the methods approved at 40 CFR Part 136.3. Meanwhile,Regions may wish
to exercise their authority under 40 CFR part 136.5 to allow use of this method.
If 1 can be of any additional assistance on this matter or others,please contact me at
oshi m.mbi n(axna.uov.
cc: Quality Assurance Managers(all Regions)
Water Management Division Directors(all Regions)
ATP Coordinators(all Regions)
Carey Jackson,Ph.D.,Hach Company
Kevin Roberts,CSC,SCC
YvomotMazodM •marne«cwsume
attYcladlaocYclaele•PnnlMxNpVppolaWo Ql paiedlnkion 1<�Pocieonsumat,fioce55CMadnv Frseflagektl Pape,
6

The Mountaineer Publishing Company Page 1 of 4
��ttGt�C�S ,i,(
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RESIDENTS ALONG THE PIGEON RIVER DOUBT THE '30-
MINUTE COMPUTER GLITCH' EXPLANATION FOR LAST ' llVoald Yot
Rather .
WEEK'S FOAMY DISCHARGE a Be Here...?
VickiHyatt- Editor
Three landowners along the Pigeon River aren't
buying the explanation that a 30-minute computer Featured Sponsor
glitch caused the Pigeon River to run black and foamy —
last week. I t
Kenneth Cole said he and his two neighbors who own
property along the Pigeon River in the Crabtree vrww.POP4 H t rze coM
community have been discussing the changes in the
water for the past three months, and said there was a y
noticeable change at least six weeks ago. d
Rick Smith, Rid Runner aturats.
The color changes have been off and on for the last REALTOR 4..—
ge
six weeks,Cole said, noting that at times the water has r
been so black you can't see the bottom of the river. And all the foam. It looks
like it did back in the 50s and 60s.
On Sept. 15, Evergreen Packaging Group, formerly Blue Ridge Paper Products,
Inc., self-reported a discharge into the Pigeon River. When contacted about the Bear Creek Cabin Rentals
report several days later, Keith Haynes,the N.C.Department of Health and Are you looking for a beautiful vacation geta
Environmental Sciences' Water Quality Division employee responsible for nestled in the heart of the Smoky Mountains
overseeing discharge permits in Haywood, said the problem was the result of a Creek Cabins may be just what you are look
30-minute computer error.
SOAR-Adventure Summer Camp...
It was this issue that prompted Cole and two other riverfront landowners to features success-oriented, high adventure p
speak out about the changes they had noted in the Pigeon. preteens, teens and adults with Learning Di;
AD/HD. SOAR offers: summer camps,week
The foam started in early summer and progressively got worse, said Joe Haynes, retreats,winter break and semester courses
who also owns riverfront property below the Canton mill.I never thought
anything about it, but when it started piling up at least six weeks ago like the
remnants of the 50s,we knew something was definitely wrong.
Cole noted that with environmental improvements through the years, about 99
percent of the foam had been cleaned up.
But two or three months ago, we started noticing foam again, not just a little bit
but big chunks that got hung up on trees and rocks, he said.
littp://www.themountaineer.com/ems/display/Top_Stories/pageDisplay.php?page2display=1190613600*0... 9/25/2007

The Mountaineer Publishing Company Page 2 of 4
Cole said while he, Haynes and Grover Payne noticed changes months ago, they
said nothing because they knew how sensitive the subject is in Haywood
County.
Fifteen years I've been living here, and I've never seen foam on the river like
this,Payne said. I think somebody must be lying to say it was a 30-minute
computer error because it has been like this for six weeks.
An article in Wednesday's issue of The Mountaineer reporting on the condition
of the river and quoting officials who provided the computer error explanation
prompted Cole, Haynes and Payne to speak up.
Don't lie to me, Cole said of the explanation. This summer has been unusually
dry, and I'm not stupid. The solution to pollution is dilution. The river is at its
lowest point, so whatever they dump, it shows up.
Cole said, ironically, after the news article appeared,the river foam almost
ceased.
Would you like to respond to the editor about the story you just read?If so,
please fill out the following form to write a letter to the editor.
Story Headline:L
Reporter's Name:
Please type your comments in the box below:
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Color Event—9/15/2007
Canton Mill
On Saturday afternoon 9/15/2007,there was a control power failure that affected the evaporator
and oxidation portions of the Kraft recovery process at the Canton Mill. While restoring the
recovery process from upset conditions,an overflow of the slurry tank in the Chloride Removal
Process occurred. The overflow alarm and spill collection system on this tank did not function
properly due to a plugged overflow line. High color materials entered the mill sewer system.
The duration of the overflow was 28 minutes'between 4:27 and 4:55 pm. The overflow was
immediately stopped when detected. Wastewater treatment personnel were notified and initiated
polyamine treatment of color materials that had reached the mill's wastewater treatment plant.
Corrective measures to prevent reoccurrence, including the installation of an overflow recovery
system, are underway.

.,eer Publishing Company 2 Page 1 of 4
•-x rr 'u4� Ridge I,OCATE•D IN 111STORIC DOWNTOWN WAYNTSVII
2J NYTIMES BEST SELLERS LARGE SELECTION(
C - es`6,1.. A4SAGA77NESOUr-OP=TOWN'NE{i'SPAPEILSFREEWI-
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WHAT REALLY HAPPENED? r —�
- � Would Yot
Jeff Schmerker- Staff Writer Rather
Although a malfunction at the Evergreen paper
company in Canton left the Pigeon River foamy and Featured Sponsor ,
black for days, the event will likely not result in ai'
violation of the company's discharge permit. fr`
Company officials reported that a computer error 1 ,
allowed a liquid called black liquor to run through the t Y
company's wastewater treatment plant for about 30 ✓ '
minutes last Saturday.
WWW.PoP4HIRE.COM
Officials from the state Division of Water Quality Karen Case, —'
didn't test the river until Wednesday. A report should REALTOR
be issued this week.
iRidge.Runner Nate s
Roger Edwards,the state agency's surface water protection supervisor,who is
based in Asheville, said the event would likely not warrant a violation.
Evergreen's environmental permit, Edwards said, is one of the most
comprehensive and complicated in Western North Carolina.
The company samples water both above, at and below the plant on a daily and Bear Creek Cabin Rentals
Are you looking for a beautiful vacation geta
weekly basis, testing for more than two dozen items. nestled in the heart of the Smoky Mountains
Creek Cabins may be just what you are look
Those samples are figured into Evergreen's allowable daily maximum and
monthly average allowances. It is unlikely the material present in the 30-minute
event would exceed any of those parameters, Edwards said. SOAR-Adventure Summer Camp...
features success-oriented, high adventure p
There was no permit violation he said even though he hadn't et seen the Preteens,teens and adults with Learning week
P g Y AD/HD. SOAR offers: summer camps,week
report. retreats,winter break and semester courses
Evergreen self-reported the event on Saturday after it occurred, according to
state officials. Because the liquid went though the company's wastewater
treatment plant, he said, and was not a direct discharge into the river, it did not
violate discharge-rules. And although it went through the treatment plant,the
black liquor was too concentrated to be cleaned by the system.
The result was an increase in color(and foam)to the Pigeon River for a number
of days, Edwards said,I don't know when it went back to normal.
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-..eer Publishing Company Page 2 of 4
A direct discharge to the river, he said,would have resulted in immediate
testing.
Effects of the release of black liquor into the river were likely amplified due to
the low volume of water currently in the Pigeon and the fact that flow to the
treatment plant has remained the same and could be to blame for residents'
complaints that the river below Evergreen has been noticeably darker and
foamier in recent weeks.
Black liquor is byproduct formed during the woodmaking process. In the
process, lignin, the natural substance which holds wood fibers together, is
separated from cellulo$e, which is used to make paper fibers. Black liquor is the
combination of lignin with water and the chemicals used for the extraction.
Normally, black liquor is sent to a boiler but the computer error resulted in it
being sent to the wastewater plant.
Part of an agreed-upon correction, said state environmental specialist Keith
Haynes, is that Evergreen will build a reservoir meant to hold the black liquor
rather than send it through the wastewater plant should a similar malfunction
occur in the future.
The discoloration and foam was likely still visible in the river for days after the
event, Edwards said, because of the concentrated nature of the material which
was released.
Evergreen, formerly the employee-owned Blue Ridge Paper Products,was
purchased by a New Zealand billionaire this summer.
Despite changes in ownership, officials say there has been no change to the
company's record of environmental compliance.
Sergei Chernikov, environmental engineer with the DENR's Division of Water
Quality in Raleigh, has worked closely with the discharge permit at Canton's
paper mill system.
Overall, the company has a pretty good compliance record, Chernikov said. The
foam in itself might not be related to the discharge that was reported. Reports of
violations for this particular facility are.very rare. They spent a lot of time and
money on their wastewater treatment.
Chernikov cited a report prepared by Dr.Norman Liebergott, a Canadian ho is a
highly respected consultant with expertise on paper mills.
Liebergott's report prepared last year indicated the Canton facility is one of the
best in facilities in world when it comes to managing environmental discharges,
Chernikov said.
Attempts to reach a company spokesperson were unsuccessful.
Would you like to respond to the editor about the story you just read? If so,
please fill out the following form to write a letter to the editor.
Story Headline:
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BLUE RIDGE
PAPER PRODUCTS INC. I •z
August 14, 2007 D IL}S III' ILLS U D
Mr. Keith Haynes AUG 6 2007
North Carolina Department of Environmental
C ` WATER QUALITY SECTION
And Natural Resources : ' ASHEVILLE REGIONAL OFFICE
Asheville Regional Office
Division of Water Quality
2090 US Hwy. 70
Swannanoa,NC 28778
RE: No. 6 Fuel Oil -NRC Report No. 845104
Dear Mr. Haynes,
Blue Ridge Paper Products,Inc. is providing follow-up written notification for the subject
spill report. This letter follows a telephone call to you and Mike Parker at
10:20 AM on August 10, 2007. As a precaution an oil boom was installed below the
mill's discharge immediately following the initial call.
On August 9, 2007 at approximately 7:30 PM anlestirfrated quantity of less than 100
gallons.of No. 6 Oil was released to Blue Ridge's Wastewater Treatment Plant.
On August 10, 2007 at approximately 9:00 AM small spots of oil residue were observed
in the Pigeon River below the Treatment Plant discharge and verbally reported
immediately to your office, the LEPC and NRC.
Further investigation identified similar oil residual on the river above the mill. Visual
checks on the Wastewater Lab's 8 and 24-hour composite effluent samples for 8/9 & 8/10
showed no oil present. The filter pads from analysis of these effluent samples also
showed no presence of oil. Therefore,there was no abnormal discharge of oil. The
residual oil material was captured and removed in our Wastewater Treatment Plant.
The oil residual observed in the Pigeon River below our discharge on 8/10 originated
from upstream of the Canton Mill.
Please call use if you have any questions or need additional information.
Sincerely
Louie J tus Paul Dickens
Sr. Enviro Engineer Manager,Environmental Affairs
828-646-2372 828-646-6141• • -
175 Main Street • P.O.Box 4000 • Canton,North Carolina 28716
Phone:[phone]
Raising Your Expectations

Copy: Greg Shuping
Haywood County LEPC
215 North Main Street
Waynesville.NC 28786
US Environmental Protection Agency
Region IV Office
Emergency and Remedial Response Section
61 Forsyth Street
Atlanta, Georgia 30303
Attention: Terence Byrd
Blue Ridge Paper Products, Canton Mill
Derric Brown, Director Regulatory Affairs
Jim Giauque, EHS-Principal Environmental Engineer

1-71 - .Zo -aoo7
�Qt TIiEST,".�
�4
'<FqI�GNLV k` .
�2!
G
STATE OF TENNESSEE
DEPARTMENT OF ENVIRONMENT AND CONSERVATION
401 CHURCH STREET
L&C ANNEX 6TH FLOOR
NASHVI LE TN 37243-1534
0
Mr. Alan W. Kl' ,P.E.,Director
Division of Wat Quality
NC Departm of Environment and Natural Resources
1617 Mail Se ice Center
Raleigh;NC 7699-1617
Subject: Blue Ridge Paper Products, Inc.
Renewal ofNPDES Permit(NC0000272)
Dear Mr. Klimek:
Over the past few months we have been in contact with your permitting staff as they have
worked to renew the NPDES permit for the Blue Ridge Paper Products (BRPP) facility located in
Canton,North Carolina. We appreciate the efforts of your staff to keep Tennessee involved and
infomed as the permit reissuance effort moves forward. We also look forward to reviewing the
draft permit during the official public comment period.
We understand that NC DWQ wishes to move forward as quickly as possible with the permit
renewal;however,it appears the process is currently on hold awaiting the findings of the EPA-
sponsored Technology Review Workgroup (TRW). We strongly support the TRW effort and
encourage EPA to complete its report as soon as possible. While the BRPP facility has made
tremendous improvements in the quality of its wastewater discharge over the past two permit
cycles, we look forward to the upcoming permit renewal and the inclusion of the TRW findings
to ensure that these improvements continue to the maximum extent practicable.
p ECE� WE
D
LAPR 25 ,2007
r`1"P 7 02007 DENR-WATEROUALITY
SURFACE WATER PROTECTION SECTION
DIV.OF WATER QUALITY
DIRECTOR'S OFFICE

If you have questions, please contact me at 615-532- 0632. The staff contact for this project is
David Hair at(615) 532-0647 or by E-mail at [e-mail].
Sincerely:
VU(�_r'%'Z'
Paul Estill Davis, P.E.
Director
Water Pollution Control
CC: Mr.Paul Sloan,Deputy Commisioner,TDEC
DWPC, Permit Section&Johnson City Environmental Field Office
Mr.Roosevelt Childress, EPA Region IV, Sam Nunn Atlanta Federal Center, NPDES Permit Section, 61 Forsyth
Street SW, Atlanta,GA 30303
Mr.Don Anderson(4303T),EPA Headquarters,Office of Science and Technology, 1200 Pennsylvania Avenue N.W.,
Washington,DC 20460

' -\Q�W ATFR Michael F.Easley,Governor
��\l William G.Ross Secretary ^
�/J [ North Carolina Department of Environment and Natural
Resources
Alan W.Klimek,P.E..Director
Division of Water Quality
SURFACE WATER PROTECTION ' `
e April 5, 2007 L= L
Tony Serrao
168 Main Street
Canton, NC 28716
Subject : Complaint Investigation
Blue Ridge Paper WWTP
NPDES Permit NC0000272
Haywood County
Dear Mr. Serrao:
On March 22, 2007 Division of Water Quality staff
investigated your complaint concerning excessive odors from the
wastewater treatment plant located at the subject facility and
odors in the Pigeon River downstream from the site. During the
investigation, no unusual odors were noted around the plant or
downstream in the Pigeon River below Clyde. In fact, odors were
practically nonexistent in the surrounding area .
Please be aware that the Division of Water Quality does not
have odor regulations, other than assuring the proper operation
of a treatment plant in order to minimize odors . If a facility
is meeting its permit effluent limits, odors should be minimal;
however, it should be noted that due to the nature of
wastewater, some odors are always going to be present .
If you have any questions, please do not hesitate to
contact me at 296-4500 .
Sincerely,
AT( e.
Roger Edward's, Regional Supervisor
Surface Water Protection
Nor`thCarolina
,NaWra!(y
North Carolina Division of Water Quality 2090 U.S.Highway 70 Swannanoa,NC 28778 Phone[phone] Customer Service
Internet: www.ncwalerquality.org FAX [phone]
An Equal OppodunitylAffinnative Action Employer-50%Recycled/10%Post Consumer Paper

Subject: Fw: request
From: [e-mail]
Date: Tue, 6 Mar 2007 09:17:22 -0500
To: [e-mail]
CC: [e-mail]
Your cc -
Paul Dickens
-----Forwarded by Paul Dickens/CantonBlueRidge on 03/06/2007 09:17 AM -----
Paul To Sergei Chemikov<[e-mail]>
Dickens/CantonBlueRidge cc Glenn Rogers/Canton/BlueRidge@B1ueRidgePaper, Bob
03/06/2007 09:10 AM Williams/CantonBlueRidge@BlueRidgePaper,
[e-mail], Derric
Brown/CantonBlueRidge@B1ueRidgePaper
Subject Re: request Link
3/6
Dr. Chemikov-
A spreadsheet with the requested figures updated flim the end of 2006 is attached. Also attached is a
word document with a discussion of compliance with the North Carolina narrative water quality standard
for color. This text is taken from the May 2006 Color Compliance Report. In evaluating,color, it is
important to consider all of the factors in the narrative standard.
Concerning the mill's effluent color performance, two points. We have continued to make
improvements year to year. Scale in presenting graphs of data is important. The long-term trend since
1988 appears to be approaching an asymptotic limit. Annual and production-normalized data since
1997 are important to include. On a production-normalized basis, our color performance is among the
best, if not the best, of Kraft pulp and paper mills in the world. We refer you to the NCASI color study,
to data provided by Dr. Liebergott and to the Technology Review Workgroup for this benchmarking.
Color data statistics for the river monitoring points are in the Color Compliance Report. There was no
significant change to these statistics with data thru the end of 2006. Average color at the NC/TN state
line during the current permit term (Dec 2001 thru Dec 2006) is 17 true color units, and all daily
measured values have been below 35 true color units. Average color at HEPCO during the current
permit term is 24 true color units, and all monthly average color values since Dec 2001 have been below
45 true color units.
Please advise any additional information or materials that you may need.
1 of 3 3/6/2007 3:50 PM

Paul Dickens
Manager, Environmental Affairs
Blue Ridge Paper Products, Inc.
[e-mail]
828-646-6141 FAX [phone]
Sergei Chernikov <[e-mail]> To [e-mail]
03/05/2007 10:52 AM cc
Subject request
Paul,
I am working on the rationale for .removing the color variance and was
wondering if you could e-mail me a few graphs that have already been
prepared by you, it would save me some time.
If it is possible, I would like to received the following:
1) Color at Fiberville 1997-2006.
2) Color at HEPCO 1988-2006.
3) Color at TN/NC Line 1998-2006 .
4) Figure 42, # 3, and # 4 from Color Compliance Report (May 2006) .
Thank you!
Sergei
Sergei Chernikov, Ph.D.
Environmental Engineer
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
phone: [phone] ext. 594
fax: [phone]
Content-Type: application/vnd.ms-excel
'Sergei Request.xls
Content-Encoding: base64
2 of 3 3/6/2007 3:50 PM

6.0 Evaluation of Compliance with the North Carolina Color Standard
This section examines current conditions of stream color in the Pigeon River below the
Canton Mill and compliance with the North Carolina water quality standard for color.
6.1 North Carolina Color Standard
The North Carolina water quality standard for color(Color Standard) is a narrative
standard set forth in Title 15A,North Carolina Administrative Code, Subchapter 213,
subparagraph.0211 as follows:
15A NCAC 2B.0211 Fresh Surface Water Quality Standards for Class C
Waters
General. The water quality standards for all fresh surface waters are the basic
standards applicable to Class C waters. ...
(1) Best Usage of Waters. Aquatic life propagation and maintenance of
biological integrity (includingfzshing and fish), secondary recreation,
agricultural and any other usage except for primary recreation or as a
source of water supply for drinking water, culinary or food processing
purposes; ...
(3) Quality standards applicable to all fresh surface waters:
69 Oils, deleterious substances; color or other wastes: only such
mnounts as shall not render the waters injurious to public
health, secondary recreation or to aquatic life and wildlife or
adversely affect the palatability offish, aesthetic quality or
impair the waters for any designated uses ...
North Carolina has never established a numeric stream color standard. No river or stream
in the state has a numeric standard for color, and for streams where color is regulated,
numeric discharge standards are applied on a site-specific basis (for example, Clark
Creek tributary to South Fork Catawba River). The only way to determine compliance
with the Color Standard is to consider its components.
6.2 Analysis of the Standard
The North Carolina Color Standard has six components:
• Public health
• Aquatic life and wildlife
• Palatability of fish
• Secondary recreation
• Aesthetic quality

• Designated uses
An analysis of these components follows:
Public Health - Stream water color is not related to public health, and stream water
color in the Pigeon River is not affecting public health. The ecological health of the
Pigeon River has improved dramatically since 1988 and is continuing to improve.
Aquatic Life and Wildlife - The Pigeon River has been sampled extensively for fish
and macroinvertebrates since 1987. The most recent biological assessment was
conducted in 2005. There is a diverse and healthy aquatic community in the Pigeon
River below the Mill.
Since 1997 the Canton Mill wastewater effluent has been subjected to EPA Whole
Effluent Toxicity testing using a very pollutant sensitive indicator species
(Ceriodaphnia). The mill has passed all of these tests at 90 to 100% effluent
concentration. Based on more than eight years of this testing and the diverse and healthy
aquatic community in the river, color in the river is not injurious to aquatic life.
Finally, NCASI has summarized research on the biological impacts of color in streams
receiving pulp mill effluents (NCASI Special Report 94-07, Hcunm: Perception and
Biological Impacts of Kraft Mill Effluent Color, June 1994). This NCASI work indicates
that stream color concentrations below 100 color units have no effect on the health of
aquatic organisms. Color levels in the Pigeon River downstream of the Canton Mill are
consistently well below this 100 color unit threshold.
Color in the mill's effluent is not injurious to aquatic life or wildlife.
Palatabilitv of Fish — Stream water color is a result of lignin, a natural material that
does not affect the taste of fish. Color is not a parameter associated with fish palatability.
Secondary Recreation - As discussed in Section 5.0, recreational use of the Pigeon
River in North Carolina is increasing. There is a successful commercial rafting industry
in Tennessee. Color is not impeding recreational use of the river.
Aesthetic Quality - An examination of water quality standards for color in the 27 states
in EPA Regions 1-5 showed that 22 of the states relied on a narrative standard similar to
North Carolina. Most of those states have not adopted any numeric interpretation of their
color standard.
For the Pigeon River, no numeric interpretation of the narrative color standard has been
established by the state of North Carolina. Fifty (50) units of true color, measured in
platinum cobalt units and used for the Canton Mill Color Variance, is EPA's
interpretation of the North Carolina standard. In choosing 50 color units, it is believed
that EPA relied on information derived from a 1975 NCASI Study. This study focused
on perception of color concentration changes detectable to human observers in streams

receiving pulp mill effluents (NCASI Technical Bulletin No. 283, A Study to Define
Changes in Pulpmill Effluent-Contributed Color in Receiving Waters Detectable to
Human Observers, December 1975).
Perception of stream color is subjective and varies due to environmental factors including
light conditions, water depth, bottom visibility and contrast, water turbidly, position of
the observer and land uses adjacent to the stream. Perception of change in color is not an
objective standard and should not be the single factor used to assess compliance with the
aesthetic component of the Color Standard.
The aesthetic quality of the Pigeon River is best measured by actual use of the river, the
ecological health of the river and property values in the surrounding community.
Recreational use of the river in North Carolina is increasing. There is a successful
commercial rafting industry in the Tennessee portion of the river. There is a diverse and
healthy aquatic community in the Pigeon River, reflecting dramatic improvements since
1988. Property values in Haywood County, including land along the Pigeon River below
the Canton Mill, have increased by more than forty percent (40%) since 2002. These
factors demonstrate that the aesthetic quality of the Pigeon River is not adversely affected
or impaired. The aesthetic component of the Color Standard is met.
Designated Uses - The Pigeon River is classified as "Class C waters"in the State of
North Carolina. Designated uses for this classification are: aquatic life propagation and
survival, fishing, wildlife, secondary recreation, and agriculture. As documented in this
report all designated uses for the Pigeon River are supported.
6.3 Conclusion
The Blue Ridge Paper Canton Mill has achieved remarkable reductions in effluent color
since 1988 that have continued during the 2001 Permit term. The reductions in effluent
color are reflected in reduced color levels in the Pigeon River below the Canton Mill.
There is a diverse and healthy aquatic community in the river below the Mill. The river
is being used for secondary recreation in North Carolina and Tennessee. All designated
uses of the river are supported. At the current level of Canton Mill effluent color
performance, color in the Pigeon River below the Mill complies with the North Carolina
Color Standard.

i
_tiver on 13 Feb
Subject: Blue Tint in River on 13 Feb
From: [e-mail]
Date: Wed, 14 Feb 2007 10:27:32 -0500
To: [e-mail]
CC: [e-mail],[e-mail], [e-mail]
2/14/2007
Re: Blue Tint in River on 2/13
Blue Ridge Paper Canton Mill
Roger Edwards, DWQ—
You requested a short summary of the subject event.
After investigation, we confirmed that the blue tint in the Pigeon River reported on morning of 2/13 was
result of a paper dye release to our wastewater plant that occurred shortly after 12 noon on 2/12. The
MSDS for the dye material is attached. The dye was not apparent in any of our internal wastewater
samples for 2/12, and our wastewater operators did not have evidence of any problems until daylight on
2/13 after the dye material had processed through secondary treatment. We contacted Keith Haynes of
your office at 8 am on 2/13 and began our investigation.
The dye is an optical brightener used in paper production. It is a non-hazardous material derived from
natural plant substances called stilbenes. The dye is applied directly to paper at the paper machines.
Concentrated dye was inadvertently sewered when a new dye handling system malfunctioned during a
power supply disruption shortly after 12 noon on 2/12 at our No. 20 paper machine. We identified the
root cause of this failure and will modify the control system to interlock the dye supply when power
fails.
We had discussions with Greg Shuping of Haywood County Emergency Management throughout the
day on 2/13 concerning the river and our investigation.
Please contact us if you need additional information.
Paul Dickens
Manager,Environmental Affairs
Blue Ridge Paper Products, Inc.
[e-mail]
828-646-6141 FAX [phone]
Content-Type: application/octet-stream
Seccobrite 4MA.pdf i
Content-Encoding: base64
1 of 1 2/14/20073:37 PM

8276462905 MEDICAL MEDICAL 10:40:05a.m. 02-13-2007 218—
,a2b 646 2367 # „/ ,7
NEW
SECCO TECHNOLOGIES, LLC ?
P. O. BOX 917
3RAHAM, N.C. 27253
FEL: (336) 261- 0490 SG�`i0
FAX: [phone]
MATERIAL SAFETY DATA SHEET
CHEMICAL EMERGENCY CALL CHEMTREC 1-800-424-9300
1 PRODUCT INF.ORMA-.10
PRODUCT TRADE NAME SECCOBRITE® 4MA LIQUID
SYNONYMS NONE
CHEMICAL FAMILY Triazlnyl Stilbene
C.I. Fluorescent Brightener220
INTENDED USE Fluorescent Whitening Agent for Paper
National Fire Proteollon Association(NFPA)Rating:
IEALTH 0 FLAMMABILITY 1 REACTIVITY 0
Hazardous Materials Identification System(HMiS)Rating
HEALTH 0 FLAMMABILITY 1 REACTIVTY 0 PERSONAL PROTECTION D
This Material Safety Data Shoat comPltes with 29 CFR 1910.1200 OSHA Communication Standard
2 ° Hi4ZFDS IENMFiGhilON.{.1'.1 .},
EMERGENCY OVERVIEW
FHealth;
Liquid
Yellow
Trace
This product has no known adverse effect on human health.
None known.
OSHA Hazardous Substance: This material is classified as NOT HAZARDOUS under OSHA regulations.
rotential Health Effects : None known
Primary Route(s)of Entry; Ingestion,Inhalation,Eyes
A;
Page Y of 7

8276462905 MEDICAL MEDICAL 10:40:17a.m. 02-13-2007 318—
:628 645 2367 # 12/ 17
' Created on sr.Wo06 10.08:00 AM
Seccogrlte 4MA Liquid
f3 ..:.'.C' 1.7
QMP.giSITIONf�IN'�F#�[�iEfNTrINFbRM�1`TION
Com onenis =CASer Wei ht##On 2,2'—(1,2-ethenediyl)bis[S-[[4-[bis(2- 9 18-28%-[g4-sulfophenyl)amino]-1,3,5.tdazin-salt
This product does NOT contain any of the following chemical compounds:
Lead,cadmium,mercury or hexavalent chromium above a total of 1 Do ppm.
Phthalates
Alkytphenoletoxylates(APEO)
MAK III (German Azo Ordinance)Amines
PCB
E .;FiRSR Alb IiAASURES,
,
Eyes: In the case of contact with eyes,rinse immediately with plenty of water and seek medical
attention.
Akin Wash thoroughly with soap and water, remove contaminated clothing and footwear. Wash
clothing before reuse. Get medical attention if irritation should develop.
Inhalation, Remove to fresh air. If not breathing, give artificial respiration. If breathing is difficult,give
oxygen and get immediate medical attention,
Ingestion : Do not induce vomiting. If vomiting should occur spontaneously,keep airway clear- Get
medical attention.
5 s ,: FR>=, IGItT►NCx�MEA9llRE'a'F� '� . A: r :?:
..l
Fire Fighting Measures: Standard procedures for chemical fires.
Suitable Extinguishing
Media: Carbon dioxide,dry chemical,foam or water spray,
PIre Fighting Equipment: Wear self-contained breathing apparatus and protective suit.
.[azardous Combustion
Products: Burning may produce oxides of carbon,nitrogen or sulfur.
Page 2 of 7

..................
8276462905 MEDICAL MEDICAL 10:40:32 a.m. 02-13-2007 4/8�
;828 646 2367 4 13/ 17
Created on Etamoas 10:08:00 AM
SOCCOBefte 4MA LfquId
As 1
Cleanup Instructions
Stop leaks. Clean up large spills with vacuum truck. Soak up small spills with Inert
absorbent material(e.g.sand)and place In labeled waste container for disposal. Wear
adequate personal protective clothing and equipment.
RATON .......
Handling: Avoid contact with eyes,skin and clothing. Wear chemical splash goggles,gloves and protective
clothing when handling. AvDid breathing spray or mist Use with adequate ventilation and employ
YEI3081101Y Protection where spray or mist maybe generated.
Storage Store Product inclosed containers between 40—115 OF (5 -450C)outPfdir I act sunlight.
It Is recommended mix product before using. Product,If frozen,may be recovered by thawing and mixing. Recmimended materials of construction for permanent service include FRP,Teflon,
and 316L SS.
FOR INDUSTRIAL USE ONLY.
Exposure Guidelines: There are no OSHA orACGIH exposure guidelines available for component(s)of this product.
Personal Protects ysEQUIPment '
Eye I Face Protection: Wear splash Proof chemical goggles or face shield.
"Skin Protection:
Wear chemical resistant gloves and protective clothing.
Respiratory Protection: Use NIOSH approved respirator as needed to mitigate exposure to product mists.
Engineering Controls: Work In well ventilated areas.
RIM :7;�';;111
"hysical Form: Liquid
--_olor:
Odor: Amber
Boiling Point: Trace organic
Freezing/melting point: >100 OC(>212'OF)
<-5qC(<2a*F)
Page 3 of 7

8276462905 MEDICAL MEDICAL 10:40:49 a.m. 02-13-2007 518�
:62a 646 2367 {, 14/ 17
Created on 61912006 10:08A0 AM
Seocoerite 4MA Liquid
- Solubility in water. Miscible
Specific Gravity: 1.10-1.13 @ 25°C
Viscosity; <100 Cps @ 25 4C
Vapor Density: Not determined
Vapor Pressure: Not determined
PH: 8.5—10.5
Percent Volatile; Not determined
VOC: 0% (EPA Method 24/24A)
Partition Coefficient(tog pow): -2 83,20 4C
Autoignitlon Temperature. Not determined
Decomposition Temperature: Not determined
E 1/1 (water,350 nm): 550
Conductivity: 25-60 mS 0 25 4C
Flammability Limits in Air: Not determined
Upper Not determined
Lower Not determined
Flash Point(method): >93 4C (>200 OF);Tag Closed Cup
40 ;S7A81 1TYAlbirdCTIU ' �h ^
I
�.. w.. ....e R.:.cuo ta,,.xn ui�Ma a • • •.
Stability: Stable(Shelf Life=1 year)
;onditions to Avoid: None known
Incompatibility: Product formulation is Incompatible with acidic conditions and cationic materials
(precipitation). Product performance Is Impacted by Ultra Violet absorbing materials
(TiO2,quenchers)and polyvalent cations(hard water).
Hazardous Decomposition Products: No decomposition expected under storage conditions indicated.
Possibility of Hazardous Reaction: None expected
TOXIGOL®GIC 7
Acute Oral Toxicity: LD50:>15,380 mg/kg (Rat) (active component)
Acute Dermal Toxicity: LD50:>3,000 mglkg (Rabbit) (active component)
Acute inhalation Toxicity: LC50:>17,600 mg/ma (Rat) (active component)
Eye irritation: Not an irritant (Rabbit)
17;kin Irritation: Not an irritant (Rabbit)
Skin Sensitization : RIPT(Humans)—Not a primary irritant or sensitizer.
Carcinogenicity: None of the components in this product at concentrations greater than 0.1 %are
I
listed by IARC,NTP,OSHA or ACGIH as a carcinogen.
Page 4 of 7

827 646 2905 MEDICAL MEDICAL 10:41:04 a.m. 02-13-2007 6/8�
:62a. 646. 2a67 tt IS/ 17
Created on 5/9/2008 10:08:00 AM
SeccoSrite 41VIA Liquid
Carcinogenicity Studles: CI FS P20 was not carcinogenic in rats.
Mutagenicity: Ames Assay—negative
Teratogeniclty: Negative(Rabbit)
Neurotoxielty: Not determined
Chronic Toxicity: Not determined
ECOtO'CalCl4UN�0 IUTATIgJV
n"t>
4.
Toxicity to Fish: LC50:> 100 mg/L (96 hrs
LC50:>Joao mg/L (96 hrs) (Rainbow trout)
NOEC=100 mg/L (96 hrs) (Rainbow trout)io rio)
NOEC=859 mg/L (14 d) (Brachydanio rerfo)
Toxicity to Invertebrates: LC 50 >1000 mg/L (24hr) (Daphnia magna)
NOEC=10o mg/L (48hr
(Daphnia magna)
oxicity to Algae: EC50> 1000 m /L 96hr. 9 ( ) (Scenedesmus subsplcatus)
Foxiclty to Sewage Bacteria: Not determined
Activated Sludge Respiration
lAhibition Test: No inhibition at 300 mg 1 L
Biological Oxygen Demand(B0D): <0.01 g/g
Chemical Oxygen Demand(COD): 023 g/g
Total Oxygen Demand(TOD). Not determined
Biodegradability: Not determined
Bioaccumulation; Not determined
Other Environmental Data. None
13 , :.DI$PbSA�L` ONSIbER31QNS_" �r r
:taste Disposal: Dispose of product in accordance with applicable federal,state and local regulations.
Containers: Emptied containers should be rinsed and returned to Sacco Technologies, LLC.
Page 5 of 7

8276462905 MEDICAL MEDICAL 10:41:16 a.m. 02-13-2007 71t?
:alb 646 2367 4 Is/ 17
Created on 519MOCS 10:08:00 AM
SeccoBrlte 4MA Liquid
1.14. "'TRANSPORTMFOR IlAMO.N; ;
1
U.S.Department of Transportation(DOT): Not regulated
International Maritime Dangerous
Goods 01VIDG): Not regulated
International Air Transportation
Authority(IATA): Not regulated
15 R9GWATORKINFORIIliA�fON'''
FEDERAL REGUI ATIONS
i
OSHA Hazardous Substance: Non hazardous under OSHA.
lean Air Act—
Hazardous Air Pollutants(HAP): This product does not contain any Hazardous Air Pollutants(HAP),as
defined by the U.S.Clean Air Act Section 112(40 CFR 61).
Clean Air Act—
Volatile Organic Compounds(VOC): This product does not contain any SOCMI Intermediate or Final Volatile
Organic Compounds(VOC),as defined by the U.S.Clean Air Act Section
111 (40 CFR 60A69).
Clean Air Act—
Ozone Depleting Substances(ODS): This product does not contain,nor was manufactured with,any Class 1 or
Class II ozone depleting substances (ODS)as defined by the U.S.Clean Air
Act Section 602(40 CFR 82)
Clean Water Act—
Priorily Pollutants: This product does not contain any priority pollutants listed under the U.S.
Clean Water Act Section 307(Priority Pollutant List) (40 CFR 401.15)
lesource Conservation and
Recovery Act(RCRA): Not a hazardous waste under RCRA(40 CFR 261.21)
SARA Section 302—Extremely Hazardous
Substances(EMS): This product does not contain any components regulated under Section 302
as Extremely Hazardous Substances.
'ARASection 304—CERCLA Hazardous
ubstances: This product does not contain any components regulated under Section 304
(40CFR 302)as hazardous chemicals for emergency release notification.
Page 6 of 7

8276462905 MEDICAL MEDICAL 10:41:30 a.m. 02-13-2007 a/8�
- ' :626 646 2367 k 17/ 17
Created on EN1200610D8:00 AM
SeccoBrite 4MA Liquid
SARA Section 311/312 Hazard
;ommunication Standard(HCS): This product is not regulated under Section 3111312 HCS(40 CFR 370)
SARA Section 313 Toxic
Chemical List(TCL): This product does not contain any components listed on the Section 313
Toxic Chemical List.
TSCA Section 8(b)Inventory Status: All component(s) of this product are either exempt or listed on the TSCA
Inventory,
TSCA Section 5(e)Consent Orders: This product is not subject to a Section 5(e) Consent Order.
TSCA Significant Now Use Rule(SNUB): This product is not subject to a Significant New Use Rule(SNUR).
TSCA Section 5(f): This product is not subject to a Section 5(f)/6(a)rule.
c .
TSCA Section 12(b)Export Notification: This product does not contain any component(s)that are subject to a
Section 12(b) Export Notification.
STATE REGULATIONS:
California Proposition 65: This product does not contain any components)currently on the California
list of Known Carcinogens and Reproductive Toxins.
Pennsylvania Right-To-Know: This product does not contain any component(s)currently listed.
INTERNATIONAL REGULATIONS:
Chemical Weapons Convention: This product does not contain any oomponent(s)listed under the Chemical
Weapons Convention Schedule of Chemicals.
Comestic Substance List(DSL,Canada): All components are listed on the DSL.
)OTH1E'R-INFQFtfU A`fION `
PREPARED Sr. F.Gouzoules, Ph.D. DATE: May 1,2006
Product Safety&Regulatory Manager LAST REVISED: May 1,2006
CHEMICAL EMERGENCY TELEPHONE (CHEMTREC) 1 -800 424-9300
A8 Information,recommendations,and suggestions appearing herein conceming ourproduots based upon tests and data believed to be reliable.
owever,It Is the users responsibility to determine the safely,toxicity,and suitability for his own use of the product described herein. Since the actual use
r others Is beyond our control,no guarantee,expressed or implied,is made by Sacco Technologies,LLC as to the effects of such use;the results to be
totalned er the safety and toxicity of the product nordoes Sacco Technologies,LLC assume any liability arising out of use,by others,of the product
pareferred to herein. The information herein is not to be construed as absolutely complete since additional information may be necessary or desirable when
rticular or exceptional cond8lons or circumstances exist or because of applicable laws or government regulations.
Page 7 of 7

of W ATF9 Michael F. Easley
Governor
�O pG ©�,[, William G.Ross,Jr.,Secretary
NCDENR North Carolina Department of Environment and Natural Resources
Alan W.Klimek,P.E., Director
Division of Water Quality
January 30, 2007 .
Donald F. Anderson �� y
Senior Environmental Engineer I '
Engineering and Analysis Division JAN 3 1 2007
Environmental Protection Agency
EPA West - Connecting Wing; Rm 6233V WATER QUALITY SECTION
1200 Pennsylvania Avenue, NW A8HEVILLE REGIONAL OFFICE
Washington, DC 20460 4'
Subject: Blue Ridge Paper Products, Inc.
NPDES Permit NC000
Haywood County
TRW Representatives from North Carolina
Dear Mr. Anderson:
Division of Water Quality hereby delegates Mr. Roger Edwards, Supervisor,
Asheville Regional Office, Surface Water Protection, and Dr. Sergei Chernikov,
Environmental Engineer II, Western NPDES Program of our staff to represent the
State of North Carolina on the Technology Review Workgroup (TRW). The TRW
representation is necessary for the renewal of Blue Ridge Paper Product's NPDES
Permit. Both Mr. Edwards and Dr. Chernikov look forward to their participation on
this workgroup.
Sincerely, `
Alan W. Klimek, P.E.
Cc: NPDES File
shevillevRegiona Office%Roger Edward
EPA Region IV, Roosevelt Childress/Karrie-Jo Shell
Paul Davis, P.E., Director, Tennessee Division of Water Pollution Control
6th Floor, L&C Annex
401 Church Street
Nashville, TN 37243-1534
N.C.Division of Water Quality/NPDES Unit Phone:[phone]
1617 Mail Service Center,Raleigh,NC 27699-1617 fax:[phone]
Internet:h2o.enr.state.nc.us DENR Customer Service Center..1 800 623-7748

�,ue Ridge Paper]
Subject: [Fwd: Re: Blue Ridge Paper]
From: Alan Klimek<[e-mail]>
Date: Fri, 19 Jan 2007 11:19:28 -0500
To: Paul Rawls <[e-mail]>,Matt Matthews <[e-mail]>, Susan A
Wilson<[e-mail]>, Sergei Chemikov <[e-mail]>, Jeff
Manning<Jef£[e-mail]>,Roger Edwards<[e-mail]>
CC: Coleen Sullins<[e-mail]>
Perhaps EPA has decided that this is a big fish needing some frying.
Alan
Subject: Re: Blue Ridge Paper
From: Alan Klimek<[e-mail]>
Date: Fri, 19 Jan 2007 11:17:20 -0500
To: Dan Oakley<[e-mail]>
CC: "Mary P. Thompson" <[e-mail]>
Perhaps we should meet to discuss and agree on a path forward. I have a conference
call that Giatinna has set up for 1:00 on Jan 26 to talk about this. I do not agree
with EPA's position.
Alan
Dan Oakley wrote:
I talked with Mary Wilkes on 01/17/07. She says Jim Giattina is the primary
technical person, and that he would be getting back to you soon; I'm not sure if
it would be before the next TRW meeting or not. From the legal perspective, she
confirmed that EPA would be required to stick to its. previous numerical
interpretation of our narrative standard (50 c.u. downstream . -- she was not
certain if that was end-of-pipe or at HEPCO) until the state presented a basis for
a different interpretation.
We then talked in general terms about how best to get to permit issuance in light
of the current fact that the EPA wqs interpretation is not being met. She sees 3
options, all of which are variants of the same theme.
1) The state proposes a wqs revision, with supporting documentation (e.g. , a
color test like was done previously) outside the permit process. This could be
either statewide or Pigeon River only, I think. The timing on this is significant
because the permit may need renewal prior to any wqs revision taking place. 2)
The state renews the permit and the variance, in much the same manner as 2001,
with different benchmarks for further improvements if. the TRW recommends them.
3) The state proposes a permanent change to the uses via an Use Attainability
Analysis. This did not seem like a viable option, but it was mentioned.
In short, it looks like we will need to provide them with a definitive basis for a
different interpretation of our narrative wqs, either during this renewal process,
or during the next 5-year permit term. Mary Wilkes feels the variance will still
be needed until that showing is made and accepted by EPA.
Alan Klimek wrote:
INo objections. In fact it seems they may need some prodding so we can move
forward. They still need that technical review group to confirm that the
company has done about all that can be done wrt removing color.
1 of2 1/19/2007 11:57 AM

,clue Ridge Paper]
Alan
Dan Oakley wrote:
Billy Clark called me this week, to give me an update on the company's
position re the elimination of the color variance. He has talked with
Frank Crawley as well. Billy asked me to call Mary Wilkes, EPA counsel, to
see what she is thinking (Mary also handled this permitting for EPA in 1996
and 2001) . I plan to do that next week, unless you have any objections. I
will let you know what she says.
j Content-Type: message/r&822
,Re: Blue Ridge Paper:
Content-Encoding 7bit
2 of 1/19/2007 11:57 AM

0Q W A TE9 `•-- .. Michael F.Easley,Governor
Ross Jr.,Secretary
r "REGIONAL
o (�vuQnIn nt Natural Resources
... . U ISimek,P.E.Director
iv r n of Water Quality
' 2007January 4,2007Y SECTIONNAL OFFICE
The Honorable Patrick U. Smathers r
Town of Canton
58 Park Street
Canton, North Carolina 28716-4324
SUBJECT: Town of Canton
Blue Ridge Paper Products WWTP
Construction of Flood Retaining Wall
Project No. XP96447306-0
Final Inspection
Dear Mayor Smathers:
The Construction Inspection Group (CIG) of the Construction Grants and Loans Section performed'a
final inspection for the federally funded portion of the subject project on
December 18, 2006. A copy of the inspection report is attached for your records.
The project was substantially complete on November 1, 2006. Therefore, the initiation of operation
date for the purposes of the loan is November 1, 2006. A cutoff date of December 30, 2006 has been
established, after which additional project costs incurred will not be eligible for STAG grant participation.
If you and/or your engineer have any questions regarding this inspection, please contact me at (919)
715-6220.
Sincerely,
Ontonio V. Evans,P.E.
Environmental Engineer
Construction Inspection Group
AVE/sd
Attachment
cc: McGill Associates
DWQ-Asheville Regional Office
PMB/STAG/Jennifer Kinghorn
CIG-Antonio Evans
Construction Grants and Loans Section One
1633 Mail Service Center Raleigh NC 27699-1633 NorthCaTolina
Phone:[phone]/FAX:[phone]/Intemet:www.nccgl.net ' �/'
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer.Paper f�/a atuivally

RL� k II V ,E �
2 20 , � 9
AUG 06 �J�Qad7 age
BLUE RYkl'�(;,"E WATERQUALITYS`_ OFFICE
�.e AGHEVILLE REGIONAL OFFICE
PAPER PRODUCTS INC.
July 31, 2006
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 2220
Connie Brower
DENR
Division of Water Quality Planning Section
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: 2004-2006 Triennial Review of Surface Water Quality Standards
Blue Ridge Paper Comments
Dear Ms. Brower:
Blue Ridge Paper (Blue Ridge) would like to request a copy of any comments made during the
public hearings on the color variance.
Blue Ridge has submitted extensive information related to the color variance through the NPDES
permit renewal process. Those submittals constitute the Company's comments on the color
variance. If you have any questions, please call at the number below.
Sincerely,
J. Glenn Rogers
Water Compliance Coordinator
828-646-2874
cc: ✓Roger Edwards
Surface Water Protection Supervisor
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
2090 US Highway 70
Swannanoa, North Carolina 28778
Blue Ridge Paper Products - Environmental Group
175 Main Street e PO Box 4000
Canton, North Carolina 28716 e 828-646-2000
Raising Your Expectations

Ms. Connie Brower—NC DWQ
31 July 2006
Internal Distribution:
cc: C-File Water
D. Brown
B. Williams
P. Dickens
Blue Rid.ge Paper Products Inc. - Environmental Group
175 Main Street o PO Box 4000
Canton, North Carolina 28716 o 828-646-2000
Raising Your Expectations

,.w for Blue Ridge Paper
Subject: Fw: 316a review for Blue Ridge Paper
From: [e-mail]
Date: Thu, 27 Jul 2006 09:11:52 -0400
To: [e-mail]
CC:[e-mail], [e-mail],[e-mail],
[e-mail]
7/27
Roger-
Derric Brown asked that I forward this to you. EPA sent a copy to Sergei, but not to you. We will start
thinking about these comments,but will wait until DWQ has decided on what, if any, comments to
formally make on the 316a study.
I am also sending a copy to Dr. Wilson and Dr. Coutant at UTK.
Bryn Tracy has been informally discussing his comments on the 316a with Dr. Wilson. We really
appreciate Bryn's open dialogue. We have an addendum ready that addresses Bryn's good input and
corrects a few errors in table data that Brynn found. Question-should we go ahead and submit this
addendum or wait until we get formal comments on the 316a?
Paul Dickens
Manager, Environmental Affairs
Blue Ridge Paper Products, Inc.
[e-mail]
828-646-6141 FAX [phone]
-----Forwarded by Paul Dickens/Canton/B1ueRidge on 07/27/2006 08:55 AM -----
-----Original Message-----
From: [e-mail]
[mailto:[e-mail]]
Sent: Monday, July 24, 2006 11:32 AM
To: [e-mail]
Cc: [e-mail]; [e-mail];
[e-mail]; [e-mail];
[e-mail]; [e-mail]
Subject: 316a review for Blue Ridge Paper
Mike,
I am in the process of reviewing the 2005 316a Demonstration Study
pertaining to the Blue Ridge Paper Mill. The mill was required to
complete a 316a demonstration in accordance with EPA's 1997 draft 316a
Guidance document as a condition of their 2001 permit. My
understanding of the EPA guidance is that applicants must confer with
the state agency or EPA regarding a study plan prior to commencing with
the data collection. The study plan was submitted to NC sometime in
2005, but not to EPA.
1 of 2 7/27/2006 9:43 AM

.w for Blue Ridge Paper
My review is based on the assumption that the mill followed the EPA 316a
Guidance for the demonstration study. I need the following information
addressed or submitted in order to complete my review:
1. The mill determined that the river was not classified as one of "Low
Potential Impact" for fish. Therefore, fish sampling was required.
Regarding the recommended screening procedures (page 18) for fish
contained in the EPA 316a Guidance, I request the mill provide an
explanation why they only sampled fish for two months rather than
monthly sampling for a longer period of time as stated on page 30 of the
EPA Guidance. Page 30 states:
"For field studies, experimental design should be appropriate to
determine the general characteristics of all life stages of fishes
inhabiting the primary and far field study areas. The data collected
should allow for a comparison of the relative importance of these two
areas with respect to species composition, numbers of each type, growth,
and reproduction.
Samples should be taken at monthly intervals to provide data
representing seasonal and life stage habits except during and
immediately following periods of spawning when a more intense sampling
effort should be provided. "
Note that the primary study area (page 78) is defined as "the entire
geographic area bounded annually by the locus of the 2 degree C above
surface isotherms as these isotherms are distributed throughout an
annual period. The reference ambient temperature shall be recorded at a
location agreed upon by the Regional Administrator/Director. " "Far
Field Study Area is defined on page 76 as "that portion of the receiving
water body, exclusive of the primary study area, in which impacts of the
thermal discharge and its interaction with other pollutants are likely
to occur. The area should include:
1. Zones where the habitats are comparable to those existing in
the primary study area, and
2 . The zones inhabited by populations of organisms that my
encounter the thermal effluent during their life history. The actual
boundary of the far field study area should be agreed upon by the
Regional Administrator/Director. "
2. The mill should provide a map of study area (see page 32) that
depicts the 2 C isotherm lines, the primary study area, the area of
potential damage (see page 74) and the reference area(s) . It would
also be helpful for my review if the mill could overlay the information
in table 4 .3 .2 on page 61 (Comparison of IBI scores) on the isotherm
map as well as hydrologic data (2005 average monthly flow) for the river
(see page 47) .
3 . Lastly, I would like for the mill to submit (electronically) the
temperature data collected in 2000, 2001,2002 and 2003 for the same 14
stations (11 main stem plus 3 tribs) sampled for the 2005 study. Also,
for the 316a studies performed for previous permits (1995 and 2000) , I
would like to know the dates the mill sampled for fish.
Once I get this information, I plan to forward the 2005 316a
Demonstration Plan and supporting information to Dave Melgaard for his
review.
Thanks, Mike.
Karrie-Jo Robinson-Shell, P.E.
404/562-9308
2 of 2 7/27/2006 9:43 AM

BLUE RIDGE JuL 2 6 2006
DD
PAPER PRODUCTS INC.
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
25 July 2006
Overnight Via DHL
Mr. Roger Edwards
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
Division of Water Quality
2090 US Highway 70
Swannanoa, North Carolina 28778
Subject: 2006 Liebergott Report
2006 NCASI Color Study
Blue Ridge Paper Canton Mill
NPDES Permit#NC0000272
Dear Mr. Edwards:
Blue Ridge Paper Products Inc. is submitting two reports to the Technology Review Workgroup
(TRW) for reference and review as part of 2006 NPDES permit renewal:
2006 Leibergott Report
2006 NCASI Color Report
These reports supplement the May 2006 Blue Ridge Paper Color Compliance Report.
2006 Leibergott Report
In May 2006, Blue Ridge Paper contracted with Liebergott Associates, Inc. and GL&V USA to
update the 2001 Bleach Environmental Process Evaluation and Report (BEPER also known as
the 2001 Liebergott Report). The 2006 Leibergott Report is an assessment of the progress made
at the Canton Mill on the recommendations from the 2001 report. It includes:
• a review of the results of changes implemented and improvement achieved since 2001
• an audit of current process conditions with feedback on opportunities for additional
improvement
• recommended potential technology options that could further improve environmental
performance
Blue Ridge Paper Products
175 Main Street a PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mr. Roger Edwards, NC-DENR
25 July 2006
The Executive Summary of the 2006 Liebergott Report states:
"This report concludes that Blue Ridge Paper Products has done a very good job
implementing the 2001 recommendations and has made additional environmental
improvement as a result. An updated comparison of the Canton Mill to other Kraft mills
in the USA, Canada, and Finland indicated that there still are no COD, BOD, or color
values lower than those achieved by the Canton mill. Given the current state of
adaptable technology and the mill's already high level of environmental performance,
fixture improvements are expected only to be marginally incremental. The potential for
future improvements are described in the body of this report."
2006 NCASI Color Study
The National Council for Air and Stream Improvement(NCASI) is the environmental research
organization of the pulp and paper industry. In early 2006, NCASI sponsored a study of color
control technology for wastewaters from Kraft pulp mills. The last such industry study was done
in 1995. Blue Ridge Paper's Canton Mill was one of five participating mills in the study. The
contractor for the NCASI study was EKONO, Inc, a consulting firm that specializes
benchmarking studies for the pulp and paper industry.
The 2006 NCASI Color Study compliments the 2006 Liebergott Report. It documents the
current state of art for Kraft pulp wastewater color control. The Blue Ridge Paper Canton Mill is
Mill A in the NCASI Color Study Report.
Summary
If there are any questions regarding the 2006 Liebergott Report or NCASI Color Study or if more
copies are needed for additional members of the TRW, please contact us at the numbers below.
Sincerely,
J. Glenn Rogers Paul Dickens
Water Compliance Coordinator Manager, Environmental Affairs
828-646-2874 828-646-6141
Blue Ridge Paper Products Inc.
175 Main Street e PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mr. Roger Edwards, NC-DENR
25 July 2006
Enclosures:
2006 Update—Bleach Environmental Process Evaluation and Report
2006 NCASI Color Study—Review of Color Control Technologies and Their Applicability to
Modern Kraft Pulp Mill Wastewater
cc: (w/encl): Don Anderson
US Environmental Protection Agency
Airel Rios Building
Office of Science and Technology (4303 T)
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Sergei Chemikov
Environmental Engineer I
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Karrie-Jo Robinson-Shell
USEPA REGION 4
61 Forsyth Street, S.W.
Atlanta, GA 30303-8960
Paul E. Davis, P.E., Director
6th Floor, L&C Annex
401 Church Street
Nashville, TN 37243-1534
cc: C-File Water
D. Brown
J. Clary
B. Williams
Blue Ridge Paper Products Inc.
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

BLUE RIDGE
PAPER PRODUCTS INC.
11 July 2006
Mr. Keith Haynes
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
Division of Water Quality
2090 US Highway 70
Swannanoa,North Carolina 28778
Subject: Canton Mill Color Request
Blue Ridge Paper Canton Mill
NPDES Permit#NC0000272
Dear Mr. Haynes:
Blue Ridge Paper Products, Inc. (Blue Ridge) is providing follow up information on the events
that occurred on July 6, 2006 and led to elevated color levels in the Pigeon River. Around
11:00am a black liquor line that connects two tanks in the Chloride Removals Process (CRP)
became completely plugged. This line blockage caused a 15-20 minute overflow of one of those
tanks. The black liquor material from the overflow entered the mill's sewer system and
wastewater treatment plant.
Investigation revealed that solids from the CRP process had built up in the line and a large piece
of material broke off and plugged the line. Operations personnel immediately became aware of a
loss of black liquor through internal monitoring systems and manually by-passed the system to
stop the release. It is estimated that approximately 15,000 gallons of material was released to the
wastewater treatment plant in a very short period of time. Although the event led to elevated
color levels in the mill's effluent, it did not disrupt operations at the mill's wastewater treatment
plant and monthly color is expected to be well in compliance. This is the first time this has
happened at the Canton mill since the inception of CRP in the mid-1990s. The CRP process has
been and remains an integral part of our overall color reduction process. If you have any
additional questions regarding this matter please don't hesitate to call.
Sincerely,
J. Glenn Rogers
Water Compliance Coordinator
828-646-2874
Blue Ridge Paper Products- Environmental Group
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

ATF9 Michael F. Easley
G Governor
Pfo
©DEANR William G. Ross,Jr., Secretary
North Carolina Department of Environment and Natural Resources
p Alan W. Klimek,P.E., Director
Division of Water Quality
June 9,2006
James D. Giattina,Director
Water Management Division
EPA Region IV,Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-8960
Subject: Response to EPA Scientific Panel
Study of Pigeon River
Dear Mr. Giattina:
The North Carolina Division of Water Quality(Division)has received the report from EPA Region IV entitled
"Pigeon River Science Panel Data Review and Recommendations". The Division has a number of serious
objections and comments that we would like to bring to your attention.
The report was written to satisfy Paragraph 33 of the Settlement Agreement between EPA,North Carolina,
Tennessee and several government and non-profit organizations. The Settlement Agreement,which called for this
study,was the result of a challenge by Tennessee and third parties to a 1996 NPDES permit issued for Champion
International paper mill (currently Blue Ridge Paper Products,Inc.)by the Division. Paragraph 33 of the
Agreement states that"EPA will lead in cooperation with North Carolina and Tennessee an independent
evaluation of current information on the Pigeon River". North Carolina was not involved in the development of
the report and was not provided an opportunity to comment. In addition,the Division believes that the presented
study is inaccurate, as it contains what we believe are numerous errors and omissions. Our detailed comments on
the report are included in the Appendix attached to this letter. The Division would be pleased to provide EPA
Region IV with any of the current benthic data, ambient water quality monitoring data on the Pigeon River,as
well as discharge and instream monitoring data gathered by Blue Ridge Paper Products.
We see no compelling reason for developing the report at this late date,especially in light of the considerable
progress that has been made in restoring water quality and aquatic life on the Pigeon River.Nevertheless, if EPA
Region IV believes further action is needed in this area, any effort to proceed should follow the provisions stated
in Paragraph 33 of the Settlement Agreement. We appreciate your time and attention to this matter and we also
look forward to continuing to work with you on improving water quality in North Carolina and adjacent states.
Sincerely,
Alan W.Klimek;
- D
JUN 13 2006
WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
N.C.Division of Water Quality I NPDES Unit Phone:[phone]:
1617 Mail Service Center,Raleigh,NC 27699-1617 fax:[phone]
Internet:www.ncwaterquality.org DENR Customer S6rvice Center.1 800 623 7748-
_..

Appendix
I. Issues within the Report as it Exists Today
Considering the comments already made, it is important to at least look at the Report as it exists to get
some consideration of the evaluation it offers.
In looking at the reason this report was being done—paragraph 33 of the December, 1997 Settlement
Agreement—the charge was "EPA will lead, in cooperation with North Carolina and Tennessee, an
independent evaluation of current information on the Pigeon River". The evaluation was to include a
convened group of scientists to:
1) evaluate existing data
2) identify additional data needed
3) and, if necessary, conduct an ecological assessment
Contrary to the charge, instead of a collaborative evaluation, it appears EPA assigned this task to a
group of three scientists,with no input from North Carolina. It appears the Panel tried to complete task
1) for data through 2004, made some recommendations that attempted to address task 2) (possible data
that could be collected in the future for conducting an ecological assessment), and for task 3) failed to do
an ecological assessment.
In relation to the data review, the report doesn't seem to incorporate significant data sources that are
available through NC and other agencies/groups, particularly the electronic databases within NC DWQ's
Environmental Sciences Section and the effluent and in stream monitoring data collected under the
NPDES permit. The staff at DWQ could have been extremely helpful in providing this information and
to providing the"Panel" with insight on the data and the extensive history of study within this
watershed. Some of the recommendations made by the "panel"clearly show a lack of knowledge about
the work that has been done on the river.
A significant amount of work has been performed during 2005 to document ecological improvements in
the river and to develop essential information for the 2006 permit renewal. Considering the report has
already been delayed for nearly ten years, it would seem prudent at this time to at least incorporate
recent data which would provide a better understanding of the river's ecological health today.
By limiting the data review process and by excluding the NC agency personnel with extensive
knowledge of the Pigeon and this ecosystem,this process failed to get a true and accurate look at the
issues as they exist today.
The Panel findings utilizing data from 1983 to 2004 seem to be:
1) Lack of continuity--data was not gathered continuously and consistently over the two decades
2) Sampling and methods of calculating benthic communities differ between NC and TN
3) Significant improvements in water quality occurred during the early 1990's
4) Substantial improvements to the benthic and fish communities have clearly occurred over time
5) Downstream fish communities show an increasing diversity of native species—suggesting
substantial improvement in the ecological condition of the Lower Pigeon River

6) Dioxin concentrations in fish has decreased substantially such that consumption advisories
have been eliminated in TN and rescinded to include only common carp in Waterville
Reservoir in NC
From those findings, there is no conclusion that the Pigeon River presents any ecological health risk and
the only human health risk appears to be for those people who may eat common carp from Waterville
Reservoir(this is a very low risk indeed). In looking at the data for dioxin and understanding the
changes at the mill, it is clear that dioxin is steadily decreasing in fish and should soon be at levels
where the last consumption advisory can be removed.
Although there was no stated reason or logical argument provided to conclude that a future ecological
assessment needed to be performed, the Panel recommended activities that could be done,presumably
by state agencies, in the future. They include:
1) Centralized banking of data
2) Periodic synoptic benthic surveys
3) Continuous DO, temperature, and conductivity monitoring at three places on the Pigeon River
and some unidentified number of major tributaries.
4) Reduce dioxin sampling of bottom feeding fish in Waterville Reservoir to once every five
years—all that is needed to confirm that dioxin will remain below levels of health concern.
Perhaps monitor dioxin in sediments and other biota.
5) Perform sediment transport modeling
6) A general list of ecological information about pollutant levels, stressors, organism responses,
predators, etc.
These recommendations are clearly beyond any scope of the intention of Paragraph 33 and would
represent an unsupportable portion of NC water quality monitoring budgets for the entire state. Should
EPA choose to fund the type of ongoing data collection on the Pigeon River,NC will be happy to
participate. These conclusions represent a"research project'view of this system rather than a realistic
review of the extensive database available on this system and the dramatic improvement in
environmental quality over the last few years. The"panel" failed to establish any basis for needing this
kind of unprecedented assessment. The Pigeon River system is well on its way to full recovery and is
currently meeting State and Federal standards in these regards.
Il. Specific Questions and Comments
1. p. i. We believe the three-week time constraint prevented the panel from developing a complete
and thorough report.
2. p. ii. The mill's dissolved oxygen monitoring record is extensive as are its DMRs.
3. p. iii. Synoptic surveys covering many points on the river is not feasible because much of the
river is not wadeable and we feel that EMAP Wadeable Streams sampling protocols should never
be used.
4. p. iii. Sediment transport modeling was performed already by CP&L in 1991 --refer to Lawler,
J. P. and B. H. Tracy. 1995. Environmental issues in relicensing hearings for Carolina Power
and Light Company's Walters Hydroelectric Plant on the Pigeon River,NC. Proc. Intemat.
Conf..Hydropower. J. J. Cassidy (ed.). Waterpower '95. San Francisco, CA. pp. 301 - 310. p.

5. p. 3. and p. 5. The data have been collected from the Pigeon River since at least 1940 and
possibly as early as 1908.
6. p. 4. All DWQ, BRP, and Progress Energy data are traceable to methods, SOPS, site descriptions,
reports, fish species analyzed for contaminants, QA/QC, etc.
7. p. 4. The Division disagrees with statement that there is "lack of any commonality in application
ofstation names". All sites are known by all researchers and are all geo-referenced.
S. p.4. (and throughout the report) NC benthic data was never asked for. We supply our data
electronically to anyone who asks for it but we were never asked for the data. A significant
amount of data are available on the web and all are available electronically or in hard copy.
9. p. 5. The Division believes that an unbiased report cannot be developed if all parameters are not
reviewed.
10. p. 7. Blue Ridge Paper(BRP) and DWQ have many "fixed stations" along the Pigeon,River that
are sampled at minimum monthly and some hourly, daily or weekly.
11. p. 8. The report does not mention BRP or DWQ discharge monitoring reports (DMR) and
ambient monitoring data; no mention of Progress Energy's 2004 data.
12. p. 9. and 10. DWQ benthic macroinvertebrate data have been collected following a consistent
SOP for nearly 20 years.
13. p. 10. The NC benthic program has the NCBI which is a Biotic Index not Biotic Integrity, and
the Tennessee IBI is a fishery index,not a benthic one.
14. p. 11. Benthic data collected by DWQ, BRP, and Progress Energy have always been readily
available.
15. p. 11. -- It is true that DWQ fisheries data are available only for tributaries to the Pigeon River.
We are not staffed to sample large rivers. Data are available electronically and in hard copy,but
it was never requested by the"Panel".
I& p. 11. DWQ was also a participant and one of the initial members on the Re-introduction Project
for the NC portion of the river.
17. p. 11. 2004 and 2005 data are available on reintroduction numbers.
18. p. 12. To the best of our knowledge, the DWQ staff has never put biological data into STORET,
therefore we don't know what data was extracted nor why it contains so many errors.
19. p. 12. The report did not consider BRP data from 2005 or 2000 or from earlier years.
20. p. 12. The Division was not contacted for fisheries data.
21. p. 12.NCDENR, 2004 is not in the references.
22. p. 13. The Division would like to note that TVA generally does not sample tributaries,they tend
to sample mainstem reaches of river while DWQ samples the tributaries.
23. p. 14. DWQ does not monitor for dioxins and furans, BRP and Progress Energy are required to
by NPDES permit and FERC License requirements.

24. p. 15. It may be that"no data were provided on the fish species sampled", but this information is
available. All fish tissue contaminant data collected by BRP, DWQ, and Progress Energy are
tracked by species and have been since the mid-I980s.
25. p. 15. The statement that W WTP discharge monitoring data were not available to the "Panel"is
not accurate. To the best of our knowledge the"Panel"has never contacted DWQ to request the
data.
26. p. 16. The report did not consider dioxin in sediment data collected by CP&L in 1991.
27. p. 18. 3rd paragraph. There are no "macrophyte beds" in the river. Their presence in 2002 was
due to an exceptional,prolonged drought and such beds were not seen before or since then. The
mats do not settle out in the reservoir and contribute to the organic loading of the reservoir.
28. p. 20. The "prolific weed growths"was a one-time event not seen previously or since then.
29. p. 20. The Division disagrees with the statement that habitat data are not reported, since 1998
every NC biological sample has a habitat form filled out at the time of sampling.
30. p. 21. The Division would like to emphasize that the Tennessee portion of the river is in a
different ecoregion than the upstream portion and is also of much larger size.
31. p. 21. Reference to green darter should be changed to greenside darter?
32. p. 21. One would not expect gizzard shad in high gradient, cool waters as are found in much of
the NC portion of the river.
33. p. 21. In the absence of the mill, it could be possible to predict what the fish community would
be like. There are other rivers the size of the Pigeon River in western NC from which such
comparisons could be made.
34. p. 26. Are fish found at depths of 30 -35 in near the dam? What are the dissolved oxygen levels
in the hypolimnetic waters? Do common carp inhabit such depths?
35. p. 27. There are few depositional areas above the reservoir, which is why.common carp still tend
to pick up a low dose of dioxins in the reservoir.
36. p. 27. Were temporal reservoir level fluctuations examined?
37. p. 27. The bypass reach of the Pigeon River is a very atypical reach in terms of flow and its fish
communities.
38. p. 28. The DMR data from BRP has always been readily available.
39. p. 28. The flow monitoring data are available at nine sites within the Pigeon River watershed in
NC.
40. p. 29. Dissolved oxygen has never been identified as a problem at the base of the bypass reach.
41. p. 30. Comments already provided for the I&M of Data.
42. p. 30. The fate and transport of dioxins in sediment and fish are known.

43. p. 31. Did the"Panel'review Lawler and Tracy (1995) or any of the FERC documents and
testimony of expert witnesses related to the issue of contaminated sediments?
44.p. 31. Is there any evidence of risk from bioaccumulation of toxins in higher predators(e.g., river
otters) in the Pigeon River system?
45.p. 31. Does the"Panel' understand that any future release of water from the dam will not be
from the hypolimnion and will not be transporting sediments from the reservoir to the bypass
reach?
46.p. 31. The database for fish tissue contaminants now includes more than 15 years worth of data,
probably one of the longest continuous monitoring of dioxins in the country. Therefore,
statement- "limited fish tissue contaminant concentrations" is inaccurate.
47. p. 31. As stated previously, the macrophytes growths was a one-time, limited event.
48.p. 31. Due to the gradient of the river, the only zone for contaminant deposition is in the
reservoir.
49.p. 31. Southeastern Fishes Council, 2003 is not listed in the References.
50. p. 32. What are the diets of river otters and great blue herons, ospreys or other birds of prey?
These species typically do not consume 5-10+year old common carp. The number of common
carp may actually be decreasing in the reservoir.
51. p. 41. The report does not utilize 2003 and 2004 data.

Cocke County Community Meeting
Blue Ridge Paper Products — Canton Mill
March 23, 2006
Agenda
• Welcome and Introductions
• Opening Remarks - County Mayor Iliff McMahan Jr. tap N
• Canton Mill since the Floods
• 2006 —Renewal of NPDES Permit �,�.1�aQ T1
• TDEC's Reintroduction efforts on the Pigeon— Mr. Jonathon Burr
• University of Tennessee' Involvement— Dr. Larry Wilson
Ms. Joyce Coombs
• Partnership and Collaborative Effort
• Native Fish Reintroduction
• Kids in the Creek— Ron Moser, Haywood Waterways Assoc.
• Future Meetings
• Lunch

WRONG TRACK?
Some Performance Track Facilities Report Increased Levels of Toxic Pollution
February 8,2006
The US Environmental Protection Agency advertises its "Performance Track"
program as a haven for companies with exemplary environmental records. In return for a
voluntary commitment to go "beyond compliance,"Performance Track corporations are
promised regulatory incentives, an"exclusive"right to be shielded from"routine"
inspections, free advertising (including photographs with the Administrator), and insider
access to senior decision-makers in government. EPA is expected to announce plans to
expand the program at a meeting with state environmental commissioners on February
22, and recently awarded $40 million in support contracts. The federal agency may ask
states to cut back on their own inspections of Performance Track companies at the
February meeting.
But at least some of the manufacturers reaping Performance Track rewards are
releasing more toxic pollution to the environment than they were before signing up to the
program. Thirteen large manufacturing plants with a significant history of toxic
emissions joined the program in 2001, its first year. The Environmental Integrity Project
compared emissions reported by these companies to the Toxics Release Inventory in
2000, the year before they joined Performance Track, with amounts reported in 2004, the
latest year for which information is available.
The data suggest that instead of leading the pack, some Performance Track
Members may be falling further behind. More specifically:
• Seven facilities reported increasing air emissions of toxic pollutants by a
combined total of more than 2 million pounds between 2000 and 2004 (see Table
A). Toxic pollutants include carcinogens (chemicals linked to cancer) as well as
pollutants that cause birth defects or other diseases. International Paper's
Androscoggin mill in Maine, one of the flagship Performance Track facilities,
more than doubled its toxic emissions between 2000 and 2004, while Monsanto's
chemical plant in Muscatine, Iowa, increased toxic air emissions more than 80%.
Ironically,EPA allows Performance Track Members to reduce their monitoring of
air toxics, even though emissions at some plants are clearly rising.
• Toxic air emissions from eleven of the thirteen companies include carcinogens
like acetaldehyde, ethylbenzene, formaldehyde, or lead. Six of these eleven
companies reported increasing air emissions of carcinogens by more than 164,000
pounds between 2000 and 2004 (see Table B). 3M's chemical plant in Guin,
Alabama, led the pack by more than doubling its emissions of ethylbenzene over
four years, with International Paper's Maine plant close behind with a 90%
increase in carcinogens overall.

• Three plants do not discharge toxic chemicals directly to surface water. Five of
the ten that do reported releasing 457,000 pounds more toxic pollution to nearby
rivers in 2004 than they did in 2000 (Table Q. Dupont's chemical plant in
Chesterfield County, Virginia nearly tripled its reported toxic discharges over the
four year period, as did Intemational Paper's kraft mill in Mansfield, Louisiana.
• Of the five plants that report significant releases of persistent bioaccumulative
toxins like lead, four reported increasing discharges of this deadly pollutant
between 2000 and 2004 (Table D). Some of the release's at these four facilities,
which increased more than 3600 pounds over the four year period, may reflect a
failure to report the discharges in earlier years.
• Three Performance Track facilities—3M in Brownwood, Texas, IBM in Essex
Junction, Vermont, and Siltronic in Portland, Oregon, either reported decreases or
no significant change in toxic pollutant releases between 2000 and 2004.
A complete list of the toxic pollutants released by the thirteen Performance Track
facilities can be found on Table E. The data available through the Toxic Release
Inventory (TRI)provides only a partial view of the record at Performance Track plants.
No doubt some of the higher pollution levels can be explained by increases in production,
though other facilities have been able to cut their toxic releases while expanding output.
Major pollutants like sulfur dioxide or particulate matter are not reported to TRI, nor are
wastewater discharges of sewage and other noxious pollutants that are not defined as
toxic chemicals. Unfortunately, this data can be time consuming and difficult to obtain,
and it is not made available through the Performance Track Program.
At the very least, however, the data suggests a mismatch between the incentives
EPA offers—fewer inspections and less monitoring of toxic pollutants—and what the
public gets out of this program in return. Participants must invest in "environmental
management systems"to audit their own performance, but the design of these self-
policing programs is left to the companies themselves, and the results are confidential.
Performance Track applicants must also select their own environmental goals from
among a menu of options developed by EPA that are vaguely worded, and which may
have little to do with the most serious environmental risks caused by plant operation.
For example, a company can opt to invest in community "revitalization," or
decide to reduce "vibration,"whatever that means. Existing commitments include
carpooling (BMW) and recycling cafeteria trays (Dupont). Not surprisingly, many
Performance Track members choose projects, like reducing water consumption, that offer
rather obvious economic paybacks. These are undoubtedly worthwhile projects, but do
not justify eliminating the monitoring of toxic air emissions, or shielding some of the
largest polluters from enforcement scrutiny.
Apparently, there are no consequences for not meeting commitments—targets that
are missed are simply adjusted downward to match actual performance. For example,

Dupont's annual report for 2004 notes that it decided not to pursue a planned wastewater
treatment upgrade at its plant in Spruance, Virginia, because the expense was deemed
"too excessive." The report advises EPA that it will therefore only cut water
consumption about 6 million gallons a day, instead of the 50 million gallons originally
promised. The same Dupont facility adjusted its commitment to reduce emissions of
nitrogen oxide, after finding that emissions had actually increased.
In short, Performance Track offers self-policing in its most extreme form, as
participants get to pick their subjects,design their own tests, grade themselves, and even
change their report cards after the fact to avoid a failing grade. In return, EPA
enthusiastically promises fewer regulations and less enforcement, in language
reminiscent of late night ads on cable television:
"Want to save time and money with fewer inspections? Read about this exclusive
incentive for Performance Track members."
EPA also offers its services publicizing the virtues of Performance Track companies,
promising new members, "the opportunity to meet and be photographed with the
Administrator or other high-ranking officials," and giving members preferred access to
senior decision-makers within the Agency. Not satisfied with these benefits, EPA has
announced plans for further rollbacks in regulation for those who sign up for this
voluntary program. Announced efforts include:
• More cutbacks in pollution monitoring and reporting requirements;
• More favorable terms for loans made under the State Revolving Fund;
• ,Various efforts to "streamline" and "expedite"permitting.
But a limited review of the results so far conflicts with the Agency's assumption that
this program somehow encourages superior environmental performance. EPA should
pause for breath before expanding Performance Track, conduct an independent and open
evaluation of just what it has accomplished, and determine whether the returns are worth
sacrificing laws that protect the public health and our environment.
References:
To find 2000 TRI data,click here to search for Performance Track facilities by state:
http:/hvww.epa.go\dtriexnlorer/
To find 2004 TRI data,click here to search for Performance Track facilities by company name and state:
hu p://wivw.epa.eov/tri-efd r/
For a list of OSHA carcinogens,click here:http://www.epa.eov/tri/chemical/oshaearc.htm
For a TRI PBT chemical list,click here:htip://www.epa.gov/tri/chemical/vbt them list.lum
To find a list of all Performance Track members and their respective annual performance reports,click
here:https://vosemite.epa.eov/opei/ptrack.nsf/vaMembersSoriPagesifaMembei-sByFacilityNaine

oECE � � � �
BLUE RIDGE
PAPER PRODUCTS INC. - q 2005
i NOVIV L
1 November 2005 WATER QUALITY SECTION
ASHEVILLE REGIONAL OFFICE
CERTIFIED MAIL -
RETURN RECEIPT REQUESTED
7099 3220 0007 0371 5856
Mr. Keith Haynes
North Carolina Department of Environment
and Natural Resources
Asheville Regional Office
Division of Water Quality
2090 US Highway 70
Swatmanoa, North Carolina 28778
Subject: NPDES Permit#NC 0000272
Daily Maximum BOD Excursions
Blue Ridge Paper Products Inc
Canton Mill
Dear Mr. Haynes:
In accordance with Part II.D.6.a of the subject permit,Blue Ridge Paper Products Inc. is
reporting maximum day BOD effluent limit excursions for October 21, 2005 and October 22,
2005. This letter follows our telephone calls to you on October 27 and October 28, 2005 and
satisfies the five-day written report requirement. You visited the Canton Mill and inspected our
wastewater treatment facilities on October 31, 2005.
As you are aware, the Canton Mill experienced a steam and power system failure on the morning
of October 18, 2005. This event caused a one-day unplanned mill outage. Our wastewater
treatment plant was not directly affected by the mill outage,but organic load to the activated
sludge process was reduced during the two days that it took to fully restart the mill and balance
out wastewater flows and loadings. On the morning of October 20, 2005 the mill's foul
condensate stripper system experienced an internal mechanical failure that required removing the
stripper from service for repair. During stripper repair, the full foul condensate flow was routed
to our wastewater plant for treatment. The sewered foul condensate created a step increase in
organic load to the activated sludge system. The nature of the organic load also changed. The
activated sludge system responded with rapid growth producing a young sludge with dispersed
solids that did not settle well. Total suspended solids in the secondary effluent were elevated on
October 21 and 22. BOD results for those days were elevated as well.
Blue Ridge Paper Products
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mr. Keith Haynes, NC-DENR
1 November 2005, Page 2
Both the mill's air and wastewater permits allow for up to 10 percent stripper downtime.related
to maintenance. Repairs to the stripper after the October 20, 2005 failure required 4.5 days
including 36 hours to purge the stripper column prior to entry. Outside contract resources were
needed to complete repairs. These resources and supplies were obtained as quickly as possible
by the mill. The crews worked overtime on Saturday and Sunday October 23 and 24 to complete
repair and restore the stripper to full operating condition. The foul condensate stripper was
placed back into service on Monday October 25, 2005.
Secondary effluent data for the power outage and stripper outage periods are listed below.
Please note that the maximum day effluent BOD values on October 21 and 22, 2005 are less than
120 percent of the daily maximum permit limit.
SE TSS, SE TSS, SE BOD5, SE BOD5,
Date m /l lbs/da m /l Ibs/day Event/notes
10/17/05 20.0 4435 8.30 1841 normal stripper
operation
10/18/05 34.0 6343 11.68 2179 mill power failure at
0100, mill down for
day
10/19/05 43.0 10,228 13.31 3166 mill restarting
10/20/05 56.0 13,339 18.26 4369 stripper failure, down
for repair at— 1130
10/21/05 73.0 18,167 46.20 11,498 turbid effluent
10/22/05 60.0 13,520 51,60 11,673 turbid effluent
10/23/05 64.0 13,984 35.51 1 7,759 effluent improving
10/24/05 64.0 14,166 37.05 8201 effluent improving
10/25/05 45.0 10,159 20.64 4660 stripper back on line
10/26/06 24.0 5302 9.46 2090 normal stripper
operation restored
Limit, Daily NA 49,560 NA 10,897 Permit limits -Part
Maximum I I.A.(1), outfall 001
In the past, the Canton Mill wastewater treatment facilities have assimilated and treated similar
foul condensate flows during stripper maintenance outages without an effluent BOD excursion.
We were surprised with the BOD results during this outage and conducted a process incident
review on October 28, 2005.
Blue Ridge Paper Products Inc.
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mr. Keith Haynes, NC-DENR
1 November 2005, Page 3
We believe that the effluent BOD excursions on October 21 and 22, 2005 are related to the
unplanned outage of the foul condensate stripper for emergency maintenance. There is one
significant difference compared to past stripper outages—prior to this outage we ran the foul
condensate stripper at a higher daily percent stripped rate in an attempt to reduce third-party odor
complaints related to foul condensates management within the mill. Prior to May 2005, the
Canton Mill operated the foul condensate stripper with a daily target rate of 95 percent of foul
condensates stripped and burned in our lime kilns. Excess foul condensates sewered were 25
gallons-per-minute (gpm) on an average daily basis.
Based on odor study work shared with the DENR ARO in June 2005, the Canton Mill adjusted
foul condensate stripper operation to a daily target rate of 99 percent stripped and less than 5
gpm sewered. As a result of this change and other changes related to in-mill control of color,
the BOD load to secondary treatment after May 2005 dropped approximately 12,000 lbs/day.
We are currently operating below the design organic load for the Canton Mill secondary
treatment system. The mill has been carrying both a lower total inventory of activated sludge
and a lower fraction of bacteria that are well assimilated to treating foul condensates. When the
full foul condensate flow was routed to wastewater treatment on the afternoon of October 20,
2005, the activated sludge system tools longer than in the past to respond to the change in
organic loading. Aeration basin dissolved oxygen levels did not substantially drop on October
21 and 22, so the wastewater operators did not have any immediate indication of a treatment
process upset. Since effluent BOD is a lagging indicator, the treatment process upset was over
before process control actions could be taken. Blue Ridge Paper will continue to review the
October 2005 stripper outage and determine appropriate ways to overcome treatment limitations
from lower activated sludge inventory.
As Blue Ridge Paper continues to find ways to operate its Canton mill at higher closure rates for
odor and color control, some adverse effects of lower organic loading to the wastewater
treatment plant are becoming apparent. Blue Ridge remains committed to current odor and color
control strategies and will remain diligent in efforts to operate within the limits of those
strategies while avoiding disruptions to wastewater treatment.
Please contact us if you have questions.
Sincerely,
Paul S. Dickens John J. Pyrately
Manager, Environmental Affairs Wastewater Supervisor& Operator-in-Charge
[e-mail] [e-mail]
828-646-6141 828-646-6720
Blue Ridge Paper Products Inc.
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Mr. Keith Haynes, NC-DENR
1 November 2005, Page 4
JGR/PSD
cc: C-File Water
Water Regulatory Communication
G. Rogers
D. Brown
L. Justus
J. Giauque
B. Williams
J. Clary
L. Cooper
B. Shanahan
Blue Ridge Paper Products Inc.
175 Main Street • PO Box 4000
Canton, North Carolina 28716 • 828-646-2000
Raising Your Expectations

Interim Wastewater Treatment Rounds
BRPPI
12 Sep 2004
Until further notice, we will do a 4-hour grab sample round of wastewater treatment to verify
that pH, flow and other instrumentation are properly functioning. There is a temporary round
bench sheet next to pH meters in the lab.
River Runner will resume normal daily and weekly schedule including weekly color samples.
The river runner log book was saved and there is a temporary supply of weekly river color
logsheets.
4-hour round
check proper operation of all equipment, check aeration basin Dos, take manual flow reading,
verify no foam on river
pH grabs locations—PI, PE, SE and splitter box. Compare actual reading from grab against
strip chart instrumentation.
Color monitorine
On 9/12 and 9/13 we will only do daily color on PI and SE composites. Use the existing bench
sheet for the daily color data. As soon as a new color lab can be set up, we will resume 2-hr PI
color monitoring to support restart of mill.

Interim Wastewater Process and Compliance Monitoring
BRPPI
12 Sep 2004
We will continue the wastewater shift log and daily results log books.
Until PC's can be put back at wastewater treatment, the Enviro group will take the daily results
log book and enter the information into OPS 32. There are two PCs in the EHS trailer that run
OPS 32.
We will collect the samples below for process control and compliance. Samples will be shipped
each day to PACE labs for analysis. The Enviro Techs will do the sample run to PACE each
day. Have samples and chain of custody ready by 11 am.
The new refrigerators are for wastewater samples and not for food or water. Ice for sample
coolers will be stored in the freeze sections.
Daily samples sent to PACE will be logged in a new sample log\book and the chain of custody
forms will be put in a chain of custody notebook. We will assign a chronologic number ID to
each sample.
An example chain of custody form for the daily samples is provided in the new sample logbook.
Be certain to put the flood-related PO number(90257) on the daily samples shipped to PACE.
DAILY SAMPLES:
Primary Influent, Primary Effluent and Secondary Effluent
Collect 8-hr composites from PI, PE and SE. (Take grabs if samplers do not work). Pour up 1-
liter samples for each shift and put in sample refrig. Collect samples at lam, 3pm and 11 pm.
Prepare a 3-liter, 24-hr composite sample by combining the three shift composites.
Assign number to each sample in sample log book, label bottles and pour up the following for
each composite:
PI, PE and SE
BOD—500 nil
TSS —250 nil
SE only
Ammonia Nitrogen (NH4-N)— 125 nil (bottle has preservative)
Ortho Phosphate (OP)— 125 nil
AOX—500 nil (bottle has preservative)
Use remaining PE and SE composite sample for daily color.

Temporary Round Bench Sheet Dickens
BRPPI Wastewater Plant Date:
12-Sep-04
Complete a sheet for each day until further notice
Round 3:00 AM 7:00 AM 11:00 AM 3:00 PM 7:00 PM 11:00 PM
Operator initials
Time start
end
Actual Instrument Actual Instrument Actual Instrument Actual Instrument Actual Instrument Actual Instrument
pH grab samples,std units Grab Chart Grab Chan Grab Chan Grab Chan Grab Char) Grab Chart
Primary Influent
Spliher Box
pH adjust working? YES NO YES NO YES NO YES NO YES NO YES NO
Primary Effluent
Secondary Ef0uent
Aeration Basin DO,mg/L H5 Hsi H5 H6 H5 H6 45 966 #5 N H5 j_6
Actual Instrument Actual Instrument Actual Instrument Actual Instrument Actual Instrument Actual Instrument
Wastewater Flow,mgd flow(staff) Chart flow(staff) Chart flow(staff) Chan flow sta Chart flow staff Chart flow(staff) Chart
Foam on River?(circle) YES NO YES NO YES NO YES NO YES NO YES NO
i/yes,increaselticdefoamer
Treatment Equipment YES NO YES NO YES NO YES NO YES NO YES NO
&Basin Levels OK?(circle)
Notes on problems/Muss:
tempbench.xls Page 1 of 2 Printed 9/12/2004

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Attachment I (Electronic Copy)
Color Reduction Initiatives Under 2001 NPDES Permit - May 2004 Update
Blue Ridge Paper Products, Inc. - Canton Mill
Color Reduction Measure ""12001 2002 -'$63 2004 2bb5 2006
1 2-Hour Color Testing ' � �� � r xxrrum r
2 Lieber ott Recommendations Implemented
3 Use of Off-line Clarifier ;� ss�s�xis'>nss*tsssstssx�st 4.'S.Y3,'3^'ftifiY3nia,w`LbAS>';SiS:s'd��f.F.3S°,'h$FSS4>'Ss s�s;^ar�sstnasuss>r>stttsrstssss;>s;,sss
4 Hwd Brown Recovery Tank Line to Pine Blow Tower m=V&=M ram a�uii ira
5 1-Hour color testing before and during maintenance outages
6 llinstallation of Mechanical Seals Vag -mmnw= 'W&mM
y Improvement of equipment used for handling Pine and sy><,sssysys�ss�sxssssssssx ;ssx�rssssussrrssss sa>;t »sxssystz;�sss^tss;;;;�ss^tssst:,r�smsssK
Hardwood Knot Rejects
8 $1.5MM spent on Bleach Filtrate Recycle Improvements s�ututuu xd'�stst[o'tustttutA'<uu>uxxixarttiusts3' iss'uta'suttntt 'sxtt
9 Installed Pine Brownstock Control Logic improvements i3Tia s�ii�itiY,33�;TLiiTii?iis'Ts'AS?A 7AYAIST3TSSS mussszss�
Determined multiple contributers and interaction effects causing µs� WX"MM xvsassusxstv ::ssx
10 Sewer Generated Color
11 Bench-scale sewer-generated color work
12 Process Optimization/Six Sigma Team designated for �TYTmyi
Hardwood Fiberline color improvements
13 Improvements made to Pine Brownstock sumps for better s .st>mssswtt>»tns
recover
14 White Rot Fungus Trial-growth efforts unsuccessful,may re-
visit in future.
l5 Pine Brown Recovery Tank Line to Hwd Blow Tower
----------------- ----------------- ------------------ -,,.,. -------- ------------------ -----------------
[20
De-Waterin is osal of Pine and Hwd Screen Rejects a.�sssv. asttss%ts ,sstt&s'szss
Trial to confirm and size system for C1O2 de-colorization of -
CRP/evaluate full-scale application
Green liquor sump at recovery fumances
Milk of Lime Trial —
Pilot Scale Plant for Ozone De-Colorization(may drop if C1O2
dechlorization is successful
— Past Process Change Implementation i— Process Evaluation or Change
M'=== Continued Performance Improvement MUMMM Expected Performance Improvement
Colorprojschd.xls, Initiatives Page 1 of 1 Printed 10/28/2004

MCDENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor January 13,2003 William G.Ross Jr.,Secretary
Mr.David E. Jenkins
Director of Conservation and Public Policy
American Canoe Association
7432 Alban Station Boulevard
Suite B-232
Springfield,Virginia 22150-2311
Mr.Will Callaway
Executive Director
Tennessee Environmental Council
1700 Hayes Street
Suite 101
Nashville,Tennessee 37203
Re: Blue Ridge Paper Products,Inc.
NPDES Permit No.NC0000272
Gentlemen: `
I am in receipt.of your letter,dated November 19, 2002,requesting informal discussions
to resolve a described dispute over the implementation of the 1997"Settlement Agreement
Concerning 1996 Water Quality Color Variance and 1996 NPDES Permit(NC0000272).issued
to Champion International Corporation". In the letter you voice various concerns over the
permitting and performance of the Canton Mill,which is now.operated by Blue Ridge Paper
Products,Inc. pursuant to an NPDES permit issued by the State of North Carolina in November
2001.
While I appreciate your concerns and I share your goal of continued and steady'
improvement to the water quality in the Pigeon River,I do not agree that the 1997 Settlement
Agreement governs any resolution of these issues. The permit and.variance that were based on
the 1997 Settlement Agreement have now been replaced by the currently-effective permit and
variance which were issued in November 2001.
1601 Mail Service Center,Raleigh, North Carolina 27699-1601
Phone: [phone] FAX: [phone] Internet: www.enr.state.nc.us/ENR/
u[aa pocn.nyNny,u RV ECIIJ,,.`,�Qt:CN IIa PoY`aqune o»,:

r
Page Two
January 13,2003
Re: Blue Ridge Paper Products, Inc
NPDES Pennit No.NC0000272
We concluded in 2001 that the conditions placed in the permit will assure that Blue Ridge
Paper will achieve significant improvements in its color loading discharge to the Pigeon River.
As you will recall,the basic structure ofthe permit calls for a series of steps to lower the lbs/day
of color based on demonstrated performance and process changes. As the deadlines and
milestones of the permit are reached,we will learn more about what can be attained and
determine the necessity of continuing the color variance in the next permit period.
I am willing for our Department to meet with you to discuss the mill's performance and
the permitting timelines. If you are amenable to such a meeting, perhaps in the Asheville area,I
will be glad to invite the appropriate officials of the company,the EPA and the Tennessee
agencies and counties. Please contact Alan Klimek,Director of the Division of Water Quality
(919/733-7015),if you believe such a meeting would be helpful.
Thank you for the letter and thank you for your commitment to environmental protection
and natural resources conservation.
Sincerely,
Q�
William G.Ross,Jr.
Secretary
cc: James Palmer
David Moreau
Robert Ray
Justin Wilson
Pall Davis
Iliff McMahan
Rod Dykes
Bob Williams
Alan K,imek
Dan Oakley

12-18-02 14:29 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P02/06
n:
STATE OF TENNESSEE
DON SUND91XIST
GOVE"OR
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 3 03 03-3 1 04 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
1617 Mail Service Center
Raleigh,N.C. 27669-1617 David Jenkins
Director of Conservation &
The Honorable IliffMcMahan,Jr. Public Policy
County Commissioner, Cocke County American Canoe Association
360-Main Street 7432 A1baa 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 dispute:is subject to resolution according to Paragraphsl9iand 40 of the agreement
Tennessee her;65y consents to extension of the infornial�resohffibti perrod'•atid'identifies
David-McKiiniejrand Paul Davis as its representatives ffthdt' iocess. Yis'b&Wnly our
wish ilfatthe dispute can'be amicably resolved.
State Capitol,Nashville, Tennessee 3724"001
Telephone No. [phone] -��

12-18-02 14: 29 SLUE 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.WiIson
Dep to the Governor for Policy

12-18-92 14: 30 BLUE RIDGE PAPER PRODUCTS ID=6286466892 PO4/06
•- �_..,,r„, �lwrzro. aLenoarac, manimna¢ 6 I670t branch 1404 5529224 T-616 P.01IIA01 F-660
sarE�ly,S '
Y UNITED STATES ENVIRONtdENTAL PROTECTION AGENCY
REGION 4
=- :?yt ATLANTA FEDERAL CENTER
61 FORS'YTH STREET
AT!ANTA,GEORGIA xem-a96o
NOV 0 7 2002
Ms. Hope Taylor-Guevara,
Clean Water for NOYh Carolina
2a'ia Page Avenue
Asheville, NC 238U1
Dear Ms_Taylor-Goevatm
Thank you'for your letter dated October 24,2002 on behalf of your organization and
twelve otherenvironmental groups,M Administrator Whitman and Regional Administrator
Palmer Concerning the wastewater discharge permit for Slue Ridge Paper Products in Canton,
%lordi Carolina
A response to your letter is being prepared by staff in the Water M. agemcnt Division u
address your concerns. Due to the complexity of the concerns that you have raiscd,•it is our goal
to provide you with a response by the first of December.
NVe apologize for the delay and appreciate your patience. If you have questions in the
intrrim,please fe--1 free to contact W.Marshall Hyatt at 404/562-9304.
Sincerely,
/Water��2emenfl)ivirsoion
na, 7c
o.^rgxnr.Fcau sa p-Pa;
FAX TRANSMITTAL �+e Pap.— i
F}a• a ��V� W � a.. Fns i --..
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ReeyeledlReeyalahlo.Nnled wb I/agoleble Oi aas dines sn RMOWe aper(Mmimym 30Y.Poateon=wj
1:1-03-62 14:42 TO:BLUE RIDGE PAPER PRODUCTS FROM:[phone] PNI

12-18-02 14: 30 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P05/06
i
UNITED STATES ENVIRONMEt,N'AL PROTECTION AGENCY
3m
REGION 4
ATI.AWA FEDERAL CENTER
61 FORSYTH STREET-
Al LA -GEORGIA 30303.8960
DEC -91
GIs.Hope Taylor-Guevara
Clean Water for North Carolina
24 ',1 Page Avenue
Asheville. NC28801
Dcar Ms.Taylor-Guevara:
Thank you for;your October 24.2001 lever on behalf of your organization and twelve
other envirOrrrienlal groups,to Christine Todd Whitman.Administrator of the U.S.
Environmental Protection Agency(EPA),and me,concerning the wastewater discharge permit
for Blue Ridge PaperProdocts(Blue Ridge)in Canton,North Carolina_ On behalf of
Administrator Whitman,I am providing the following response.
As your letter notes,the color provisions of the Blue Ridge National Pollutant Discharge
Ehntinatinn System(NPD1;S)permit reissued by the North Carolina Department of
Unvironmenral and Natural Resources(NC DF-NR)in November, 2001 resulted from an
extensive process which included many stakeholders. The N*C DENP,with EPA's assisuance,
caught review and advice from a technical team of EPA pulp and paper experts,who conducted a
technical evaluation of the mill's colorreduction efforts. vlr. -Norm Liebergott, a Canadia,l pulp
artd paper expert recommended by several environmental groups,also conducted an independent
evaluation.
The findings from each parry were Then assessed aid synthesized by the Technology
Review Work (TRW),consisting of reptesentarives from EPA,NC DF-N4 the Tennessee
T 'ivisior. of Water Pollution Control, and the Tennessee Wildlife Resources Agency- The
TRW's recommendations were, in turn,provided to the NC D1 NR,as the permuting asercy..
"These recommendations formed the basis for the draft permit that went to public notice ill
August '001 and forwhich a public hearing wS held in September 200t. Based on comrrenis
rcx:ctved, the NC DENR bade sign scant changes to the draft permit, incorporated them in a
prupa.:cd final permit in October 2001,and issued the final permit in that form in Novcmhtr
2001. The November 2001 permit became effective in December 2001 and was not
admmistratively appealed-
PAX TRA_NSMITTAI_
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(2- .12-02 15 :25 TO:BLUE RIDGE PAPER PRODUCTS FR4td:404562t3692 P01

12-18-02 14: 31 BLUE RIDGE PAPER PRODUCTS ID=8286466892 P06/06
2
','he Permit as issued reflected substantial public involvement and independent scrutiny duoughnut its dcvclopment. We beGevc that the requirements of 13lue Ridge's NpDES permit
wtl] rssuit to significant improvements in the water quality of the pigeon River during the term of
the permit,and that the permit meets the requiremenrs of the Clean Water Act. during
share your
expectation that efforts wilt continue over the tams of the permit to identify feasible methods to
reduce color loadings below the levels allowed in the permit,and that these can be factored into
thr. permit as soon as possible.
Your letter requests that the EPA reopen the NTDES permit for Blue Rid se to modify the prov;sions of the permit relating to color. Because the NC DENR is the perrnittino agency in this
instance.any requests for reopening this Dermit should be directed to them,;it the following
address: 1617-%fail Service Center,Raiei;h, North Carolina, 2 7699-1 6 17.
«re appreciate and share your sincere concern for the quality of the environment in this
area of North Carolina and Tennessee,and hope to continue to work with you and the States of
:Worth Carolina and Tennessee tolvard this end. For any additional Information, please do not
h"Sitate to contact Marshall Flynn of my staff at(404)562-9304.
Sincerely,
-
I Palmer,zer -
Regionai Administrator
cc: William Ross. NYC DENR
Alan W. KIimek.P.E—NC DENR
titiltnn Hamilton,Tennessee Dept.of Environment and Conservation
Paul E. Davis,Tennessee Dept,of Environment and Conservation
David McKinney,Tennessee Wildlife Resourceg Agency
12- 12-02 15 :26 TO:ELUE RIDGE PAPER PRODUCTS FROM:4045B28692 P02

bma ' '

@C) Champion
Champion International Corporation
NTON MILL bti� �
MKI CA
DIAGRAMMATIC OUTLINE OF PROCESSES {� aS
' OOD1NTHE PULP AND PAPER y 0 r (5 y v ` Y
IN THE MANUFACTURE OF
CHI+BIN c ) '
/ /
: CHIP
SCREEN BLOW TOWER 1l. b f/
'BARKING'ARUMi + - VAPORATORI 0LIM�E°KILN FILTER
j 'CHIPPER / / LIME SLAKING
.. BOILER '.L �. / rT - •:. ..-. : _ .. _ _
TURSINE, .I _ -
GENERATOR I
• , " - - BLEACHING � GESTER 1
C E CAUSTICIZEfl �- _
STEAMA POWER -
PLANT - •+� d•' .' I IIIII. RECOVERY -
- - '"' •� - .: �� I CLARIFIER BOILER
HYDRAPULPER-► - ;• } :, 'PULP WASHING. - DISSOLV
JORDAN6RECOVERY
ING iANK. I•�';�'♦;
"�,,W - CHEMICAL REC
� _ �_.. � J �cl w� OYERY CYCLE„ -
e
HEADBOX OM FOREST'TO 'PAPER
CLEANERS'-- FOURDRINIER PRESSISECTION
,DRYER
SECTION -
�i DRYER
rSECTION�
• I �N
RECOVERED: -
WHITE WATER • '� -
♦
• • - .SLITTER.
t -
" � �WINDER
• • +INI
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SIZE PRESS ' i
CALENDEH STACK rOS
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CHAMPION INTERNATIONAL CORPORATION
CANTON MILL
1986 STATSST'ICS.
DAILY WE USE DAILY WE PRODUCE
(tons/operating day)
Wood. . . . 5 , 260 tons Pulp . • • . • 1 , 539 tons
C'oal,. . . 1 , 030 tons (Pine - 879)
Fuel n' t 24, 79 gallons (Fardwood - '660 )
Lime . . . . . . 230 toms Paper and Board. 1 , 656 tons
Starch• . . . 5.2 tons (Paper - 960 )
Clay. . . . . . 70 tons (Board - 696)
Caustic. . . 106 tons Tall Oil . . . . . . . . 28 tons
Chlorine . . ill tons Turpontine . . . , . . Y , 095 gallons
OPERATION OF THE MILL REQUIRRS
YEARLY
Wages and Benefits . . . . . ,. . . . $ 1001 $11 , 991
Wood (chips ) . . . . . • • 60 , 993 , 198
Freight. 2'1 , 389 , 14a
Purchased Electricity. . 11, 812 , 979
Telephone and Telegraph. . . . . . 578 . 316
Coal , Oil , Bark, Fuel. .. . .. . . . 21 , 078, 090
Taxes - Canton; NC. , . . . . . : . . 642 , 304
- Hi-wood County: . . 759 . 639
Other ., . . . . . . . . . . . 21 , 310
Total Taxes. . . . . . . . . . 1, 423 , 253
.Employees :
Canton mill.- . , : ,. . . . 1 , 954
Waynesville plant. . 293
total: . . 2 ,247

..f`f.0 srA;,
�s,{
n`r/J UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
+r4lPF41E;e REGION 1V
343 GOURTLAND STREET
ATLANTA, GEORGIA 30365 •
COPY TO:
ALAN KLIMEK
' DENNIS RAMSEY AUG"8Lgz,�
AUGs STEVE TEDDER
Y ;u ks sT L RET.DRIQ. RECEIPT REQUESTED WATER QUALITY
SECTION
REF: 4WM-FP
RECEIVED
Water. Quality Division
Mr. R. Paul Wilms
Director, Division of -Environmental Management AUG 9 1985
North Carolina Department of Natural Resources Western Regional.Office
and Community Development Asheville, North Carolina
512 North Salisbury Street
P. O. Boa 27687
Raleigh, North Carolina 27611
Dear Gam„"e -
Pursuant to 40 CPR Section 123.44(b)(2), this letter. states the issues and
objections that EPA has to the terms and conditions of the •proposed NPDES
permit" for Champion International Corporation (NC0000272). A review has been
completed of the permit, your letter of June 18, 1985, and previous correspon-
dence from EPA (February 26, 1985, and April 23, 1985). As detailed below,-
considerable progress has been made in resolving our concerns regarding this
permit but several are still unresolved.
Resolved`.Issues
Our previous comment regarding total dissolved solids has been resolved by
including the reopener clause in the May 14th permit.
Inclusion of bioassay testing in the permit has adequately addressed our concern..
Additionally, it is my understanding that the State intends to perform additional
chronic toxicity testing as well. I would appreciate written confirmation of
your plans.
r
After reviewing all of the -material submitted, it is our conclusion that the
temperature variance submitted was not a revision to water quality standards
but was a Section 316(a) determination. It is our opinion that the Final
Order issued by the Environmental Management Commission dated October 11, 1984,
adopting the Division of Environment's (DEK) Findings. of Fact and Conclusions
of Law with some modification meets the requirements of a 316(a) determination.
The modification of the DEM, recommendation was only that DER is expected to
perform additional monitoring. if this is contrary to your understanding of
the situation, please let me know.

Mr. R. Paul Wilms
Page 2
objections:
EPA objects to the permit limitations related to color on the basis that com-
pliance with Section 301 (b) (1 )(C) of the Clean Water Act has not been adequately
addressed, i.e., color standards in the North Carolina and Tennessee segments
of the Pigeon River may not be met unless the terms of the permit are changed.
We understand that DEM intends to evaluate the instream color level of the
Pigeon River within North Carolina after Champion begins operation of the full
scale color removal facility. We further understand that DEM intends to take
additional action if the color level remains above acceptable levels. However,
at the present time the permit does not provide any basis for how DEM interprets
the aesthetic quality criterion relative to color for the designated use of the
Pigeon River in North Carolina or how DEM will make its determination of whether
additional action is needed. By this, we do not mean that DEM is required to
set any type of numerical color value for the river, but rather that DEM needs
to explain using subjective terms, if necessary, the factors to be consider
and the methodology to be used by DEM to judge compliance. For example, Diff
map intend to use a panel to determine whether the color level meets the
aesthetic quality criterion.
If there is an adequate description of the factors and methodology added to
the permit, DEM, EPA, the company and other interested persons would all have
a basis for determining whether permit compliance had been achieved. This
addition to the permit would resolve EPA's concern on this issue.
In regard to the Tennessee water quality standard, Tennessee has interpreted
their narrative criterion to be 50 color units. Based upon EPA's previous
analysis and the 75% color limitation in the permit, any time the untreated color
level exceeds 800 color units at low river flows, the 50 color unit standard at
the state line may be violated. Although the permit indicates that the Environ-
mental Management Commission (EMC) may subsequently,modify the color removal
level to require further color removal processes, a clirectly enforceable limi-
tation is needed. It will be necessary to add a color limitation of 50 color
units measured in the river at EEe state line to the permit. The limitation at
the state line should be expressed as apparent color. However, in recognition n
of the fact that the Champion Paper Company may not be the sole cause of
increased color levels at the state line, the following stipulation should be
added. 'If the apparent color level exceeds 0 color units, an ana ysis or
true color must be performed. If the true color level exceeds 50, then this
would represent a violation of the permit.' This recognizes-that e company's
contribution of color to the river is based on true color.
The permit indicates that the EHC may order Champion to undertake additional
actions should the demonstration facility prove to be unsuccessful. Our concern
is with the qualifying language, i.e., *may." In order to make it clear-that
the effluent limitations are to be achieved to meet water quality standards, the
word 'shall' should be used.

Mr. R. Paul Wilms
Page 3
In addition, we find that your June 18, 1985, response to the Tennessee Depart
ment of Public Health pursuant to 40 CFR 123.44(c) (2) to be inadequate for the
same reasons given above.
The State of North Carolina or any interested person may request a public
hearing on these objections pursuant to 40 CFR 123.44(e) within ninety (90)
days of your receipt of this letter. If no public hearing is requested, it
will be necessary for the State to resubmit a proposed permit that resolves the
objections within that same time period of ninety (90) days or the exclusive
authority to issue an NPDES permit will pass to EPA per 40 CFR Sec. 123.44(h).
We will work with you and your staff to the maximum extent to resolve this
issue in an orderly and expeditious manner.
Sincerely yours,
v�
Jack E. Haven
Regional Administrator
cc: See Enclosure

ADDRESSEES:
Honorable Albert Gore, Jr.
United States Senate
Washington, D. C. 20510
Honorable Jim Sasser
United States Senate
Washington, D. C. 20510
M/M Michael H. Hyrum
139 Smokey Park Highway
Apartment #4
Ashville, N. C. 28806
Mr. Cary A. Davis
Attorney for Pigeon River Action Group
Legal Environmental Assistance Foundation
Central Appalachian Office
530 Gay Street, Suite 204
Knoxville, TN. 37901
Mr. Tammy Fondren
94 Tarbell Mobile Home Court
Chapel Hill, N. C. 27514
Mr. Lindsay Jones
Western North Carolina Alliance
Route #1, Box 304
Zirconia, N. C. 28790
Mr. C. D. Mullinix, Chairaan -
Pigeon River Action Group
�. P. O. Box 105
Waynesville, N. C. 28786 --
Mr. Michael D. Pearigen \
Asst. Attorney General -
Office of Attorney General
450 James Robertson Parkway
Nashville, TH. 37219-5025
- Mr. Matt Schuster
2922 Poplar Street
Doraville, GA. 30390
Dr. Charles B. Weaver
Georgia Izurtitute of Technology
School of Geophysical Sciences'
Old Civil Engineering Bldg.
Atlanta, GA. 30332