NC0000272_Meeting Notes_20050519

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Blue Ridge Paper
Products Inc .
Canton Mill
Mill Information
and Wastewater
Permit Reference
NPDES No. NC 0000272
DWQ Mill Visit and
Permit Discussion
5/19/2005
BLUE RIDGE
PAPER PRODUCTS 4NG.,

Mill Tour - Basic Process Flow
CHIPS F"'
iProduction LIME
SCREENING KILNS
V p� N NaOH NaCO3
White Liquor
DIGESTERS CAUSTIZING
Green Liquor
FIBERLINES Black Liquor t
Washing —► EVAPORATORS --pp- RECOVERYFURNACES
Bleaching
Chemical Recovery
PAPER MACHINES Cycle

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Color Loadings to Mill Sewer Areas 11-May-05
"Good Color" Upper Limit
Sewer Area Daily Color Units Average Xbar UNPLx
---------- ----------- ----- ------------ -----------
Primary Influent 35929 Lbs/day 42, 720 71,095
Pri.Infl.New NCASI* 33505 Lbs/day
Pri Inf Turbidity 7 10 .5 23. 9
PI BMP LAL 70,322** Lbs/day
PI BMP UAL 78, 609** Lbs/day
Secondary Effluent 27774 Lbs/day 37,260 50, 175
#1 Sewer( ll & 12 MC) 1400 Lbs/day 1690 4335
#2 Sewer 177 PPM
2B Sewer (Digesters) 980 Lbs/day 3955 8970
3A Sewer (EO Filtr) 6360 Lbs/day 9180 18,250
3A Calculated Sewer 3730 Lbs/day
#4 Sewer 144 PPM 204 390
Contaminated Condensate Sewer Values
Concentration 415 mg/L
Flow 596 GPM
Color 2968 Lbs/day 4420 7695
Combined Condensate Sewer Values
Concentration 182 mg/L
Flow 194 GPM
Color 424 Lbs/day 1510 4840
5B Sewer (Recovery) 7760 Lbs/day 6885 16, 070
CRP Color 980 Lbs/day 3630 7470
6A Sewer 6300 Lbs/day 6760 10, 600
6A Calculated Sewer 5630 Lbs/day
6A Sewer pH 6 . 5
Pine Bleach 3090 Lbs/day 4365 9660
4 . 9 Lbs/ton pulp
Pine D1 1780 Lbs/day 2650 5230
Pine Eo 650 Lbs/day 1700 6125
Pine D2 660 Lbs/day 135 233
Hardwood Bleach 6270 Lbs/day 8510 13, 045
7 .4 Lbs/ton pulp
Hardwood Dl 3190 Lbs/day 5635 10, 150
Hardwood Eo 3080 Lbs/day 2925 5130
BFR Closure 89 . 6 % >85 <75
Unaccounted Color 9737 Lbs/day
Sewer Total 26192 Lbs/day
* New NCASI color test method which accounts for turbidity.
**The Primary Influent Lower Action Level (LAL) and Upper Action Level (UAL)
must be exceeded for two consecutive days before investigative or
corrective action is mandatory.

Blue Ridge Paper
Products Inc.
Canton Mill
Mill Information
and Wastewater
Permit Reference
NPDES No. NC 0000272
DWQ Mill Visit and
Permit Discussion
5/19/2005
BLUE RIDGE
PAPER PRODUCTS -INC.

DWQ Wastewater Visit & Permit Discussion
5/19/2005
Blue Ridge Paper Products Inc. Canton Mill
• Wastewater plant tour
— Control room, lab and computer room
— Process flow walk thru
— Flood impacts & recovery
• Mill overview tour
• Permit discussion (aEHS Offices)
— Brief Permit history
— Color performance & challenges
— Re-permitting in 2006
— Acid sewer and flood strengthening projects

Y/
Wastewater Tour
• Wastewater process diagram and sewer schematics
are attached
• Canton Mill
— Fully integrated ECF bleached kraft mill
— 1420 tons per day annual average capacity
— Both hardwood and pine fiber lines
— 1 paper board machine and 3 paper machines
— 1000 employees
— $90 million per year payroll
— $500 million per year in sales including DairyPak

Gantom Mill Environmental
Investment
Over $526 million invested over last 15 years in
environmental process improvement
Both fiber lines exceed Cluster Rules requirements
Is a minimum impact mill with world class
environmental performance through a combination of;
➢ Oxygen delignification with 100% substitution of chlorine
dioxide for elemental chlorine (OD100TM)
➢ Bleach Filtrate Recycle (BFRTM)
➢ State-of-the-Art BMPs
Secondary effluent contains very low BOD, TSS, COD, AOX and
color levels
Bleach plant effluent non-detect for 2,3,7,8 TCDD and
chlorophenolics
Extensive Sump and Spill Recovery Systems

Secondary Effluent Performance
Blue Ridge Paper Products Canton Mill
Parameter 2004 Pre-Flood 2005 Jan-Apr Limits
Flow, mgd 25.08 24.97 29.9 mon avg
BOD, mg/I 7.4 9.3
Ibs/day 1547 1966 3205 mon avg
TSS, mg/I 14 17.2
Ibs/day 2919 3633 12,549 mon avg
True Color, ppm 190 188
Ibs/day 3%737 399134 42,000 annual avg

Canton Mill Secondary Effluent Color Performance
Annual Averages: 1988-2006
400000 Including Permit Limitations
Permit Limitations
350000 1 -258,945#/d Monthly Ave. eff. 4/14/94
2 - 172,368#/d Annual Ave. eff. 4/14/94
^> 3 - 125,434#/d Monthly Ave. eff. 12/12/96
300000 4-98,168#/d Annual Ave eff. 12/12/96
J2 5 -95,000#/d Monthly Ave eff. 1/1/98
ZVI
6-69,000#/d Monthly Ave. eff. 1211/98
`0 250000
S 7-60,000#/d Annual Axe. eff. 12/1/98
U 8-48,000#/d Annual Ave. eff. 5/1/01
200000 ❑2 9-40,000-42,000#/d Annual Ave eff. 1211/03
10-32,000-39,000#/d Annual Axe eff. 3/1/06
w
150000
0
100000
50000
0
1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006
Annual Permit Limitations tSE Color Annual

Flood Impacts and Recovery
Canton Mill wastewater Plant
• Back-to-back historic floods - Frances 9/8/04 &
Ivan 9/17/04 — topped mill dikes and flooded the
wastewater plant
— Lost lab and control room
— Motors, controls and power feeds wet
• Restored secondary treatment within 4 days of
Frances and within 5 days of Ivan
— Contracted out lab analysis for temporary period
— Restored permit-required monitoring and records and in
stages while pre-flood systems were restored.
• Restored full wastewater lab within 90 days

Wastewater Treatment Process Diagram
H2 SOq Ph Confiol PE NH4 H POq Po Addllbn
Intemrllterlt Addll
of CaCO3
bn
t
#4
Chiller
20D' Diameter
Dewatered Sludge 12' Deep
To la1dN 2.62 Moron
GalanAeralbn BasksPorynser M c Szbm hew v11A MaDn eebn
Prhrsaty Shrdgef0ln 12 Atilt pro 6z belt Pf95ses Recycle SludgeRecycle
CksNler
14,75' Deep 200' Dkameter
3A7 Won Sludge 12' Deep
Milloon
Galora Pumps 2.62 Moon
Flow Gown
Press
Station Fate
#2
#1 Waft Sludge Re%,cb
Pff
Cladler Polymer #d
126' Diameter CO2 pH CAW
11' Deep Corltm1 150' Dkameter
1.01 M1on 11189
Do
Gallons Gallons
LAW Corlfaat
Lift BQ G1B Chamber
Sample Collection Pumps screen Charlber
Sites Oxygen
Denotes Site
City Sewer
Aeratbn
PI - Ptlrnary Influent Mill Wastewater Pf Cascade
PE -Primary Effluent as SE
n.
SE -Secondary Effluent Final Effluent

Q� �! N0. 1S PM
CAMPGROUND MAW FOLEY BARK BOOK TOIL
LIMM AND CAUSTIC MflT BOILER N0. 12 PH ODRRS
STORIIT TANKS CLF11 PM
ERGO COOL4IIim NO. 11 FM STORAGE
NMI FL BLEACH F$OWATBt
07 OEMMIER
PLANT CF$1 HILL
WFREF
N4 20 PM
ACID FILTRATE BROKE TANK
COO!ER .Y ACTH S�TG
RECI AII1
EO COOLER [--o-
OVERFLOW
1
LINE vw BLOW TALK
� SEWER
COM310 TOWER
WATER TANKS
STRIPPER
gFEED TAIX DIGESTERS BL04 TALK
E� BFECOVERY
LOWDOWN COAL d
MANUFACTUiE Ba0)ELS a
EVAPORATORS
STORA¢
N0. 3 SEWER N4 2 AREA SEWER
COMBINED MUD COWB�SATE �
COKERSATE SAMPLE STATIONS
OVe(ffSHE CAUSTICIZINO
PCC PLAPTT LII1E �
10
BLO 6 HEAVY 3A SEWER
LIOUOR STG
NO. 11 RE0. 1B toPUMPS
m
BOILER
N0. 10 REC NEW 58 SEWER
BOILER MILL SEWER SYSTEM
POST CW
iz7

ERCO CLO2 GENERATOR
N01 FILTER PLANT BLEACH CFEMICAL PREPARATION
N4 19 WW CHEST
NO. 18 PM
FRESH WATER NO, 19 MACI ENE
BOOSTER PUMPS
NO. 19 HOTWELL `
r
�-------------i FINISFBNC RWM
Na 20 PAPER MACHINE 3
i
CENTRAL WHITE WATER CHEST
N0. 20 WW CHEST
MAIN COOLING TOWBi
� t�
i
i � d
GENERATOR COOLING BODSTHi PUMPS
N0. 9 TURBINE GONENSER N0. 12 MACHINE
BOILER FEEOWA7ER PUMPS
NO. 11 MACHINE
i -------------- '--
i
i � N0. 11 TURBBNE CONOEI ------------ -----------------
FOWER BOILER
BEARING COOLING PAPER CHEM PREP
i
j LOWER END
i
-----------------------------------------------------------------------------------------
PRESSURE CONTROL VALVES PAPER MILL WATER SYSTEM

HILL FILTEi PLANT
MAIN COOLING TOWER
NO.1
FIBERLUE
Nall TURBINE NO. 19 PM HOTWELL
CONDENSER
PINE BLOWHEA7 N0.1 FL Rx"j,
ffARY
WHEATSEC. CONOHNSEft HO TT�+ ONOENSERHANGERS
HWO BLOWHEAT COOLING TOWER COOLING TOWEL
SEC. CONDENSER WARM WATER HO TMWIAK ER
CONDENSATE
SWENSON EVAPORATOR \ STRIPPER
SURFACE CONDENSERS
WEST GB EVAPORATOR I NO. 11 & 12 PMS NOB TURBINE
SURFACE CONDENSER F®WATER DOWENSER
PINE TURPENTINE
CONDENSER
NO2 FL PINE BLOWHEAT
HOTMWAATER PRIMARY CONDENSER
HWD NRPENI7NE HEAT EXCHANGERS
CONOBNSER
0 AND�OOLF�ILS7RATE EIoc
MILL COOLING
WATER SYSTA
COOLERS F N��
ICC COOLING RIVER
TOWER PUMP
HOUSE
OE'OLY CONTAMINATED
BARK BOILER CONDENSATE ::]7
SEAL WATER NAKEIP
SCHEMATIC OF HEAT RECOVERY SSYSTEMS
LNW 11/15M

ATTACHMENT II - A
PAN FOVER
4 Fj2U
EYAP fly
NT
PLANT
PLW t GUSE
20 RAW WATER 28
MARKETS
FILTER PLANT SLUDGE 03
MILL COOLING u BI W� 115E Os
EVAP V
PAPER K L.L
N(L 11 PM L0
Na 12 PM L3
NO. 20 PM 20
NO. 19 PM 27
CMER PREP 0
FCC PLANT 03
PUP GIST. LS
2.0 WHITE WATER
PUP MILL
111 �q PREP OB 131
COOOZiG L4
BLEACWNG 45
REMVERY 34
EVAP LI
49 � 38
GENERATION
8.9 KSCEI_�ANOM 89
TOWN OF a CANTOR Bffi
CITY WATER
CANTON MILL WATER BALANCE
FLOWS IN MGO 047E MAR. U MH

1-40
Station 5
RM 19.0 5
Bluffton TN
(19.3j
Hartford,TN
.•�7�,TENNESSEE T)
— — NORTH •
CAROLINA
19G1�R 4 m
6 Hydro Plant f( A
(26.0)
2 11 ii
/
1
A
Ij 5tit'
Walters Dam B�
Station 48 Station 4A
RM 39.0 RM 41.5
4A Waterville Lake
Fines Creek
New Hepco Bridge
�
FLOW Jonathan
Creek Old Rt.209
3 Station 3 Station 2 Mill Outfall
RM 52.3 RM 59.0 RM 63.3
Waynesville STP 2
Outfa
54 l acJ Canton,NC
r� e�
f��a6le Clyde Station 1 1
RM 64.5
(Control)
IFigure 2-1. Fish tissue sampling station locations on the Pigeon River.
2-3

Mill Tour — Basic Process Flow
CHIPS Pulp
Production LIME
SCREENING KILNS
NaCO3
NaOH
White Liquor t
DIGESTERS CADS TIZING
Green Liquor t
FIBERLINES Black Liquor
Washing EVAPORATORS --*- RECOVERYFURNACES
Bleaching
1 Chemical Recovery
PAPER MACHINES Cycle

Fro M' Forest to Paper
dhlp BN CmMp Twer
Chemical Additives
"ap°°" N t per and Reactions
�� cope Ste"
mom ✓�Me�,�" ape t �' h A.White liquor added to wood
b„rsed chips—starts to dissolve Ilgnin.
mrluel i°roNB B.Black liquor(white liquor+Ilgnin
Pub sae.ne
o°"O1°r°` Cau , residue)washed out.
61eom6 P..,Plant q,'Y°0d01ti I nlll' RepowryeeMr C.Oxygen Reactor for further
M... p1tW4VT dellgnification.
C.Pulp bleached to Increase
eveperetor - whiteness.
M°tlJno Cheat
V Pap wwrnp GeMul RemnryCrde E.Pulp extracted with caustic soda
I j - to further remove tignin.
Ranters
1 F.Pulp bleached to increase
whiteness. '
Heed Me
Cleaners—+ F°uNMler
G.Bleached pulp slurry. Paper
pre'.sea. additives(such as pH adjusted
f �—oryerseCpn dyes,rosin,alum,clay,titanium
dioxide)added to enhance
�� r Uyersaerim1 paper properties.
1 H.Paper sheet formed here
through dewatering.
sMer I. Black liquor concentrated.
R°wvorsa�.ter , ✓ °` J.Black liquor converted to
green liquor.
`p er'"e° K.preen liquor manufactured.
St.Prsae L.Green liquor converted to
while liquor.
w.�wersua M.Calcium carbonate settled out
Reel and sent to time kiln, Clarified
White liquor goes back into new
cooking cycle at Point A.
N.The temperature of non-contact
process water is reduced by
the cooling towers for reuse In
the mill.
'Making( ; ur mark for you.
x LUR RIneR PAPRR p.nn,,,,. INf.

Canton Mill 2002 Statistics
(per calendar day) (per operating day)
Wood 5,080 tons Pulp 1,355 tons Wood (chips) $69,155,433 Employees:
Coal 1,127 tons Pine 579 tons Freight $12,208,565 Canton Mill Fuel Oil 099
18,748 gal. Hardwood 776 tons Purchased electricity1,238
Fresh Lime 98 tons Paper and Board 1,596 tons Telephone $9,190,028 Waynesville Plant 238
Starch 80 tons paper $590,317 Total 1,337
P P 801 tons Coal, oil, gas, bark fuel $21,231,534
PCC's 117 tons board 795 tons _
Caustic 56 tons Tall Oil 26 tons Taxes:
Turpentine 1,010 gal Canton $1,006,631
Haywood County $1,196,212
Total $2,202,843
All numbers,with the exception of Taxes and Employees,reflect Canton Mill only

MILL OVERVIEW
e Built in 1908 to produce pulp for the Champion International Hamilton, Ohio Mill
• 3 uncoated paper machines, Nos. 11, 12, and 20 producing 280,000 tons per year
• 1 paperboard machine,No. 19, producing 254,000 tons per year
• $526 million invested over the last 15 years plus another$29 million invested by Blue
Ridge
• Significant improvements to mill operations
• Improved environmental performance
• Pulp bleaching system replaced
• Improved quality/productivity
• All machines converted to alkaline
• Causticizing Project to improve reliability of lime kilns and slaking equipment
• No. 19 PM upgraded technology to improve board strength, surface quality,
and yield
, • The J. E. Edwards/Optivision Computer System for the Company.
r

The Canton Manufacturing Process
Overview: Blue Ridge Paper Products' Canton, North Carolina, facility is,a pulp and
paper mill that makes uncoated paper and bleached paperboard. The mill occupies some
200 acres through which the Pigeon River flows, and it is readily accessible to the network
of roads and rail necessary to bring raw materials in and ship products out.
Two million tons of wood arrive at the mill each year; approximately two-thirds are
purchased from private landowners, and the remaining third comes from residual sources
such as chip mills, etc. The mill's four machines -- three paper and one board—produce
close to 1,500 packed tons each day, adding up to approximately 535,000 packed tons
annually. The uncoated paper, most of which goes directly from the mill to our customers
in large sheets or rolls, is used for a variety of end products, including letterhead,
envelopes, notepads, and endpapers in books. Some of that paper, in turn, is used in
copiers and printers and for the commercial printing of brochures, catalogs, annual reports,
and school supplies. Recycled fiber also is included in some envelope papers. Paperboard
from the mill is sold for use in a variety of packaging applications.
The Canton mill has been upgraded to meet new or changing market demands and to
integrate the latest pulp, papermaking, and environmental technologies. The Canton
Modernization Program(CMP), completed in June of 1994,represents'a$330 million
investment and features pioneering methods for reducing emissions. The Canton mill is
currently operating a full-scale demonstration of ,a patented Bleach Filtrate Recycle
(BFRTm) technology. BFR is designed to close the loop on the bleaching process, and
further reduce the mill's impact on the environment. BFR and the CMP underscore Blue
Ridge's dual commitment to the regional economy and the environment.
The Woodyard: The woodyard is the first step in the papermaking process at Canton.
Wood chips come in by truck and railcar from forestlands in North Carolina, South '
Carolina, and Tennessee. The chips are made from two kinds of wqod: softwood, such as
pine, and hardwood, such as oak. Softwood fibers are long and tough and help give paper
its strength. Hardwood fibers are shorter and provide paper its smoothness. All of
Canton's paper and paperboard contain both kinds of wood in varying proportions to
achieve different paper characteristics based on end use. Envelope grades, for instance,
have-more softwood for strength. Offset printing grades, on the other hand, contain more
hardwood fibers for smoothness.
Pulp Manufacturing: This process, during which wood chips are turned into the pulp
used to make paper and paperboard,'involves cooking or pulping the chips. A mixture of
chips and a cooking solution called white liquor, which consists of sodium carbonate and
sodium hydroxide, is heated in a digester, which essentially is a large pressure cooker.
Canton has 18 digesters: 10 for softwoods and eight for hardwoods. In the digester,
lignin, the natural binder that holds wood fibers together, is dissolved and yields cellulose
fiber called brown kraft pulp. Next, the pulp is thoroughly washed, screened, and then

bleached to a bright white, using a combination of oxygen and chlorine dioxide in a
process we call ODIOOT . The OD1oo process was designed to improve the quality of the
mill's wastewater. The bleaching time for pulp vanes depending on the brightness
required, but the process from chips to bleached pulp takes about 18 hours, after which the
pulp is held in high-density storage tanks until it is needed on the paper machines.
Paper and Paperboard Manufacturing: Canton's three paper machines, Nos. 11, 12,
and 20, produce more than 765 packed tons of uncoated paper each day, while No. 19
makes approximately 700 packed tons of paperboard a day for a combined total of nearly
535,000 packed tons annually. The pulp,refined and mixed with large amounts of water
and various additives, is pumped to the four paper machines. Also at this stage, hardwood
pulp and softwood pulp are mixed together in various proportions to enhance the paper's
smoothness,printability, and strength. The pulp solution, about 99.5 percent water, flows
horizontally onto a rapidly moving, fine mesh screen called the wire. A uniform sheet is
formed as excess water is drained away. Depending on the machine and the grade of
paper being made, the continuous web of paper is formed and dried at speeds ranging from
750 to 2,000 feet per minute. At the end of the dryer, about 95 percent of the water has
been removed, with the remaining moisture left in the sheet to prevent cracking. The
calender stack, a set of rolls stacked one above the other,irons the paper to reduce its
thickness and increase smoothness. Then, as it leaves the calenders, the paper is wound
onto large reels. When the reel is full, it is taken to the winder where it is cut into smaller
rolls to meet the needs of our customers' converting equipment.
Converting and Shipping: Once the manufacturing process is complete, the priority is to
ship the paper and paperboard. But depending on end uses and customers needs, most of
the uncoated paper made at Canton is shipped directly to customers.
Recovery and Utility: This is the stage of the manufacturing operation that recovers,
recycles, and makes ready for reuse most of the spent pulping chemicals (the remainder of
which is burned as fuel). After being cooked, the pulp contains both fiber and used
cooking liquid, or black liquor, which is mainly composed of dissolved lignin and other
natural wood chemicals. The chemicals and dissolved lignin are concentrated in the
evaporators, and the resulting thick liquid is burned in recovery boilers. Further
processing in the lime kiln and causticizing area recovers 90 percent to 95 percent of the
original pulping chemicals, which are reused in the digesters. This part of the mill also is
responsible for the steam and electrical generation that powers the entire papermaking
process.
The Environment: At Blue Ridge Paper Products, safeguarding the quality of air, water,
and soil -- along with reducing waste and conserving resources is an integral company
commitment. Canton is a model of the ongoing efforts to protect the environment by
reducing, reusing, and recycling. A large share of the$330 million spent on the CMP was
directed toward reducing the color of the mill's wastewater. Among other successes, the
mill already has reduced the amount of water used each day by more than 35 percent.

a
Additionally, the color of the wastewater has been significantly reduced by more than 80
percent.
Two processes at Canton are centerpieces of a program that is expected to set new industry
standards for improved pollution prevention: oxygen delignification used with 100
percent substitution of chlorine with chlorine dioxide which we call OD100; and bleached
filtrate recycle, or BFR. The OD100 process captures and recycles many dissolved wood
chemicals that might otherwise be discharged with wastewater. The ODloo technology is
what the EPA has based its new effluent standards for the industry. Canton.also is the
demonstration site for BFR, which has the potential for lessening the impact of the
papermaking process on the environment. This breakthrough technology opens the door
to the concept of a closed bleaching process that has only a minimal impact on the
environment. OD100 and BFR demonstrate a commitment to investing in the technologies
that both protect the environment and make quality paper products.
vm

Brief NPDES Permit History
Blue Ridge Paper Products Canton Mill
• 1988 EPA-issued Permit
— Initial color variance based on technical and economic
review of color treatment technologies
— 85 ppm at TN state line, color prediction model
— Allowed Canton mill modernization project to proceed
during 1990 — 1992
• 1994 — 1996 State-issued Permit
— Set color discharge mass limits
— NC / TN dispute over state line color
— Meanwhile, Canton mill effluent color discharge
reduced by 75% compared to 1988 levels
— BFR demonstration

Brief NPDES Permit History
Blue Ridge Paper Products Canton Mill
• 1997 Settlement Agreement
— Resolved issues between NC, TN and enviro groups
— Revised color & temperature variance for NC portion
of Pigeon River
— Set annual color mass discharge limits to meet 50 ppm
at state line under 30Q2 flow conditions
— Established Technology Review Workgroup (TRW)
and NPDES Committee
— Required implementation of BFR and certain BM[Ps
— Established tiered color reduction limits based on
technical, economic and operational feasibility
— Established framework for interested party participation
in 2001 permit

Brief NPDES Permit History
Blue Ridge Paper Products Canton Mill
• 2001 Permit
— Renewed color & temperature variance for NC portion
of Pigeon River
— TRW heavily involved in permit development
— Continued tiered color reduction limits based on
implementation / evaluation of "highest certainty",
"reasonable certainty" and "lowest certainty" items.
— Established schedule of technical reports and
performance evaluations to support tiered color
reduction limits
— Canton mill effluent color discharge reduced by 85 to
90% compared to 1988 levels
— Permit expires 11/30/2006

Present SE Color Limits
Annual Average
• December 2001 : 48,000 lbs/day
• January 2004: 42,000 lbs/day
• March 2006: Target 32,000 — 39,000 lbs/day
To reach 32K,
we'll need to run
at 28 — 30!
r r

Brief NPDES Permit History
Blue Ridge Paper Products Canton Mill
g p
Other milestones
Canton Mill purchased by employees — May 1999
Blue Ridge Paper became Charter Member of EPA
Environmental Performance Track — Dec 2000
Fishing advisories for dioxin lifted
2001 — NC portions of Pigeon River
2002 —TN portions of Pigeon River
Non-game species re-introduction project
coordinated by University of Tennessee Knoxville
2002 — TN portions of Pigeon River
2004 — Expanded to NC portions of Pigeon River

NC DHHS release:Dioxin Posting on Pigeon River Rescinded; Page 1 of 2
Michael F. Easley Carmen Hooker Buell
Governor Secretary
North Carolina
Department of Health and Human Services
For Release: IMMEDIATE
Date: August 28, 2001
Dioxin Posting on Pigeon River Rescinded;
Walters Lake Advisory Partially Rescinded
RALEIGH-The fish consumption advisory on the Pigeon River in Haywood County has
been completely lifted and the Walters Lake advisory has been partially lifted, Interim State
Health Director Leah Devlin announced today.
The lifting of the Pigeon River advisory indicates that all fish from the river can now be
eaten safely. The original advisory, enacted by the State Health Director in 1988, had
advised the public not to eat fish from the Pigeon River below the Champion International
paper mill located in Canton because of dioxin contamination. The advisory was reduced in
1994 to include only carp and catfish.
Walters Lake, also known as Waterville reservoir, is located downstream from the mill. Fish
tissue samples from the river and lake for the past two years show that only carp from
Walters Lake are still contaminated above the recommended level for dioxin. Therefore, a
limited advisory for carp in Walters Lake remains in effect. The limited advisory
recommends that women of child-bearing age and children not eat any carp from Walters
Lake. All other persons can consume one meal of carp per month from the lake.
There are no longer any restrictions on eating gamefish such as largemouth bass,
smallmouth bass, crappie,bream and trout or any species of catfish from the lake.
"This is good news," said Dr. Devlin. "The environment has truly gotten cleaner in this area
and the conditions continue to improve, and that's why we were able to further revise these
advisories."
"North Carolina has a very stringent water quality standard for dioxin," said Bill Ross,
Secretary of the N.C. Department of Environment and Natural Resources. "That standard
has driven improvements at the mill, which have paid off with the continued downgrading
of these advisories. Eliminating the discharge of dioxin into our state's waters has created a
cleaner environment."
Improved pollution controls at the Canton paper mill were enacted during the late 1980s.
The Canton mill, formerly owned by Champion International, was purchased by mill
employees and renamed Blue Ridge Paper Products Inc. in 1999.
For questions regarding fish advisories, contact the Occupational and Environmental
htti)://www.dhhs.state.nc.us/pressrel/8-28-Ola.htm 5/18/2005

NC DHHS release:Dioxin Posting on Pigeon River Rescinded; Page 2 of 2
Epidemiology Branch of the N.C. Department of Health and Human Services at 919-733-
3410 or visit the NC DHHS Fish Consumption Advisory web site at
http://www.schs.state.nc.us/epi/fis
Public Affairs Office Debbie Crane
101 Blair Drive, Raleigh, NC 27603 Director
[phone]
FAX [phone]
http://www.dhhs.state.nc.us/pressrel/8-28-Ola.htm 5/18/2005

RESULTS OF 2004
DIOXIN MONITORING IN FISH TISSUE
I
Prepared for:
Blue Ridge Paper Products Inc.
Canton Mill
Canton, North Carolina
Prepared by:
EA Engineering, Science;and Technology, Inc.
444 Lake Cook Road, Suite 18
Deerfield, 1L 60015
f
February 2005
_ 1920201

EXECUTIVE SUMMARY
Bottom feeding species were collected in 2004 from six locations in the Pigeon River and
analyzed for 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD), 2,3,7,8-tetrachlorodibenzofuran
(TCDF), and other CDD and CDF isomers. TCDD and TCDF concentrations in fillet
composites from bottom feeders were very low (range=non-detected to 1.0 ppt) at the three
riverine locations downstream of the mill. Bottom feeders used at these locations were
common carp, black redhorse, and channel catfish. TCDD concentrations in bottom feeder
fillet composites at the two Waterville Lake locations were 1.7 ppt and 1.6 ppt (Stations 4A
and 4B, respectively) for carp and non-detect for flathead catfish (Station 4A) and channel
catfish (Station 4B). Since 1990, TCDD concentrations in common carp fillets have declined
dramatically (94-99 percent) at all downstream stations(Figure ES-1).
B
r
f
vii

Figure ES-1. TCDD Concentrations in Carp Fillets Couected from the Pigeon River, 1990-2004
(Stations 2 and 3).
20
15
c
4 Station 2
0
— -©— Station 3
•L
w
L
d
Q
Y 10 —
Q
❑
U
F
5
q\
b o
- - - - --
0
19gO 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004
YEAR
a) TCDD concentrations at Station 3 were not detected,therefore,the value plotted represents the detection limit for that sample.
b) TCDD concentrations at Station 2 were not detected,therefore,the value plotted represents the detection!limit for that sample.
c) TCDD concentrations at Stations 2 and 3 were not detected from 2000 through 2004,therefore,the values plotted represent detection limits for those samples.

figure ES-1 (Cont.). TCDD Concentrations in Carp Fill,, lollected from the pigeon River, 1990-2004
(Stations 4A and 4B).
70
60 5
50
o �� 1 Station 4a
40 — ►— Station 4b
a
M
a 30
F LI
20
10A,0
1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004
YEAR

Effluent Color Performance
and Challenges
Blue Ridge Paper Products Inc.
Canton, NC
NCASI Effluent Color Management Workshop
Baltimore, MD
21 March 2005
Updated 5119105 for DWQ VisitN��� BLUERIDGE
PAPER -PRO-DUCTS INC.

Blue Midge Paper Products
Canton Mill
1420 ton per day Kraft mill
- hardwood and softwood, 55% : 45% split
- free sheet paper and food grade paper board
Environmental Setting
- in heart of Blue Ridge Mountains
- on small river
133 sq mile upstream watersheds""
200 mgd average annual flow
35 mgd 7Q10 flow
- under close scrutiny for color

Wastewater Utilities
Blue Ridge Paper Canton Mill
29.9 mgd permitted wastewater discharge
monthly and annual average effluent color limits
25 mgd average discharge
activated sludge secondary treatment in tanks
mill wastewater plant • treats
wastewater - 1 • mgd municipal flow
n

Effluent Color Management
Blue Ridge Paper Canton Mill
NPDES permit is driver
— 2001 permit includes color reduction tiers
— 48k lbs/day in 2001 -> 40 to 42k lbs/day by 2004
--> 32 to 39k lbs/day by 2006
Technical approach to achieve color limits
— Bleach Filtrate Recycling TM
— Water conservation and reuse
— Tight mill operations
— Spill collection and recovery facilities
— BMP program focus on color

Historical Color Performance
Blue Ridge Paper Canton Mill
Annual Average Secondary Color
Blue Ridge Paper Canton Mill (tnru Apr 2005)
c�
U)
380 Canton Mill Modernization,
C400 333 301 307 BFR Demonstration
300
Color Improvement Projects
c 200
120
V 100 78 83
d
41 42 43 --41--45 40 39
LL
0
�/�W R1) RL (�(,�.O P� S� 5cp A� !l'J (p A` AV (�, OO O�
V/ N� Nq NJ Nq Nq ),q N(>j Nq Nq N4 Nq Nq VO VO VO VO VO ��
n�O
A

Color Improvement Projects
Blue Ridge Paper Canton Mill
• Color Prevention Approach
- 24-hr composite sample color monitoring of in-mill
sewers and 2-hr primary influent color monitoring
- spare clarifier for spill diversion & treatment
- numerous improvements to spill collection and storage
for outages and process malfunctions
- closure and internal recycling of filtrates and wash
water from small color sources
- double mechanical seals
- BFR and washing reliability upgrades to maintain high
filtrate closure
- color performance is a mill KPI

Color Improvement Projects
Color Reduction Initiatives Under 2001 NPDES Permit-May 2005 Update
Blue Ridge aper Products, Inc. - Canton Mill
Color Reduction Measure Mffi-69-7=1 2oo2 INF2-05=1 2004 =2005M 2006
1 2-Hour Color Testing _ __ __
2 liebereott Recommendations Implemented Permit-
3 Use of Off-line ClarifurforSpill Diversion
4 Hwd Brown Recovery Tank line to Pine Blow Tower
5 1-Hour colortestmg before and during maintenance outages specified
6 Installation of Mechanical Seals(clean waterse rc ation) and other
7 Improvement of equipment used for handling Pine and
Hardwood Knot Rejects
S $1.5MM spent on Bleach Filtrate Recycle Improvements _
9 Installed Pine Brownstock Control Logic' rovements initiatives
to Determined multiple contributors and interaction effects
causing Sewer Csnemted Color
II Bench-scale sewer-generated colorwork identified
12 Process Optimization/Six Sigtnt Team designated for
Hardwood Fiberline color lutmovements by Blue
13 Improvements made to Pine Brownstock sumps for better
recovery
14 White Rot Fungus Trial-growth efforts unsuccessful,may Ridge
re-visit in future.
15 Pine Brown Recovery Tank Line to Hwd Blow Tower
16 Milk of line Trial(not successful) ___ Peal
O PPY0. lit
Pine and Hardwood Quaternary Screen Rejects Press
17 (eliminate quaternary screen rejects discharge to sewer, since 2�01
recover filtrate and shives)
Trial to confumand size system for C102 de-coloriation of -
18 CRP/evaluate full-scale application(trials completed after Sep
04 Floods,not economically,technically or operationally
feasible)
19 Cacen liquorsump at recovery furnaces(implementation
delayed b Sep 04 floods)
Additional Spill Tank Veto=for color material recovery
20 during outages and process upset events
21 Acid Sewer Rerouting-improved segregation of bleach plant
filtrates with option to bypass primary clarifiers
Completed Process Change/Evaluation Process Evaluation or Change
too Continued Performance 1 rovement Expected Performance Improvem

Recent Color Performance
Blue Ridge Paper Canton Mill
Annual Average Secondary Color a lbs per day held steady
Blue Ridge Paper Canton Mill(thru Apr 2005)
m
9
w 60
0 40 40 39 Production-Normalized SE Color
30 Blue Ridge Paper Canton Mill (thru April 2005)
o a
0 20 m 40.0
0 10 °a 32.4 32.0 30.4 32.3
w 0 2000 2001 2002 2003 2004 2005 30.0 2�2
rn
pre- YTD `o
flood 0 20.0
d
W 10.0
N
2000 2001 2002 2003 2004 2005
6800 lbs per day color pre- YTD
flood
reduction accounting for
production lbs / ADTP x 0.508 = kg / tonne

Current and Best Color Performance
Blue Ridge Paper Canton Mill
Production
Normalized
Avg SE Color Color, Avg SE Color
Year Ibs per day Ibs per ADTP Conc, mg/I
2000 42,130 32.4 210
2001 42,676 32.0 212
2002 413166 30.4 205
2003 44,627 32.3 219
2004 pre-flood 399737 27.4 190
2005 YTD 399135 27.2 174
2004 417463 29.2 205
Best performance periods This color
Dec 03 — Feb 04 25.91bs per ADTBP performance is
Mar — Apr 05 23.8 lbs per ADTBP among best of best
SE color concentration 160 to 180 ppm pulp mills in world

Color Challenges and Issues
Blue Midge Paper Canton Mill
• Sewer generated color
- color of bleach plant filtrates increases 20% or more
across sewer system and wastewater treatment
- effect of pH, sulfides, temperature and anaerobic
conditions not fully understood
(not all color is created equal)
• washing consistency
- can hurt filtrate recycling r
and closure
• Single events 4�
- add 1500 to 3000 lbs to s,
monthly avg color
- add 500 lbs to annual avg color

Color Challenges and Issues
Blue Ridge Paper Canton Mill
The last 10,000 lbs/day of color
2006 target of 32,000 lbs/day 4 22.5 lbs / ADTP or 11 .4 kg / tonne
- no magic bullets
- about at the limit of tight mill operations and color
prevention techniques
- about at the limit of BFR `�
other internal recycles
h
Y 1
- want to achieve 2006
target with color prevention
techniques if possible

2006 NPDES Permitting
• 316a Thermal Variance Study
— Contracted to University of Tennessee, Knoxville
concurrent with non-game species reintroduction work
— Work plan submitted 3/l/05
— Field work this summer
• Statistical evaluation of color performance to
support 32-39k lbs/day color target is due
12/1/2005
— DWQ & TRW review & recommendation - 2/1/06
— Revised color limit, if applicable - 3/1/06
• Thermal variance report and permit application are
due by 1 May 2006

Current Color Improvement Projects
Color Reduction Initiatives Under 2001 NPDES Permit-May 2005 Update
Blue Ridge Paper Products, Inc. - Canton Mill
Color Reduction Measure 2001 1 2002 INE2003 1 2004 2005 2006
1 2-Hour Color Testing
2 Uebergott Recommendations Implemented Initiatives
3 Use of Off-line Clarifier fors ill Diversion
4 Hwd Brown Recovery Tank Line to Pine BlowTower
5 1-Hour color testing before and during maintenance outages identified
6 Installation of Mechanical Seals(clean water segregation
) by Blue
7 Improvement of equipment used for handling Pine and
Hardwood KnotRe'ects
8 $L5MM spent on Bleach Filtrate Recycle Improvements Ridge
9 Installed Pine Brownstock Control Logic rovements K V
10 Determined multiple contributors and interaction effects
cousin Sewer
lesewenem[edColor Paper to
I1 Bench-scale sewer-generated color work
12 Process Optimization/Six Sigma Team designated for
Hardwood Fibedine color irrprovements, achieve
13 Improverrents made to Pine Browastock sumps for better
recovery
14 White Rot Fungus Trial-growth efforts unsuccessful,may March
re-visit in future.
I5 Pine Brown Recovery Tank Line to Hwd BlowTower
16 Milk of Lim Trial(not successful) 2006 color
Pine and Hardwood Quaternary Screen Rejects Press
17 (eliminate quaternary screen rejects discharge to sewer,
recover filtrate and strives) reduction
Trial to cent=and size system for C102 decolorization of -
18 CRP/evaluate full-scale application(trials completed after Sep
04 floods,not economically,technically or operationally targets
feasible
19 Caeen liquor sump at recovery furnaces(implementation
delayed outages
ge and pros)
Additional Spill Tank Volume for color material recovery
20 Burin outa es and process upset events
21 Acid Sewer Returning-improved segregation of bleach plant
filtrates with option to bypass primary clarifiers
Completed Process Change Evaluation Process Evaluation or Change
rt— Continued Performance Improvement Expected Performance Improve

Color Reduction Initiatives Under 2001 NPDES Permit - May 2005 Update
Blue Ridge Paper Products, Inc. - Canton Mill
Color Reduction Measure 20D1 2002 2003 2004 2Q95 2006
1 2-Hour Color Testing
2 Lieber ott Recommendations Implemented
3 Use of Off-line Clarifier for Spill Diversion
4 Hwd Brown Recovery Tank Line to Pine Blow Tower
5 I-Hour color testing before and during maintenance outages
6 Installation of Mechanical Seals(clean water segregation)
Improvement of equipment used for handling Pine and
7 Hardwood Knot Rejects
8 1$1.5MM spent on Bleach Filtrate Recycle Improvements
9 Installed Pine Brownstock Control Logic improvements
10 Determined multiple contributors and interaction effects causing
Sewer Generated Color
11 Bench-scale sewer-generated color work
12 Process Optimization/Six Sigma Team designated for Hardwood
Fiberline color improvements
13 Improvements made to Pine Brownstock sumps for better
,recovery
14 White Rot Fungus Trial-growth efforts unsuccessful,may re-
visit in future.
15 Pine Brown Recovery Tank Line to Hwd Blow Tower
16 Milk of Lune Trial(not successful)
Pine and Hardwood Quaternary Screen Rejects Press(eliminate OMMMMMM
17 quaternary screen rejects discharge to sewer,recover filtrate and
shives
Trial to confirm and size system for C102 de-colorization of
18 CRP/evaluate full-scale application(trials completed after Sep
04 floods,not economically,technically or operationally
feasible
.................................... ............................................................................................................ ................................... ....................................
Green liquor sump at recovery furnaces(implementation
19 delayed bv Sep 04 floods)
Additional Spill Tank Volume for color material recovery during
20 outages and process upset events
21 Acid Sewer Rerouting-improved segregation of bleach plant
filtrates with option to bypass primary clarifiers
- Completed Process Change/Evaluation Process Evaluation or Change
MWOMM Continued Performance Improvement Expected Performance Improvement
Colorproischd.xls, Initiatives Page 1 of 1 Printed 5/18/2005

VGBI
BLUE RIDGE PAPER PRODUCTS, INC. .
FOR: CANTON MILL '
AND
CLEAN WATER FUND OF NORTH CAROLINA
ON BEHALF OF THE ENVIRONMENTAL COALITION ON BRPP
BLEACH ENVIRONMENTAL PROCESS
EVALUATION AND REPORT
JUNE 8, 2001
L..

�] G N
i
A Comparison between Selected Effluent Parameters from the Blue RidgePaper Products Inc Canton Mill
Bleach Plant Effluent and Other Facilities in the U.S.A., Canada and Finland(Integrated Mills)
Pulp
Production
BHWK BSWK AOX TSS BOD . COD Color Flow*
Data From ADMT ADMT Lbs/ton Lbs/ton Lbs/ton Lbs/ton Lbs/ton Gal/ton
Canton Mill 1999 765 655 0.17 2.08 0.73 13.69 31.22 15,145
Canton Mill 1995 0.33 2.81 1.34 30.80 56.20 19,547
NCASI Study
Avg 2.16 6.68 4.13 76.88 200.55 20,637
Min 0.20 1.00 0.91 13.90 31.90 13,413
Max 16.78 23.00 16.06 224.00 581.00 42,000
Espanola Mill, 2000 450 550 0.36 7.2 4.00 99.02 124.20** 20,800
Boyle Alberta Mill, 2000(2) 1700 1480 0.40 4.8 0.41 15.0 51.11 22,890
CPPA Study
30HW,4SW, 38-43 mills
9 HW/SW-Avg 1.20 8.1 5.20 68.20 146.22 22,140
Min 0.32 4.3 0.41 15.90 24.20 19,800
Max 2.35 24.60 28.20 83.96 297.20 29,000
TCF Finland (mills
produce TCF and ECF HW& HW& 0.10 N/A 1.6 30.02 40.3 9,000
pulps based on demand) SW SW
(1) 1995 NCASI Solid Waste Survey (23 mills) - overall average of 17 to 30 mills
(2) 2000 (2) Canadian Mill data (Softwood pulp bleached on different days)
(3) 1996 CPPA Environmental Study (48 mills)
(4) 1999 Finnish mill data - (3 mills)
* Flow is Total Mill Effluent Flow
*" Reported Data is Color from the effluent treatment plant; estimated color in bleach plant effluent is 175
Lbs/ton. All other data in the table is bleach plant effluent (in flow to the effluent treatment plant).
CONFIDENTIAL 12

i
Acid Sewer Project
Blue Ridge Paper Products Canton Mill
• Acid sewer replacement
— Acid sewer was damaged by floods. Repairs were
made, but line requires long-term replacement.
— Plan - reroute acid filtrates in manifolded force main
above ground across river to primary clarifier splitter
box
— Benefit will allow better acid filtrates segregation and
reduce sewer generated color in primary clarifiers
— Schedule — out for bid 5105. Construction this summer
and tie-ins during Sep 05 semi-annual outage
— Wastewater construction permit ?

Flood Proj ects
Blue Ridge Paper Products Canton Mill
• Flood Strengthening
— Have raised critical electrical supply and control
systems at wastewater plant to above elevation of Sep
2004 floods
— Evaluating options to pump flood waters to keep mill
and critical systems at wastewater plant dry
— Recognition that mill and wastewater operations will be
disrupted by future floods of Sep 2004 magnitude.
— Focus is on protection of critical systems to minimize
damage and expedite future flood recovery.

2001 NPDES Permit Compliance Timeline
Permit No.NC0000272
Date: Color Requirements and Limitations:
December 1,2001 Monthly average effluent true color loading shall not exceed 55,000 pounds per
Completed day. The average annual discharge of true color for each calendar month shall
not exceed 48,000 pounds per day.
October 1,2002
(internal target date) Implement all `Highest Certainty' action items by October 1,2002 or in
sufficient time to generate a representative database of mill effluent color data
for statistical analysis due by October 1,2003.
Highest Certainty items include:
• Process Optimization
o See Liebergott Report for specific fiberline optimization
requirements
• Improved black liquor leak&spill collection and control
o Continuous improvement of operating practices so more leaks
and spills are recovered rather than discharged to sewer;
o Improvement in preparation for planned outages to maximize
capture of tank clean-out waste and routing to recovery;
o Reduction of clean water that continuously runs into sewers
to prevent dilution of smaller spills and facilitate recovery of
highly colored wastewaters;and,
o Improvement in the equipment used for handling of knot
rejects to prevent black liquor leaks into the recovery sumps.
• BFR reliability improvement
Highest Certainty items shall reduce the annual average color discharge limit
6,000—8,000 lbs/day,based on the statistical analysis conducted for the October
1,2003 report.
October 1,2003
Completed Report due to DWQ,which must include:
• Statistical analysis of monthly average color since implementation of
`Highest Certainty' actions and technologies
• Mill performance as related to color since `Highest Certainty' actions
and technologies implemented,and
• All available data necessary to derive the lowest achievable annual
average and monthly average color loading limits.
November 1,2003 The NCDWQ,in consultation with the TRW and NPDES Committee,shall
Completed recommend the lowest achievable annual average and monthly average color
loading effluent limitations(based on the mill's October 1,2003 report.)

December 1,2003 Limits recommended by DWQ become effective if they are within or below the
Completed, got target range of 40,000—42,000 pounds per day as an annual average.
extension to 12/15/03 If the DW Q's recommended limits are above the target range,the Permit shall
be modified in accordance with NC's permitting process to reflect those limits.
DWQ will then recommend alternate interim limits to become effective
December 1,2003 and a new effective date for achieving an annual average
color loading limit of 40,000—42,000 pounds per day.
Report due to DWQ,TRW and the NPDES Committee on the feasibility of
achieving a target annual average color reduction within the range of 3,000 and
8,000 pounds per day from the reduction achieved by implementation of the
'Highest Certainty'actions. Report shall include:
• An evaluation of the use of the `Reasonable Certainty' actions
identified in the EPA Tech Team Report(Ozone/Chlorine Dioxide
stage for hardwood bleach line and second stage oxygen delignification
for the pine line),
• Any other actions that would result in additional color reductions(see
last bullet),
• Actions taken by the permittee to reduce color loading since permit
issuance,
• The technical,economic, and operational feasibility of implementing
the 'Reasonable Certainty' actions on a continuous or intermittent basis
in order to achieve a target annual average color reduction within the
range of 3,000 and 8,000 pounds per day,
• The projected additional color reduction expected for each technology
J evaluated and maximum color reduction possible using the identified
1 technologies,
• A proposed schedule for implementation of process improvements or
installation of technologies required to achieve an additional effluent
color reduction of 3,000—8,000 pounds per day and,
• An updated report on the results of ongoing and additional planned
color reduction activities.
February 1,2004 DWQ,in consultation with the TRW,shall approve or modify the Permittee's
recommended plan for achieving an additional 3,000—8,000 pounds per day
reduction to the target annual average.
NOTE: Permit was modified to annual average limit of 42,000 lbs/day and
monthly maximum limit of 52,000 lbs/day.
December 1,2004 Report Due to DWQ and TRW evaluating color reduction technologies
Extension to April 1, associated with the CRP wastestream. Report must include/identify:
2005 due to Sept.2004 floods
• Technical,economic,and operational feasibility of implementing the
applicable technologies on all or a portion of the purge stream,
• Specific economic and implementation issues associated with the
improvements,
• Projected additional color reduction expected for each technology
evaluated and maximum color reduction possible using the identified
technologies including,but not limited to:
F o Analysis of the land application of the high chloride
1 wastewater,
o Commercial incineration,

/ o Coagulant/precipitation technologies and,
o Solidification for land disposal
February 1,2005 DWQ,in consultation with the TRW,shall evaluate the feasibility of
Extension to.Tune 1, implementing identified technologies for further color reduction and shall
2005 due to Sent. submit to the NPDES Committee their recommendations regarding color
2004 floods reductions associated with the treatment of the CRP stream.
If during the course of the CRP evaluation Blue Ridge identifies a technical,
economic,and operationally feasible color reduction technology that can be
implemented for treatment of the CRP wastestream,the permittee may request
that the TRW review this technology for implementation at the Canton Mill. If
the TRW agrees such technology is suitable and that the color reductions
achievable are adequate,the mill's obligation to research additional technologies
will be waived after formal notification from Blue Ridge Paper.
December 1,2005 Permittee shall submit,as related to 'Reasonable Certainty' items,a statistical
analysis of Blue Ridge Paper's effluent quality performance including:
• A statistical analysis of monthly average and annual average color
discharge,
• Mill performance as related to color,and
• All available data necessary to derive the lowest achievable annual
average and monthly average color loading limits.
February 1,2006 DWQ,in consultation with the TRW,shall recommend to the NPDES
Committee the lowest achievable annual average and monthly average color
loading effluent limitations.
March 1,2006 If the recommended limits are within or below the target range of 32,000—
39,000 pounds per day as an annual average,the limits shall become effective.
If the recommended limits are above the 32,000—39,000 pounds per day target
range,the Permit shall be modified in accordance with NC's permitting process
to reflect those limits.
Report due to DWQ the TRW and the NPDES Committee on the color
reduction efforts as part of the Variance review process (Triennial Review).
Report shall include:
• An evaluation of Color in the Pigeon River at the Fiberville Bridge and,
• An evaluation on the feasibility of complying with NC's Color
Standard.
The NPDES Permit shall be subject to reopening based upon the following and in association with the
required triennial reviews:
• Any breakthrough in color removal technologies,which shall be brought to the NPDES
Committee for consideration,by BRPP and the DWQ,as soon as they are discovered.
• An acceptable statistical analysis of effluent color discharge data demonstrating significantly
better color removal performance than that currently prescribed in the variance and permit.
• Successful application of end-of-pipe color reduction technology or in-mill color minimization
effort that results in significant and measurable reduced mass color discharge.

4, The permittee shall not increase the mill's pulp production capacity during the term of this permit,unless
the permittee can demonstrate that the increased production can be achieved while reducing color loading.
In addition,increasing the mill's pulp production capacity may require permit revision in accordance with
NC's NPDES Permitting rules.
1

MichaelState of Norrth Carolina
y William G.Ross,Jr.,Secretary
F" Department of Environment and Natural Resources
y Alan W.Klimek,P.E.,Director
Division of Water Quality
February 27,2004
Robert Shanahan,Vice President and Operations Manger
Blue Ridge Paper Products (,114h
il
P.O.Box 4000
Canton,North Carolina 28716 7
Subject: NPDESPermit Modification
Color Limitations
r Permit Number:NC0000272
". Blue Ridge Paper Products
Canton Mill
Haywood County
Dear Mr. Shanahan:
Blue Ridge Paper's NPDES permit was reissued on November 15,2001. That permit included
several special conditions concerning effluent color discharges from the mill. Section A. (8.) of the
permit in part 5.required that Blue Ridge Paper submit "a report including a statistical analysis of
the permittee's monthly average color discharge,mill performance as related to color, [and] all
available data necessary to derive the lowest achievable annual average and monthly average color
loading limits"by October 1,2003. Blue Ridge Paper provided the required report in accordance
with that condition.
The 2001 NPDES Permit also required that the Division review the October 1 report in consultation
with the Technology Review Workgroup (TRW),Chaired by the Environmental Protection Agency
and with members from both North Carolina and Tennessee,and determine appropriate color
loading limitations for this permit. The TRW provided to DWQ its final recommendation on what it
believes is the most appropriate interim color limitations for the mill for annual average color
discharged and for monthly average color discharge on February 4,2004. The Division has
reviewed that recommendation and is providing this written notification to Blue Ridge Paper that its
annual average and monthly average limitations for effluent color are being revised.
Therefore, and in accordance with condition A. ( 8.) 6. of your permit and the TRW
recommendation,I am revising your annual average color limitation to the following:
Effective January 1,2004,the average annual discharge of true color for each calendar year shall not
exceed 42,000 pounds per day. Pounds of effluent color shall be determined in accordance with the
existing conditions and monitoring requirements of Permit Number NC0000272,issued on
November 15,2001.
rIn addition,I am making an administrative change to your permit to reduce your monthly average
color limitation from the current level of 55,000 pounds per day to 52,000 pounds per day. This
F change is effective March 1,2004 and reflects the recommendation of the TRW. As indicated above,
pounds of effluent color shall be determined in accordance with the existing conditions and
monitoring requirements of Permit Number NC0000272,issued on November 15,2001. This change
reflects a more restrictive limitation for monthly average color discharge and a monthly average
North Carolina Division of Water Quality [phone]
1617 Mail Service Center FAX[phone]
Raleich, North Carolina 27699-1617 n...r,e.....................,,,.,___-......___.._,

IA Ridge Paper Products
y it No. NC000272
r hex = z, g
` tation in line with the reduction of the annual average color limitation. This change provides a
s more effective regulatory control requirement for monthly average color and provides bett
r_.,_o protection of the water quality of the Pigeon River. er
The described changes affect only the limitations for annual and monthly average color discharge
limitations in the NPDES permit in section A. (B. )2. All other conditions in this permit remain in
effect as issued on November 15,2001 and effective December 1,2001. Please include a copy of this
letter with all copies of the plant's permit filed with the company and used for reference at the mill
site.
If any parts,or requirements of this permit modification are unacceptable to you,you have the t
righ
eipt of this
to an adjudicatory hearing upon written request within thirty(30) days following rec
letter. This request must be in the form of a written petition,conforming to Chapter eipt50B of the
North Carolina General Statutes,and filed with the Office of Administrative Hearings (6714 Mail
Service Center,Raleigh,NC 27699-6714). Unless such demand is made, this decision shall be final
and binding.
The Division appreciates the continued progress of Blue Ridge Paper in improving the quality of
your treated effluent and the Pigeon River. We anticipate continued improvement and pro gr toward the overall goal of this process: removal of the color variance for Blue Ridge Paper by the
expiration date of the NPDES Permit. If you have any questions concerning this permit
modification,please call Forrest Westall at 828/251-6208.
Sincerely,
Alan Klimek,PE
cc Central Files
Forrest Westall
Sergei Chernikov
Keith Haynes
Don Anderson
Paul Davis
David McKinney
Karrie-Jo Shell

State of North Carolina
Department of Environment
and Natural Resources �
Division of Water Quality
Michael F. Easley, Governor NCDENR
William G. Ross, Jr., Secretary
Gregory J.Thorpe, Ph.D., Acting Director
November 15, 2001
Mr. Robert Shanahan
Vice President-Mill Manager
Blue Ridge Paper Products
P.O.Box 4000
Canton,North Carolina 28716
Subject: NPDES Permit Issuance
Permit No.NC0000272
Blue Ridge Paper Products Inc.
Haywood County
Dear Mr. Shanahan:
After conducting a public hearing on Blue Ridge Paper's Request for renewal of the color
variance, temperature variance and the NPDES Permit, the Environmental Management Commission's
NPDES Committee approved renewal of the color variance, with the color conditions contained herein,
on October 10, 2001.The conditions related to color(as approved by the NPDES Committee)have been
incorporated into this permit and are an enforceable part of the permit.
In considering the comments presented at the September 6, 2001 public hearing, the hearing
officer made several recommendations for the color variance and the NPDES permit. The
recommendations made by the hearing clearly indicate the hearing officer's commitment to addressing
the concerns raised at the hearing and have been incorporated into the approved color variance and this
NPDES Permit. Specifically, the changes to the color variance and this permit include:
➢ The color variance and permit explicitly requires the Canton mill to implement all of the
'Highest Certainty' action items (as identified by the EPA's Tech Team).
➢ The initial color limit reduction to 42,000 pounds per day is now stipulated as a range of
40,000—42,000 pounds per day. After implementation of the 'Highest Certainty' action
items, the Technology Review Workgroup will evaluate mill performance. If the limit
recommended by the TRW is within or below the 40,000 to 42,000 pounds per day, that limit
will become effective on December 1, 2003, after written notification from the Director of
the Division of Water Quality.
➢ The color variance and permit explicitly requires the Canton mill to evaluate all of the
'Reasonable Certainty' action items.
➢ The color variance and permit explicitly states that the second 3,000 to 8,000 pounds per day
color reduction is in addition to the initial 6,000 to 8,000 pounds per day color reduction.
➢ The range for the final color limit effective December 1, 2005 is now 32,000 to 39,000
pounds per day. If the limit recommended by the TRW is within or below the 32,000 to
39,000 pounds per day, that limit will became effective on March 1, 2006, after written
notification from the Director of the Division of Water Quality.
➢ The report evaluating color reduction technologies for the Chloride Removal Process purge
stream is due on December 1,2004, so that this waste stream can be evaluated by the
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617-TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER- 50%RECYCLED/ 1 0%POST-CONSUMER PAPER
VISIT US ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES

Permit Number: NC0000272
Technology Review Workgroup for additional color reductions by the end of the permit
cycle.
➢ The evaluation of color reduction technologies associated with the Chloride Removal Process
waste stream shall include land application, commercial incineration, and solidification for
land disposal. The inclusion of these technologies should not be interpreted as limiting the
scope of this evaluation,rather that in addition to other technologies the report should include
the technologies referenced above.
➢ The color condition has been reworded to clarify that the role of the color ranges is not
permitting limits; rather they are clauses to trigger reopening of the permit. If the effluent
color limit, which will be set only after implementation of the"Highest Certainty" items and
the"Reasonable Certainty"(or equivalent) items, fails to fall at least within the ranges set in
the condition,Blue Ridge Paper would be required to satisfactorily justify the circumstances,
for not achieving the stipulated color reductions, to the Division of Water Quality, the
Technology Review Workgroup and the Environmental Management Commission's NPDES
Committee. If the TRW and the Division of Water Quality concur with Blue Ridge Paper's
rationale for not achieving the stipulated ranges,the permit would be reopened for public
comment, prior to presenting these findings to the NPDES Committee. If the performance of
the mill results in a limit within or better than these two color ranges, the permit would not be
reopened and the performance attained would become the limit that is effective on the date
stipulated in the color condition.
➢ Finally, the color condition has been reworded to better describe that the methodology for
determining the effluent color limits are based on the performance of the mill after
implementation of the identified technologies.The effluent color limit implemented at the
end of the permit cycle, will be set only after all the"Highest Certainty" items and
"Reasonable Certainty"(or alternative technology that will achieve similar color reductions)
items have been implemented. After implementation of these items, the Division(based on
the recommendation of the Technology Review Workgroup)will set a final effluent color
limit based on a statistical analysis of the performance of the mill.
The Division of Water Quality commends Blue Ridge Paper for their initiative and leadership in
fostering community involvement. The openness and willingness of Blue Ridge Paper to work with the
community was evident at the public hearing and has manifested itself in a trust between the community
and the company. The Division strongly recommends that Blue Ridge Paper continue their efforts to
foster this relationship and maintain a leadership role on the Community Advisory Committee.
The Canton mill has made incredible strides in reducing its impact on the Pigeon River, though
significant work remains. The Division of Water Quality has worked together with the community,EPA,
the State of Tennessee, and Blue Ridge Paper to develop a permit and color variance conditions that
meets the goals of all the parties. By the end of the permit cycle,the Division expects that, for the first
time since the variance was issued in 1988,the Division and the NPDES Committee will be able to
evaluate whether the Canton mill's performance has achieved compliance with North Carolina's narrative
color standard(15A NCAC 2B .0211(3)(f)).
However, if mill performance fails to achieve the color reductions expected, the Division
recommends that Blue Ridge Paper consider facilitating another independent evaluation of the Canton
mill, similar to the evaluation conducted by Dr.Liebergott.
In addition to the changes and recommendations regarding color above the hearing officer
suggested the following changes to the permit:
➢ Clarification on the sampling location for the Fiberville Bridge instream monitoring station
(refer to Special Condition A.(5.))

Permit Number: NC0000272
➢ Monitoring of the full range of dioxin and furan isomers on the effluent from the Canton mill
(refer to Special Condition A.(9.)).
Division personnel have reviewed your application for renewal of the subject permit, the
temperature and color variance. Accordingly,we are forwarding the attached NPDES discharge permit
that incorporates the recommendations of the hearing officer and the conditions of the color variance.
This permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between North Carolina and the U.S.Environmental Protection Agency
dated May 9, 1994 (or as subsequently amended).
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty (30)
days following receipt of this letter. This request must be in the form of a written petition, conforming to
Chapter 150B of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings (6714 Mail Service Center,Raleigh,North Carolina 27699-6714). Unless such demand is
made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division
may require modification or revocation and reissuance of the permit. This permit does not affect the
legal requirements to obtain other permits which may be required by the Division of Water Quality or
permits required by the Division of Land Resources,the Coastal Area Management Act or any other
Federal or Local governmental permit that may be required.
If you have any questions concerning the draft permit for your facility, please call Michael Myers
at(919)733-5083, extension 508.
Sincerely,
Gregory J.Thorpe,Ph.D.
Acting Director
cc: Central Files
NPDES Files
Aquatic Toxicology Unit
Marion Deerhake-North Carolina Environmental Management Commission,NPDES Committee
Jerry Wilde-Dead Pigeon River Council
402 W.Broadway
Newport,Tennessee 37821
Forrest Westall-Asheville Regional Office/Water Quality Section
Dan Oakley-North Carolina Attorney General,Environmental Division
Keith Haynes-Asheville Regional Office/Water Quality Section
Rob Lang-Compliance and Enforcement Unit
Diane Reid-Classification and Standards Unit
Scott Gordon-Chief of Permits, Grants,and Technical Assistance Branch,EPA Region IV
Roosevelt Childress Jr.-Environmental Protection Agency,Region IV
Marshall Hyatt-Environmental Protection Agency,Region IV
Karrie-Jo Shell-Environmental Protection Agency,Region IV
Don Anderson-Environmental Protection Agency,Headquarters
Mark Perez-Environmental Protection Agency,Headquarters

Permit Number: NC0000272
Justin P.Wilson—Deputy to the Governor
Tennessee State Capital,Suite G10
Nashville,Tennessee 37243
Paul Davis—Tennessee Division of Water Pollution Control
6th Floor,L&C Annex
401 Church Street
Nashville,TN 37243-1534
Charles Lewis Moore—County Executive Cocke County
360 Main Street,East
Newport,Tennessee 37821
David Jenkins—American Canoe Association
7432 Alban Station Boulevard,Suite B-232
Springfield,Virginia 22150-2311
Hope Taylor-Clean Water Fund of North Carolina
29'fz Page Ave
Asheville,North Carolina 28801
David McKinney—Tennessee Wildlife Resources
Ellington Agricultural Center
P.O.Box 40747
Nashville,Tennessee 37204
Jonathon E.Burr—Tennessee Division of Water Pollution Control
Regional Environmental Assistance Center
2700 Middlebrook Pike,Suite 220
Knoxville,Tennessee 37921
Robert Williams—Blue Ridge Paper
175 Main Street
P.O.Box 4000
Canton,North Carolina 28716
Derric Brown—Blue Ridge Paper
175 Main Street
P.O.Box 4000
Canton,North Carolina 28716
Patsy R.Williams—Chairman Newport/Cocke County Tourism Council
360 East Main Street
Court House Annex,Suite 141
Newport,Tennessee 37821
Dianne Keys—Newport/Cock County Tourism Council
360 East Main Street
Court House Annex,Suite 141
Newport,Tennessee 37821
Timothy L.Dockery—Director
City of Newport
Parks and Recreation Department
433 Prospect Avenue
Newport,Tennessee 37821
A. Dean Williams—Coordinator
Newport/Cocke County Economic Development Commission
433 Prospect Avenue
Newport,Tennessee 37821
Ray Snader—News Director
WNPC Radio AM/FM
377 Graham Street
Newport,Tennessee 27821

Permit Number: NC0000272
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission,
and the Federal Water Pollution Control Act, as amended,
Blue Ridge Paper Products Inc.
is hereby authorized to discharge wastewater from a facility located at
Blue Ridge Paper Products Inc.
Canton Mill Wastewater Treatment Plant
Off Highway 215
Canton
Haywood County
to receiving waters designated as the Pigeon River in the French Broad River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I, II, III and IV hereof.
This permit shall become effective December 1, 2001.
This permit and authorization to discharge shall expire at midnight on November 30, 2006.
Signed this day November 15,2001.
Gregory J.Thorpe,Acting Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit Number: NC0000272
SUPPLEMENT TO PERMIT COVER SHEET
Blue Ridge Paper Products, Inc.
is hereby authorized to:
1. Continue operation of a 29.9 MGD wastewater treatment plant for the treatment of wastewater
associated with the Blue Paper Products Inc. pulp and paper mill, the Town of Canton's
chlorinated domestic wastewater and landfill leachate. The treatment system consists of the
following treatment units:
• Grit Chamber
• Bar Screen
• Lift Pumps
• Polymer addition
pH control(COZ injection or H2SO4 backup)
/• Three primary clarifiers
• Nutrient Feed
• Aeration basins
• Three secondary clarifiers
• Residual belt presses
• Effluent flow measurement
• Cascade post aeration with oxygen injection
• Instream oxygen injection facilities
The facility is located at the Blue Ridge Paper Products WWTP, off Highway 215, Canton,
Haywood County, and;
2. Discharge treated wastewater from said treatment works at the location specified on the attached
map through outfall 001 into the Pigeon River, which is classified C water, in the French Broad
River Basin.

Permit Number: NC0000272
A. (1.)EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee
is authorized to discharge treated industrial,municipal,stormwater and landfill wastewater through
outfall(s) 001. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics Effluent Limits Monitoring Requirements
Monthly Daily Measurement -Sample;Type Sample
Average Maximum Frequency I Location']
Flow 29.9 MGD Continuous Recording I or Ej
BOD,5-day,20°C 3205 lb/day 108971b/day Daily Composite I,E,
Total Suspended Residue 125491b/day 49560 lb/day Daily Composite 1,El
NH3-N Daily Composite El
AOXz 1556.9lb/day 2822.2lb/day Daily Composite El
Color Daily Composite El
Dissolved Oxygen Oxygen4 Daily Grab Ei
Tem erature Daily Grab El
PIFDaily Grab El
Conductivity Daily Grab E,
Fecal Coliform 200/ 100 ml 400/ 100 nil Weekly Grab E,
COD Weekly Composite E,
Silver Quarterly Composite El
Zinc Quarterly Composite El
Total Nitrogen
(NO2-N+NO3-N+TKN) Monthly Composite E,
Total Phosphorus Monthly Composite El
Chronic Toxicity Quarterly Composite E,
Cadmium Quarterly Composite E,
Trichloro henol 3.0 QuarterlyComposite E,
Pentachlorophenol 8.9 g/L Quarterly Composite El
Selenium 10.6 /L Quarterly Composite El
2,3,7,8 Tetrachloro-dibenzo- 0.014 pg/L Quarterly Composite I,El
dioxin10
Conductivity Daily Grab Pigeon River
Flow I Daily Grab Pigeon River
Fecal Coliform Weekly Grab Pigeon River
Color Variable Grab Pigeon River
Tem erature Variable Grab Pigeon River
Dissolved Oxygen Variable I Grab Pigeon River
Footnotes:
I. Sample Location:I-Influent,E,—Effluent,Pigeon River-Instream sampling as specified in A.(5.)Instream
Monitoring Special Condition.
2. AOX monitoring shall be in accordance with the Sampling Plan for Cluster Rule Parameters(dated March 19,
2001)or subsequent modifications approved by the Division. AOX data shall be submitted on a quarterly basis
along with other Effluent Guideline chemical data;refer to A. (7.) Effluent Guideline Sampling Plan Special
Condition.
3. See A. (8.) Color Analysis and Compliance Special Condition.
4. The daily average effluent dissolved oxygen concentration shall not be less than 6.0 mg/L. See A. (10.)
Dissolved Oxygen Special Condition.
5. The monthly average instream temperature measured at a point 0.4 miles downstream of the discharge location
shall not exceed 32°C during the months of July,August,and September and shall not exceed 29.0°C during

Permit Number: NCOOOO272
the months of October through June. The monthly average instream temperatretemnerature measured at this
location shall not exceed the monthly average instream temperature of the upstream monitoring location by
more than 13.9°C [See Special Condition A.(13.)Temperature Variance Review Special Condition].
6. The pH of the effluent shall not be less than 6.0 nor greater than 9.0(on the standard units scale).
7. Chronic Toxicity(Ceriodaphnia)at 90%Effluent Concentration:March,June,September,December(see A.
(4.)Chronic Toxicity Permit Limit(Quarterly)).
8. Trichlorophenol and Pentachlorophenol limits and monitoring are provisionally waived since the facility has
certified that chlorophenolic biocides are not used at this facility. If the facility changes operations to include
chlorophenolic biocide,the Permittee shall notified the Division prior to use and the limits and monitoring
requirements shall become immediately effective.
9. If after 18 months selenium has not been detected,the facility may request that the Division review selenium
data for possible removal of the limitation.
10. See A. (9.) Dioxin Monitoring Special Condition.
11. See A. (5.) Instream Monitoring Special Condition.
See A.(6.) Best Management Practices(BMP)Special Condition.
See A. (11.) Town of Canton Inflow and Infiltration Special Condition.
Definitions:
MGD—Million gallons per day lb/day—Pounds per day
ml—Milliliter BOD—Biochemical Oxygen Demand
µg/L-Micrograms per liter AOX-Adsorbable Organic Halides
COD-Chemical oxygen demand pg/L-picograms per liter

Permit Number: NC0000272
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration, the
discharge of wastewater from the pine bleach plant to the wastewater treatment plant through
outfall(s) 002(E21), shall be limited and monitored by the Permittee as specified below and in A. (7.)
Effluent Guideline Sampling Plan Special Condition:
Effluent Characteristics Limits Monitoring 'ReciuirementsZ
Monthly , Daily Measurement 'Sample rType3 Sample
Average, , Maximum' Frequency Location'
Flow' Weekly Calculated Ez
Chloroform 5.15lb/day 8.60lb/day Weekly Grab EZ
2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L Monthly Composite E2
dioxin(TCDD)
2,3,7,8 Tetrachloro-dibenzo- 31.9 pg/L Monthly Composite EZ
p-furan(TCDF)
Trichlorosyringol < 2.5 µgII2 Monthly Composite EZ
3,4,5-Trichlorocatechol < 5.0 µg/L Monthly Composite E2
3,4,6-Trichlorocatechol < 5.0 µg/L Monthly Composite E2
3,4,5-Trichloroguaiacol < 2.5 µg/L Monthly Composite Fe
3,4,6-Trichloroguaiacol < 2.5 µg/L Monthly Composite E2
4,5,6-Trichloroguaiacol < 2.5 µg/L Monthly Composite E2
2,4,5-Trichlorophenol < 2.5 µg/1. Monthly Composite E2
2,4,6-Trichlorophenol < 2.5 µg/L Monthly Composite EZ
Tetrachlorocatechol < 5.0 µg/L Monthly Composite Fa
Tetrachloroguaiacol < 5.0 µg/L Monthly Composite E2
2,3,4,6-Tetrachlorophenol < 2.5 µg/L Monthly Composite F2
Pentachlorophenol < 5.0 µg/L Monthly Composite E2
Footnotes:
1. Sample Location:EZ—Effluent is composed of Bleach Plant Effluent-acid(acid sewer collected from tap
installed on filtrate pump from C102 bleaching stage D-100 and from tap installed on filtrate pump from C102
bleaching stage D-2)and Bleach Plant Effluent-alkaline(alkaline sewer collected from tap installed on filtrate
pump from alkaline extraction stage E.).See A. (7.)Effluent Guideline Sampling Plan Special Condition
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters as prepared by the permittee(Internal Outfall 002 parameters+internal Outfall 003
parameters+AOX from Outfall 001)shall be reported on a quarterly basis or more frequently;refer to A. (7.)
Effluent Guideline Sampling Plan Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance or flow
meters,and report total bleach plant flow(acid+alkaline wastestreams)in DMRs. Grab-collect separate grab
samples every 4-hours for 24-hour period from both the acid and alkaline streams,which will then be
composited separately by the lab,and analyzed as separate 24-hr composite acid and alkaline samples.
Composite-collect separate grab samples every 4 hours for 24-hour period from both the acid and alkaline
streams,then prepare and analyze a single flow-proportioned composite of the acid and alkaline wastestream.
4. For compliance purposes,the permittee must report the total chloroform mass loading based on addition of
separate acid and alkaline chloroform mass loadings.
5. Limits are based on Minimum Levels (MI.)specified in 40 CFR 430.01.
Definitions:
lb/day—Pounds per day µg/L—Micrograms per liter
pg/L—Picograms per liter

Permit Number: NC0000272
A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning upon the effective date of the permit and lasting until expiration, the
discharge of wastewater from the hardwood bleach plant to the wastewater treatment plant through
outfall(s) 003 (E31), shall be limited and monitored by the Permittee as specified below and in A. (7.)
Effluent Guideline Sampling Plan Special Condition:
Effluent Characteristics Limits Monitoring Requirements
Monthly DailyAverage Measurement Sample Type3 Sample
Average Frequency Location'
Flow2 Weekly Calculated E,
Chloroform 7.14lb/day 11.93lb/day Weekly Grab E3
2,3,7,8 Tetrachloro-dibenzo- < 10 pg/L. Monthly Composite E3
p-dioxin(TCDD)
2,3,7,8 Tetrachloro-dibenzo- 31.9 pg/L Monthly Composite E3
p-furan(TCDF)
Trichlorosyringol < 2.5 gg;112 Monthly Composite E3
3,4,5-Trichlorocatechol < 5.0 µg/L Monthly Composite E3
3,4,6-Trichlorocatechol < 5.0 µg/L Monthly Composite E3
3,4,5-Trichloroguaiacol < 2.5 µg/L Monthly Composite E3
3,4,6-Trichloroguaiacol < 2.5 µg/L Monthly Composite E3
4,5,6-Trichloroguaiacol < 2.5 µg/L Monthly Composite E3
2,4,5-Trichlorophenol < 2.5 µg/1. Monthly Composite E3
2,4,6-Trichlorophenol < 2.5 µg/L Monthly Composite E3
Tetrachlorocatechol < 5.0 µg/L Monthly Composite E3
Tetrachloroguaiacol < 5.0 µg/L Monthly Composite E3
2,3,4,6-Tetrachlorophenol < 2.5 µg/L Monthly Composite E3
Pentachlorophenol < 5.0 µg/I. Monthly Composite E3
Footnotes:
1. Sample Location:E3—Effluent is composed of Bleach Plant Effluent-acid(acid sewer collected from tap
installed on filtrate pump from C102 bleaching stage D-100)and Bleach Plant Effluent-alkaline(alkaline
sewer collected from tap installed on filtrate pump from alkaline extraction stage Eo).See A. (7.)Effluent
Guideline Sampling Plan Special Condition.
2. Monitoring and flow calculations shall be in accordance with the"Sampling Plan for Cluster Rule Parameters"
(dated March 19,2001)or subsequent modifications approved by the Division. Chemical results for Effluent
Guideline parameters,as prepared by the permittee(Internal Outfall 002 parameters+internal Outfall 003
parameters+AOX from Outfall 001)shall be reported on a quarterly basis or more frequently;refer to A. (7.)
Effluent Guideline Sampling Plan Special Condition.
3. Sample Type: Calculated-calculate separate flows for alkaline and acid sewers by water balance or by flow
meter,and report total bleach plant flow(acid+alkaline wastestreams) in DMRs. Grab-collect separate grab
samples every 4-hours for 24-hour period from both the acid and alkaline streams, which will then be
composited separately by the lab,and analyzed as separate 24-hr composite acid and alkaline samples.
Composite-collect separate grab samples every 4 hours for 24-hour period from both the acid and alkaline
streams, then prepare and analyze a single flow-proportioned composite of the acid and alkaline wastestream.
4. For compliance purposes,the permittee must report the total chloroform mass loading based on addition of
separate acid and alkaline chloroform mass loadings.
5. Limits are based on Minimum Levels (NIL)specified in 40 CFR 430.01.
Definitions:
lb/day—Pounds per day µg/L—Micrograms per liter
pg/L—Picograms per liter

Permit Number: NC0000272
A. (4.) CHRONIC TOXICITY PERMIT LIMIT(QRTRLY)
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to
Ceriodaphnia dubia at an effluent concentration of 90%.
The permit holder shall perform at a minimum,aaarterl monitoring using test procedures outlined in the"North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure,"Revised February 1998,or subsequent versions or
"North Carolina Phase 11 Chronic Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or subsequent
versions.The tests will be performed during the months of March,June,September,December.Effluent sampling
for this testing shall be performed at the NPDES permitted final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or ChV below the permit
limit,then multiple-concentration testing shall be performed at a minimum,in each of the two following months as
described in"North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure"(Revised-February 1998)or
subsequent versions.
The chronic value for multiple concentration tests will be determined using the geometric mean of the highest
concentration having no detectable impairment of reproduction or survival and the lowest concentration that does
have a detectable impairment of reproduction or survival.The definition of"detectable impairment,"collection
methods,exposure regimes,and further statistical methods are specified in the"North Carolina Phase II Chronic
Whole Effluent Toxicity Test Procedure" (Revised-February 1998)or subsequent versions.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge
Monitoring Form(MR-1)for the months in which tests were performed,using the parameter code TGP3B for the
pass/fail results and THP3B for the Chronic Value.Additionally,DWQ Form AT-3 (original) is to be sent to the
following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh,North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days
after the end of the reporting period for which the report is made.
Test data shall be complete, accurate,include all supporting chemical/physical measurements and all
concentration/response data,and be certified by laboratory supervisor and ORC or approved designate signature.
Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for
disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required,the
permittee will complete the information located at the top of the aquatic toxicity(AT)test form indicating the
facility name,permit number,pipe number,county,and the month/year of the report with the notation of`No Flow"
in the comment area of the form.The report shall be submitted to the Environmental Sciences Branch at the address
cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,monitoring will be
required during the following month.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water
Quality indicate potential impacts to the receiving stream,this permit may be re-opened and modified to include
alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism
survival,minimum control organism reproduction,and appropriate environmental controls,shall constitute an
invalid test and will require immediate follow-up testing to be completed no later than the last day of the month
following the month of the initial monitoring.

Permit Number: NC0000272
A. (5.) INSTREAM MONITORING SPECIAL CONDITION
Stream Mile Location Description Parameter Frequency
Designation Marker
UP 63.8 Pigeon River upstream of the Temperature Daily
waste treatment plant outfall D.O. Daily
(prior to mixing with the Conductivity Daily
discharge) Color 2/Week
Flow Daily
Fecal Coliform Weekly
DNl 62.9 Pigeon River at Fiberville Bridge Temperature Daily
D.O. Daily
Conductivity Daily
Color I 2/Week
DN23 57.7 Pigeon River Above Clyde Temperature Daily
D.O. Daily
DN3 55.5 Pigeon River Below Clyde See Footnote 3 See Footnote 3
DN4 53.5 Pigeon River at NCSR 1625 See Footnote 3 See Footnote 3
bridge
DN5 42.6 Pigeon River at Hepco Temperature Weekly
D.O. Weekly
Color Variables
Flov2 Daily
Waterville Reservoir See Footnote 4 Annually
DN6 26.0 Pigeon River prior to mixing with Color Variable
Big Creek
BC -26.0 Mouth of Big Creek prior to Color Variable
mixing with the Pigeon River
DN7 24.7 Pigeon River at Browns Bridge Temperature Weekly
(-NCITN State Line) D.O. Weekly
Color Variables
All instream samples shall be grab samples.
1. Color(See A. (8.) Color Analysis and Compliance Special Condition) All instream samples collected
shall be representative of the Pigeon River and Big Creek, respectively. Both true and apparent color
shall be monitored using the methods specified in A. (8.)Color Analysis and Compliance Special
Condition. Samples shall be collected at stations DN6,BC, and DN7 only when at least one generator
at CP&L is in operation and releasing water to the Pigeon River. Samples collected at DNl shall be
collected from the middle or midpoint of the transect of the Pigeon River.
2. Flow monitoring is necessary, as specified above, for the True Color calculation stipulated in A. (8.)
Color Analysis and Compliance Special Condition.
3. Dissolved Oxygen. The average daily dissolved oxygen concentration measured at River Mile 62.9
(DNl), and 57.7 (DN2), shall not be less than 5.0 mg/l and the instantaneous minimum dissdlved
oxygen concentration shall not be less than 4.0 mg/1 (See A. (10.) Dissolved Oxygen Special
Condition). If the dissolved oxygen drops below 5.0 mg/1-at station 57.7 then monitoring shall be
required at stations 55.5 (DN3) and 53.5 (DN4).
4. See A. (12.) Waterville Reservoir Sampling Special Condition.
5. Sampling is required 2/week during the summer and once per week during the winter. Summer is
defined as the period from April 1 through October 31, while winter is defined as November 1
through March 31.

Permit Number: NC0000272
A. (6.) BEST MANAGEMENT PRACTICES(BMP) SPECIAL CONDITION
The permittee must implement the BMPs specified in Section A below. The primary BMP objective is to
prevent leaks and spills of spent pulping liquors, soap, and turpentine. A secondary objective is to
contain,collect, and recover at the immediate process area, or otherwise control,those leaks, spills,and
intentional diversions of spent pulping liquor,soap, and turpentine that do occur. BMPs must be
developed according to best engineering practices and must be implemented in a manner that takes into
account the specific circumstances at the mill.
Section A. BMW Implementation Requirements
1. The permittee must return spilled or diverted spent pulping liquors, soap, and turpentine to the
process to the maximum extent practicable as determined by the mill,recover such materials outside
the process, or discharge spilled or diverted material at a rate that does not disrupt the receiving
wastewater treatment system.
2. The permittee must establish a program to identify and repair leaking equipment items. This program
must include: (i)Regular daily visual inspections of process area with equipment items in spent
pulping liquor, soap, and turpentine service; (ii)Immediate repair of leaking equipment items, when
possible. Leaking equipment items that cannot be repaired during normal operations must be
identified, temporary means for mitigating the leaks must be provided, and the leaking equipment
items repaired during the next maintenance outage; (iii)Identification of conditions under which
production will be curtailed or halted to repair leaking equipment items or to prevent pulping liquor,
soap, and turpentine leaks and spills; and(iv)A means for tracking repairs over time to identify those
equipment items where upgrade or replacement may be warranted based on frequency and severity of
leaks, spills, or failures.
3. The permittee must operate continuous, automatic monitoring systems that the mill determines are
necessary to detect and control leaks, spills, and intentional diversions of spent pulping liquor, soap,
and turpentine.These monitoring systems should be integrated with the mill process control system
and may include, e.g., high level monitors and alarms on storage tanks; process area conductivity(or
pH) monitors and alarms; and process area sewer,process wastewater, and wastewater treatment plant
conductivity(or pH)monitors and alarms.
4. The permittee must establish a program of initial and refresher training of operators, maintenance
personnel, and other technical and supervisory personnel who have responsibility for operating,
maintaining, or supervising the operation and maintenance of equipment items in spent pulping
liquor,soap, and turpentine service.The refresher training must be conducted at least annually and
the training program must be documented.
5. The permittee must prepare a brief report that evaluates each spill of spent pulping liquor, soap, or
turpentine that is not contained at the immediate process area and any intentional diversion of spent
pulping liquor, soap, or turpentine that is not contained at the immediate process area.The report
must describe the equipment items involved, the circumstances leading to the incident, the
effectiveness of the corrective actions taken to contain and recover the spill or intentional diversion,
and plans to develop changes to equipment and operating and maintenance practices as necessary to
prevent recurrence. Discussion of the reports must be included as part of the annual refresher training.
6. The permittee must establish a program to review any planned modifications to the pulping and
chemical recovery facilities and any construction activities in the pulping and chemical recovery areas
before these activities commence. The purpose of such review is to prevent leaks and spills of spent
pulping liquor, soap, and turpentine during the planned modifications, and to ensure that construction
and supervisory personnel are aware of possible liquor diversions and of the requirement to prevent
leaks and spills of spent pulping liquors, soap, and turpentine during construction.
7. The permittee must install and maintain secondary containment(i.e.,containment constructed of
materials impervious to pulping liquors) for spent pulping liquor bulk storage tanks equivalent to the

Permit Number: NC0000272
volume of the largest tank plus sufficient freeboard for precipitation. An annual tank integrity testing
program, if coupled with other containment or diversion structures,may be substituted for secondary
containment for spent pulping liquor bulk storage tanks.
8. The permittee must install and maintain secondary containment for turpentine bulk storage tanks.
9. The permittee must install and maintain curbing, diking or other means of isolating soap and
turpentine processing and loading areas from the wastewater treatment facilities.
10. The permittee must conduct wastewater monitoring to detect leaks and spills, to track the
effectiveness of the BMPs, and to detect trends in spent pulping liquor losses. Such monitoring must
be performed in accordance with Section E.
Section B. BMP Plan Requirements
1. The permittee must prepare and implement a BMP Plan.The BMP Plan must be based on a detailed
engineering review as described in this section. The BMP Plan must specify the procedures and the
practices required for the mill to meet the requirements of Section A, the construction the mill
determines is necessary to meet those requirements including a schedule for such construction,and
the monitoring program(including the statistically derived action levels)that will be used to meet the
requirements of Section E.The BMP Plan also must specify the period of time that the mill
determines the action levels established under Section D may be exceeded without triggering the
responses specified in Section E.
2. The permittee must conduct a detailed engineering review of the pulping and chemical recovery
operations--including but not limited to process equipment, storage tanks,pipelines and pumping
systems, loading and unloading facilities,and other appurtenant pulping and chemical recovery
equipment items in spent pulping liquor, soap, and turpentine service--for the purpose of determining
the magnitude and routing of potential leaks, spills, and intentional diversions of spent pulping
liquors, soap, and turpentine during the following periods of operation: (i)Process start-ups and shut
downs; (ii)Maintenance; (iii)Production grade changes; (iv) Storm or other weather events; (v)
Power failures; and(vi)Normal operations.
3. As part of the engineering review,the permittee must determine whether existing spent pulping liquor
containment facilities are of adequate capacity for collection and storage of anticipated intentional
liquor diversions with sufficient contingency for collection and containment of spills.The engineering
review must also consider: (i)The need for continuous, automatic monitoring systems to detect and
control leaks and spills of spent pulping liquor, soap, and turpentine; (ii)The need for process
wastewater diversion facilities to protect end-of-pipe wastewater treatment facilities from adverse
effects of spills and diversions of spent pulping liquors, soap, and turpentine; (iii)The potential for
contamination of storm water from the immediate process areas; and(iv)The extent to which
segregation and/or collection and treatment of contaminated storm water from the immediate process
areas is appropriate.
4. The permittee must amend its BMP Plan whenever there is a change in mill design, construction,
operation, or maintenance that materially affects the potential for leaks or spills of spent pulping
liquor,turpentine, or soap from the immediate process areas.
5. The permittee must complete a review and evaluation of the BMP Plan five years after the first BMP
Plan is prepared and,except as provided in Section B.4., once every five years thereafter. As a result
of this review and evaluation,the permittee must amend the BMP Plan within three months of the
review if the mill determines that any new or modified management practices and engineered controls
are necessary to reduce significantly the likelihood of spent pulping liquor, soap, and turpentine leaks,
spills, or intentional diversions from the immediate process areas, including a schedule for
implementation of such practices and controls.
6. The BMP Plan, and any amendments thereto,must be reviewed by the senior technical manager at the
mill and approved and signed by the mill manager. Any person signing the BMP Plan or its
amendments must certify to the Division under penalty of law that the BMP Plan (or its amendments)

Permit Number: NCO000272
has been prepared in accordance with good engineering practices and in accordance with this
regulation. The permittee is not required to obtain approval from the Division of the BMP Plan or any
amendments thereto.
Section C. BMP Recordkeeoing Requirements
1. The permittee must maintain on its premises a complete copy of the current BMP Plan and the
records specified in Section C.2 and must make such BMP Plan and records available to the Division
for review upon request.
2. The permittee must maintain the following records for three years from the date they are created: (i)
Records tracking the repairs performed in accordance with the repair program described in Section A;
(ii)Records of initial and refresher training conducted in accordance with Section A; (iii)Reports
prepared in accordance with Section A; and (iv)Records of monitoring required by Sections A and E.
Section D. Establishment of Wastewater Treatment System Influent Action Levels
1. The permittee must conduct a monitoring program per Section D.2, for the purpose of defining
wastewater treatment system influent characteristics(or action levels), described in Section D.3,that
will trigger requirements to initiate investigations on BMP effectiveness and to take corrective action.
2. The permittee must employ the following procedures in order to develop the action levels required by
Section D:
• Monitoring parameters.The permittee must collect 24-hour composite samples and analyze the
samples for a measure of organic content(e.g., Chemical Oxygen Demand(COD) or Total
Organic Carbon(TOC)). Alternatively, the mill may use a measure related to spent pulping liquor
losses measured continuously and averaged over 24 hours (e.g., specific conductivity or color).
• Monitoring locations.The permittee must conduct monitoring at the point influent enters the
wastewater treatment system. For the purposes of this requirement, the permittee may select
alternate monitoring point(s) in order to isolate possible sources of spent pulping liquor, soap, or
turpentine from other possible sources of organic wastewaters that are tributary to the wastewater
treatment facilities(e.g., bleach plants,paper machines and secondary fiber operations).
3. By the permit effective date, the permittee must complete an initial six-month monitoring program
using the procedures specified in Section D and must establish initial action levels based on the
results of that program. A wastewater treatment influent action level is a statistically determined
pollutant loading determined by a statistical analysis of six months of daily measurements.The action
levels must consist of a lower action level,which if exceeded will trigger the investigation
requirements described in Section E, and an upper action level, which if exceeded will trigger the
corrective action requirements described in Section E.
4. By January 15,2002, the permittee must complete a second six-month monitoring program using the
procedures specified in Section D and must establish revised action levels based on the results of that
program.The initial action levels shall remain in effect until replaced by revised action levels.
5. Action levels developed under this Section must be revised using six months of monitoring data after
any change in mill design,construction, operation, or maintenance that materially affects the potential
for leaks or spills of spent pulping liquor,soap, or turpentine from the immediate process areas.
Section E. BMP Monitoring Corrective Action and Reporting Requirements
1. The permittee must conduct daily monitoring of the influent to the wastewater treatment system in
accordance with the procedures described in Section D for the purpose of detecting leaks and spills,
tracking the effectiveness of the BMPs,and detecting trends in spent pulping liquor losses.

Permit Number: NC0000272
2. Whenever monitoring results exceed the lower action level for the period of time specified in the
BMP Plan, the permittee must conduct an investigation to determine the cause of such exceedance.
Whenever monitoring results exceed the upper action level for the period of time specified in the
BMP Plan, the permittee must complete corrective action to bring the wastewater treatment system
influent mass loading below the lower action level as soon as practicable.
3. Although exceedances of the action levels will not constitute violations of an NPDES permit,failure
to take the actions required by Section E.2 as soon as practicable will be a permit violation.
4. The permittee must report to the Division the results of the daily monitoring conducted pursuant to
Section E.1. Such reports must include a summary of the monitoring results, the number and dates of
exceedances of the applicable action levels, and brief descriptions of any corrective actions taken to
respond to such exceedances. Submission of such reports shall be annually, by March 3 1"of the
following year.
Section F. BMP Compliance Deadlines
1. The permittee is subject to the following BMP deadlines:
• Prepare BMP Plans and certify to the Division that the BMP Plan has been prepared in
accordance with this regulation not later than the permit effective date.
• Implement all BMPs specified in Section A that do not require the construction of containment or
diversion structures or the installation of monitoring and alarm systems not later than the permit
effective date.
Establish initial action levels required by Section D not later than the permit effective date.
Commence operation of any new or upgraded continuous, automatic monitoring systems that the
mill determines to be necessary under Section A (other than those associated with construction of
containment or diversion structures)not later than the permit effective date.
Complete construction and commence operation of any spent pulping liquor, collection,
containment, diversion, or other facilities, including any associated continuous monitoring
systems, necessary to fully implement BMPs specified in Section A not later than the permit
effective date.
• Establish revised action levels required by Section D as soon as possible after fully implementing
the BMPs specified in Section A,but not later than January 15, 2002.
• Submit Annual Reports required by Section EA to the Division by March 31"of the following
year.
Section G. BMP Definitions
1. Action Level: A daily pollutant loading that when exceeded triggers investigative or corrective action.
Mills determine action levels by a statistical analysis of six months of daily measurements collected at
the mill.For example, the lower action level may be the 75th percentile of the running seven-day
averages (that value exceeded by 25 percent of the running seven-day averages) and the upper action
level may be the 90th percentile of the running seven-day averages (that value exceeded by 10
percent of the running seven-day averages).
2. Division: North Carolina DENR,Division of Water Quality, 1617 Mail Service Center,Raleigh,
North Carolina 27699-1617.
3. Equipment Items in Spent Pulping Liquor,Soap, and Turpentine Service: Any process vessel, storage
tank, pumping system, evaporator,heat exchanger,recovery furnace or boiler, pipeline, valve, fitting,
or other device that contains, processes, transports, or comes into contact with spent pulping liquor,
soap, or turpentine. Sometimes referred to as"equipment items."
4. Immediate Process Area:The location at the mill where pulping, screening,knotting, pulp washing,
pulping liquor concentration, pulping liquor processing, and chemical recovery facilities are located,
generally the battery limits of the aforementioned processes. "Immediate process area" includes spent

Permit Number: NC0000272
pulping liquor storage and spill control tanks located at the mill, whether or not they are located in the
immediate process area.
5. Intentional Diversion: The planned removal of spent pulping liquor, soap, or turpentine from
equipment items in spent pulping liquor, soap, or turpentine service by the mill for any purpose
including,but not limited to, maintenance, grade changes, or process shutdowns.
6. Mill: The owner or operator of a direct or indirect discharging pulp, paper, or paperboard
manufacturing facility subject to this section.
7. Senior Technical Manager:The person designated by the mill manager to review the BMP Plan.The
senior technical manager shall be the chief engineer at the mill, the manager of pulping and chemical
recovery operations, or other such responsible person designated by the mill manager who has
knowledge of and responsibility for pulping and chemical recovery operations.
8. Soap: The product of reaction between the alkali in kraft pulping liquor and fatty acid portions of the
wood, which precipitate out when water is evaporated from the spent pulping liquor.
9. Spent Pulping Liquor: For kraft and soda mills"spent pulping liquor"means black liquor that is used,
generated, stored, or processed at any point in the pulping and chemical recovery processes.
10.Turpentine: A mixture of terpenes, principally pinene, obtained by the steam distillation of pine gum
recovered from the condensation of digester relief gases from the cooking of softwoods by the kraft
pulping process. Sometimes referred to as sulfate turpentine.

Permit Number: NC0000272
A. (7.) EFFLUENT GUIDELINE SAMPLING PLAN SPECIAL CONDITION
The bleach plant effluent samples(Outfalls 002 and 003) shall be analyzed for 2,3,7,8-TCDD in
accordance with EPA Method 1613. A single sample, from each of the bleach plant effluents, may be
analyzed to determine compliance with the daily maximum effluent limitation.
The bleach plant effluent samples (Outfall 002 and 003) shall be analyzed for the 12 chlorinated phenolic
compounds in accordance with EPA Method 1653. A single sample, from each of the bleach plant
effluents, may be analyzed to determine compliance with the daily maximum effluent limitation. The
Minimum Levels for each of the 12 chlorinated compounds are the same as the Daily Maximum
concentrations listed on the effluent pages for the respective outfall(s).
The final wastewater treatment plant effluent sample(Outfall 001) shall be analyzed for AOX in
accordance with EPA Method 1650, or subsequent test methods approved by the Division.
The permittee may request future monitoring modifications to the Effluent Guideline requirements,
including 1)use of ECF certification in lieu of monitoring for chloroform in the bleach plant effluents
(Outfall(s)002 and 003) when this rule is promulgated by EPA; 2) demonstrating compliance using
samples collected less frequently than every four hours; 3) using automated composite volatile samplers
for chloroform sampling; and 4)using automated composite samplers for chlorophenolic,2,3,7,8 TCDD
and 2,3,7,8 TCDF sampling. Such future requests will be evaluated in accordance with 15A NCAC
2H.0114.
The flow calculations for internal Outfall(s)002 and 003 shall not be subject to accuracy requirements
specified under Part II, Section D.3. This exclusion is similar to that provided for pump log flow
calculations.
Chemical data for Effluent Guideline parameters (Outfall(s)002 and 003 parameters+AOX from Outfall
001) shall be submitted to the Division on a quarterly basis or more frequently(January-March,April-
June,July-September, October-December). Quarterly submissions shall be due 60 days following the
last day of each quarter(Due dates=May 31,August 31,November 30, and February 28). Chemical data
shall be submitted on Division-approved DMR forms, with a separate form provided for each month.

Permit Number: NC0000272
A. (8.) REQUIREMENTS FOR COLOR ANALYSIS AND COMPLIANCE SPECIAL CONDITION
1. The color reduction requirements contained in this special condition have been derived directly
from the mill's efforts to identify possible reduction measures and from the EPA Technology
Review Workgroup(TRW report dated August 3, 2001)and the EPA Tech Team Report(dated
July 25, 2001). These requirements are aimed at securing the highest feasible reduction of the
mill's effluent color over the permit cycle and for laying the foundation for removal of the color
variance by the expiration date of this permit.
The EPA Tech Team Report identified three levels of possible color reduction actions (identified
in the report as Highest Certainty,Reasonable Certainty and Lowest Certainty). Each of these
tiers of reductions have identified specific actions or technologies that when implemented may
result in additional color reductions in the mill's effluent. For example,the color reduction goals
of the condition in Paragraph 6 of this special condition is premised on the implementation of all
the actions of'Highest Certainty.'
Paragraph 7 of this special condition requires the company to evaluate actions of'Reasonable
Certainty'. Identified under Reasonable Certainty'are the technologies of Ozone/Chlorine
Dioxide stage for the hardwood bleach line and second stage oxygen delignification for the pine
line. This condition requires the permittee to examine the technical, economic and operational
feasibility of implementing these technologies.The review of this required evaluation (Paragraph
7) will be supported by the EPA TRW. Regardless of the outcome of this feasibility analysis, the
permittee is required to achieve 3,000- 8,000 pounds per day additional color reduction, except to
the extent allowed by Paragraph 6. This is considered the equivalent reduction of what would be
expected from the installation of the two technologies identified by the EPA TRW process.
Color Treatment of the Chloride Removal Process Purge Stream is the color reduction
methodology with the'Lowest Certainty'. Therefore, this condition requires the permittee to
evaluate potential technologies for treatment of this wastestream and to implement those if shown
technologically, economically and operationally feasible.
Built into this special condition is a series of regulatory requirements that the permittee achieve
reductions of the mill's effluent color consistent with each series of reduction actions. This means
that following implementation of the Highest Certainty'actions the mill's annual color limit must
be reduced by 6,000- 8,000 pounds per day, except to the extent allowed by Paragraph 6. If the
implementation of all the actions identified under'Highest Certainty'actually result in better long
term effluent quality, this in no way reduces the permittee's responsibility to achieve the color
reductions measured by those actions identified as having Reasonable Certainty'of success and
determined to be technically, economically and operationally feasible under paragraph 7.
The mechanism for applying the overall success of the mill's efforts to reduce color is
demonstrated by the actual color Performance. This performance will be the basis for limitations
established following implementation of the Reasonable Certainty'category actions and the
process of developing the mill's limitations for the next permit renewal. Again, it is the goal of
this special condition to achieve the color reductions identified by the EPA TRW and lay the
foundation for removal of the color variance by the expiration date of this permit.
2. The average annual discharge of true color for each calendar month shall not exceed 48,000
pounds per day. The monthly average effluent true color loading shall not exceed 55,000 pounds
per day. For the purpose of this permit/variance only, "pounds of true color" is calculated by the
following equation:

Permit Number: NCO000272
Effluent Flow(frtgd) x Effluent True Color Level-(Platinum Cobalt Units)x 8.34.
3. All samples collected for color analysis and for use in the above calculation shall be measured
and reported using the procedure referenced in 39 FR 430.11 (b) (May 29, 1974) -true and
apparent color or as amended by the EPA.
4. Blue Ridge Paper, in accordance with activities underway at the mill and in response to the work
of the EPA Technology Review Workgroup(EPA TRW),has already begun the process of
identifying and implementing technically, economically and operationally feasible process
optimization measures, which can be taken to further reduce color discharges from the mill. The
permittee is directed to continue evaluating mill operations with the goal of fully identifying
opportunities for preventing and controlling measurable black liquor leaks and spills (Best
Management Practices-BMPs). Such BMPs include but are not limited to:
➢ Continuous improvement of operating practices so more leaks and spills are recovered rather
than discharged to sewer;
➢ Improvement in preparation for planned outages to maximize capture of tank clean-out waste
and routing to recovery;
➢ Reduction of clean water that continuously runs into sewers to prevent dilution of smaller
spills and facilitate recovery of highly colored wastewaters; and
➢ Improvement in the equipment used for handling of knot rejects to prevent black liquor leaks
into the recovery sumps.
5. As indicated in Paragraph 4,the permittee has already begun the process of implementing the
specific actions and technologies identified by the EPA Tech Team as having the'Highest
Certainty'. The permittee is directed to implement all the specific actions and technologies the
EPA Tech Team Report identified as having the 'Highest Certainty'. The specific action items
identified as having the 'Highest Certainty' include: Process Optimization,Improved black liquor
leak&spill collection and control,and BFR reliability improvement. These 'Highest Certainty'
action items and technologies shall be implemented in sufficient time to generate a sufficient
database of representative mill effluent data for statistical analysis by October 1,2003.
By October 1, 2003, the permittee shall submit to the North Carolina Division of Water Quality a
report including a statistical analysis of the permittee's monthly average color discharge, mill
performance as related to color, all available data necessary to derive the lowest achievable
annual average and monthly average color loading limits. By November 1,2003, the Division of
Water Quality (in consultation with the Technology Review Workgroup) shall recommend,
considering the statistical analysis report submitted by the permittee and the demonstrated
performance of the mill, the lowest achievable annual average and monthly average color loading
effluent limitations. If the limits determined to be achievable are within or below the target range
of 40,000-42,000 pounds per day as an annual average, the limits shall become effective on
December 1, 2003,by written notification from the Director. If the limits determined to be
achievable by the Division of Water Quality(in consultation with the Technology Review
Workgroup) are above the target range, the Permit shall be modified in accordance with North
Carolina's permitting process to reflect those limits.

Permit Number: NCO000272
6. Implementation of the'Highest Certainty'action items or technologies shall reduce the annual
average color discharge limit 6,000-8,000 lbs/day,based on the statistical analysis conducted
according to Paragraph 5. Beginning December 1, 2003, upon written notification from the
Division of Water Quality the annual average discharge of true color shall not exceed 40,000-
42,000 pounds per day.
However, if by November 1,2003, the Division of Water Quality(DWQ), in consultation with
the Technology Review Workgroup',and the NPDES Committee agree that there are
overwhelming technical, economic, or operational barriers to the Permittee's ability to attain a
40,000-42,000 lbs/day annual color loading limit,DWQ shall recommend to the NPDES
Committee, alternate interim limits to become effective December 1,2003. At that time, DWQ
shall recommend a new effective date for achieving an annual average color loading limit of
40,000-42,000 pounds per day. These recommendations shall be based on what DWQ
concludes Blue Ridge Paper can reasonably achieve, giving consideration to the actual
demonstrated color levels discharged and the 'Highest Certainty'action items and technologies
implemented pursuant to Paragraphs 4 and 5. Based on DWQ's recommendations, the NPDES
Committee will determine an alternate interim limit to become effective on December 1, 2003,
and the new effective date for achieving an annual average color loading limit of 40,000-42,000
pounds per day. After the NPDES Committee's final decision, the NPDES Permit will be
modified in accordance with North Carolina's permitting process.
7. The permittee shall submit to the Division of Water Quality, the Technology Review Workgroup
and the NPDES Committee by December 1, 2003, a report on the feasibility of achieving a target
annual average color reduction within the range of 3,000 and 8,000 pounds per day from the
reduction achieved by implementation of the 'Highest Certainty'actions. This report shall include
an evaluation of the use of the Reasonable Certainty'actions identified in the EPA Tech Team
Report and any other actions that would result in additional color reductions, actions taken by the
permittee to reduce color loading(since permit issuance), and the technical,economic, and
operational feasibility of implementing the Reasonable Certainty'actions on a continuous or
intermittent basis, in order to achieve a target annual average color reduction within the range of
3,000 and 8,000 pounds per day. As identified in the EPA Tech Team Report, the'Reasonable
Certainty'actions are the technologies of Ozone/Chlorine Dioxide stage for the hardwood bleach
line and second stage oxygen delignification for the pine line.The report shall identify specific
economic and implementation issues associated with the proposed improvements.The report
shall also project expected additional color reduction for each technology evaluated and
maximum color reduction possible using the identified technologies.The report shall also include
a proposed schedule for implementation of process improvements or installation of technologies
required to achieve an additional an effluent color reduction of 3,000- 8,000 pounds per day.The
permittee shall provide this evaluation/report,together with an updated report on the results of
ongoing and additional planned color reduction activities, to the Division of Water Quality, the
Technology Review Workgroup and the NPDES Committee. By February 1, 2004,DWQ(in
consultation with the Technology Review Workgroup) shall approve or modify the permittee's
recommended plan for achieving an additional 3,000-8,000 pounds per day reduction to the
target annual average.
The Technology Review Workgroup shall act in an advisory role to the North Carolina Division of Water
Quality,and NC DWQ Shall consult with the Technology Review Workgroup prior to making any decisions
regarding color reduction activities at the Canton Mill.

Permit Number: NC0000272
8. By December 1, 2005, the permittee shall submit, as related to the implementation of the process
improvements evaluated according to Paragraph 7, a statistical analysis of Blue Ridge Paper's
effluent quality performance.This report shall include a statistical analysis of the Blue Ridge
Paper's monthly average and annual average color discharge, mill performance as related to color,
and all available data necessary to derive the lowest achievable annual average and monthly
average color loading limits.
By February 1, 2006,the Division of Water Quality(in consultation with the Technology Review
Workgroup) shall recommend to the NPDES Committee, considering the statistical analysis
report submitted by the permittee and the demonstrated performance of the mill, the lowest
achievable annual average and monthly average color loading effluent limitations. If the limits
determined to be achievable are within or below the target range of 32,000-39,000 pounds per
day as an annual average, the limits shall become effective on March 1, 2006,by written
notification from the Director. If the limits determined to be achievable by the Division of Water
Quality (in consultation with the Technology Review Workgroup) are above the target range,the
Permit shall be modified in accordance with North Carolina's permitting process to reflect those
limits.
9. By December 1, 2004, the permittee shall evaluate color reduction technologies associated with
the Chloride Removal Process (CRP)wastestream. The CRP analysis shall concentrate on the
technical, economic, and operational feasibility of implementing the applicable technologies on
all or a portion of the purge stream. The report shall identify specific economic and
implementation issues associated with the improvements.The report shall also project expected
additional color reduction for each technology evaluated and maximum color reduction possible
using the identified technologies.Though not limited to the following, the report shall include an
analysis of the land application of the high chloride wastewater,commercial incineration,
coagulant/precipitation technologies,and solidification for land disposal. The Division of Water
Quality(in consultation with the Technology Review Workgroup) shall evaluate the feasibility of
implementing identified technologies for further color reduction and shall submit to the NPDES
Committee by February 1,2005, DWQ's recommendations regarding color reductions associated
with the treatment of the CRP wastestream.
If during the course of this evaluation Blue Ridge Paper identifies a technical,economic, and
operationally feasible color reduction technology that can be implemented for treatment of the
CRP wastestream, the permittee may request that the Technology Review Workgroup review this
technology for implementation at the Canton mill. If the Technology Review Workgroup concurs
that the identified technology is suitable for the Canton mill and that the color reductions
achievable are adequate, the mill's obligation to research additional technologies will be waived
after formal notification from Blue Ridge Paper that the identified technology will be installed
and placed into operation.This notification shall include language indicating the permittee's
commitment to the implementation of the technology, along with a schedule for implementation.
The Division of Water Quality will notify the permittee in writing that the proposed
implementation schedule is acceptable.
10. By March 1, 2006, the permittee shall submit a report to Division of Water Quality, the
Technology Review Workgroup and the NPDES Committee on the color reduction efforts as part
of the Variance review process(Triennial Review of North Carolina's Water Quality Standards).
This report shall also include an evaluation of color in the Pigeon River at the Fiberville Bridge,
and an evaluation on the feasibility of complying with North Carolina's Color Standard.

Permit Number: NC0000272
11. The 1997 Settlement Agreement contained provisions to limit color in the Pigeon River at the
Hepco USGS gauge station. The new effluent limits in this permit are more stringent than the
provisions in the 1997 Permit and Color Variance and will result in reduced color levels in the
Pigeon River. It is possible to calculate the monthly flow at the Canton gage station above which
instream color at the Fiberville Bridge will not exceed 50 true color units. Using the 55,000
pounds per day monthly average true color loading limit(implemented on the effective date of
the permit) the flow at the Canton Gage station, which will provide for color less than 50 true
color units at the Fiberville Bridge is 171.8 MGD. Therefore,the monthly average color in the
Pigeon River at the Fiberville Bridge will be less than 50 true color units whenever the monthly
average flow (at the Canton gage station) is greater than 171.8 MGD.
12. The governing flow criterion for true color at Canton is 58.1 MGD (30Q2 stream flow). The flow
established, pursuant to Paragraph 11, is greater than this 30Q2 stream flow, therefore, for flows
less than the 171.8 MGD at the Canton Gage station but greater than 193.3 MGD (30Q2 flow) at
the Hepco gage station, the monthly average color in the Pigeon River.at Hepco will be less than
50 true color units.
13. Beginning December 1,2003, the monthly average color in the Pigeon River at the Fiberville
Bridge will be less than 50 true color units whenever the flow at Canton is greater than the flow
established using the following equation and based on the monthly average effluent limit
established per Paragraph 5:
Flow—at—Canton—USG.S(MGD)—!Monthly Averaee Effluent Color Limit Ib/day-12468 31+31.6+2.4
308.58
For flows at the Canton Gage station less than the flow established here but greater than 193.3
MGD at the Hepco gage station,the monthly average color in the Pigeon River at Hepco will be
less than 50 true color units.
14. Beginning March 1,2006,the monthly average color in the Pigeon River at the Fiberville Bridge
will be less than 50 true color units whenever the flow at Canton is greater than the flow
established using the following equation and based on the monthly average effluent limit
established per Paragraph 8:
Flow_at—Canton—USGS(MGD)—(Monthly Averaee Effluent Color Lim'Llb/day-12468 3)+31.6+2.4
308.58
For flows at the Canton Gage station less than the flow established here but greater than 193.3
MGD at the Hepco gage station,the monthly average color in the Pigeon River at Hepco will be
less than 50 true color units.
15. The potential exists that there could still be periods of time corresponding to periods of lower
flow in the river, when color at Fiberville might exceed 50 true color units. Therefore, the
permittee shall continue to implement the approved Low Flow Contingency Plan for mitigating
the occurrence and degree of this potential exceedence.
16. The permittee shall not increase the mill's pulp production capacity during the term of this permit,
unless the permittee can demonstrate that the increased production can be achieved while
reducing color loading. In addition, increasing the mill's pulp production capacity may require
permit revision in accordance with North Carolina's NPDES Permitting rules.

Permit Number: NC0000272
17. The NPDES Permit shall be subject to reopening in order to modify the color requirements based
upon the following and in association with the required triennial reviews:
➢ Any breakthrough in color removal technologies. Such breakthroughs shall be brought to the
NPDES Committee for consideration,by Blue Ridge Paper and the Division of Water
Quality, as soon as they are discovered.
➢ An acceptable statistical analysis of effluent color discharge data demonstrating significantly
better color removal performance than that currently prescribed in the variance and permit,
except as noted herein.
➢ Successful application of end-of-pipe color reduction technology or in-mill color
minimization effort that results in significant and measurable reduced mass color discharge.
18. The transfer of this NPDES permit will not proceed until any successor-in-interest to the current
permittee has agreed to accept the provisions of this permit and request and received from the
NPDES Committee a transfer of 2001 Revised Color Variance.

Permit Number: NC0000272
A. (9.) DIOXIN MONITORING SPECIAL CONDITION
The permittee shall perform the analyses for dioxin and dibenzofuran as outlined below:
En
g Point Monitoring
Re uirements
Measurement Sample Type
Frequent
ewater Quarterly Composite
Quarterly Composite
Annual Composite
te Annual Composite
1. The samples shall be analyzed for 2,3,7,8-TCDD and 2,3,7,8 TCDF in accordance with EPA Method
1613. A single sample may be analyzed. Alternatively, the sample volumes may be collected to
enable the sample to be split(duplicate analysis).The Minimum Level in the effluent for 2,3,7,8-
TCDD and 2,3,7,8 TCDF by EPA Method 1613 is 10 pgil.
2. The samples shall be analyzed for the full range of dioxin and furan isomers as identified in the list
below and shall be in accordance with EPA Method 1613. A single sample may be analyzed.
Alternatively, the sample volumes may be collected to enable the sample to be split(duplicate
analysis).The minimum level using these methods for the purpose of compliance evaluation is
considered to be 10 picograms per liter
DIOXIN DIBENZOFURAN
Isomer Isomer
2,3,7,8 TCDD 2,3,7,8 TCDF
1,2,3,7,8 PeCDD 1,2,3,7,8 PeCDF
2,3,4,7,8 PeCDF
1,2,3,4,7,8 HxCDD 1,2,3,4,7,8 HxCDF
1,2,3,7,8,9 HxCDD 1,2,3,7,8,9 HxCDF
1,2,3,6,7,8 HpCDF
1,2,3,6,7,8 HxCDD 2,3,4,6,7,8 HxCDF
1,2,3,4,6,7,8 HpCDD 1,2,3,4,6,7,8 HpCDF
1,2,3,4,7,8,9 HpCDF
If dioxins or dibenzofurans are detected in the effluent above the minimum level, the permittee
shall initiate more frequent monitoring of sludge and landfill leachate. The dioxin and
dibenzofuran monitoring as stipulated in this condition shall continue until such time that the fish
consumption advisory is completely lifted in North Carolina, or if after sufficient data has been
generated, statistical analysis indicates that the bleach plant effluent does not contain reasonable
potential to exceed the permitted limits.
Additional Requirements
Fish tissue analysis shall be performed in accordance with the Division of Water Quality approved
monitoring plan, which will be reviewed as necessary. The monitoring plan is an enforceable part of this
permit. All dioxin data collected as part of this monitoring requirement will be reported as required in the
plan, no later than'180 days after sampling.

Permit Number: NC0000272
A. (10.) DISSOLVED OXYGEN SPECIAL CONDITION
The permittee shall maintain an average daily dissolved oxygen concentration of not less than 5.0 mg/1
with a minimum instantaneous value of not less than 4.0 mg/1 at River Miles 62.9 (DNI) and 57.7(DN2).
The permittee shall operate oxygen injection facilities at the outfall structure, at 0.9 miles downstream of
the discharge, and at 2.1 miles downstream of the discharge, as necessary, to comply with this
requirement. These facilities shall be operated in a manner which will maintain the water quality standard
for dissolved oxygen in the Pigeon River downstream of the discharge. Blue Ridge Paper shall report the
date and duration of oxygen injection use as a supplement to the monthly Discharge Monitoring Report
(DMR)forms. If the dissolved oxygen drops below 5.0 mg/L at station DN2 then monitoring shall be
required at stations DN3 and DN4.
A. (11.) TOWN OF CANTON INFLOW AND INFILTRATION SPECIAL CONDITION
The permittee shall make continued efforts to promote reduction of inflow/infiltration to the Town of
Canton's wastewater collection system.
A. (12.) WATERVILLE RESERVOIR SAMPLING SPECIAL CONDITION
Sampling for Waterville Reservoir shall be conducted once annually during 2002 and 2004. Sampling
shall be performed during a low flow period to correspond with the fish tissue study (see A. (9.)Dioxin
Monitoring Special Condition).
Sampling shall be performed at Waterville Reservoir prior to Laurel Branch,Waterville Reservoir near
Wilkins Creek and Waterville Reservoir near the dam. Each location shall be sampled for the following
parameters:
PARAMETERS'
Temperature
Dissolved Oxygen
Conductivity
pH
Total Nitrogen
Nitrite+Nitrate
Ammonia
TKN
PO4
Total Phosphorus
Chloro hyll-a
Secchi Depth
All samples shall be collected at 0.1 meters beneath the surface of the water in the lake.
A. (13.) TEMPERATURE VARIANCE REVIEW SPECIAL CONDITION
During the next permit renewal,Blue Ridge Paper shall complete an analysis of temperature and shall
submit a balanced and indigenous species study, no later than May 1, 2006. As part of this analysis,Blue
Ridge Paper shall submit a complete temperature variance report documenting the need for a continued
temperature variance.
The study shall be performed in accordance with the Division of Water Quality approved plan. Request
for revisions to this plan shall be submitted for approval no later than March 1, 2005. The temperature
analysis and the balanced and indigenous study plan shall conform to the specifications outlined in 40
CFR 125 Subpart H and the EPA's Draft 316a Guidance Manual, dated 1977.

State of North Carolina
ROY COOPER Department of Justice REPLY TO:Francis W.Crawley
ATTORNEY GENERAL Envimnmental Division
P. O. BOX 629
R . Box 6 [e-mail]
Telephone:919n l 6.6600
27602-0629 Fax:919nl6-6767
October 15, 2001
Robert Williams,Director Certified Mail
Environment Health & Safety Affairs Return Receipt Requested
Blue Ridge Paper Products, Inc.
P. O.Box 4000
Canton, North Carolina 28716
RE: NPDES Committee Decision on the Color Variance for the Canton Mill
J Dear Mr. Williams:
1 The NPDES Committee of the Environmental Management Commission at its October
10,2001 meeting received the hearing officer's report of the public hearing and, upon duly made
motion and vote, approved the color variance with its conditions for the Blue Ridge Paper
Products mill in Canton. The variance will be effective as of the effective date of the renewed
NPDES Permit No. NC 0000272 for the Canton Mill and the terms of the previously existing
variance will continue in effect until that time. A copy of the Color Variance is enclosed.
Very truly yours,
ancis W. Crawley
Special Deputy Attorney General
Commission Counsel
cc: William Clarke
Gregory Thorpe
Paul Davis
Davis McKinney
Davis Jenkins
Charles Moore
Roland Dykes
a)

r ENVIRONMENTAL MANAGEMENT COMMISSION
l NPDES Committee
IN THE MATTER OF REQUEST FOR )
VARIANCE FROM WATER QUALITY )
STANDARD-BASED EFFLUENT ) COLOR VARIANCE
LIMITATIONS BY BLUE RIDGE )
PAPER PRODUCTS, INC. )
CANTON, NORTH CAROLINA )
THIS MATTER came on to be heard before the NPDES (National Pollutant Discharge
Elimination System) Committee of the North Carolina Environmental Management Commission
at its scheduled meeting in Raleigh, North Carolina, on October 10, 2001, for consideration of re-
issuing a color variance, originally granted to Champion International Corporation on July 13,
1988, and modified on October 9, 1996, on December 11, 1996, and on December 11, 1997, to
Blue Ridge Paper Products, Inc. ("Blue Ridge Paper") the successor corporation.
Upon duly made motion and vote, the NPDES Committee hereby adopts the following
Findings of Fact and Conclusions of Law:
FINDINGS OF FACT
(taken from the October 9, 1996, Order)
1. Pursuant to a request for variance, dated January 12, 1988, submitted by
Champion International Corporation ("Champion"), the NPDES (National Pollutant Discharge
Elimination System) Committee of the North Carolina Environmental Management Commission
granted Champion a variance from the North Carolina water quality standard for color, as that
standard is interpreted by the U.S. Environmental Protection Agency. The .variance was
r memorialized in the NPDES Committee's Final Decision, dated July 13, 1988:
l

2
2. Pursuant to Ordering Paragraph 6 of its Final Decision, the NPDES Committee
established a Variance Review Committee to review the Canton Mill's proposed modernization
program and to recommend any changes to the existing variance. As stated in Ordering
Paragraph 6 of its Final Decision, the NPDES Committee was charged with determining "if
changes in the variance are warranted due to the effectiveness of the treatment system or because
of advances in color reduction technologies for this type wastewater."
3. Modification of the variance as recommended by the Variance Review Committee
would,not result in any discharge of waste that would endanger human health or safety. The
variance for color was to allow discharge of wastewater at levels that would prevent Champion's
contribution to the true color from causing the true color at the North Carolina/Tennessee State
( line to exceed 50 true color units at all flows equal to or greater than 126 cfs at the Hepco
` Gauging Station. The substance being discharged, for which.the variance was sought, is not
bioaccumulative. The color does not, at the volumes and levels involved here, present a risk of
indirect or direct human impact or broad environmental -damage. The waters are not water
supply. Therefore, the discharge would not endanger human health or safety.
4. Reduction of color discharge by application of best available technology was
found to be not economically reasonable and to result in serious hardship without equal or greater
benefit to the public. A detailed and thorough study and evaluation of color removal
technologies was performed and reported in Champion's 1995 and 1996 Color Removal
Technology Reports submitted to Division as required by the then-existing color variance.
5. Champion completed its mill modernization project which re-configured its
facility as an oxygen delignification, 100% chlorine dioxide substitution (OD-100) bleach mill.

3
The project resulted in limited color reduction in its effluent discharge. The end-of-pipe
technologies considered in 1988 and updated for the 1996 review established: a) standard
water/wastewater separation technology (lime, alum, or polymer) had not been applied in a
similar fashion, b) these technologies would result in high capital and operating costs at the mill,
c) color reduction on this type of waste, using these type technologies had no operational
efficiency "track record" (effective under normal paper mill production variations, and consistent
and reproducible color removal), and d) the process color removal effectiveness of OD-100 may
present other in-process reduction opportunities that were not realized as of October 9, 1996.
6. In review of the color data, including the short time since the re-configured mill
became fully operational, it was determined that a more restrictive limitation should apply for
color. Therefore, the more restrictive monthly and annual average color limitations contained in
the Ordering Paragraph 2, of the October 9, 1996, Order, were established.
7. Based on the continued development of color discharge information from the
reconfigured mill, Champion was required to statistically evaluate its monthly average color
discharge, its.annual average color discharge, and the performance of the State line color model.
These evaluation processes were to be ongoing and the results of the evaluations were required to
be reported to the Division of Water Quality ("Division" or "DWQ") prior to each water quality
standards triennial review period. The results of these evaluation processes were to be utilized
by the Division and the next Variance Review Committee to make recommendations to the
NPDES Committee on future revisions to the variance. Champion was:to follow the Color Data
Variance Review Requirements proposed by the staff and the hearing officer, in reporting these
evaluations.

4
8. Champion was also required to take such actions as necessary to prevent their
contribution of true color from exceeding 50 true color units at the North Carolina/Tennessee
State line at all flows equal to or greater than 126 cfs at the Hepco Gauging Station.
Furthermore, the method by which compliance was to be determined continued to be the color
predictive model.
(taken from the December 11, 1996, Order)
9. On October 17, 1996, the Director of the Division of Water Quality transmitted to
the United States Environmental Protection Agency, for its review, the October 9, 1996, order for
Modification of Color Variance Granted on July 18, 1988.
10. By letter dated December 23, 1996, Tennessee advised EPA that it considered the
permit to be invalidly issued, and that North Carolina had failed to comply with §402(b)(5) of the
Clean Water Act, 33 U.S.C. §1342(b)(5). Subsequently, on January 13, 1997, Tennessee filed a
contested case petition with the North Carolina Office of Administrative Hearings challenging
the permit and color variance. Thereafter, Champion, Cocke County, and Newport were allowed
to intervene in the North Carolina contested case proceeding.
11. In an effort to resolve the color issue without time- and resource-consuming
litigation, North Carolina, Tennessee, Cocke County, Newport,Champion, and EPA agreed to an
informal negotiation process. The North Carolina contested case proceeding was stayed during
this process. On November 21, 1997, Tennessee Environmental Council and American Canoe
Association were also allowed to intervene in the North Carolina contested case proceeding.
12. The parties to the contested case agreed to measures to achieve additional color
reduction over that required in the permit issued on December 12, 1996 and by the color variance

5
i
adopted on December 11, 1996. The parties agreed that the December 1996 Permit and Variance
would be modified to reflect these requirements and effectuated a Settlement Agreement which
would be entered in the contested case.
13. The December 1996 permit and variance required that Champion implement a one
year demonstration of full-scale bleach filtrate recycling (BFRT") technology on the mill's pine
line and that, as of December 1, 1998, Champion implement and operate BFRT"' technology on
its pine line, unless Champion could demonstrate to the NPDES Committee that BFRT' was not
commercially viable.
14. The 1996 permit and variance required Champion to evaluate the potential for
additional minimization of color losses from the manufacturing process and raw material storage .
areas (i.e. in-mill color minimization; or, spill prevention/control measures) that might result in
Further color reduction and to report its findings to the NPDES Committee. Reports were to be
submitted by March 1, 1998 and again by June 1, 2001, so that they could be used by the
Committee in conjunction with the required Variance review process held every three years to
determine if the variance would be readopted or made more stringent. As a part of the efforts to
resolve the challenge to the 1996 permit and variance, a Technology Review Workgroup (TRW )
was formed, comprised of experts on the pulp and paper industry from EPA and representatives
of the environmental agencies for the State of Tennessee and North Carolina.
15. The 1996 permit and variance required Champion to evaluate and report to the
NPDES Committee on end-of-pipe color reduction technologies that could conceivably be
implemented at the mill. The evaluation was to include an incremental color improvement
analysis which concentrated on the technical, economic, and operational feasibility of the

6
application of these technologies on a continuous or intermittent basis. The intermittent
application of these technologies was to look particularly at periods of low river flow. These
reports were to be submitted to the NPDES Committee for its consideration as part of the water
quality standards Triennial Reviews to determine whether the variance should be readopted or .
made more stringent. The reports were to identify specific economic and implementation issues
associated with the incremental improvements of color levels expected by installing these
technologies at the mill. They were also to project the expected additional color reduction
possible using the identified technology.
(Events and Activities since Champion conveyed the Canton Mill)
16. On May 14, 1999 the ownership and operation of the Canton Mill along with
several related production facilities was transferred from Champion to Blue. Ridge Paper
Products Inc. ("Blue Ridge Paper"). Subsequent to that change, Blue Ridge Paper in a letter
dated May 7, 1999, requested that DWQ reissue the Canton Mill permit to the new owners. On
July 14, 1999 the DWQ issued to Blue Ridge Paper the NPDES permit for the Canton Mill. In
taking this action, the DWQ reminded Blue Ridge Paper of the new owner's responsibility to
comply with all the requirements of the Settlement Agreement and the 1997 Revised Color
Variance.
17. In accordance with the requirements of the Settlement Agreement, the 1997
Revised Color Variance, and the revised 1996 NPDES Permit for the Canton Mill, Blue Ridge
Paper assumed the responsibility for submission of all reports and evaluations required by these
documents and due after May 14, 1999. Blue Ridge Paper has submitted all required reports and
has complied with the conditions of the Agreement, Variance and Permit. In a letter dated

February 21, 2001,.Blue Ridge Paper submitted to the DWQ its request for renewal of the
facility's NPDES Permit which is scheduled to expire on November 30, 2001, permit number:
NC0000272. The Division, along with the EPA and the TRW has worked to evaluate the Canton
facility and the information submitted by the permittee in support of its request for renewal of the
permit. It was anticipated by the Division that the variance and the permit would be considered
for re-issuance in the same time frame.
18. The TRW has been provided copies of all correspondence and report materials,
has visited the facility, consulted with EPA's Technology Team ("Tech Team," the group of staff
and consultants assigned by the federal agency to support this review effort), met on site, and
discussed the issues by telephone on several occasions in an effort to provide recommendations
to the parties to the Settlement Agreement and to the NPDES Committee on what revised color
conditions should be placed in the variance and renewal permit for the Canton Mill. Those
efforts culminated in two important documents: the EPA Tech Team Report dated July 25, 2001
and the TRW recommendation report dated August 3, 2001. A critical component of these
evaluations was the report funded jointly by Blue Ridge Paper and a consortium of
environmental groups interested in the mill and its impact on the Pigeon River (Bleach
Environmental Process Evaluation and Report prepared by Dr.Norm Liebergott, PhD, Liebergott
& Associates Consulting Inc. and Mr. Lewis Shackford, GL&V Pulp Group, Inc.). The TRW
and the Tech Team utilized this report in developing their final recommendations.
19. In support of the need for the color variance, Blue Ridge Paper submitted to the
Division a report dated June 1, 2001 and entitled: Analysis of the Impact of Additional Water
Treatment Technology on the Profitability of the Blue Ridge Paper Products, Inc. Canton Mill.

8
This evaluation provides the basis for examining the economic impacts that would occur if the
Mill were to be required to provide color reductions beyond those outlined in this Color
Variance.
20. Based on this foundation of information, the Division developed a draft color
requirement for the Canton Mill and submitted that condition along with the draft NPDES permit
and variance to public notice on August 3, 2001. On September 6, 2001, Ms. Marion Deerhake,
EMC and NPDES Committee of the EMC, convened and conducted a public hearing on the draft
permit and an effluent color variance for the Canton Mill. Ms. Deerhake's Hearing Officer
Report and the recommendations made concerning the Color Variance are the basis of the
variance language appearing below, and are further incorporated by reference herein.
21. The Color Variance conditions established as the result of the work of the TRW
will continue the improvements to color in the Pigeon River, leading to reduced pounds per day
of color over the life of the Permit, which is to be issued contemporaneously with this Color
Variance; the discharges allowed do not endanger human health or safety, and actually result in
improved water quality from the previous permitted period of operation; and a continued
variance from the North Carolina narrative water quality standard for color, as interpreted
numerically by the United States Environmental Protection Agency, is necessary due to the fact
further reductions cannot be made at this time in an economically reasonable manner and, if
required, would produce serious hardship without equal or greater benefits to the public.
22. The NPDES Permit No. NC0000272 for the Canton Mill and this Color Variance
are, to the extent feasible, to be issued contemporaneously and the terms of this Color Variance
included as Special Conditions in the permit.

9
CONCLUSIONS OF LAW
(from the October 9, 1996, Order)
1. Pursuant to Ordering Paragraph 6 of the July 18, 1988, Final Decision, the
NPDES Committee reviewed the then-existing variance following the Champion Canton Mill
modernization program.
2. The previously existing variance from the North Carolina water quality standard
for color, memorialized in the NPDES Committee's Final Decision, dated July 18, 1988, was
determined to remain in effect except as specifically modified by the October 9, 1996, order.
3. Based on the effectiveness of the treatment system subsequent to the Canton Mill
modernization project and due to the potential for improvements in color reductions by use of
bleach filtrate recycling (BFIZ7 '), changes to the variance were determined to be warranted.
(from the December 11, 1996, Order)
4. On its own motion and prior to the effective date of the October 9, 1996, order for
Modification of Color Variance Granted on July 18, 1988. the NPDES Committee amended its
October 9, 1996, order, to satisfy concerns of the United States Environmental Protection
Agency, to clarify its conditions and to make the conditions more restrictive on Champion
International Corporation.
(from the December 11, 1997, Revision to Color Variance)
5. By duly adopted motion and vote, the NPDES Committee Ordered that the Color
Variance to Champion International Corporation be granted as a Revised Color Variance, with an
effective date of December 11, 1997.

( 10
(Issuance to Blue Ridge Paper)
6. The NPDES Committee has reviewed and considered the Color Variance for
application to Blue Ridge Paper Products, Inc.; and finds that the color variance should be
granted and re-issued during the term of the corresponding NPDES permit.
7. This Color Variance is granted and re-issued pursuant to N.C.G.S. 143-215.3(e);
further reductions in color cannot be made at this time in an economically reasonable manner,
and, if required, would produce serious hardship without equal or greater benefits to the public.
Based on the foregoing Findings of Fact and Conclusions of Law, it is hereby ORDERED
that the variance from the North Carolina water quality standard for color, as previously
memorialized in the orders of July 18, 1998, October 9, 1996, December 11, 1996, and
December 11, 1997 granted to Champion International Corporation, is re-issued to Blue Ridge
Paper Products, Inc. and now reads as follows:
A. Blue Ridge Paper Products, Inc. is granted this Color Variance, pursuant to
N.C.G.S. 143-215.3(e), as a variance to water quality based effluent limitations for color.
B. The Division of Water Quality shall issue NPDES Permit No. NC0000272, for the
Canton Mill, and draft its provisions to reflect all the conditions of this Color Variance including
the following specific wording:
1. The color reduction requirements contained in this. special condition have been
derived directly from the mill's efforts to identify possible reduction measures and
from the EPA Technology Review Workgroup (TRW) (report dated August 3,
2001), and the EPA Tech Team Report (dated July 25, 2001). These requirements
are aimed at securing the highest feasible reduction of the,mill's effluent color
over the permit cycle and for laying the foundation for removal of the color
variance by the expiration date of this permit.

r 11
The EPA Tech Team Report identified three levels of possible color
reduction actions (identified in the report as .Highest Certainty, Reasonable
Certainty and Lowest Certainty). Each of these tiers of reductions have identified
specific actions or technologies that when implemented may result in additional
color reductions in the mill's effluent. For example, the color reduction goals of
the condition in Paragraph 6 of this special condition is premised on the
implementation of all the actions of'Highest Certainty.'
Paragraph 7 of this special condition requires the company to evaluate
actions of'Reasonable Certainty'. Identified under 'Reasonable Certainty' are the
technologies of Ozone/Chlorine Dioxide stage for the hardwood bleach line and
second stage oxygen delignification for the pine line. This condition requires the
permittee to examine the technical, economic and operational feasibility of
implementing these technologies. The review of this required evaluation
(Paragraph 7) will be supported by the EPA TRW. Regardless of the outcome of
this feasibility analysis, the permittee is required to achieve 3,000 - 8,000 pounds
per day additional color reduction, except to the extent allowed by Paragraph 6.
This is considered the equivalent reduction of what would be expected from the _
installation of the two technologies identified by the EPA TRW process.
Color Treatment of the Chloride Removal Process Purge Stream is the
color reduction methodology with the 'Lowest Certainty'. Therefore, this
condition requires the permittee to evaluate potential technologies for treatment of
this wastestream and to implement those if shown technologically, economically
and operationally feasible.
Built into this special condition is a series of regulatory requirements that
the permittee achieve reductions of the mill's effluent color consistent with each
series of reduction actions. This means that following implementation of the
'Highest Certainty' actions the mill's annual color limit must be reduced by 6,000-
8,000 pounds per day, except to the extent allowed by Paragraph 6. If the
implementation of all the actions identified under 'Highest Certainty' actually
result in better long term effluent quality, this in no way reduces the permittee's
responsibility to achieve the color reductions measured by those action identified
as having 'Reasonable Certainty' of success and determined to be technically,
economically and operationally feasible under paragraph 7.
The mechanism for applying the overall success of the mill's efforts to
reduce color is demonstrated by the actual color performance. This performance
will be the basis for limitations established following implementation of the
'Reasonable Certainty' category actions and the process of developing the mill's
limitations for the next permit renewal. Again, it is the goal of this special

/ 12
` condition to achieve the color reductions identified by the EPA TRW and lay the
foundation for removal of the color variance by the expiration date of this permit.
2. The average annual discharge of true color for each calendar month shall not
exceed 48,000 pounds per day. The monthly average effluent true color loading
shall not exceed 55,000 pounds per day. For the purpose of this permit/variance
only, "pounds of true color" is calculated by the following equation:
Effluent Flow (mgd) x Effluent True Color Level(Platinum Cobalt Units)x 8.34.
3. All samples collected for color analysis and for use in the above calculation shall
be measured and reported using the procedure referenced in 39 FR 430.11 (b)
(May 29, 1974) - true and apparent color or as amended by the EPA.
4. Blue Ridge Paper, in accordance with activities underway at the mill and in
response to the work of the EPA Technology Review Workgroup (EPA TRW),
has already begun the process of identifying and implementing technically,
economically and operationally feasible process optimization measures, which can _
be taken to further reduce color discharges from the mill. The permittee is
directed to continue evaluating mill operations with the goal of fully identifying
opportunities for preventing and controlling measurable black liquor leaks and
spills (Best Management Practices - BMPs). Such BMPs include but are not
limited to:
Continuous improvement of operating practices so more leaks and spills
are recovered rather than discharged to sewer;
Improvement in preparation for planned outages to maximize capture of
tank clean-out waste and routing to recovery;
Reduction of clean water that continuously runs into sewers to prevent
dilution of smaller spills and facilitate recovery of highly colored
wastewaters; and
Improvement in the equipment used for handling of knot rejects to prevent
black liquor leaks into the recovery sumps.
5. As indicated in Paragraph 4, the permittee has already begun the process of
implementing the specific actions and technologies identified by the EPA Tech
Team as having the 'Highest Certainty'. The permittee is directed to implement all
the specific actions and technologies the EPA Tech Team Report identified as
having the 'Highest Certainty'. The specific action items identified as having the
'Highest Certainty' include: Process Optimization, Improved black liquor leak &

{ 13
spill collection and control, and BFR reliability improvement. These 'Highest
Certainty' action items and technologies shall be implemented in sufficient time to
generate a sufficient database of representative mill effluent data for statistical
analysis by October 1, 2003.
By October 1, 2003, the permittee shall submit to the North Carolina
Division of Water Quality a report including a statistical analysis of the
permittee's monthly average color discharge, mill performance as related to color,
all available data necessary to derive the lowest achievable annual average and
monthly average color loading limits. By November 1, 2003, the Division of
Water Quality (in consultation with the Technology Review Workgroup) shall
recommend, considering the statistical analysis report submitted by the permittee
and the demonstrated performance of the mill, the lowest achievable annual
average and monthly average color loading effluent limitations. If the limits
determined to be achievable are within or below the target range of 40,000 -
42,000 pounds per day as an annual average, the limits shall become effective on
December 1, 2003, by written notification from the Director. If the limits
determined to be achievable by the Division of Water Quality (in consultation
with the Technology Review Workgroup) are above the target range, the Permit
shall be modified in accordance with North Carolina's permitting process to
reflect those limits.
6. Implementation of the 'Highest Certainty' action items or technologies shall
reduce the annual average color discharge limit 6,000 - 8,000 lbs/day, based on
the statistical analysis conducted according to Paragraph 5. Beginning December
1, 2003, upon notification from the Division of Water Quality the annual average
discharge of true color shall not exceed 40,000 - 42,000 pounds per day.
However, if by November 1, 2003, the Division of Water Quality (DWQ),
in consultation with the Technology Review Committee', and the NPDES
Committee agree that there are overwhelming technical, economic, or operational
barriers to the Permittee's ability to attain a 40,000 - 42,000 lbs/day annual color
loading limit, DWQ shall recommend to the NPDES Committee, alternate interim
limits to become effective December 1, 2003. At that time, DWQ shall
recommend a new effective date for achieving an annual average color loading
limit of 40,000 - 42,000 pounds per day. These recommendations shall be based
on what DWQ concludes Blue Ridge Paper can reasonably achieve, giving
consideration to the actual demonstrated color levels discharged and the 'Highest
Certainty' action items and technologies implemented pursuant to Paragraphs 4
' The Technology Review Workgroup shall act in an advisory role to the North Carolina
_. Division of Water Quality, and NC DWQ Shall consult with the Technology Review Workgroup
prior to making any decisions regarding color reduction activities at the Canton Mill.

14
and 5. Based on DWQ's recommendations, the NPDES Committee will
determine an alternate interim limit to become effective on December 1, 2003,
and the new effective date for achieving an annual average color loading limit of
40,000 - 42,000 pounds per day. After the NPDES Committee's final decision,
the NPDES Permit will be modified in accordance with North Carolina's
permitting process.
7. The permittee shall submit to the Division of Water Quality, the Technology
Review Workgroup and the NPDES Committee by December 1, 2003, a report on
the feasibility of achieving a target annual average color reduction within the
range of 3,000 pounds per day and 8,000 pounds per day from the reduction
achieved by implementation of the 'Highest Certainty' actions. This report shall
include an evaluation of the use of the 'Reasonable Certainty' actions identified in
the EPA Tech Team Report and any other actions that would result in additional
color reductions, actions taken by the permittee to reduce color loading (since
permit issuance), and the technical, economic, and operational feasibility .of
implementing the 'Reasonable Certainty' actions on a continuous or intermittent
basis, in order to achieve a target annual average color reduction within the range -
of 3,000 pounds per day and 8,000 pounds per day. As identified in the EPA Tech
Team Report, the 'Reasonable . Certainty' actions are the technologies of
y Ozone/Chlorine Dioxide stage for the hardwood bleach line and second stage
oxygen delignification for the pine line. The report shall identify specific
economic and implementation issues associated with the proposed improvements.
The report shall also project expected additional color reduction for each
technology evaluated and maximum color reduction possible using the identified
technologies. The report shall also include a proposed schedule for
implementation of process improvements or installation of technologies required
to achieve an effluent color reduction of 3,000 - 8,000 pounds per day. The
permittee shall provide this evaluation/report, together with an updated report on
the results of ongoing and additional planned color reduction activities, to the
Division of Water Quality, the Technology Review Workgroup and the NPDES
Committee. By February 1, 2004, DWQ (in consultation with the Technology
Review Workgroup) shall approve or modify the permittee's recommended plan
for achieving a 3,000 - 8,000 pounds per day reduction to the target annual
average.
8. By December 1, 2005, the permittee shall submit, as related to the implementation
of the process improvements evaluated according to Paragraph 7, a statistical
analysis of Blue Ridge Paper's effluent quality performance. This report shall
include a statistical analysis of the Blue Ridge Paper's monthly average and annual
average color discharge, mill performance as related to color, all available data
necessary to derive the lowest achievable annual average and monthly average
color loading limits.

( 15
By February 1, 2006, the Division of Water Quality (in consultation with
the Technology Review Workgroup) shall recommend, considering the statistical
analysis report submitted by the permittee and the demonstrated performance of
the mill, the lowest achievable annual average and monthly average color loading
effluent limitations. If the limits determined to be achievable are within or below
the target range of 32,000 - 39,000 pounds per day as an annual average, the limits
shall become effective on March 1, 2006, by written notification from the
Director. If the limits determined to be achievable by the Division of Water
Quality (in consultation with the Technology Review Workgroup) are above the
target range, the Permit shall be modified in accordance with North Carolina's
permitting process to reflect those limits.
9. By December 1, 2004, the permittee shall evaluate color reduction technologies
associated with the Chloride Removal Process (CRP) wastestream. The CRP
analysis shall concentrate on the technical, economic, and operational feasibility
of implementing the applicable technologies on all or a portion of the purge
stream. The report shall identify specific economic and implementation issues
associated with the improvements. The report shall also project expected _
additional color reduction for each technology evaluated and maximum color
reduction possible.using the identified technologies. Though not limited to the
following, the report shall include an analysis of the land application of the high
- chloride wastewater, commercial incineration, coagulant/precipitation
technologies, and solidification for land disposal. The Division of Water Quality
(in consultation with the Technology Review Workgroup) shall evaluate the
feasibility of implementing identified technologies for further color reduction and
shall submit to the NPDES Committee by February 1, 2005, DWQ's
recommendations regarding color reductions associated with the treatment of the
CRP wastestream.
If during the course of this evaluation Blue Ridge Paper identifies a
technical, economic, and operationally feasible color reduction technology that
can be implemented for treatment of the CRP wastestream, the permittee may
request that the Technology Review Workgroup review this technology for
implementation at the Canton mill. If the Technology Review Workgroup
concurs that the identified technology is suitable for the Canton mill and that the
color reductions achievable are adequate, the mill's obligation to research
additional technologies will be waived after formal notification from Blue Ridge
Paper that the identified technology will be installed and placed into operation.
This notification shall include language indicating the permittee's commitment to
the implementation of the technology, along with a schedule for implementation.
The Division of Water Quality will notify the permittee in writing that the
proposed implementation schedule is acceptable.

16
r
10. By March 1, 2006, the permittee shall submit a report to Division of Water
Quality, the Technology Review Workgroup and the NPDES Committee on the
color reduction efforts as part of the Variance review process (Triennial Review
of North Carolina's Water Quality Standards). This report shall also include an
evaluation of color in the Pigeon River at the Fiberville Bridge, and an evaluation
on the feasibility of complying with North Carolina's Color Standard.
11. The 1997 Settlement Agreement contained provisions to limit color in the Pigeon
River at the Hepco USGS gauge station. The new effluent limits in this permit are
more stringent than the provisions in the 1997 Permit and Color Variance and will
result in reduced color levels in the Pigeon River. It is possible to calculate the
monthly flow at the Canton gage station above which instream color at the
Fiberville Bridge will not exceed 50 true color units. Using the 55,000 pounds per
day monthly average true color loading limit (implemented on the effective date
of the permit) the flow at the Canton Gage station,'which will provide for color
less than 50 true color units at the Fiberville Bridge is 171.8 MGD. Therefore, the
monthly average color in the Pigeon River at the Fiberville Bridge will be less
than 50 true color units whenever the monthly average flow (at the Canton gage
station) is greater than 171.8 MGD.
12. The governing flow criterion for true color at Canton is 58.1 MGD (30Q2 stream
flow). The flow established, pursuant to Paragraph 10, is greater than this 30Q2
stream flow, therefore, for flows less than the 171.8 MGD at the Canton Gage
station but greater than 193.3 MGD (30Q2 flow) at the Hepco gage station, the
monthly average color in the Pigeon River at Hepco will be less than 50 true color
units.
13. Beginning December 1, 2003, the monthly average color in the Pigeon River at
the Fiberville Bridge will be less than 50 true color units whenever the flow at
Canton is greater than the flow established using the following equation and based
on the monthly average effluent limit established per Paragraph 5:
Flow at Canton_USGS(MGD)=(Monthly Aveme Effluent Color Limidb/dav-12468.3)+31.6+2.4
308.58
For flows at the Canton Gage station less than the flow established here
but greater than 193.3 MGD at the Hepco gage station, the monthly average color
in the Pigeon River at Hepco will be less than 50 true color units.
14. Beginning March 1, 2006, the monthly average color in the Pigeon River at the
Fiberville Bridge will be less than 50 true color units whenever the flow at Canton
is greater than the flow established using the following equation and based on the
monthly average effluent limit established per Paragraph 8:

17
Flow at Canton_USGS(MGD)=(M`hly Awraee Effluent Cola[ Limit.lb/day-12468 31+31.6 +2.4
308.58
For flows at the Canton. Gage station less than the flow established here
but greater than 193.3 MGD at the Hepco gage station, the monthly average color
in the Pigeon River at Hepco will be less than 50 true color units.
15. The potential exists that there could still be periods of time corresponding to
periods of lower flow in the river, when color at Fiberville might exceed 50 true
color units. Therefore, the permittee shall continue to implement the approved
Low Flow Contingency Plan for mitigating the occurrence and degree of this
potential exceedence.
16. The permittee shall not increase the mill's pulp production capacity during the
term of this permit, unless the permittee can demonstrate that the increased
production can be achieved while reducing color loading. In addition, increasing
the mill's pulp production capacity may require permit revision in accordance with
North Carolina's NPDES Permitting rules.
17. The NPDES Permit shall be subject to reopening in order to modify the color
/ requirements based upon the following and in association with the required
l triennial reviews:
Any breakthrough in color removal technologies. Such breakthroughs shall
be brought to the NPDES Committee for consideration, by Blue Ridge
Paper and the Division of Water Quality, as soon as they are discovered.
An acceptable statistical analysis of effluent color discharge data
demonstrating significantly better color removal performance than that
currently prescribed in the variance and permit, except as noted herein.
Successful application of end-of-pipe color reduction technology or in-mill
color minimization effort that results in significant and measurable
reduced mass color discharge.
18. The transfer of this NPDES permit will not proceed until any successor-in-interest
to the current permittee has agreed to accept the provisions of this permit and
request and received from the NPDES Committee a transfer of 2001 Revised
Color Variance.
1 a

18
C. The Division of Water Quality shall include review of this variance as a specific
item in its Triennial Water Quality Standards review, as required by the federal Clean Water Act,
and make appropriate recommendations to the NPDES Committee.
D. This variance shall extend for an indefinite period of time, subject to
consideration during the water quality standards triennial reviews. Any modification or
termination based thereon shall be subjected to the public hearing process required by N.C.G.S.
143-215.3(e).
It is further ORDERED that this Color Variance shall be effective as of the effective date
of the renewed NPDES Permit No. NC 0000272 for the Canton Mill, and the terms of the
previously existing variance shall continue in effect until that time.
This the b--6-1 day of October, 2001.
Charles H. Peterson, Acting Chairman
NPDES Committee
i

19
CERTIFICATE OF SERVICE
This is to certify that I have this day served a copy of the foregoing COLOR VARIANCE
on the parties listed below by the methods indicated, addressed to each as follows:
Robert Williams, Director CERTIFIED MAIL
Environment Health & Safety Affairs RETURN RECEIPT REQUESTED
Blue Ridge Paper Products, Inc.
P. O. Box 4000
Canton, North Carolina 28716
William Clarke, Esq. CERTIFIED MAIL
Roberts & Stevens RETURN RECEIPT REQUESTED
P.O. Box 7647
Asheville, North Carolina 28802
Gregory J. Thorpe, Acting Director HAND DELIVERY
Division of Water Quality
N.C. Department of Environment
and Natural Resources
' 9th floor, Archdale Building
Raleigh, North Carolina 27601-7687
Jennie Odette, Clerk HAND DELIVERY
Environmental Management Commission
N.C. Department of Environment
and Natural Resources
9th floor, Archdale Building
Raleigh, North Carolina 27601-7687
Paul Davis CERTIFIED MAIL
Tennessee Department of RETURN RECEIPT REQUESTED
Environment & Conservation
6th floor, L & C Annex
401 Church Street
Nashville, Tennessee 37243-1534
David McKinney CERTIFIED MAIL
Tennessee Wildlife Resources RETURN RECEIPT REQUESTED
Ellington Agriculture Center
P. O. Box 40747
Nashville, Tennessee 37204

20
Gary A. Davis CERTIFIED MAIL
Tennessee Environmental Council RETURN RECEIPT REQUESTED
P. 0. Box 2346
Knoxville, Tennessee 27901-2346
Beverly Bannister CERTIFIED MAIL
U.S. Environmental Protection RETURN RECEIPT REQUESTED
Agency, Region 4
Director of Water Management
100 Alabama Street, SW
Atlanta, Georgia 30303
David Jenkins CERTIFIED MAIL
American Canoe Association RETURN RECEIPT REQUESTED
7432 Alban Station.Boulevard
Suite B-226
Springfield, Virginia 22150
Charles Lewis Moore CERTIFIED MAIL
County Executive RETURN RECEIPT REQUESTED
Cocke County Tennessee
360 Main Street East
Newport, Tennessee 37821
Roland Dykes CERTIFIED MAIL
Mayor of Newport RETURN RECEIPT REQUESTED
P.O. Box 370
Newport, Tennessee 37821
This the 154'i'day of October, 2001.
ROY A COOPER
Attorney General
Francis W. Crawley
Special Deputy Attorney General
N. C. Department of Justice
P. 0. Box 629
Raleigh, North Carolina 27602-0629
919/716-6600

MCO"110 co""
(q�tq rrW,4 -cam
:�i
12131197NPDES Permit and Modified Variance Compliance Timeline
Date: Requirements,Limitations & Details:
January 1, 1998 Monthly average discharge of true color will not exceed 95,000 Ibs/day
March I, 1998 Status Report Due to NPDES Committee on the analyses prepared for other
permitting agencies concerning the effects of the BFRTM technology on air
emissions
June 1, 1998 Report Due to Technology Review Workgroup(TRW)and NPDES Committee
which will identify a STRATEGY and TIMELINE for implementing the
following color reduction measures until the target effluent limitations are met or
all measures have been fully implemented:
• Further upgrading and integrating of sewer monitoring
— additional flow measurement and sampling stations
— substantially improve the mass balance
• Automated mill process control systems with operational
procedures and management oversight to reduce black liquor leaks
and spills.
• Continued operator training
• Identifying and implementing additional controls for known but
unmeasured sources of liquor losses
— evaporator set
— knot rejects bins
• Modifying digester area to facilitate capturing of leaks and spills
• Diverting clean water discharges
• Capturing and recycling liquors during fiber line disruptions:
— detailed scheduling of planned outages
— contingency planning for unplanned outages
• Thoroughly evaluate additional measures to modify its process
operations and controls to remove or reduce sewer generated color
The report will include an explanation of and rationale for both the
implementation strategy and proposed time line. The report will also identify
those measures which will be implemented in the event the effluent limitations of
December 1, 1998 are not met
June 1, 1998 Fully implement the following four BMPs:
• Installation of replacement digester recirculation pumps and a spill
collection sump
• Installation of a pine courtyard Parshall flume slide gate
• Installation of weak black liquor containment
• Other measures including:
— Correction of evaporator set demister clogging
— Installation of condensate instrumentation and sampling ports
for the evaporator set
— Assurance of continued dry conveying of knot rejects

October I, 1998 If TRW determines, and NPDES Committee agrees,that there are overwhelming
technical,economic or operational barriers to the permittee's ability to attain the
60,000 Ibs/day annual average and 69,000 lbs/day monthly average color loading
limits,the TRW shall recommend to the NPDES Committee the alternate
interim limits to become effective 12/1/98. TRW shall also recommend to the
NPDES Committee a new effective date for achieving annual average color
loading limit of 60,000 Ibs/day.
December I, 1998 Submit to TRW a contingency plan, corresponding to periods of river flow less
than 330 cfs at Hepco gauging station, for mitigating the occurrence and degree
of potential exceedences of 50 true color units at Hepco by evaluating:
• scheduling of maintenance
• intermittent treatment
• production curtailment
• any other temporary measures
NOTE: The model limitation maybe extended beyond 1211198 if the NPDES
Committee establishes interim limits which require the model to be used to
assure compliance with 50 true color units at the state line.
Monthly average discharge of true color shall not exceed 69,000 Ibs/day
Annual average discharge of true color shall not exceed 60,000 lbs/day
Pigeon River color at Hepco gage shall be less than 50 true color units whenever
monthly average flows are greater than 330 cfs.
January 1, 1999 Begin implementation of Eo recycle on the hardwood fiber line
February 1, 1999 TRW will recommend to the NPDES Committee either approval of or
modification to the plan.
March 1, 1999 The low flow contingency plan shall become effective upon approval
December I, 1999 Report Due to TRW and NPDES Committee on:
• Evaluation of color reduction benefit gained from Eo recycle on
the hardwood fiber line
• Potential color reduction benefit to be gained from full
implementation of the BFRTM technology on hardwood fiber line
--- NOTE: All of the above color related work is referred to as the NEAR-TEPMPACKAGE---
June 1,2000 Anticipated that full implementation of Near-Term Package could be effectuated
January 1,2001 Report Due to TRW and NPDES Committee on the feasibility of achieving a
target annual average color loading limit within the range of 48,000-52,000
lbs/day on full implementation of the Near-Term Package.

March I,2001 A) Evaluate and report on end-of-pipe color reduction technologies in
conjunction with the Triennial Review of NC Water Quality Standards. This
evaluation shall include:
• Incremental color improvement analysis
• Technical, economic and operational feasibility of the application
of these technologies on a continuous or intermittent basis
(specifically at periods of low river flow)
• Economic and Implementation issues associated with the
incremental improvement of color levels expected by installing
these technologies
• Projection of the expected additional color reduction for each
technology and the maximum color reduction possible
B) Updated report on the results of all ongoing and any additional planned color
reduction activities.
April 1,2001 TRW shall recommend to the NPDES Committee and other Settlement
Agreement parties,considering the feasibility report submitted on January 1,
2001 and the demonstrated performance of the mill,the lowest achievable annual
average and monthly color loading effluent limitations.
May I, 2001 The recommended limits, if within the target range(48,000-52,000 Ibs/day),
shall become effective
June 1, 2001 • Submit Report to the NPDES Committee and NCDENR, Division of Water
Quality,on the comparative evaluation of the above collaborative efforts as
part of the Variance review process.
• Statistically evaluate the monthly average color discharge,annual average
color discharge and performance of the mill in relation to color discharged.
•Results used to make recommendations to the 1997 permit for the 2002 permit.
November 30,2001 Permit shall expire at midnight
GENERAL The mill's pulp production capacity will not be increased during the
PROVISION permit unless this can be done in a way that also reduces color loading.

V �son- ion
Distribution List January 13, 1998
Ben Bilus �41
Canton. NC Mill -
Settlement Agreement Regarding
1996 Water Quality Color
Variance And 1996 NPDES
Permit Issued to Champion
Attached is a fully executed copy of the Settlement Agreement.
BSB.jm
Distribution
Dick Diforio
Ed Clem
Tom Siegrist
Bob Williams
Derric Brown
Al Joyce
Bill Manzer
Tucker Hill
Dave Hearne
Tom Griffen
Billy Clarke
Jeff McNealey
Steve Brown
Susan Jackson

`A'Fs
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY -
REGION 4
° ATLANTA FEDERAL CENTER
61 FORSYTH STREET, SW
ATLANTA, GEORGIA 30303-8909
RECEIVED
JAN 13 1997
LEGAL AFFAIRS
January 8, 1998
[See Addressed List Attached]
SUBJ: Champion Permit Matter
Gentlemen:
Enclosed is a copy of the final,fully executed Settlement Agreement in the above-
referenced matter.
i
I would like to take this opportunity to thank each of you with whom I had occasion to
work on this project for the high level of professionalism and courtesy which you brought to this
matter. I thoroughly enjoyed working with each of you and look forward to the opportunity to
do so in the future.
Sincerely,
Mary J
Associate gio ttorney
Attachment
Encl.
I
Recycif"*Cyolaale•Printed with Vegetable Oil Based Inks on 100%Recycled Paper(40%Postoensumer)

ADDRESS LIST
I
Barry Turner
Deputy Attorney General
Office of the Attorney General
Cordell Hull Building, 2nd Floor
425 5th Avenue North
Nashville, TN 37243-0495
Paul E. Davis, Director
Division of Water Pollution Control
TN Department of Environment and Conservation
6th Floor
L & C Annex
401 Church Street
Nashville, TN 37243-1534
Daniel C. Oakley
Senior Deputy Attorney General
NC Department of Justice
114 West Edenton Street
Suite 311
Raleigh, NC 27602
Forrest R. Westall
Regional Water Quality Supervisor
NC Department of Environment and Natural Resources
Division of Water Quality, Asheville Regional Office
59 Woodfin Place
Asheville, NC 28801
Benjamin S. Bilus
Senior Associate Counsel
Champion International Corporation
One Champion Plaza
Stamford, Connecticutt 06921
David E. Jenkins
Director of Conservation and Public Policy
American Canoe Association, Inc.
7432 Alban Station Boulevard, Suite B-226
Soringfield, VA 22 1 50-23 1 1

John Noel
Pigeon River Coordinator
Tennessee Environmental Council
1700 Hayes Street. Suite 101
Nashville, TN 37203
Honorable James E. Robinson
Mayor, City of Newport
P.O. Box 370
Newport, TN 37822
Mr. Harold Cates
Cocke County Executive
Court House Annex, Room 146
360 East Main Street
Newport, TN 37821
1

SETTLEMENT
A RE *^^ RQGARDIN 996 WATER nrrar r
COLOR VARIANCE AND 1296 h nv4 PrRmTm T
nSUEn
TO CHAMPION IXTERNATTOhr T rOR ORATrnu
I. INTRODUCTION
1. The United States Environmental Protection Agency
(EPA) , the State of North Carolina (North Carolina) , the State of
Tennessee (Tennessee) , Cocke County, Tennessee (Cocke County) ,
the City of Newport, Tennessee (Newport) , the Tennessee
Environmental Council (TEC) , the American Canoe Association
(ACA) , and Champion International Corporation (Champion) enter
into this Settlement Agreement to resolve the concerns of
Tennessee, Cocke County, Newport, TEC, and ACA with the amended
modified water quality color variance granted by North Carolina
to Champion on December 11, 1996, and approved by EPA on December
26, 1996, and with the NPDES permit issued by North Carolina to
Champion on December 12, 1996. It is also intended that this
Agreement will be the basis for resolution of the contested case
Proceeding pending before the North Carolina Office of
Administrative Hearings to which all of the foregoing, except
EPA, are parties .
II. PROCEDURAL HISTORY
2 . Champion operates a bleached kraft pulp and paper mill
on the Pigeon River at Canton, North Carolina, and discharges
treated wastewater from its mill operations, domestic wastewater
from the Town of Canton, and leachate from its active landfill
into the river. The Pigeon River below Canton is designated by
cNorth Carolina as a Class C river (secondary recreation, fishing,
aquatic life, including propagation and survival , and wildlife)

and flows from North Carolina northwestwardly into Tennessee.
Under the Federal Water Pollution Control Act (commonly referred
to as the Clean Water Act) , 33 U.S.C. § 1251 st. 'sprT„ and under
North Carolina ' s Water and Air Resources Act, N.C. Gen. Stat. §§
143-211 aL z,_„ Champion is required to have an NPDES permit for
these discharges .
3 . Until January 1, 1997, when the permit issued on
December 12 , 1996, by the State of North Carolina took effect,
Champion was operating its Canton mill under an NPDES permit
issued by EPA, effective October 25, 1989 . EPA issued that
permit after objecting to, and subsequently vetoing, the permit
that North Carolina had issued to Champion in mid-1985 . EPA
vetoed the North Carolina permit on the grounds that it did not
reasonably ensure compliance with Tennessee ' s narrative water
quality criteria for color. On November 13, 1985, EPA notified
Champion that it had assumed permitting authority for the
Champion permit . North Carolina and Champion challenged EPA' s
authority to take over the permit in federal court . In 1987, the
District Court for the Western District of North Carolina
rendered an opinion upholding EPA' s permitting authority.
Chamninn v.
, 648 F.Supp. 1390 (W.D.N.C. 1987) . This opinion
was upheld by the Fourth Circuit Court of Appeals in 1988,
Champion v. , 850 F. 2d 182 (4th Cir. 1988) , and EPA issued its
permit on September 25, 1989 . Champion and the Dead Pigeon River
.Council appealed the EPA permit . After an administrative hearing
before EPA Administrative Law Judge Thomas B. Yost, the permit
ti-
was upheld on February 12 , 1992 .

4 • In 1988, the NPDES Committee' of the North Carolina
Environmental Management Commission granted Champion a variance
from the North Carolina narrative water quality criterion for
color. EPA approved this variance on August 11, 1988 .
5 . The EPA-issued permit and the North Carolina color
variance have operated together to control the contribution of
effluent color by Champion to the Pigeon River, by the use of a
predictive model and a color limitation of 50 true color units on
a monthly average basis at the North Carolina/Tennessee state
line.
6 . Champion ' s EPA-issued permit for the Canton mill (NPDES
Permit No. NC0000272 ) was set to expire on October 24, 1994 . On
March 28, 1994, Champion applied to the North Carolina Department
Of Environment, Health and Natural Resources (NCDEHNR) for
-' renewal of this permit . At that time, North Carolina advised
Champion that it believed EPA was the proper permitting agency,
since EPA had assumed control of the facility ' s permit in the
previous permit cycle . Champion, therefore, applied to EPA for a
renewal on April 15, 1994 . EPA then advised Champion that North
Carolina was , in fact , the proper permitting agency, and Champion
filed its renewal application with North Carolina on November 18,
1994 .
7 . The 1988 color variance was reviewed by the North
Carolina Environmental Management Commission as a part of its
triennial review and was -continued on May 12 , 1993 . On November
29 , 1994, EPA approved the continued variance.
8 • On June 6, 1996, North Carolina conducted a public

..............................
hearing in Haywood County, North Carolina, to consider renewal of
NPDES Permit No. NC0000272 and modifications to the 1988 color
variance. A public comment period extended for thirty (30) days
after the public hearing. The effluent color limitation for the
Canton Mill was one of the issues subject to comment .
9 • Tennessee provided public comment at the hearing as
well as in writing thereafter through the Tennessee Department of
Environment and Conservation (TDEC) and the Tennessee Wildlife
Resources Agency (TWRA) . Those comments stated that color in the
river in Tennessee was still objectionable, particularly during
the low-flow period from mid-summer through fall. The comments
further stated that additional conditions needed to be placed on
effluent color to meet the Tennessee narrative water quality
criterion for color. ACA members also participated in the public
hearing. TEC provided written comments which also raised
objections to the noticed permit . EPA also provided comments on
the publicly-noticed draft permit by letter, dated July 3 , 1996.
TEC and ACA also subsequently submitted additional comments to
EPA expressing concerns regarding the permit and variance.
10 . Following the public hearing, North Carolina,
Tennessee, EPA and Champion attempted to resolve the color issue
through several formal and informal mechanisms . Based on the
Public record and EPA' s comments, a proposed final permit was
prepared on October 1, 1996 . The North Carolina NPDES Committee
then mod----I mite 1988 color variance un uctober 15, 1996 .
11 . Discussions among North Carolina, Tennessee and EPA
continued thereafter; additional targets for continued color
w.

reductions and more restrictive mass-based color limits were
Placed in the permit and variance by North Carolina, based on
comments received, and Tennessee was added as a specifically-
named member of the Variance Review Committee, which would
periodically consider the variance conditions . These changes
were documented in the variance modification by a new Amended
Order of the North Carolina NPDES Committee issued on December
11, 1996, and in the permit issued on December 12, 1996.
12 . EPA Region 4 supported the December 1996 variance
amendments by letter dated December 9, 1996; and EPA Region 4
subsequently approved the amended color variance modification by
letter dated December 26, 1996.
13 . By letter dated December 23 , 1996, Tennessee advised
EPA that it considered the permit to be invalidly issued and that
North Carolina had failed to comply with § 402 (b) (5) of the Clean
Water Act, 33 U.S.C. § 1342 (b) (5) . Subsequently, on January 13 ,
1997, Tennessee filed a contested case petition with the North
Carolina Office of Administrative Hearings challenging the permit
and color variance. Thereafter, Champion, Cocke County, and
Newport were allowed to intervene in the North Carolina contested
case proceeding.
14 . In an effort to resolve the color issue without time-
and resource-consuming litigation, North Carolina, Tennessee,
Cocke County, Newport, Champion, and EPA agreed to an informal
negotiation process . The North Carolina contested case
Proceeding was stayed during this process until September 26,
�� 1997 . On November 21, 1997, TEC and ACA were also allowed to

intervene in the North Carolina contested case proceeding.
15 . The agreements which follow constitute what the parties
to this Agreement believe to be an appropriate and reasonable
resolution of the pending disputes surrounding the contested
permit and variance. All parties to this Agreement are committed
to the ultimate achievement of water quality standards in the
Pigeon River, both in North Carolina and in Tennessee. This
Agreement and the modified variance and the permit resulting
therefrom represent a major step toward that goal. At the same
time, the parties recognize that there is further work to be done
and they are committed to attaining further reductions in color
in the river at the quickest possible pace.
III. TECHNOLOGY MODIFICATIONS
TO THE VARIANCE/PERMIT
_.. 16. The parties hereby agree to the following measures to
achieve additional color reduction over that *required in the
permit issued on December 12 , 1996 and by the color variance
adopted on December 11, 1996 [hereinafter the December 1996
Permit and variance] . The parties further agree that the
December 1996 permit and variance will be modified [hereinafter
the 1997 Permit and the Revised Variance] to reflect these
requirements and effectuate this Settlement Agreement . Except as
modified by the Settlement Agreement, all other provisions of the
December 1996 permit and variance, including the monitoring and
reopener provisions, will be maintained in the 1997 Permit and
the Revised Variance.

i
17 . The Dece
mber 1996 permit and variance required that
Champion implement a one-year demonstration of full-scale bleach
filtrate recycling (BFR7") technology on the mill ' s pine line and
that, as of December 1, 1998, Champion implement and operate
BFRTH technology on its pine line, unless Champion could
demonstrate to the NPDES Committee that BFRT" was not
commercially viable. Champion has nearly completed the process
of the required demonstration phase of BFRT . Based on the
results of the demonstration effort, Champion commits to continue
the full operation of the BFRT" technology on the mills pine
line on a continuing basis, subject to the process set forth in
Paragraph 22 .
18 . The 1996 permit and variance required Champion to
evaluate the potential for additional minimization of color
losses from the manufacturing processes and raw material storage
areas (i.e. in-mill color minimization; or, spill
prevention/control measures) that might result in further color
reductions and to report its findings to the NPDES Committee.
Reports were to be submitted by March 1, 1998 and again by June
1, 2001, so that they could be used by the Committee in
conjunction with the required variance review process held every
three years to determine if the variance would be readopted or
made more stringent . As a part of the efforts to resolve the
challenge to the 1996 permit and variance, a Technology Review
Wor?c--=u-. .. , , formed, com r4sed cf F - experts on the pulp and paper
industry from EPA and representatives of the environmental
agencies for the States of Tennessee and North Carolina . The

Technology Review Workgroup shall replace the'-previously existing
North Carolina Variance Review Committee and *shall be maintained
during the life of the 1997 Permit in order: to make the
recommendations and determinations which this Agreement calls for
such Workgroup to make. The Technology Review Workgroup shall,
at all times, be chaired by EPA and be comprised of three
technical representatives from EPA with expertise on the pulp and
paper industry, two environmental agency representatives from the
State of Tennessee, and two environmental agency representatives
from the State of North Carolina. The Workgroup shall make
itself available to consult with and provide information to
community representatives at appropriate times . In addition,
consistent with any limitations under law or regulation relating
to confidential business information, copies of all written
reports and recommendations generated pursuant to this Agreement
shall be provided to the parties to the Agreement at least 20
days before any recommendation or determination by the Workgroup
becomes final . The Workgroup shall review any comments or input
received on such documents prior to making its final
recommendations or determinations . Any comments or input
received by the Workgroup shall be made available to all parties
to this Agreement .
19 . Working with the Technology Review Workgroup, Champion
has already begun the process of identifying and implementing
Possible prevention- anc control measures which can !De Laken to
further reduce color discharges from the mill . Champion commits
to further evaluate mill operation so as to fully identify

.............. ...
opportunities for preventing and controlling measurable black
I
liquor leaks and spills (best management practices - BMPs) . This
evaluation will include gathering more extensive and detailed
data on sources of color within the mill to substantially improve
the accuracy of measurements, to improve the mill ' s existing BMP
program, and to complete efforts to identify, quantify and
substantially improve the accuracy of a mass balance of sources
of leaks and spills of black liquors, including unmeasured
sources and discharges during periods of fiber line disruption.
Such BMPs include: further upgrading and integrating of sewer
monitoring (e.g. , additional flow measurement and sampling
stations to facilitate more comprehensive and daily monitoring of
sources) and automated mill process control systems with
operational procedures and management oversight to reduce black
liquor leaks and spills ; continuing operator training;
identifying and implementing additional controls for known but
unmeasured sources (e.g. , evaporator set, knot rejects bin, etc . )
Of liquor losses ; modifying the digester area to facilitate
capturing leaks and spills; diverting clean water discharges; and
capturing and recycling liquors during fiber line disruptions
through detailed scheduling of planned outages and contingency
planning for unplanned outages . Champion also commits to
thoroughly evaluate additional measures to modify its process
operations and controls to remove or reduce sewer generated
color.
20 . Champion agrees to provide a report to the Technology
t Review Workgroup and the NPDES Committee no later than June 1,

i
1998 . This report will identify a strate
gy •and time line for
implementing those color reduction measures identified in
Paragraph 19 until the target effluent limitations in Paragraph
24 are met or all measures in Paragraph 19 have been fully
implemented. The report will include an explanation of and
rationale for both the implementation strategy and the proposed
time line. The report will also identify those measures which
will be implemented in the event that the effluent limitations
set out in Paragraph 22 are not achieved by the color reduction
measures specified in that paragraph.
21 . Four BMPs which have already been identified as having
both a high potential for achieving color reduction and a high
level of implementability are: a) installation of replacement
digester recirculation pumps and a spill collection sump; b)
installation of a pine courtyard Parshall flume slide gate; c)
installation of weak black liquor tank containment, and; d)
correction of evaporate set demister clogging, installation of
condensate instrumentation and sampling ports for the evaporator
set, and assurance of continued dry conveying of knot rejects .
Champion commits to fully implement all four of these BMPs by
June 1, 1998 .
22 . The 1996 permit and variance required that the annual
average effluent true color loading should not exceed 98, 168
lbs/day and that the monthly average true color loading should
not exread 125, 434 lbs/day . Based on current demonstrated
achievable levels which have resulted from measures that Champion
has already undertaken to reduce color from the mill , the parties

agree that the 1997 Permit and Revised Variance shall provide
that beginning January 1, 1998, the monthly -average discharge of
true color from the mill shall not exceed 95, 000` lbs/day. Based
on an analysis of the available data from the BFR2T demonstration
Project and the spill prevention/control measures that have
already been identified by Champion and the Technology Review
Workgroup as being implementable in the near-term, it is
anticipated that full-scale implementation of BFR29 on the pine
line combined with the four BMPs identified in Paragraph 21 will
reduce annual average color loading by approximately 40% below
the limits in the December 1996 permit . Therefore, the 1997
Permit and Revised Variance will require that, beginning December
1, 1998, the annual average discharge of true color shall not
exceed 60, 000 lbs/day and the monthly average true color loading
shall not exceed 69, 000 lbs/day. However, if by October 1, 1998,
the Technology Review Workgroup determines, and the NPDES
Committee agrees, that there are overwhelming technical, economic
or operational barriers to Champion' s ability to attain the
above-stated color loading limits, the Technology Review
Workgroup shall recommend to the NPDES Committee the alternate
interim limits to become effective December 1 , 1998 . The
Workgroup shall, at the same time, also recommend to the NPDES
Committee a new effective date for achieving an annual average
color loading limit of 60, 000 lbs/day. These recommendations
shall be based cn wh.L Caie Workgroup concludes Ci.amoion can
reasonably be expected to achieve, giving due consideration to
the demonstrated discharge levels which the mill has , in fact,

achieved and taking into account the evaluations conducted
pursuant to Paragraph 19 and the report submitted by Champion
pursuant to Paragraph 20 . Based on the Workgroup' s
recommendations, the NPDES Committee will determine the alternate
interim limits to become effective on December 1, 1998, as well
as a new effective date for achieving an annual average color
loading limit of 60, 000 lbs/day. The permit will then be
modified in accordance with North Carolina' s permitting process
to reflect these determinations .
23 . The 1996 permit and variance required Champion to
evaluate color reduction strategies for further optimization of
BFR1" technology and to report on the feasibility of
implementation on the hardwood line. Champion commits to begin
implementation of that portion of the BFRTm technology which
involves the recycling of the Eo stage of the hardwood line by no
later than January 1, 1999 . Champion further agrees to provide
an evaluation of that implementation as well as the potential for
full implementation of the BFRT" technology on the mill ' s
hardwood line to the Technology Review Workgroup and the NPDES
Committee by December 1, 1999 . The evaluation will include data
reflecting the color reduction benefit gained from the partial
implementation and a projection of potential color reduction
benefit to be gained from full implementation of the BFR
technology on the hardwood line .
24.. . Based on the work that Champion and the Technology
Review Workgroup have already done in the area of in-mill color
I `- reduction measures, it is anticipated that further color

reductions, beyond those to be obtained by BFR"` on the pine line
in combination with the four BMPs identified in Paragraph 21,
could be expected after implementation of the BMPs and measures
to reduce and/or remove sewer generated color identified in
Paragraph 19, and partial BFR " (i. e. , recycle of Eo filtrate) on
the hardwood line. This combined package of in-mill color
reduction measures (i .e. , the four BMPs in Paragraph 21, the
additional BMPs and sewer-generated color reduction measures
identified in Paragraph 19 as implemented pursuant to Paragraph
20, full implementation of BFR on the pine line, and partial BFR
on the hardwood line) shall hereinafter collectively be referred
to as the Near-Term Package. It is further anticipated that full
implementation of the Near-Term Package could be effectuated by
( June 1, 2000 , resulting in a target color annual average loading
within a range of 48, 000-52, 000 lbs/day. Champion shall submit
to the Technology Review Workgroup by January 1, 2001, a report
on the feasibility of achieving a target annual average color
loading limit within the range of 48, 000-52 , 000 1bs/day based on
full implementation of the Near-Term Package. This report shall
include all available data necessary to derive the lowest
achievable annual average and monthly color loading limits . By
April 1, 2001, the Technology Review Workgroup shall recommend,
considering the feasibility report submitted by Champion and the
demonstrated performance of the mill, the lowest achievable
a :ual average and month-,'••
color loading effluent limitations .
The Workgroup evaluation and recommendation report shall be
submitted to the NPDES Committee and the other parties to this

Agreement. If the recommended limits are within the target
range, the limits shall become effective on May 1, 2001, by
written notification from the Director of the North Carolina
Division of Water Quality. If the limits determined to be
achievable by the Workgroup are not within the target range, the
Permit shall be modified in accordance with North Carolina's
Permitting process to reflect those limits . The Workgroup's
recommendation of limits under this Paragraph shall take into
account appropriate effluent variability.
25 . The 1996 permit and variance contain provisions to
limit color in the Pigeon River at the NC-TN state line to a
maximum monthly average of 50 true color units . The new effluent
limitations in this Agreement at Paragraphs 22 and 24 are more
stringent than the provisions in the 1996 permit and variance and
will result in color levels at the state line well below 50 true
color units . It is possible to calculate the monthly flow at the
Hepco gage above which instream color will not exceed 50 true
color units for any specific color discharge from the Champion
facility. Using the 69, 000 lbs/day monthly average true color
loading limit anticipated in Paragraph 22 to become effective
December 1, 1998, the flow which will provide for color less than
50 true color units at the Hepco gage is 330 cubic feet per
second (cfs) . Therefore, the parties to this Agreement agree
that the scope and magnitude of the 1996 variance will be reduced
in the Revised 'variance to provide that : c-Zfe-uLive December 1,
1998, color in the Pigeon River at the Hepco gage shall be less
than 50 true color units whenever monthly average flows are

I greater than 330 cfs . The parties to this Agreement further
I
agree that should alternate interim limits be set pursuant to
Paragraph 22 , or when monthly limits are established pursuant to
Paragraph 24, the above variance conditions will be revised in
accordance with the above approach. Using North Carolina's
governing flow criteria (30Q2) , historical flow records, and the
December 1, 1998 effluent limits in Paragraph 22 , it is expected
that color in the Pigeon River at the Hepco gage will be less
than 5o true color units 91% of the applicable time. Similarly,
using the May 1, 2001 effluent limits in Paragraph 24, it is
expected that color in the Pigeon River at the Hepco gage will be
less than 50 true color units 96% of the applicable time.
Champion agrees to cooperate fully with any periodic independent
monitoring (including activities such as splitting samples)
requested by EPA or the State of North Carolina. In-stream
monitoring data gathered during the 1997 Permit term will be
evaluated at the end of the 1997 Permit term to determine whether
the limits established under the Permit, in fact, attained the
color levels as expressed in the Variance. This information will
be used to develop new requirements for the next permit which
further reduce color levels in the Pigeon River.
26. As Paragraph 25 recognizes, there could still be some
Periods of time, corresponding to periods of lower flows in the
river, when color at the Hepco gage might exceed 50 true color
units . Champion agrees to develop a contingency plan for
mitigating the occurrence and degree of these potential
exceedances which correlates measures designed to achieve

mitigation with periods of lowest flow, with"particular attention '
I
being given to periods of higher recreational use in the river.
In developing the plan, Champion shall evaluate any reasonable
means, including scheduling of maintenance, intermittent
treatment, and production curtailment, which would achieve
additional color reductions during temporary periods of lower
flows in the river, when color at the Hepco gage might exceed 50
true color units . The contingency plan shall be submitted by
December 1, 1998, for review by the Technology Review Workgroup.
Champion agrees to work in good faith with the Workgroup to
resolve any issues which arise during this review in order to
achieve a mutually acceptable plan. By February 1, 1999, the
Technology Review Workgroup will recommend to the NPDES Committee
/ either approval of or modifications to the plan. The NPDES
Committee will approve the contingency plan, either as submitted
or with the changes the Committee determines are appropriate.
The plan shall become effective upon approval, which shall be no
later than March 1, 1999 .
27 . Champion commits to, and North Carolina will direct,
the continuing improvement of existing process and related
technologies which could improve the efficiency of all water-
using equipment and operations throughout the mill, with the goal
of meeting North Carolina' s water quality standards under the
Clean Water Act without a variance .
28 . The 199, pe-mit and variance required Champion to
evaluate and report to the NPDES Committee on end-of-pipe color
L4 reduction technologies that could conceivably be implemented at

the mill. The evaluation was to include an incremental color
I
improvement analysis which concentrated on the technical,
economic, and operational feasibility of the application of these
technologies on a continuous or intermittent basis . The
intermittent application of these technologies was to look
particularly at periods of low river flow. , These reports were to
be submitted to the NPDES Committee for its consideration as part
of the water quality standards Triennial Reviews to determine
whether the variance should be readopted or made more stringent.
The reports were to identify specific economic and implementation
issues associated with the incremental improvement of color
levels expected by installing these technologies at the mill.
They were also to project the expected additional color reduction
Possible using the identified technology. The first such
evaluation/report, which was due March 1, 1998, has essentially
been completed as a result of the Technology Review Workgroup's
efforts . A subsequent evaluation/report was to be due March 1,
2001 . Champion agrees to provide this evaluation/report,
together with an updated report on the results of all ongoing and
any additional planned color reduction activities , to the
Technology Review Workgroup and the NPDES Committee March 1,
2001 . The Technology Review Workgroup shall evaluate this
combined report and make recommendations to the NPDES Committee
for further color reduction targets for inclusion in the next
NPDES penui� .
29 . The parties agree that the 1997 Permit shall require
��J that Champion and any successor-in-interest to Champion's

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technical resources within the Agency which may be available to
support and further such development opportunities in Cocke
County. EPA will also support and work closely with TVA on its
Quality Communities Initiative, a community based effort being
undertaken by TVA, the goal of which is to develop a long-term
economic development strategy for Cocke County and surrounding
areas . In addition, North Carolina and Tennessee will foster
joint planning and public input on decisions affecting the Pigeon
River by establishing a Joint Watershed Advisory Committee and
Champion will establish a facility Community Advisory Committee.
V. ECOLOGICAL ASSESSMENT OF THE PIGEON RIVER
SYSTEM AND THE WATERVILLE RESERVOIR
33 . Over the years, a number of studies have been conducted
by various entities on the health of the aquatic biological
community in the Pigeon River and, in particular, analysis of
fish flesh contamination. However, EPA believes* that a more
current evaluation of the level of contaminants remaining in the
system and the overall health of the river and of the Waterville
Reservoir should be undertaken. EPA will lead, in cooperation
with North Carolina and Tennessee, an independent evaluation of
current information on the Pigeon River. The evaluation will
include convening a group of scientists to evaluate existing
data, to identify additional data needed, and, if necessary, to
conduct an ecological assessment . EPA agrees to take the lead in
convening the scientific panel . The information gather-d from
such an assessment would be used to determine whether any
significant ecological or health risks exist, and, if so, what,
i -•- if any, steps could and should be taken to address those risks .

VI. ADDITIONAL, COVENANTS AND
AGREEMENTS OF THE PARTIES
34 . In consideration of the covenants and agreements made
by the other parties to this Settlement Agreement, North Carolina
covenants and agrees to modify the amended modified color
variance granted to Champion on December 11, 1996, and to revise
NPDES Permit No. NCO000272 issued to Champion on December _12,
1996, to reflect the requirements found in' Section III of this
Settlement Agreement . North Carolina agrees that these
modifications to the variance and permit will be made and the
1997 Permit and Revised variance incorporating those requirements
will be finalized and will become effective no later than
December 31, 1997 . North Carolina agrees that it will not
further modify the 1997 Revised Variance prior to the triennial
� ._. review, or further modify the 1997 Permit prior to its expiration
in 2001 except as provided in this Agreement, unless North
Carolina seeks to impose more stringent requirements in the
variance and/or the permit to protect water quality. North
Carolina agrees to conduct public hearings on Champion' s next
NPDES permit renewal application by June or July of 2001 and to
make its decision on reissuance of the NPDES permit, as well as
its decision on extension of or modifications to the color
variance, by October 31, 2001 .
35 . In consideration of the covenants and agreements made
by the other parties to this Settlement Agreement, Champion
agrees to the modifications to be made by North Carolina to the
variance granted it on December 11, 1996, and to the NPDES permit
issued to it on December 12, 1996 . Champion further agrees not

to seek administrative or judicial review of 'the 1997 Revised
Variance and/or the 1997 Permit as long as they are consistent
with this Agreement . Champion agrees to submit its NPDES permit
renewal application for the Canton mill no later than March 1,
2001 .
36 . In consideration of the covenants and agreements made
by the other parties to this Settlement Agreement, Tennessee,
Cocke County, Newport, TEC and ACA agree that they will neither
Oppose EPA' s approval of the 1997 Revised Variance, nor request
that EPA object to the 1997 Permit . Tennessee, Cocke County,
Newport, TEC and ACA further agree that they will not seek
administrative or judicial review of the 1997 Revised Variance
and/or the 1997 Permit so long as they are consistent with this
Agreement . The same parties further agree that they will not
seek to have any change in water quality standards that Tennessee
might make during the life of the 1997 Permit effective against
Champion prior to the next permit term.
37 . EPA has reviewed and considered the proposed changes to
the December 12, 1996 permit and the December 11, 1996 variance
called for by this Agreement in accordance with its obligations
under the Clean Water Act . EPA hereby represents that as long as
the 1997 Permit and Revised Variance are consistent with this
Agreement, it will approve the 1997 Revised Variance and will not
object to the 1997 Permit .
38 . Tennessee, CO kc: \Liiuuty, Newport , TEC, `^
r.�ts, North
Carolina and Champion agree to enter into an agreed order to
resolve the North Carolina contested case proceeding, State o

Tenneaapa at a1 v. North Ca of ;na n o
Huh and jijatur^l Rasrnir t al No. 97 EHR 0041.
That
agreed order, which will be filed with the Administrative Hearing
Officer as soon as the 1997 Permit and Revised Variance have both
been issued, will incorporate by reference this Settlement
Agreement and will constitute a dismissal with prejudice of the
contested case Petition. The agreed order also will reflect that
North Carolina Senior Administrative Law Judge Fred G. Morrison
is suitable to all parties as a mediator of any disputes that may
arise regarding North Carolina's or Champion's compliance with
this Settlement Agreement . Disputes will be presented to Judge
Morrison if the parties are unable to reach resolution under the
informal dispute resolution procedures specified in Section VII
+ of this Settlement Agreement.
VII. DISPUTE RESOLUTION
39 . North Carolina, Tennessee, Cocke County, Newport, TEC,
ACA and Champion agree that should a dispute arise regarding
compliance with this Settlement Agreement by any of those
Parties, the parties shall first attempt to resolve the dispute
informally. It is the intent of the parties that EPA, which is
not a party to the North Carolina contested case proceeding, may
participate so as to facilitate informal dispute resolution if
requested by any other party to do so, and if EPA chooses to do
SO .
40 . As a condition precedent to a party bringing any civil
suit for breach of this Settlement Agreement, that party must
first attempt to resolve the purported dispute as expeditiously

as possible within the following framework. All time frames for
informally resolving disputes may be lengthened by mutual
consent . Each of the parties will designate a representative for
informal dispute resolution. A party representative claiming
that a dispute has arisen will summarize the dispute in writing,
and circulate the- written summary to all other party
representatives within five (5) working days . If the party
representatives fail to resolve the dispute within twenty (20)
working days, the parties agree that any party, except EPA, shall
next seek resolution of the dispute by calling for a formal
mediation, to be conducted by Senior Administrative Law Judge
Fred G. Morrison. Notwithstanding any other provision in
Paragraphs 39 & 40 of this Agreement, if a dispute arises
regarding this Agreement, the parties agree that any party may
make any administrative or judicial filing necessary to avoid the
running of any limitations period for bringing such
administrative or judicial action.
41 . All the parties agree that should a dispute arise
regarding any actions EPA is to undertake as part of this
Settlement Agreement, the parties shall attempt to resolve the
dispute informally. All time frames for informally resolving
disputes may be lengthened by mutual consent . Each of the
parties shall designate a representative for informal dispute
resolution . These representatives may be the same
representatives designated under paragraph 40, above. A paccy
representative claiming that a dispute has arisen shall summarize
( the dispute in writing, and circulate the written summary to all

other party. representatives within five (5) working days . The
party representatives will endeavor to resolve the dispute
P within
twenty (20) working days . For any such dispute, EPA' s party
representative will initially be designated by the Region 4
Administrator. If the parties are unable to resolve the dispute
With the Region 4 representative, any party may request that EPA
Headquarters designate a representative for that particular
dispute, and the parties, working with the EPA representative,
will have an additional ten (10) working days to resolve the
dispute .
VIII. RESERVATION OF RIGHTS
42 • The covenants and agreements set forth in this
Settlement Agreement do not pertain to any matters other than
those expressly specified in the Settlement Agreement . All
{ parties reserve, and this Settlement Agreement is without
Prejudice to, all rights any party to this Agreement may have
against any other party to this Agreement with respect to all
other matters .
IX. EFFECTIVE DATE
43 . Each party shall execute the signature page of this
Settlement Agreement and return the executed signature page to
EPA. The Settlement Agreement shall become effective upon EPA's
receipt of executed signature pages from all of the parties .
Upon receipt of all executed signature pages, EPA shall
immediately issue a notice ' trcr to all parties st?ting the date
on which the Settlement Agreement became effective. The parties
all acknowledge that because this Settlement Agreement is

intended to be the basis for resolution of the North Carolina
contested case proceeding, State o Ten a
Carolina nPn of Fnv; o7Lm n u ,l
h d N
Pr
alp, No. EHR 0041, Tennessee was required to have the Settlement
Agreement approved through its statutory compromise and
settlement procedure before it executed the Agreement. Under
Tenn. Code Ann. § 20-3-103, the settlement of any litigation to
which Tennessee is a party must be approved by the Attorney
General and Reporter, the Comptroller of the Treasury, and the
Governor. North Carolina was required to have the Settlement
Agreement approved by the Department of Environment and Natural
Resources as the agency responsible for issuing the permit, and
by the NPDES Committee, as the agency responsible for issuing the
variance,
X• AUTHORIZED SIGNATURES
44 . Each of the undersigned representatives of the parties
certifies that he or she is fully authorized by the party he or
she represents to enter into the terms and conditions of this
Settlement Agreement and to legally bind such party to this
Agreement ,
IT IS SO AGREED:
UNITED STATES ENVIRONMENTAL%PROTECTION AGENCY
./
BY "- Date : ��/ �A /q -7
John ,H.. Hankinson, Jr:
Regional Administrator

STATE OFF NORTH CAROLINA
p 4 BY: "/ ^^`tic C . Date: IZ�
Wayne McDevitt 3e51
Secretary, DENR
By. .. B C"d Date: 17-13d -7
Daniel V. Besse
Chairman, NPDES Commit ee
[Co orming to original si. dated 12/22/971
S T OF T
By. lei ��-
ustin P. Wilson Date:
eputy Governor for Policy
COCK C UNPY, TE S
By: Date: f, l� 7
arold E. ates
County Commissioner
CITY OF ftWPORT, NNESSEE
ames Rob nson Date:
Mayor
TENNESSEE ENV, ONMENTAL COUNCIL
John Noel \ Date : /=•�
Pig n iye-r-Coordinator
AME CANOE SO IATION
By
s
David E. Date:
n n
Director fi6onservation
and Publis_,policy
CHAMPION I ATE AL
,L PORAT N
By:
Richa Date:
i�rio,
Senior Vi Preside t,
Envir°nm nt, Health & Safety
�� [Conforming to original signature dated 12/19/971

SENT BY:ROBERT & STEVENS. F.A. ; 3-12-08 ; 3:33PM ; KOISLICTS & MhVIINS-> 'IKAINING;g it 5
Roberts & Stevens, P.A.
ATTORRTYSAT LAW
BB&T Building
One Pack Square(28801)
Post Offire Bnr 7647
Asheville,North Carolina 288w
Telephone[phone]
.7-clecopier(704)258-6999
FAX TRANSMISSION COVER SHEET
Date: N4ttrch 12, 1998
To; Ben 1311m; Derric Brown; Bob Williams; Tom Siegrist; Dick Diforio; Ed Clem;Jeff
McNcaley;and Al Joyce ,/
40
Fax: "V358-2941; 646•6892;203/358�7407;614/227-4522; 646-2929
Rc: Dismissal in Contusred Caseand New DENRAssistant Secretary
Scnden William Clarke
Comments: Attached is a sipped espy of the Order of Dismissal which wsa nigted on February 20,
1999.
YOU SHOULD RECEIVE,_pAGE(S), INCLUDING'1'H1S COVER SHEET. IF YOU DO NOT
KECEIV'h ALL PACES,PLEASE CALL TANYA BALLENGER
Notice.: The inforumban contained in this fmin ile massage Is atlorney privileged and nuiritmtinl inforrnaflon huendcd only for the
use of the individual or entity named nbove. If the reads of this rnesiage is trot the intmdcd rcciplent,you are huchy nnt;nrd that
any dose nination,distribution or copy of this communication is stricdy prohibited. If you have r&v3vcd this conunwtication in error,
;lease Immedtnrely notify us by telephone and return the original mcssago to us at the shove address via the U.S.Postal Service.
ttX.S:a6900.1
C

SENT BY:ROBERT & STEVENS. P..a. ; 3-12-08 3;33PNI ROBERTS & STEVENS- TRAINING;# 2/ 5
r"IlEO
r IN TIE OFFICE OF ADMINIS"IMTIVE HEARINGS
1 WAKRk0%Tl2 NQIR:!IIMAROLR4A
99 EHR 0041
STATE OF TRNN'ESSEE, )
TENNESSEE DEPARTML.NT OF )
ENVIRONMENT AND CONSERM-10N,
THINNESSHE WILDLIFE RESOURCES )
COMMISSION, and TENNESSEE )
WILDLIFE RESOURCES AGENCY, )
Petitioners, )
)
and ) ORbER
CITY OF NEWPORT, TENNESSEE. }
COCKE COUNTY, TENNFS4RF; }
AMEII.ICAN CANOE ASSOCIATION, and )
TENNESSEE ENVIRONMENTAL }
COUNCIL, )
Intervenor-Petitiouars,
)
V. }
)
NORTH CAROLINA DEPAIZTIvMM )
OF ENVIRONMENT AND )
NATURAL RESOURCES,DIVISION OF )
WAIF( QUALITY,NORTH )
CAROLINA ENVIRONMENTAL. )
MANAGEMBNT COMNIS5ION, )
NPAES COMMITTEE, )
}
Respondents, )
and '
CHAMPION UI JTRNATTONAL )
CORPORATION, )
i�rten'enor-Respondent. )

SPENT BT:ROBERT & STEVENS. P.A. ; 3-12-08 ; 3:34PAI ROBERTS & STEVENS- TRAINING;# 3/ 5
TITIS MATTER COh11NG ONTO BE HEARD before the undersigned Administrative Law
( Judge and it appearing to the Court as follows:
1. The parties have amicably resolved all matters at issue in this contested cizc and have
entered into a Settlement Agreement which has been filed in this matter, The Settlement Agreement
is hereby incorporated in this Ozder by reference,
2. The parties have agreed that the undersigned Administrative Law Judge is a suitable
,person to serve as mediator in any disputes which clay arise folder the Settlemenc AS 80me11t.
J. The parties, by their signatures below, have agreed that this contested case should
now be dismissed.
IT IS THEREFORE ORDERED;
1. This contested case is brreby dismissed with prejudice.
2. Thu uadmignad shall serve as mediator in any disputes which may arise under the
Settlement Agreement,
This the. day of 1998
FRED 0.MORRISON,Jdt.
Administrative Law Judge
2

SENT 1iYMBEff & SICVhMS, r.A. i U-12-Ud i ;J;04rrd i rVf5r CIS & wtyt J HERIMINUiF 4/ A
CONSBNT:
MICHAEL F. EASLE'Y JOHN KNOX WALKUP
Attorney Guncra� � Attome and Reporter
autakleY My cr
SeniorAeputy General Aeput AttomCy General
N.C. Department of Justice State Tennessee
P.O.Box 629 Office of the Attorney General
Raleigh NC 27602-0629 433 Fifth Avenue North
[phone] Nashville TN 37243-0485
[phone]
J. CONVNER&ASSOCIArro
Attorneys for State of Tennessee
James L. ConECIIIMA� irI2
0
311 East Main street
Durham NC 27701
rHAMPION INTERNATIONAL
CORPORATION
By' Benjaoxin S. Bilus
Senior Ai%wciatc Counstl
Charttpiort International Corporation
One Champion Plaza
ord C i (1fi971
ROB S AND S'TEVENS PURTP-.It.,WRIGHT,MODS &AILTHUR
Atlort a for Champion Attorneys for Champions
tnternationfil C�[�K� Inte 'Deal Co�pornti
By: williwn Clafke, > sq By;, ey
F_U. Box 7647 41 o trw.t
Asheville NO 28802 ast ain Street
[phone] Columbus 01143215
3

SENT BY;ROBERT & STEVENS, P.A, ; 3-12-38 ; 3:35PN ; ROBERTS & S'I'hVfN5� I1tA rvIY[i s 5/ ti
DUNIN& TUCKER ASSOCIATES
Atto p fu:Cocke County, Tennessee
4 /
By: Clydr iWDAt'
n
317 East Main Street
Newport TN 37821
CAMPBEL.L& HOOPER
Aftrnrys for City ofNowport,Tennessee
By: Roy 4 Campbell,Jr_
335 East Main Street
Newport TN 37821
AJNTERICAN CANOE ASSOCIATION, INC,
By: David Bookbinder
General Counsel
7432 Alban Station Blvd.
Suitt B-226
13y. k,aakJo> Rzq
Attorney for Ameilo= Canoe Association, JnC,
P.O.Box 3793
/Chapel Hill NC 27515
TgNNI;SSEE 4NVIRONMENTAL COUNCIL
By: Crazy A.Davie,F..sq
Attomey for Tennessee I;nviAwuncntal Council
P.O. Box 2346
Knoxvtlle'I'N 27901.2346
Cam.•�7�..
By: John D.Runkle, ER.
Attonley for Tennessee Frvironmental Council
P.O.13ox 3793
Chapel Bill NC 27515
IbLI1�U1JSr0199111AI
4
l`
1
i

C
LY TimUNIVERSITYOTENNESSEE
Institute of Agriculture
Department of Forestry,Wildlife and Fisheries
274 Ellington Plant Sciences Building
Knoxville„TN 37996-4563
Phone.[phone]
Fax:[phone]
E-mailt httpY/twf.ag.utkedu,
2005 Study Plan- Canton Mill Thermal Assessment
NPDES Permit No.NC 0000272
Principal Investigator:J.Larry Wilson,PhD,University of Tennessee,Knoxville
Blue Ridge Paper Products,Inc(BRPP) is required to submit a thermal variance report under Section 316a of
the Clean Water Act as part of the May 2006 application to renew the NPDES permit for their Canton Mill
on the Pigeon River in the French Broad River Basin of North Carolina. Blue Ridge Paper has selected a
team led by the Department of Forestry,Wildlife and Fisheries at University of Tennessee,Knoxville(UTIq
to complete fieldwork and prepare the 316a Thermal Variance Report.
The following Study Plan (with a brief summary of each task) is provided to fulfill various monitoring
requirements in the NPDES permit for the 316(a) demonstration. Under the permit,this study plan must be
submitted to the Division of Water Quality (DWQ) of the North Carolina Department of Environment and
Natural Resources (NC DENR)by March 1,2005.
The 2005 study will include sampling locations examined during previous thermal variance studies in 1995
and 2000. EA Engineering,Science and Technology conducted the 1995 and 2000 studies under contract to
Blue Ridge Paper. For 2005, the UTK team will include other work in the Pigeon River involving non-game
species reintroduction and related watershed assessment studies.This approach is intended to provide a
multi-seasonal assessment of biological conditions in the Pigeon River to supplement intensive sampling
during the summer period of potential thermal stress.The additional data are being collected as part of the
Pigeon River Restoration Project,which began in 2001 in the Tennessee portion of the river and was
expanded into North Carolina portions of the river in 2004.
The Pigeon River has been impacted by human activities since the late 19th century. Since the Canton Mill
modernization project in the early 1990s, there has been substantial improvement in water quality in the river
downstream from the mill.The 2005 study will assess the appropriate biological and physical parameters
necessary to prepare the thermal assessment report.The effects,if any,of the September 2004 historic floods
on aquatic habitat and species restoration efforts will also be addressed.

2005 Study Plan- Canton Mill Thermal Assessment
Page 2
( -- Task 1- Conduct Biological Surveys to Support a Continuation of the Mill's Thermal Variance
During July and August 2005, UTK will survey fish and macro-invertebrates at the following 13 stations on
the Pigeon River in North Carolina(11 stations) and Tennessee (2 stations).River mile refers to distance
upstream of the confluence of the Pigeon River with the French Broad River in Tennessee.
River Mile Location
64.5 Upstream of mill
63 Fiberville
61 D.O. augmentation station
59 Upstream of Clyde
55.5 Downstream of Clyde
54.5 Downstream of Waynesville WWTP
52.3 Old Rt 209
48.2 Ferguson Bridge
42.6 New Hepco Bridge
Trib Richland Creek
Trib Jonathan Creek
24.7 Waterville(IN)
19.3 Groundhog Creek-Bluffton (IN)
These data will be augmented (where applicable)with spring and fall fish and invertebrate data compiled from
Pigeon River samples that have been,and will continue to be,collected as part of an on-going Pigeon River
Restoration Project since 2001. Collection procedures to be used at each location will follow methodologies
established and presently used by TVA,TWRA,TDEC,and EPA;specific protocols include TVA 2004(fish
/ sampling),TVA 2002 (benthic sampling),and Barbour et al. 1999 (benthic sampling). Collection techniques
will also be consistent with NCDENR sampling guidelines (NCDENR 2001,2003) and are comparable to
those used during previous thermal assessment data collections (EA-EST,Inc. 1995,2000,2001a,2001b).
The 2005 study will be restricted to fish,macro-invertebrates,and habitat evaluation and will include
measurement of routinely-collected field physical/chemical parameters (i.e., temperature,DO, conductivity,
and water transparency [Secch depth (visual) and/or turbidity levels (meter)]. Field data will be summarized
and used to assess the biological communities at selected sites and may include various comparative
descriptors such as species richness and composition,indicator species, trophic function,abundance and
condition,and reproductive function.These categories, and specifically the individual parameters (metrics),
are often used to determine index of biotic integrity(IBI) scores;however, care must be taken to ensure the
protocols used are designed for the specific stream/river sampled.
Task 2- Representative Important Species
Based on collections from Task 1,representative important species (RIS)will be identified to represent a
range of thermal tolerances, trophic levels, and recreational importance. It is important to note that as a
human-activity impacted river,not all species present in reference watersheds or historically found in the
Pigeon River may be collected during the 2005 thermal variance study.The RIS determination will be based
on life history characteristics of native fish presently inhabiting the Pigeon River and from historically
documented records.Native species of recreational importance include smallmouth bass,largemouth bass,
rock bass, and channel catfish.Targeted trophic level groupings (and example species) include herbivores
(stoneroller,),insectivores (river chub,mottled sculpin,bluegill,northern hogsucker,black redhorse), and
piscivores (smallmouth and largemouth bass,rock bass,channel catfish)(Barbour et al. 1999).Based on the
EPA protocols,most of the above species are listed as `tolerant'to `intermediate tolerance' (depending on
t region of the country) based on thermal variations while a few(northern hogsucker,black redhorse,mottled
sculpin,river chub) are generally considered thermally sensitive,i.e., `intolerant'.

2005 Study Plan- Canton Mill Thermal Assessment
Page 3
Task 3 -Update the Previously Developed Temperature Model and Low Flow Statistics
A temperature model has previously been developed for the discharge of the Blue Ridge Paper Products
(BRPP) Canton NO to the Pigeon River(EA Engr 2001a). Model calibration was based upon data collected
by mill personnel for the 6-year period 1994 to 1999.Additional verification of the diel temperature range was
provided by the deployment of continuously recording thermographs at Pigeon River locations during July
2000.As part of the year 2005 316(a)Temperature Variance Study, the temperature model will be further
verified by making comparisons between model predictions and more recent temperature data collected by
mill personnel and deployed thermographs.
Pigeon River temperature data collected by mill personnel since 1999 include daily values at Canton,
Fiberville,and Clyde,and weekly values at Hepco.Additional temperature data will be obtained by six
thermographs which will be deployed for a 4-6-week period during July and August 2005.The thermographs
will be deployed during the fast biological survey and retrieved during the second survey.They will be
deployed in the river at six specific locations: Canton (upstream of mill discharge),mill discharge, Fiberville,
Clyde,Richland Creek,and Crabtree Creek.
The model calculates at an hourly time step using hourly meteorological data for surface heat exchange.
Hourly air temperature,wind speed,and solar radiation data are available from the mill.The surface heat
exchange calculation also requires relative humidity,which will be obtained from the NOAA station at
Asheville.The model is executed using the reported discharge temperature and flow data at the mill and using
the USGS river flow data at Canton and Hepco.
The Pigeon River temperature model will be executed for the duration of the summer 2005 thermograph
deployment period, and for an extended period corresponding to the collection of river data by mill
personnel.A standard error of estimate between predicted and observed temperatures will be calculated and
compared to previous values determined during the original model calibration/verification.The model
calibration will be adjusted if deemed appropriate.
The re-verified Pigeon River temperature model will be used in support of the thermal variance study.Year-
long model run outputs can be summarized as daily/weekly mean temperatures or other intervals of interest
as a function of season.Worst-case mill discharge or receiving water conditions can also be presented.
Low flow frequency statistics including the 30Q2 and 7Q10 will be updated as part of the study.The USGS
Canton and Hepco station data will be obtained for the historical period of record.The frequency statistics
will be generated using a log Pearson program that has previously been verified against flow statistics
generated by the USGS.The program allows multiple daily averaging periods and yearly return intervals to be
used. Comparisons can also be made between the historical period of record and more recent periods to
demonstrate changes in the runoff characteristics of the watershed.
Task 4-Prepare a 316(a) Demonstration Report
Based on the data collected during Task 1, the results of the temperature model (Task 3),an updated review
of the thermal tolerance literature,and any other applicable data (e.g.,NC DENR data,Progress Energy
data), UTK will prepare an updated 316(a) Demonstration Report(i.e., "Balanced Indigenous"Report).This
report will address the central question posed by 5316(a) of the Clean Water Act,i.e.,does the thermal
discharge in question allow for the maintenance or establishment of a balanced indigenous population(BIP)
(community) of aquatic organisms?
4

2005 Study Plan- Canton Mill Thermal Assessment
Page 4
r A BIP (BIC) is a biotic community typically characterized by diversity, the capacity to sustain itself through
cyclic seasonal changes,presence of necessary food chain species, and non-denomination of pollution-
tolerant species (Coutant 2000). The term"balanced"derives from long-standing knowledge that most
natural aquatic communities are composed of many species of organisms without an overwhelming number
of any one of them. "Indigenous"generally refers to the presence of species that would be normally found at
the site,although it is not restricted to only truly native species,and managed,introduced species are often
included. The UTK team will use the previously prepared successful demonstration (EA-EST 2001b) as a
template for the 316a Thermal Variance Report due in May 2006.
References
Barbour,M.T.,J. Gerritsen,B.D. Snyder,and J.B. Stribling. 1999. Rapid bio-assessment protocols for use in
streams and wadeable rivers:Periphyton,benthic macro-invertebrates, and fish. 2nd Edition. EPA
841-B-99-002.U.S. Environmental Protection Agency,Office of Water,Washington,D.C.
Courant, C.C. 2000. Summary of 316(a).Precedents.Mimeo compiled from numerous sources. 4 pp.
EA Engineering Science and Technology,Inc. 1995.A Study of the Aquatic Resources and Water Quality of
the Pigeon River.Prepared for Blue Ridge Paper Products,Inc. EA Engineering Science and
Technology,Inc. Deerfield,IL.
EA Engineering Science and Technology,Inc. 2000. A Study of the Aquatic Resources of the Pigeon River
during 2000. Prepared for Blue Ridge Paper Products,Inc. EA Engineering Science and
Technology,Inc.Deerfield,IL.
EA Engineering Science and Technology,Inc. 2001a. Pigeon River Temperature Model. Prepared for Blue
Ridge Paper Products,Inc. EA Engineering Science and Technology,Inc. Deerfield,IL.
EA Engineering Science and Technology,Inc. 2001b. Canton Mill Balanced and Indigenous Species Study
for the Pigeon River. Prepared for Blue Ridge Paper Products,Inc. EA Engineering Science and
Technology,Inc.Deerfield,IL.
North Carolina Department of Environment and Natural Resources. 2001. Standard Operating Procedures -
Stream Fish Community Assessment&Fish Tissue. Division of Water Quality,Environmental
Services Branch,Raleigh,NC.
North Carolina Department of Environment and Natural Resources. 2003. Standard Operating Procedures
for Benthic Macro-invertebrates.Division of Water Quality,Environmental Services Branch,Raleigh,
NC.
Tennessee Valley Authority.2004. IBI designations for fish species of the Tennessee Valley.Mimeo. 6 pp.
Tennessee Valley Authority. 2002.Benthic macro-invertebrate assessment:Level 1. Mimeo. 5 pp.
Tennessee Valley Authority. 2004. Protocol for conducting an index of biotic integrity biological assessment.
15 pp.

2005 — 2006 Scope of Work
University of Tennessee
Non-game Species Reintroduction Project Support
Balanced and Indigenous Species Study/316a Thermal Variance Renewal
Reference UTK Proposals dated 12/13/04
Dr. Larry Wilson,Principal Investigator
Paul Dickens and Glenn Rogers, Blue Ridge Paper Products oversight
Greg Seegert,EA Engr-technical advisor to Blue Ridge for project
Project Milestones
Work Plan 3/1/05 - complete
Biological survey site tour with EA Engr for continuity with previous studies 4/19-20/05 -complete
Train field crews and conduct biological surveys using study plan methods as part of non-game species
reintroduction work—May&June 2005
Blue Ridge/UTK fieldwork progress meeting June 2005
I • review schedule and final preparations for thermal assessment intensive sampling in July and
August
Intensive sampling-— 13 weeks starting 7/13/05
• benthic and fish crews to work each site at same time
Blue Ridge/UTK field work progress meeting late July/early August 2005
• review field work preliminary results and make final preparations for annual dioxin fish tissue
sampling
• non-game species work plan for 2006 support renewal(budget planning)
Annual dioxin fish tissue sam line- first half of August 2005 before UTK fall registration
Blue Ridge/UTK data review meeting October 2005
• review field data summaries and confirm that biological survey and thermal assessment data
(including dioxin fish tissue results) are ready for preparation of the biological assessment report,
thermal model report and dioxin fish tissue report
• determine schedule for project meetings for preparation,review and production of project reports

Milestones - Balanced and Indigenous Species Study/316a Thermal Variance Renewal
Page 2
Reports
November 2005
• Draft biological assessment study
• Draft thermal model
• Draft dioxin fish tissue report
December 2005
• Final biological assessment study
• Final thermal model
• Final dioxin fish tissue report
January 2006
• Draft 316a Thermal Variance Assessment/Demonstration
• Annual dioxin fish tissue sampling report is due to NC DENR
February 2006
• Final 316A Thermal Variance Assessment/Demonstration
April 2006
• Application for NPDES permit renewal including Thermal Variance Assessment is due to NC
DENR

Team List: Pigeon River Permitting Process Studies
UTK Proposal: 12/O1/04
Project Leader:
Dr.Larry Wilson,Professor,Fisheries/Aquatic Biology
Forestry,Wildlife and Fisheries -University of Tennessee,Knoxville (UTIq
Data collection/analysis crew:
Joyce Coombs-Research Specialist II
Melinda Wilson-Ph.D. candidate,Macro-invertebrate monitoring and assessment
Brac Salyers-M.S. candidate,Tangerine darter propagation
Michael Gaugler-Ph.D. candidate,Habitat evaluation/assessment
Other UTK Personnel:
Dr.John Tyner-Assistant.Professor,Water Resources (thermal modeling, oxygen sag)
Biosystems Engineering and Environmental Science
Dr. Ted Henry-Adjunct Assistant Professor,Environmental toxicology(tissue analysis/tox screen)
Center for Environmental Biotechnology/Forestry,Wildlife and Fisheries
Other Agency Personnel:
Dr.Ray Albright-Adjunct Professor,Water resource inventory/monitoring(oxygen model)
National Park Service(Adjunct with Forestry,Wildlife and Fisheries)
Project Collaborators:
Dr. Chuck Coutant-Distinguished Research Ecologist(316a thermal studies)
Environmental Sciences Division,ORNL
Dr. David Etnier-Emeritus Professor,fish/invertebrate taxonomy and distribution (aquatic
resources inventory)
Ecology and Evolutionary Biology(retired)
Included are brief CVs from team personnel along with several selected examples of work.The academic
folks have provided publication lists;if you need copies of selected pubs,I'm sure we can get them for you.
Note that some item(s) in Dr. Coutant's packet are labeled `Privileged and Confidential' and should be
handled accordingly.

Pigeon River Restoration Project Page 1 of 3
University Links AZ /WebMail / Dew Enter search select type of search �;=
Index Directory
LI-
Pigeon River Restoration Project (PRRP)
Front Page
Pigeon River Maps non-game species reintroductions
Cocke County, TN
Haywood County, NC
PRRP Projects
Fish Reintroduction
Tangerine Darter Propa ag tion
Benthic Invertebrate Survey
Video Resources
PRRP Partners
UTK Fisheries
TDEC-WPC
Blue Ridge Paper
CFI. Inc.
TVA
TWRA
US Fish &Wildlife Service
USGS
NCWRC
NCDWO
Haywood Waterways
PRRP Supporters
Pigeon River Fund
Haywood Comm. College
W. Carolina University
UNC-Asheville
Contact Information
Pigeon River (North Carolina &Tennessee)
http://web.utk.edu/—mjwilson/index.php 5/18/2005

Pigeon River Restoration Project Page 2 of 3
Pigeon River Topography
The headwaters of the Pigeon River are located at Sam Knob on Black Mountain, at an elevation of
approximately 6130 feet. Sam Knob is 30 miles southwest of Asheville, North Carolina. The river flows
from Sam Knob north to Canton, North Carolina. Blue Ridge Paper Products, Inc, is located on the river
in Canton. The Pigeon River flows through the papermill at Canton and then along Interstate 40 for
approximately 25 river miles to Waterville and the Progress Energy Hydroelectric Dam.
From Canton to Waterville, the elevation changes from 2580 to 2258 feet. A small bypass channel
curves around the dam and runs 12.5 river miles before merging with the water being released from the
dam aquaducts at the Tennessee State Line. The Pigeon River then flows 4.5 river miles to Hartford,
Tennessee. The elevation at Hartford is about 1260 feet. This 160 foot drop in river elevation produces
class III and IV rapids.
Progress Energy and the 12 Hartford white-water rafting companies work together to plan recreational
water releases from the Waterville Dam for rafting. After passing through Hartford, the Pigeon flows
through Denton (1800 ft) and Newport (1040 ft), Tennessee. The Pigeon empties into the French Broad
River at an elevation of about 1000 feet.Due to these elevational changes, the Pigeon River is divided
into two regions or ecoregions; a high gradient stream from Sam Knob to around Denton, Tennessee and
a low gradient stream from Newport, Tennessee to the French Broad River.
A Brief History of the Pigeon River
A papermill was established in Canton, North Carolina on the Pigeon River in the early 1900's. The mill
has been operated in that locality for about 100 years. After 1983, Champion Paper began to upgrade the
papermill to reduce emissions going into the river. Blue Ridge Paper Products, Inc. bought out
Champion and completed the upgrades in equipment and the reductions in emissions biased on EPA
criteria. Blue Ridge Paper is an employee-owned and operated facility and has spent millions of dollars
to upgrade the papermill. This corporation continues researching methods to increase efficiency and
reduce any adverse impacts on the Pigeon River.
UTK Fisheries began working with Blue Ridge Paper in 2001. A plan was launched to reintroduce
native non-game fish species into the Pigeon near Newport, Tennessee. The Tennessee Department of
Environment and Conservation (TDEC),Water Pollution Control Division provided advice and
assistance in collecting and relocating fish into the Pigeon River. In early 2004, the fish reintroduction
project was expanded into North Carolina with the aid of the North Carolina Wildlife Resources
Commission.
Native Fish Reintroductions
After 1993, the Pigeon River water quality and water clarity improved. Larger, native fish species were
then able to recolonize the Pigeon River from its tributaries. The river was surveyed yearly for fish
species by TVA, TWRA and TDEC-WPC. These organizations realized that several of the smaller
http://web.utk.edu/—mjwilson/index.php 5/18/2005

Pigeon River Restoration Project Page 3 of 3
native fish species had not returned to the Pigeon. In 2001, in conjunction with UTK Fisheries, US Fish
& Wildlife Service, USGS and Blue Ridge Paper, these Tennessee state agencies put together a list of
native, non-game fish species missing from the Pigeon River.
The first species of fish to be collected and relocated were the Bluebreast Darter, Blueside Darter and
Guilt Darter. And in 2002, additional species were added; Stargazing Minnow and Smoky Madtom
(small catfish). In 2003, the Stripetail Darter and the non-parasitic American Brook Lamprey and
Mountain Brook Lamprey were also collected for relocation into the Pigeon River.
In 2004, with financial support from Blue Ridge Paper Products, the Pigeon River Restoration Project
was expanded to include the Upper Pigeon River in North Carolina. The project team met in March
2004 and invited the North Carolina Wildlife Resources Commission to participate. An additional list of
missing fish from North Carolina's half of the Pigeon River was assembled. Efforts to relocate Saffron
Shiners, Mirror Shiners, Silver Shiners and Telescope Shiners began soon after this meeting. UTK
Fisheries and TDEC-WPC headed up the collection efforts. NCWRC assisted in the collections and
relocations of these shiners to the Pigeon River a few miles downstream from the papermill.
Native Freshwater Mussel & Snail Reintroduction
Native freshwater snails (1996) and mussels (2000) were reintroduced into the Pigeon River near
Newport, Tennessee. From 2000-2004, about 20,000 individuals from 3 snail genera were released;Io,
Pleurocera, Leptoxis. The latter two genera are reproducing and spreading downstream in the Pigeon.
Also during the past few years, around 200 individuals from 9 different mussel species have been
reintroduced. The common names for these 9 species are the Elktoe,Threeridge, Purple Pimpleback,
Spike, Wavyrayed Lampmussel,Plain Pocketbook, Kidneyshell, Pimpleback and Creeper. The life cycle
of the mussel requires a host fish species to carry the free-living mussel larvae. Studies need to be
conducted to determine if mussel reproduction is occuring and whether or not the Gilt Darter or any
darter present in the Pigeon is a successful host species for any or all of the mussel species.
©2004 University of Tennessee, Dept. of Forestry, Wildlife&Fisheries
http://web.utk.edu/—mjwilson/index.php 5/18/2005

UTK Proposal: Pigeon River Recovery Project (extension)
05/16/05 - 05/15/08
Proposed Plan of Work:
Re-introductions of the blueside darter, stripetail darter, stargazing minnow, mountain madtom and
the lampreys (ABL,MBL) will continue in the Tennessee reach (2005-2008).The bluebreast darter
will be re-evaluated in 2005 because no collections have occurred in the past two years from our
only source, the Nolichucky River, due to continuous high flows that made collections impossible.
In 2005,we will also look into possible new candidates for re-introduction. We will continue the re-
introduction of the mitror, saffron, silver and telescope shiners in the North Carolina reach (2005-
2008). Re-introduction of a species will continue until it is determined that a population has been
established. New possible candidates for North Carolina include the gilt darter, a successful re-
introduction in the TN reach, and the fantail darter. A habitat assessment (2005/2006) will need to
be conducted to determine the availability and location of fantail habitat (slab rock).
Habitat assessment will be conducted above Canton,NC, to assist in locating similar suitable habitat
for targeted species to be relocated below the mill.A re-evaluation of Pigeon River habitat in both
NC and TN reaches will be necessary as a result of changes in stream morphology due to flooding
from two hurricanes. This will be started as soon as feasible in 2005. The potential for the use of
geo-referenced underwater video mapping is being assessed, and if feasible,will provide a substantial
upgrade in habitat assessment (2006-2008).This could also be used to provide a benchmark for
riverine habitat in the Pigeon and possibly its major tributaries.
The attempt to propagate the tangerine darter at Conservation Fisheries Inc. will continue (2005-
2008) with a possible spawn in the spring of 2005 but a more likely spawn in 2006, due to the age of
the brood fish (juveniles when collected in fall of 2004). Offspring would be held for grow-out for at
least one year or longer.Two other species are being considered for possible propagation and future
release into the Pigeon as well: the ashy darter, and the blotchside logperch.
Macro-invertebrate sampling will continue through 2008. Historical analysis will be completed in the
spring/fall of 2006.
Mollusk re-introductions will continue (2005-2008).An effort will be made to re-evaluate mussel
survival and consider new re-introduction sites in Tennessee and North Carolina.
Monitoring for re-introduced species will continue (2005-2008) at every low water opportunity to
locate species and to make habitat observations. Seine collecting will begin in late winter and snorkel
surveys will begin when water temperatures rise to >50 F.Annual IBI's will be conducted as
scheduled. In the Spring of 2005, a snorkel survey for the blueside darter will be conducted from the
re-introduction site (PRM5.5) to the mouth of the Pigeon to locate fish and to evaluate habitat.
Development of a Pigeon River Recovery Project website will continue in 2005. Links to project
contributors will be established as well as to related organizations such as Southern Appalachian
Man and the Biosphere and the Southeast Watershed Forum, Inc.
A timeline for the proposed activities is attached.

Project Timeline
20051 20061 20071 2008
i }
Monitoring
l
Fish Re-introductions
� I
Mollusk Re-introductions ,
I
r +
Habitat
Assessment
TN &NC Reaches
Habitat
Assessment -
Above bove Canton,NC
i
Fantail Habitat Assessment
t
(Underwater Video Mapping of River Substrate '
angerine Propagation
Ashy Darter Propagation
3.
Macroinvertebrate Sampling,

UTK Proposal: Pigeon River Recovery Project (extension)
05/16/05 - 05/15/08
Budget:
Blue Ridge Paper Products:
The proposed Pigeon River Recovery Project activities are scheduled for 36 months at a
total cost of$252,000. If approved as an extension of the existing project, the monthly
amount would be $6500 for the period 05/16/05 through 11/15/06, and $7500 per month
for the period 12/16/06 through 05/15/08. The funds would provide salary/benefits for
the Project Coordinator, Research Specialist II Q. Coombs), as well as associated project
costs, such as collection equipment maintenance and replacement, student wages, supplies,
travel, report preparation/presentations, indirect costs, etc.
UTI{ and Other Agency/Organization Support:
Dr. Larry Wilson (UTIq will continue to serve as Project Leader. The Department of
Forestry, Wildlife and Fisheries also provides support for the following personnel: Melinda
Wilson - a Ph.D. student who is doing the Pigeon River invertebrate assessment/recovery
study, Michael Gaugler - a Ph.D student who will be working with Pigeon River habitat
evaluation, and Brac Salyers - a M.S. student who is working with the tangerine darter
propagation. The UTK team is working with Dr. Paul Ayers and his students (Biosystems
Engineering Technology) to evaluate underwater video habitat mapping techniques and its
applicability to Pigeon River studies. The UTK PRRP team will also be helping the
Haywood Waterways Association in spring and summer 2005 with Pigeon River
environmental educational activities, including the `Kids in the Creek" program.
The Tennessee Wildlife Resources Agency and US Fish and Wildlife Service have
contributed funds toward the tangerine darter propagation. Conservation Fisheries provides
the culture expertise and the use of facilities (along with UTIq for artificial propagation
activities. The Tennessee Department of Environment and Conservation has contributed
substantially to the collection and relocation of targeted re-introduced fish species while the
USGS-Water Resources Division has contributed in a similar manner with the relocation of
snail and mussel species.

Joyce Coombs "Cooper,Chris"<[e-mail]>, "[e-mail]"
•' <[e-mail]> <[e-mail]>, "[e-mail]"
04/29/2005 09:16 AM <[e-mail]>,"Saylor,Charles F."
<[e-mail]>, "Scott, Edwin M."<[e-mail]>,
"Shute,Peggy W."<[e-mail]>,
"[e-mail]"<[e-mail]>, Bo Baxter
<[e-mail]>, Bob Williams
<[e-mail]>, Bryn Tracy
<[e-mail]>, Carl Williams
<[e-mail]>,Dave McKinney
<[e-mail]>, David Yow
<[e-mail]>,Derric Brown
<[e-mail]>, dipnet<[e-mail]>,
Eric Romaniszn<[e-mail]>, Jeff Simmons
<[e-mail]>,John Fridell
<[e-mail]>,Jonathon Burr
<[e-mail]>,Keith Haynes
<[e-mail]>, Larry Everett
To <[e-mail]>, Lorie Stroup
<[e-mail]>, Mark Campen
<[e-mail]>, Mark Fagg<[e-mail]>,
Matt Kulp<[e-mail]>, Mike Gaugler
<[e-mail]>,mjwilson<[e-mail]>,Paul
Dickens<[e-mail]>, Pete Wyatt
<[e-mail]>,Powell Wheeler
<[e-mail]>, Richard Kirk
<[e-mail]>, Rick Bivens
<[e-mail]>,Ron Moser
<[e-mail]>,Sarah McRae
<[e-mail]>,Scott Van Horn
<[e-mail]>,Sheryl Bryan
<[e-mail]>,Stephanie Chance
<[e-mail]>,Steve Fraley
<[e-mail]>,Steven A Ahlstedt
<[e-mail]>,Tom Martin<[e-mail]>,
wayne h schacher<[e-mail]>,Wayne
Starnes<[e-mail]>
cc
bcc
Subject New Re-intro Numbers and......
Pigeon River Folks:
Not only do we have new collection and release data but we have great news -
Conservation Fisheries, Inc. just notified us that the Tangerine Darters have
spawned! ! !
Thanks again to all our volunteers and supporters!
Joyce
Joyce A. Coombs
Research Specialist II
Dept. of Forestry, Wildlife & Fisheries
University of Tennessee, Knoxville
[phone]
R
RE-INTROS 4.26.05.xis

RE-INTR^^' CED SPECIES: NO VIE Tags'
collection F +', -4 Mum ow Chub Madlom_Lamprey e$Lmer„f„-,,,:�,. „> +"r, }ti¢ +, VIE. Collect, relCase - Y" je 9_ __ : 1 „cilor
--.. -r -- -.. ,m ,P
dates - .Bluetircast.'Blueside;eStnpetailz, Staggazing River a;Mt7cs Am Brook M'*'....-'�..' ?blmvr;;`,SiiffrQnq iSilver,�Teleseo ei tags site SifO R red
1114/01 128 Rios+MPLP, TI G green
5/23/01 120 1 Rros;;MPLP TI Y yellow
10/2/01 132 4 G Pos, MPLP. TI O orange
10/9/01 41 121 Y'ros,N TI = P ink
11/6/01 52 122 6 Y,ros N TI .Ta 1 ocatton '
2/8/021 51 113 4 Q,Aw MPLP TI*' ANT anterior dorsal fin
2/15102 43 107 18 O ANT MPLP TI* I POS 1posterior dorsal fin
3115/02 145 31 OlmT MPLP. TI
4/26/02 116 FB Ti ;IttvenSoacce "'" '
5/21/02 157 56 O ANT MPLP TI-- CC I Cosby Creek
5/28/02 136 116 O ANT'MPLP TI FB 117rench Broad
6/25/02 1 68 " FB TI I LC ILittle Chucky Creek
8/28/02 28 86 9 P ANT N TI LRCB Little River Coulters Br
10/23/02 126 6 P iurr. MPLP TI LRT Little River,Townsend
3/13/03 61 1151 5 2 1 RANT MPLP, TT* MPLP Mid Prong,LPigeon
4/3/03 42 841 29 R wT, MPLp TI:* N Nolichucky
5/30/03 163 ;FI3 TI UPR Up Pigeon,RM 64.5
6/3/03 20 64 R wr MPLP TI* WC Wilhite Creek
7/21/03 14 5 5 2 R mT LRCB TI
7/28/03 1 48 10 LRT, ITI.
8/15/03 5 66 1 IRANT'WC "TI*
_'Release;Site"s;a1'N `
8/21/03 237 108 LRT TI TI Tannery Island
8/26/03 23 FI3 TI UPD Up Denton,RM 17.5
9/26/03 192 121 LRT. TI
10/14/03 27 141 4 IG ANT,MPLP` TI-*,_ ":Release Sites;NC` _:
10/28/03 12 11 188 28 JG-AW MPLP' TI* FBR Ferguson Br,Riverside
2/20/04 211 O Pos!LC' MMB GC Golf Course,RM 52.5
3/11/04 171 78 UPR FBR
3/30/04 167 2751 CC FBR
4/16/041 19 54 42 10 Fos MPLP TT*
4/30/04 174 1y1PLP; TT
5/12/04 194 FB TI
8/13/04 72 97 LRT _' TT
8120/04 102 FB T1
8/25/04 318 666 CC FBR,
8/26/04 973 155 UPR ' FBR
9/22/04 14 70 5 Pros- 1%4pLp-- TI '
9/24/04 115 198 _; ;LRT: '.TI
10/22/04 112 1 1 IP,aos +MPLP TI,.
3/22/05 111 8 G ros_MPLF UPD
Totals 1126 334 1010 729 499 ' 0 677 .664 534 :1144 233 485 941 *eiuc me
Gilt `Bluet ers Blu�si8e3 Surpe ad'Stargazing River Mt 'Am Brook Mt Brook M uor Siiif ou uV i„T,el�scope; MNIB,
Minnow Chub 1Mi @Wml Lamprey

RE-INTF 'CED SPECIES: No;�'YE`Tags w _
couecrinn �' "`.�,i a� �„ �s*.� 4a.Minnow Chub ,hludtom; Lamprey Shmer""'t - 'Collect: ieleaSe',
�., ,., .. ,r •
dates axh. .Bliirbi;C2sf 'Bluesxa ?^Strlpetai Stargazing River # Mt,a Am Brook Mt sroox `a 'or„ ,$TffiVns SSdyolr` eloscope};ka s , site-. ., site ? R Ied
Pg 1 TTI'- :-1126 334 -1010 . 729° -499 A 677 '4'"664 , , 534. 1144 -2331 485 9,41 r`� � �� a G green
3/30/05 312 505 C,C. FBR Y yellow
3/31/OS 39 R;ros:, BC GC O orange
4111105 20 Wins MR" t' GC P pink
4/26/05 114 2 52 6 WIT', TLUP
Zvi E'Ca ix,OcaL WKI
ANT anterior dorsal fin
POS 1posterior dorsal fin
`7Rauer;So"eicq
CC Cosby Creek
' BC Boylston Creek,NC
FB lFrenchBroad
LC Little Chucky Creek
LRCB Little River Coulters Br
LRT Little River;Townsend
_..... - __ ..I MPLP Mid Prong,L Pigeon
MR Mills River,NC
- N Nolichucky
UPR Up Pigeon,RM 64.5
WC Wilhite Creek
17
Sitiesm
TI ITannery Island
UPD jUp Denton,RM I
to . 'lteleaS .Sites`r*'NC
FBR Ferguson Br,Riverside
GC Golf Course,RM 52.5
Totals 1299 334 . 4010 '731`'.. 551 6 F• AV ; 664 "534 '1144 z.233 797.S;. ,1496
GilC' 156&gst%B1u"'"'esi7 Stnpetaiti Stargazing River Mt*s.'"-�''s*,K Am amok Mt Brook 1VIm""am",Sal'fi"oa"" Save Tel cgp`e^
Minnow Chub 1S1'adedi 'Lamprey

canton KIM Sewers
C a �oT, Canducfivky, Haw and Hoher Loss
t Plan -_
Overview 'Mill Sewers Hill Filter „ Erco Flows - Color - Fiber
Chemical Storage 0 6130102 10.46:04 AM
0.42 MGD
I FIL 4.61 MLbs Color Eo F
____. MGD19 PM
Fill Rile Bark Depoly 4.60 To Fiber
y leach 5.68 Mlbs Color D-1
Ctlg Boiler Broke Plant
1.57 MGD #20 PM
i' 3.75 Tons Fiber
#2 Fiberline D
i a
I
i' �, s G 1.9 Delta T
- }� ,dJ= a1 A.rs"i E 20.8 River Temperature
T #1 FIL
E Brown
N, 0.27 Tons Fiber RL Stock #14 PM Area
S Washing
tr a 1.SA l WBL
MGD �#11 R8 k Evaps Power y2P #t2 PM
i Power BoilersBoiler MJ
#10 RB MGD
2 a
r,•� � a x� }J #11 PM
Kilns 1.61 Tons Fiber
Sysle s Off 2.53 Tons Fiber
1.44 MLbs Color 4.08 MGD J
Re Elul _ 2291 Color @ TN
4.00 � 7.04 DA. C) F.vl
MGDP HW 5.30
Caust y, Screen Tons Fiber a­0 0
---
Room { 20.30 ons Fiber
1.48 MGD
29879 WTP 8 _27745 #Color z?�
25.82 MGD Mill f ,: ^� �ii luai t°°la°a LciiL
(Yesterday) i 3. , �1 4 Turbidity #Color 7256
17.24 MGD River Flow _ Y am- #/DayTSS 26.27 MGD

4• ,.,
i` .� _
r'
�• ... rq
1 4
..

Color Removal Technology Assessment for Chloride Removal Process (CRP) Purge Stream - March 2005
Blue Ridge Paper Products
NPDES Permit No. NC0000272
Permit-Specified Technologies Other Technologies
Commercial Coagulation/ Solidification for Land Bleaching-Clozone Bleaching-Chlorine CRP on Lime Precoat
Technology Land Application Incineration Precipitation Disposal (C102&03) Dioxide(CI02) Filter Other
EVALUATION Literature review and Commercial quote for off Bench scale treatability Commercial quotes for Engineering estimate for Bench scale&field trials Series of field trials Short duration field trails Third party evaluations
METHODS engineering calculations site incineration study of lime,aluminum off-site solidification and on-site evaporation and quotes for
salts, iron salts and land disposal equipment to solidify the proprietary treatment
polyamine CRP purge stream technologies including
wet air oxidation,
activated carbon,filter
paper solids separation,
catalyzed oxidation and
ultra filtration.
TECHNICAL& Not an appropriate Not an appropriate Infeasible technology- Infeasible technology Infeasible technology Infeasible technology- Infeasible technology- Unproven technology- Proprietary technologies
OPERATIONAL technology due to high technology due to high low to moderate color due to large operating due to high operating consistent bleaching consistent bleaching wide variation in color evaluated were not
FEASIBILITY chlorides in CRP purge chlorides and dissolved removal with large expense associated with and capital cost. performance difficult to performance difficult to removal. Needs more effective or not
stream. salts in CRP purge sludge generation. off-site hauling and maintain. CI02 alone is maintain. Operating work to confirm commercially viable for
stream. Potential for effluent treatment. equally effective problems with off- feasibility. color removal from the
toxicity. bleaching agent for CRP gassing and foam. CRP purge stream.
pure stream.
ESTIMATED ANNUAL NA >$25 million >$370 k >$3.6 million >$2.1 million >$615 k >$145k Undetermined NA
OPERATING COST
ESTIMATED CAPITAL NA >$150 k for tank truck >$1.7 million >$150 k for tank truck > 11.1 million >$1.8 million >$1.2 million Undetermined NA
COST loading facility loading facility
POTENTIAL FOR
SECONDARY The contribution of CRP color to secondary effluent color is small and less than the normal variation in day to day secondary color measurements. There is no certainty that color removal in the CRP purge stream will result in an equivalent
EFFLUENT COLOR secondary effluent color reduction.
EVALUATION NOTES NA Potential to remove all High chloride content of Potential to remove all Ruled out as option in Inconsistent color Inconsistent color High chlorides in CRP NA
CRP color from mill. CRP purge stream may CRP color from mill. 2001 Color Removal removal performance removal performance purge stream may
CRP purge stream require special materials CRP purge stream Technology Assessment during trial. Operating during trial. Process corrode mud filters and
handling without and higher equipment handling without Report. problems with off- control strategy for full other equipment.
crystallization and cost. No indication that crystallization and gassing and foam. scale system is not Special materials of
plugging during truck color removal in CRP plugging during truck Process control strategy defined. Operating cost construction may be
loading and purge stream will result loading and for full scale system is assumes on-site bulk required. Need to
transportation will be in equivalent secondary transportation will be not defined. Operating CI02 supply. No evaluate effect of CRP
difficult. May require effluent color reduction. difficult. May require cost is power and indication that color filtrate recycling back
dilution and add to cost. Polyamine can adversely dilution and add to cost. chemical reagents. No removal in CRP purge into process. Precoat
Requires at least 3 effect secondary effluent Requires at least 3 indication that color stream resulted in filter does not operate
tanker trucks per day. toxicity. tanker trucks per day. removal in CRP purge equivalent secondary continuously. Impacts
Requires heated storage Requires heated storage stream resulted in effluent color reduction. on landfill leachate and
tank and truck loading tank and truck loading equivalent secondary potential for color return
facility. facility. effluent color reduction. to mill not known.
CONCLUSION
TECHNICALLY,
ECONOMICALLY AND NO NO NO NO NO NO NO Undetermined NO
OPERATIONALLY
FEASIBLE ?
2005 CRP Report Summary Final.xls, Report Summary 11x17, Rev 4- Final Page 1 of 1 Printed 5/18/2006

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ATTACIE"ENT II
NOTE: The legal boundaries of the
II I / /,11 j ` _ / '( \• rt n C Iv r. •h, I O \ �o? O I facility are shown on Attachment III.
1
II 1137_-e � � ( I II Imo' �� ,. t �� f � `I..• � IL /i .
.I•: esj7 � � i,(N aCr l,. •�" � .. 4:.`,a ,� �_�e r�o0 �� ©wijl S;.S�1!
Pa• .0 YT 7 `� � 'r1,3"f .II 1 .,. C - ) �.Q\\l\ �� � �� /�.�� ///��71�,/,,
.III � h TT`' •�: .�/ lT o o I _ � � (�)��-. �) ��-
II ri• � Sm•• N O • • IvIII;L S`a., a r 4 •� � xftj/ �_�,+�i •-•`rl
P •i t ® ,�� I' etlli ri e % '/. 8 3. \ i�50
J u� _� � 3 in gt••� � ;� G1J fl e•/� .III .SIP � .�>� ti-1i � � 4� `�'J � 'p 0 R
o I Io Off!/ � � � t�P ania Ave � t c� .�.� .1 ���•\\`�I io f
O' I h .•� � IFlltl .r .I ."r7• __ _ ��J / _� �ol
e� _
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�/J� ( 1 •• J
-� -i .\ Via\ ��L//.�7 •',� ,\ 1977 \ �� • .1 \� . � ` .//.�/, o•� ..{ /. ! `l icE_ NORTH
O 1 :\ p• 1) T��I� �� j` I oo / O _J l: 2000 1000 0 2000
SCALE IN FEET
,`r •O$ G C r ��, % I I I >��y y - 1 500 200 0 500
SCALE IN METERS
• ° 7 `.� o ,.1 '�••P,•• EO �5• j/ 161M5 _ 0.` .o '.,y - .� �.��•
SOURCE:
f a
Base map adapted from USGS 7.5 minute senas quadrangle(1:24,000)
PR39�5, �: n ov . h \(n° 'lo ���\ // •��` / �s/o --`/`. moo '-`� (\ �: o` - ( 'G Canton,NC(1990).
I \ � - o • , `�• I".
r
6eo lJ 6 _ • ' 60�`� �' _•„- f l BLUE RIDGE PAPER PRODUCTS,INC.
HAYWOOD COUNTY
o � k h.» ° •e -/I.% ; \r o ' F;t CANTON,NC MILL
'wo Poem ial h S ..p �t
_
_ _ e I''PI[�wO vJ\i '..��•1v .Ee t nPi' nOn3 .: N t` i
I ��Y�/ +'%m-. � , � �'-qi� Ji�'� j .. ..nc i� I I� .� ,'�• 858 n. .�� �� 0
Location Map
NPDES Permit No.NC0000272
)
�,;-1 �• a f -�ii I ,���.;AllZlv�J�i tl 11 ..,� .

1 2 3 4 5 6 7 8 9 10 ; 11 12 13
K BY-PASS WASTE MIXED LIOUOR K
r-------
NUTRIENT FEED
I
H2SO4 PH CONTROL NH40H H3PO4 � r ------rt -----------
( BACK-UP ) AB OR AERATION
DIGESTER If BASIN j
J i 2. 3 MG i 3.4 MG i
' POLYMER ADDITION
AB OR
54.82 i D2G3SMGR A BASIN N i FOR TSS CONTROL
3. 4 MG i
Ii 1---------- ----------� I
INTERMITTENT ADDITION
AERATION BASIN
PRIMARY EFFLUENT i OF CACO 20 SURFACE AERATORS
i
0 INJECTION INTERMITTENT
2 SULFIDE CONTROL
H ad* i H
i
i *4
CLARIFIER
200' DIAMETER 11. 48
*3 0 SLUDGE D i 2.82 DILLI M ON
CLARIFIER
G 15.5 200' DIAMETER GALLONS 0
14. 75 DEEP i w
3.47 MILLION 1-f
GALLONS �� i "-
_____RECYCLE_SLUDGE Cow
------- -
l�� 23. 92
OUR
F `� _ PRIMARY SLUDGE
ARUSFANDRITZ �� z F
�---- 0.6 ---- BELT PRESSES i �
05
2 20012AD CLARIFIER
TER 11.48 w
E CLARIFIER i FLOW i 2. 82 MILLION � E
i GALLONS
15.5 200 DIAMETER SPLITTING 0
14. 75' DEEP i STATION i o
3. 47
GALLONSION i w
N OXYGEN
D e ❑
COZPH
CONTR0 ��� CLARIFIER FLUME
REAERATION \ 150' DIAMETE
* 1 CASCADE 14' DEEP
C CLARIFIER 1.85 MILLION
125' DIAMETER �' LOW z GALLONS 6.22 C
11' DEEP LIFT ¢w GRIT FINAL
1.01 MILLION PUMPS mw CHAMBER EFFLLUEENT
GALLONS u
B SPILLLLY OUR FOR FLOW COMPLIANCE
COLLECTION •. B
�; urt xvvmr u.. GRAVING TITLE
MILL 29. 0 CITY WWTP - FLOW DIAGRAM
WASTEWATER SEWER BLUE RIDGE PAPER PRODUCTS
NOTE$ 0.9
- CANTON MILL
1 . ALL FLOWS AT DESIGN RATES IN M6D
A MILL WIIIFERINO wnaR.xmrn Glbl.11q 1pOES pEFll[T N0.
NC0000272
c OB L. GONTEPoRTO ORTE B2-05-01
'- cu. ,� M[LL ORNYINO NUMBER
- F- 107A-526
1 2 3 4 5 6 7 8 9 10 11 ' 12 13

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